attachment no. c · with cadbury management. the determination of the significance of an...

1

. Attachment No. C.1

I

EHS Policy

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SECTION No. ENVIRONMENTAL MANAGEMENT

4 SYSTEM REQUIREMENTS

Cadbury Ireland Ltd. 1 ENVIRONMENTAL MANUAL

REVISION No. DATE PAGE 1.2

19-Apr-2006 3 of25

Environmental Policy

Cadburv Ireland Ltd (Coolick) is fullv committed to reducing the environmental impact of its

Operations and its activities. Cadbury Ireland Ltd (Coolock) will take steps to actively reduce any

threat to the environment through the operation of the EMS. Cadbury Ireland will incorporate the

Cadbury Schweppes GEM guidelines and the CS Environmental Health and Safety Policy.

Cadbury Ireland Ltd will implement and ensure the effective operation of the IS014001 system.

1.

2.

3.

4.

5.

6.

I!,

7.

8.

9.

10.

Ten Key Commitments.

Conduct our business in compliance with environmental health and safety laws and with our Global Standards, and regularly assess the compliance of our operations against these requirements. Maintain and continually improve systems to manage our EHS responsibilities, establishing and ensuring employee.

Set clear targets for continuous improvement in our EHS performance and monitor these targets to ensure that they are met.

Strive to prevent pollution and to minimize the environmental costs and impacts of our global operations.

Provide a safe and healthy environment for our employees, contractors and other visitors to our site.

Assess and eliminate or control the EHS risks of new and existing operations, and continually assess the environmental performance of our products, seeking ways to contribute positively to their performance.

Train and motivate our employees to understand their EHS responsibilities and to participate actively in our EHS programme.

Work with our supply chain and business partners to improve our collective EHS performance, to protect the ecosystems that provide our raw materials and to minimise the impacts of transportation. Communicate openly with our shareoweners, employees, customers and other interested parties by regularly reporting on our commitments and our EHS performance and maintaining an open dialogue.

Review and update this policy regularly. Originated By: Thomas Byrne.

Signature:

Approved By:

Signature:

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Register of Environmental Aspects

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Cadbury Ireland Ltd. Significant Aspects Register 2006

Revision Number .5

Title

Register of Significant Environmental Aspects.

Dublin Factory

Cadbury Ireland Ltd.

2006.

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Register of Significant Aspects in Order of Ranking.

1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 11. 1 lb. 12. 13. 14. 15.

Factory Energy Usage. Aqueous Discharges. Total Packaging / Solid Waste. Hazardous Materials. Occupational Exposure to Noise & Chemicals. Site Water Usage. No-Mould Water Usage. Use of Contractors. Cooling Towers & Legionella. Domestic Water Systems & Legionella. Emissions to Atmosphere. Supply Chain Activities Product / Packaging Design. Visual Impact of Site Hazardous Waste Environmental Noise.

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Tom Byrne Signed by Environmental Manager ._______________________________ Revision Number 5

Identification of Aspects and Ranking system.

The decision as to whether an aspect is significant or not lies solely with the Environmental Manager in consultation

with Cadbury management. The determination of the significance of an environmental aspect is based on simple risk

assessment methodology or failure mode and effect analysis

The Frequency of Occurrence of the aspect is denoted by the letter F and a numerical value between one (i.e. rare)

and ten (i.e. regularlconsistent, e.g. discharges) is assigned.

The Likelihood of Loss of Control is denoted by the letter L. A numerical value between one and ten is assigned, where a value of one indicates control loss is highly unlikely and a value of ten indicates control loss is highly likely.

The Severity of Consequences of each environmental aspect is denoted by the letter C and is assessed using the following decision making criteria: (1 .) to (vl): Legislative and Regulatory compliance Community/Employee sensitivity Impact on air, land or water Cost benefit reasons, e.g. insurance liability, strategic concern Potential for resource depletion Potential for an Accident to occur.

A score for Severity of Consequences (C) is calculated for each Aspect by assigning a score under each criterion in the following manner:

Legislative and Regulatory compliance: Not regulated I no legislative requirement Moderately regulated and compliant Strictly regulated / legislated and compliant Strictly regulated I legislated and occasionally non-compliant Strictly regulated I legislated and consistently non-compliant

Community I Employee Sensitivity: No observed reaction Sporadic complaints Widespread complaints Vigorous community I employee action Permanent injury or death caused

Impact on Air, Land and Water: No measurable impact on environmental media Local nuisance, e.g. odour, dust Short term adverse impact on environmental media e.g. fish kill Long term adverse impact on environmental media, Permanent damage to environmental media or ecosystem, e.g. irrevocable damage to potable groundwater sources.

Cost Benefit Reasons: Major financial saving to the company Minor financial saving to the company No financial cost to the company Minor financial cost to the company Major financial cost to the company

= 1 point = 2 points = 3 points = 4 points = 5 points

= 1 point = 2 points

= 4 points = 5 points

= 3 points

= 1 point

= 3 points = 4 points = 5 points

= 2 points


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. . Cadbury Ireland Ltd. Significant Aspects Register 2006

Revision Number 5

I I

Potential for Resource Depletion: No depletion of natural resources Some depletion of renewable natural resources, e.g. papedwater usage Some depletion of non-renewable natural resources e.g. gas, oil usage Large scale depletion of renewable natural resources Large scale depletion of non-renewable natural resources,

Potential for Accidents to take place: Very slight risk of having an accident. There is a chance of having a minor accident as a result of activity Risk of having an accident is real but will not result in a major incident The potential for having an accident which will require a full investigation and possibly lead to a claim or prosecution being made. Will result in emergency response with strong implications for the firm.


= 1 point = 2 points

= 4 points

= 5 points

= 3 points

The sum of the decision making criteria scores for each environmental aspect is deemed to be the numerical value for the C factor which represents the potential Severity of Consequences.

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Impact Number And Rank.


Environmental Impact Frequency Liklihood 1 Severity of I Of I Of Consequences

Revision Number 5

6

7

8

9

10

11

1 lb

12

13 14

15

Calculation of Significant Rating.

to noise and chemicals

Site Water Usage 10 9 4 3 4 4 4 1

No - Mould Water 10 7 4 5 4 5 4 1 Usage Use of Contractors 10 7 4 2 4 5 4 3

Cooling Towers & 10 5 2 5 4 5 3 5 Legionella Domestic Water Systems 10 5 4 2 3 5 4 4 and Legionella

Emissions to 10 6 5 1 1 5 5 1 Atmosphere

Supply Chain Activities 10 6 4 4 4 3 2 1

Product - packaging 7 5 3 3 3 5 5 1

Visual Impact of Site 10 3 2 3 4 4 3 2 Hazardous Waste 7 3 3 2 4 5 3 3

Environmental Noise 4 3 2 2 1 2 1 1

Design

Occurance Control Loss. C = Sum of Criteria.

Significance

2070

1960

1800

1610

1260

1200

1100

1080

1080

--1

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Cadbury Ireland Ltd. Significant Aspects Register 2006 I

1 Revision Number 5

I I

Environmental Aspect No. 1 Activity:

Energy 1 .O The main energy sources used by Cadbury Ireland are Electricity, Gas, Oil and

water. The total energy consumed by Cadbury Ireland Ltd in 2005 was 57.8 Gwh based on the total consumption of Gas and Electricity. Energy and water is measured weekly and reported by the environmental manager in the environmental files records every four weeks. There is now an automatic update file for electricity and gas, the records are kept on a computer database for each area such as “A”,”B”, “C” and K Block and site services. The figures are compared to the previous years in terms of total Kwh per ton output and charts are updated accordingly. These charts and data are made available to the appropriate stakeholders as deemed necessary by the environmental manager. All of these records are kept on lotus123 and Excel files. Actions to reduce power wastage and water conservation are identified in the management objectives manual, which is based on the aspects as identified in this register. There was an energy audit carried out in 2002 the first since the Niffes report of 1997 and the breakdown of energy consumption as identified in that report has been completed. However the new energy audit conducted in 2002 has outlined a new strategy to save 1 % per annum. A new Carbon Tax was introduced in Ireland at the end of 2004 which will add extra cost to our energy bill. We will continue to engage with S.E.I. through in 2006 to find ways to reduce the impact of this tax.

1.1 Oil Supply. Oil is supplied to site as required and it is delivered directly to the main storage tank located beside the boiler house. Both boilers are now running on Natural Gas and there is still a facility to run the boilers on oil if the need arises. The boilers will be fired on oil every month to ensure their availability when the need arises and a record will be kept in the boiler-house log. Little oil was used or consumed in 2003 and this will be repeated in 2005.

1.2 Water Supply. Mains water is supplied to Cadbury Ireland by Dublin City Council and it is charged at € 0.789 per M3. Water is used in some of our processes such as

Caramel Making, Crkme making and washings of moulds and floors etc. It is also used for heating systems and for cooling towers make-up. DCC carried out a mass balance use of water on the Cadbury site during 2002 and the results show areas where savings can be made. The report is kept by the environmental manager and its findings will be included in the management programme for 2003 to 2006.

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-. .


Revision Number 5

IEvaluation Of Impacts. Energy and water is considered the first most significant impact under the following headings.

Aspect :

Energy usage relates directly to the burning of fossil fuels and the depletion of natural resources

Associated Impacts

Air pollution, land and water pollution as a result of spent fossil fuels and leaking condensate lines.

Frequency, F

Energy is used daily, 365 days of the year in the factory.

Likelihood of Loss of Control, L

There is the possibility of loss of control of energy usage especially at weekends when plant and machinery is left running when there is no production. This is evident from the amount of energy consumed in the plant, there are often two or more air compressors running to keep up with leakage demand.

