The following sections describe how Packages does or plans to mitigate potential social and environmental issues arising from the project in compliance with the Performance Standards.
Social and Environmental Assessment and Management System-
Assessment:
The Lahore site has evolved substantially without social and environmental assessment during its more than forty years of manufacturing. Despite this, the company is aware of the effects of its operations on its neighbors, many of whom have arrived after establishment of the factory. The incompatibility of a pulp and paper mill with a residential neighborhood was an important motivator for Packages to seek to move it operations.
The Bulleh Shah Paper Mill development was subject to assessment by the Pakistani authorities who issued permits to construct and operate the facility conditional upon Packages fulfilling certain conditions, particularly related to community development, which has been done. In addition, an environmental and social impact assessment was undertaken by a local consultant in support of earlier financing for BSPM. Development of BSPM continues, and although certain key process decisions, such as choice of bleaching technology for the next phase of expansion remain outstanding; Packages will ensure that future developments are compatible with Best Available Techniques for the pulp and paper industry. A hazards and operability (“HAZOP”) review will be undertaken of the existing designs and of the designs for plant expansion.
Management Program:
Packages has a well-established continuous improvement culture, which is driven by the company’s department of Industrial Performance. This department does effectively liaise with Packages’ technical and production management departments, and has been responsible for management of Packages’ environmental performance since around 2005. Since early 2007, this department has also been responsible for occupation health and safety, taking this responsibility from the team which had charge of premises safety and security. In both disciplines, the department has established implementation structures, through process improvement teams, has employed external trainers for staff capacity building and has established results monitoring protocols. Data are disseminated within the Company including to senior management level. Packages’ paper and board mill, and its packaging operations have both been certified compliant with ISO 14001, while certification of compliance with OSHAS 18001 is expected in the first quarter of 2009. The company is also developing HACCP-based procedures for its food packaging materials business; expecting certification of its entire operation by the end of 2008.
Community Engagement:
Packages has relatively little community development engagement in its own right, though it does contribute to community development through the Babar Ali foundation to which it donates some financial resources and also senior staff time.
Packages has established a community development committee to manage community development activities in the area around BSPM. Through this committee Packages does engage with the communities around the mill, and so this communication channel provides a community grievance mechanism. At an early stage of development of the mill, meetings were held with local people in order to identify the hopes and concerns of the communities, and these have been taken into account in planning community development activities.
It is expected that by 2009, the project will have created 250 permanent jobs filled by local hires in Kasur, while the production expansion will increase the company’s wheat straw purchases from 95,000 tons (costing 272 million rupees) in 2005 to 125,000 tons expected to cost around 470 million rupees in 2008.
Labor and Working Conditions:
Working Conditions and the Management Worker Relationship-
Packages has comprehensive human resources policies and procedures which are documented in the company’s “Company Service Rules.” An abbreviated form of this document is provided as a booklet to each employee, and is available to all employees through the company’s intranet.
The working relationship is communicated to employees through the booklet described above and through the written letter of appointment.
Packages does have a trade union, through which collective bargaining agreements are made, and which can represent worker grievances. Both salary and non-salary benefits are competitive, and Packages’ contributory employee welfare scheme is particularly appreciated.
While Packages does not have a formal policy covering these matters, the company strictly adopts policies of non discrimination, be it gender religious or inter-provincial discrimination.
While Packages does expect ultimately to transfer all paper-making to BSPM its experience has been that the closures to date at Lahore have been accomplished without compulsory redundancy, all employees have been able to find alternative positions at Lahore. Packages expects to be able to continue this trend.
Packages youngest employee is 18 years of age. Packages does purchase recycled paper, through a complex supply chain that includes formalized waste paper collection from paper product users, but which also includes the informal sector. There is known to be some degree of child labor, working in family units within the informal waste paper supply chain, though several stages removed from the users of recovered paper. Packages and IFC are jointly designing a program to increase recovery of recyclable materials (for example, plastics, glass and metals as well as paper) in the Lahore area and which is intended to address adverse social effects prevailing in the informal sector.
