Global Compact Business Case-Study
Sasol and the Promotion of Unleaded Fuel
Assessing implementation of Principle 7 of the Global Compact
(the precautionary approach) in the context of Sasol’s activities
relating to the phase-out of leaded petrol in South Africa
Case Author: Jonathon Hanks
(University of Cape Town Graduate School of Business)
Reviewed by: Professor Oliver Williams
(University of Notre Dame)
2 December 2003
Case Abstract
This case study reviews the activities and experience of Sasol – a large South African based multinational
petrochemical company – regarding the phasing out of leaded fuel in South Africa. A key focus of this
study relates to Sasol’s decision (and its subsequent activities) regarding the use of
Methylcyclopentadienyl Manganese Tricarbonyl (MMT) as an alternative fuel additive to lead with the
aim of thereby facilitating a more rapid and widespread transition to unleaded fuel use.
The various controversies relating to the potential environmental and health effects of MMT are briefly
outlined, and are then assessed in terms of their implications regarding the implementation of the
precautionary approach. The case study reviews the activities that Sasol undertook as part of its
commitment to implementing an open and transparent process with its stakeholders on this issue, in the
absence of regulatory requirements or guidelines relating to fuel additives. The nature of Sasol’s activities
is then evaluated against the expectations of the precautionary approach.
While the focus of this case study is on a single specific issue, the study is intended to serve as the basis for
identifying some general lessons that may be applied more broadly in the context of business strategy. The
underlying aim of the case study is to explore some of the uncertainties associated with the interpretation
and application of the precautionary approach, and to identify the potential implications and lessons learnt
for traditional decision-making processes in the corporate sector.
Table of Contents
1
INTRODUCTION AND OVERVIEW ........................................................................................................................................................... 1
1.1 COMPANY PROFILE .......................................................................................................................................... 1
1.2 STATEMENT OF THE PROBLEM TO BE SOLVED .................................................................................................. 1
2
UNDERSTANDING THE NATURE OF THE ISSUE ................................................................................................................................. 2
2.1 SASOL AND THE PHASING OUT OF LEADED FUEL – BACKGROUND................................................................... 2
Understanding Sasol’s Motivations Regarding Unleaded Fuel and MMT .................................................. 2
2.2 THE PRECAUTIONARY APPROACH – UNDERSTANDING THE ISSUES .................................................................. 4
What are the implications of implementing the precautionary approach? .................................................. 5
3
THE CASE STORY: IMPLEMENTING THE PRECAUTIONARY APPROACH? ................................................................................ 5
3.1 A SUFFICIENT BASIS FOR INVOKING THE PRECAUTIONARY APPROACH? ........................................................... 5
3.2 ASSESSING THE ALTERNATIVE OPTIONS ........................................................................................................... 7
3.3 THE PROCESS OF STAKEHOLDER CONSULTATION ............................................................................................ 8
Initial Government Interaction ..................................................................................................................... 8
Customers: Oil Companies .......................................................................................................................... 8
Motor Vehicle Manufacturers and Marketers .............................................................................................. 9
Fuel Retailers ............................................................................................................................................... 9
Motorists represented by the Automobile Association of SA (AA) ............................................................... 9
The Media..................................................................................................................................................... 9
The Legal Resource Center (LRC) ............................................................................................................. 10
Subsequent government interaction ........................................................................................................... 10
Sasol’s commitments .................................................................................................................................. 10
3.4 ASSESSING THE RISKS .................................................................................................................................... 11
Environmental Health Risk Assessment on MMT ....................................................................................... 11
MMT Concentrate Handling and Dosing: Environmental Impact Assessment (EIA) Process .................. 11
Manganese Exposure Assessment .............................................................................................................. 11
Exhaust Gas Emission Tests ....................................................................................................................... 12
4
ANALYTICAL FRAMEWORK .................................................................................................................................................................. 12
4.1 REVIEWING THE PROCESS: EVIDENCE OF A PRECAUTIONARY APPROACH? ..................................................... 12
4.2 LESSONS LEARNT AND UNANSWERED QUESTIONS ........................................................................................ 14
4.3 CONCLUDING THOUGHTS ............................................................................................................................... 15
REFERENCES...................................................................................................................................................................................................... 17
APPENDIX 1 – EVIDENCE OF UNCERTAINTY REGARDING THE USE OF MMT ............................................................................... 18
APPENDIX 2 – LRC CONCERNS REGARDING MMT WITH RESPONSES BY ETHYL ........................................................................ 19
- ii -
1 Introduction and Overview
This case study reviews the activities of Sasol, a South African based multinational petrochemical
company, relating to the phasing out of leaded fuel in South Africa. An important objective of the
study is to assess the extent to which Sasol may be seen to have applied a precautionary approach
(in accordance with Principle 7 of the Global Compact) in its decision and subsequent activities
regarding the use of MMT as a fuel additive. In so doing, the case study seeks to contribute to an
improved understanding of some of the issues associated with the interpretation and application of
the precautionary approach, and to share experiences on the lessons learnt for traditional decisionmaking processes in the corporate sector.
1.1 Company Profile
The Sasol Group of companies comprises fuel, chemical and related manufacturing and marketing
operations; these are complemented by coal-mining operations, and by oil and gas exploration and
production activities. The largest Sasol operation converts coal into value-added synfuels and
chemicals using Fischer-Tropsch process technologies. From 2004 onwards, Sasol will be using
natural gas as a primary feedstock for chemicals in South Africa. The company is also currently
developing an international gas-to-liquids (GTL) venture based on their unique Slurry Phase
Distillate process.
Sasol employs more than 30 000 people and in the 2002/03 financial year had a turnover of more
than US$ 7 billion. The Group is listed on the Johannesburg Securities Exchange (JSE) and the New
York Securities Exchange (NYSE), with a market capitalisation (in 2002/03) of more than US$ 7.5
billion. Sasol is a signatory to the international chemical industry’s Responsible Care initiative, and
has been active in terms of implementing accredited environmental management systems and
undertaking sustainability reporting. Due to the nature of its activities, the company is under regular
scrutiny by local and international NGOs. In 2000, the Group Executive Committee adopted
sustainable development as a strategic business philosophy and a number of steps have
subsequently been taken towards integrating sustainable development as a management imperative
throughout the Group. An overview of the company’s sustainability performance is provided in
their latest GRI-based sustainable development report (Share it with Sasol) available from the
company website: www.sasol.com
Sasol supplies 42% of all the transportation fuel in South Africa, the bulk of which is produced
through conversion of coal using the Fischer-Tropsch process technologies. In terms of a supply
agreement that ends this year, Sasol supplies 100% of the fuel in the Gauteng province of South
Africa, the inland industrial and commercial hub of the country, as well as to surrounding
provinces. Due to the nature of its unique refinery processes, Sasol’s petrol and diesel has
significantly lower levels of sulphur than the fuel that is supplied (in the other regions of the
country) by the other oil companies.
1.2 Statement of the problem to be solved
The case study seeks to address the following questions in the context of Sasol’s decision – and its
subsequent activities – relating to the phase out of leaded fuel in South Africa:
 What does the precautionary approach / principle1 mean in practice?
 How was the precautionary approach understood and applied in this circumstance?
 What are the main lessons to be learnt from the experience evidenced in this case study?
 What unanswered questions and concerns are raised by this study that may have a bearing on
similar future efforts by companies that may seek to adopt a precautionary approach?
Page 1
2 Understanding the Nature of the Issue
2.1
Sasol and the Phasing out of Leaded Fuel – Background
For decades, refiners have added tetraethyl lead (TEL) to petrol as a cost-effective means of
increasing octane. TEL also provides engines with lubrication benefits and prevents valve seat
recession in older vehicles. There are however a number of recognised health concerns regarding
lead, including in particular that it impairs the development of brain function in children, and
contributes to cardiovascular disease and premature mortality in both adults and children. 2 As
regards the use of leaded fuel, concerns have been raised that this is the largest source of exposure
to lead in most urban areas, estimated at accounting for up to 90% of airborne lead in some
developing country cities. Lead has also been shown to damage catalytic converters, thus negating
their contribution to improved air quality. As a result of these concerns, there has been a growing
move internationally to phase out leaded fuel. Various initiatives are currently underway regarding
the phase-out of leaded fuel in Sub-Saharan Africa, which is one of the few areas in which the use
of leaded fuel is still widespread. Last year, long after the introduction of MMT, South Africa
committed to phasing out leaded fuel by 2006.
Unleaded fuel (ULP) was first introduced in South Africa in 1996, primarily for technical reasons,
the main driver being to meet the needs of imported vehicle technology. By 2000, five years after its
introduction, the market penetration of ULP was only 15%, as against an expected initial
penetration of 30%. Several reasons have been cited for this lower than anticipated level:
 Many consumers believe that the lower octane of ULP affects their vehicle’s performance;
 There is the concern that older technology vehicles – constituting a large percentage of South
African vehicles – need lead to prevent valve seat recession3;
 Unlike in most of the rest of the developed world, unleaded petrol was not more cost effective
to the consumer due to a lack of subsidies; and
 Finally, there is the concern that exhaust gas emissions from the vehicles that lack catalytic
converters – the majority of the South African fleet – are higher for ULP than for leaded fuel.
