The Sponsor/BCML 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 environment and social policies, IFC 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 Sponsor/company is summarized in the paragraphs that follow. Further information is provided in the attached documentation.
- PS1: Social and Environmental Assessment And Management Systems:
The Sponsors are committed to achieving high performance levels on environment, social, occupational health and safety (EHS) aspects associated with the operations of the company. While EHS aspects have not been managed under a structured system in the past, the company has commenced strengthening EHS management by implementing an integrated quality and EHS management system certified to ISO 9001, ISO 14001 and OHSAS 18001 standards. Further, the company will, within a timeframe agreed with IFC:
- put in place an EHS management system (EHSMS) across all of its operations, with IFC Performance Standards, ESRS and ESAP requirements appropriately incorporated, which will be certified to ISO 14001 and OHSAS 18001 standards;
- appoint a fulltime senior executive at the corporate level for oversight of EHS aspects across all of BCML’s operations; and
- designate at least one person at each operating facility as EHS manager.
The company has carried out Environmental Impact Assessments (EIA) for the proposed sugar plants (including co-generation facilities) at Gulharia and Kumbhi; has delineated mitigation measures; and will implement appropriate mitigation measures for all identified impacts. Further, the company will make available to IFC relevant consents/clearances/permits and authorizations for the project, as and when these are obtained by the company. The company will put in place, within a timeframe agreed with IFC, EHS standards for contractors and their sub-contractors and ensure adherence to the EHS standards during construction and operation.
- PS2: Labor and Working Conditions:
The company is in the process of implementing a documented Human Resource (HR) Policy and Manual. Further, conditions of work/employment for workmen/labor are stipulated in detail under the standing orders, which the company adheres to.
The Standing orders detail:
- classification of various categories of workmen;
- communication of terms of employment including hours of work, leaves, pay days, shifts, wages, grade;
- eligible leaves, holidays and leave records;
- procedures for temporary lay-off;
- termination of employment; and
- disciplinary procedures.
The HR manual describes the procedures for:
- recruitment and selection (including internal recruitment, induction and probation);
- grade structure, emoluments and benefits;
- leave policies; performance management, increment and promotions;
- Employee Code of Conduct, SHE Policy, HR mission and procedures for:
- manpower planning, recruitment and selection, induction and placement;
- employee welfare; emoluments, benefits and employee welfare;
- performance appraisal, increment, promotions, recognition and career development;
- training and development;
- disciplinary procedure and other items.
Conditions of employment as well as wages and benefits are communicated to employees through employment letters and notices. The company will prominently display the Standing Orders (conditions of work), in the local language at each of its plant and project locations. The company''s existing plants at Balrampur, Babhnan, Rauzagaon, Tulsipur and Maizapur have labor unions. BCML’s HR Policy commits to equal opportunity and non-discrimination and these aspects are embedded in the company’s HR practices and procedures. The company will implement an employee grievance redress procedure consistent with IFC’s Performance Standard (PS) 2 requirements and also further strengthen the disciplinary action/misconduct procedures to make it consistent with IFC PS2. Further, the company will articulate a maternity leave and benefits policy in accordance with host country requirements. The company will upgrade the occupational health and safety status at its existing plants. Particularly, within a timeframe agreed with IFC, the company will develop and implement a companywide program on:
- guarding of moving machine parts;
- use of personal protective equipment during construction and operation;
- training (at induction, general awareness, operation specific and ongoing/refresher) on occupational health and safety, which will be linked to training need analysis procedures in the HR manual; and
- development, implementation, display/groundmarking and training on emergency management and response.
While BCML will, on an ongoing basis, manage occupational health and safety through the OHSAS 18001 certified EHSMS, the company will, within a timeframe agreed with IFC, put in place departmental, plant level and corporate safety committees, comprised of both worker and management representatives. Further, the company will formalize procedures to ensure that the labor contractors meet national laws with regard to age, insurance and wages. The company distributes pesticides to farmers within the command area of its plants and has a program in place to enhance farmer awareness on safe pesticide handling practices. The company will, within a timeframe agreed with IFC, further strengthen this program and periodically report to IFC, on the initiatives implemented under the program. The company will within a timeframe agreed with IFC, for the explosives facility at the Maisapur plant (acquired from Indogulf), engage explosives expert to:
- survey the facility;
- identify and remove all hazardous materials, explosives and hazardous components lying at the facility to a safe location; and
- develop a decommissioning action plan.
Till all hazardous material is removed from the Maisapur plant premises, the company will implement stringent access control procedures.
