The following potential environment, health and safety and social aspect of the project were analyzed:
- availability and current land use of areas planned for plantation expansion;
- development of appropriate environmental and social management systems;
- air emissions, wastewater and solid waste handling issues for processing plants;
- occupational health and safety issues for workers in plants and in field operations;
- plantation management practices including the use of agricultural chemicals;
- labor issues for the workforce; and,
- relationships with local communities and community development assistance.
The sponsor has presented plans to address these impacts that will 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
- IFC social and environmental Performance Standards and environmental, health and safety (EHS) 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 Systems
Social and Environmental Assessment.
Prior to its merger with Salala, Weala Rubber Company produced an environmental management plan (EMP) for its operation to meet a Liberian government requirement that all existing operations have such a plan. The Liberian government subsequently requested, however, that all environmental management plans be done by an independent consultant approved by the Government. As Salala now includes both the rubber processing factory and the plantation – and because of the expansion plans at the plantation – Salala is carrying out an environmental and social impact assessment (ESIA) on all of the operations using a government-recommended independent consultant. IFC will review this ESIA when it becomes available and will ensure that its recommendations are integrated in the corrective action plan for the company. The management company, (Socfinco N.V.), undertakes its own internal audit of the company''s environmental and social performance.
Social and Environmental Management and Organization.
To manage good practices in the plantation and to maintain relations with surrounding communities, the company will develop a systematic approach to managing social and environmental aspects of its operations. The company has identified the quality control officer as the person responsible for the environmental performance of the company and has started monitoring its wastewater. The former is a requirement of the Liberian government. The company will put in place a monitoring program that will meet IFC’s requirements for monitoring data. With respect to the company’s social performance, IFC is requesting that the company appoint a dedicated Community Relations Officer with a social development background; this person would also take responsibility for managing the workers’ camps embedded in the Salala plantation. To build its approach to sustainable plantation management, as required by PS 6 (see below), the company will document its procedures and ensure that those procedures are followed. To ensure continuous improvement, the company will develop an environmental and social action plan (ESAP) detailing, at least annually, time-bound actions and committing sufficient resources to make sure they are completed.
Stakeholder Engagement.
At present the company relies on the Town Commissioner for its interaction with the community. The presence of a dedicated Community Relations Officer will aid the broad dissemination of information about Salala’s social development activities and environmental performance to the larger community. Salala will create a formal grievance mechanism to allow the direct lodging of grievances with the company by community members. With respect to the company’s environmental aspects, the ESAP will be a means for communicating the company’s social and environmental performance to the local communities. The company will also inform the Community of the results of those aspects of its management plans for the plantation so that the communities know the measures taken to protect the natural resources upon which they depend. The company will, finally, make the forthcoming EIA available for community comment prior to finalization.
Monitoring and Reporting.
Salala has been using an independent consultant to test the ambient conditions in the river adjoining the plant and the effluent entering the river from its effluent pond. Salala will set up a system in which the results of monitoring are incorporated into management decision-making, in particular the formulation of document procedures and the ESAP, and are report to Salala’s board to ensure that actions in the ESAP have sufficient resources. Salala will also monitor and report on the measure detailed under the discussion of PS 6, e.g., implementation of procedures, soil conservation, habitat protection, and plantation management plan implementation.
With the following measures put into place, the project will meet the requirements of PS 1:
- Training in environmental monitoring for the designated environmental officer;
- Appointment of a community relations officer;
- Documentation of procedures with respect to protection of the natural environment in the plantation;
- Develop and dissemination of an annual environmental and social management plan;
- Public disclosure of those aspect of the plantation management plan related to resources used by the local communities; and
- Annual public disclosure of the ESAP.
PS 2: Labor and Working Conditions
Human Resources Policy. Salala Rubber will develop a human resources policy that includes an explicit statement on non-discrimination.
Working Conditions. As part of the project, Salala will refurbish worker housing on the plantation. Much of the housing is now wattle-and-daub construction, reflecting the lack of other materials during the period of conflict. The company has already refurbished the camp health center. They have provided new boreholes, but some of these will need to be repaired.
Workers’ Organizations. As a result of the merger, two labor unions represent the company’s workers: one represents the workers of the old Weala plant and the other represents the workers of the old Salala plantation.
Retrenchment. The company did experience a labor action in November 2007. As a result, the workers were given the option of leaving the company and taking the retirement payment due them. This turn-over in workers was voluntary on their part and did not represent a forced retrenchment.