It was in this context, and with the aim of promoting greater penetration of unleaded fuel, that Sasol
chose in October 2000 to introduce MMT – a cost-effective but controversial manganese-based
octane improver (see Box 1) – as an additive in their refinery process for unleaded petrol.
Understanding Sasol’s Motivations Regarding Unleaded Fuel and MMT
Sasol’s decision to promote the use of ULP was in response to the international move towards
phasing out leaded fuel, and in particular to the need to conform with the requirements of new
vehicle technology. In addition to this technical driver, there were also seen to be broader marketing
opportunities in linking the promotion of ULP to Sasol’s general marketing focus on providing
cleaner fuels. As a result of the Fischer-Tropsch and gas-to-liquid process technologies, Sasol’s
petrol and diesel both have significantly lower levels of sulphur than that of local competitors,
offering a distinguishing feature. An important additional consideration underlying Sasol’s decision
to increase the supply of ULP by using MMT relates to the fact that in terms of existing licensing
agreements Sasol is only permitted to use a single Sasol-branded pump in the service station
forecourts of other oil companies. With the ability thus to supply only one grade of petrol per
service station, and with the increasing market shift towards ULP, there were clear advantages in
supplying ULP that could be used in both new and old cars. This would result in savings associated
with providing only one product line, and was also particularly relevant as a large proportion of
Sasol’s customer base drive older vehicles where concerns for valve seat lubrication are prevalent.
Page 2
Box 1 – MMT: A cost effective octane booster or Pandora’s Box?
Methylcyclopentadienyl Manganese Tricarbonyl (MMT) is an organic manganese compound fuel additive
that is used to boost octane levels in gasoline and diesel fuels. MMT was developed by Ethyl in the 1950s to
reduce common engine knock in automobiles. MMT has been used in leaded petrol for more than 30 years
and in unleaded petrol for more than 25 years. It is currently approved for use in various countries. 4
Cited Benefits of MMT
The following benefits have been cited for the use of MMT:
 Provides a cost-effective source of petrol octane increase
 Reduces the amount of crude oil needed during the gasoline refining process and lowers emissions from
refineries, including reducing greenhouse gases by up to 20%
 Reduces overall tailpipe emissions, including emissions of nitrogen oxide and carbon monoxide
 It is compatible with fuels used in vehicles equipped with advanced emissions control technologies, and
maintains the performance of catalytic converters
 Helps refiners to lower aromatics and hence benzene levels
 Provides protection against valve seat regression in older cars designed to use leaded gasoline
 Can result in greater immediate unleaded capacity, particularly in regions (such as South Africa) that have
a large older fleet; to the extent that MMT permits this change, its use will result in lower exposure to
atmospheric toxics such as benzene
Concerns regarding the use of MMT
Despite these cited benefits, various observers and interested parties have expressed a number of concerns
regarding MMT, with some suggesting that the use of MMT could “open a Pandora’s box of other
problems.” These main concerns may be divided into two broad categories: environmental health concerns,
and technical concerns regarding the impact of MMT on vehicles. Following is an outlines of key concerns:
 The known neurotoxicity of manganese at high (occupational) exposure levels has led to concern
regarding the use of MMT as an additive, particularly given the experience with lead
 Concerns have been expressed regarding the impact on vulnerable populations (such as those with high
workplace exposure, children, the aged, and those with pre-existing neurological disease)
 The potential for an increase in exposure and absorption particularly in locations of greater concentration
of vehicle emissions
 Concerns were raised regarding the difference between South African urban areas and those in North
America and Europe, the suggestion being that this could have detrimental implications for SA
 Finally, there are concerns that the manganese that is not emitted from the tailpipe can damage spark plugs
and exhaust catalysts; this underlies the position of the World Wide Fuel Charter against MMT
Section 3 of this report examines how Sasol has sought to address these concerns within the scope of its
commitment to using a transparent decision-making process relating to the use of MMT. A table outlining
these concerns, with responses by Ethyl, is included in Appendix 1.
On the basis of a detailed examination of alternative non-lead octane boosters, as well as an initial
techno-economic study of MMT, Sasol regarded MMT as the preferred option. The following
attributes of MMT were seen to be particularly pertinent in this regard:
 It provided Sasol with a cost-effective5 means of increasing the octane of unleaded fuel,
enabling Sasol’s Synfuel plant to substantially increase unleaded petrol capacity with
minimum capital investment.
 The use of MMT meant that Sasol could convert all their existing pumps (constituting 15% of
total fuel sales) to unleaded “dual fuel” usable by all vehicles.6 The switch would thus result
in an immediate 15% increase in ULP usage inland. Introduced at a maximum of 18 mg/
manganese, as compared to the current lead content of up to 400 mg/ for leaded petrol, this
Page 3


allowed refineries to reduce lead in their petrol pools by a factor of five for each part
manganese, resulting in immediate environmental benefits.
There were seen to be benefits through the life cycle as compared with some of the other
alternatives; this included for example reduced use of crude at the refinery stage resulting in
reduced refinery emissions, as well as minimising the potential environmental health impacts
associated with using ULP in cars without catalytic converters.
Finally, the fact that MMT has been in use in Canada for more than 20 years, and had been
approved by the US EPA, was seen as an important affirmation.
Recognising that there were some concerns and uncertainties regarding the use of MMT, and
notwithstanding the fact that MMT had been approved for use in various OECD countries, Sasol
had decided from the outset to follow a transparent process and to identify and respond to
stakeholder concerns, with the aim of ensuring the responsible introduction of MMT into the South
African market. This decision was undertaken in the absence of any legal guidelines or
requirements on fuel additives, and was seen to be the first time that such a route was followed in
South Africa for the introduction of a fuel additive. This approach was seen to be in keeping with
precautionary principles as embodied in South Africa’s National Environmental Management Act,
apparently “not in an attempt to comply with specific legislation, but as part of its commitment to
the Responsible Care approach to Product Stewardship.” 7
2.2
The Precautionary Approach – Understanding the issues
An important objective of the study is to assess the extent to which Sasol may be seen to have
applied a precautionary approach (in accordance with Principle 7 of the Global Compact) in its
decision and subsequent activities regarding the use of MMT as a fuel additive. In so doing, the case
study seeks to contribute to an improved understanding of some of the issues associated with the
interpretation and application of the precautionary approach, and to share the lessons learnt for
traditional decision-making processes in the corporate sector.
The precautionary principle is a notoriously contentious issue, and one that has bedevilled the
negotiation of multilateral environmental agreements, with considerable debate evidenced in
particular in the differing positions of negotiators in Europe and North America. While it is
recognised that there is a distinct difference between the “precautionary approach” and the
“precautionary principle”8, it is suggested that for the purposes of this case study there is merit in
applying a more encompassing approach. For this reason, references in this document to the
precautionary approach are seen to include the provisions of the precautionary principle. (It is
noted that Principle 7 of the Global Compact makes explicit reference to the – arguably less
ambitious – precautionary approach).
Using this broader understanding, it is understood that application of the precautionary approach
demands that precautionary action is undertaken in those instances where there are credible threats
of harm to human health or the environment, notwithstanding the existence of residual scientific
uncertainty about the cause and effect relationships. Strict application of the principle places an
obligation on the proponents of particular activities to take a risk averse approach when there is
credible evidence that it may be harmful to human health or the environment, even if the nature of
that harm is not fully understood.
Page 4
What are the implications of implementing the precautionary approach?
"When an activity raises threats of harm to human health or the environment, precautionary measures
should be taken even if some cause and effect relationships are not fully established scientifically. In this
context the proponent of an activity, rather than the public, should bear the burden of proof. The process
of applying the Precautionary Principle must be open, informed and democratic and must include
potentially affected parties. It must also involve an examination of the full range of alternatives, including
no action."
1998 Wingspread Statement
Building on the above definition used in the 1998 Wingspread Statement, as well as on the approach
adopted in the European Commission Statement on the Precautionary Principle, it is suggested that
a precautionary approach essentially encompasses the following five broad sets of activities: 9
1. The first step is to assess whether in fact the precautionary principle should be invoked. This
requires that the potentially negative effects are identified, and that the scientific data relevant
to these risks is evaluated. The precautionary principle is only invoked when, due to the
insufficiency of the data or their inconclusive or imprecise nature, it is impossible to determine
the risk in question with sufficient certainty.
Once it has been decided on the basis of this evaluation that the precautionary approach is required,
then it is suggested that the following precautionary activities should be implemented:
2. Undertaking an assessment of the alternative options, noting the environmental, health and
economic costs and benefits of each approach
3. Adopting a transparent, inclusive, and open decision-making processes that involves
interested parties in the study of the various risk management options
4. Implementing an ongoing process of research and monitoring, with the decision/s periodically
re-examined, based on any new available information
5. Implementing the proportionality principle, such that the costs of action to prevent hazards are
not disproportionate to the likely benefits in both the short and term
The following section reviews the extent to which each of the above elements associated with the
implementation of the precautionary approach were followed in the context of Sasol’s approach to
phasing out unleaded petrol, and to using MMT as part of this solution.
