The IFC appraised the following social, environmental, health and safety issues:
- social and environmental management systems.
- community engagement;
- labor and employment practices;
- worker health and safety, ongoing within the plant and during construction;
- water extraction and usage;
- air emissions, including ambient air quality in the cement plant and air emissions from the new captive power plant;
- liquid effluents and solid waste;
- quarry management and rehabilitation;
- workplace and ambient noise;
- community health and safety, particularly related to truck traffic;
- fire prevention and emergency response; and,
- land acquisition
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 IFC Policy and Performance Standards on Social and Environmental Sustainability, 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.
- PS1: Social and Environmental Assessment and Management System:
Under Senegalese law, the company must provide environmental impact assessment documents for new projects that have potential social and environmental impacts. In this case, the documentation covered three aspects of the proposed IFC project: the new cement production line; the new 24 MW captive power plant; and the extension of the quarry. These documents were made publicly available for a period exceeding 30 days and were subject to both technical review and public hearings that included community representation. The IFC reviewed these documents and found them generally acceptable to meet IFC standards. The documents, however, lacked non-technical executive summaries. Furthermore, some significant aspects of the IFC project were not covered, in particular the measures to reduce air pollution from the existing kilns. The company is implementing these mitigation measures to meet Senegalese air emissions standards set in 2003, which must be met by June 2007 under an agreement between industry and the government. The government does not require that the company undertake an environmental assessment of these improvements. To cover the need for both a non-technical summary and to cover all aspects of the proposed IFC project, the company has agreed with IFC to write a non-technical executive summary that will be publicly disclosed.
The quarry extension and captive power plant have already received government approvals and are under construction. The new cement production line is waiting for final approval, but the ESIA has been the subject of public disclosure and review. SOCOCIM will provide IFC with copies of all available clearance documents prior to IFC’s investment.
Management of social, environmental, health and safety issues is integrated into the regular management lines of the company. The company does not have a formal social and environmental management system. However, the existing system, with environmental responsibilities built into line manager job responsibilities, addresses in practice IFC’s requirements under PS 1 for a system that identifies risks and impacts of projects; defines policies and objectives; assigns responsibility and provides training for those responsible; monitors the results; reports on those results; and seeks continuous improvement. Responsibility for community engagement rests with a manager within the Sococim general manager’s office, with decisions about community expenditures made at the Sococim Board of Director’s level. The plant has a long-standing health and safety committee made up of workers from various parts of the plant, including union membership. The plant has recently started an environmental committee as well, with similar membership. The environmental committee provides a newsletter on its activities that is available to the local community.
The company’s commitment to continuous improvement in environment, health and safety is evidenced, with respect to the environment, in the operation of the existing facilities, and by the declining lost-time accident rate in the plant over the previous three years. The accident frequency for 2005 was around 5 Lost-Time-Accidents per Million-Man-Hours, which is within the normal range for this type of operation.
Training on health and safety is provided to new hires, and one third of the workforce is retrained each year on fire fighting and on safety. Managers receive yearly training on managing health and safety and risk management. Environmental training is covered during training on the operation of specific types of equipment, training that the manufacturer provides.
Sococim’s community engagement, as previously mentioned, includes consultations related to the EIAs and the recent effort to provide a newsletter on environmental performance to the local community. The company also provides support on both a regular and ad hoc basis to local community projects, such as support for educational and women-related projects in cooperation with the local government of Rufisque East. IFC finds this community engagement to be adequate for the purposes of PS 1, but has recommended a more formal approach, with longer-range planning, in the development of community projects.
- PS2: Labor and Working Conditions:
Sococim does not have a formal human resources policy. The company will develop one and provide it to IFC to meet the provisions of PS 2 prior to IFC’s investment. In practice, however, Sococim meets the fundamental requirements of the policy in that it does not discriminate in hiring and promotion. Workers are represented by two unions. Both unions are represented on a joint management-worker committee that meets once a month to hear grievances.
Several aspects of worker health and safety have been previously mentioned under the discussion of PS 1. The company maintains oversight of contractor workers on its site, and exacts fines for those who do not use appropriate personal protective equipment.
Ambient dust levels from the operations at the plant are visibly high. The project will include measures to reduce this dust, such as covering storage piles. The company has ordered the equipment necessary to monitor ambient dust and, based on whether monitoring determines that dust levels remain too high, will take additional measures.
Sococim requires educated workers in virtually all areas of its operations. The company does not employ child labor.
