SPASA has presented plans to address these issues and demonstrated that the proposed project will comply with applicable local regulations and World Bank policies and guidelines. The measures proposed to address the project’s information provided indicating how these potential environmental impactsimpacts will be addressed in the development of the project includes during its implementation are described in a Corrective Action Plan (CAP) (See Appendix A) and is summarized in the paragraphs that follow.
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SPASA operations include seven footwear-manufacturing plants, two covering and tarpaulin plants one sports ball manufacturing plant, nineteen Meggashops outlet stores and three Timberland stores. Six of the plants are located in the northern and Northeastern Brazil, Natal, Santa Rita, Campina Grande, Joao Pessao, and Manaus. The additional four operations are located at Mogi Mirim (Sao Paulo State), Poso Alegre ( Minas Gerais State), and two plants at Veranopolis (Rio Grande do Sul State). In addition to these plants there are also 14 minor scale satellite plants that support most of the above mentioned operations.
SPASA has five business areas including Athletic Footwear, Sandals and Low-end Footwear, Coverings and Tarpaulins, Meggashops, and Timberland operations. The manufacturing of athletic footwear includes cutting/preparation/stitching; sole manufacturing, assembling, and finishing. There are two types of footwear manufacturing (i) vulcanized shoes, and (ii) cemented shoes. Vulcanized shoes require that rough rubber and the fabric parts are manually cemented using forms and adhesives. The finished shoe is further vulcanized. Cemented shoes have all parts cemented using forms and adhesives. Sandals production includes the cementing of rubber sheets, assembly of the sole, vulcanization, and final parts assembly. The two types of coverings, polyethylene and PVC, are produced in two steps, the fabric production and the film extrusion. By pressing both, film and fabric, the coverings are formed.
As part of the project, SPASA will open nineteen additional Meggashops in commercial areas. All the land acquisition will be conducted as private land sales with legal owners on a willing buyer/willing seller basis and will involve neither relocation nor economic displacement since they will be located in already developed and commercially zoned areas that do not contain any squatters or illegal land occupant.
For its operations, SPASA uses a variety of materials including rubber, PVC, adhesives, solvents, plasticizers, canvas, leather, nylon, polyester, dyes, etc. The types of materials used will not be increased as a result of the project. The vapors generated in the work environment are being controlled and will continue to be controlled as a result of the project. SPASA will install, as needed, the appropriate ventilation systems and will control the air releases prior discharging them to the atmosphere. The boilers, which are used to produce steam will be monitored to determine the air emission levels and will be also controlled to ensure that all emissions and workplace air conditions are in compliance with the applicable World Bank guidelines.
SPASA will continue recirculating process waters and, as part of the project, will upgrade and install, as necessary, wastewater treatment plants to treat domestic and process effluents prior being discharged. The treated effluents will be in compliance with the applicable World Bank guidelines.
Currently, SPASA has solid waste segregation programs and as needed it will develop solid residues handling management programs. As part of the project, in several of its plants, it will upgrade/build areas for proper temporary storage and handling of the solid residues generated. Most of the wastes generated (i.e., paper, plastic, rubber, wood, etc.) are either reintegrated into the process or sold for reuse. The remaining wastes are and will continue to be properly disposed, in accordance to the local regulations, by either placing them in secured landfills or incinerating them in cement kilns.
SPASA will continue implementing and will develop, as needed strict measures to handle the raw materials. Specific measures include, double containment walls around the tanks to avoid the risk of ground contamination in case of a leak or an accidental spill. It will also upgrade the raw material storage areas, which stored flammable materials, at most of the operations to prevent the possibility of accidents. Needed fire prevention measures will be implemented and the personnel will continue to be trained in the safe use and handling of these materials.
All SPASA operations will continue to maintain excellent housekeeping and safety signaling. In addition, as part of the project, SPASA will continue implementing measures and programs that will enhance significantly the working conditions of its employees. The rigorous ergonomics programs already initiated will continue to be implemented and the excellent medical access available at all plants will be maintained and improved as needed.
To reduce noise emissions, the equipment at all plants is regularly maintained and if necessary, additional measures will be taken to comply with the World Bank guidelines.
SPASA has established an environmental health and safety (EH&S) structure at plant level which depending on the number of employees includes safety engineers, environmental technicians, physicians, and nurses who work in close cooperation with the plant managers. This team is doing an outstanding job in identifying problems, establishing corrective and proactive action programs, training personnel, and monitoring performances. As part of their activities, the EH&S team implementationperforms monitoring of its air emissions, liquid effluents, and workplace conditions; risk analyses during and after commissioning of new projects; develop and implement standard operating procedures; conduct training; and ensure that the fire brigades, which are available at all times, are fully trained. SPASA will complement the existing EH&S structure at corporate level, as needed and mutually agreed with IFC, with specialized professionals to ensure the implementation and full compliance of the environmental programs and initiatives.
SPASA has engaged in a retrenchment program at some of its operations in full compliance with the Brazilian labor requirements and the Union Agreements. In addition, SPASA is providing medical insurance for three additional months beyond termination and will pay additional salaries in addition to those established by law. SPASA will also provide support through the Commerce and Industry Federations to implement training and placement programs.
SPASA is committed to inform IFC of any initiatives that generate material environmental impacts and will submit the proposed mitigation actions before such a project begins to be implemented. Likewise, SPASA will inform IFC, at the earliest possible date, of any expansions or improvements that could cause physical or economic displacement and will submit plans for appropriate mitigation measures to be approved by IFC prior to implementation of such an activity.
