- EHS Assessment and Management Systems
- Environmental and Social Assessment:
In the development of all new projects, Cemar undertakes environmental and social assessment of the aspects and impacts, both negative and positive, in the project’s zone of influence according to the regulatory requirements of the State of Maranhao and national Brazilian regulations. The environmental and social assessment cycle begins at the earliest stage of the project planning effort, that is, during field surveys and pre-feasibility studies, where technically and financially feasible alternatives are examined. This process considers applicable legal requirements of the various authorities and jurisdictions in which the project will be constructed and operated, which, due to the capacity of power transmission and distribution of the company is limited to state and municipal requirements. The company often relies on external consultant experts to conduct assessment which trigger the application of federal regulatory requirements such as may be the case during construction of sub-transmission or distribution lines in legally protected lands.
- Management Program:
Cemar’s published Mission, Vision, and Values statement highlights the company’s concern for the environment and the communities in which it operates. The company’s social and environmental commitment is further manifested through the recent organization and implementation of environmental and social management programs which focus on key operational areas including:
- occupational health and safety of its workers and contractors;
- prevention of risks to the public from with the presence of electric distribution infrastructure in the community;
- social responsibility and the safe and efficient use of electricity in the household;
- protection of natural resources; and
- compliance with applicable regulations.
Cemar identifies actions to prevent and control the impacts based on the results of environmental and social impact assessments and based on the results of internal audits. Programs are structured to primarily to manage construction impacts and normal operations. Quantitative indicators have been established for some of these programs to more accurately determine performance. For example, occupational and public safety indicators are closely followed and compared against benchmarks of other Brazilian electricity distribution companies. Included in the programs are a series of policies and guidelines primarily oriented to toward worker health and safety, the issues of greatest relevance to the operation of the company and its subcontractors.
- Organization, Training and Monitoring:
Overall responsibility and authority for implementation of Cemar’s environmental and social policies and programs lies with the corporate human resources department. Led by its director, the department includes a group of full-time qualified environmental and safety professionals who include a coordinator and eight (8) safety technicians supported by a labor doctor, all of whom are assigned primary responsibilities in specific areas such as licensing, audits and inspections. Due to the rapid growth of a government-subsidized rural electrification program (called the Light for All Program), Cemar has increased the number of its own staff and the number of construction subcontractors dedicated to this program. An additional dedicated group of approximately five (5) full-time qualified environmental and safety professionals are currently assigned to this particular program and, like their main operations counterparts, are included in every new project development team and assigned the responsibility for overseeing environmental and social assessment and management activities.
Cemar has a training program targeting the safety of employees and subcontractors involved in construction and maintenance of its sub-transmission and distribution network. Training programs cover a number of key areas including:
- electric safety for new installations;
- organization of health and safety committees;
- defensive driving; first aid;
- fire safety;
- rescue in heights;
- workplace norms and procedures.
Employees and subcontractors are also trained in a training facility in understanding workplace risks and their prevention and control (mainly electrical hazards and working in heights), including the use of personal protective equipment (PPE), hazardous materials handling, and emergency response.
Performance is currently monitored through periodic internal audits of its own operations and of its contractors. The auditing program focuses on the identification of any necessary corrective actions. Cemar specifically monitors health and safety performance indicators including accidents and fatalities rates of employees, sub-contractors, and the public and strives to improve its performance on a yearly basis. Cemar also conducts industrial hygiene assessments on an annual basis as required by Brazilian law and has instituted the government required joint health and safety committees (CIPA) with representatives from the workers and management who supervise and report on health and safety issues encountered during work.
- Reporting:
The results of the internal and contractor audit program, worker health assessments, and CIPA meetings are periodically reported to management, principally within the human resources and legal departments who are assigned the principal responsibility for performance in environmental, health, and safety issues.
- Labor Issues
- Working Conditions and Management of Worker Relationships:
The company has a well developed human resources management program which supports workers’ rights to collective bargaining, freedom of association and other basic rights. The company is in the process of formalizing a human resource policy and a grievance mechanism that will ensure a transparent and confidential treatment of employee concerns. Employees are currently able to raise concerns through worker union representatives or through the public Labor Rights system (Justica de Trabalho).
