The sponsor has presented plans to address these impacts to ensure that the proposed project will, upon implementation of the specific measures agreed, comply with applicable host country laws and regulations and World Bank/IFC requirements. The information about how these potential impacts will be addressed by the sponsor/project is summarized in the paragraphs that follow.
Environmental audit of existing operations against IFC and host country requirements: In 1998, as part of an IFC review of its initial investment in SPM, the company was required to conduct environmental and health and safety audits of key operations, including its waste water treatment system, air emissions from boilers, and employee exposure to dust, heat and noise. The results of these audits formed the basis for a detailed corrective action plan (CAP). Under the terms of the CAP, SPM submitted monthly monitoring reports to IFC for more than a year, which detailed the progress the company was making on key aspects of its environmental and health and safety performance. In addition to monthly waste water testing carried out by SPM’s in-house laboratory, the CAP required that independent analyses also be conducted annually to verify in-house test results. Independent auditors also were hired to assess emissions from SPM’s boilers, and to conduct hearing tests for employees. The monthly reports were submitted to the Swaziland Environment Authority (SEA). as well as to IFC. SEA has also conducted periodic inspections of SPM’s waste water treatment system. SPM has confirmed in writing that the plant complies with all relevant Swazi government regulations.
Production processes and source(s) of process inputs: The production processes utilize equipment that is standard in the tissue and Kraft paper industries. In addition to water, the primary input is waste paper, which SPM has historically sourced from South Africa. As part of the upgrade and rationalization of its facilities, SPM will begin utilizing waste paper from the municipal landfill in Matsapha. The decision to source waste paper locally has benefits for SPM, in that it will lower transport costs, and for the municipality, as doing so will reduce the volume of waste paper going into the landfill by about 90 percent.
Eco-efficiency including energy, water and raw materials use: SPM utilizes electricity from the national grid, which is supplied by a hydroelectric facility. The bulk of its inputs are waste paper that would otherwise be landfilled. The primary opportunity for improved environmental efficiency is therefore related to water use. SPM uses a total volume of water of 2500 m3/day, and flow meters have been installed to monitor water consumption. Although the equipment manufacturers recommend the use of fresh water in most of the plant, SPM has modified the processes to enable the use of recycled water. The company expects to be able to use recycled water to meet 50% of its total water requirement after the plant upgrade is complete.
Air emissions, including odor: Air emissions are generated by the boilers used to dry the sheets of tissue and Kraft paper. The company utilizes coal-fired boilers made in South Africa. These boilers are manufactured to meet South African emission standards and specifications. As part of the environmental audits conducted by SPM, an independent evaluation was undertaken of the boiler emissions. The evaluation concluded that emissions were within the limits established by both the World Bank group and SEA. SPM has incorporated both the World Bank group and SEA emission limits in its EMS as the reference standards for emissions, and conducts monitoring of ambient emissions throughout the facility approximately three times a year. SPM has agreed to conduct annual stack tests of its emissions to confirm compliance with IFC and SEA standards and to submit the results to IFC and SEA. Submission of the first set of stack test results will be made a condition of first disbursement in the Loan agreement.
Source of water and power for processing, including fuel storage if applicable: Water for the plant is supplied from two sources: a borehole on the property and the canal that feeds the nearby national hydroelectric power plant. The electric supply authority has given SPM water rights to draw from the canal. The total water requirement is 2500 m3/day, and the drawn water requires pretreatment prior to use in the plant. Although the equipment manufacturer recommends that fresh water be used in key areas of the facility, SPM has substituted recycled process water for a significant fraction of its water requirement, as described above. SPM utilizes electricity from the national grid, which is supplied by a hydroelectric facility. The power supply is quite reliable; as a result, the plant does not require backup generating capacity.
Process effluent treatment and disposal: The most significant environmental impact from the plant relates to water consumption and discharge of process waste water. SPM has committed considerable resources to minimizing its water use, and to treating and recycling its waste water to the degree possible. Since the mid-1990s the company has undertaken a program of continuous improvement to its effluent treatment system. The program has had two primary objectives: to minimize the amount of waste water discharged to the river, and to ensure that the water that is discharged is treated to meet relevant local and international discharge standards. Included in the system is equipment to recover as much fiber for reuse as possible, equipment to separate non-hazardous solid waste from effluent to be discharged, and two large settling and aeration ponds. Untreated water is never discharged, and treated water is tested daily to monitor compliance to the requisite limits. The daily testing regime also tests the effectiveness of SPM’s environmental management tools, including process control logs and reports, production reports, daily operational review meetings, monthly review meetings, and annual audits. In addition, water flow is monitored incoming and outgoing. Flow meters have been installed to monitor water consumption and discharge. An automatic valve closes to prevent allowable discharge volumes from being exceeded. The company has agreed to provide IFC and SEA with quarterly monitoring reports on its effluent treatment and discharge system.