3 The Case Story: Implementing the precautionary approach?
3.1
A sufficient basis for invoking the precautionary approach?
“Whether or not to invoke the Precautionary Principle is a decision exercised where scientific
information is insufficient, inconclusive, or uncertain and where there are indications that the possible
effects on the environment, or human, animal or plant health may be potentially dangerous and
inconsistent with the chosen level of protection.” European Commission (2000)
As outlined in the previous section, the first question to be asked (in this instance as regards the
proposed use of MMT) is whether in fact it is necessary for the precautionary principle to be
invoked. This requires that the various potential negative effects are identified, and that the
scientific data relevant to these risks is evaluated. If there are seen to be credible threats of harm,
notwithstanding the existence of residual scientific uncertainty, then the precautionary principle
demands that precautionary action be undertaken.
As part of their overall assessment of alternatives to leaded fuel Sasol undertook an initial technoeconomic study of MMT. Completed in 1996, this study, which included various specification and
Page 5
performance tests, indicated that MMT was a desirable option. In addition to this techno-economic
study a review of the international experiences with MMT was also conducted. This international
study included discussions with oil companies, motor manufacturers, motor vehicle service
departments and health departments, as well as a review of the literature, affidavits, testimony,
technical reviews and public and media reaction to legal cases involving MMT. While this review
showed that the use of MMT was technically acceptable, it also highlighted that it was a
controversial option, with international motor manufacturers and various environmental health
NGOs campaigning against its use. Recognising this controversy, the international review included
a detailed analysis of the US EPA’s court cases involving the approval of MMT for unleaded
gasoline in the US (1995), as well as the Government of Canada’s decision to continue to allow the
use of MMT in Canada (1998). Recent government approvals in the UK (1999), France (1999) and
China (1999) were also examined. Following the resolution in 1998 of the restrictions on the use of
MMT in Canada, Sasol decided there was a sufficient case to proceed with using MMT.
An important contributing factor for this decision was the findings of a personal exposure study
undertaken by the Research Triangle Institute in Toronto, Canada (where almost 100% of the
unleaded gasoline contains MMT). Constituting one of the largest studies on personal exposure ever
undertaken on a product, the study found that the inhalation intake of all components of the
population in Canadian urban centres where there are no major manganese emitting industries, is
less than 50% of the tolerable daily intake. The assessment included infants, elderly and those
heavily exposed because of occupation or proximity to roads. No correlation was evident between
levels of respirable manganese (PM10 or PM2.5) and MMT sales or use. The conclusion of Health
Canada based on the study – namely that “airborne manganese resulting from combustion of MMT
in gasoline powered vehicles is not entering the Canadian environment in quantities or under
conditions that may constitute a health risk” (Health Canada, 1998) – coupled with the fact that
Canada has used MMT for the past 20 years, had an important bearing on Sasol’s decision.
While this international experience may be seen by some as constituting a sufficient basis for a
“reasonable decision” based on “sound science”, for others10 there was still seen to be sufficient
uncertainty and cause for concern to invoke the precautionary principle and to avoid using MMT
pending further clarity. A number of organisations and individuals have thus maintained that further
studies are required on the health and environmental impacts of MMT, and that the burden of proof
should be on the suppliers of the fuel to show that such harm is not caused, before MMT is allowed.
In this regard, a set of specific issues for South African conditions have been identified as areas
requiring further additional study before MMT could be introduced in South Africa (Appendix 1).
Pending answers to these questions, it is has been argued that “it would be prudent to err on the side
of caution before putting quantities of manganese irretrievably into our environment.” (Myers J;
2000). Most of these issues were included in written comments submitted by the Legal Resources
Centre, and are provided in Appendix 2 with a response from Ethyl.
As is demonstrated by the brief selection of quotes in Box 3, there are some strongly diverging
perspectives on the application of the precautionary principle in the context of MMT. These
differences in outlook raise some important and potentially difficult questions for corporate
decision-makers in determining whether or not the precautionary principle should be invoked:
 At what stage is the available scientific information no longer deemed to be “insufficient,
inconclusive, or uncertain”?
 What actions are required by the proponent of the activity to provide assurance of this? And
how feasible is it to provide sufficient data that something is not a threat?
 How does one judge an “acceptable” level of risk for society? And who should judge this?
Page 6

Influence and role of regulatory requirements?
Box 2 – Perspectives on Invoking the Precautionary Principle in the Context of MMT
The following statements provide an indication of the differing perceptions as to whether the precautionary
approach should be invoked for MMT.
The need for further precaution?
“… There is still an important lack of adequate toxicological information (on MMT) and further studies are needed to
provide successful implementation of evidence-based risk assessment approaches.” Zayed (1999)
“… it should be noted that the automotive industry and most petrol refiners are, and have consistently been, opposed to
the introduction of MMT in SA, and particularly in the USA. Whatever their motives – be they investment in other
octane enhancing technologies or product lines – their opposition does cause one to think more broadly about risk
characterisation… Put together with the precautionary principle one is immediately led to the notion that other
technologies should be seriously considered along with costs and benefits to various affected parties.” Professor Myers,
Director of Occupational and Environmental Health Research Unit (University of Cape Town).
“Because of the continuing debate, we believe that there remains a need for suppliers of the fuel and/or additives, when
used in petroleum products, to provide satisfactory evidence that ‘no greater harm will result from the fuel when the
additive is included…’ We believe that the onus should be on the supplier of the fuel to prove the above claim and that
the additives should be prohibited unless satisfactory evidence is supplied…” Australian Automobile Association
(January 2001)
“While it is true that the EPA does not have data showing MMT to be a threat, the lack of data is exactly the problem.
EPA does not have data proving MMT is not a threat… EPA believes that the American public should not be used as a
laboratory to test the safety of MMT. EPA believes more testing should be done before cars across the country begin
emitting into the air this additive – which contains the heavy metal manganese.” US EPA Press Release (March 1996)
Sufficient data for a reasonable decision?
“Measures based on the precautionary principle must not be disproportionate to the desired level of protection and
must not aim at zero risk, something which rarely exists.” European Commission (2000)
“The precautionary principle might apply in instances when data do not exist. This is not the case for MMT in
gasoline. Much information exists, probably more that for any fuel or fuel additive in history. An independent risk
assessment, which addresses many of these items, has been prepared by an independent risk assessor for South African
conditions. The conclusions of the risk assessment are the same as those arrived at by Health Canada, the Committee
on Toxicity in the U.K. and the Ecotoxicity Commission in France, i.e. MMT is safe to use.” Ethyl – Memorandum
responding to concerns raised by the Legal Resource Centre
“Studies indicate that 20 years of MMT use in Canada have presented no health hazard to the general public. And to
deny consumers the benefits of innovative, beneficial products while forcing companies to prove the impossible – that
their product is completely safe and absolutely risk free – is a prescription for disaster… The real hazards apparent in
the MMT story are not exposure levels but fear – fear created by the exaggerated and erroneous propaganda of MMT’s
opponents and by the EPA’s efforts to disallow a product with a history of safe use.” American Council on Science and
Health 1998
Notwithstanding the fact that MMT has been subjected to numerous studies and approved for use in
various OECD countries, Sasol – recognising these uncertainties regarding the use of MMT –
undertook to adopt what may (arguably) be seen as a precautionary approach. This included
assessing alternatives, entering into dialogue, and undertaking ongoing research and monitoring.
3.2
Assessing the alternative options
In seeking to meet the increasing need for ULP supply in South Africa, the technical department of
Sasol has, since the early 1990’s, examined some of the possible alternatives for non-lead octane
boosters. In reviewing these alternatives, the following issues need to be considered:
 Ensuring appropriate octane levels, particularly in the context of high altitude;
 The nature and cost of any required modifications to refineries;
 The implications for new vehicles, and the potential impact on catalytic converters;
Page 7


The need to protect against valve seat recession in older vehicles;11 and
Implications for the existing fuel distribution network
While each of the alternatives to leaded fuel are deemed to be better than lead in terms of impacts
on health, they are all seen to have their own specific drawbacks. For example, while organic
compounds such as aromatics and other ethers are an option, there are concerns that the resulting
higher benzene emissions may increase risks of cancer and water contamination. Similarly, while
increased ethanol blending has been successfully used in Brazil, various concerns have been cited
regarding the economic feasibility and technical merits of a transition to more widespread ethanol
use in South Africa. And although alternative metallic additives to lead can be used (such as MMT),
concerns have been expressed regarding their possible impacts on health and automotive equipment.
Finally, the most common route taken in other countries has been refinery modifications and
upgrades, but these are often the most expensive option facing petroleum companies.
It is not within the scope of this paper to evaluate in detail the various alternative options that were
available. Such an analysis requires a detailed technical appreciation and economic assessment of
the alternatives. At the level of principle, a key consideration is to assess the extent to which
provision was made for balancing environmental, health and socio-economic considerations in
evaluating the various alternatives, and the degree to which these were seen to be a motivating
factor in the final decision.
