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 Performance Standards on Social and Environment 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. This is summarized in the attached Environmental Action Plan (EAP).
- Environmental and Social Management
Küçükçalik last year combined its four Turkish manufacturing sites, which had been operating as three legal entities covering yarn texturizing and weaving; dye, print, finish and stitching (confection); and embroidery (which includes dyeing), into one legal entity. This consolidation has required development of a new management structure for the combined company, and consolidation of certain management and policy matters, including those covering management of environmental and social matters. The Human Resources Director and the Manager of Quality and IT are jointly managing this standardization program.
Two of the factories have had environmental policies since 1999, and these will be expanded to cover all operations. The company has comprehensive systems for management of HR issues, though is less strong in environmental and safety management and plans to enhance its technical ability to manage these issues by recruitment of an environmental engineer and a safety engineer. There has been little environmental monitoring or management historically because potential impacts were considered slight. Safety data are recorded. Training needs are currently under review, and following training needs assessment additional safety, security and manufacturing quality (including management of environmental issues) training will be expanded in future years.
Küçükçalik shall develop and integrate environmental and safety management systems within its quality assurance management, and shall achieve ISO 14001 and OHSAS 18001 or equivalent certification respectively of its environmental and occupational health and safety management systems at all sites within two years in Turkey and three years in Egypt of IFC disbursement.
On completion of the reorganization process, the Finance, HR and Quality (including environmental management) structures established will be used to manage all Küçükçalik’s operations including those in Egypt.
- Environmental Assessment and Planning
IFC visited the proposed site in Egypt in early March 2007, a few days before Küçükçalik formally took title. However, an Environmental Impact Assessment study had started, and was expected to be complete in mid-April 2007, at which time it will be submitted to the Egyptian authorities for approval, following which step project construction activities can commence, and to IFC.
Küçükçalik’s Turkish factories are low environmental impact facilities established in an industrial area. All factories have certificates from the Turkish authorities which confirm that the factories meet local environmental and safety requirements and thus may be permitted to operate. Issuance of these permits followed environmental assessment by the Turkish authorities. Küçükçalik has a machinery list which is approved by environmental inspectors and which must be kept up to date. In the event of additions which have very low environmental impact (e.g. twisting machines), such updating is permitted by telephone conversation. Inspection will be required of new dyehouse machinery (the jet dyeing machines).
- Working Conditions
Küçükçalik has a written human resources policy, covering aspects of management behavior (innovation) and employee access to management, recruitment, performance appraisal, social matters and remuneration. The policy is based on a well established Küçükçalik code of ethics, which is based upon honesty, good communication, establishment and maintenance of a high reputation, personal development including equal opportunity and training.
Turkish authorities undertake labor and OHS inspections at least annually, and a number of customers also make inspections from time to time. A recent labor audit, conducted on behalf of a major European retailer, was shared with IFC. This identified no non-compliances and several areas of best practice.
The HR policy and company values are communicated to workers on notice-boards, in induction training and in key aspects of the employment contract. The written employment contract, which is based upon Turkish labor law covers rights and responsibilities of employer and employee and includes mention of, for example, starting date, place of work, working regulations, (making reference to the employee handbook) safety and security procedures, disciplinary procedures, salary/wages, non-salary benefits, payment date, working hours, recording system and overtime payments. Normal working hours are 45 per week, worked in a shift pattern of 6 days on and then one off, with up to 3 hours overtime daily. The maximum legally permitted overtime is 270 hours/year, and examination of records in late 2006 showed individual annual overtime working from 33 to 249 hours annually. Overtime is compensated at time + 100%. Normal minimum wages in this region of Turkey are close to the legal minimum which in late 2006 was 531 YTL/month gross: Küçükçalik pays its lowest paid workers slightly more than the legal minimum. Non-salary remuneration includes paid national holidays and annual leave in accordance with Turkish law (13 national holidays, plus paid leave of 15 days/year after one year, 18 days/year after five years'' service and 20 days after more than ten years'' service or for employees over 50 years of age) and legal social provisions such as health insurance and a retirement pension. There is no formal employees'' grievance procedure, though good communication is one of Küçükçalik’s core values: managers are therefore expected to make themselves available to hear and act upon any grievances. Complaints/suggestion boxes are available throughout the company. Last year, the 9-10 complaints were mainly about canteen food and service bus routes.
Küçükçalik does not have an official trade union and does not enter collective negotiations with any worker organizations. Nevertheless, workers are free to join a trade union without discrimination. Küçükçalik has a policy of non-discrimination in recruitment or advancement on any grounds unrelated to a person''s ability to undertake his or her duties.
Küçükçalik’s youngest employee is 18 years of age; date of birth is checked by examination of national identity cards upon taking up employment. A few younger persons on approved vocational training schemes are employed in light and non-hazardous duties. Küçükçalik is legally responsible for employment conditions in its contract weaving suppliers, and also assumes responsibility for these in the view of its major customers. Küçükçalik therefore regularly checks its suppliers to ensure that they apply the same standards as Küçükçalik itself.
There were 9 lost time accidents in 2005, which is a respectably low figure for annual working hours close to 5 million, and 2 lost time accidents in 2006. Machinery is well guarded: Küçükçalik does maintain MSDSs for all chemicals used, and mostly takes appropriate precautions, though hydrogen peroxide storage can be strengthened. The oven used after pigment printing was observed to discharge smoke into the workspace. Workspace air quality has been monitored with satisfactory results. The company doctor stated that she had not identified any occupational illness among employees.