Protecting the Workforce. The Liberian Labor Law forbids child labor in plantation activities. The company neither employs children in its plantation nor at the processing plant. IFC reviewed the risk of possible harmful child labor among the out-growers working with Salala and determined that given the large number of out-growers selling to Salala, the risk exists but does not contribute to low labor costs and is addressable. The company will, in addition to including in its out-grower contracts a provision ensuring that the out-growers are committed to following Liberian law also undertake out-grower education to discourage employment of children in rubber activities. This provision will also meet IFC’s requirements.
Occupational health and safety. IFC noted a need for increased use of proper footwear and ear protection in the rubber processing plant. The company provides the required equipment, but compliance is still inconsistent. IFC suggested that a joint worker-management committee be set up to encourage people in using their personal protective equipment. The company will also undertake a systematic review of the machinery to ensure that all the guards are in place and of the placement of fire extinguishers to ensure they are located where they may be needed and have proper signage.
With the following measures put into place, the project will meet the requirements of PS 2:
- Development and dissemination to the workers of a human resources policy;
- Putting provisions into out-grower contracts requiring adherence to Liberian labor law, including provisions related to child labor;
- Roll out of a training program on child labor to out-growers;
- Formation of a joint worker-management health and safety committee; and
- Systematic review by the company of safety features within the Weala factory.
PS 3: Pollution Prevention and Abatement
Liquid Waste. The company has undertaken tests of its wastewater and ambient stream conditions. The test results show that the effluent entering the stream is cleaner than the ambient stream conditions. However, the test did not measure biological oxygen demand (BOD) in the effluent, but just dissolved oxygen at one, rather than two, points in time. The company is constructing settlement tanks where the process water leaves the plant, and a second treatment pond. Both the existing pond and the new pond are aerobic in the belief that the effluent does not contain organic matter. Sludge from the current system is taken away by a third party.
The effluent treatment system now only treats process water. The company will install a drainage system to capture the serum from the raw rubber waiting for processing. The addition of rubber serum, made up of protein and carbohydrates, to the wastewater treatment system will probably require the addition of anaerobic treatment. Also the drainage system is likely to pick up oil and grease from around the site, so that an oil separator may need to be added to the settlement tanks. Monitoring of BOD and oil and grease in the discharged effluent will determine the need for these additions to the treatment system.
Air Pollution. The project uses three diesel generators, two for continuous operation (one of 850 kva and another of 725 kva) and a smaller one of 150 kva for back-up power when the plant is stopped. The company has purchased new generators with maintenance support. Neither of the larger generators is of sufficient size for IFC to be concerned about air emissions as long as they are well maintained. During forest clearing operations, the company does not burn the cleared brush.
Emergency preparedness and response. The company needs to put together a fire suppression plan, which includes the appropriate location of fire extinguishers.
Pesticide Use and Management. The company is using agrochemicals, primarily fungicides that have identified impacts on human health, though not to the natural environment. To ensure that exposure to these fungicides is minimized, the company will have a written procedure for their use, including consideration of integrated pest management (IPM), training people in their handling and application, provide the necessary protective equipment, and supervise the application so that procedures are followed through. Because there is a very limited capacity in Liberia for applying a full IPM approach, the project will take the following feasible steps toward IPM: (1) will use agrochemicals for control not eradication; (2) review the possibility of using resistant strains of rubber trees in future plantings; (3) monitor the prevalence of pests, including fungus, to detect patterns or uncover other means of prevention and control; (4) use mechanical means of removing the pest where possible; (5) identify and use possible biological controls; and (6) use synthetic pesticides only when and in areas needed for control.
With the following measures put into place, the project will meet the requirements of PS 3:
- Construction of a drainage system for the plant emptying into the treatment ponds;
- Monitoring of effluent according to international methods and standards;
- Development of a fire suppression plan for the processing factory; and
- Take the above-detailed measures toward integrated pest management.
PS 4: Community Health, Safety and Security
Security. Salala Rubber has its own internal security personnel, but also use government police personnel for additional protection. The policemen are unarmed. As noted, the company will, in consultation with the community, put in place a grievance mechanism. This mechanism will include any issue with security personnel.
