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 company is summarized in the paragraphs that follow. Further information is provided in the attached documentation.
PS 1: Social and Environmental Assessment and Management System
JISL’s management proactively addresses environmental, social, occupational health and safety (EHS) aspects associated with its operations. JISL has articulated quality, health and safety, environmental and social accountability policies. JISL has also received several international and national awards for entrepreneurship, innovation and environmentally responsible initiatives.
JISL’s production facilities in India include: food processing units in Jalgaon (Maharashtra), Baroda (Gujarat) and Chittoor (Andhra Pradesh) and MIS / plastics operations in Jalgaon (Maharashtra), Hyderabad (Andhra Pradesh) and Udumalpet (Andhra Pradesh).
The company has employed, in-house fulltime qualified professionals, for oversight of EHS aspects at corporate level as well as for its plastics and food operations in Jalgaon as well as Chittoor. The company is in the process of identifying dedicated competent EHS personnel for its other facilities in India such as Udumalpet, Baroda, Hyderabad etc. by March-09.
Except for the Udumalpet and Hyderabad facility, all facilities have at least one or more of the following certifications such as: ISO 9000:2000 or ISO14001. Food processing facilities are certified to standards such as ISO 22000:2005, HACCP and Food Safety standards, British Retailer Consortium standards, Codex Alimentarius, Kosher standards etc.
All of JISL’s owned agricultural sites (farms and plantations) are EUREPGAP certified; and its tissue culture lab is ISO 9001 certified, and central laboratory operations are certified to GLP standards and NABL.
As a condition of previous IFC investment, JISL is in the process of implementation across its facilities in Jalgaon and Chittoor (Andhra Pradesh), an integrated EHS management system (EHSMS) certified to ISO 14001 and OHSAS 18001 standards, with IFC’s Performance Standards and EHS guidelines duly embedded in the EHSMS. EHSMS manual and other documentation has been developed by external consultants and issued to respective departments. The same has been implemented and internal audit has been carried out. Final certification audit at Jalgaon and Chittoor is expected to be undertaken in early 2009. For its other facilities in Baroda, Hyderabad and Udumalpet JISL is in the process of developing EHSMS documentation and is planning to have integrated EHS MS in place by June-2009. JISL has been exploring the possibility of obtaining an internationally recognized certification for its food products such as Rainforest Alliance, Fair Trade, SA 8000 and Organic products.
Supply Chain for Agribusiness Operations
Mangoes are the main raw materials for the fruit processing operations of JISL. Little over 10% of the total requirement is met through the captive mango production from JISL’s own plantations in Jalgaon, which are EurepGAP certified. The balance raw material is purchased in trading markets in Maharashtra and neighboring states of Andhra Pradesh, Gujarat, Karnataka and Tamilnadu – which are major mango producers. Other fruits such as pomegranate, berries etc. are also sourced from the open trading markets.
For the onion processing operation, approximately 40-45% of the total requirement is met through contract farming, while the rest is met through purchases in open markets across India.
JISL’s contract onion farming covers 4200 acres of land and 1700 contract farmers. The Company''s contract farming program includes provision of technical and financial support to farmers.
Further, to promote efficient agronomic techniques in the farming sector, JISL has undertaken several initiatives including: development and provision of high yield seeds; method and result demonstration for farmers; technical assistance on introduction of drip irrigation and watershed development; periodic meetings with farmers to discuss techniques to improve yield per hectare, dissemination of information booklets and training on good agricultural practices.
JISL has processes in place to ensure pragmatic use of pesticides. As a condition of previous IFC investment, JISL does not use pesticides under WHO hazard class Ia, Ib and II in its own farms / premises as well as in its contract farming operations. The company is also working on the Integrated Pest Management (IPM) and Integrated Vector Management (IVM) programs in the farms of its contract farmers.
JISL has developed, implemented and communicated to the contract farmers, a formalized grievance redress process with the help of extension officers, for receiving and responding to contract farmers grievances.