There has been no systematic OHS risk assessment, though one is planned when the safety engineer is recruited. Personal protective equipment (masks and ear plugs) are provided, but ear plugs were not universally worn. All employees have a compulsory annual health check-up covering lung function, cardiography, audiometry, blood pressure, motor control, and eyes & vision. There is analysis for developing adverse trends as well as absolute values. More regular tests are carried out when indicated by job function, so for examples flock printing workers have more regular tests of lung function and cafeteria workers undergo regular tests. There are also health promotion events, covering items such as family planning, basic safety training, baby care and basics of family health care.
Fire protection is substantially by hose reels and portable extinguishers, and plans are placed at regular intervals in building showing locations of extinguishers, exit routes and exit locations. Without studying such charts exits routes were not always obvious, especially in the large and internally divided weaving factory. Exit routes, signage and emergency lighting will be reviewed and upgraded to clarify exit routes to those unfamiliar with the site.
- Hazardous Materials
Hazardous materials are generally well managed. Küçükçalik has MSDSs for all the materials it uses and in general follows appropriate precautions in their use. The chemicals store was neat and tidy with adequate material containment. One exception to this was in storage of concentrated hydrogen peroxide where two large containers were stored in a passageway between the chemical stores and a production area. A secure storage facility shall be created for this chemical.
Küçükçalik has Oekotex certification of its dyestuffs.
- Emissions to Water
All liquid effluents arising from Küçükçalik’s four Turkish sites are directed to the Inegöl waste water treatment plant. This facility monitors its output of COD, BOD, TSS and oil and grease daily and heavy metals weekly. Its discharge standards are well within local and IFC minimum requirements. Küçükçalik’s factories’ effluents are monitored every two days, and effluents from all sites are well within the treatment plant''s acceptance criteria, and that from the embroidery facility is very close to compliance (untreated) with WBG textile guidelines. Observation suggested excessive mixing of inks in the dye kitchen serving the printing section, over and above quantities which can be used immediately. This ultimately will increase raw material costs and increase effluent system loading.
For Egypt, Küçükçalik has confirmed that its effluents will be pre-treated on site, before discharge for further treatment by the 10th of Ramadan municipal system.
- Emissions to Air
In Turkey, Küçükçalik has a certificate from the local environmental regulator which states that emissions to air are not environmentally significant and need not be measured. Emissions data are therefore not available. Emissions to air are products of combustion arising from boilers and thermal fluid heaters at the production sites, and from four gas-fired engines used in a cogeneration system at the dyeing plant, and exhausts from finishing machines such as stenters and paint / ink drying ovens.
In Turkey, it is only at the dyeing facility that the rate of thermal energy use exceeds 10 MMBtu/hr, and therefore requires measurement of combustion products under the terms of IFC’s General Environmental Guidelines. However average demand at the Embroidery and Yarn dyeing facilities is close to this threshold and increasing. The major fossil fuel users at the dyeing factory are four gas-fired 5 MWe engines used in a cogeneration system. Monitoring data shows minimal particulate or sulfur oxides emissions. NO2 emissions from three of the four engines are well within IFC and local requirements, while emissions from the fourth (nominally identical) engine exceed the IFC guidelines, but meets local requirements.
Küçükçalik will identify the reasons for high NOx emissions from one of the four engines in the dyeing factory, believed to relate to engine control and/or maintenance and will revise adjustments to match those of the other three engines. If adjustment does not achieve NOx compliance, then engine selection will be revised to minimize running hours of the non-compliant engine, and further technical solutions to high NOx emissions will be sought.
Küçükçalik will measure VOC emissions to air from its stenters and paint/dye finishing machines, and will report these measurements to IFC. If results exceed IFC guideline values, then IFC and Küçükçalik shall agree a program of changes designed to achieve IFC guideline compliance within three years.
No design information on process requirements or utility system design was available for the Egyptian facility at the time of appraisal. However, Küçükçalik has confirmed that design will be compliant with local and IFC guideline requirements. Air conditioning for the jacquard weaving facility will not employ ozone-depleting refrigerants.
Küçükçalik will confirm to IFC, as a condition of disbursement, that NOx emissions to air from its proposed utility plant will meet local and IFC requirements.
Most of the obvious process energy efficiency measures are in place. For example the continuous dyeing / washing ranges have countercurrent rinsing, and dryness control is implemented on a roller stand dryer. Heat recovery projects have been implemented on batch dyeing machines, which feature multiple drains to facilitate heat and water recovery and reuse. The dyeing factory has an engine-based cogeneration system to meet its electrical and heat needs. Other energy efficiency opportunities remain, in steam system insulation, but particularly in control of lighting, where large areas are lit continuously even though intermittently occupied by humans.
- Solid Waste Management
Wastes arising from Küçükçalik’s operations are substantially accounted for by polyester fabric and yarn scraps, paper wastes and plastic bobbins. All are collected separately and sold for recycling. Küçükçalik also expects to be able to sell plastic, paper and fabric wastes for recycling in its Egyptian operation. Waste water treatment plant sludge will be disposed of in an approved landfill.