Severity of Consequences, C ~

Legislative and Regulatory Control

There is currently no legislation governing the us of energy within the European Union. Save 11, is the most recent EU non technical program aimed at promoting the rational use of :nergy within the community. Implications for Cadbury Ireland is that it is a voluntary program !n which companies may participate in if they wish. A summary of the SAVE program is included n the Legal register, section 7 pages 2 to 4. A C02 tax will be introduced in 2004.

Community/Employee Sensitivity

411 of the energy sources being used by Cadbury Ireland Ltd are being used throughout the :ommunity and would not generate any great concern amongst employees or the local community. lowever under commitment 3 in the Cadburv Schwemes GEM we are to “adapt programs to :nsure efficient use of raw materials and natural resources across all segments of our business and o minimize the quantify of waste pollutants associated with our activities. In 2001 John Brock issued in instruction to all CS business units to save 1% energy per annum over a 10 year period.

F = 10

L = 10

5

3

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Tom Byrne

The use of electricity, oil and gas results in the generation of smoke, C02, CO, Nox, and S02. which cause the following negative impacts on air. 0 Smoke Visibility Impairment.

CO Air Quality. Nox & SO2 - Acid Rain

0 CO2 -Greenhouse Gas. For steam generation Cadbury Ireland Ltd is using natural gas which is a clean and convenient fuel. Both Boilers are now hlly automated and are controlled by Hamworthy controls for better efficiency.

Cost Benefits

Excessive usage and waste of these resources will result in increased costs to Cadbury Ireland Ltd. Electricity usage in 2002 cost the company €16 102 18, and gas usage cost €8053 18- A one percent saving in each of these fuels would save the company E24 155- per annum based on current costs.

Potential for Resource Depletion

.There is a substantial usage of oil, natural gas and other natural resources used in the generation of power and heat. Therefore it is important that these be used efficiently and only as required.

Accidents and Emergency.

Not a major issue with this aspect.

Sum (i) + (ii) + (iii) + (iv) + (v) + (vi) = Severity of Consequences Score, C

Significance Ratings S = F x L x C

5

5

5

3

C = 26

S = 2600

Management of this activity by:

Objective

Procedure(s):

Monitoring &

Measurement:

To reduce energy usage by 1% in 2003

EP 17.01 & EP 09.01, EP.07.01

In accordance with procedure EP09.01

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.~ ..... ... .

'1 . ,.,

Cadbury Ireland Ltd. Significant Aspects Register 2006 I Revision Number 5

I

Environmental Aspect No. 2 Aqueous Discharges Activity

The factory uses a lot of water for washing & cleaning plant on an ongoing basis, we have been issued with a

licence from Dublin City Council and we must remain within the set parameters.

Aspect

Process and washdown water from various parts of the factory enters the foul waste drains and is routed through the

monitoring stations located at the Cocoa Blocks. The only treatment carried out on the effluent is within the various

grease traps. Bacteria is fed into the traps on a daily basis and air is pumped to help the bugs to live and to operate at

optimal efficiency. This treatment helps with Ph correction and the reduction of the loads within the traps. Two of the

plants which place most of the load on the traps are Eclairs and Boost which cook caramel.

Associated Impacts

DCC are particularly sensitive with regards to Ph being below 6 and above 10 our licence limits and have instructed us

to correct the levels. Large amounts of water lead to higher effluent treatment charges and wastage associated with it.

Frequency, F

Water is used on an ongoing basis and the frequency is awarded a factor of ten.


Untreated effluent leaves the plants especially when there are wash-downs and during CIPs. The effluent

will pass through a grease trap on the line of discharge and then through one of the two monitors. The

ikely-hood of loss of control; can be quite high as there is a high dependence upon the operators not to

lump product in tanks etc. Since operators have not had any training yet there is a hgher likelihood of

kgitive emissions.

Severity of Consequences, C


Discharges must comply with the parameters as laid down ing the eMuent discharge licence.

Dublin City Council (Water Pollution) Acts 1997 and 1990.

L = 9

5

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Procedure(s):


Records are kept by the Environmental Manager and are returned to the DCC offices where they are kept

on file. The public office files are open to the public and can be viewed on request, adverse publicity

could result if we exceed our licence levels.

EP.27.01

Impact on Air, Land and Water

Excessive levels of effluent will result in fines or prosecution.

Cost Benefits

Prevention of loss to the drains will save significant levels of money.


There is the potential for losses of water, ingredients, energy and detergents during wash-downs.

Accidents and Emergency

No significant danger of accidents.




4

5

5

5

2

C =26

3= 2340

I

Monitoring &

Measurement: I

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I 1 Cadbury Ireland Ltd. Significant Aspects Register 2006

Revision Number 5

Environmental Aspect No. 3 Total Packaging Waste / Solid Waste. Activity

Total Packaging Waste.

Description : Packaging and Solid waste arises as a result of the activities in the Coolock Factory.

Seven hundred and eighty tons are generated which have to be handled and dealt with.

Aspect Packaging waste is a particularly sensitive issue in Ireland at present and landfill sites are being

reduced in number which is resulting in increased costs. The Waste management act 1996 is rigorously

implemented and pursued by the authorities. The main packaging generated on site are, Cardboard, Plastic,

Timber, Metal, Glass etc.

Associated Impacts

Litter nuisance has a high visual impact on the public and can result in complaints from the local authorities etc.

~~ ~ ~

Frequency, F

Waste is generated at about 55 tons per week including packaging waste, canteen waste, shell waste

md animal feed. Packaging waste is segregated in the new recycle centre etc.


Solid waste is collected by a number of licensed contractors and transported to the various waste

outlets. There is always the possibility of spillage which could result in a non compliance complain1

etc.



The waste management act 1996, the litter act 1997 and all of the instruments place the onus on the

producer to comply fully with laws. To reduce the likelihood of a prosecution in this regard,

Cadbury Ireland carry out an audit of the various contractors annually


b y litter spills associated with the handling, removal and transport of packaging waste from site

md during all of the process stages, segregation etc could generate a nuisance for all of our

;takeholders.


,caking landfills could lead to leaching of toxins and other pollutants etc. Most of the

Jadbury waste being sent to landfill consists of Oven Dross, and canteen waste, everything

L = 9

4

4

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Revision Number 5 I -

elselis being recycled.

Cost Benefits

The handling, segregation and processing of waste is expensive business but landfilling is no longer

an option as costs are increasing at an alarming rate.

By segregating at source there are large savings to be made in hture against these rising costs.


With packaging waste there is a high likelihood of depleting resources due to the composition of the

materials and the use of special inks.


There is little chance of accidents in the use of packaging materials.



5

5

2

C = 24

S = 2160

Objective No.: 1 2 I

Procedure(s): I EP.28.01

Monitoring &

Measurement:

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Revision Number 5

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Environmental Aspect No. 4 Hazardous Materials. Activity

Hazardous materials are stored on site some of which are used during the production process, a full list of materials are kept by the laboratory manager and an MSDS register is also kept. A variety of laboratory chemicals are stored on site in small quantities, pesticides by the gardeners and some refrigeration gases are kept and used for product cooling purposes etc. .

Many of the chemicals used in the plant are classified as hazardous materials, and due care is required in handling these materials. Adequate facilities for the storage of these materials is in place and all hazardous materials are kept within the compound. Chem-store units were specifically purchased for the storage of hazardous materials and the keys for the units are located in the engineering stores, with security and the site services manager.

Associated Impacts

The proper storage of these materials is essential to ensure against accidents and fugitive emissions of these materials

which could pollute the river.

Hazardous materials are handled on a daily basis by stores staff and other operators across the factory. On this basis a score of nine has been awarded to this aspect


Without the proper bunded storage facility there is a strong likelihood that an accidental spillage can happen either by something being knocked over, or during emptying or filling containers Etc.

L = 9

Severity of Consequences, C Sub-Totals

Legislative and Regulatory 5

The dangerous substances act which relates to the storage on site and use by activities of dangerous

substances. Cadbury Ireland must take all practical steps to prevent risk of injury to persons or

property from such substances being stored, handled or transported on site. A comprehensive

summary of the relevant act and amendments is contained in the legal register.

Community/Employee Sensitivity 5

The incorrect handling, storage or treatment of hazardous materials could constitute an occupational Iealth and safety risk to employees. This could be manifested in inhalation, skin irritation, eye :ontact or as a carcinogen etc.

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Cost Benefits

An accident on site could result in an insurance liability and or prosecution by the Local Authority.


5

Any spillage of such materials would mainly arise under emergency conditions. Better storage and tighter control procedures are required to ensure against pollution to land, air & water.


4

3

Accidents and Emergency 3


Wective No.: 4 To ensure that all hazardous materials are stored safely in the Hazmat -

Procedure(s):

flonitoring &L

VIeasuremen t:

compound.

EP 15.01 & EP 16.01, EP.26.01

Weekly inspections.

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Environmental Aspect No. 5 Occupational Exposure to Noise and Chemicals. Activity

The main occupational exposure issues identified by the company in the safety statement as follows,

(1) Occupational Exposure to noise.

(1 1) Occupational Exposure to chemicals.

Aspect

Noise.

Areas within the factory have been identified with noise levels above 9OdE3, notices for the compulsory wearing of ear

protection have been posted.

Chemicals.

There are a number of areas within the factory where chemicals being used have an associated risk for example in the

Hazardous materials store.