3.3
The process of stakeholder consultation 12
Sasol has stated that it was committed from the outset to follow an inclusive and transparent process
regarding the introduction of MMT in South Africa. This commitment was made in the absence of
any regulatory requirement for stakeholder participation, and was seen to be undertaken as part of
their commitments as a signatory to the international chemical industry’s Responsible Care
initiative. Key stakeholders were identified and their attitudes to the proposed introduction of MMT
were determined. This process also served the important purpose of obtaining internal alignment
within Sasol, as well as providing greater awareness of the potential risks involved. Following is a
brief outline of the stakeholder process that was undertaken.
Initial Government Interaction
Sasol had a number of initial interactions (meetings and correspondence) with the Department of
Minerals and Energy Affairs and the Department of Environmental Affairs and Tourism, in which
they advised the government of the process that they proposed to follow in the absence of any
regulations. At a meeting at Chief Director level it appeared that the Departments were satisfied
with this proposed process. They indicated that they would consult with other departments before
replying with a formal position. No position statement was forthcoming. Following stakeholder
pressure on government, a number of additional interactions later took place between Sasol and the
government. These are outlined below.
Customers: Oil Companies
Sasol held a number of individual and collective meetings with each of the oil companies in South
Africa with the aim of understanding and responding appropriately to their concerns.13 During the
discussions it became apparent that each of the oil companies had their own internal positions
regarding the use of MMT. In one case14 there was a corporate policy of not supporting the addition
of any metals to petrol, while in other cases the position on MMT was more ambivalent, in some
stances with own in-house tests and evaluations being conducted.15 A common concern expressed in
these discussions related to the position of vehicle manufacturers16 against the use of MMT.
Page 8
Acknowledging these concerns, the participants supported Sasol’s proposal to conduct a Health
Risk Assessment for South African conditions.
After the various consultations, Sasol sent a letter to each CEO of the various oil companies,
responding directly to their specific concerns. The letter notified them that MMT was to be added at
the refineries, ending with the statement: “Sasol trusts that this response addresses your company’s
concerns adequately, and further that it enables you to accept our decision.” In the replies that were
received, none expressed opposition to Sasol’s contractual right to add MMT, and no “substantiated
technical opposition” was raised. Concerns were however again expressed regarding the opposition
of NAAMSA, as well as the potential opposition of environmentalists. Final meetings were then
held with all the oil company CEOs to confirm the date of introduction of MMT. Most of the South
African refineries has subsequently begun using MMT as part of their unleaded petrol production.
Motor Vehicle Manufacturers and Marketers
Global automobile and engine manufacturers have consistently expressed opposition to the use of
MMT in fuel, citing concerns that the manganese that is not emitted from the tailpipe can cause
spark plug misfire and damage catalytic converters. This position is expressly stated in the third
edition of the auto industry’s World-Wide Fuel Charter (WWFC), an international initiative aimed
at harmonising fuel quality world-wide in accordance with vehicle needs. This position is disputed
by Ethyl, the supplier of MMT, who maintain that this has not been proven, and that it has been
rejected by various experts, governments and court decisions. In response to these concerns, Sasol
arranged for Ethyl to inform OEM’s of the latest results of their tests regarding the impact of MMT
on catalytic converters. Sasol also held a series of meetings with motor manufacturers, during which
they requested manufacturers to identify specific technical concerns to be further examined and
addressed as required. Other than expressing solidarity with the WWFC, no specific concerns were
raised and no further tests were called for. Following a meeting with the National Association of
Automobile Manufacturers of South Africa (NAAMSA) Sasol undertook to compensate vehicle
owners in the event of compatibility and performance problems in their vehicles shown to be due to
MMT, as well as to review the use of MMT on a biannual basis (every two years).
Fuel Retailers
The two fuel retailers associations, the FRA (Fuel Retailers Association) and SAFDA (South
African Fuel Dealers Association), were informed of MMT and the benefits related to its use in the
South African context. They indicated that it was acceptable to them.
Motorists represented by the Automobile Association of SA (AA)
Information sessions were held with the AA at various levels. The AA indicated that the
performance data related to the usage of MMT backed by the Sasol’s undertaking to support
motorists if they experienced problems due to the usage of petrol with MMT was acceptable. They
recognised Sasol’s co-operation and suggested that Sasol should handle enquiries with a toll-free
line. This line was subsequently set up at the AA call centre.
The Media
A number of sessions were held with the motoring, financial and environmental media informing
them of technical details of MMT and the positive benefits for South Africa and South African
motorists. The response of most of the motoring and financial journalists was that it was not an
issue worth publishing. A number of environmental journalists however opposed Sasol’s plans. In
one case where the article was seen by Sasol as being sufficient to create significant public concern,
Sasol entered into discussions with the journalist to correct the facts and a retraction was
subsequently obtained.
Page 9
The Legal Resource Center (LRC)
The Legal Resource Centre, a public interest law unit, became involved in the MMT debate by
informing environmental journalists of possible health risks and by issuing a legal demand to DME
to require a full environmental impact assessment (EIA) for the introduction of MMT. Sasol
responded by informing the LRC that, on the basis of internal and external legal opinion, an EIA
was not required in this instance. This position was later supported by the Department of
Environmental Affairs and Tourism, who agreed with Sasol that a Risk Assessment was a preferred
approach. In a subsequent meeting between Sasol and the LRC, the LRC indicated that a primary
concern of their intervention was to test the process to be followed for the introduction of new
products or additives into the market place. Expressing concerns with self-regulation, the LRC
proposed requirements that Sasol agree to a lower manganese level and to a defined period of use.
While Sasol underlined their commitment to a monitoring process and a biannual review of MMT
use, they rejected these specific requirements, arguing for example that a decision to remove MMT
should be later reviewed on the facts at the time. The LRC later telephonically responded that they
would no longer oppose the addition of MMT to South African petrol. (A summary of the main
concerns raised by the LRC, with responses by Ethyl, is provided in Appendix 2).
Subsequent government interaction
At the same time as these interactions were taking place, various stakeholders – including BP, the
National Association of Automobile Manufacturers of South Africa and the Legal Resource Centre
– expressed their concerns to government regarding the use MMT. In a resulting meeting between
Sasol, DEAT and the LRC, that was held as MMT was beginning to be dosed at the refinery, DEAT
stated that they had some (unspecified) concerns regarding the health risk assessment that Sasol had
commissioned. In a subsequent letter to Sasol, the Minister of Environmental Affairs and Tourism
“implored” Sasol to commit to a number of actions in line with provisions of the National
Environmental Management Act. These included: submitting for approval a protocol to undertake
baseline measurements on manganese levels in cities prior to introducing MMT; implementing a
programme to monitor manganese levels subsequent to its introduction; and an annual review of
independently audited results to determine the continued use of MMT or its discontinuance. In their
reply, Sasol reiterated their previous stated commitments to undertaking a repeat monitoring study
and to annually reviewing the dosage level of MMT and possible corrective actions.
Sasol’s commitments
During the process of consultation, Sasol undertook to meet the following commitments:
 To limit the use of manganese to a maximum of 18 mg/ in ULP that may contain 13 mg/
lead (as compared with 400 mg/ in the leaded petrol that it replaces);
 To undertake a baseline study of personal exposure to airborne manganese before introducing
MMT; this was undertaken by an expert third party, using an approach similar to that used in
the USA, Canada and the UK as required by their regulatory authorities;
 To employ an independent expert to undertake a repeat monitoring study comparable to the
baseline study one year after introduction of MMT to establish whether the risk assessment
and international experience is valid for SA;
 To biannually review the dosage level and possible corrective action based on objective and
meaningful criteria for the SA situation;
 Entering into an agreement with NAAMSA in terms of which Sasol has undertaken to
compensate for any vehicle problems that may arise due specifically to the use of petrol with
MMT in as far as it differs from typical South African fuel without MMT; and
 To withdraw MMT if it is proven to be a cause for concern.
Page 10
3.4
Assessing the risks
In addition to the above process of consultation, and largely in parallel with that process, Sasol
undertook a number of activities aimed at identifying the relevant risks associated with the use of
MMT. These included an independent environmental health risk assessment, an EIA for the dosing
installation, an independent manganese exposure assessment and various exhaust gas emission tests.
Environmental Health Risk Assessment on MMT
An independent health risk assessment of the use of petrol with MMT in South Africa was
completed in June 2000, before the above-reviewed stakeholder process was undertaken. The study
found that the addition of MMT to petrol would not negatively effect vehicle gaseous emissions,
and that the levels of manganese emitted from exhausts would result in exposure substantially
below levels specified by the WHO as being acceptable level for a lifetime of exposure (Infotox;
2000). The study also found that MMT would not pose an additional risk in the event of petrol
spills, nor as regards occupational exposure at filling stations, concluding that there were no healthrisk based reasons why MMT should not be added to South African petrol. The study was a public
document and was made available to all the oil companies, DME, DEAT, motor manufacturers and
the LRC. Critical comments on this risk assessment were received from Ford (Ford; 2000), and
from the Director of the Occupational and Environmental Health Research Unit at the University of
Cape Town (Myers; 2000). Key concerns cited of the Risk Assessment included that:
 It focuses on oxides of manganese, and not on manganese phosphates and sulphates which are
seen to be the main forms of tail-pipe emissions and which are much more soluble in water.
