On Tuesday, 20 November, Sasol participated in the South African Human Rights Commission’s (SAHRC) inquiry into the state of the Vaal River. As an industrial user of this resource, we welcome the invitation by the SAHRC to participate and support its mandate. Sasol’s team of specialists and subject matter experts presented an overview of Sasol’s reliance on the Integrated Vaal River System (IVRS).  This will be followed by a written submission to the SAHRC.

We have noted the extensive media reports on the raw sewage discharges into the Vaal River in the past several weeks and months. We are deeply concerned about the current state of this vital resource. 

In the context of the hearing on 20 November, Sasol wishes to clarify media reports on 20 and 21 November pertaining to Sasol’s compliance with waste water discharge and further, to the reference to its waste incinerators.

Waste water discharge compliance
As stated to the Commission, Sasol currently discharges waste water under a Water Use Licence (WUL), issued in December 2016 by the Department of Water and Sanitation (DWS) which imposes conditions and strict limits governing discharges of treated water into the river as a lawful water user. These conditions were set with due consideration of the Vaal River Catchment Management Strategy and the relevant resource water quality objectives. 

Our Sasolburg Operations complies with its WUL and waste water discharge limits. In the event of incidents, associated deviances, however small, are investigated and reported  to the authorities in line with the conditions set-out in our WUL. The few incidents where the discharge specifications were exceeded, were of short duration in all instances. Moreover, we regularly engage with the DWS to ensure our ongoing alignment on the interpretation of the WUL conditions and its application.

There were two incidents (on 4 December 2017 and 23 March 2018) of sewage overflow into the Leeuwspruit emanating from Sasol’s waste water treatment facility in Sasolburg which treats the town’s sewerage on behalf of the municipality. These were the result of excessive rainfall entering the municipality’s sewage collection infrastructure which placed excessive pressure on Sasol’s waste water treatment infrastructure, beyond its capacity. This was duly reported to the local municipality and the DWS. The overflows were of a short duration and impact assessments were undertaken and reported to the DWS. As the Sasol treatment plant is not designed to handle and treat such excessive flows, the municipality has been requested to address the root cause, while Sasol has made available additional pumping capacity to help mitigate future excessive flow scenarios. The ingress of high storm water flows can, however, only be fully mitigated by the municipality.

Incinerator
A reference was made by the Commission to Sasol’s incinerators in Sasolburg as mentioned in the Department of Environmental Affairs (DEA) 2016/2017 Environmental Compliance Report (this was not issued or compiled by the Department of Water and Sanitation). While we welcome questions on our environmental compliance and management by the Commission, the Sasolburg incinerators referenced in the DEA report have no operational bearing on our activities linked to the Vaal River and specifically waste water discharge compliance. Notwithstanding, as confirmed by the report, we experienced some air quality related compliance challenges with our Sasolburg incinerators and, voluntarily decommissioned the incinerators with the commitment to only re-commission them if sustained compliance can be ensured.

Given the current state of the IVRS and its importance to the entire region, Sasol welcomes this inquiry as part of identifying the root causes of the raw sewerage affecting the river and communities residing in its proximity, as well as the associated risks with the IVRS. Through this process, Sasol intends to foster a collaborative approach in resolving this challenge with key stakeholders.

Sasol is a responsible corporate citizen, key stakeholder and a lawful, responsible water user of the IVRS. Compliance is a priority for Sasol and is a commitment that remains steadfast. 

As a member of the Strategic Water Partners Network, a signatory of the United Nations Global Compact (UNGC) since 2001, and an endorser of the UNGC CEO Water Mandate, we recognise that the responsible management and use of the IVRS by all stakeholders, amongst others, is key and in the best interest of all those who have the right to it. 

It is for these reasons that Sasol’s lawful use of this resource is managed by dedicated operational teams who are supported by subject matter experts in the areas of water, waste, land and biodiversity management. Furthermore, we are also involved in a number of water conservation/ water demand management initiatives with local and national governments and other key stakeholders in the spirit of continuous improvement and public-private partnerships. 

Our approach on respecting human rights is incorporated in our Code of Conduct and is guided by the United Nations Guiding Principles on Business and Human Rights, the International Bill of Human Rights, the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work. This forms a cornerstone of our integrated sustainable development framework.

We remain committed to supporting the Commission’s inquiry and to assisting and collaborating with the institution to advance the objectives of this investigation. To this end, we welcome the Commission’s intention to conduct a site visit at our discharge points. We deem this as a sustainability imperative in the interest of all who have water use rights, especially the vulnerable communities.  

Sasol is committed to the health and safety of all our employees, our fence-line communities and the environment.