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 sponsor/project is summarized in the paragraphs that follow. Further information is provided in the attached documentation.
- PS 1: Social and Environmental Assessment and Management System
PLL’s management proactively addresses environmental, social, occupational health and safety (EHS) aspects associated with its operations. The company has an environment management system (EMS) and an occupational health and safety management system (OHSMS) certified to ISO 14001:1996 and OHSAS 18001:1999 standards respectively [both together referred to as EHS management system (EHSMS)]. The EHSMS is applicable to all of PLL’s projects/operations and includes procedures for:
- aspect, impact and risk identification;
- compliance with regulatory requirements;
- development and implementation of management programs;
- incident and accident handling, recording, reporting, investigation and analysis;
- emergency preparedness and response;
- responsibility distribution;
- training and awareness;
- communication and consultation;
- monitoring, recording, reporting and documentation;
- audit;
- corrective action; and
- management review.
The EHS management system is well implemented on the ground.
While PLL does not undertake environment and social assessment (ESA) of the projects where its role is limited to that of an EPC company, PLL implements/adheres to the EHS management plan (EMP) prepared by the sponsors of such projects. However, as part of its EHSMS, the company has identified the key EHS impacts and risks, associated with its construction activities in various sectors and implements a management program to minimize/mitigate the identified impacts. PLL will implement a program, to prepare and make available to each project team, a project site specific EHS Management Plan, which will incorporate/be based on:
- the standard requirements of PLL’s EHSMS;
- the EMP and Risk Management Plan made available by the sponsor of the project; and
- relevant provisions of IFC’s Performance Standards and WBG/IFC EHS guidelines.
The company will, within a timeframe agreed with IFC, embed IFC Performance Standards in its EHS management system. As part of its effort to ensure that PLL’s projects achieve outcomes consistent with the provisions of IFC’s Performance Standards, PLL will develop formal procedures to review and screen projects it bids for either as an EPC company, construction company or as an equity holder. The review of projects under the new procedures will lead to the following outcomes:
- the acceptance of contracts in which the company’s environmental and social standards (including those of IFC’s Performance Standards 1 through 8) can be met; and
- the re-evaluation, renegotiation, or decision on rejection of contracts that cannot be implemented according to PLL''s requirements.
IFC will assist PLL in the development of assessment/screening procedure and pilot its implementation in a sample of projects.
PLL has employed in-house fulltime qualified professionals both at corporate and operations levels, for oversight of EHS aspects across all of the company’s operations. The company’s EHS organization includes:
- a corporate EHS and Quality head with oversight responsibilities for all projects and operations; and
- qualified EHS officers at each project location for day to day management of EHS aspects including oversight of implementation of the EHSMS.
The company deputes community liaison professionals at each project site to engage with communities in the vicinity of PLL’s project locations. PLL will:
- implement a management system; and
- enlarge the scope of work of the community liaison professional, to ensure effective oversight and application/implementation of IFC’s Performance Standards pertaining to social aspects (PS 4, 5, 7 and 8).
The company requires its contractors to also adhere to PLL’s EHS procedures and has a training program in place for contractor’s labor. The company has procedures for recording, investigation and reporting of EHS incidents including those involving PLL’s contractors’ labor. The company monitors EHS performance on a monthly cycle and PLL’s Board of Directors reviews EHS performance annually.
The company manages environmental impacts of its operations as per the EMS. The EMS includes, besides the standard ISO 14001 procedures, good practices for:
- equipment/material selection and operation to meet emission and energy efficiency norms;
- management of emissions and discharges to air, water and soil;
- fugitive dust suppression; management of hazardous materials and wastes; and
- elimination of use of CFCs and asbestos.
The company will upgrade the EMS with inclusion of procedures for:
- adherence to MARPOL and International Maritime Organization’s requirements on pollution prevention, in its barge operation;
- spill prevention, control and cleanup also in aquatic and marine environments;
- prevention of loss of top soil and erosion control;
- minimization of noise impact on communities resident in the vicinity of project sites;
- rehabilitation of borrow pits and quarry sites;
- sediment control measures in natural watercourse/river/stream crossings; and
- meeting IFC emissions, discharges and ambient conditions norms in ready mix concrete batching and hot mix plants.
The company will ensure that its contractors also adhere to PLL’s standards on pollution prevention and abatement. The company has a monthly emission monitoring and reporting program for batching and hot mix plants, which the company will expand to include monitoring of ambient air quality and noise levels, particularly at sensitive receptors.
PLL will, in accordance with both IFC’s PS6 provisions, develop and implement procedures, to minimize and mitigate impacts on bio-diversity, particularly when its project sites are located in, pass through or are in the vicinity of:
- critical natural habitat;
- protected areas including wildlife sanctuary, national parks, reserved forests, breeding grounds of key species and archaeological monuments; and
- other eco-sensitive areas like marine environment, rivers, streams and wetlands with aquatic or other flora-fauna.