 It “makes no attempt to assess the impact of MMT or the combustion products on wildlife and
plant fauna.”
 “The combination of misleading statements, selective quoting from the scientific literature
and the recommendation for use of the higher two of the three existing guidance levels…
reveals (a) particular bias”
 The exposure data from Canada cannot be taken as representative for South Africa and the
assumption that 0.04g/m3 “should be assumed for the modelling process undertaken in the
report… seems to invalidate all the modelling detail that follows.”
The author of the Risk Assessment had provided a detailed written response to the concerns raised
by Ford. Some of the principal technical concerns and calls for further research raised by Myers, are
similar to those raised by the LRC, briefly reviewed in Appendix 2 below.
MMT Concentrate Handling and Dosing: Environmental Impact Assessment (EIA) Process
An EIA was followed for the installation of the dosing facility at the Sasol refineries, covering the
handling of MMT and its dosing to petrol. An exemption was applied, and approved, on the basis
that handling MMT is no different as for certain other refinery chemicals, such as tetraethyl lead.
Manganese Exposure Assessment
In April 2000, an independent South African company conducted a baseline personal exposure
study on airborne manganese, using an approach similar to that used in the USA, Canada and the
UK as required by their regulatory authorities. The monitoring in South Africa involved 20 selected
persons identified as belonging to the highest potential exposure groups (namely parking lot
attendants, taxi drivers, and couriers). Each person carried around a monitor, 24 hours a day. The
study found that the individuals had average exposures significantly below levels set by the WHO
as being safe for a lifetime of exposure, and comparable to levels in other cities internationally. The
study was repeated within a year of the introduction. Of the twenty subjects monitored in 2000, ten
Page 11
participated in 2002; the other ten were either not available or chose not to participate, so another
ten people were chosen as replacements. For the entire cohort, the exposure to PM2.5 and PM10
manganese were found to be marginally lower in 2002 (following introduction of MMT) than in
2000 (prior to introduction). All other measured parameters were also slightly in the same direction.
For the ten individuals that participated in both years, the exposures to PM2.5 and PM10 manganese
did not change year-to-year. For these ten individuals the only change was in PM2.5 aluminium
exposure, which was slightly lower in 2002. The manganese exposures found in South Africa are
about the same as found in other countries during similar studies.
Box 3 – Separate Baseline study of Mn Levels in Blood
A separate cross-sectional analytical study was recently performed in schools in Cape Town and
Johannesburg to measure mean blood manganese concentrations. The report of this study has only been
distributed for discussion and not for circulation or quotation (and thus the authors are not cited here).
The primary findings of the study were that manganese in blood was shown to be statistically associated
with manganese in dust at the schools, and that blood levels were higher in Johannesburg than in Cape
Town. The researchers noted that MMT had been introduced to petrol in the Johannesburg region 24
months prior to the survey. Although this is not explicitly stated the report is seen to infer that that there
could be an increase in the potential for health risk associated with the use of MMT in the Johannesburg
region. This suggestion has however been criticised for its failure in particular to consider the impact of
what is generally the largest source of exposure to manganese, namely food, especially in the context of
potential differences in diet in the two regions. The observation is also made that many publications have
failed to confirm a clear relationship between manganese in blood and occupational (high-level)
inhalation exposures, and that correlations are generally too weak to be used for individual biological
monitoring; hence there was some surprise with the correlation cited from this study. (van Niekerk; 2003)
Exhaust Gas Emission Tests
Sasol undertook a comprehensive set of exhaust gas emission tests in which they compared petrol
containing MMT with typical current unleaded petrol. This was tested in vehicles representing the
range of technologies in South Africa. The results showed that the use of three-way exhaust
catalytic converters was the most significant factor in improved air emissions. Sasol petrol with
MMT was found to result in the following emission improvements: an average 10% reduction in
hydrocarbon emissions; an average 15 % reduction in carbon monoxide; an average 3% reduction in
nitrous oxide emissions; and a marginal improvement in carbon dioxide emissions. Ageing tests of
three-way catalytic converters were conducted up to 75 000 kilometers. This found that catalyst
ageing was up to 50 % less with Sasol’s MMT petrol than unleaded. (Goosen et al, 2002).
4 Analytical framework
4.1
Reviewing the process: Evidence of a precautionary approach?
On the basis of the above review – and using the outline of the precautionary approach proposed in
section 2.2 – it may be argued that the process that Sasol adopted regarding its decision to use MMT
may be seen to reflect a precautionary approach. Activities that support this suggestion include:
 Undertaking a comprehensive evaluation of the risks and benefits of the various alternatives
throughout the life cycle of the alternative products;
 Undertaking a thorough review of the international experience of MMT, with the aim of
understanding the nature and risk level of the potential negative effects;
 Choosing to implement a process of consulting with key stakeholder groups aimed at
identifying and responding to their concerns relating to the use of MMT, notwithstanding the
Page 12



absence of any regulatory guidelines and despite indications from the international review that
there was arguably a sufficient basis to use MMT;
Commissioning a health risk assessment in South Africa, as well as undertaking relevant
baseline studies and follow-up investigations, into the potential impact of MMT; various
conservative assumptions were seen to have been used in the risk assessments;17
Undertaking to compensate vehicle owners for any vehicle problems that may arise
specifically due to the use of petrol with MMT;
Committing to biannually review the dosage level and to implement possible corrective
action based on objective and meaningful criteria for the South African, as well as
undertaking to withdraw MMT if it is proven to be a cause for concern.
Despite these various activities, some interested parties have suggested that these are not sufficient
to constitute meaningful implementation of the precautionary principle.18 They argue for example
that there are still too many uncertainties regarding MMT, and that steps should be taken to prevent
“introducing a potential neurotoxin into a very efficient delivery system, automobiles” without first
proving that MMT will not cause harm.19 A number of specific issues have thus been identified as
requiring further study before MMT should be approved (See Appendix 1 and Appendix 2).
Questions have also been raised regarding the nature and timing of the stakeholder process. It has
been suggested, for example, that in terms of the strict application of the precautionary principle:
“The involvement of stakeholders… needs to begin at the beginning rather than being artificially
confined to the later ‘risk management’ stages of the conventional approach. The stages of hazard and
risk appraisal, management and communication are not sequential, as in the traditional model, but
require stakeholder involvement at the earliest stage.”20
In this regard, it has been acknowledged that there may have been scope for Sasol to start their
consultations earlier in the decision-making process. 21
To counter the suggestions that the full extent of the precautionary principle might not have been
applied, Sasol and others have drawn attention to issues associated with the “proportionality
principle” in terms of which “the costs of action to prevent hazards should not be disproportionate
to the likely benefits in both the short and long term.” (European Commission; 2000).
Implementation of this principle should include a consideration not only of the potential financial
and social costs associated with the alternatives, but also the costs associated with not implementing
the chosen option. A relevant consideration in this regard is the fact that Sasol’s decision to use
MMT resulted in an immediate increase in the use of unleaded petrol, with an ensuing significant
reduction in the concentration of heavy metals. It has been suggested that the extent to which
Sasol’s decision contributed directly to the more widespread phasing out of leaded fuel, particularly
in the context of a lack of economic incentives, should be seen as one of the principal benefits in
any “cost/benefit” assessment of alternatives.
Advocates of such a response may be tempted to argue that “to deny consumers the benefits of
innovative, beneficial products while forcing companies to prove the impossible – that their product
is completely safe and absolutely risk free – is a prescription for disaster.” (American Council on
Science and Health; 1998). Other, more cautious, observers however may wish to recall the
experience of CFCs, once praised for the significant benefits they were seen to deliver with lower
risk to the then current alternatives, but in fact were later found to cause ozone depletion.
Page 13
4.2
Lessons Learnt and Unanswered Questions
“The public tends to value science by its end purpose. If that purpose relates to human health, to human
well being generally, or to environmental safeguard, then it is given high rating. Where science seems to
pursue a narrow, and especially a commercial interest, then it is less approved of.” (Jenkins; 2000)
As this case study has demonstrated, companies that are seeking to implement the precautionary
principle / approach as part of any decision-making process, are likely to be faced with a number of
difficult and at times controversial questions (not to mention possible “terminological confusion”)
associated with the concept. On the basis of the brief review conducted in this case study, it is
possible to identify a number of important lessons learnt and unanswered questions regarding
efforts at integrating the precautionary approach within a company’s processes and operations:

The first key observation is that it is frequently difficult and potentially controversial to
determine whether or not the precautionary principle should be invoked. The experience in
this case study raises a number of important questions in this regard:
- At what stage can one assume that the available scientific information is no longer
“insufficient, inconclusive, or uncertain”?
- What actions are required by the proponent of the activity to provide assurance of this?
- How feasible for example is it to provide sufficient data that something is not a threat?
- And in assessing whether the principle should be invoked, how does one judge what is
an “acceptable” level of risk for society? As the European Commission puts it, this is an
“eminently political responsibility” and thus presumably in the purview of government
rather than the individual corporation.

