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.
- PS1: Social and Environmental Assessment and Management System
Punj Upstream’s management is committed to address social, environmental, occupational health and safety (SEHS) aspects associated with its operations. While the company, being a start-up, does not presently have a SEHS management system (SEHSMS), Punj Upstream, within a timeframe agreed with IFC, will:
- borrow and adapt PLL’s EHSMS, which is certified to ISO 14001 and OHSAS 18000 standards;
- appropriately amalgamate in its EHSMS, its technical collaborator’s EHSMS; and
- embed IFC’s Performance Standards in its Social and EHSMS (SEHSMS).
Punj Upstream will obtain ISO 14001 and OHSAS 18001certification for its SEHSMS, within a timeframe agreed with IFC. The technical collaborator’s EHSMS incorporates procedures of relevance to oilfield service operations. The company’s SEHSMS will include SEHS Policy and procedures for:
- aspect, impact and risk identification and mitigation;
- compliance with regulatory requirements;
- development and implementation of management programs;
- SEHS structure, organization and responsibility; internal and external communication and consultation;
- training and awareness; monitoring, recording, reporting and documentation;
- internal and third party audits; corrective action; and
- management review.
The SEHSMS will also include a hierarchy of documented:
- standard operating procedures and work instructions;
- objectives, plans and programs; and forms and templates.
While Punj Upstream will likely not undertake environment and social assessment (ESA) of the projects it bids for (since its role is limited to provision of oilfield services), the company will implement/adhere to the EHS management plan (EMP) prepared by the E&P company seeking Punj Upstream’s services. However, as part of its SEHSMS, the company will have procedures to identify the site specific SEHS impacts and risks associated with its activities and will implement a management program to minimize/mitigate the identified impacts. Punj Upstream will, as part of the SEHSMS, have procedures to make available to each site management team, a site specific SEHS Management Plan, which will incorporate/be based on:
- the standard requirements of Punj Upstream’s SEHSMS;
- the EMP and Risk Management Plan made available by the E&P sponsor of the project; and
- relevant provisions of IFC’s Performance Standards and WBG/IFC EHS guidelines.
The company will, as part of its effort to ensure that its projects achieve outcomes consistent with the provisions of IFC’s Performance Standards, develop formal procedures to review and screen projects it bids for. The review of projects under these 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 the company’s requirements.
PLL will draw upon its screening procedure and will assist Punj Upstream in the development and implementation of assessment/screening procedure in a sample of projects.
Punj Upstream will, as part of its SEHSMS and in accordance with IFC’s PS6 provisions, develop and implement procedures, to minimize and mitigate impacts on bio-diversity, particularly when its project sites are located in 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.
Further, the company will, in accordance with IFC’s PS 8 provisions, develop and implement a chance find procedure in its SEHSMS 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.
Punj Upstream will, within a timeframe agreed with IFC, employ in-house fulltime appropriately qualified social and EHS professionals for oversight of SEHS performance. The company’s SEHS organization will draw upon the existing corporate SEHS resources available with PLL, for company-wide oversight of SEHS performance but will deploy an appropriately qualified EHS team at each project location for day to day management of EHS aspects and implementation of the SEHSMS. The company will also depute community relations professionals at the corporate and at project site as required to engage with communities in the vicinity of its project locations and to ensure that outcomes consistent with IFC’s Performance Standards pertaining to social aspects (PS 4, 5, 7 and 8) are achieved.
The company will implement procedures which require its contractors to also adhere to its EHS procedures. Punj Upstream will implement an EHS training program for employees as also for contractor’s labor. The company will implement procedures to monitor and report SEHS performance on a monthly cycle including an annual review of SEHS performance by Punj Upstream’s Board of Directors.
- PS2: Labor and Working Conditions
Punj Upstream will engage 108 employees per site directly or through contractors. The company will adapt and implement in its operations, PLL’s HR Policies and procedures. Currently, PLL is reviewing IFC’s Performance Standard 2 (PS2) and proposes to articulate policies and procedures, to make its HR practices consistent with IFC’s PS2 provisions. Punj Upstream will also implement PLL’s updated HR policies and procedures to meet IFC’s PS2 provisions. Punj Upstream will depute HR professionals at corporate and at project sites as required, who will be responsible for communication of the company’s HR policies to employees and labor, and ensuring that company HR policies and host country labor laws are complied with.
The company will manage occupational health and safety through its OHSAS 18001 certified SEHSMS. The SEHSMS will include operational control procedures for activities with identified occupational health and safety (OHS) risks, to meet IFC’s EHS guidelines, including for:
- safe equipment/facility design;
- blowouts, fire and explosion;
- incident, disease and accident recording, investigation, reporting and corrective action;
- emergency preparedness and response;
- work permits;
- physical condition checks;
- lighting and ventilation;
- work area air quality;
- housekeeping; and
- other safety requirements.
The company will make available personal protective equipment (PPE) to all employees including contractor’s labor and ensure its usage. Punj Upstream will employ an appropriately qualified safety officer, fire officer and also doctors/para-medical staff at each of its rig sites. The company will implement a safety training program for all new labor (including contract labor), entering a project site. The company will, for its employees and labor, ensure:
- living conditions with basic amenities and electricity;
- mess facilities for food;
- drinking water which meets host country potable water norms;
- provision of toilets and bath including separate toilets and baths for women; and
- primary medical facilities.
- PS3: Pollution Prevention and Abatement
Punj Upstream will manage environmental impacts of its operations as per the SEHSMS. The SEHSMS will include procedures to ensure that IFC’s PS3 and applicable EHS guideline provisions are met including for:
- equipment/material selection and operation to meet emission, energy efficiency and resource conservation norms;
- management of emissions and discharges to air, water and soil;
- management of hazardous materials, hazardous wastes, naturally occurring radioactive material and other wastes (solid and liquid);
- management of spills;
- minimization of project footprint; and
- noise levels.
The company will ensure that its contractors also adhere to the company’s standards on pollution prevention and abatement. The company will implement a monthly emission monitoring and reporting program including monitoring of ambient air quality and noise levels, particularly where sensitive receptors are in close proximity to the company’s operations.
- PS4: Community Health, Safety and Security
Punj Upstream will procure equipment and infrastructure that meet good industry practices. The company will, as part of the SEHSMS, implement procedures to ensure that community health, safety and security impacts are identified and mitigated in accordance with IFC’s Performance Standard 4 provisions including for community exposure to:
- noise, spills, fire and explosion;
- movement of equipment, material and wastes;
- noxious air emissions; and
- degradation and/or contamination of resources on which communities resident in the vicinity of the rig sites, are dependent.
The company will periodically monitor ambient air quality as also noise levels in potentially affected communities/villages, and implement mitigation measures where required. The company will implement procedures to minimize the risk of exacerbation of community exposure to disease and other potential host community impacts due to influx of its employees/labor. Further, Punj Upstream will ensure that all its employees and laborers undergo periodic health check up including for HIV/AIDS.
The company will employ security, who may be armed. Further, in certain bid situations, security may be provided by national/state security/police/armed forces. The company will, within a timeframe agreed with IFC, develop and implement a security personnel procedure in accordance with IFC’s PS 4 provisions. The security personnel procedure will include procedures for ensuring that:
- past records of security personnel deployed 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.
- PS5: Land Acquisition and Involuntary Resettlement
In addition to the screening procedure, the company will implement, as part of its SEHSMS, procedures to obtain assurance that land acquisition, renting or leasing as the case may be including compensation for loss of crop and associated assets/structures, at the sites where its rigs are deployed, is carried out in accordance with IFC’s PS 5 provisions.
