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 - 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. Further information is provided in the attached documentation.
- Corporate social, environmental, and health and safety management systems
National and local government permitting requirements:
The Tata Group is recognized internationally as a leader in progressive environmental, social responsibility and occupational health and safety initiatives, all of which are well established within TTL. Tata’s approach to environmental management requires that all Group companies:
- develop a vision and mission statement that state their policy on environmental management;
- define a corporate environment policy and communicate the policy to all employees;
- establish environmental management systems and programs, and budget annually for environmental improvements;
- train employees on environmental performance and systems;
- regularly assess resource consumption and opportunities for minimizing discharges to air, water and land;
- set quantitative objectives and targets for continuous improvement meet or exceed legal compliance levels;
- review environmental performance throughout the organization;
- regularly disclose annual environmental performance to stakeholders; and
- move toward certification to international standards such as ISO 14000/14001. TTL has obtained all requisite Government of India “Consents to Operate” for its existing operations under the Air Act, Water Act and Hazardous Waste (Management and Handling) Rules (HWMH Rules).
The new Company, NEPC, will make copies of these permits and authorizations available to IFC as annexes to the Annual Monitoring Reports.
- Sources and volumes of water, including water minimization, recycling and harvesting:
TTL uses a total of 97,000 cubic meters (m3) of water per day for all domestic and processing purposes at the 24 plantations included in the project. An additional 45,000 m3 is used for irrigation purposes at 13 of the 24 estates during the dry season (mid December to mid March). Water is obtained from both surface and underground sources. TTL has undertaken efforts to minimize water use, including testing soil moisture levels regularly and only irrigating when levels reach a minimum level, and irrigating early in the morning or late in the afternoon to minimize evaporation losses. TTL’s management team has initiated rainwater harvesting programs at two of the estates (Teok and Borjan) and estimates that these have accounted for savings 2500m3 of water annually. The NIPO management group, which will comprise the management team at NEPC, intends to roll out its rainwater harvesting program at all of the estates over the next two years. As part of its continuous improvement efforts, NEPC will continue to assess methods for reducing water consumption at the estates, and will report annually on these efforts to IFC and other stakeholders.
Biodiversity conservation and sustainable resource management:
The entire area under cultivation has been heavily modified, having been used as tea plantations for more than 100 years. Within this existing land use framework, TTL has a well developed program to ensure the sustainable management of the lands under its control. Use of agrochemicals and extraction of water are both minimized. Under its existing labor agreements, TTL must provide a source of cooking fuel to its employees. Fuel for this purpose is obtained largely from fallen trees and a carefully monitored program of harvesting large trees that are excessively shading certain estates, resulting in sub-optimal growth. Concurrently, TTL oversees a tree planting program to add cover to those parts of the estates that are receiving too much sun. At present, a total 150,000 shade trees are planted annually. It is expected that NEPC will continue a similar level of planting.
Sources and volumes of power, including fuel storage and biomass power generation potential:
The tea estates currently obtain most of their power requirement from generators fueled by high speed diesel (HSD) oil and furnace oil. Coal is used to fire tea dryers, and solar power is used for lighting and to pump water at some of the estates. Annual fuel consumption at all of the estates in the 2005-06 financial year was approximately 4500m3 of HSD oil, 15,000 tonnes of coal, and 1700m3 of furnace oil. As part of its program of continuous environmental improvement, TTL has undertaken a number of projects to reduce energy consumption and convert to cleaner fuels. To date, 10 of the 24 estates have converted completely to natural gas use. TTL expects that, by 2008, natural gas will be made available to the North Bengal area by extending the existing pipeline from Assam. When this happens, the remaining 14 estates will be converted to natural gas. As another energy saving measure, TTL has replaced aluminum fans used in the withering (the first stage of processing) troughs with fiber reinforced plastic (FRP) fans. FRP blades achieve higher optimum efficiency, resulting in improved air delivery per unit of power. TTL estimates total power saving from this measure to be 28-40%. The NIPO management team has set up a working group to identify energy efficiency and cleaner energy options within NEPC, and will report annually on these efforts to IFC and other stakeholders.
Air emissions:
There is no single large scale source of air emissions at the NIPO estates. The continuous burning of small amounts of fossil fuels, especially coal, results in dispersed emissions of particulates, NOx and CO2 over the 260 square km of the estates. TTL management has undertaken a number of initiatives to reduce its reliance on fossil fuels, as described above. Ongoing efforts to convert natural gas at all of the estates will reduce overall emissions to negligible levels. In the interim, NEPC will report annually on the results of these efforts to IFC and other stakeholders, including volumes of all fossil fuels used during the reporting period. Dust generated in the tea sorting room is removed by the exhaust fans. In addition, masks are provided to all employees working in the sorting room, and the use of these is strictly enforced.
