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Read the Registration Document - Guerbet

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2) Environmental informationa) General policyThe production of chemical active ingredients for contrast agents generates different safety andenvironmental risks. These risks are inherent to <strong>the</strong> dangers of certain chemical products, <strong>the</strong>ir production,transport, use and elimination.Active chemical ingredients used to produce contrast agents for medical imaging are distinguished by <strong>the</strong>irlow toxicity and excellent level of tolerance, even though certain ingredients might be noxious in <strong>the</strong>irnatural form. In contrast, certain syn<strong>the</strong>tic intermediates or products used in <strong>the</strong> production of <strong>the</strong>se activeingredients (raw materials, solvents, reactants, intermediates, etc.) may present certain risks.The Group implements and environmental policy supported by Executive Management and deployed at itsmanufacturing sites through an HSE (health, safety and <strong>the</strong> environment) management system.The foundation of this HSE management system is based an evaluation of risks destined to preventincidents having an impact on people, property and <strong>the</strong> environment (including <strong>the</strong> identification of majoraccident scenarios).HSE manuals describe <strong>the</strong> safety and environmental systems and management organisations deployed at<strong>the</strong> sites.The Lanester and Marans sites (SEVESO upper tier risk category sites) are subject to special requirements.They organise full-scale response exercises for managing emergency situations in collaboration withregional authorities. The Internal Emergency Plan (POI) and <strong>the</strong> Emergency Response Plan (PPI) are inthis way tested for <strong>the</strong> purpose of achieving ongoing improvements in <strong>the</strong> abilities of teams to respond in<strong>the</strong> event of a crisis, both internally and, when interfacing with outside emergency relief teams.Outside communications for Seveso site operations are assured through local coordinating bodies (CLIC orComité Local d’Information et de Concertation) that include members of <strong>the</strong> operating entity, departments of<strong>the</strong> Prefecture, elected officials and local associations.The safety and environmental risk management systems implemented at <strong>the</strong> sites also define:- Performance indicators and associated objectives;- Training requirements for operational staff and regular follow-up;- Management of feedback/lessons learned through <strong>the</strong> analysis of incidents or near accidents withinor outside <strong>the</strong> sites (ex: use of BARPI databases on industrial risks and pollution that maintainsrecords of industrial accidents) and adoption of necessary corrective measures;- Inspections and audits;- Review of <strong>the</strong> system and its performance by supervisory staff.Since 2010, audits have been performed at <strong>the</strong> manufacturing sites. They are based on internal standardscomparable to standard and systems such as OHSAS 18001, ISO 14001 and SGS (Management andSecurity System for SEVESO sites in France). These audits make it possible to first identify, and <strong>the</strong>nimplement actions contributing to a sustainable HSE performance within <strong>the</strong> framework of a continualimprovement process. Audits conducted in 2012 made it possible to measure progress achieved at <strong>the</strong>manufacturing sites while identifying priority areas for improvement.In December 2012, technology risk prevention plans (Plans de Prévention des Risques Technologiques orPPRT) for <strong>the</strong> Seveso sites of Lanester and Marans were approved after a three-year review period. Theseplans define notably zoning measures applicable around <strong>the</strong> Lanester and Marans sites.66

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