Cemar provides new employees with induction training that includes instruction in job-specific tasks, occupational health and safety requirements, and company rules and procedures. The company rules and worker benefits at Cemar are communicated through the Collective Labor Agreement (signed between Cemar and the STIU – MA (Sindicato dos Urbanitarios) valid for the 2006/2007 period) that outlines the basic terms and conditions of employment, including working days and hours, safety procedures, disciplinary procedures, leave, benefits and termination of employment. The company Employee Conduct Manual complements the employee handbook. The Employee Conduct Manual outlines a number of issues applicable to management and line workers including the company mission and values, general behavior standards, the company’s definition of conflict of interest, rules for external communication, and protection of the confidential information, among others. Workers are required to sign individual employment contracts which further define worker roles and responsibilities and which explains worker compensation and payment procedure ensuring workers are paid regularly and on time. Cemar further communicates worker benefits through the Employee Benefits Manual which outlines health insurance and other enhanced employment benefits.
Approximately 60% of the workforce employed by Cemar in construction, operation and maintenance activities is subcontracted through a network of over 60 companies. The majority of the subcontracted resources are dedicated to a program sponsored by the federal government to extend electric service to poor and rural communities known as the Light for All Program (Programa Luz para Todos or PLPT). The growth of the PLPT program is driving Cemar to develop a comprehensive contractor management system which evaluates and monitors the environmental, health and safety performance of contracted companies. Contractor management already includes legal specifications in contracts and inclusion of past performance on environmental, health, and safety issues in the contractor selection and/or contract renewal process.
Cemar complies with Brazilian national law which requires employers to recognize workers rights to organize in an organization of their choosing and without interference. Cemar supports employees’ rights to freedom of association and collective bargaining in compliance with Brazilian law; about 50% of employees and contractors are members of the STIU, the principal union which represents the interests of electric utility workers in the State of Maranhao and elsewhere in Northeastern Brazil. The STIU represents all employees (members and non-members) in the negotiation of the collective bargaining agreement.
Cemar’s current operations take place in mostly rural areas where skilled labor is scarce. Cemar encourages its subcontractors to hire local labor to the extent feasible in order to minimize the need for travel for construction and maintenance crews and supports them with a subcontractor training program. Cemar relies on its own adds and on employment services firm for the pre-selection of potential candidates based on education, technical training, and experience. Cemar applies non-discriminatory practices in its employee and contractor selection process.
- Occupational Health and Safety:
The company tracks total accident frequency rates as well as accident severity rates (the severity rates include a measure of lost work days) of its workers and contractors. The company’s accident frequency and severity rates have remained relatively steady or declined over the last three years and are among the lowest when compared among Brazilian electricity companies. Contractor accident frequency rates have also experienced a decline over the last three years and are amongst the lowest when compared among Brazilian electricity companies’ contractors. However, contractor accident severity rates increased between 2005 and 2006, with total contractor fatalities of 7 in 2006 vs. 1 in 2005 and 2 in 2004. This abrupt increase could be attributed to numerous factors which may include the sharp increase in demand for contractors due to rapid growth of the PLPT electrification program, the lack of a qualified labor force in the state of Maranhão, and the need for improved training of this workforce.
The company is working to further improve its contractor safety training programs. It has recently hired an additional safety specialist within the PLPT program who will be dedicated to develop and implement a contractor safety monitoring and auditing program, including additional training of Cemar’s construction site supervisors.
- Emissions, Effluents and Waste:
Key environmental issues during construction of sub-transmission and distribution lines may include dust, noise, and vibration from construction vehicle transit and earth moving activities as well as potential for soil erosion as is common to all construction sites. These impacts are expected to be temporary and are managed based on the recommendations of the project-specific environmental impact assessment and based on established environmental management procedures.
- Hazardous Materials and Wastes Management:
The company is effectively managing emissions, effluents and wastes associated with its operations. Principal activities include the return of potentially hazardous wastes to the original product manufacturers including such wastes as old mercury lamps, alkaline and acid base batteries, and used tires from the company fleet. The company has historically generated insulating oils contaminated with polychlorinated byphenyls (PCBs), a persistent organic pollutant regulated under international conventions. The company indicates that PCBs were mainly present in a few high-potency transformers which have been removed from substations since 2001 and the transformers and contents sent to an approved specialized incinerator. The company contracts the services of RHEDE, a transformer manufacturer and refurbisher located in the state of Goias to refurbish or replace all of the transformers removed from service throughout the distribution network. Since 1981, Brazilian law has banned the use of PCBs in new equipment. Cemar will prepare and adopt a procedure to properly manage any transformers encountered as part of the maintenance and replacement program which predate the ban and which may have the potential to contain PCB contaminated insulating oils. The procedure will include testing of the insulating oil and documentation of proper treatment and disposal of oil and equipment found to contain PCBs, in compliance with Brazilian requirements.
