The sponsor has presented an outline and commitments 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.
Artemisia annua (Artemisia) growing requires minimal water input (irrigating only twice per week with some locations only rain fed) and limited pesticide use, which are specially selected to have a short leaf life. Fertilizers are used based on soil analysis and suitability review which is done for all farms (captive and out grower). From a resource (water and chemical) point of view, the production of this crop is thus not intensive. ABE has developed a set of comprehensive plans to address the above issues. These plans include the following: Growers Manual - for all out grower reference based on EUREP-GAP; Production Procedures and Policy Manual – for Extension Workers as a field tool; Code of Practice for Agrochemical Use – guidelines for chemical inputs incorporating IPM principles; Safety Management Manual – for Kabale and Athi River Extraction Plants; and Environmental Management Programme (EMP) – for the Athi River and Kabale Extraction Plants. These plans and documents govern all aspects of production from the field to extraction plant and address the key issues listed above.
- Land use change
No land use change negatively impacting sensitive habitat or having negative economic impact is anticipated. All Artemisia growing is being done in existing agricultural areas and impacts will be positive as the project will diversify local incomes. ABE is coordinating its activities with the Kenya Plant Health Inspectorate (KEPHIS); National Institute for Medical Research (Tanzania); and the Uganda Agriculture Productivity Enhancement Program (Uganda). ABE did not introduce Artemisia to East Africa; it sources its seeds from renowned and credible sources; and has a policy against using GMOs.
- Pesticides handling and application
As mentioned there is limited pesticide used in the production process (out grower or captive). While fertilizers are used and trials are underway for a suitable herbicide, all chemical use and agricultural practice is in line with EUREP-GAP and Integrated Pest Management (IPM) principles. No pesticides are registered for use in Artemisia nor are they ever likely to be. However, Novartis have undertaken to carry out Maximum Residue Limits (MRL’s) on a number of pesticides, including spiked trials, that determine no detectable pesticide residues are present in the leaf at post harvest stage.’
- Water supply
Out growers will be required to obtain water permits for their extraction source points and provide copies of these to ABE, most out growers are anticipated to have rain fed crops. With respect to captive crop production ABE must ensure water permits exist for all extraction points. No negative impacts on other users are anticipated based on leased land locations and planned irrigation needs. ABE will be required to measure extraction rates and liaise with the respective water authorities and other users in the area on a regular basis and modify extraction rates based on this coordination. Two of the captive operations fall within the Lake Naivasha area in Kenya. ABE water use on the two farms (which are about 6 km from the Lake) is from 6 existing boreholes and ABE’s percentage use of borehole water will be under 10% of individual borehole yield. Anticipated irrigation rates are low at 10 m³/ha/day at 2 days/week in dry periods (less in wet) and area under irrigation by ABE is small at approximately 500 ha, which translates to less than 5% of the respective estates. Impacts are thus expected to be minimal. The Kericho captive growing operations are 100% rain fed. Water supply for extraction operations is from the local grid.
- Power Supply
The main power consumption is at the Extraction Plant level for steam/heat generation. ABE is installing a biomass boiler at Athi River to generate steam from waste/spent leaf. This will result in large energy efficiencies and reduce fossil fuel consumption. The plant at Kabale is oil fired but is small capacity and complies with applicable guidelines on a mass emissions basis. In due course, a biomass boiler will also be installed at Kabale. Electrical supply is otherwise from the grid and backup power for office and general use is from generators which will be equipped with secondary containment for fuel supply.
- Out grower extension services
The Growers Manual and the Production Procedures and Policy Manual, listed above, govern the standards which out growers must meet and the services and commitments ABE will provide. These documents advise and recommend systems to minimize erosion; prevent field contamination of the crop (from chemicals, manure etc.); improve soil quality (periodic testing of all Out grower soil is done based on a predetermined need by (ABE); maintain plant health; harvest when drug content in the plant is optimal; use only recommended levels of fertilizers based on soil analysis; and periodically rotate crops. ABE have tapped grant money from a variety of sources to support technical assistance (TA) and out grower support services; IFC, on review of these programs, will attempt to define, as necessary, a role to further boost these efforts.
- Labor standards
ABE follows respective national law and EUREP GAP requirements with respect to labor practices. No minors/children are employed in the operations; ABE will ensure, by screening/discussing with Out growers, any potential for harmful child labor at the smallholder level. Employee wages, health benefits, pensions, work hours and conditions will be as per national law. It is ABE’s intention to maintain, for its development impact, Out growers to Captive growing at a ratio of approximately 50-50. Of these Out growers approximately 60% will be large operations (of several hundred ha) and 40% smallholders at anywhere from 1-2 ha or more. Extension services will be supplied to both categories of out grower.
- Hazardous materials management/ Extraction Plant Safety
The extraction process is solvent based and utilizes hexane and ethanol. Hexane is a highly flammable and volatile substance. The storage facilities for hexane at Athi River were developed according to Shell standards, who will supply the hexane in their own trucks; and the Athi Plant was designed by Pharmaplan (India) to the NFPA Standard for Solvent Extraction (a US based code). However a HAZOP is necessary and ABE have agreed to complete a HAZOP for Athi River and Kabale prior to operationalizing the Athi River Plant. In addition the company will develop an EMP for the Kabale Plant based on the Athi River EMP. ABE are also targeting ISO 9001 compliance.
- General employee safety and training
ABE have developed a comprehensive Quality Management System which governs safety at the agricultural and extraction plant level and incorporates the standards and plans previously mentioned. This system incorporates EUREP-GAP principles, Good Manufacturing Practices (GMP), NFPA fire safety standards, and OSHA workplace standards. Employees handling hexane and ethanol will receive specialized training and will undergo regular medical checkups. Other staff will be provided with personal protection equipment and training appropriate to their duties.
- Waste disposal
Generated from the operations is minimal and mainly comprises: spent leaf – which will be reused as fuel in the biomass boilers or composted; liquid effluent at the extraction plant level – which comprises only water and hexane (100% of hexane is recovered); air emissions from boilers and generators – which will be minimal based on capacity and heat input; general office and workshop waste – which is disposed of in compliance with local law; spoil from construction of the Athi River Plant – which will be disposed of in a designated site. Bi-products from the production process (oil, waxes, and camphor) are valuable and recovered for sale.
No CFC or PCB based equipment will be used as part of the project. ABE has set a high bar with respect to the standards to which they are developing this project and are following international standards and best practice at the agricultural and manufacturing level. This project will have significant global health benefits and significant local benefits for rural farmers.
This ERS will be made available at the ABE Extraction Plant in Athi River and Kabale, the Company offices at Nakuru, Kampala, and Usa River and the respective municipal offices of these locations. Availability of the ERS at these locations has been advertised in a national newspaper.