Associated Impacts

Noise levels within the factory are being reduced systematically and on an ongoing basis, the introduction of head sets

with built in radios is one such example. Where chemicals are being used personal protective clothing is provided,

however training in the handling of these chemicals could be improved.

Score ~

Frequency, F I F = l O I Some staff are either exposed to constant noise or the handling of chemicals or detergents on a regular

basis.


Noise exposure is a greater risk than exposure to chemicals as chemicals are used in-frequently but the

background noise effect is continuous. Likelihood of loss of control is not a major concern due to the

procedures which are in place. Hearing tests are being carried out on all staff in 2006.

L = 7


Legislative and Regulatory Control 5

There is lots of legislation in place to cover the occupational hazard of being exposed to both noise and

chemicals.

CornrnunityEmployee Sensitivity

High noise levels are irritating to staff having to work in such areas and require regular monitoring to 5

ensure compliance with regulations. Any accidents concerning chemicals would also attract a wide

audience especially if there was a serious accident.


4ny chemical spills would give cause for concern, but chemicals are covered by procedures. 3

[nternal noise pollution does not attract any notice from the community at present.

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Cost Benefits

Good applied procedures could help offset costly litigation from persons affected in hearing or chemical

burns.

.~ Cadbury Ireland Ltd. Significant Aspects Register 2006

5

Revision Number 5


Any accidents arising out of chemical handling will result in at least an internal inquiry or if serious

enough from an external body such as the HSA.


5

C = 26

I



Chemical usage necessitates the use of valuable resources.

S = 690

1 3

Objective No.:

Procedure(s):

Monitoring &

Measurement:

EP.07.01, EP.lO.O1, EP.14.01, EP.15.01, EP.18.01, EP.19.01 EP.22.01 EP.26.01

Noise monitoring on an annual basis.

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Environmental Aspect No. 6 Site Water Usage. Activity : Water is used across the factory for domestic use cleaning in place, toilets, washing, Cooling towers make-up

and for the hot-well make up at the boiler house.

Aspect : The use of water whether hot or cold adds to the loading on the effluent discharges as well as adding cost to the

Utilities site-wide.

Associated Impacts

Hot water usage contributes to C02 emissions and will in fkture represent higher costs etc.

Frequency, F

Water is used every day on plants across the factory

Likelihood of loss of control, L

Water hoses are left knning frequently and sometimes there are fkgitive emissions from the plants.

Severity of Consequences, C Score I to 5 Legislative and Regulatory Control.

EMuent discharges are subject to the conditions attached to our effluent trade licence.

Community/Ernployee Sensitivity

All of our effluent results are sent to the offices of the Dublin City Council and can be inspected bj

members of the public if requested.


Polluted water has to be treated at the new facility at Ringsend Dublin by DCC at a cost to us, hot watei

uses energy and contributes to C02 pollution.

Cost Benefits :

All energy sources are expensive and this adds cost to the supply chain for the business.


Clean water is a precious resource and the effluent leads to waste of resources in the treatment chemicals

etc.


Hot water can bum peopfk or unlagged pipe associated with hot water can lead to an accident.



Score

1 to 10

F = 10

L = 9

Sub-Totals

4

3

4

4

4

1

c = 2 0 -

s = 1800


Objective No.: 1 5

Procedure(s): EP 17.0 1 Monitoring &

Measurement: As stated in procedure EP 17.01

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-

fironmental Aspect No. 7. No - Mould Water Usage rity

Water consumption within the No - Mould Plant is excessive and most of it goes to waste whilst it used to

maintain vacuum on the cooker.

Aspect

Water wastage on the scale of the eighty cubic meters per day is costly to the tune of €20000 per annum to buy

and another € 11200 per annum for treatment costs. The loading of this on the drains puts strain on the

interceptor to which we add bacteria for the correction of Ph.

Associated Impacts

Precious resource depletion and added cost to the facility.

Score

Frequency, F F = 10

Water is used each day the plant is run


If water being left running when the plant is stopped then this plant suffers from loss of control.

L = 7

I

(1) Severity of Consequences, C Sub-Totals


Little legislative control over this water as it runs to drain clear. 1 4 1 Community/Employee Sensitivity

Community is becoming more sensitive to waste water as it is expensive to prepare by the 5

authorities.


When the water is contaminated by the process then it can add to water pollution and treatment.

Waste water is expensive we pay for the water and we pay DCC for treating the waste water.

4

Cost Benefits

5


The potential for resource depletion is high even though it is a renewable resource. 4


There is little opportunity for accidents with the water as it is at supply temperature.

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Cadbury Ireland Ltd. Significant Aspects Register 2006 1

S = 1610

I I I 1

Sum (i) + (ii) + (iii) + (iv) + (v) + (vi) = Severity of Consequences Score, C I C = 2 3

Objective No.:

Procedure(s):

7

EP.27.01

Monitoring &

Measurement: Indications via the monitors on site.

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Tom Byrne

Activity

Use of Contractors.

Cadbury Ireland uses contractors on some of the new large projects and for general installations.

Aspect

There is a likelihood that any contractor can through accident or otherwise cause an environmental incident. There is

also the possibility that a contractor could introduce a prohibited material that could cause a pollution incident through

fugitive emissions etc.

Associated Impacts

Any fugitive emission could lead to an incident which could draw the company into a pollution incident etc.

Contractors attend the factory on a daily basis, they are frequently used in different functions.

Likelihood of Loss of Control, L L = 7

There is an average chance of the likelihood of the loss of control while using contractors.



Little chance of regulatory control as all contractors are briefed and indoctrinated on site conditions. I



Little or no impact here.

4

Any dumping of materials down drains could lead to water pollution.

Cost Benefits 5

Pollution could prove very costly.

Potential for Resource Depletion 4

Materials are frequently being used by contractors which does lead to the depletion of resources.

Accidents and Emergency 3

There is seldom accidents with contractors but there is always the possibility of one

Sum (i) + (ii) + (iii) + (iv) + (v) + (vi) = Severity of Consequences Score, C I c = 2 2 I

Significance Ratings S = F x L x C s = 1200

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Tom Byrne Signed by Environmental Manager .___-___________________________ Revision Number 5


Objective No.: 1 9

Procedure(s):

Monitoring &

Measurement:

EP. 13.01

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I

Environmental Aspect No. 9 Cooling Towers & Legionella. Activity

There are nine Cooling towers installed in the factory for supplying cooled water to refrigerant plants which

cool the product. Within each tower there is the potential for the growth of bacteria and other water based

bugs etc, these can grow out of control if they are not effectively maintained and treated.

Aspect : The possibility of Legionella outbreaks from the towers exist which could prove detrimental to stafi

and public health. This could result in the closure of the factory and lead to a major investigation by the

health authority in conjunction with the National Disease Surveillance Centre.

Associated Impacts

Bad publicity and possible close - down of the business could result from a outbreak of legionnaires disease.

Frequency, F

Cooling Towers are used all of the time processes are running, so the potential for problems exist at all

times.


There is a rigorous treatment and maintenance regime in place which reduces the chance of any

Legionella within the towers.



There is a new guide line which has only been put in place by the N.D. S.I. this guideline places the onus

on the operators and owners of such equipment to protect it against Legionaires Disease.

Community/Employee Sensitivity Community awareness of Legionella is low at present, but this will increase in time with the increased

reporting of such outbreaks.


Chemical dosing can cause pollution through spillage etc.

Cost Benefits

Treatment and maintenance of towers is expensive, but an outbreak would be disastrous and extremely

:ostly.


Both chemicals and water are used in cooling towers which are natural resources.

L = 5

2

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I

A

” -* Cadbury Ireland Ltd. Significant Aspects Register 2006

Tom Byrne Signed by Environmental Manager ._____-------------------------- Revision Number 5

xidents and Emergency

At present there is little potential for accidents from the towers or the chemicals being used.


5

C = 2 4

Significance Ratings S = F x L x C s =1200

Objective No.:

Procedure(s):

Monitoring &

Measurement:

6

EP 29.01, EP.26.01

Monthly testing for Bug count & four times per annum for Legionella.

Weekly testing by Lab for TVCs.

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Q I

The N.D.S.1 guide lines place the obligation on Cadbury to ensure that all risks are minimised or

eliminated.


Community awareness of Legionella in Ireland is low at present, but with the recent case in Waterford

resulting in a death it is likely to change.


He treatment of water to eliminate the risk of Legionella must be carried out under control;

t


4

2

3

Revision Number 5

rironmental Aspect No. 10 Domestic Water systems & Legionella Activity

Water systems are installed in almost every building and pre-fabs, systems which are fed by storage tanks

are particularly a t risk of harbouring Legionella in any of its forms. The systems feed shower heads are of

particular concern as it is these systems which contribute to a large proportion of outbreaks of Legionella

among the public.

Aspect.

Stagnant water covers a number of risk factors such as the build up of solids in the water as sludge. Legionella can

grow in sludge and can be harboured against disaffection unless it is conducted correctly. At risk are shower heads

which aerate the water into aerosol sprays etc. In this form unsuspecting persons especially the weak, very young or

old persons can catch Legionella. Almost 50% of all cases of Legionella are related to persons catching it whilst on

holidays, it is therefore essential to have a proper documented system in place to prove you have taken every

precaution to protect your staff and the public at large.

Associated Impacts

With the establishment of the National Disease Surveillance Centre in Ireland any outbreak within a 2 Mile radius of

the factory would tend to focus the attention of the national response team. It is a distinct possibility that they would

focus on factories firs and put the onus on the site to prove that they are not responsible for the outbreak.

Hot and cold water systems are used on a continuous basis, there is the potential for a problem at any time.


