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, host country laws and regulations and the World Bank/IFC environment and social policies and the environmental, health and safety guidelines. Information about how these potential impacts will be addressed by the sponsor/project is summarized in the paragraphs that follow. Further information is provided in attached documentation.
- Management systems for food safety, quality, environmental and social affairs.
The company is effectively managing environmental and social affairs and, aside from the industrial effluent issue that will be resolved as part of this investment, is in compliance with WBG policies and guidelines and Argentine regulatory requirements. San Miguel fully recognizes the business case for environmental and social affairs management and has certified, applicable management systems in place to integrate environmental and social affairs management into all aspects of operations. These certifications are export client mandated and have far reaching implications in intramural and extramural activities in lemon orchards, harvesting (3rd parties), fruit packaging and industrial products manufacturing. San Miguel’s quality and food safety programs begin in the fruit orchards. San Miguel has implemented and certified a Euro-Retailer Produce Working Group Good Agricultural Practices (EurepGAP) program. EurepGAP implementation entails institutionalization of standards and procedures to ensure that agricultural activities are undertaken in a responsible way that respects food safety, the environment, and the welfare of workers. For fruit preparation and packaging and in industrial lemon product production, San Miguel has implemented and holds certification for its Hazard Analysis and Critical Control Point (HACCP) program. HACCP is an internationally recognized food safety program that requires precise definition of product flow and processing procedures specifically addressing Good Manufacturing Practice (GMP) to produce safe and wholesome products through strict control of physical facilities, sanitation, pest control, product handling and other areas. Sanitation Standard Operating Procedures (SSOPs) are oriented to sanitation control and require the company to take proactive steps to ensure that their products are safe, pure, and effective. Moreover, San Miguel effectively utilizes its quality and food safety programs to implement protection against bioterrorism and prevent sabotage. San Miguel’s program is fully compliant with the US FDA’s Public Health Security and Bioterrorism Preparedness and Response Act 2002.
- Employment considerations in view of relocation of selected industrial operations.
There will be no employee retrenchment associated with the consolidation of industrial processing operations the Famailla plant. San Miguel will continue to operate the Tucuman plant in processing and packaging fresh fruit and storage of industrial products (e.g. concentrated juices, oil, and dried peel) awaiting export. San Miguel will provide transportation to the Famailla operation for experienced industrial process employees currently employed in the Tucumán operation once the consolidation program at Famailla is complete.
Air emissions from steam and heat generation.
San Miguel’s existing boilers utilize sweet natural gas for production of steam and hot water. Analytical reports submitted previously demonstrate that air emissions from these units comply with Argentine regulatory and IFC guideline limits for particulate, NO2 and SO2. With industrial expansion at Famailla the boilers installed in Tucuman will be moved to Famailla and smaller units will be purchased for Tucumán. With the installation of the anaerobic reactor unit process for wastewater management (see below) San Miguel’s Famailla facility will be able to produce a biogas containing ~70% methane; this biogas will be used to co-fire boilers at Famailla and reduce dependency on non renewable fuel resources.
Sustainability and quality of potable water supply used in fresh fruit processing and food manufacturing.
Water for the Famailla industrial operation comes from shallow ground water wells on site and the municipality services Tucuman operations. Both water sources are subject to microbial contamination and vary in quality. Raw waters are pretreated and then processed through reverse osmosis membranes to remove contaminants and to prepare them for use in industrial manufacturing, juice dilution and cleaning. Source water and treated water are monitored closely in compliance with Hazard Analysis Critical Control Point (HACCP) food safety requirements. Additionally, San Miguel applies its extensive laboratory capabilities for pesticide residue analyses to its water monitoring program. A third party laboratory in Buenos Aires performs confirmatory pesticide residue analysis.
Industrial wastewater management.
San Miguel will consolidate industrial lemon operations (i.e. production of juices, oils, and dried peel) at the Famailla plant. Wastewater from the Tucuman operation will be significantly reduced and simplified; and, it will be feasible to treat fresh fruit wash water in a more conventional manner that will be carried out in compliance with the Corrective Action Plan (CAP). The company has characterized its unique, difficult industrial wastewater emanating from industrial lemon processing operations. Additionally, the effluent is highly bacteriostatic thus complicating potential biological treatment options. Through a series of pilot tests, the company has defined a cost effective treatment solution consisting of several unit processes including dissolved air flotation (DAF) pretreatment, anaerobic digestion reactors and biological treatment prior to discharge. San Miguel’s full-scale system will be installed in three phases that will allow optimal sizing of each unit process and accommodation of the company’s operating period of 150 days/year. Implementation of the three phases will be carried out in compliance with the CAP.
Uruguay operations.
San Miguel’s Uruguay operations are significantly smaller and are predominantly oriented to fresh fruit product production (e.g. grapefruit, oranges, mandarins, and other sweet fruit). All processing waste is collected and sold without dehydration as animal food. The company has fully implemented HACCP and is in the process of obtaining and EurepGAP certification. As with Argentine operations, these food safety and production certifications have far reaching, positive implications in intramural and extramural environmental and social affairs management activities in orchards, harvesting (3rd parties), fruit packaging and industrial products manufacturing.
Solid waste management.
San Miguel has detailed procedures in place addressing mandatory classification and management of solid waste from operations that include segregation, classification and appropriate disposal. Few hazardous materials are used and the bulk of these are associated with laboratory operations. San Miguel is in compliance with Provincial Law 6605 and National Law 24051 that address generation, use, transport, treatment and final disposal of hazardous materials and wastes. Organic wastes emanating from wastewater operations are currently land filled. However with the implementation of the wastewater management scheme for industrial effluents, organic solids will be composted and sold for soil amendment, animal food, or other purposes.
Occupational health and safety in processing, agriculture and allied facilities.
San Miguel has an extensive occupational health and safety program that includes supporting procedures and clearly established lines of responsibility and extensive employee training. Employee training courses include orientation to HACCP, BMP, GMP, food microbiology, first aid, safety and fire emergency brigades training, forklift operation, ammonia management, caustic soda management, highway safety regulations, potentially hazardous substances, fire and safety drills, use of work tools, laboratory safety, etc. Contract harvest employees are also provided with extensive training programs that address not only field and harvest safety but also mandatory quality practices in fruit harvesting. San Miguel complies with EurepGAP requirements that agricultural activities be undertaken in a responsible manner. Accident statistics are collected and evaluated for implications such as further training to ensure continuous program improvements.
