The company 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 including: the host country laws and regulations; IFC’s Performance Standards; and the World Bank Group (WBG)/IFC environmental, health and safety guidelines. The information about how these potential impacts will be addressed by the company is summarized in the paragraphs that follow. Further information is provided in the attached documentation.
- PS 1: Social and Environmental Assessment and Management System
JISL’s management is committed to proactively addressing environmental, social, occupational health and safety (EHS) aspects associated with its operations. The sponsor and the company have received several international and national awards for entrepreneurship, innovation and environmentally responsible initiatives. JISL has articulated quality, health and safety, environmental, and social accountability policies.
The company’s:
- dehydrated products unit has management systems certified to ISO 9000:2000, ISO 22000:2005 (HACCP and Food Safety standards), British Retailer Consortium standards, Codex Alimentarius, Kosher standards and is US-FDA registered;
- fruit pulp & concentrate products division has management systems certified to ISO 22000:2005 standards, SGF International Standards, Codex Alimentarius, Kosher standards and is US-FDA as also JAS registered;
- the plastics division has management systems certified to ISO 9000, ISO 14001 standards and is in
the process of obtaining a certification in accordance with OHSAS 18001 standards;
- owned agricultural sites are EUREP GAP certified; and
- its tissue culture lab is ISO 9001 certified, and central laboratory operations are certified to GLP standards and have applied for NABL certification.
While the above said management systems focus on quality and food safety, barring at the plastics plant where the company has implemented an environment management system (EMS) as well, JISL also has processes in place to manage environment, occupational health and safety aspects associated with its operations. The company will further strengthen the processes for management of EHS aspects and will, within a timeframe agreed with IFC, implement across all of its operating facilities, EHS management system (EHSMS) certified to ISO 14001 and OHSAS 18001 standards, with IFC’s Performance Standards and EHS guidelines duly embedded in the EHSMS. Further, the company will evaluate the possibility of obtaining an appropriate and internationally recognized Fair Trade certification.
JISL undertakes limited environment and social assessment (ESA), adequate for the nature of its operations and has management program in place to mitigate the identified impacts. However, while implementing the EHSMS, the company will undertake a comprehensive ESA, identify the significant EHS impacts and risks associated with its operations, and implement management programs to minimize/mitigate the identified impacts. JISL will ensure that the management programs incorporate relevant provisions of IFC’s Performance Standards and WBG/IFC EHS guidelines.
The company has employed, in-house fulltime qualified professionals, for oversight of EHS aspects. In its other facilities, the management representative for the quality and food safety management system also oversees EHS aspects. The company will, at each of its plant/facilities and also at corporate level, employ fulltime and appropriately qualified EHS professionals to oversee implementation of and adherence to the EHSMS. The company will, as part of the EHSMS, require its contractors to also adhere to JISL’s EHS procedures and will implement a training program for contractor’s labor. The company has procedures for recording, investigation and reporting of EHS incidents. The company will upgrade the incident monitoring and investigation process to include contractors’/contract labor as well. The company has procedures in place for periodic monitoring and internal reporting of EHS performance on a monthly cycle.
- PS 2: Labor and Working Conditions
JISL has a HR manual and manages labor working conditions under the state government’s Model Standing Orders. The Model Standing Orders are generally consistent with PS 2 provisions and are displayed in the local language at plant premises. The company has HR professionals deputed at each of its plants, who are responsible for communication of JISL’s HR policies to employees and labor. Working conditions are communicated to employees and labor through their appointment letters, and in the orientation program. JISL has started putting in place a joint works council, comprised of both management and worker representatives, to receive and redress worker concerns. The company will implement the joint works council process across all of its facilities. The company will review IFC’s Performance Standard 2 (PS2) and will, within a timeframe agreed with IFC, articulate policies and procedures, to make its HR practices consistent with IFC’s PS2 provisions. Towards this, the company will engage a third party to:
- review the existing HR policies, procedures and practices against PS2 provisions; and
- develop an action plan, for development and implementation of policies and procedures where required, that are consistent with PS2 provisions.