A contract exists between GE Betz and Cadbury for the sterilization and monitoring of these systems.

In-house maintenance of shower heads and showers is also being set up on a formal basis to help reduce

L = 5

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I Cost Benefits 5

A single death resulting from a Legionella outbreak would extinguish any treatment cost concerns.


Chemicals used for treatment and water usage are both valuable resources. 4

Accidents and Emergency I While good control and treatment of the towers is in progress there is little risk fir accidents. l 4 Sum (i) + (ii) + (iii) + (iv) + (v) + (vi) = Severity of Consequences Score, C c = 22

Significance Ratings S = F x L x C s= 1100


Objective No.:

Procedure(s): EP.29.01 Monitoring &

Measurement: Annual checks in place and annual sterilization.

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U

The boilers are used most of the year and burn fuel for malung steam, hot water or for keeping

jacketed lines warm. The main steam boilers run at 82% efficiency which is excellent based on their

age and size.

I

Environmental Aspect No. 1 1 Emissions to Athmosphere

F = 10

Activity

The principle emissions to atmosphere are combustion gases from boilers. These consist of:

@ I

1. The main boiler plant which houses two gas fired steam boilers which can be converted to run on oil,

should the need arise. Space Heaters for the factory, office block HWS boilers and a range of gas boilers

used to heat the various processes and jacketed pipe-work.


A close eye is kept on the energy usage at the Dublin Site. L = 6

Aspect

Both main boilers used for steam generation are within emission limit values as set out in T.A. Luft, the German Air

Quality Standard based on the last test carried out sa part of the Niffe audit.Both of our Steam Boilers are

fully automatic and are run on natural gas. Both of the steam generating boilers are within the TA Luft

standard and are running automatically. All of the gas boilers are run continuously and use natural gas.



Associated Impacts

The boilers emit flue gases such as Sox, Nox, CO2 etc. from the first of Jan 2005 Carbon tax will be applied to the

running of the Cadbury sites in Europe. Cadbury Ireland has obtained a permit but not the final emission level of CO2

This will not be finalised until mid Summer 2004.

~

Sub-Totals

5

Score

Frequency, F

The T.A. Luft quality air standard remains the standard for air monitoring from flue stacks.

New permits pursuant to the Directive 2003/87/EC applies in the pilot phase from Jan 2005.



To comply with the Kyoto agreement Cadbury Ireland will continue to reduce energy consumption .

" I I I

1

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Cosb Benefits I I ~~

Energy is continually rising in cost whether in Natural gas supply or electricity costs, any savings will

help our competitiveness. Once the new permit system is put in place any exceedences will result in

the purchase of Carbon Credits at the market price.

5


The use of natural gas and fossil fuels for the generation of energy results in the depletion of natural

resources. Energy conservation is essential to help in the reduction of this loss.


There is little risk associated with this aspect provided all safety procedures are adhered to at all times.


5

1

C = 18

Significance Ratings S = F x L x C . S = 1080

Objective No.:

Procedure(s):

Uonitoring &

Measurement:

1.

EP 17.01, EP.26.01

As per the procedure above.

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Revision Number 5

Suppliers are those companies, which supply goods or services to the company. The goods supplied include

processed foods, chemicals, fuels, packaging, lubricants etc.

Aspect : Services rendered include the means by which these companies execute their responsibilities including the

disposal of waste, transportation of goods and other aspects of the business.

Associated Impacts

The environmental impacts of companies engaged in the manufacture of raw materials which they supply to us are indirect impacts for Cadbury Ireland. Ongoing impacts can only _ _ _ be partially asskssed through regular (every 3 years) environmental questionnaires being sent to suppliers for completion.

The supply of materials to Cadbury Ireland is a daily event.

~ ~


Most of our suppliers have had initial approaches made regarding their environmental policies. On at

least two occasions we have been approached by local authorities concerning illegal dumping by these

suppliers.

L = 6

Severity of Consequences, C . Sub-Total:


This is now at a level of high priority with enforcement agencies and local authorities.

4

Community/Empioyee Sensitivity ' 4

At an all time high where litter pollution is concerned, heightened sensitivity due to fines and waste I charges being implemented. I

Impact on Air, Land and Water 4

Badly maintained transport, illegal dumping on land or in water could have a detrimental effect on

land air or water or a combination of these.

Cost Benefits 3

The cost of a pollution incident could be high, the associated adverse publicity could be higher.

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Q


All materials used have an effect on resource depletion.

2


Slight risk associated with the delivery and transport streams


1

s = 1080

I Sum (i) + (ii) + (iii) + (iv) + (v) + (vi) = Severity of Consequences Score, C I C = l 8

Objective No.:

Procedure(s):

Monitoring &

Measurement:

8

EP 15.01, EP 16.01

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Zommunity and employee sensitivities are high where waste is concerned and the transport of waste.

Waste has a big impact on the environment as mentioned in aspet 2 earlier in this manual.

I I

3

3

Environmental Aspect No. 12. Product Design. Activity: Product/ Packaging Design & Disposal.

New products and especially packaging are designed to enhance the sale of product from the factory. Th

selection of materials for these products can have an impact on the environment especially when it comes t

disposing of them.

Aspect

Food produce is normally manufactured for consumption and any waste is disposed through the animal feed chain.

Packaging and canteen waste is different and must be segregated for recycling or for land-filling.

Metal and machinery waste must be dealt with in a different way and must be channelled through the right stream fo

disposal. All new projects are reviewed under the GEM RAM review method for environmental impacts. (Guidelin

16, RAM Signoff)

Associated Impacts

Air, Water, Noise and Land pollution are all possible consequences of irresponsible handling of waste and indeed thi

running of new processes. Vigilance is required when designing a new product, process or packaging material, and th~

end of life of the materials must be taken into account at the design stages.

Score

Frequency, F I F = 7

New designs are reasonably frequent in Ireland and very frequent in Ireland.

Likelihood of Loss of Control, L L = 5

Loss of control is less likely than instances in the past due to the checks which are in place under the

guidelines of the GEM Manual.

I Severity of Consequences, C Sub-Totals


All aspects of new process design, waste materials, hazardous materials and their disposal are

legislated for and the controls are rigorous.

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Tom Byrne Signed by Environmental Manager ._______________________________ Revision Number 5

I

Cost Benefits

The better thought out the design the more cost effective the finished product, haste makes waste and

there is no waste only raw materials misplaced.


There is always a great potential for resource waste if the design of a process, product or packaging is

done in haste, or if it is not thought through fully.


There is no excuse these days for a hazardous process, or plant without all of the safety implications

being taken into account.



5

5

1

c = 20

Objective No.: 10

Procedure(s): EP 11.01

Monitoring &

Measurement:

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Revision Number 5

ironmental Aspect No. 13 Visual Impact.

The Cadburys plant at Coolock is maintained to a very high standard and blends into the surrounding area. It i!

company policy to incorporate all Cadbury plants in a garden type environment and the importance of this i:

imparted to new employees on induction. During construction extreme care was taken in both the selection of the

site and the colour schemes for the buildings so that facilities would fit as naturally as possible into its

environment. Extensive landscaping has been completed and the buildings and grounds are maintained to the

highest standards. Extensive planting on the perimeter of the site has helped to screen the developments. Muck

effort has been made to provide stable habitats for a variety of flora and fauna. The visual impact of the plan

enhances the environmental performance of Cadburys. Cadburys Dublin have received many awards ir

recognition of the excellent visual impact of the plant. The land surrounding the plant is zoned for industriai

development and is occupied by other industries.

Any spillages, paper litter or untidiness would draw the attention of the Dublin City Council which would result in an

inspection being carried out.

Associated Impacts

We could be prosecuted for litter nuisance or pollution to the Santry River either events could result from the site

being untidy and from spillages.

Score

Frequency, F

Materials are handled across the yard hourly and on a daily basis, there are opportunities for spillage F = 10

3r for accidents to happen.


Toss of control could happen if operators were not trained in environmental matters, 65% of all

3perators are still not trained.

L = 3

I

severity of Consequences, C Sub-Totals


Spillages, pollution to Rivers and litter nuisances are all comprehensively covered by legislation.

-c

2


Ater and river pollution draw the attention from both the employees and the public at large. 3

Impact on Air, Land and Water 4

rhere is a high impact associated with pollution, water pollution is prosecutable in the courts, litter

bollution is also high on the regulators agenda.

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Q


Tom Byrne Signed by Environmental Managef.2 .............................. Revision Number 5

C 1st Benefits

Clean ups and fines can run very expensive 4


Resource depletion from this aspect is generally low, unless you have a major disaster on your hands. 3

I I Accidents and Emergency

Low risk generally. I 2 l Sum (i) + (ii) + (iii) + (iv) + (v) + (vi) = Severity of Consequences Score, C c = 18


Objective No.:

Procedure(s): EP. 26.0 1

Monitoring & Weekly inspections. Measurement:

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1


Tom Byrne Revision Number 5

Activity

Sources

The main sources of hazardous waste are spent laboratory chemicals, fluorescent light

tubes and waste oil and deodoriser fats from the Cocoa Block.

Register of Impacts

Wastes are generally stored in controlled areas prior to movement off-site. Only licensed and approved

hazardous waste contractors are used to remove hazardous waste off site for recovery, reuse, recycling or

disposal. Waste chemicals from the laboratory mainly arise from the chemical oxygen demand test materials

which contains chromic, mercuric, chloride, silver, sulphate. A consignment note or C1 form for the

consignment of toxic and dangerous waste must be used when disposing of the material off site. Deodoriser

fats are collected in UN approved containers and stored safely prior to disposal. Shannon Environmental

Services or another licensed contractor takes this material once sufficient quantities have built up. Waste oil

from plant machinery, etc. is taken off-site by licensed waste disposal contractors for recycling Copies of

permits for the contractor are retained on file. Atlas Oil is the waste oil contractor used by Cadbury Ireland Ltd.

