Key environmental, health and safety, human resources and social issues in a project in this industry sector include the following:
The company has presented extensive information on its current practices and procedures that seek to address environmental and social risks and impacts to ensure that the proposed project currently complies with or will upon implementation of specific additional agreed measures, comply with host country laws and regulations and the IFC Performance Standards on Social and Environment Sustainability and environmental, health and safety guidelines. Information about how these potential impacts are or will be addressed by the sponsor/project is summarized in the paragraphs that follow. Additional actions are summarized in the attached Environmental and Social Action Plan (ESAP).
PS1: Environmental, Health and Safety, and Social (ESHS)Assessment and Management Systems:
Management Systems-
There is a well maintained Environmental and Social Management System (ESMS) implemented in AGD, to assess environmental impacts to avoid or minimize the adverse impacts on workers and the environment, which is compliant with IFC Performance Standards. Most of the plants are certified for quality (e.g.: ISO 9000:2000) and for food safety. The ESMS includes drinking water control, life and fire safety, effluent control, training for employees, occupational health and safety procedures and policies, and management of solid and hazardous wastes.
AGD has been implementing a “Good Manufacturing Practices” (BPM) system in almost every plant, which has increased the level of awareness to its production processes. AGD has continued the quality control certification process for food safety on T6 and T6I as well as certified PBIP-ISPS (International Ship and Port Facility Security Code). Both T6 and T6I are fully compliant with environmental regulation in Argentina
As regards to AGD''s supply chain, the company processes 6 million tons of soybeans per year, mainly sourced from third parties. None of the company''s agricultural operations are located in the Chaco region. From the soybean purchased from third parties, about 10 percent come from the Chaco region. The company originates most of its soybeans needs from its own "centros de acopio", also buying from third parties and brokers.
The company will update its database system to collect information on farmer suppliers in the Charata area in the Chaco region and any other collection centers (acopios) in the Chaco region. The new data collection should include information on compliance with national environmental legislation (illegal land clearing). Following additional data collection, identify any changes in the company''s management of suppliers in the Chaco acopios/collection centers to reduce any detected risk from illegal land clearing in the Chaco supply chain. This shall include informing Chaco farmers with whom the company has soy purchase contracts that AGD expects them to comply with Argentine legislation related to new land clearing.
PS2: Labor and Working Conditions:
AGD has a total permanent labor force of 1,493 at all of its operations. All employment is in compliance with national labor law and there is no child labor involved. AGD promotes good labor relationships through full respect for all labor and social security laws, direct hiring of seasonal workers at facilities during harvest peaks. AGD’s hires 596 workers on a seasonal basis. Freedom of association is protected under Argentine law and AGD workers may join unions if they desire. The company maintains a clear and transparent system for workers to manifest any concern they have with designated AGD staff to deal with these. AGD has a comprehensive and well developed Human Resources Policy.
Occupational health and Safety-
The company maintains a monitoring system of the workplace conditions for all plants which includes workplace air quality, noise and heat exposure. The measurements show material compliance with both IFC guidelines and Argentinean standards. AGD is properly monitoring and mitigating the situation by providing proper ear protection to its employees as part of the PPE (personal protection equipment).
The company provides PPE and appropriate training to all workers. Occupational health and safety issues are managed at the level of each operation by a designated OHS manager. Fire and PPE safety and signage is visible and adequate. PPE usage was consistently good at all the locations visited. Workplace air quality and noise is within acceptable limits. Fire drills and emergency preparedness drills are carried out on regular basis.
Training-
The company will implement a training programme on environmental issues for its workforce as part of the content of the induction process for new employees. Currently AGD has a high need of skilled people to work on its facilities, mainly IT knowledge. The training process varies with AGD’s demand and could be summarized in:
Induction training – workplace knowledge, accident prevention for new staff and internal code;
Management training - CRM, personal coaching, team coaching, project management, HR management and self development;
Capacity Building - Time management;
IT - Office for windows pack, database server and Java;
Safety - Occupational health and safety system management, Personal Protection Equipment use, first aid, agrochemicals management, final disposal of empty packs and dealing with heavy loads;
Technical training - Soy varieties, mechanical maintenance, boiler maintenance, plagues combat, labor laws, safe handling of agrochemicals, grain market, climate, negotiation, quality control, logistics, pallets tracking, data warehousing, Supply chain management, metrology, software testing and empty spaces management.