The company will, going forward, manage occupational health and safety through its OHSAS 18001 certified management system. In the interim, the company will upgrade the status of occupational health and safety on its manufacturing premises particularly: fire safety system, emergency response, safety signage and exits; ventilation; guarding of moving parts; health hazard identification and control; and occupational health evaluation and monitoring. The company has put in place safety committees comprised of both worker and management representatives, which meet on a quarterly cycle to develop and implement corrective action plans. JISL will put in place safety committees at each of its manufacturing facilities. While JISL provides personal protective equipment (PPE) to all employees, its usage by workers including contract labor, needs to be improved. The company will implement a company wide safety training program and EHS induction training for all new employees, labor (including contract labor), entering a company facility. JISL ensures that doctors/para-medical staff and ambulance are available at all of its facilities. While JISL undertakes annual workplace air quality monitoring, the company will, within a timeframe agreed with IFC, undertake a benchmark workplace air quality monitoring program at its plastic processing plant, to demonstrate compliance with IFC’s EHS guidelines.
- PS3 : Pollution Prevention and Abatement
JISL will, going forward, manage environmental impacts of its operations as per the ISO 14001 certified EMS. The main business of the company, MIS, promotes water conservation and pollution prevention. Further, the company also assembles and markets solar heating and lighting systems. The company has implemented various energy efficiency and resource conservation measures on its own premises including use of: solar heating and lighting systems; generation and use of biogas from domestic sewage and process effluents; use of treated effluent in irrigation on premises; bio-diesel production pilot and vermi-composting of non hazardous solid wastes with high organic content.
At JISL’s facilities in Jalgaon: there is an effluent treatment plant comprised of sequenced anaerobic and aerobic treatment and the treated wastewater meets host country requirements; domestic sewage is treated through septic tank and the overflow is led into the ETP; furnace oil based boilers have bag filters and the emissions to air meet host country requirements; there are diesel generator sets for backup power; hazardous ETP sludge and other hazardous wastes are disposed through authorized entities in a secure land fill or for regeneration or recycling; management of scrap and other non hazardous wastes needs to be upgraded though these are presently being segregated and sold to recyclers; and the refrigerant gases in refrigeration systems and chillers are in accordance with host country regulations on ozone depleting gases. Going forward, JISL will implement company wide procedures and measures to ensure that: facility emissions and discharges; ambient air quality and noise levels; management of hazardous materials, hazardous wastes and other wastes; specific water and energy consumption; use of refrigerant gases; and monitoring as also reporting program, are in accordance with both host country and IFC norms. JISL undertakes contract onion farming on 4200 acres of land through 1700 contract farmers. The company has processes in place to ensure pragmatic use of pesticides.
Further, as part of its EHSMS, the company will implement procedures to ensure that pesticides under WHO hazard class Ia, Ib and II are not used in its contract farming operations or on its premises. JISL will, develop and implement an Integrated Pest Management (IPM) and Integrated vector Management (IVM) program in its contract farming operations (as also on its own premises), to reduce reliance on synthetic pesticides. Further, the company will also, implement a program to build farmer awareness on and to encourage farmers, to adopt IPM and IVM techniques. The company uses Aluminum Phosphide and Methyl Bromide for export containers fumigation purposes only. While the company has outsourced fumigation to agencies authorized by host country regulators, the company will implement procedures to ensure that such agencies carryout fumigation in accordance with international good practices, to mitigate risk of occupational exposure to these fumigants.
- PS4:– Community Health, Safety and Security
The company uses equipment and infrastructure that meet good industry practices. The company will, as part of the EHSMS, put in place procedures to: assess potential community impacts of its projects and operations; mitigate identified risks and impacts including risk of uncontrolled release of hazardous materials from its operations or in hazardous material transport. Further, the company will prepare and implement an onsite and offsite Disaster and Emergency Management Plan, and link it to the district emergency response plan.
The company employs security, which is unarmed. The company implements procedures for ensuring that: past records of security personnel employed are screened; and security personnel have clear objectives and permissible actions laid out. Further, the company will, within a timeframe agreed with IFC, implement procedures so that security personnel are trained in avoidance of human rights violations and the use of fire arms; security incidents are recorded, investigated and corrective action implemented; bona fide complaints against security personnel are investigated and appropriate disciplinary actions are implemented; and there is a grievance mechanism for aggrieved members of community or employees, in the event of a violation of the code for security personnel. The company will evaluate adoption of the UK Voluntary Principles on the Use of Security Forces.