Detailed examination of all waste streams generated on site is necessary to confirm correct disposal methods

are being used in all cases.

Aspect

Hazardous Waste is a direct environmental impact of Cadburys and the environmental impact of waste is considered

under the following headings:

Waste Oils.

Deodoriser fats I contain impurities.

0 Chemical I toxic waste.

Spent containers.

f any of these were to be disposed of incorrectly there could be major implications, political as well as financial. There

ould also be adverse publicity as a result of improper disposal.

Lssociated Impacts

'ublic awareness of illegal dumping by waste contractors have added to the whole paradigm surrounding hazardous

vaste.

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Revision Number 5

Frequency, F

Hazardous waste materials are handled on a regular basis by trained operatives engineering stores staff such as waste oil, waste oil cloths, flourescent tubes, chemicals and waste detergents etc.


There is always the odd chance of a mishap when handling waste materials, especially oil based products.



Hazardous waste is generated from wastes due to the production activities in the factory and must be disposed of in accordance with the waste management act of 1996 translated into law in 1998. A summary of the relevant acts and instruments is shown on page 7 section 3, in the register of environmental legislation and a full outline of the various acts in pages 1 to 62 of the register. The register is in agreement with the Cadbury Gem Manual section, 1 1.1-5 to 1.1-9. Both of these registers are located with the environmental manager.


[ncorrect handling, treatment or storage of hazardous waste could lead to an occupational health md safety risk to employees such as inhalation of fumes or skin contact. This could lead to an zccident which could involve the H S A and possible litigation.


9n accidental discharge of hazardous waste at the site could have consequences for the quality of surface water discharged from site. This would be considered a pollution incident and would then :ome under the Water Pollution Act 1977. The implications for Cadbury Ireland Ltd is to ensure hat all pollutant matter is contained on site, including that arising from emergency situations, iccidents or spillage’s.

Cost Benefits

b accident involving the transportation of hazardous waste might involve an insurance liability, n addition the onus is on Cadbury Ireland Ltd to ensure that the waste contractor is operating in an ippropriate manner.

Score

F = 7

L = 3

Sub-Totals

3

2

4

5

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Potential for Resource Depletion. Where possible Cadbury lreland Ltd will recycle all recyclable hazardous in accordance wth the BATNEEC EU directive and in line with commitments 4&5 Cadbury Schweppes corporate environmental policy. Failure to so would result in a resource depletion and unnecessary use of raw materials such as solvents etc.


I Tight control in accordance with the relevant legislation is required to ensure against accidents.

Sum (i) + (ii) + (iii) + (iv) + (v) + (vi) = Severity of Consequences Score, C I c = 2 0

3

3

Significance Ratings S = F x L x C S = 420

' !

Objective No.:

Procedure(s):

Monitoring &

Measurement:

EP 19.01, EP.03.01,EP.07.01,EP.26.01

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- Act


-

ironmental Aspect No. 16 Environmental Noise. ity

Sources:

There are no external noise sources audible at the Plant boundary.

Register of Impacts:

Boundary noise levels were measured in Aug 2002 in accordance with IS0 1996. The

results are presented in the TMS report ref 001 16A Rev 0. Which is held by the

environmental manager.

Aspect

Sources:

There are no external noise sources audible at the Plant boundary.

Register of Impacts:

Boundary noise levels were measured on the gth Aug 2002 in accordance with IS0 1996

The results are presented in the TMS report ref 00116A Rev 0. Which is held by thc

environmental manager. Associated Impacts

A noise is liable to disturb people and provoke complaints when its level exceeds the pre-

existing ambient level by a certain margin or when it attains a particular absolute value.

People's reactions to noise may be influenced by factors such as:

(a) Noise level;

(b) Noise character;

(c) Habituation;

(d) Degree of control over the noise;

(e) Personal sensitivity to noise;

(0 Attitude to the source;

(g) State of personal health;

(h) Activity engaged in;

(i) Time of day or night;

0') Character of area;

(k) Visibility or otherwise of the noise source; and Seasonality of the operation.

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Revision Number 5

The area around the plant is an area with heavy road traffic and much local industry, both of whicl

would contribute to the ambient noise level, a further audit will be carried out in 2004.

Frequency, F

There is little background noise associated with the plant at the perimeter of the factory.


There is little likelihood of loss of control at present, vigilance with regard to the installation of new

plant must be maintained.



EU Directive 2004/49/EC the Assessment and Management of Environmental Noise.

EPA Act 11992(Noise) Regulations, 1994 (SI No.179 of 1994).


Community sensitivity can be acute especially were there a noise keeping them awake at night.


Not significant

Cost Benefits

Not significant


Not significant 1

Score

F = 4

L = 3

Sub-Total!

2

2

1

2

I


Deafness calaims could be significant


1

c=9

Significance Ratings S = F x L x% S= 108

Management of this activity by: Objective No.:

Procedure(s): I EP.06.01 Monitoring & 1 Every two to three years by an independent consultant, or in response to an Measurement: 1 enquiry fiom the EPA.

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Attachment No. C.3

EHS Manual

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Cadbury Ireland Ltd. ENVIRONMENTAL MANUAL

Originated By: Thomas Byrne. Approved By:

SECTION No.

4

I

MANAGEMENT

ENVIRONMENTAL REVISION DATE I PAGE I No. 1.2

1 19-Apr-2006 1 1 of25 1 I SYSTEM REQUIREMENTS

4.1 GENERAL REOUIREMENTS

I

management system in order to improve environmental performance. Improvements in this

environmental management system are intended to translate into improved environmental

performance. The requirements of the environmental management system are described

throughout this document. The environmental management system is to ensure that there is

continuous improvement and there will be close monitoring and reporting of the progress.

a

’ , i

Signature: Signature:

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1 Cadbury Ireland Ltd. 1 ENVIRONMENTAL MANUAL

I No* lm2

4.2 ENVIRONMENTAL POLICY

4.2.1 The management of Cadbury Ireland Ltd (Coolock). has adopted a policy of operating an

Environmental Management System which complies in every respect with the requirements

of I S 0 14001. It is corporate policy to continuously operate to this standard.

4.2.2 It is also corporate policy to use the management system to quality for certification to the

Q IS0 1400 1 standard.

4.2.3 Cadbury Ireland Ltd. will ensure that this policy statement is clearly understood,

implemented and maintained at all levels of the company, is not publicly available and is

applicable to all its activities and products and their associated environmental impacts.

4.2.4 Cadbury Ireland Ltd is committed to a policy of continual assessment and improvement of

it's environmental performance as measured by the quantified objectives and aims to reduce

impacts on the environment to levels corresponding to those which would arise fiom the

economically viable application for the best technology available.

@ 4.2.5 The management of the company will do all in its power to ensure adequate equipment,

personnel, training and facilities are available for creating, sustaining and improving quality

in the company's working environment.

4.2.6 The environmental policy statement is reproduced in the following page of this section. All

employees have been familiarised with the contents of the statement during training

sessions.

4.2:7 The Company is committed to the prevention of pollution.


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I Cadbury Ireland Ltd. J ENVIRONMENTAL MANUAL

I No. 1.2 I SECTION No. I ENVIRONMENTAL I REVISION DATE PAGE

Environmental Policv

Cadburv Ireland Ltd (Coolick) is fullv committed to reducing the environmental impact of its

Operations and its activities. Cadbury Ireland Ltd (Coolock) will take steps to actively reduce any

threat to the environment through the operation of the EMS. Cadbury Ireland will incorporate the

Cadbury Schweppes GEM guidelines and the CS Environmental Health and Safety Policy.

Cadbury Ireland Ltd will implement and ensure the effective operation of the IS014001 system.

Ten Key Commitments.

1. Conduct our business in compliance with environmental health and safety laws and with our Global Standards, and regularly assess the compliance of our operations against these requirements. Maintain and continually improve systems to manage our EHS responsibilities, establishing and ensuring employee.

2.

3. Set clear targets for continuous improvement in our EHS performance and monitor these targets to ensure that they are met.

4. Strive to prevent pollution and to minimize the environmental costs and impacts of our global operations.

5. Provide a safe and healthy environment for our employees, contractors and other visitors to our site.

6. Assess and eliminate or control the EHS risks of new and existing operations, and continually assess the environmental Performance of our products, seeking ways to contribute positively to their performance.

7. Train and motivate our employees to understand their EHS responsibilities and to participate actively in our EHS programme.

8. Work with our supply chain and business partners to improve our collective EHS performance, to protect the ecosystems that provide our raw materials and to minimise the impacts of transportation. Communicate openly with our shareoweners, employees, customers and other interested parties by regularly reporting on our commitments and our EHS performance and maintaining an open dialogue.

9.



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Cadbury Ireland Ltd. SECTIONNO. I ENVIRONMENTAL 1 REVISION DATE

I ENVIRONMENTAL MANUAL

PAGE

10. Review and update this policy regularly.

4.3 PLANNING

4.3.1 ENVIRONMENTAL ASPECTS

4.3.1 Initially, a Review was carried out which examined the following areas:

(i) Legislative and regulatory requirements.

(ii)

@ I

The evaluation and registration of significant environmental aspects.

(iii) The examination of all existing environmental management practices and

procedures .

4.3.1.2 The evaluation of aspects was carried out by a combination of document survey, and by

direct inspection and measurement.