This in turn raises the question of the extent to which the individual company – in applying
the precautionary principle – can reasonably be expected to take a leadership role in making
any required judgements in the absence of a decision from government, and in the context of
“positive” findings from an independent and transparent risk assessment process, particularly
when there are potential conflicts with commercial interests. This raises the question:
- In what circumstances (e.g. under what level of uncertainty), is it reasonable or feasible
to expect a company (in the absence of government) to move beyond the suggested
positive findings of a risk assessment?

An underlying lesson from this case study is that the adoption of an open and transparent
stakeholder process forms a critical component of implementing the precautionary approach.
An important question raised by this study relates to the stage in the decision-making process
at which stakeholders should be engaged. Some have suggested for example that meaningful
implementation of the precautionary principle would have required an earlier engagement of
stakeholders. Others have maintained that in the context of the Canadian experience and from
a pragmatic business perspective, Sasol’s approach may be seen as sufficiently precautionary.

In terms of the stakeholder engagement process that Sasol adopted, a number of the key
participants within Sasol have identified some important lessons for future initiatives:22
- At a general level, while it is acknowledged that stakeholder engagement processes may
be time consuming and resource intensive, there is nevertheless seen to be significant
potential for mutual benefits; for these to materialise it is important to see stakeholders
as potential assets and opportunities, rather than as liabilities and risks.
- The public often makes judgements based on perceptions, rather than on what may be
perceived as “sound science.”23 Taking the initiative with effective and transparent
communication can help to narrow the gap between perceptions and fact.
Page 14
- It is important to continue to solicit input from stakeholders and to be adaptable to
possible changes in stakeholder demands. Stakeholder concerns should be reviewed
regularly, with any associated action plans adapted as required.
- There are almost always going to be stakeholders who are unsatisfied with the proposed
outcome. It is important that these stakeholders are not dismissed, but rather that efforts
are taken to illustrate, in a non-patronising manner, how their demands might conflict
with other legitimate stakeholder needs.
- In a project of this nature, ongoing and appropriate communication with the media
should be maintained. They should be kept informed in an open and friendly manner,
minimising any potential for perceived technological arrogance.
- It is important to build networks and to promote the leverage of knowledge, resources
and expertise both within the Group, as well as externally, including in particular with
industry associations.

4.3
An observation that was raised by a number of the participants in this initiative is that the
precautionary principle may be invoked for purely political and/or commercial interests,
rather than with a genuine desire to minimise risk to the broader community. With the aim to
promote a more effective and “bias-free” decision-making processes, it has thus been
suggested that each of the various claims and counter-claims should all be assessed and
evaluated on the same basis. Comment by interested parties on the submissions of other
stakeholders should be facilitated, and full access should be provided to the other
stakeholders’ data and testing methodology. Ideally there should be independent peer review
of any claims and counter-claims, with minimal reliance use of anecdotal submissions.
Concluding thoughts
At the 2003 meeting of the World Economic Forum in Davos, Switzerland, the annual gathering of
the world’s business leaders identified three priority challenges facing the business community:
rebuilding trust in corporations; dealing with systemic risks (such as climate change and
HIV/AIDS); and promoting sustainable development. If business leaders are going to respond
meaningfully to each of these challenges, and demonstrate leadership in doing so, then they will
need to grapple with understanding and implementing the precautionary principle. Appropriate
implementation of a precautionary approach is fundamental to rebuilding trust, it underlies efforts to
deal with systemic risk, and in many instances is a critical component of promoting sustainable
development.
But as this case study demonstrates, a commitment to implementing a precautionary approach will
frequently result in difficult questions being asked of corporate decision-makers. Not only will they
be required to rethink some of the conventional parameters of risk, broadening it to include more
than “sound science”, but in many instances they may need to revisit any existing tendencies
towards a risk-denial mentality.
Page 15
Box 4 -Assessing Sasol’s activities against the Global Compact Performance Model
One of the issues raised for consideration in this case study is the extent to which Sasol’s commitment to the
Principles of the Global Compact is being internalised within the company. This box provides a brief review of
some of the main considerations as compared against the elements of the GC Performance Model.
At present Sasol’s various commitments to implementing the spirit of the UNGC principles is being achieved
largely through its exiting strategic commitment to sustainability, and through its implementation of such initiative
as Responsible Care, rather than through any specific effort at integrating the individual UNGC Principles. More
information is obtainable from Sasol’s Sustainable Development Report (www.sasol.com)
Vision: The commitment to implementing the main elements of a precautionary approach is consistent with the
company’s vision and five shared values. It is further reflected in the decision of Sasol’s Group Executive
Committee to formally adopt sustainable development as a strategic business philosophy, as well as its commitment
to implementing the provisions of the Responsible Care Programme.
Leadership and Resources: Various management structures are in place aimed at implementing the Group vision
and improving the global reach of sustainability governance throughout the organisation. A Board member has
specific responsibility for sustainability issues, and the Board receives advice on these matters from a high level
Group Risk and SH&E Committee.
Empowerment: The sharing of experience and development of sustainability related skills throughout the Group is
achieved inter alia through the Sasol’s global network of SH&E Communities of Practice, through the Corporate
SH&E Governance Audits, as well as through the annual internal SH&E Conference.
Policies and Strategy: The company has a corporate-wide SH&E Policy and Guidelines, as well as a set of Group
Indicators of Performance and 2005 Targets, one of which relates to achieve a high level of implementation of the
Responsible Care Codes of Practice throughout the Organisation.
Process and Innovation: The Sasol Vision includes a commitment to being innovative, which is further driven
through the Group Targets. This is exemplified by the nature of the Group’s ground-breaking research and
development activities. More recently there have been increasing efforts on promoting product stewardship efforts
throughout the Group.
Impact on society: Numerous stakeholder engagement and community outreach activities have been implemented
throughout the Groups’ operations globally. The nature of the Group’s social activities have received favourable
comment from international rating agencies (such as the SAM DJSI).
Impact on people: Various activities are implemented within the organisation, These include for example initiatives
relating to employment equity and diversity, employee training and development, as well as internal health and
safety programmes.
Impact on value chain: Some work has been done in terms of involving suppliers and customers through the
supply chain on sustainability related issues. This includes for example working with suppliers to promote black
economic empowerment, as well as assisting certain suppliers and customers on product stewardship activities.
Reporting: Sasol has issued a number of external reports on elements of it sustainability performance, the latest of
which (Share it with Sasol) was developed using the GRI guidelines.
Page 16
References
ACEA (2001) ACEA Position on Metal Based Fuel Additives
Aitken J (2000) Response by Ethyl Corporate to Cape Times article (15 August 2000)
Alliance to End Childhood Lead Poisoning Don’t Repeat the Leaded Gasoline Experiment (www.aeclp.org)
American Council on Science and Health What’s the Story? MMT (www.acsh.org/publications/story/mmt/)
Australian Automobile Association (2001) Setting National Fuel Quality Standards: Setting National Fuel Quality
Standards
Ethyl Corporation About MMT (www.ethyl.com/Products/MMT)
European Environment Agency (2001) Late Lessons from Early Warnings: The Precautionary Principle 1896-2000
Fourie M., van Niekerk W., and Mouton G. Technical Background Document for the Development of a National
Ambient Air Quality Standard for Lead (Infotox, February 2003)
Goosen R., Goede F., van der Merwe D., Farina K., and Botha J.J. (2001) The responsible and transparent process to
introduce an additive, MMT, into petrol in SA (Presented at Sasol SH&E Conference, March 2001)
Gosling M (2000; 1) MMT Debate Rages On: Allegations Denied over octane-booster (Cape Times, 1 September 2000)
Gosling M (2000; 2) Sasol’s unleaded petrol booster a “health risk” (Cape Times, 15 August 2000)
Health Canada (1998) Risk
sc.gc.ca/ehp/ehd/catalogue)
Assessment
for
Combustion
Products
of
MMT
in
Gasoline
(www.hc-
Infotox (2000; 1) Response to Comments by Ford Research on the MMT Health Risk Assessment (July 2000)
Infotox (2000; 2) Environmental Health Risk Assessment: Methylcyclopentadienyl Manganese Tricarbonyl (MMT) as
an Automotive Performance Enhanced in Petrol in South Africa (July 2000)
Legal Resources Centre (2000) Memorandum on MMT use in South Africa
Montague P. (2003) Corporate Campaign against Precaution (October 2003) www.rachel.org
Myers J. (2000) Comments on the Infotox Environmental Health Risk Assessment on MMT as an Automotive
Performance Enhancer in Petrol in South Africa (UCT, August 2000)
Schettler T., Barret K. and Raffensperger C. (2000) The Precautionary Principle: Protecting Public Health and the
Environment (www.sehn.org)
van Niekerk (2003) W MMT in Petrol: Facts and Fallacies Paper presented at NACA conference (October 2003)
World Bank Group (1998) Pollution Prevention and Abatement Handbook
Zayed J. (1999) Major Concerns related to the use of MMT in the context of the Precautionary Principle Pollution
Probe, November 1999
In addition to using the above reference material, the author conducted a number of background interviews with relvant
Sasol employees and with external stakeholders, and was provided with access to copies of internal Sasol emails as well
as copies of correspondence with external parties.