PS 2: Labor and Working Conditions
JISL has a HR manual and manages labor working conditions under the state government’s Model Standing Orders. The Model Standing Orders are generally consistent with PS 2 provisions and are displayed in the local language at plant premises. The Company has HR professionals deputed at each of its plants, who are responsible for communication of JISL’s HR policies to employees and labor. Working conditions are communicated to employees and labor through their appointment letters, and in the orientation program.
JISL has constituted a joint works council, comprised of both management (50%) and worker representatives (50%), to receive and redress worker concerns. The council meets every 6 months to review and address any grievances and/or issues of concern for the workers.
The company has reviewed IFC’s Performance Standard 2 (PS2) and has agreed with IFC, to articulate policies and procedures, to make its HR practices consistent with IFC’s PS2 provisions. For this, JISL has engaged an external consultant to review the existing HR policies, procedures and practices against PS2 provisions and develop an action plan, for development and implementation of policies and procedures where required, that are consistent with PS2 provisions.
JISL conducts EHS induction training for all new employees as well as regular safety training programs for its staff and workers - including contract labor entering the company facility. Doctors/para-medical staff and ambulances are available at all of its facilities.
The company has put in place safety committees comprised of both worker and management representatives, which meet on a quarterly basis to develop and implement corrective action plans. While JISL provides personal protective equipment (PPE) to all employees, its usage by workers including contract labor, needs to be improved. For this, JISL management has initiated a strong effort to create awareness and ensure a proper usage of PPE among all its employees – which include management directives, training sessions, close monitoring by shop floor supervisors, random checks by senior management and a fine plus departmental award system, among others.
As part of its EHSMS, JISL makes it mandatory for its contractors to adhere to JISL’s EHS procedures and requirements as conditions of contract. JISL periodically monitors and internally reports the EHS performance of its contractors on issues such as workplace safety, use of PPE and safety training of contractors’ labor. However, in view of ongoing heavy construction activity, there is a need to further step up the monitoring of EHS compliance of its contractors (especially construction and transport).
For this purpose, JISL has agreed to undertake an internal safety audit of the activities of its construction and transport contractors by 31 January 2009 and develop an action plan before 15 February 2009. Based on the outcomes of this safety audits, JISL has agreed to include necessary EHS related clauses all its in future contracts as well as develop a new documented procedure for monitoring its contractors across all its facilities. Further, JISL has agreed to institute an internal safety audit every six months covering all its facilities and contractors.
PS3: Pollution Prevention and Abatement
As a condition of the earlier IFC investment, JISL has implemented company wide procedures and measures to monitor and ensure that facility emissions and discharges; ambient air quality and noise levels; management of hazardous materials, hazardous wastes and other wastes are in accordance with both host country and IFC norms.
At JISL’s facilities in Jalgaon, there are separate effluent treatment plants (ETPs) for plastics and food divisions and the treated wastewater is used for irrigation in JISL’s own fields nearby. The treated wastewater meets host country and IFC requirements. The capacities of the ETPs are adequate to accommodate the additional wastewater generated after the capacity expansion.
Outside Jalgaon, adequate ETP facilities are operational at all its facilities except Udumalpet, and the treated wastewater is reused for gardening or irrigation of JISL’s own fields nearby. Udumalpet facility, which JISL recently acquired, came with an old ETP in poor condition, which is currently not operational. However Udumalpet facility is very small (with 3 machines for PVC pipe and one machine for PE tube) and does not generate process wastewater, except for cooling water. However to take care of any spillage of raw material and floor washings, the effluent is passed through double filtration (sand media and charcoal) and is discharged for agricultural purpose after testing by agronomists. The domestic effluent is treated separately in septic tanks. However, JISL is currently in the process of assessing the quality of treated water vis-à-vis the regulatory and IFC requirements. JISL has agreed to complete these studies by 31 March 2009 and subsequently upgrade the ETP, if necessary.
JISL has very recently replaced its old furnace oil based boilers for food processing operations in Jalgaon, with a new dual fuel (coal and biomass – primarily bagasse) fired boiler of higher capacity. This new energy-efficient boiler is equipped with bag filters and the air emissions meet host country and IFC requirements as revealed through preliminary monitoring.