4.3.1.3 On the basis of this evaluation, a Register of Environmental Impacts has been prepared

and is an individually controlled document within the Environmental Management

System. It is updated by means of Procedure Number EP 12.01 "Identification and

Evaluation of Impacts".

The Register of Environmental Impacts details all significant environmental impacts, both

direct and indirect of it's activities and products.

Consideration of impacts likely to arise as a result of abnormal operating activities and

incidents, accidents and potential emergency situations is also included.

Cadbury Ireland also evaluates all new materials, processes and projects and all significant

modifications to existing processes via its procedure # EP 1 1 .O 1 "Evaluation of New

Processes/Materials". Any actual or potential impacts identified at this stage are evaluated


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I SECT1oNNo.

4

ENVIRONMENTAL I REVISION

MANAGEMENT I No. 1.2 DATE I PAGE + 19-Apr-2006 5 of 25

for significance and managed by operational control or by setting an objective. They are

also logged in the Register of Impacts.

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. . . .. .. - . . . . - . . . . . . .

Cadbury Ireland Ltd. SECTIONNO. 1 ENVIRONMENTAL

ENVIRONMENTAL MANUAL

REVISION . DATE PAGE

4 I SYSTEM REQUIREMENTS

MANAGEMENT

19-Apr-2006 6 of 25

I No. 1.2 I

4.3.2

Q

LEGAL AND OTHER REQUIREMENTS:

A Register of Health, Safety and Environmental Legislation is separately maintained by

Cadbury Ireland Consultants TMS Ltd as an online live register which is updated as new

information is made available. Corporate requirements will also be included in the register

where there is a specific requirement to do so. This new style register is being used from

2006 onwards and is available via the web.

/ I

Originated By: Thomas Byre . Approved By:

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4.3.3 OBJECTIVES AND TARGETS:

SECTION No.

4

Cadbury Ireland is committed to comply with all relevant legislative and regulatory

requirements. In addition, other objectives and targets, which are consistent with the

environmental policy, are also identified.

REVISION No. 1.2

ENVIRONMENTAL

MANAGEMENT

SYSTEM REQUIREMENTS

The objectives and targets are set out in the numbered foms identifies specific objectives

and targets under a number of sub headings. Managers in each area of the factory are

required to review and identi@ objectives as set out. The company is committed to

improving on these as part of its drive towards continuous improvement in environmental

performance. The targets are location or issue specific.

@

Key environmental objectives and targets are identified, managed and controlled by means

of the procedure on the setting and monitoring of objectives. (ref. Setting and Monitoring

of Objectives EP 09.01). They will also form a constituent part of management's goals.


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SECTION No. ENVIRONMENTAL

MANAGEMENT

SYSTEM REQUIREMENTS 4

REVISION DATE PAGE No. 1.2

19-Apr-2006 8 of 25

4.3.4 ENVIRONMENTAL MANAGEMENT PROGRAMME:

Cadbury Ireland has established a programme for implementing the environmental policy

and achieving the environmental objective and targets. This is achieved by defining the

duties and responsibilities of all personnel whose work can have a significant actual or

potential impact on the environment.

The programme specifies the objective to be achieved, the person responsible for attaining

the objective, the efficacy date and the method of monitoring successful achievement of

the objective. These objectives are hrther translated into practical targets with associated

steps towards their achievement. Definitions for objectives and targets are included in

section 3 of this manual.

Procedure number EP 1 1.01 addresses the environmental management of projects relating

to new developments, products or processes or modified products or processes where the

modification introduces significantly different environmental impacts.

Originated By: Thomas Byrne.

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REVISION No. 1.2

DATE PAGE SECTION No.

4

ENVIRONMENTAL

MANAGEMENT

SYSTEM REQUIREMENTS

Quality Services

Manager

Margaret Conologue

Site HSE Site Engineer

Manager Utilities

T Byme Aodhan Breen


I 19-Apr-2006 1 9 of 25

4.4 IMPLEMENTATION AND OPERATION

4.4.1 STR UCTURE AND RESPONSIBILITY:

Head of Manufacturing

Ireland

CSMS

Manager

IPM Manager A Manufacturing

Managers

* 3

Manufacturing

Teams

Physical Logistics

Manager

QEHS Manager

Michael Doran

Projects Manager

Ireland

Approved By: Originated By:


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SECTION No. I ENVIRONMENTAL

MANAGEMENT

Management Environmental Responsibilities. 4.4.1.1 Head of Manufacturing.


I

19-Apr-2006 I 10 of 25

The Head of Manufacturing is the Manufacturing Director for Cadbury Ireland. The head of Manufacturing has responsibility for all site and factory matters including quality and environmental issues. The factory managers along with the HSE manager ensure that the company environmental policy is understood, implemented and maintained. It is the responsibility of the QHSE manager the HSE Manager and the Factory Managers to ensure that trained personnel are available for verification activities. The Factory managers have responsibilities for the factory resources and the sections of the environmental documented system as listed below.

4.4.1.2 QEHS Manager

Is responsible for the Environmental Management System which is in operation at the Coolock Factory. In particular the environmental manual, the system described therein, and the HSE Manager who reports directly to the QEHS Manager.

4.4.1.3 Health Safety & Environmental Manager.

The HSE Manager reports directly to the QEHS Manager, and has the responsibility of ensuring that all aspects of the environmental system are implemented in accordance with the C.S. GEM Guidelines. The HSE manager has the responsibility of maintaining records for a period of five years for all documented environmental control parameters and correspondence. The responsibilities of the HSE manager are listed below.

The HSE Manager is designated as the management representative with responsibility for ensuring

that the requirements of IS0 14001 are implemented and maintained.

The main duties and responsibilities of the HSE Manager are as follows:

(i) Establishing and documenting the environmental standards and criteria to be applied for each product and process. These will be clearly documented in the system and will include details of primary inspection points and control processes in the plant.

Originated By: Approved By:


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REVISION I PAGE No. 1.2 t 19-Apr-2006 11 of 25

SECTIONNO. I ENVIRONMENTAL

MANAGEMENT

(ii) Ensuring that each departments' responsibility for environmental probity is suitably documented.

(iii) Ensuring that adequate records are maintained for demonstration of conformance to environmental requirements.

Conducting internal audits of the Environmental Management System to ensure continued adherence to documented requirements.

(iv)

(v) Monitoring non-conformances within the environmental management system.

(vi) Ensuring that adequate resources are available to maintain the environmental system at its required level.

(vii) Dealing with external relations in matters relating to the environment.

(viii) Assisting in internal dissemination of environmental information.

(1 x). Site safety responsibility for all aspects.

4.4.1.4 Manufacturing Managers Report directly to the Head of Manufacturing and have the responsibility for all manufacturing aspects of their plants. They also have the responsibility to ensure that all environmental aspects associated with their plants are managed within the permitted parameters. That there is an active policy to reduce waste of resources materials, energy and water. They have the added responsibility to ensure that all written environmental instruction associated with their plant and procedures are communicated to the relevant personnel through the team leaders who report to the manufacturing manager.

4.4.1.5 Team leader / Line Manager.

Is on the Factory Premises while production is taking place, has the responsibility for day to day matters relating to production and operational decisions. The team leader is responsible for the efficient and effective use of all raw materials, water and energy. He/she is also responsible for


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Q 'I I I

0 I

SECTION No. ENVIRONMENTAL I REVISION

Cadbury Ireland Ltd. DATE PAGE


4 I SYSTEM REQUIREMENTS

MANAGEMENT I I I 19-Apr-2006 I 12 of 25

I No* 1-2

the personnel under their control and the actions of their personnel. Environmental matters are part of the manager's responsibility and they are written into their job description.

4.4.1.6 Project Engineering Managers.

These managers report directly to the Site Senior Project Engineer and have the responsibility of designing and installing factory projects within fixed budgets. Project Managers initiate RAM Forms and have the responsibility to ensure that the HSE Manager is made fully aware of the environmental implications of their projects. A new section is to be made available on all RAM/CE Forms in 2006, to be signed off by the Environmental Manager.

4.4.1.7 Process Engineers.

These managers report directly to the Manufacturing Manager and have on line process / manufacturing and quality responsibilities. The process managers have environmental responsibilities to ensure that rework is minimized (thus reducing energy and material / resource usage) and that the washdown levels from the manufacturing plants is kept at a minimum.

4.4.1.8 IPM Manager.

Is responsible for issuing specifications for packaging materials used in the manufacture of product in the Dublin Factory. Reduce, Re-use and recycle packaging materials are the basis for the packaging department on the hierarchy of packaging material usage. User friendly materials must be used where possible for recycling, minimal amounts of packaging must be used on all products. The packaging department must record all specifications of packaging materials for inclusion in the data base for REPAK Statistics.

4.4.1.9 Engineering Support Managers.

Responsible for the day to day maintenance of the plant at Dublin, for ensuring that leaks are fixed when detected, The support manager is responsible for the up keep of buildings, plant and breakdown maintenance. The support manager is also responsible for the environmental aspects associated with their work, to reduce energy usage, water usage and to ensure the safe and correct disposal of hazardous waste.

4.4.1.9.1 Site Engineer.

Has a wide range of responsibilities, which covers the entire premises and is responsible for the environmental aspects associated with her/ his job. In particular the environmental monitoring equipment must be kept running at all times and the Boiler House must be kept in a good

Originated By:

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1 Cadbury Ireland Ltd. SECTIONNO. I ENVIRONMENTAL I REVISION DATE

1 ENVIRONMENTAL MANUAL

PAGE

1 4

MANAGEMENT I No* lm2 I operating and efficient mode. The site engineer works closely with the HSE manager to ensure that the grounds are kept clean, neat and free from pollutants.