PS 5: Land Acquisition
The plantation concession is 20,080 acres and the plant (factory), with associated residential areas and gardens, occupies a 25-acre plot of land. The plantation concession was acquired by Salala Rubber’s predecessors in 1958 on a 70-year lease. The plant land is also a leased property currently on a 10-year renewable lease, which was originally acquired in the 1960s. Previous land use at the plantation concession included farms, Kolleh-ta and Pennah-ta villages, and use of the forest for fuel wood and game. Relocation of Kolleh-ta and Pennah-ta was done over 40 years ago with due compensation paid to the affected persons. Restoration of livelihood of the physically relocated did not arise because the new locations were very close to the concession, and provided similar natural endowments. During the war in Liberia, people from local communities did move into the concession area and grew crops. As the former Salala Rubber Corporation, before merging with Weala Rubber Company, sought to expand areas after the war, it compensated people for their crops and other standing assets. The Company observed due process for compensation. Various government agencies including the Ministry of Finance (involved in valuation of structures) Ministry Agriculture (involved in assessment of crops) and Ministry of Land and Mines (involved in land and physical property valuation) took part in assessment of properties for compensation. Now, the new Salala Rubber Corporation, the result of the merger with Weala Rubber Company, provides a two-year moratorium on lands earmarked for development to enable farmers who have encroached on the concession to harvest their crops. The company is improving its documentation on land acquisition by undertaking a more technologically improved survey including cadastral and GIS surveys and mapping, grievance logging and compensation documentation. The company will put into place a compensation framework that will ensure that any future instances of compensation standing crops or new land will meet the requirements of PS 5.
With the development and public disclosure of a compensation framework for land re-acquisition and expansion, this project will meet the requirements of PS 5.
PS 6: Biodiversity Conservation and Sustainable Natural Resource Management
Areas for expansion of the plantation over the next two years are modified habitat, mostly low bush. Older forests with potentially good biodiversity are found along some of the major water courses in the plantation area. Salala has committed to maintaining these and any similar habitats in other areas of the plantation that may be of high biodiversity value.
Sustainable Natural Resource Management. No sustainability certification exists for rubber plantations. The Roundtable on Sustainable Palm Oil contains practices, however, that can be applied to rubber plantations as well. Additionally, the Forest Stewardship Council is putting in place new plantation standards. Combined, these principles provide the following practices relevant to PS 6 that Salala will incorporate into its management, monitoring and reporting system for the plantation:
- Operating procedures documented;
- Soil surveys and topographical information are carried out of the plantation area;
- Maintain soil fertility through monitoring nutrient status of soils;
- Minimize and control erosion of soil;
- Avoid extensive planting on steep slopes/marginal soils;
- Maintain quality and availability of surface and ground water;
- Maintain ecosystem integrity and provide environmental services within plantation stands, including protecting riparian zones of native vegetation and possible conservation corridors;
- Identify any rare/threatened/endangered species, high conservation value habitats, if such exist - and incorporation of protective measures for them into management plans;
- With the local communities, identify and map socially important natural features in the plantation area or affected by the plantation that provide resources to local communities - and incorporate protective measures into the management plans.
Salala is in the process of gathering topographical information about the plantation and will carry out soil surveys in addition. It will develop procedures covering soil fertility monitoring, erosion control, agrochemical handling, and handling of slash following clearing for new planting. The company is identifying riparian zones of native vegetation and will look for any habitats that may be worth preserving for their conservation value or landscape connectivity. No rare/threatened/endangered species or high conservation value habitats have been identified at the Salala plantation and, given the historical use of the land, they are unlikely to be found. The ESIA consultant will, however, complete a review of all land within the concession, and Salala will have the principles and procedures in place to protect any that might be found. Salala will also seek technical assistance to see how their operations can maintain environmental services including maintaining the quality of surface and ground water.
Several other principles have already been discussed in relation to the following Performance Standards (above):
PS 1: - Disclosure of information on social and environmental impacts to local communities and identification of measures for their mitigation;
- Implementation of a grievance mechanism for the communities and workers
PS 2: - Development and distribution of a human resources policy
PS 3: - Use of agrochemicals for control, not elimination, of pests
- Leaving biomass from clearing in the fields and use of fire for waste disposal
PS 5: - Development and implementation of a compensation framework for land re-acquisition and expansion.
With the putting into place of the measures for sustainable plantation management detailed above, the project will meet the requirements of PS 6.
PS 8: Cultural Heritage
Salala Rubber has, in keeping with established practice of its predecessor, preserved a 12-acre ancestral burial ground within the plantation. An additional 26 acre parcel of land has also been preserved, on request, for the Massaquoi Town to preserve a relocated shrine and for expansion of the town (village). These shrines and the forest engulfing them are also treated as biodiversity offsets.