Cemar does not use significant quantities of hazardous materials in construction or operational activities. The insulating oils used in all of its new or refurbished transformer are of mineral origin. Additionally, the majority of power transformers which contain the greatest quantities of oil in a single piece of equipment are installed on top of concrete containment structure able to temporarily hold the contents of the transformers in the event of an accidental release due to fire or other malfunction.
- Noise:
Noise in the form of buzzing or humming, as well as ground vibrations, can sometimes be emitted from high voltage transformers in sub-stations. In December 2006, Cemar was issued a notice of non-compliance by the state of Maranhao Secretariat of Environment and Natural Resources in response to a public complaint about transformer noise at a location within the city of Sao Luis. Cemar is in the process of implementing corrective actions to comply with state of Maranhao and World Bank Group noise standards and guidelines.
- Atmospheric Emissions:
The main sources of atmospheric emissions include combustion emission from the fleet of maintenance vehicles operated by the company and its sub-contractors. Additional sources of emissions include the gas SF6 used for isolating purposes in switching equipment and indirect emissions from the production of electricity for own consumption. Screening estimates from all of these sources indicate that total GHG emissions are below 100,000 ton-CO2 equivalent per year.
- Energy Efficiency:
Given that the greatest opportunity for improvement in energy efficiency lies with the company’s reduction in technical losses and improved efficiency of end users (customers), Cemar has historically planned and implemented programs to promote and invest in improvement of both of these areas. Ongoing capital investment projects include improvements in the sub-transmission capacity which will help reduce technical losses while historically the company has donated over 175,000 energy efficient fluorescent light bulbs to low income families and substitution of over 60,000 lamps for public lighting in over 100 municipalities. The program with the municipalities resulting in the replacement of mercury vapor public lighting lamps with lower wattage sodium vapor substitutes and therefore had the double benefit of reducing energy consumption and removing a product with hazardous substance. Cemar has implemented additional energy efficiency programs with the replacement of lighting systems in public schools and the replacement of lighting and cooling systems in the University of the State of Maranhao.
- Community Health and Safety:
The company has a program that aims to educate communities in the service areas about the hazards associated with accidental contact with electrical equipment in public areas (i.e. by children climbing in trees located near power lines, while retrieving kites, or by approaching fallen cables, etc) as well as safety measures for end users in the household (i.e. avoiding handling of connections on wet surfaces or keeping hands out of light sockets, etc). The company monitors the total number of accidents and fatalities associated with interactions between the community and the distribution infrastructure. The total number of accidents for 2006 was below the Brazilian average and amongst the lowest for reporting companies. Public fatality rates have shown a relative decrease over the last 3 years (from 12 in 2004 to 3 in 2006). The company provides specific procedures and trains its employees in the safe operation all types of light and heavy-duty vehicles in order to reduce the rate of accidents.
The company provides instructive information to communities in presentations or via the internet on such issues as the safe use of electricity in the home, staying away from broken transmission and distribution cables, avoiding illegal access into substations and other infrastructure by children at play, and other general safety precautions around electric installations.
The company has a well-publicized emergency call-in number that is attended 24 hours a day, seven days per week, as well as service personnel available around the clock. There is a procedure in place to forward emergency calls to the appropriate public services in charge of emergency response when these are required based on the nature of the emergency.
- Biodiversity Conservation:
Given that over the two thirds of the State of Maranhao, and hence the company’s concession are is located in the Legal Amazon, and given the presence of several legal protected areas within the state, the company actively and successfully manages biodiversity concerns associated with its operations. Cemar’s environmental management program includes a screening process for projects which are likely to be located in legally protected areas or other situations requiring special environmental permits for the removal or alteration of existing vegetation. In these cases, the company contracts the services of environmental consultants to assist in the preparation of environmental impact assessments and processing of the permits with the state or federal environmental authorities. While the vast majority of Cemar’s construction of new distribution lines takes place along existing urban and rural roads with limited vegetation removal, where vegetation removal activities are required, these are performed in accordance with the requirements of environmental permits. Vegetation management programs along sub-transmission line rights-of-way or urban distribution systems are designed to maximize the use of local non-invasive species that do not interfere with the network operation and maintenance activities.