PS3: Pollution Prevention and Abatement:
Field operations on AGD owned farms include common practices for field production of soybeans and peanuts. For crop nutrients, chemical fertilizers are applied. The farms utilize direct planting (zero tilling) to reduce soil erosion. Pesticides are used, according to appropriate standard procedures for application.
Air Emissions-
All Point Source emissions are in compliance with IFC guidelines and Argentinean standards for Particulate Matter (PM), NOx and SO2. Ambient Air monitoring is performed for all plants but Aceite Dalmacio Velez Plant, because of the use of Natural Gas, a cleaner source of energy which is composed of methane (89%), ethane (6%), propane (1,8%) with only 0,7% nitrogen and no sulfur, as power source.
Liquid Effluents-
The effluent monitoring in Aceitera Chabás indicates compliance with both IFC guidelines and Argentinean standards. All other plants are also in compliance with both IFC guidelines and Argentinean standards. AGD will carry out annual periodical analysis of soil irrigated by process effluents from the soybean oil plant in Gral. Deheza which are used to irrigate trees used for reforestation.
Ambient Noise-
The Ambient Noise monitoring data indicates compliance with both IFC guidelines and Argentinean standards.
Solid Waste-
Solid waste monitoring is well performed by AGD. Solid waste is properly collected, handled, stored and disposed. Some creative solutions for solid waste were created such as the use of peanut shells as alternative fuel for the Gral. Deheza’s boiler. There is a strong recycling policy implemented in all plants and recyclables are sold to external companies. The non-recyclable solid waste is disposed in landfills, some of them sanitary landfills.
Hazardous Waste-
In Argentina, light bulbs are considered domestic waste and are not disposed properly, allowing the disposal of toxic components in landfills. IFC has checked an alternative for disposing light bulbs properly but it would require an investment of the Company in clean technologies such as a dry lamp crusher. AGD uses some dangerous chemicals in the production of its products such as N-hexane, Sodium Hypochlorite, Diesel oil, Acetone, Toluene, Sulfuric Acid, Phosphoric Acid and Ammoniac. The Company also generates wasted lubricant in every plant, which is handled, stored and disposed in a proper way. AGD will develop and implement a plan for leak tests or accurate inspection in the underground N-Hexane tanks in order to prevent soil pollution in Gral. Deheza plant.
Workplace Monitoring-
Workplace noise and temperature - Working stations at T6 and T6I will be audited by an external company for heat exposure and noise levels. In T6 and T6I, the noise level can reach a peak of 98 db, which is a source of concern even when the employees are using appropriate PPE, which is the case. The workplace temperature varies from 31ºC to 34ºC, and should be also tested for possible corrective actions. The Company will submit a report to IFC, and implement mitigation actions if so.
Incident Monitoring-
The number of lost workdays in Aceitera Chabás has increased in the last 2 years. In order to deal with this situation, AGD is investing in work training programs and restructuring some problematic procedures such as lifting of heavy loads and poor signage. The accident incidence has also increased at Niza, Aceite Dalmacio Velez plant and Gral. Deheza plant. The incidence rate has decreased at the Alejandro Roca plant and Envasado de Aceite plant. In accordance with the ESAP, AGD is developing a plan to improve work place safety and further reduce last time incidence in the workplace.
There was an accident on April 4, 2005 causing a casualty of an outsource employee in Alejandro Roca plant. AGD provide an Accident Investigation Reporting a Death by a collapse in the storage silo structure in the peanut industry. The analysis of the accident indicates that the operator was located beneath the silo without noticing the collapse of the same and apparently he did not hear any noise and did not react to this situation. AGD checked all the designs of the structures but could not find any signal (cracks, joints or defects) that indicated the structure weakness. The company proceeded to the correction of the structures.
