The sponsor has presented plans to ensure compliance of Suzano’s projects with applicable host country laws and regulations and World Bank/IFC requirements as presented in the paragraphs below and in the Corrective Action Plan listed in Table 1.
Environmental, Health, and Safety (EHS) and Social Management
Suzano has developed a strategy to achieve economical-financial results coupled with social responsibility and environment preservation. Since 1993, Polibrasil voluntarily subscribed to the Responsible Care Program coordinated in Brazil by the Brazilian Association of Chemical Industries (ABIQUIM). This program establishes guidelines in the environmental, safety and occupational health areas. Suzano has been actively participating in the program’s technical commissions.
Suzano’s plants also have ISO certifications as follows:
- the three polypropylene Polibrasil plants are certified by ISO 9001 (quality) , ISO 14001 (environmental), and OHSAS 18001 (health and safety) standards.
Politeno''s production facilities, both plants are certified by ISO 9000 and ISO 14001 standards.
- The three Petroflex plants are certified by ISO 9001, ISO 14001 and OHSAS 18001 standards.
- Riopol is being designed and built with the most advanced technology, adopting clean technologies, minimizing production of residues, and in accordance with best international environmental and safety practices. It is expected to obtain the ISO and OSHAS certifications.
Polibrasil has a corporate group dedicated to coordinate the EHS aspects of the company and each plant has specialized personnel dedicated to implement and ensure that the sound EHS practices are put into place. The company has a rigorous monitoring program including liquid effluents, ambient air quality, air and fugitive emissions, and workplace conditions. It also has an intranet system where all details related to EHS aspects are posted and are easily accessible to all employees.
The company has detailed EHS audits programs including internal and external audits. It has properly trained teams to conduct internal audits and also have third party audits such as those from:
- VERIFICAR, a voluntary Brazilian external audit system for Responsible Care Program and
- the audits to renew the ISO 14001, and OSHAS 18000 certifications.
The non-conformance items identified are resolved as soon as possible. Specifically, the following audits were carried out in 2004: Environmental Management System (ISO 14001); Occupational Safety and Health Management System (OHSAS 18001). EHS Management System of Contracted Companies; Incident Report; Emergency Control System; Maintenance Working Fronts of Operational Units; and Carriers of Chemicals.
To assess its alignment with its strategic plan, Polibrasil has developed performance indicators which also include key safety and environmental indicators, such as, water consumption per ton of end product manufactured, power consumption per ton of end product manufactured, steam consumption per ton of end product manufactured, environmental costs per ton of end product manufactured, mass of DQO in the effluent per ton of end product manufactured, VOC emissions, number of reportable accidents, absenteeism rate, etc.
Environmental Performance of Industrial Operations –
- Polibrasil Operations Duque de Caxias.
The main raw material used in the production of Polibrasil''s polypropylene is propylene. Propylene is provided locally within Rio de Janeiro, by pipeline from Petrobras refinery. It is also transported by ship from Camacari to the nearby Petrobras terminal and then it is sent by pipeline to the plant. A smaller amount is transported by truck. After the start up of operations at Riopol, Polibrasil will have access to an additional supply of propylene by pipeline. Petroflex, located nearby, supplies all the plant water needs (potable, clarified water and steam). The electricity is obtained from the Rio de Janeiro electricity distribution system. The packaging and warehousing operations are conducted by a third party, Katoen Natie.
All process emissions generated (i.e., plant purges, etc.) as well as emergency releases are sent to the flare to be burned to carbon dioxide and water. Dust generated in the extrusion area is collected by bag houses. Polibrasil periodically monitors fugitive emissions and makes improvements, as needed, to ensure emission concentrations are maintained at less than 500 ppm, as established by the USEPA regulations. By the end of 2005, the company will implement a fugitive emissions minimization program. Polibrasil also conducts ambient air quality at property boundary and participates in the air quality monitoring program of the entire Duque de Caxias Industrial District.
The wastewaters generated include domestic waters, process, and contaminated rainwater. After treatment, the effluents are leased into the Canal São José upstream of the Estrela River. The treated wastewater comply will Brazilian as well as World Bank requirements with the exception of oil and grease concentrations. Polibrasil anticipates sending its untreated wastewaters to be treated at the Petroflex plant. Polibrasil has committed to ensure full compliance of the wastewater concentrations with World Bank requirements by March 2006.
