By complying with all relevant safety, health and environmental management (SHE) legislation and international obligations, the group is committed to consult with stakeholders, achieve high standards of environmental performance, and implement internationally-accepted standards for occupational health, safety and environmental management. Kumba aims to continuously improve safety, health and environmental performance and SHE management systems in all operations as an integral part of our commitment to sustainable development.

Overall responsibility for SHE monitoring and performance rests with the Kumba board, exercised through the SHE committee and consulting forums at corporate level and at each division.

At Kumba, SHE covers all operational aspects and activities with the potential to affect the safety and health of people and the environment. This duty of care covers the entire life cycle of our operations, from exploration and planning to operation, closure, decommissioning, remediation and rehabilitation and post-closure care that focuses mainly on ensuring that environmental sustainability is achieved.

The SHE policy and management standards have been developed in consultation with relevant stakeholders and are mandatory for all Kumba operations. The objectives are to:

• Provide a risk-based SHE management framework, consistent with national legislation, the Kumba SHE policy, ISO 14001, OHSAS 18001, and other internationally-recognised standards that support the implementation of SHE best practice across all Kumba operations
• Provide a Kumba-wide framework to effect SHE legal compliance
• Set out and formalise expectations for the progressive development and implementation of more specific and detailed SHE management systems at all levels of Kumba operations
• Provide performance criteria against which SHE management systems across Kumba can be measured
• Provide a basis from which to drive SHE continuous improvement
• Integrate SHE elements into all relevant existing Kumba policies and practices.

The SHE management process is driven to a large extent by well-established risk management principles. Processes and working areas are broken down into units, where baseline risk assessments are followed by issue-based risk assessments. All operational teams are trained in applying risk assessment on new projects and tasks. Control measures to reduce risk are implemented systematically according to the following risk parameters:

• Engineering design
• Engineering control and SHE systems
• Early warning systems
• Administrative control (eg procedures, training and inspections)
• General protective mechanisms and processes.

OHSAS 18001 AND ISO 14001 CERTIFICATION
We planned to have all our operating business units certified for ISO/OHSAS management systems (ie to OHSAS 18001 and ISO 14001 standards) by 31 December 2004 (Table 1). The operations which did not meet this target are well positioned to achieve accreditation in the 2005 financial year. The status of certifications at the end of the reporting period is tabled overleaf.

Grootegeluk is one of the operations to have achieved OHSAS 18001 and ISO 14001 certification. Here Grootegeluk’s safety officer SHEQ, Dave Reyneke, and head of quality management and SHEQ systems, Renier Swart, reflect on the achievement.

Table 1: OHSAS 18001 and ISO 14001 certification

To ensure a fully-integrated SHE risk management system, some of our business units went further to integrate the ISO/OHSAS management tools into a single system. In 2004, Tshikondeni and Ferrosilicon received integrated ISO/OHSAS certifications, demonstrating that their SHE management systems are devoid of duplication, resource wastage, fragmented solution options and decision-making.

SAFETY AND HEALTH
In health and safety management, the focus is on minimising major occupational risks in the work environment including:

• Self-propelled mobile equipment
• Fire and explosives
• Fall of ground
• Electricity and other sources of energy
• Human behaviour
• Noise exposure
• Airborne pollutant exposure
• Radiation and ventilation.

Occupational safety and health incidents and trends are reported to the relevant authorities in accordance with prescribed standards. The relevant indicators used are aligned with the industry initiative to achieve uniform parameters. All incidents are analysed monthly and bi-annually to determine the contributing factors and implement proactive measures to prevent further incidents. Lessons learned from incidents are shared throughout the group.

Legal assessment forms part of the ISO/OHSAS certification process and all divisions have a legal register. No legal action for non-compliance occurred over the review period.

Additionally, Kumba makes every effort to keep disabled employees in service, including accommodating them in alternative positions.

SAFETY TARGETS
The following safety targets have been set for the company for the 2005 financial year:

• Kumba aspires to a zero-injury rate at all its activities. Regrettably, two fatalities were reported for the 18-month period ended 31 December 2004 (both within 2004). While this is below the four fatalities recorded in the calendar year ended 31 December 2003, it is still regarded as unacceptable
• A 30% yearly improvement on the lost-day injury frequency rate (LDIFR) is applied. The new target for 2005 is 1,75.
  