Occupational Health and Safety:
As described in the section describing social and environmental management, Packages has been very active since early 2007 in management of occupation health and safety, building upon earlier work in this area. Risk assessments have been undertaken and risk control measures defined across most of the Lahore site, and action plans substantially implemented. Many of these are simple, such as enhancement of machinery guarding and provision of personal protective equipment. Safety procedures have been developed describing safe approaches to, for example, incident and accident investigation, lock-out, tag-out, confined spaces, hot works, working at height and safe storage and use of compressed gases. Packages believes its accident recording is more systematic than ever before, and incidents (near misses) are now investigated. In addition, there is a new-found resistance to identify operator error as a cause of an accident, which instead would most likely be attributed today to inadequate training or supervision. Over 200 man hours of safety-related training has been provided to staff at Lahore site, and more than 130 man hours at BSPM. In 2008 to date, Packages has recorded around 2.2 lost time accidents per million. This is a creditable figure in this industry and reflects a significant improvement from 4.2 lost time accidents per million man hours worked in 2007.
Pollution Prevention and Abatement-
Resource Efficiency:
Packages manufactures pulp from wheat straw through the CTMP and sulfite pulping processes. Wheat straw is an agricultural waste in this part of Pakistan. Packages also recycles paper and card in its operations at both Lahore and BSPM and minimizes its use of wood pulp consistent with maintaining adequate paper strength.
BSPM is designed to be an efficient user of utilities, and will therefore represent a considerable improvement over Lahore. Specific electricity use is at good practice levels, and design specific water use is 34 m3/tonne. This figure has not yet been achieved, but additional water metering and a number of projects to reduce water consumption will be implemented during 2008. By contrast, specific water use at Lahore has only recently been reduced below 100 m3/tonne.
Emissions to Air, Lahore Factory:
Air emissions from pulp and paper-making at Lahore arise from products of combustion from two gas-fire steam boilers, and one recovery boiler. All are monitored regularly and are well within IFC guideline values and local requirements. Diesel generators formerly used are no longer required with the transfer of paper-making to BSPM.
Emissions of volatile organic compounds arise from nine printing machines and two flexible packaging laminating machines used in the packaging materials business. VOC emissions are not regulated in Pakistan, but emissions considerable exceed IFC guideline values. Packages is in discussion with a number of possible suppliers to develop solutions to control these emissions. It expects to develop solvent recovery solutions for the two laminator machines which use single solvents, and will install a solvent-laden vapor incineration system for the other machines. It is expected the solution will include heat recovery either to heat thermal oil used in the process or to drive the absorption refrigeration air conditioning systems. Packages expects to commission its solvent recovery system by the end of 2009.
Emissions to Air, BSPM:
Air emissions at BSPM arise from a gas turbine based cogeneration system and a gas-fired power boiler. Emissions are monitored regularly and are well within IFC guidelines and local requirements. Packages has monitored NOx levels at its boundary found these to be below detection level. Addition air emissions will develop when Packages starts chemical pulping at BSPM. At that time, and before orders are placed, and air emissions model will be prepared to confirm that Packages operations will not cause deterioration in ambient air quality
Liquid Effluents, Lahore Factory:
Liquid effluents at Lahore are treated by primary clarified only before discharge to watercourse. Effluents do not meet local or IFC standards for discharge to water courses, and Packages is committed to meeting these requirements by the conclusion of the investment program to be funded by this project. However, the nature and scale of investment necessary to treat these effluents depends upon which pulp and paper-making process effluents are considered in its design and could vary greatly. It would not be appropriate to devote large financial resources to developing end-of-pipe effluent treatment solutions if the process involved were to move shortly. Production processes in question are the manufacture of board (PM1) and tissue (PM 4 and PM9) and their supporting chemical straw pulping and recycled fibre processing lines.
The following process will be adopted. Packages will continue its discussions with potential suppliers to determine the technical specification, operating parameters and cost of various effluent treatment solutions. In parallel, by the end of February 2009, Packages will define its timetable for moving the remaining pulp and paper-making operations from Lahore. At this time, the production processes whose effluent must be treated by the new Lahore effluent treatment plant will be known, and an appropriately-scoped order can be placed by June 2009. The resulting effluent treatment solution will be developed during 2009 and will be commissioned by December 2010.