The company conducted soil and groundwater contamination assessments to determine whether there is contamination in the area. The results indicated that there are some minor violations based on the Dutch standard lists regulations. Even though, none of them were considered significant, Polibrasil will continue conducting monitoring to ensure no problems arise.
All waste generated by the site is disposed according to the Brazilian law and approved by the state environmental agency through a monthly report of waste disposal. Polibrasil has a waste recycling program for the waste generated on-site including, discarded product, plastics, glasses, metal, paper, printer ink cartridges and spent lubricant. Additionally, batteries and fluorescent lamps are collected and sent to specialized recycling companies. Health wastes and empty drums of lubricant and mineral oil are incinerated. Domestic wastes are sent to an authorized landfill.
Polibrasil conducts periodic monitoring of the wastes generated and produces a monthly report of the amounts of controlled chemicals used (sent to the Federal Police Department) and the amounts and types of waste generated, transportation companies, and disposal facilities.
In addition, Polibrasil conducts environmental audits to ensure good performance, as follows:
- an annual environmental legal requirements audit as a requirement by state law which is available for public consultation, is sent to the state environmental agency – FEEMA,
- an annual environmental management system audit and
- a responsible care audit.
As part of this project, Suzano will build a new terminal in the Guanabara Bay, Rio de Janeiro, in the same general area as the existing Petrobras terminal. After the new terminal is completed, Polibrasil will no longer use the Petrobras terminal. The company has conducted an environmental assessment including impacts, mitigation measures and the environmental action plan to be implemented during the terminal’s operation and which will comply with the applicable World Bank guidelines. Copy of this assessment is part of this environmental review summary (ERS). As part of Polibrasil’s commitment to reduce impacts, Polibrasil has agreed with the national environmental authorities (IBAMA) to recover five times as much of the natural area that will be affected, with the construction of this terminal, in an area approved by IBAMA. Suzano has also conducted a public consultation related to the terminal. Details of this consultation are also part of this ERS.
- Polibrasil Operations Maua:
The main raw material used in the production of Polibrasil''s polypropylene is propylene. It is transported by pipeline from Petroquimica Uniao and Petrobras refinery (RECAP), both located within the same Petrochemical Complex. RECAP also supplies the plant’s process water and firewater and the municipal water supply company (SAMA) supplies boiler, drinking, and sanitary water. The electricity is obtained from network distribution system. The packaging and warehousing operations are conducted by a third party, Katoen Natie.
The plant has a 21 ton/h-natural gas boiler whose emissions fully comply with the World Bank guidelines. The dust generated in the extrusion area is collected by bag houses. There are no hydrocarbons emissions released directly to the atmosphere since the purges are conveyed to an off-gas header and sent to RECAP for reuse. The fugitive emissions are monitored periodically and corrective action programs are put in place, as needed to ensure emissions levels below 500 ppm.
The process and domestic wastewaters generated are collected and treated in an activated sludge system and then sent to a holding basin (solid decanter) prior being released to the Tamanduateí River. The storm water is collected in a separated pit and then sent to an oil separator prior sending it to the same holding basin. All wastewater parameters with the exception of oil and grease comply with the applicable World Bank requirements. Suzano is committed to ensure compliance by December 2005.
As part of its continuous improvement program, the company has a water reuse program and has developed a waste recycling program for all waste generated in the site including plastics, paper, printer ink cartridges, spent lubricant and mineral oil, plastic glasses and metal. Additionally batteries and fluorescent lamps are collected and sent to specialized recycle companies. Empty drums of catalyst are currently being stored on site while a suitable disposal strategy is developed. The plant will build adequate areas to temporary store process generated waste by December 2005. Domestic wastes are sent to a landfill approved by the local authorities.
On 2001, the company conducted a soil and groundwater evaluation assessment which identified soil and groundwater contamination by a solvent (Isooctane) used as raw material in the old Slurry process. The source of contamination was eliminated on January 2003 when the Slurry Plant was decommissioning. The company has a remediation program in place using multiphase extraction. The state environmental agency (CETESB) is closely supervising this program. In addition, during the first quarter of 2004 the company confirmed that the contamination plume extends beyond the Polibrasil boundary and has reached two neighboring industries within the Petrochemical complex. The involved companies were informed and authorized the remediation actions. The remediation program will continue and cover this additional area. Suzano will maintain IFC informed of the evolution of this remediation program.