- PS3: Pollution prevention and abatement:
BCML has identified key environmental aspects and potential significant impacts of the project and addressed these in design. Going forward, the company will manage environmental impacts under the ISO 14001 certified EHSMS. The project design includes various energy efficiency and water conservation/recycling/reuse measures. The company will implement a companywide program to: harvest rainwater; and recycle 75% of the treated wastewater. While the source of energy at all locations will be bagasse-based cogeneration plants, groundwater is the primary water source. The company will, for each of the greenfield plant locations, map the groundwater drawdown profile on account of groundwater extraction. Principal air emission is particulate matter (PM) from boilers, and fugitive emissions during both construction and operation. The EMP details adequate mitigation measures and the company proposes to install high efficiency wet scrubbers of 99.9% efficiency to meet host country limits and IFC limits. The particulate matter emissions from boilers at the existing plants barring the Haidergarh sugar plant, exceeds IFC limits. The company will, within a timeframe agreed with IFC, develop an action plan to ensure that the PM emissions meet IFC limits. Further, the company will monitor air emissions across all of its facilities, to demonstrate compliance with IFC requirements and if required, within the first year after disbursement, implement appropriate corrective measures to meet IFC requirements. The company will ensure that the refrigerant used in chillers/air conditioning system and fire extinguishers across all of its facilities (existing and proposed), comply with the Ozone Depleting Substances Rules set by the GOI under Montreal Protocol requirements. The greenfield sugar plants are designed to achieve an effluent rate of 0.1 m3/tcd, which is within IFC norms. The effluent treatment plant (ETP) proposed at each of the sugar plant is designed to meet host country and IFC norms. Treated effluent from existing plants at Balrampur, Tulsipur, Haidergarh and Babhnan meet IFC limits. The company will upgrade management of hazardous materials and wastes to be in accordance with good industry practices and IFC guidelines on hazardous materials management. In particular, the company will, within a timeframe to be agreed with IFC, implement a program to:
- segregate and store all hazardous material appropriately under secondary containment;
- identify all hazardous wastes generated as per host country rules on hazardous waste handling and management;
- label, segregate and store all hazardous wastes under secondary containment; and
- dispose hazardous wastes through authorized entities only.
Other wastes generated will be fly ash, ETP sludge and filter mud. Fly ash generation rate is less than 5.5 Kg/tcd (meets IFC norms) and will be disposed in land fills. The company will, within a timeframe agreed with IFC, implement a companywide Bagasse Ash Disposal Management Plan. The program shall define:
- appropriate selection criteria for land to be used for filling with bagasse ash;
- prohibited fill and disposal areas and techniques; and
- criteria for compaction, drainage and final cover.
ETP sludge and filter mud, is being disposed to farmers as bio-fertilizers in the existing plants and the same is proposed under the project. The company encourages pragmatic use of pesticides and undertakes awareness programs on safe handling of pesticides. The company will develop and disseminate, to the cane growers in its command area, a Pesticide Management Guideline, which is consistent with IFC Performance Standards. The company has reviewed and will meet IFC’s Performance Standard requirements on Pest Management, in its cane development operations. Towards this end, the company will implement a program to encourage farmers to adopt Integrated Pest Management (IPM) and Integrated vector Management (IVM) and reduce reliance on synthetic pesticides. The critical ambient considerations in the context of each of the proposed plants are suspended particulate matter, noise and impact on account of ground water extraction. Material impact on ambient SPM, noise and groundwater levels is not expected. The company will, within a timeframe to be agreed with IFC, implement a companywide program on monitoring of ambient air quality and where required, will implement appropriate mitigation measures to meet IFC limits. Ambient noise levels at plant boundary meet host country and IFC limits at the existing plants and in the proposed project as well. In view of the fact that the principal fuel for energy generation is bagasse, net nil GHG emission is expected from the sugar facilities. The company will, besides timely submission of annual environmental and social monitoring reports (AMRs), also submit quarterly status reports on implementation of the Environmental and Social Action Plan (ESAP), appended to this ESRS. The quarterly status reports will be continued till all action items in the ESAP have been implemented and closed out.
- PS4: Community health, safety and security:
The company will ensure that there is minimal impact on community environment, health and safety, during both construction and operation. The company has, as part of the environmental assessment, identified likely community health and safety impacts and will implement mitigation measures for the identified impacts. Infrastructure and equipment meet good industry practice requirements at the proposed plants. The company will, as part of the EHSMS, put in place procedures to mitigate risk of uncontrolled release of hazardous materials, including risk to communities from hazardous material transport. Further, the company will, within a timeframe to be agreed with IFC, prepare and implement an onsite and offsite Disaster and Emergency Management Plan, and link it to the district emergency response plan. The project is not expected to exacerbate community exposure to disease either due to changes in land/hydrologic or other terrestrial/air quality/hydrologic regimes or due to influx of large pool of migrant laborers. The company has outsourced security services and the security personnel are armed. The company will, within a timeframe agreed with IFC, develop and implement procedures for ensuring that:
- past records of security personnel employed is screened;
- security personnel have clear objectives and permissible actions laid out;
- security personnel are trained in avoidance of human rights violations, use of fire arms and handling various situations with clear procedures;
- security incidents are recorded, investigated and corrective action implemented;
- bonafide complaints against security personnel are investigated/disciplinary actions 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.
- PS5: Land acquisition and Involuntary Resettlement:
The capacity expansion at Ruazagaon plant is proposed within the existing plant premises and no land acquisition is proposed. For the proposed green-field plants, the company has acquired 130 acres of agricultural land both at Kumbhi and at Gulharia. All land acquisition was undertaken on a willing buyer - willing seller basis and did not involve any involuntary resettlement. The land acquisition involved 48 and 36 number of purchase agreements with farmers at Kumbhi and Gulharia sites respectively. The price paid for the acquired land was at least 25% above the average price of non project related sale/purchase of land in the vicinity of the proposed plant sites. The prices were arrived at based on negotiated settlement after consultations with the farmers. The company will put in place a grievance redress mechanism to receive and respond to grievances pertaining to land acquisition.
