The company has presented plans to address any impacts to ensure that the proposed project will, upon implementation of the specific agreed measures, comply with applicable environmental and social policies and requirements, and environmental health and safety guidelines of the World Bank/IFC, and laws and relations of local authorities, Andhra Pradesh, and India.
The company has been an IFC client since 1998, submitting annual monitoring reports which have indicated substantial compliance with World Bank Group/IFC Environmental and Social (E&S) policies and guidelines in force at the time of the loan. The company agrees that it will meet all applicable policies and guidelines and will ensure that their contractors and subcontractors abide by the same standards.
Emissions to the environment from current project operations of air, water, solid waste, toxic/hazardous materials are within WBG/IFC and national guidelines. Process wastewater is used for irrigation of trees in a “greenbelt” around the factory. Cooling water is drawn from the Bay, recycled and discharged back into the Bay. Fly ash from air pollution control devices is sold to local “cottage industry” brick manufacturers in a program established by the company.
With the exception of some high-noise areas, the company meets or exceeds WBG/IFC health and safety policies and guidelines. Fire safety is adequately addressed throughout the operations. Dust is controlled and workers wear appropriate PPE. The company’s occupational safety record is exemplary, with no lost time or fatal accidents in the last 3 years, of either RCL’s employees or on-site contractors/subcontractors, out of more than 3,070,000 man-hours worked.
The current labor force is 197 permanent employees and 171 contractors/subcontractors, for a total of 368 jobs. It is anticipated that the project will result in a net gain of 25 jobs. The company estimates that this will create approximately 100 support/secondary jobs in the region. During construction, about 300 workers will be engaged in various related activities for about 1 year. All workers meet the Indian minimum age requirement of 18 years.
The company is in the process of becoming ISO 14001 certified and anticipates that certification will be achieved by the end of 2004 or in 2005. Monitoring of the use of natural resources, energy, and waste production is currently at a relatively high level and could be considered adequate for measuring effects and evaluating options.
A corrective action plan for any potential impacts will be implemented by RCL and will consist of the following (detailed in two phases):
Current Operations
- Clearly mark areas where noise levels exceed OSHA standards for prolonged exposure and provide/require appropriate hearing protection for access/working.
- Restricted access areas will be marked with universal signage, in symbols, and words, for prohibited entry without appropriate hearing protection
Construction Phase - RCL’s contractors/sub-contractors will:
- Identify sites, and receive approval/permits for disposal of surplus debris/refuse
- Dispose of surplus debris/refuse only at approved sites previously identified
- Provide Personal Protective Equipment (PPE), particularly for dust emissions, noise, hardhats, and appropriate footwear
- Control fugitive dust by sprinkling water over the construction site, materials storage piles, and access roads
RCL will hold its contractors/sub-contractors to its own, national, and WBG/IFC Occupational, Health and Safety standards and forced and harmful child labor policies by including this requirement in its contracts. The severity of infraction(s) and/or repeated violations can be cause for cancellation of the contract.