Handling and management of agrochemicals and pest management practices and guidance to outgrowers:
Under Indian regulation, tea growers may only use a specified number of agrochemicals permitted by the Indian Tea Board. TTL has provided the IFC with the names of all chemicals used and the volumes consumed on an annual basis. None of these is listed on IFC’s Environmental, Health and Safety Guidelines for Pesticide Handling and Application (July 1, 1998) as either banned pesticides or pesticides whose use should be avoided if suitable alternatives are available. Field workers regularly scout for pest infestations and only apply chemicals when levels reach predetermined thresholds. To minimize potential chemical exposure to its employees handling hazardous chemicals, TTL provides all requisite personal protective equipment (PPE) including hand gloves, goggles, masks, boots and aprons as per requirements and recommendations for handling the various types of chemicals used on the estates. TTL also endeavors to rotate employees involved in agrochemical handling/application every quarter to a non-hazardous operation. Employees involved in spraying operations are given quarterly medical check-ups, including cholinesterase and other blood tests, bilirubin test, chest x-ray and urinalysis. Any employee whose tests indicate excessive exposure is immediately rotated off spraying operations. Although TTL has previously undertaken training on safe handling and application of agrochemicals, the Company is stepping up this training for all employees involved in spraying/handling of chemicals. All chemicals are stored in a locked and ventilated building. A color-coding system (ANSI) is in place for hazardous chemicals identification, including detailed labeling including information such as hazardous properties, recommended first aid measures and preventive measures. The Company will expand this system to include daily-use chemicals and stock chemicals, and will ensure that Material Safety Data Sheets (MSDSs) for all chemicals in use are made available in all locations. In conjunction with the India Tea Association, TTL is involved in experimental work to identify non-chemical pest management options suitable to its estates. TTL management has reviewed IFC’s Environmental, Health and Safety Guidelines for Pesticide Handling and Application (July 1, 1998) and agreed to abide by its provisions. TTL has not relied on outgrowers to ensure capacity for its processing plants, and NEPC does not intend to do so either.
Minimization, recycling and disposal of solid, liquid and hazardous wastes:
TTL management has adopted a comprehensive plan for managing solid and hazardous wastes. Small amounts of non-hazardous solid waste generated from the packaging, facility cleaning and sweeping is burned. Hazardous wastes from the factory include batteries, small amounts of used oils and chemical wastes. Batteries are disposed in a secure landfill, and used oils from generators are soaked in fibrous wastes (e.g., cotton bags) and burned. Expired or unused chemicals are returned to distributing companies for proper disposal or buried in secured landfill site. Empty chemical containers are rinsed, punctured and buried in a secure landfill. Hazardous medical wastes from clinics/hospitals on the estates, including needles, syringes and other sharps, are placed in puncture-resistant plastic/metal containers, autoclaved or otherwise disinfected, and buried in secure landfill site. Glassware is disinfected by autoclaving and then buried in secure landfills. TTL intends to install an incinerator at the estates’ hospital for disposal of these items in future, and NEPC will report on the status of the incinerator in the Annual Environmental and Social Monitoring Report (AMR) it submits to IFC. Non-hazardous solid wastes also will be burned in the proposed new incinerator. TTL will commence periodic audits of its hazardous waste generation and disposal procedures and volumes and report these to IFC annually.
Hygiene, fire and life safety, and emergency response at processing facilities:
Indian regulation of the tea industry, as well as the requirements of international customers requires all processed tea to be routinely sampled and tested for chemical residues. Results from the last two years of monitoring more than 800 packed tea samples, undertaken by in-house as well as third party laboratories, indicate that TTL tea is largely free from residues of pesticides / herbicides. In instances where pesticide residues have been detected these have been well below the stipulated international (EU) maximum residue levels (MRLs). Fire may occur in buildings involving tea manufacturing operations particularly in withering houses, where preliminary drying of houses either by natural or artificial means is carried out. TTL has adopted comprehensive fire prevention, identification and response protocols to minimize the likelihood of fire in the tea factories. These include predetermined safety measures in the construction of buildings, installation of machinery, and management of storage areas; and by providing adequate fire fighting arrangements. The Company follows the Bureau of Indian Standards (BIS) norms for fire fighting (IS: 2190) as regards the selection, installation, maintenance, testing and refilling of fire extinguishers. All employees receive training in fire prevention and response, and drills are held regularly at all of the estates. Employees also received training in first aid methods related to a wide range of agro-industrial accidents and injuries.