Page 17
Appendix 1 – Evidence of Uncertainty regarding the use of MMT
The following table is intended to provide a broad overview of the nature of the different perspectives – and thus an
indication of the possible level of uncertainty – regarding the use of MMT. Note: Inclusion of any the following
quotations does not imply any endorsement of that quotation by the author of this case study. These have been included
simply to highlight some of the differing opinions surrounding the use of MMT, and to reflect the differing sources of
some of these opinions
Concerns regarding MMT
Alternative Views on MMT
Health
“From a hazard identification perspective, manganese can
clearly be toxic to the central nervous system, the respiratory
system, and the male reproductive system. The level of
manganese which may be safely breathed over a lifetime is not
known with precision.” US EPA August 1994 waiver decision
“All analysis indicate that the combustion products of
MMT do not represent an added health risk to the
Canadian population” Health Canada
Impacts on
vehicles and
catalytic
converters
“The evidence in the literature demonstrated that manganesebased fuel additives will have adverse impacts on emission
control systems. At a minimum, it can be concluded from the
literature that there is a vigorous, continuing debate regarding
the impact of manganese-based additives on emission control
systems.” ACEA Position on the fuel additive MMT
“Ethyl has always taken claims from the OEMs very
seriously. We have initiated substantial research and
testing that proves these claims are untrue. In fact, after a
complete review of all available scientific data, the US
EPA (1994), General Motors of Canada, Ltd (1987),
Honda (1993) and the Canadian Government (1998)
reached the same conclusion: MMT does not interfere
with emission control devices, and in fact, lowers some
types of tailpipe emissions.” Ethyl – Fact Sheet
“The combustion products of MMT coat internal engine
components such as spark plugs, potentially causing misfire
which leads to increased emissions, increased fuel
consumption and poor engine performance… The combustion
products of MMT also accumulate on the catalyst.”
Vehicle
emissions
“In 2002 automobile manufacturers jointly completed a multiyear study of the impact of MMT on Low Emission Vehicles.
At 100,000 miles, MMT significantly increased non-methane
organic gases (NMOG), CO and NOx emissions from the
fleet.” World Wide Fuel Charter
“The Motor Industry believes that substantial emission system
risks exist related to the use of metallic additives. Now that the
catalyst poisons lead and sulphur are finally being eliminated
we believe the potential addition of other metallic compounds
to fuels is a retrograde step… we believe it would be prudent
to prohibit the use of metallic fuel additives at this time.”
ACEA Position paper (November 2001)
“Current scientific information fails to demonstrate that
MMT impairs the proper functioning of automotive onboard diagnostic systems.” Government of Canada, 1998
“MMT remains the most extensively tested fuel additive
in history. It is approved for use in the United States,
Canada, the UK and France amongst other countries.
Responsible governments and companies around the
world are using MMT as an environmentally beneficial,
cost-effective means to increase octane in unleaded
gasoline.” Ethyl
As a result of some of this perceived uncertainty, a number of parties have called for further research on certain aspects
of MMT before its use is allowed. The following issues have been identified as areas requiring further research in South
Africa (Myers J; 2000):24
 Current ambient Mn exposures levels in South Africa, ascertained in a representative population based manner;
 The health effects of the Mn species in the combustion products of petrol with MMT;
 The specific effects of inhalational risk of Mn from MMT in the context of total Mn exposure, including dietary
Mn;
 The impact of lifetime duration of exposure to Mn as compared with the relatively short periods of occupational
exposure studied in the past;
 The effects on vulnerable groups including pregnant mothers, infants and children and the aged population in
relation to specifically inhalational risk for Mn exposure;
 The impact of the interaction of the Mn nervous system effects and old age effects or the effects of other nervous
system disorders on the nervous system health of vulnerable groups in society;
 Neuropsychiatric effects and the effect on hostility, aggression and violence, especially in a South African society
that is particularly volatile in this regard; and
 Reproductive health effects.
A response to most of these queries is provided in Appendix 2 below.
Page 18
Appendix 2 – LRC Concerns regarding MMT with responses by Ethyl
Concern raised by the Legal Resources Centre25
Extracts from response of Ethyl26
Toxicity: Manganese is a neurotoxin, reproductive
and developmental toxin, pulmonary toxin, and
causes mood changes and aggression on a dose
response basis27. It is not known at which point
subtle changes occur.
“Mn is a biologically essential ingested element. Like many biologically essential
elements, Mn is shown to be toxic at extremely high exposure levels. These are very
rare instances and have only been observed in cases of very high occupational
exposure… The use of MMT in unleaded gasoline gives rise to virtually
immeasurable, and insignificant, change in airborne personal exposure levels…”
Vulnerable populations: These include: those with
high workplace exposure; children (young animals
absorb and retain manganese more avidly than
adults); the aged; pregnant and nursing mothers;
individuals with pre-existing neurological disease;
and persons with iron deficiency
“There is no scientific evidence to support the statements that these groups are
vulnerable to manganese exposure. It is ludicrous to say that people occupationally
exposed to Mn are at greater risk from use of MMT. The levels of safe exposures
(RfC, air quality guidelines etc) ate established with large safety factors to protect
the most sensitive population for a lifetime of exposure…”
Increase in exposure and absorption: Use of MMT
in gasoline will increase the average persons
absorption by several percent especially in locations
of greater concentration of vehicle emissions.28
“Inhaled manganese represents less that 0.1% of total manganese uptake into the
body. The remained comes from the diet. The contribution of inhaled Mn from use
of MMT represents a small fraction of normal airborne Mn and even less of a
fraction of elevated airborne levels near major Mn point sources. Thus a slight
contribution of inhaled Mn from use of MMT is of no consequence. Under normal
conditions, the addition of Mn from MMT is still well below established safe levels,
while at elevated levels near point sources the contribution from MMT is so small
relative to the existing level to be inconsequential.”
The US EPA standard RfC for manganese is
.05ug/m3 (ie continuous inhalation level for the
human population, including sensitive populations
that is likely to be without appreciable risk during a
lifetime) WHO standard is .15ug/m3.
“Even EPA says most likely RfC should be 0.09-0.2 g/m3 (not 0.05) to protect
most sensitive populations for a lifetime of exposure without appreciated risk and
adverse effects. The Toronto exposure study demonstrated that exposure levels are
much below the RfC of 0.05 g/m3 in a large area where MMT was used in all
gasoline at an average concentration of approximately 12 mg Mn/liter. The
contribution of MMT to manganese exposures in this study was so small as to be
unmeasurable, even though it was a very large study designed to demonstrate MMT
effects.
South African urban areas in some places eg Vaal
Triangle show consistent background concentrations
of between .05 and .15 ug/m3(see INFOTOX report
figure 3) with regular peaks of between .1 and 1.7
ug/m3. MMT use will increase these levels.
“As noted in out comments above, studies have shown Mn from MMT is
inconsequential to these levels. It should be noted that all health expects (sic) agree
short-term peaks are irrelevant. The RfC is for a lifetime of exposure. It should also
be noted that the RfC is based on exposures, not ambient levels. The Toronto study
showed that MMT use have virtually no effect on manganese exposures in the
general population.”
Uncertainties about Mn exposure: Actual
thresholds for adverse health effects for Mn
neurotoxicity are unknown. Studies have not yet
shown the effects of life long exposure or the effects
of exposure on vulnerable populations. The USEPA
RfC is not a precise demarcation of risk and studies
have shown subtle neurological effects at below this
level29.
“Because of these uncertainties, the RfC by definition incorporate large safety
factors. Just as with all chemicals/compounds, elements, No Observed Adverse
Effect Levels (N.O.A.E.L.) are established from studies of occupationally-exposed
populations and these NOAELS are lowered even more by large safety factors of
approximately 1,000 to obtain a RfC (or safe air exposure level) for the most
sensitive population for a lifetime without adverse effect. The NOAEL for Mn has
been established from many occupational studies of Mn workers and the NOAELs
are relatively consistent across all the studies, which gives additional confidence in
the data and the approach. More research has been carried out on Mn that for most
substances. The amount of MMT used in gasoline is very, very small, almost to the
point of being deminimus, up to about 20 ppm as Mn. The reference cited states that
airborne Mn levels of 0.009-0.035 g/m3 were found in the SW Quebec study.
These levels are irrelevant to his conclusions because they were measured long after
completion of the neurological portion of the study. The data were extremely
limited and represent ambient levels only, not exposures. Because they were so
limited, no attempt was made to relate ambient level to neurological effects. Since
other factors were noted to be associated with the neurological effects, we contend
strongly that the conclusion that Mn is the cause of the effects noted is flawed.”
Page 19
Concern raised by the Legal Resources Centre
Extracts from response of Ethyl
Current MMT use in Canada and the USA: Dose used
in Canada averages 8ppm, in the USA overwhelming
majority of oil companies have decided not to use it. The
USA regulated amount is 8ppm(?). SASOL proposes to
introduce it at 18ppm.
This is completely wrong information about use in Canada. The weighted
average usage is of the order of 12mg Mn/litre of gasoline. Over a 15 month
period (mid 1995 and 1996) in Toronto, where all 3 grades of gasoline were
sampled every 2 weeks at 15 service stations throughout the area, the average
was approximately 11-12 mg Mn/L… Mn is used in approximately 20
countries throughout the world. Other than the US, all the countries where
MMT is used allow a concentration of at least 18 mg Mn/L.
