The sponsor has presented plans to address these impacts to ensure that the proposed project will upon implementation of the specific agreed measures, comply with the environmental and social requirements - the host country laws and regulations and the World Bank/IFC environment and social policies and the environmental, health and safety guidelines. The information about how these potential impacts will be addressed by the sponsor/project is summarized in the paragraphs that follow.
Health, safety and environmental (HS&E) management systems, general workplace health and safety and emergency planning.
HS&E Management and Planning.
Copamex has well developed HS&E systems at individual sites and benchmarks its safety performance with international paper companies. Sites have considerable emphasis on awareness of safety issues amongst employees, several sites have received the Mexican “White Flag” safety award and three have received the Mexican “Industria Limpia” certification of good environmental performance.
Although individual sites have comprehensive HS&E procedures, there are differences in approach between sites. One mill has recently started, with external assistance, a two-year program to develop a comprehensive HS&E management system; this work is intended as a pilot with replication throughout the whole company to follow. Also Copamex’s corporate staff will review all sites’ procedures, take best practices from each and develop corporate HS&E standards and procedures. Copamex aims to achieve ISO 14001 certification for environmental management and OHSAS 18001 safety certification for its mill sites by mid-2006.
Procedures and checklists are available for hazardous operations such as hot work, handling certain chemicals, and working at height or in confined spaces. Several sites have manuals of safety rules. These are comprehensive though breaches may be observed. Copamex will develop and re-enforce its safety rules and procedures within the framework of the HS&E management system.
Most sites have emergency response plans, though again there are differences in approach. As with the HS&E management system, Copamex’s corporate staff will review these plans and ensure that all plan for all likely events.
Safety glasses and ear defenders are provided to employees and visitors and are virtually universally used. Protective footwear and clothing are provided to employees. Employees undergo health screening on taking up employment and annually thereafter. First-aid cover is provided by a company doctor throughout the working day and a network of first-aiders at other times.
High-visibility clothing will be provided for all workers in cardboard collection facilities, those who work in raw material storage and handling areas at the mills and to all pedestrian visitors to these areas.
Hazardous materials storage and handling
Several sites have dedicated facilities for storage of chemicals and other hazardous materials. Others do not, and Copamex will improve hazardous material storage where required.
Fire protection
Copamex is very aware of the need for fire protection and one site has undertaken a life and fire safety review. All sites have comprehensive fire hydrant systems which are tested regularly, and large numbers of regularly maintained extinguishers. Minor improvements were discussed and will be implemented by Copamex.
Gas burner trains to three boilers at the Chihuahua mill will be upgraded.
Noise
Copamex measures noise at the boundary of several of its sites. The Chihuahua site borders a residential area and noise at the boundary exceeds IFC’s standards. Noise mitigation measures, primarily related to the vacuum pumps located in the mill yard will be adopted to reduce noise to acceptable levels.
Air emissions from boilers, generators and other sources.
Air emissions arise from one lime kiln, boiler flue gases and exhausts from paper machine drying sections.
Emissions from the lime kiln, Mexican paper mill boilers and paper dryers have been measured and comply with IFC and Mexican requirements. Air emissions from the boilers and dryers at the Nicaraguan factory are not known: these will be measured and action taken to reduce emissions if required.
Particulate emissions from the boiler at the pine-oil products plant exceed IFC requirements but meet local requirements. Copamex will seek specialist assistance to adjust the burner - this is expected to reduce emissions – and will then re-measure emissions and take further action as required.
Cardboard box plants have small boilers which do not have significant emissions to air.
Copamex is considering a combined-cycle gas-turbine cogeneration system for one paper mill, with waste heat being used at that mill and electricity transmitted by the public distribution system to several other mills. The proposed natural gas turbines will meet IFC and Mexican air emissions standards and will reduce carbon dioxide emissions associated with Copamex’s energy use.
Process water use.
Over the last three years, Copamex has greatly increased the use of in-process recycled water in the manufacture of tissue, Kraft and bond paper. Copamex has an active water management program and is researching technology to permit total water recycling, which it believes is essential for the long-term viability of its mills in Nuevo León and Chihuahua states.
Copamex takes and treats water from municipal sewers to meet part of its needs for two mills, thus minimizing depletion of clean water sources. Water abstraction at all sites from all sources is well within limits imposed by regulatory authorities.
Waste water treatment and disposal.
One paper mill discharges effluent to a neighboring company for pre-treatment and subsequent discharge to the municipal sewer. Two other mills pre-treat effluent before discharge to municipal sewers. In both cases the municipalities treat the effluent further. Two further mills discharge treated effluent to rivers; these discharges meet local and IFC requirements. Some of these mills have de-inking processes, but these employ hydrogen peroxide bleaching. The sixth mill treats its own process waste water and effluent from the neighboring town, and discharges the combined effluent to a lagoon. Effluent quality meets IFC and local requirements.
The pine-oil plant effluent is at the border of compliance with IFC and local requirements and effluent quality has improved over the past two years following process changes. Effluent quality will be monitored regularly and further process changes to ensure discharge standards compliance will be made. Technical changes to the effluent treatment system will be made if required.