PLL will, in accordance with PS 8 provisions, develop and implement a chance find procedure in its EMS including for finds of archaeological (prehistoric), paleontological, historical, cultural, artistic, and religious values, as well as unique natural environmental features that embody cultural values, such as sacred groves.
PLL uses equipment and infrastructure that meet good industry practices. Most of PLL’s ready mix plants are fully automated, with very little manual handling. The company will, as part of the EMS, implement procedures to minimize community health and safety impacts. The company will, during construction, at appropriate locations deploy:
- fluorescent, lighted and flagged danger and diversion signs;
- access control for unauthorized persons; and
- will employ traffic marshals to direct traffic at diversions/congested areas.
PLL will ensure that its contractors adopt good EHS practices consistent with PLL’s EHSMS, during construction and in particular ensure:
- that its employees and the contractors train equipment operators and drivers in safe driving techniques;
- develop a materials movement plan to ensure that vehicle movement during construction has minimal impact on daily life patterns of nearby communities;
- undertake appropriate measures to reduce fugitive emissions from storage and transport of excavated earth and other construction material; and
- periodically monitor ambient air quality as also noise levels in potentially affected communities/villages, and implement mitigation measures where required.
PLL has procedures in place to minimize the risk of exacerbation of community exposure to disease due to influx of labor. PLL provides medical facilities including free medicine, for its labor, employees and contractor’s laborers. PLL requires that all employees and laborers (on its rolls or belonging to contractor) undergo periodic health check up including for HIV/AIDS. The company has implemented HIV/AIDS policy and a HIV/AIDS awareness program, for its own employees, labor and contractor’s laborers. The company will also assess the feasibility of extending the HIV/AIDS awareness program to communities resident in the vicinity of its project sites. IFC and PLL will explore opportunities to work together towards deepening and expanding PLL’s HIV/AIDS awareness initiative. The company will implement procedures to ensure that potential host community impacts on account of influx of labor are assessed and managed.
The company employs security, which is armed. The company will, within a timeframe agreed with IFC, develop and implement procedures for ensuring that:
- past records of security personnel employed are screened;
- security personnel have clear objectives and permissible actions laid out;
- 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.
- PS2: Labor and Working Conditions
PLL has nearly 2100 employees on its rolls and engages nearly 10,000 laborers either directly or through contractors at its various project sites. Further, the company has another 3000 employees and workmen engaged in overseas projects. Labor engaged in overseas projects are PLL’s employees deputed to these projects. PLL has standalone HR Policies instead of a HR Manual. The policies are designed to meet the labor laws of the host country in which PLL’s projects are located. The company has HR professionals deputed at each of its project sites, who are responsible for communication of PLL’s HR policies to employees and labor. The company is in the process of making available policies to employees through its intranet. Further, working conditions are communicated to employees and labor through their appointment letters. The company has processes in place to ensure that contractors meet host country labor laws. 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 manages occupational health and safety through its OHSAS 18001 certified management system, which is well implemented on the ground. The OHSMS includes, besides the standard procedures under OHSAS 18001 standards, operational control procedures for activities with identified OHS risks including physical condition checks, lighting, ventilation, welding, health hazard identification and control, occupational health evaluation and monitoring, work permit system and excavation. Further, the company has, as part of its OHSMS, developed a good practices register for identified activities that expose employees/labor to hazardous conditions. The company will implement a management system in accordance with applicable IMO requirements for its barge operations. PLL provides personal protective equipment (PPE) to all employees including contractor’s labor. While use of PPE at PLL’s project sites is adequate, the company will continue to focus on further improving use of PPEs, particularly under dangerous working conditions. The company has an active safety training program in place including daily tool box talk and EHS induction training for all new labor (including contract labor), entering a project site. PLL ensures that doctors/para-medical staff and ambulance are available at all project sites together with facilities for administering first aid.
The company and its contractors set up labor camps at project sites. The company, for its employees and labor, ensures:
- living conditions with basic amenities and electricity;
- mess facilities for food; drinking water which meets host country potable water norms;
- where labor desires self cooking, provision of LPG for cooking;
- provision of toilets and bath including separate toilets and baths for women family members of workmen; and
- primary medical facilities.
While the company has processes to monitor condition of contractors’ labor camps, there are opportunities for further improving the conditions in contractors’ labor camps. The company will implement a program to upgrade both living and working conditions of contract labor. IFC and the company will explore opportunities for working together, to embed benchmark practices amongst PLL’s contractors/contract labor in this regard.