- Polibrasil Operations Camacari:
The activities currently conducted at this site include production; materials testing (in-process and final product quality control); materials storage and maintenance. The packaging and warehousing operations are conducted by a third party, Katoen Natie.
The main raw material used in the production of Polibrasil''s polypropylene is propylene. It is transported by pipeline from Braskem. All water, vapor, and energy needed are also supplied by Braskem.
The off-gas generated are collected and burn as fuel in a four-ton/h steam-boiler. The fugitive emissions are monitored periodically and corrective actions will be implemented as needed to ensure that the concentrations are maintained below 500 ppm. This plant participates of the ambient air quality program established in the petrochemical complex.
The storm water, and the process and domestic wastewaters generated are collected, pre-treated, and sent to CETREL, a centralized wastewater treatment system for the Camacari Petrochemical Complex. After treatment, CETREL releases the effluents, through an emissary, 5-km distant into the open sea. Polibrasil requested and was granted by the state environmental authorities a special standard for suspended and dissolved solid, provided CETREL agreed it is according its capacity to treat and is informed in advance. The company will complete a program to enhance the storm water system to ensure that no-untreated contaminated rainwater will be released to the environment, by June 2006.
The company has specialized areas to collect the wastes generated and has a waste recycling program for wastes generated (i.e., plastics, paper, printer ink cartridges, spent lubricant and mineral oil, plastic glasses metal, etc.) Additionally batteries and fluorescent lamps are collected and sent to specialized recycle companies. Empty drums of catalyst are currently being stored on site while a suitable disposal strategy is developed. Domestic wastes are sent to a landfill approved by the local authorities.
In 2002, the company confirmed soil and groundwater contamination at the plant’s site with isododecane a solvent used in the process. All wastewater pipeline system was inspected and replaced or fixed to avoid further contamination. To prevent the groundwater contamination to extend beyond the plant site, the company has installed a hydraulic barrier, and since December 2002, the company has been treating the contaminated water by pumping and extracting the solvent,(pump and treat), and using the recovered solvent in its operations. However, beginning September 2005, a new technique (multiphase extraction) will begin to be used to remediate the area. Polibrasil will maintain IFC informed of the progress in this remediation program.
- Health and Safety Programs
All plants have comprehensive occupational health and industrial safety management programs in place. As part of the occupational hazards management, the company has written procedures for safe handling and storage of raw materials and residues including hazardous materials, as well as, detailed emergency response plans covering fire, explosion, releases, and medical emergencies.
As part of its programs for emergency response, the company conducts risk analyses studies to identify the worst risks scenarios and implement actions to mitigate such risks. All new project or process modifications are evaluated by a risk analysis group, which uses the HAZOP technique, to identify and prevent major hazard risks. Specific information, containing all MSDS (Material Safety Data Sheets), for each of the chemicals handled at the plants is available in computerized form.
In addition, the plants conduct periodic emergency drills to train the plant personnel and particularly the emergency response brigades. Emergency drills including other plants within the industrial complexes as well as support parties (i.e., police, civil organizations, etc.) are also conducted. Specifically, the Maua plant will be conducting such a drill including nearby communities by March 2006. Once conducted, Polibrasil will inform IFC of the results (lessons/recommendations) of this programmed emergency drill. In addition, all plants participate in the Joint Response Committees (Comites de Ajuda Mutua) conformed by the various chemical companies within the industrial complexes and the regional fire departments.
Detailed EHS training programs are also in place to ensure that all personnel including contractors are duly informed and prepared to deal with the EHS risks and implement the sound practices to prevent unsafe situations.
For the transportation of chemical materials and end products which is conducted by subcontractors, Polibrasil also has written handling and emergency response procedures which are rigorously applied by the company. In addition, the transportation companies are required to implement the Responsible Care guidelines for transportation of hazardous, which include independent third party audits.