- PS3: Pollution Prevention and Abatement;
The company currently draws power from the national grid, with a 14 MW diesel power plant for back up. The project will involve the construction of a 24 MW engine driven power plant. The plant will run on heavy fuel oil (Bunker Oil #2), with diesel fuel back up. The environmental impact assessment of the proposed power plant indicates that the plant will meet both Senegalese law and World Bank/IFC standards for nitrogen oxides (NOx) emissions given existing ambient air conditions. The plant will also meet World Bank/IFC guidelines for particulate emission from small (less than 50 MW) power plants. The EIA has concluded that with a sulfur content of below 3.4% (w/w) in the fuel used, the new plant should be able to meet both World Bank/IFC and Senegalese standards for sulfur dioxide (SO2) emissions. The actual ability to comply with the guidelines for SO2 emission will thus depend on the availability of low sulfur fuel in the local market. Once the new plant is installed, the factory will run entirely on its own generators. The existing 14 MW diesel will undergo mechanical refurbishment and will be used only as a supplement to the main 24 MW plant.
The client continuously monitors the opacity of flue gases. NOx and SO2 in the flue gas are periodically measured. The kilns meet World Bank/IFC standards for emissions with respect to NOx (600 mg/Ncm) and SO2 (400 mg/Ncm). The company has been able to source low sulfur coal, and will need to continue to do so to keep its SO2 emissions within these limits. Particulate matter has historically exceeded both World Bank/IFC and Senegalese guidelines. The electrostatic filters on the newer kiln have been refurbished and their operation is now overseen by an environmental engineer. Particulate matter levels have not been re-tested at this kiln since the refurbishment, but additional test results will be provided to IFC and, if need be, the company will take appropriate actions to correct any exceeding of the guidelines. Bag filters have been ordered for installation at the older kiln, and these filters will bring this kiln’s operation well within the applicable particulate emission guidelines.
Process water is sourced primarily from the national water company, ‘Sénégalaise des eaux’ or SDE, which supplies the peri-urban area. The plant also uses water taken from the dewatering of the quarry. By this dual supply system, and the usage of dry process operations, the plant will have sufficient water available, while not depriving any other water consumers in the area of a supply.
With respect to liquid effluent, the company treats different types according to their characteristics. For example, domestic wastewater is sent to septic tanks then dispersed into leach fields. Water, which could be contaminated with oil is sent to a holding tank, where the oil is separated (for burning in the kilns), while the oil free phase of the water is sent to the effluent holding tanks before being transported to an external site regulated according the recommendations of the Ministry of the Environment. The IFC finds the management of these liquid waste streams acceptable.
Noise levels were tested as part of the EIA for both the power plant and the new cement line. They were found to be acceptable for World Bank/IFC standards, and the project, particularly the new cement line, contains measures for additional noise suppression.
Sococim does plan to use alternative fuels in its operation. The company will explore the opportunities of using local, non-hazardous, non-chlorinate waste streams as fuel supplements in the long run. In this way the company might be able to utilize harmless waste streams, like used plastic, that would otherwise require land filling, or biomass fuels. The company will need the approval of local government to implement these opportunities.
- PS4: Community Health, Safety and Security:
A major impact from the existing operation is the truck traffic going through the Colobane Gouille Mouride neighborhood bordering the plant site. Currently approximately 300 trucks enter the plant each day. As a direct result of the project, a new access to the plant will be established and this traffic will be redirected toward the national highway on the western side of the company site, thereby avoiding the local neighborhood. At the same time, the truck parking area will remain in the current area, allowing existing small businesses to continue to provide services to the independent truckers.
Senegal has a low HIV/AIDS infection rate compared to other countries in the region, and the company, through its community involvement, supports a local HIV/AIDS education program. The possible involvement of IFC-Against-AIDS has been discussed with the company.
The EIA for the power plant carried out a risk analysis for Sococim operations as a whole and found that the handling of cement and hazardous materials were the two main risk areas in the plant. The EIA consultants made recommendations based on general principles of health and safety. These recommendations have been substantially met: for example, the plant has an emergency response plan and, as noted, the company provides training to all of its employees on fire fighting. IFC will further monitor ongoing implementation to ensure that the measures are maintained.
- PS6: Biodiversity Conservation and Sustainable Natural Resource Management:
As part of the expansion of its Bargny quarry operation, the company will remove modified habitat. This habitat has been assessed for being of potential importance to biodiversity protection as part of the EIA, but was found to have no endangered or otherwise interesting species. A rehabilitation plan, including re-vegetation has been developed for the existing Bargny quarry and is already under implementation. Trees have also been planted in the quarry area, consistent with PS 6. The company will provide IFC with rehabilitation plans for the two other quarries supplying the Sococim plant.