Labor management practices, including child labor, in the Company and its supply chain:
A total of 30,818 full time workers are employed at the 24 estates that comprise NIPO. TTL’s labor management practices are consistent with the Tata Group’s approach to labor standards, which have been at the forefront of Indian corporate practices. Tata was the first Company in India to establish an 8-hour working day and to provide employee benefits ranging from free medical aid, a provident fund, leave with pay, maternity leave, and accident compensation. In addition to ensuring that basic housing , sanitation facilities, and water supply are available to all workers, TTL provides significant employee/community infrastructure at all of the estates, including drainage systems and roads, streetlights and security services, recreation centers, and school buses for worker’s children studying outside the estates. TTL initiated the process of obtaining SA 8000 certification for 20 of its NIPO estates in October 2005 and expects to obtain certification for all 24 estates by December 2006. In addition TTL is in the process of obtaining certification of all its estates by the Ethical Tea Partnership (ETP), a UK-based organization with the aim of ensuring responsible tea production and ethical trading of tea. Launched in 1997, with a partnership of 17 member packer companies covering 47 brands of Tea sold in over 30 countries, ETP is the largest monitoring program of its kind in the world and currently monitors 1200 estates in eight countries. ETP’s objective is to provide independent verification that employment is freely chosen, freedom of association and the right to collective bargaining are respected, working conditions are safe and hygienic, child labor is not used, total remuneration packages are negotiated between unions and employers, agreements are in place regarding working hours, and no discrimination or harsh/inhumane treatment is allowed. Independent monitoring bodies assess a range of indicators including minimum age of workers, minimum wage, hours or work, equal opportunity, total remuneration, workplace health and safety conditions, medical and education facilities, housing, and basic human rights. The ‘worker-shareholder’ model that is the basis for NEPC is predicated on a continuation of these policies and procedures.
Workplace and community health and safety:
In accordance with its corporate philosophy and labor policies, TTL has in place strong workplace health and safety programs. Given the socio-economic nature of tea plantations, in which the workforce and its families comprise a large percentage of the ‘affected community,’ these policies and programs extend significantly into the surrounding community. TTL initiated a Community Development and Social Welfare (CD&SW) Program at the NIPO estates in 1984. The program’s objectives are designed to improve the quality of life of all TTL workers and their dependents, including raising the standard of living of the worker and his/her family, improving the health of the entire family; and encouraging small family norm as the felt need for better health and raised standard of living.
In the area of health care, the program provides:
- health care to all the workers and dependents through a system of estate hospitals (more than 1000 beds in total), dispensaries and a referral hospital; - full obstetric care provided to all resident pregnant mothers through the estate health care system; - early detection of at risk mothers and intervention for safe motherhood;
- regular growth monitoring of the children from infancy to 6 years of age;
- universal immunization of all children living on the estates;
- nutritional care of children aged 0-6 years at creches, through supplementary mid day meals; - --
- periodic regular health clinic for children aged 0-6 years to prevent, control, and reduce the prevalence of childhood diseases; and
- regular health education programs for the estate population conducted through estate hospitals and health extension staff.
Statistics for the past year indicate that some 28,600 in-patients and 472,200 out-patients received treatment at NIPO hospitals. CD&SW programs in the areas of education include:
- pre school learning in Montessori format to prepare children aged 2-6 years for regular schooling; and
- promotion of adult literacy among all workers, through Adult Education classes are held in the evening in over 52 adult literacy centers on the estates.
TTL currently runs 21 schools on the estates, in addition to 43 Government schools, providing education to a total eligible population of approximately 13,000 children.
Corporate social responsibility efforts, including HIV/AIDS:
Tea plantations are the main economic activity and the pre-dominant source of employment in northeast India. Both the State governments and the industry recognize the need to diversify the regions economic base. TTL has taken a leadership role in identifying and piloting non-tea crops and other economic activities, such as tourism, to diversify the region’s economic base and provide new sources of income. In late 2004, TTL engaged a business consultancy Company to undertake a study of options for re-thinking the tea industry model. The study report indicated that the tea estates could significantly increase their total profitability by developing non-tea agricultural crops, fisheries, and innovative businesses like tea/nature tourism. Based on the study findings, TTL has undertaken pilot programs to test and evaluate the suitability of 17 types of vegetables, five flower varieties, and small commercial scale fisheries. The results of these pilots are being used to identify the most promising non-tea crops for specific estates; as an example, all of the floriculture experiments yielded exceptional results in terms of product quality and the cultivation of these will therefore be taken to an expanded level of production. The Company has obtained approval from the Government of Assam to carry out these experiments on an area of 50 hectare at the Borjan and Hathikuli estates and, subsequently, received Government of Assam approval to carry out alternative cropping on 5% of its total grant area of tea. To date TTL has spent approximately $175,000 on non-tea crop experiments on the NIPO holdings. NIPO is interested in receiving information from IFC Against AIDS and assessing how it can be effectively disseminated among its employees and their families.