Liquid Effluents, BSPM:
BSPM has been treating its liquid effluents with a primary clarifier only from December 2007 until July 2008. The first aeration lagoon was commissioned in July, 2008, and this is designed to treat effluents arising from PM6, OCC slushing and the straw CTMP line to IFC guideline values. A second aeration lagoon has been constructed, and will be commissioned with the start of the second paper machine (PM7) and its supporting DIP line in August / September 2008. At the time of IFC’s visit, the first aeration lagoon was establishing its microorganism population, and effluent standard did not meet IFC guidelines. However, the waste water treatment plant design suggests that satisfactory operation of the first lagoon (for PM6 and supporting pulping) and then both lagoons together will treat liquid effluents to IFC guideline requirements for non-wood pulping.
It is anticipated that BSPM will be expanded further with the ultimate start-up of PM8 ( replacing Lahore’s PM1) and chemical pulping. Packages has determined that it will employ a soda pulping process, whose effluent is readily treatable. The bleaching process has not yet been determined, though an ECF or TCF process will be used. Packages will ensure that the production processes employed and effluent treatment technologies adopted will use best available techniques.
Wastes:
Varied solid wastes arise from pulp and paper making. Wastes, such as plastic bags which are collected from waste paper pulping are sold for use as fuel in the local brickmaking industry. Plastic scraps arising from the flexible packaging operation are similarly sold. Effluent treatment plant sludge is pressed and sold for use as a board filling material. Some grains and clean straw residues result from straw washing – these are sold as animal feed. Other material such as stones and mud separated from straw cleaning are sold for use in land filling. The future soda-based chemical pulping line will generate silica-contaminated lime which will be suitable for use in land filling. Garbage and hazardous wastes are removed from the sites by authorized contractors for off-site disposal.
Hazardous Materials Management:
Packages has a complete inventory of all hazardous materials used at both sites, and has material safety data sheets for all. Dedicated stores are used for hazardous materials, and these have been strengthened considerably over the last three years. Procedures for safe management of hazardous materials have been reviewed and where necessary developed and training provided in the use of these within the context of the OHS work described above.
Greenhouse Gas Emissions:
Annual emissions of CO2 from Packages energy consumption are estimated at 300,000 tonnes. This figure is expected to be reduced as the manufacturing transfer from Lahore to BSPM continues. Packages will quantify its GHG emissions on an annual basis.
Community Health, Safety and Security-
Transport Impacts:
Packages has developed a regional network of straw collection centers which have straw baling machines. These are used to compress straw delivered to each site for use as raw material, thus considerably reducing road traffic required for straw transport. The BSPM site is closer to the sources of straw than is Lahore, also reducing traffic impacts.
Packages has developed a rail siding at a short distance (around 12 km) from BSPM, and uses rail containers (rather than road) to transport finished paper to Karachi for export or for its converting operations in Karachi and also to transport imported raw materials from Karachi port. Roads local to BSPM have been widened and road surfaces metalled. Packages stresses the need for safe, defensive driving to all its transport operators.
Ground Water:
Studies were undertaken before construction to predict the effect of BSPM on ground water availability, and it was concluded that the effect would be very limited. Ground water level monitoring is undertaken at three locations within BSPM and has shown marginal effect of Packages activity.
Effluent discharges – BSPM:
BSPM discharges to the Pandoki-Doftoh drainage ditch. This was originally constructed as a means to remove shallow, saline ground water, when the substantial irrigation scheme in this area was planned more than 100 years ago. The ditch is an ephemeral stream, completely full at times and dry at others. At times therefore, the ditch will contain Packages effluents only. Some distance downstream of Packages, the ditch accepts effluents in Kasur, including from the town’s tanneries. Packages has constructed one deep tube well, to provide clean water for farm animals, and has opened discussions with its community development committee on constructing additional wells should demand be demonstrated.