The USEPA attempt to ban MMT as an additive was
defeated on a legal technicality rather than a substantive
finding that MMT does not pose a risk to health. The EPA
has instructed further health tests to be conducted by the
Ethyl Corp and may yet ban it.
The “technicality” referred to by LRC was a unanimous decision by a three
judge panel of the US Court of Appeals of the District of Columbia that EPA
violated the law in denying Ethyl a waiver for MMT in public health grounds.
In declaring EPA’s decision to be illegal because public health is not a relevant
criteria for evaluating waiver applications, the Court nevertheless addressed
the merits of EPA’s newly developed public health standard. Noting that
EPA’s authority to control or prohibit the use of fuel additives under the Clean
Air Act is expressly limited to those additives which present “a significant risk
of harm to public health” (a risk not presented by MMT). The Court described
EPA’s new public health standard as “bizarre” and one that defies “the plain
terms of the statutory criteria” for evaluating the public health effects of fuel
additives…”
In what way is SA different from Canada, Europe and
the USA?
 Limited monitoring or enforcement of vehicle emissions
 No mandatory controls or monitoring of additive
amounts (eg levels of lead in unleaded petrol)
 Poor maintenance programmes for old fleets
 Large vulnerable population, role of petrol attendants
 Vast majority of vehicles do not have catalytic
converters leading to higher emissions
 Poor lung health, tuberculosis, silicosis, hiv/aids, large
vulnerable populations
What is the precautionary principle? The obligation on
the state to take a risk averse and cautious approach when
uncertainty as to the environmental consequences of a
decision exist, where there is potential risk. This should
involve a complete independent assessment of impacts
focussing on South African conditions. Current
information regarding MMT supports the conclusion that it
should not be used as an additive until further data are
available and its safety is confirmed30
“The conditions listed for SA auto fleet and air pollution regulations are more
favourable for use of MMT than other possible means for making up the
octane lost by removal of lead, such as increasing use of aromatics such as
benzene etc. The SA conditions, with few catalysts to reduce the increased
toxic gaseous emissions of benzene, acetaldehyde, formaldehyde, butadiene,
resulting from non-MMT usage, are such that usage of MMT would result in
better environmental conditions than use of alternatives…”
What we need to study in applying the precautionary
principle
 Results of EPA study should be obtained and fed into a
South African impact assessment
 Baseline Mn levels in SA urban areas should be assessed
 Emissions levels for SA vehicles should be established
 Studies of sensitive populations and cumulative effects
should be undertaken
 Alternatives should be explored
Purpose and need and economic benefit for the society as a
whole as well as SASOL should be established
“The precautionary principle might apply in instances when data do not exist.
This is not the case for MMT in gasoline. Much information exists, probably
more that for any fuel or fuel additive in history. An independent risk
assessment, which addresses many of these items, has been prepared by an
independent risk assessor for South African conditions. The conclusions of the
risk assessment are the same as those arrived at by Health Canada, the
Committee on Toxicity in the U.K. and the Ecotoxicity Commission in France,
i.e. MMT is safe to use.”
“The LRC cites one paper as support that MMT should not be used until
further data are available to confirm its safety. This article is published as
“commentary” by two persons, one an academic and the other employed by an
environmental activist group. The article is strictly a review article, which
presents no new data is an opinion of two persons. Because it is clearly marked
as commentary, it is unlikely the article received any peer review. The article
was accepted for publication in July 1996, well before much new information
had become available on MMT, including the Toronto exposure study and
many papers showing the environmental benefits from use of MMT. It would
always be nice to have more information before making any decision on even
simple items. However, there is a good deal of information on MMT and it is
overwhelmingly in favor of its use.”
Page 20
ENDNOTES
1
Note that despite the recognised difference between these two concepts for the purposes of this case study they are used interchangeably throughout
this document. See Section 2.2
2
For a full discussion of lead toxicity see for example the 1995 Environmental Health Criteria Document for Lead published by the International
Program on Chemical Safety (IPCS); some useful technical information on the situation regarding lead in South Africa is provided in Fourie M. et al
(2003)
Some have argued that valve seat recession has been overstated as a concern, maintaining for example that this is a red herring, and that “numerous
experiments conducted in the U.S. on older vehicles demonstrated that unleaded petrol use posed no such risk whatsoever and could even reduce
overall maintenance costs. Even discounting these studies, automatic retention of lead residues would afford older vehicles 20,000 km of protection
even after the switch, which should out-range their viable roadworthiness.” It has been estimated for example that vehicles technically requiring a
VSR additive will account for less than 7.2% of the total vehicle population in 2006, declining to 3.2% in 2010.
3
4
Countries where MMT has been approved include Canada, the United States, France, Italy, China, Argentina, Russia and the UK
5
The independent octane study completed for Government suggested that the use of MMT would save SA industry up to R1-billion a year, as well as
mitigating the need for some of the R15-billion investment required by the refining industry to meet Government’s proposed new fuel regulations.
6
See endnote 3 above
7
Letter from Director of Chemical and Allied Industries Association to the Department of Environmental Affairs & Tourism
At a general level the “precautionary principle” may be seen to demand higher levels of precaution than the “precautionary approach”. This
difference is evidenced for example by the extent to in the negotiation of various multilateral environmental agreements certain negotiating blocs
(traditionally the JUSCANZ countries) have strongly opposed the precautionary principle, while accepting – albeit at times perhaps reluctantly –
reference to the precautionary approach.
8
9
For useful discussions of the precautionary principle see e.g. Schettler T. at el (2000); European Environment Agency (2001); Montague P. (2003)
and European Commission (2000)
10
See for example Myers (2000), Zyers (1988), the LRC (2000),
Note however the suggestion that “as a result of extensive tests and studies, the conclusion was drawn that much of the concern about valve seat
regression in normal use had been misdirected and exaggerated.” World Bank Environment Department Papers, Paper No. 40 August 1996
11
12
The information contained in this section is based largely on a paper by Goosen et al (2000), as well as on a review of internal and external
correspondence and selected interviews.
13
The principal oil companies include BP, Engen, Shell, Total and Petro SA
14
One of the oil companies (BP) took a principled decision to reject the use of MMT. This was in accordance with their corporate policy against the
addition of any heavy metals to petrol that has been adopted for stated environmental health reasons. An additional underlying motivation for this
position is seen to be BP’s commercial interest in distinguishing itself as a more environmentally responsible company. This is reflected for example
in its current extensive advertising campaign in South Africa (newspapers and television) on the use of “heavy-metal free” petrol. Shell has similarly
expressed its position against the use of MMT.
15
Some of these companies, on the basis of their own assessments and with consideration to the arguments forwarded by Sasol, have concluded that
there is insufficient evidence to demonstrate either a material impact on catalytic converters, or a material increase of manganese in the atmosphere.
16
As represented by the National Association of Automobile Manufacturers of South Africa (NAAMSA)
17
These include for example: in assessing the possible impacts associated with use of MMT assuming all vehicles switch to Sasol unleaded
(containing MMT); adopting a large safety factor for children; using conservative assumption in the methods for extrapolating impacts from animals
to humans
18
Note for example A Andrews of the LRC (personal communication);
Alliance to End Childhood Lead Poisoning. They argue that “the use of MMT is a classic case where scientific evidence proving its safety to human
health and the environment should be required before its introduction… In essence, Ethyl is asking us to repeat the large-scale human experiment of
TEL by exposing millions of people to a known neurotoxin and waiting to see what ill effects occur.”
19
20
In EEA (2000)
One of the principal lessons that Shell learnt after the Brent Spar incident is that: “Dialogue should start as early as possible in decision-making:
‘Dialogue-Decide-Deliver’ is better and less costly than ‘Decide-Announce-Defend’.”
21
22
Most of these are based on an internal paper that was presented at the 2001 Sasol Safety, Health and Environmental Conference (Goosen et al;
2001); additional comment was received in subsequent interviews and discussions
As Shell’s experience with Brent Spar demonstrates, one cannot rely on science alone: even when science and the law may be seen to on the side of
the corporation, this matters little if a sufficient mass of the public think otherwise.
23
24
A similar set of concerns is identified in a Canadian paper (Zayed, 1999)
25
As identified in a memorandum of the LRC dated 29 August 2000
26
As outlined in a memorandum of Ethyl dated (see also response of 15 August 2000 to an article in the Cape Times)
27
Frumpkin and Solomon 1196 American Journal of Industrial Medicine: “Manganese In US Gasoline Supply”
28
Frumpkin p3; Zayed 1999 “Airborne manganese particles and MMT at selected outdoor sites in Montreal” Neurotoxicity Vol 20 pp151 -7
29
Hudnell: Effects from Environmental Mn Exposures: Review of the Evidence from Non- Occupational Exposure Studies 1999, read with Mergler
et al Manganese Neurotoxicity, A Continuum of Dysfunction: Results from a Community Based Study, 1999.
30
Frumkin, H, p 7
Page 21