Solid waste handling and management: Non-hazardous solid waste is generated in the paper making process. This waste can include ash, staples, and some plastics mixed in with the waste paper. These materials can damage equipment and lower the quality of the product, and therefore must be separated from the paper through the use of screens, centrifugal cleaners and flotation systems. The quantity of this solid waste varies depending on the types of waste paper available for use. Solid wastes are disposed of at the municipal landfill in Matsapha, which is managed by the local waste management authority. As part of its EMS, SPM will maintain records regarding the amount and composition of waste disposed and provide these to SEA on a regular basis. Until recently, SPM disposed all of its solid wastes in an existing landfill on its property. SEA has asked that on-site disposal be discontinued, the existing landfill closed, and a new landfill constructed that conforms to SEA standards. At the present time, therefore, the total volume of solid waste generated by SPM’s operations (355kg per day) is disposed of in a municipal industrial waste landfill site at Matsapha controlled by the Matsapha Town Council Board. As a result of the plant upgrade, total solid waste generated will increase to 720kg per day. SPM will continue to dispose to the Council landfill until the new on-site landfill is complete, and SEA has approved it for use. SPM has engaged a firm of consulting engineers to design and construct the new solid waste landfill, in close consultation with SEA. Construction is expected to commence no later than September 2002.
Chemical and other hazardous material handling, management and disposal: SPM has provided IFC with a list of chemicals used in both the Kraft and tissue paper processes, some of which (e.g., sulfuric acid, caustic soda) require special handling. The company has confirmed that all chemicals are stored in a locked chemical storage room, which has been designed to contain any spills that might occur. The chemicals are pumped from this room directly to the particular section of the plant where they are used, thereby eliminating the possibility of large spills in the main processing areas. An inventory sheet accompanies all chemicals brought into the plant. Copies of all inventory sheets are kept in key locations throughout the factory, and include the Material Safety Data Sheets (MSDSs) for each chemical. The MSDSs provide handling and treatment information in the event of an accident or spill. Plant employees receive training on the chemical inventory sheets, as well as the function and hazards of each chemical used in the factory.
Employee health and safety: SPM has established a safety committee, which includes both management and operators, to develop and monitor a safety program for the entire plant. The committee is in the process of reviewing each production area to improve systems and procedures to achieve its goal of ‘zero injuries.’ SPM provides all requisite personal protective equipment to its staff, in accordance with local and regional standards. Shift supervisors hold a monthly safety meeting with their team for training purposes. A training program is in place to train the operating team in the operation of all equipment. This training program includes safety concerns, fire fighting, process flow, and recommended effective operating procedures for all equipment and supplies, equipment controls. Recommended start up and shut down procedures are provided in the form of a checklist for operators to follow. Suppliers of equipment and raw materials are involved in the development and presentation of training on the safe use of all equipment. Equipment and raw material suppliers have been consulted during the commissioning of the plant to ensure that equipment is properly installed and operated. Noise levels in most areas of the plant are below the local guideline of 85 dBA, with the exception of the boiler room. “Hearing Protection Required” signs are posted at the entrances to the boiler room, and hearing protection is provided for all employees who enter the area. At IFC’s request, SPM undertook a plant-wide noise level audit in 2001. SPM has implemented all of the recommendations included in the audit report. Notices have been posted in all areas where noise exceeds 85 dBA and earplugs are mandatory in these areas. Employees working in these areas have undergone ‘baseline’ hearing tests, and these are repeated annually. All employees have attended a training program on hearing protection, which will be repeated regularly for new employees and as a refresher course for existing employees. SPM has established a disciplinary action team that includes both management and staff to ensure compliance with safety rules in the facility, in the view that because 96% of all accidents occur as a result of an unsafe act, preventing unsafe acts can reduce injuries. The team’s function is to ensure that appropriate disciplinary actions are implemented fairly and effectively.
Compliance with IFC and host country labor policies and regulations: SPM has confirmed that it is in full compliance with Swazi labor laws and IFC policies on forced labor and harmful child labor. The company has established workers committees to participate in wage negotiations, health and safety programs, and environmental performance and monitoring. The company provides a number of benefits for its employees and their families including a workplace transportation program, skills training opportunities, education subsidies, health services, community programs, and an HIV/AIDS awareness and prevention campaign. SPM has played a leading role in Swaziland''s ‘AIDS Crisis Management Technical Committee,’ a group of employers and community activists who have organized programs to combat AIDS in the country.
Retrenchment of existing staff if applicable: SPM has confirmed that no retrenchment is envisaged as a result of the new project.
Adoption of an EMS satisfactory to IFC, including a mechanism for communicating on a regular basis with interested and affected parties on corporate environmental performance: SPM has provided IFC with a draft EMS covering its entire operations. The EMS is modeled closely on the EMS developed for SPM’s Unicell facility in Trinidad, which is also an IFC investment. IFC is currently reviewing the EMS and providing SPM with comments. Submission of a final EMS acceptable to IFC will be made a condition of first disbursement in the Loan Agreement.
Annual reporting on environmental performance of all IFC investments with the sponsor: SPM is familiar with IFC’s reporting requirements, having submitted monthly monitoring reports on key aspects of its environmental performance for more than a year. The company has agreed to provide IFC and SEA with quarterly monitoring reports during the project commissioning phase. Once the plant is fully operational SPM will be required to submit reports annually.
Local disclosure: The ERS will be made available at the SEA offices in Mbabane. The company will announce the availability of the ERS at these locations in an advertisement published in the Swazi Observer, a daily newspaper distributed throughout Swaziland.