At all plants, the chemicals are properly stored (i.e., tanks, cylinders, drums, etc.) The raw material (propylene) is adequately stored in spherical tanks with all needed safety and preventive precautions (i.e., alarms, fire response systems, etc.). Raw materials are located distant form the operations and, as needed, stored products (i.e., caustic soda, PEEB, mineral oil, and peroxide organic vessels) have double containment walls to prevent soil/ground contamination from leaks and/or accidental spills. The radioactive sources used mainly for level assessment are properly handled in accordance to the Brazilian regulations.
The company also has programs in place to prevent and control the occupational hazards in the workplace, as well as periodic monitoring of workers exposure to noise, chemical, radiation, vibrations, heat stress, etc. All plants have been implementing programs to reduce noise in the workplace as well as ergonomics improvements in the office areas. Remaining noise improvements will take place in Maua plant in 2005.
Polibrasil has a medical program to control the staff and contractors health associated with the hazards exposure in the workplace. Annual medical examination, pre-employment evaluation, demission medical evaluation, biological monitoring, and industrial hygiene evaluation are conducted. All accidents and “near miss” incidents are investigated and documented. All Polibrasil plants had “zero” work related reportable accidents in 2004. To further enhance its work environment, the company will begin implementing a safety process program based on behavior.
Other programs implemented by Polibrasil at its plants to promote the management of working factors that relate to the employee’s quality of life in the workplace include stress awareness and control, ergonomics, physical fitness, non-smoking, high-pressure control, and nutrition programs.
The three polypropylene facilities operate on a three-shift, around-the-clock work schedule, year round, except for scheduled maintenance downtime.
Supply Chain Aspects –
As part of Polibrasil’s effort to ensure that its suppliers and contractors comply with Polibrasil’s policies, the company has formal procedures to identify, reduce and avoid negative impacts due to contractors and suppliers. All contractors are required to have sound EHS practices and demonstrate that they do not engage in child or force labor practices in their own operations. Staff and contractors only start their activities in the workplace after taken basic EHS training. Polibrasil periodically conducts audits to evaluate the EHS performance of its contractors. In addition, all contractors are trained and monitored just as Polibrasil’s direct employees. Workplace related statistics assess Polibrasil’s direct as well as contracted employees.
Communication and Consultation –
The company has a communication policy that establishes the means to ensure effective internal as well as external communication. At each of its sites, the company makes part of the petrochemical complexes Community Councils which are the official means of interaction of the industries with the communities. The company also made available to the community the number and responsible person at each site and has an external website with contact information as well. And as a voluntary signatory of the Responsible Care program. it also complies with the communication requirements established by this imitative. In addition, concerns or complaints at the corporate or plant levels are channeled to the department in charge of the specific environmental, health, safety, or social issue.
Corporate Social and Environmental Responsibility –
Polibrasil’s track record of community projects reflects a corporate philosophy that contributing to community development is both good business and good ethics. The company participates in the Petrochemical Complexes Consultative Community Councils, in conjunction with other companies from the complexes. These Councils objective aims at discussing issues and solutions of common interest, emphasizing those aspects related to safety, health and environment directly associated with the companies’ activities. At all its sites, Suzano has established a direct and permanent communication channel between nearby communities and the industries from the Petrochemical Complexes.
As part of this project, Suzano is being stimulated to develop a program concerning post-consumer plastic. It will initially prepare a business plan addressing collection, segregation, reuse, and market opportunities. Copy of this program, including proposed actions and implementation schedule will be submitted to IFC by November 2005.
Suzano also publishes an annual Social Report based on the Ethos Sustainability indicators and has developed social programs aiming to help the communities nearby its plant sites targeting mainly education (schools, libraries), health (hospitals, health campaigns), culture (films, paint) environment (recycling). Examples include, sponsoring the project PLASTIVIDA which aims to stimulate recycling initiatives in Brazil, continuing partnership with the AACD, the Association for Handicapped Children, to provide medical, teaching and social services to principally handicapped children and adolescents. In Camacari it also supports the COOPEMARC, a cooperative of domestic residues collectors who recover and sell reusable goods mainly paper, plastic, and glass.
All other associated companies, (i.e., Politeno, Petroflex, and Rio Polimeros) also have sound community initiatives including the Rio Polimeros mangrove’s project, which is recovering 13 hectares of mangrove around the Guanabara Bay (the bay of Rio de Janeiro). Petroflex has received several national awards as a result of its social programs.