DATA LIMITATIONS
The LDIFR is the total number of lost-day injuries multiplied by a million divided by the man-hours worked, including overtime and excluding sick leave or any other leave. Up to December 2004, sick leave and other leave were not fully accounted for, however, initiatives to address this by December 2005 are in place. The Kumba LDIFR for the 12 months ended 31 December 2004 is 2,54 and 2,35 for the 18 months ended 31 December 2004. New initiatives such as the introduction of I Care safety rules and the reduction of unsafe acts are being rolled out across all our operations.

HEALTH TARGETS
Health targets for 2004 were:

• The reduction in the number of new compensatable cases of occupational diseases
• The reduction in the number of employees exposed to noise over 85dB (A) per shift through engineering control measures.

No quantitative targets were set, however new targets will be reviewed in the context of new legislation and other industrial commitments to meet the following targets for future reporting periods:

• Air quality index of <1 for 80% of exposed employees by 2006
• Risk-based medical surveillance by December 2005
• By December 2008, 95% of all exposure measurement results below the occupational exposure limit for respirable crystalline silica of 0,1mg/m³
• After December 2013, using present diagnostic techniques, no new cases of silicosis will occur among previously-unexposed individuals
• After December 2008, the hearing conservation programmes implemented by industry must ensure that there is no deterioration in hearing greater than 10% among occupationally-exposed individuals
• By December 2013, the total noise emitted by all equipment installed in any workplace must not exceed a sound pressure level of 110dB (A) at any location in that workplace
• Monitoring of risk reduction and implementing proactive indicators by December 2005.

Occupational hygiene formed an integral part of our occupational health management programme to ensure that the work environment is conducive to high health standards. All the mandatory codes of practice in terms of the Mine Health and Safety Act (29 of 1996) were implemented. To increase employee awareness, computer-based training modules were developed for occupational health.

The high number of noise-induced hearing loss cases within Kumba is attributed to the following: training practitioners in identifying and reporting noise-induced hearing loss resulted in increased capacity to detect suspected cases; and changes in noise-induced hearing loss reporting legislation, in terms of the Compensation for Injuries and Diseases Act (No 130 of 1993) which required new baseline assessments of all employees who are exposed to noise (2001 – 2003) resulted in increased reporting of suspected cases.

				Other	Noise-
	Cardio-	Asbestos-	Coal dust	occupational	induced
	pulmonary	related	pneumo-	lung	hearing
	tuberculosis	disease	coniosis	diseases	loss	Silicosis	Total
Suspected cases
2004	4	2	5	2	28	0	42
July 2003 – December 2004	4	2	5	17	58	0	86
Accepted cases
2004	2	0	2	2	16	1	23
July 2003 – December 2004	3	0	2	5	22	1	33

ENVIRONMENTAL MANAGEMENT
In line with our commitment to give due consideration to the environment at all our activities, we updated our environmental management policy in acknowledgement of all stakeholders’ rights to an environment that is not harmful to their safety and well-being. The right of future generations to use the environment to their advantage is also considered during business planning cycles, including operational, decommissioning and closure phases. Kumba is committed to promoting good relationships and enhancing capacity in the local communities where we operate.

The highlight of the review period was the implementation of an electronic environmental management system to enable consolidation of environmental data and statistics on, among others, water consumption and environmental incidents.

The focus will be expanded to include air quality and biodiversity issues.

ENVIRONMENTAL MANAGEMENT SYSTEMS
Kumba’s proactive approach to environmental management is illustrated by the implementation of advanced systems which will facilitate, among others, incident management, corrective action, data collection, data analysis and reporting. This does not only allow us to measure and analyse environmental data and resource consumption for every division in line with national legislation and internationally-accepted norms, but also complements the ISO 14001 management system.

The benefits of electronic reporting include quicker response times – which reduce real risk and the quantum of damage – as well as sharing knowledge and producing verifiable data and statistics. The system has been installed at five divisions and will be implemented at the remainder in due course. This will enable us to establish baselines throughout the group during the new financial year and allow environmental performance to be compared year on year against internal targets as well as with best-practice standards.

ENVIRONMENTAL RISKS
Kumba is in the process of developing an integrated, enterprise-wide risk management programme.

Environmental management risks will also be evaluated via this systematic and repeatable methodology that will identify, analyse, assess and rank risks. The diversity of environmental

risks are thus treated according to international principles and integrated in the overall risk management system. The risk management tools are integrated into the environmental management module of the environmental management system to facilitate standardisation and ease of use across the group.

LAND MANAGEMENT
Land management data (as at 31 December 2004) has not changed since the previous reporting period. Environmental programme management reports (EMPRs) are being updated to be more in line with new legislative requirements.