4.4.1.9.2 Quality Services Manager.

To provide resources to carry out water analysis. The laboratory manager has the responsibility of

ensuring that water samples from Cooling Towers are tested and analysed weekly, the results are to

be kept on record in the main laboratory.

Approved By:

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I Cadbury Ireland Ltd. SECTIONNO. I ENVIRONMENTAL


REVISION DATE PAGE

MANAGEMENT I No. 1*2 I 4.4.2 TMINING, A WARENESS AND COMPETENCE:

4.4.2.1 All relevant management personnel apart from the HSE Manager shall have their duties

and responsibilities relating to environmental matters defined in the organisational chart

Section 4.4.1 and the various procedures in the Environmental Procedures Manual.

In addition the Personnel Department maintains detailed training records of all personnel

which includes environmental training records. Typical of the environmental training

undertaken by Cadbury Ireland personnel includes the following:

e

a

e

e emergency responsiveness e

e environmental auditing

Environmental awareness training for all operators & Management.

chemical handling and spillage control segregation of solid waste streams ?

hazardous chemicals handling and disposal

Extensive awareness training has been carried out at senior management, middle

management, and operator levels. The senior management and the environmental

committee awareness training was carried out by an external consultant and included an

understanding of the key elements of IS014001 and an appreciation of the impacts which

the company 's having on the environment. All awareness training is logged in the

relevant training records kept by personnel.

Awareness of the environment is also encouraged in company personnel by means of a

notice board and environmental posters.


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I Cadbury Ireland Ltd. SECTION No. ENVIRONMENTAL

MANAGEMENT




19-Apr-2006 15 of 25

4.4.3

4.4.3.1

@ ('

4.4.3.2 I

COMMUNICA TION:

Procedure Number EP 02.01 on Communication specifies the method by which

environmentally related matters are disseminated both within and outside of Cadbury

Ireland. The procedure specifies the person responsible for all internal and external

communications relating to the environment.

Procedure Number EP 04.0 1 'I Environmental Complaints" and Procedure Number EP

10.0 1 "Environmental Incident Release Investigation and Reporting" detail the

responsibilities and mechanisms by which communication from external interested

parties regarding the company's environmental aspects is received, documented and

responded to.

In the event of an environmental incident, EP 10.0 1 specifies the procedure to be

followed by Cadbury Ireland in reporting the incident to the relevant regulatory

authority. In addition to this procedure a Coolock Emergency Procedures Manual is

available which covers a number of possible major incidents which can occur on site.

The manual is available from the QEHS Managers, security, the HSE, Reception and the

factory Managers.

Originated By:

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Approved By:

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Cadbury Ireland Ltd.


MANAGEMENT


4.4.4

4.4.4.1

0

1 4.4.4.2 I

I

I i I I

i 4.4.4.3

e l

I

4.4.4.4



19-Apr-2006 16 of 25

ENVIRONMENTAL MANAGEMENT SYSTEM DOCUMENTA TION:

The Environmental Management System is adequately and systematically documented

by means of:

The Environmental Manual

The Operating procedures Manual

e The Register of Environmental Impacts

The Register of Health Safety and Environmental Legislation. (WEB Based)

Circulation List:

The HSE Manager maintains a circulation list of controlled copies of each of the

aforementioned documents. Shehe is responsible for distributing and updating all

recipients of controlled documentation on the circulation lists.

Document Register:

A Register of all environmental system documentation is maintained by the HSE

Manager. The Register identifies the current revision of all documents.

Document Amendment:

All changes and amendments to documents must be approved by the HSE Manager and

must be recorded on the appropriate amendment sheet. This sheet and all amended

pageshections are circulated io the holders of the documents.


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rCadbury Ireland Ltd. SECTION No. I ENVIRONMENTAL

MANAGEMENT


REVISION DATE PAGE I No. 1.2

I

19-Apr-2006 17 of 25

4.4.5

4.4.5.1

4.4.5.2 @

1

I \ 4.4.5.3

4.4.5.4

@ 4.4.5.5

1 1

4.4.5.6

DOCUMENT CONTROL

This manual is an integral part of Cadbury's overall management system at Coolock.

This manual describes the procedures for operating and maintaining the company's

Environmental Management System.

The manual is strictly controlled by circulation and amendment. Only the latest issue

number is valid. The Quality Document ControlIer controls all revisions, issues and

circulation.

All copies of the manual are numbered and all pages and copies are subject to control by

the HSE Manager.

All of the procedures referenced in this manual has been approved by management and

express the environmental policy laid down by management.

The latest revision numbers of the Environmental Manual, Register of Environmental

Impacts and Register of Environmental Legislation are displayed/available in the HSE

Manager's office as well as in the amendment sheet attached to each document. The

only valid copy of any environmental system document is that shown with the latest

revision numbers.

Changes and additions can be suggested by all staff members and co-ordinated through

the relevant manager. All final changes must be carried out with the authority of the

HSE Manager.


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I Cadbury Ireland Ltd. SECTION No.

4


REVISION No. 1.2

ENVIRONMENTAL

MANAGEMENT

SYSTEM REQUIREMENTS

4.4.5.7 All changes and amendments are recorded on the amendment sheet. This sheet and all

amended pages are then circulated to the holders of each environmental manual.

Holders must insert new,pages and destroy the old.

4.4.5.8

@ Where appropriate, elements of the Environmental Manual are cross referenced with

elements of the Quality Manual, and Occupational Health and Safety Statement. This

cross referencing will be noted where appropriate.

I Originated By: Approved By:


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Cadbury Ireland Ltd. I ENVIRONMENTAL MANUAL

SECTION No. I ENVIRONMENTAL

MANAGEMENT


I

19-Apr-2006 19 of 25

I

, I I !

I

i

4.4.6

4.4.6.1

4.4.6.2

4.4.6.3

Q 1 ,’

OPERATIONAL CONTROL

The company shall identi@ operations and activities associated with the identified

significant impacts and write and maintain procedures governing them. All significant

impacts should be managed by means of operational control, i.e. documented in a

procedure or by the setting of an environmental objective.

Documented procedures are in existence which encompass all Cadbury Ireland activities

and processes which significantly affect or have the potential to significantly affect the

environment.

The following procedures are relevant:

Operational procedures

EP 14.01

EP 15.01

EP 16.01

EP 17.0 1

EP 18.01 Minor Chemical Spillages

EP 22.01 Empty Drum Management

EP 19-01

EP 20.01

Segregation and Storage of Drummed Materialmaste Procedure

Control of Chemicals entering premises

Guidelines for the arrival and Unloading of Bulk Tankers

Monitoring and Recording Environmental Information.

Hazardous Waste Contractor Selection and Control

Obsolete Equipment Disposal Procedure

EP 2 1 .O 1 Boiler Maintenance



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1 Cadbury Ireland Ltd. SECTION No. ENVIRONMENTAL

MANAGEMENT




19-Apr-2006 20 of 25

4.4.7

4.4.7.1

4.4.7.2

4.4.7.3 @ 1 11

I

4.4.7.4

e 0

EMERGENCY PREPAREDNESS AND RESPONSE

Procedure Number EP26.01 details the steps to be followed in the event of an accident

or emergency.

In addition, Procedure Number EP 18.01 Minor Chemical Spill Procedure details the

steps to be followed in the event of a chemical spillage.

A Coolock Emergency Procedures Manual outlining procedures for major emergencies,

local emergencies and accident inquiries is available at security, from the QHSE

manager, the HSE manager, reception and senior management.

Where an incident or accident occurs, procedure EP 10.01 outlines the responsibility for

and the mechanism by which regulatory authorities are informed (ref. Environmental

IncidenURelease Investigation & Reporting).

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Cadbury Ireland Ltd. SECTION No. ENVIRONMENTAL

MANAGEMENT


4.5

4.5.1

4.5.1.1

4.5.1.2



19-Apr-2006 21 of 25

CHECKING AND CORRECTIVE ACTION

MONITORING AND MEASUREMENT

General:

Management responsibilities shall be defined to ensure that control, verification,

measurement and testing within individual parts of the company are adequately co-

ordinated and effectively performed.

Control:

Documented procedures are in existence which encompass all Cadbury Ireland

monitoring and measurement activities and processes which significantly affect or have

the potential to significantly affect the environment.

The following procedures are relevant:

Monitoring and Control Procedures

EP 01.01

EP 05.01

EP 06.01

EP 07.01

EP 10.01

EP 11.01

EP 13.01

EP 15.01

EP 19.01

EP 21.01

EP 23.01

EP 24.01

Environmental Management Review

Internal Environmental Audit Procedure

Environmental Non-Compliance

Corrective Action Procedure

Environmental IncidenVRelease Investigation and Reporting

Evaluation of New ProcessedMaterials

Environmental Control of SubcontractorsNendors

Control of Chemicals Entering Premises

Hazardous Waste Contractor Selection and Control

Boiler Maintenance

Transport

Control of M.S.D.S. Register -.



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Cadbury Ireland Ltd. SECTION No. I ENVIRONMENTAL


REVISION DATE PAGE

I MANAGEMENT I No* lS2 I 4 I SYSTEM REQUIREMENTS I 19-Apr-2006 I 22 of 25 I I I

4.5.2 NON-CONFORMANCE AND CORRECTIVE AND PREVENTIVE ACTION:

It is the responsibility of the HSE Manager to initiate an investigation and corrective

action in the event of a non-compliance relating to the Environmental Management

System.