The Nicaraguan mill discharges process effluent to a settlement lagoon only, which drains to a lake. Copamex is developing the design for a waste water treatment plant for this factory. Nicaraguan authorities require installation by 2008, though Copamex expects to commence plant operation by mid-2005. Expansion of paper-making capacity for this site is under consideration. If this expansion takes place before 2005, then a new waste water treatment plant capable of treating effluent from the combined site will be installed as part of the expansion project.
Waste water from converting plants (which can include ink arising from wash-down) is discharged to municipal sewers for subsequent treatment: this meets IFC and Mexican standards. Inks have been analyzed to the Mexican CRETIB standard (this examines the corrosiveness, reactivity, explosive properties, toxicity, inflammability and biological properties of waste) and found to be non-hazardous.
Energy efficiency.
Specific utility consumption of paper machines is reported monthly to the plants’ senior managers and corrective action taken as required. The mills’ metering networks will be extended to provide more detailed analysis and control of energy use. Additionally, Copamex’s R&D department has several capital investments such as process heat recovery under development. These and other energy saving opportunities identified during the environmental appraisal will be evaluated by Copamex and implemented if found to be cost-effective.
Hazardous and solid waste management.
Copamex has active waste minimization programs and has a reduction in broke production as a corporate objective. Advanced paper refining allows Copamex to increase fiber yields and at the same time maintain and improve strength of its Kraft paper. Additional waste minimization opportunities in consumer products manufacture were discussed with Copamex and will be investigated further.
Pressed waste water treatment plant sludge forms the majority of solid waste. This waste is regularly subject to CRETIB analysis and has been found to be non-hazardous. At one mill, this sludge is disposed to an on-site clay-lined landfill, from which leachate is collected and discharged to the WWTP. At others, sludge is disposed of in commercial landfills by regulated contractors.
Hazardous waste is removed for disposal by licensed contractors and hazardous waste manifests maintained.
Management of a staff reduction program.
Copamex is considering complete or partial closure of a bag and sack plant and is developing a regional rather than site-based structure for production support activities such as accounts, purchasing and engineering. These activities may result in the loss of around 275 positions in 2003 or around 4% of the company workforce. No further redundancies are planned. Copamex will offer re-employment within the company where possible. Where compulsory redundancy cannot be avoided, Copamex will fully comply with the provisions of Mexican employment law and will consult with labor unions and government authorities over the redundancy program. Additionally, Copamex would provide outplacement counseling for redundant staff which would include advice on investment strategies for redundancy payments.
Waste paper collection network.
Copamex has established a network of 6 waste paper collection centers in Mexico and another four in Texas and New Mexico. Copamex collects some around half of its waste paper itself, from various sources such as factories and supermarkets, and has also established collection agreements with agencies such as the education ministry from which Copamex collects and re-uses obsolete text books. Copamex can be sure that there is no child labor in this element of the supply chain.
Copamex buys some 17% of its paper from collectors who deliver directly to the paper collection centers, and 34% from small traders who in turn buy from individual collectors. The typical collector supplying directly to Copamex has a truck and collects waste from small businesses such as printing works, which who he has an agreement to take away paper waste. It is likely that this type of collector also sells to the small traders who supply Copamex, and in fact some of the small traders are former collectors who grew their businesses to the extent that they have paper balers. Child labor is not suspected in this element of supply.
In Monterrey, there is no curbside collection of household recyclables: recyclable material is separated at municipality-operated sorting sites. While child labor is not used by the municipality, Copamex is also reluctant to take paper from this source since it is typically dirty and not well suited to its production operations.
Plantations.
Copamex has two experimental plantations, of 50 hectares close to the Pondercel mill in Anáhuac and of 600 hectares in Nayarit, which were started to determine the feasibility of developing a dedicated supply of wood for pulping. The Anáhuac plantation is located on high, arid land which has been owned by the Pondercel mill for many years and which was not previously used. Lack of rainfall and extreme temperatures at Anáhuac preclude a commercial scale plantation. The Nayarit plantation is on land formerly used for agriculture and ranching. It is not of sufficient scale to supply wood to the Pondercel mill, and sufficient additional land to make the plantation a viable wood supplier to Pondercel is not available in this area. Nevertheless, the plantation is productive and wood is harvested for uses such as construction.
Copamex has identified the agrochemicals used in the plantations. Some are considered by World Health Organization (WHO) to be “Class II moderately hazardous chemicals”, but comprehensive procedures to protect workers from accidental exposure have been developed. In addition to existing procedures, Copamex will ensure that pesticide and herbicide containers are triple-rinsed and destroyed after use.
Corporate Outreach.
The sections above describe mitigation of the environmental and social risks identified during the environmental assessment process. In addition to these, Copamex seeks IFC assistance to extend its reach in the following areas:
To develop an education program for its small waste paper suppliers to explain why it is important to ensure that there is no harmful use of child labor in the paper collection network and to increase awareness among paper collectors of the Mexican legal framework in this respect;
To provide technical assistance to its transport services contractors to ensure that these companies improve their standards of truck maintenance, emissions and safety.