ENVIRONMENTAL PERFORMANCE
Environmental management data collection focused on Kumba’s specific risk and performance issues, which are also compatible with GRI. The following data fields were selected as a starting point:

• Land controlled
• Land disturbed
• Land rehabilitated
• Electricity use
• Diesel use
• Water use
• Hazardous waste generated
• Number of environmental incidents.

Initiatives to empower the divisions to report on these issues started in 2002. Data is being collected on a monthly basis for these parameters. To convert these fields into useful environmental performance indicators (EPIs) according to the GRI, water, electricity and diesel use are divided by the tonnage of product produced for the reporting period. Kumba’s environmental management data cover

GRI elements EN 1, 3, 18, 23 and 29 and considerable progress has been made during 2004 regarding EN 6, 10, 13, 20, 21, 25 and 26 (emissions to air as well as ecology issues) on baseline information and monitoring programmes.

Special attention has been given to the quality of environmental data reporting since 2002.

Looking at the indicators produced for Kumba in total over this period, an improvement is apparent in the diesel use while electricity and water use indicators as well as the number of incidents show a decline in performance (see charts and tables). The former is as a result of savings optimisation while the latter indicate a large amount of under-reporting in the past. The suite of parameters will be systematically expanded during 2005 to include air quality monitoring issues and ecological management tracking via biodiversity action plans. Level 1 (minor) incidents generally indicate an upward trend, probably as a result of ISO 14001 implementation and related management support systems (Table 3).

REHABILITATION
Rehabilitation activities are implemented according to authority-approved plans.

A process was initiated to regularly report on the mining operations’ compliance to environmental management programme reports (EMPRs). Some mining operations have commenced with quantifying their authority-approved plans in such a way that the status of compliance could be properly measured for reporting. The first reporting will be during 2005.

Kentrige Makhanya inspects a rehabilitation test slope at Sishen.

At the Durnacol colliery in KwaZulu-Natal, major mine closure rehabilitation activities were completed during the review period, while at Hlobane colliery, closure rehabilitation is well advanced and an updated environmental management programme report was submitted to the authorities for approval. As part of an integrated water management plan, sealing of surface fractures to prevent clean water from entering old underground mine workings was so successful that the Hlobane waterfall, last seen with cascading water more than 50 years ago, is flowing again. Through these rehabilitation techniques, volumes of water decanting from the mine are decreased and downstream water quality is improved.

All mining operations have updated estimated final closure liabilities as well as immediate closure liabilities where applicable. Provision for the cost of closure and post-closure liabilities for all mines is managed through an independent rehabilitation trust fund and verified by an independent third party.

Table 3: Environmental incident statistics
	2004 INCIDENTS			2003 INCIDENTS
Business unit	Level 1	Level 2	Level 3	Level 1	Level 2	Level 3
Iron ore
Sishen	480	1	0	455	0	0
Thabazimbi	79	0	0	8	0	0
Coal
Grootegeluk	232	0	0	90	0	0
Tshikondeni	8	1	0	*	*	0
Leeuwpan	59	0	0	*	0	0
Heavy minerals
Ticor SA	119	24	0	101	21	0
Base metals
Zincor	125	0	0	126	6	0
Rosh Pinah	*	1	0	*	2	0
Industrial minerals
Glen Douglas	13	0	0	5	1	0
Total	1 115	27	0	785	30	0
* During 2003 most of the level 1 environmental incidents were grouped with general    housekeeping issues.
Type of incident		Brief description
Catastrophic (level 3)		Significant impact, extensive or long-term effect.
Reportable (level 2)		Moderate impact, medium-term effect, reportable to the relevant government authorities.
Other incidents (level 1)		Minor impacts, short-term effect
Table 4: Electricity, diesel consumption and water use per business unit: July 2003 to December 2004 (18 months)
	Electricity		Diesel	Water		Product
Business unit	(Gj)		(t)	(m3)		(kt)
Sishen	1 541 570		57 329	9 264 549		41 146
Thabazimbi	212 724		10 077	3 528 184		3 806
Grootegeluk	1 252 343		20 906	3 723 943		26 105
Leeuwpan	93 366		5 864	115 967		2 460
Tshikondeni	193 673		2 021	300 382		630
Ticor SA	2 041 074		2 883	9 486 250		772
Glen Douglas	66 014		2 443	4 585 051		2 107
Zincor (excluding sulphuric acid)	2 654 163		1 256	2 439 423		159
Rosh Pinah (zinc and lead concentrate)	228 159		1 769	1 727 348		223
Total	8 283 086		104 548	35 171 097		77 408