This will be done in accordance with Procedure Number EP 10.01 "Environmental

IncidenURelease Investigation and Reporting" and EP 07.0 1 "Corrective Action

Procedure".

Actions will include:

8 Determine the cause

8 Draw up action plan

8 Initiate corrective action

8 Apply controls

8 Record changes

Actual and potential non-conformances are reviewed at the Management Review

meeting.

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1 Cadbury Ireland Ltd. SECTION No.

4


REVISION No. 1.2

ENVIRONMENTAL

MANAGEMENT

SYSTEM REQUIREMENTS

4.5.3 RECORDS

4.5.3.1

@ 4.5.3.2

4.5.3.3

It is the responsibility of the HSE Manager to maintain all relevant records to

demonstrate compliance with the requirements of the Environmental Management

System.

Identification, collection, indexing, filing, storage, maintenance and disposition of

environmental management records shall be carried out in accordance with the

requirements of Quality Procedures.

The following environmental management records shall be maintained:

8 Internal audit reports

0 External audit reports

8 Integrity testing reports

0 Complaints reports

0 Management review minutes

0 MSDS control sheets

8 Incident release reports

0 Waste audit reports


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a


MANAGEMENT


I Cadbury Ireland Ltd. 1 ENVIRONMENTAL MANUAL


19-Apr-2006 24 of 25

4.5.4

4.5.4.1

4.5.4.2

4.5.4.3

4.5.4.4

ENVIRONMENTAL MANAGEMENT SYSTEM AUDIT

The Audit shall be carried out in accordance with Procedure EP 05.01 "Internal

Environmental Audit Procedure".

The HSE Manager is responsible for arranging, scheduling and directing the internal

environmental audits.

Audits shall be carried out by personnel having no direct responsibility in the area being

audited.

Audit Plans

The audit plan shall specifl:

0 Activities/areas to be audited 0

0

Frequency of auditing of each area Responsibility for auditing each area

Audit Protocol

The audit protocol shall specify:

0

The audit methodologies The nature of the audit reports

Audit Personnel

The HSE Manager shall be responsible for initiating corrective actions which result in

solutions to audit findings.



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I No. lS2

SECTIONNO. I ENVIRONMENTAL I REVISION DATE I PAGE

4.6

4 SYSTEM REQUIREMENTS 19-Apr-2006

MANAGEMENT REVIEW

25 of 25

4.6.1 Cadbury Ireland management shall, at appropriate intervals, review the Environmental

Management System to ensure it's continued suitability and effectiveness.

This review shall be documented and carried out in accordance with Procedure Number

EP 0 1.01 "Environmental Management Review".

4.6.2 The environmental management review shall address the possible need for change to the

plant policy and objectives, in the light of changing circumstances, environmental audit

results and the commitment to continual improvement and prevention of pollution.



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. . .. .

1 Cadbury Ireland Ltd. ENVIRONMENTAL MANUAL

REVISION DATE No. 1.2 SECTION No. TITLE

18" Apr 2006

CADBURY IRELAND LTD.

PAGE

1 o f 5

COOLOCK

DUBLIN 5


COPY NO.



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REVISION DATE No. 1.2

SECTION No. TITLE . 18" Apr 2006

PAGE

1 o f 5

SECTION CONTENTS

Foreword

Company Profile

1 Scope of Environmental Manual

2

3

4

4.1

4.2

4.3 4.3.1 4.3.2 4.3.3 4.3.4

4.4 4.4.1 4.4.2 4.4.3 4.4.4 4.4.5 4.4.6 4.4.7

4.5 4.5.1 4.5.2 4.5.3 4.5.4 4.6

Circulation List

Definitions

Environmental Management System Requirements

General Requirements

Environmental Policy

Planning Environmental Aspects Legal and Other Requirements Objectives and Targets Environmental Management Programme

Implementation and Operation Structure and Responsibility Training, Awareness, and Competence Communication Environmental Management System Document Control Operational Control Emergency Preparedness and Response

Checking and Corrective Action Monitoring and Measurement Non Conformance and Corrective and Preventive Action Records Environmental Management System Audit Management Review



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1 Cadbury Ireland Ltd. REVISION DATE No. 1.2

TITLE SECTION No.

18" Apr 2006


PAGE

1 o f 5

This Environmental Manual describes the environmental system in operation at

Cadbury Ireland Ltd., Coolock, Dublin 5.

This Environmental Manual meets the requirements of IS014001 : 1996

"Environmental Management Systems - Specification with Guidance for use".

It is proposed that this manual and associated management system would enable the

company to comply with the requirements of the EC Eco Management and Audit Scheme.

The procedures are referenced in the appropriate sections of the manual.

The manual is under documentation control. The management representative maintains the

original copy which is approved by the QHSE. Manager. A restricted number of copies of

this manual (identifiable by being stamped with "controlled copy" in red ink) are issued.

This circulation list is outlined in Section 2.

The manual is reviewed yearly, prior to the management review. Amendments are

circulated to controlled holders.

Originated By:

Signature :

Approved By:

Signature:

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I Cadbury Ireland Ltd. REVISION No. 1.2

TITLE SECTION No.


DATE PAGE

Apr 2006 1 of5

1 . 1 This environmental system covers all aspects of the environmental management system

And incorporates the Cadbury Schweppes Environmental Health and Safety Policy.

1.2 It also covers the management, monitoring and disposal of all solid, liquid and gaseous

waste streams.

@ 1.3 The manual complies with the requirements of I S 0 14001.

1.4 The system consists of:

0 The Environmental Manual

0 Operating Procedures Manual

0 Register of Environmental Impacts

0

. Environmental Management Programme

On Line Health Safety and Environmental Legislation Register.



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1 Cadbury Ireland Ltd. &VISION No. 1.2

TITLE SECTION No.


DATE PAGE

18" Apr 2006 1 of5

2.1

Q 2.2

2.3

Q i '

2.4

ADMINISTRATION OF ENVIRONMENTAL MANUAL

The Health Safety and Environmental Manager shall be responsible for the compilation,

distribution, amendment and maintenance of the environmental manual.

CONTROLLED MANUAL DISTRIBUTION

The manual shall be issued to each person identified on the circulation list.

A "controlled copy" is a copy which after distribution is updated with all manual changes.

UNCONTROLLED MANUAL DISTRIBUTION

Distribution of uncontrolled copies of the environmental manual should be avoided.

However, where they occur, they should be clearly stamped with an "uncontrolled copy"

stamp.

CIRCULATION LIST

The circulation list is as follows:

Copy No. Holder Title 1 Tom Byrne Health Safety and Environmental Manager.



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I Cadbury Ireland Ltd. SECTION No.



3.

I 19 APR 2006. 1 1 of 3

Continual Improvement:

Process of enhancing the environmental management system to achieve improvements in

overall environmental performance in line with the organisation's environmental policy.

NOTE: The process need not take place in all areas of activity simultaneously.

3.2 Environment: Q Surroundings in which an organisation operates, including air, water, land, natural

resources, flora, fauna, humans, and their interrelation.

NOTE: Surroundings in this context extend from within an organisation to the global

system.

3.3 Environmental Aspect:

Element of an organisation's activities, products or services that can interact with the

environment.

NOTE: A significant environmental aspect is an environmental aspect that has or can have a

significant environmental impact.

i , 3.4 Environmental Impact: \A

1.1

Any change to the environment, whether adverse or beneficial, wholly or partially resulting

from an organisation's activities, products or services.

3.5 Environmental Management System:

The part of the overall management system that includes organisational structure, planning

activities, responsibilities, practices, procedures, processes and resources for developing,

implementing, achieving, reviewing and maintaining the environmental policy.


I Signature: Signature :

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Cadbury Ireland Ltd. SECTION No.

3


DEFINITIONS No. 1.2

19 APR 2006.

I REVISION I DATE 1 PAGE I 2 o f 3

3.6 Environmental Management System Audit:

A systematic and documented verification process of objectively obtaining and evaluating

evidence to determine whether an organisation's environmental management system

conforms to the environmental management system audit criteria set by the organisation,

and for communication of the results of this process to management.

3.7 Environmental Objective:

Overall environmental goal, arising from the environmental policy, that an organisation sets

itself to achieve, and which is quantified where practicable.

3.8 Environmental Performance:

Measurable results of the environmental management system, related to an organisation's

control of its environmental aspects, based on its environmental policy, objectives and

targets.

3.9 Environmental Policy:

Statement by the organisation of its intentions and principles in relation to its overall

environmental performance which provides a framework for action and for the setting of its

environmental objectives and targets.

3.10 Environmental Target:

Detailed performance requirement, quantified where practicable, applicable to the

organisation or partathereof, that arises from the environmental objectives and that needs to

be set and met in order to achieve those objectives.

Originated By:

Signature:

Approved By:

Signature:

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3.1 1

SECTION No.

3 DEFINITIONS

3.12


19 APR 2006. 3 o f 3

3.13

Interested Party:

Individual or group concerned with or affected by the environmental performance o f an

organisation.

Organisation:

Company, corporation, firm, enterprise, authority or institution, or part or combination

thereof, whether incorporated or not, public or private, that has its own functions and

administration.

NOTE: For organisations with more than one operating unit, a single operating unit may be

defined as an organisation.

Prevention of Pollution:

Use of processes, practices, materials or products that avoid, reduce or control pollution,

which may include recycling, treatment, process changes, control mechanisms, efficient use

of resources and material substitution.

NOTE: The potential benefits of prevention of pollution include the reduction of adverse

environmental impacts, improved efficiency and reduced costs.

- . .



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