Life and Fire Safety-
The AGD life and fire safety monitoring and management for all plants is compliant with both IFC guidelines and Argentinean standards, and include periodical fire drills, inspections and preventive maintenance in the smoke detection and fire suppression systems and also a periodical analysis of portable fire extinguishers. A few minor deficiencies were found and corrected such as corrosion in some pipes and valves. The fire detection system in Gral. Deheza is still manual, while in Alejandro Roca there is no fire detection network. Alejandro Roca plant has a fire brigade, and is equipped with portable fire extinguishers and hydrants located in strategic positions. To further enhance fire and life safety, AGD will implement a fire detection system in Alejandro Roca plant and T6 and T6I will perform three fire drills per annum in all operating facilities (see ESAP for details).
Reduction of Water consumption-
AGD will implement a monitoring policy to reduce water consumption in Alejandro Roca and Villa Mercedes, including the implementation of proper monitoring indicators of water consumption per unit of product, which will enable the company to benchmark current consumption with the other plants and other industries and set consumption mitigation targets. In Gral. Deheza, the effluent generated is biologically treated and used to irrigate a reforestation project which is currently running.
Pesticide use and management-
AGD uses hazardous compounds according to “THE WHO RECOMMENDED CLASSIFICATION OF PESTICIDES BY HAZARD” guidelines. Among the 5 different compounds used i) Bromadiolone (16 lts/year) and Difethialone (24 Kg/year) are classified Class Ia - Extremely hazardous active ingredients of pesticides, ii) Cypermethrin (15 lts/year) and Cyfluthrin (50 lts / year) are classified Class II – Highly hazardous active ingredients of pesticides, and iii) Aluminum Phosphides is not in the WHO list.
The company has elements of an integrated pest and disease management system (IPM/IDM). AGD will hire consultants to organize a programme designed to develop a business plan to further upgrade this IPM/IDM system to create guidelines to reduce the use of organophosphate compounds, substitute these with less toxic products, and introduce biological control components into their pest management strategy. The company will implement the IPM/IDM business plan following the procedures and timetable developed by the consultants. AGD will also provide to IFC the protocol used for blood testing of workers applying pesticides. The company will inform if there is any rotation policy of these workers.
PS4: Community Health, Safety and Security:
Several AGD operations are located within the urban limits of communities, such as the case of General Deheza. There is an easily accessible office open to the public to register any concerns about smells or other industrial concerns. AGD’s senior management lives next to the operations and thus demonstrates its own high confidence with community safety conditions. Alejandro Roca plant is located in an industrial area within the city boundaries while Niza plants are located in an industrial area. All the plants were built to suit the company purposes and have a controlled environment with acclimatized areas.
Aerial spraying of crops: As is customary done in Argentina, some of the land AGD operates is subject to aerial spraying
PS5: Land Acquisition and Involuntary Resettlement:
There is no involuntary resettlement associated with this project. AGD will expand its land holdings and build new acopios. Land acquisition for collection centers is strictly one of willing buyer-willing seller. Prices are mutually agreed and reflect market values. A rigorous title-search process is done to ensure that all land purchased is fully compliant with relevant titling and applicable legislation and free of any litigation or conflicts.
PS6: Biodiversity Conservation and Sustainable Natural Resource Management:
AGD operations do not involve known modification, conversion, or degradation of any critical natural habitats. The company has followed Argentinean legislation in obtaining authorization for its own farm land clearing, which has occurred in only limited cases. No known endangered species are affected by the projects operations. No legally protected conservation areas are impacted. The majority of AGD farm land can be classified as previously developed. The company has participated in the second General Assembly of the RTRS (Round Table for Responsible Soy) and will continue to participate in the development of good agricultural practices in the management of soy.