JISL will monitor the air emissions from the new boiler for one complete processing season and shall report to IFC about the same through the annual monitoring report.
There are diesel generator sets for backup power; and the diesel is stored in an underground tank which has adequate containment to prevent spillage of diesel at the time of loading / unloading.
Hazardous ETP sludge and other hazardous wastes are disposed through authorized entities in a secure landfill or for regeneration or recycling. General scrap and other non hazardous wastes are segregated and sold to recyclers.
JISL is implementing an Integrated Pest Management (IPM) and Integrated Vector Management (IVM) program in its contract farming operations as also on its own farms, to reduce reliance on synthetic pesticides. For this, JISL has been implementing several farmer training and awareness activities to encourage farmers, to adopt IPM and IVM techniques, which includes printing and distribution of booklets, training programs and counseling with the help of extension officers.
The refrigerant gases in refrigeration systems and chillers are in accordance with host country regulations on ozone depleting gases. The company uses Aluminum Phosphide and Methyl Bromide for export containers fumigation purposes only. While the company has outsourced fumigation to licensed pest control agencies, documented procedures have been developed to ensure that such agencies carry out fumigation in accordance with international good practices, to mitigate risk of occupational exposure to these fumigants. The fumigation process is carried out strictly according to the procedure in the presence of authorized senior staff from JISL.
The main business of the company, MIS, promotes water conservation (and subsequently energy conservation due to reduced water pumping requirements). As per the estimates by JISL, with drip irrigation average water saving is 3,750 cu.m per Ha while that for sprinkler irrigation is 1,900 cu.m. Based on JISL’s sales for 2007-08, hectarage irrigated by drip and sprinkler irrigation was 97,600 Ha and 54,167 Ha respectively. As such, the total water savings achieved by JISL’s MIS during 2007-08 amounts to 469 million m3, which consequently also resulted in electrical energy saving of the order of 31,074,182 kWh. In addition, the Company assembles and markets solar heating and lighting systems contributing to overall energy conservation.
For the year 2007-08, JISL has estimated its carbon footprint of its activities in Jalgaon such as plastics park, Jain Hills (residential and office facilities), Jain Valley (food park), Anubhuti school and Wakod village. The protocol used for the estimation was internationally accepted GHG Protocol developed by World Resource Institute and World Business Council for Sustainable Development. JISL emitted nearly 180,000 tons of carbon dioxide equivalent (CO2e) comprising of direct, indirect and off-site (due to travel, transport etc.) emissions.
Through several internal programs (such as afforestation, biogas, solar, vermicomposting and electric vehicles) as well as through its EcoSaver products which are used externally (drip irrigation, sprinkler systems, solar water heaters and photovoltaic systems) JISL has reported to have achieved 265,000 T CO2e reductions and thus has a net positive carbon balance of nearly 85,000 T CO2e.
At its facilities in Jalgaon, JISL has implemented various energy efficiency and resource conservation measures, such as: use of solar water heating and lighting systems; generation and use of biogas from domestic sewage and process effluents; use of treated effluent in irrigation on premises; and is currently in the process of commissioning a 1.6 MW waste-to electricity project at its Energy Park.
This power plant will take waste from fruit processing (250-300T/day during season), which would be converted to methane in bioreactors. JISL’s biotech lab has developed special strains that can generate more methane from waste and can also work on a range of organic solid waste other than the fruits. JISL is planning to use German (Largg) and Indian (Kirloskar – Wartsila) engines to produce electricity directly from methane. JISL is planning to start generating power from this plant from by April 2009.
PS4:– Community Health, Safety and Security
The company as a part of E&S compliance for the past IFC investment has put in place procedures to: assess potential community impacts of its projects and operations; mitigate identified risks and impacts including risk of uncontrolled release of hazardous materials from its operations or in hazardous material transport – which include for instance, process chemicals, fuels, fumigation chemicals etc. JISL has also prepared and implemented an onsite and offsite Disaster and Emergency Management Plan, and is now trying to link it to the district emergency response plan.
The Company employs armed security guards who are JISL’s full-time employees. JISL implements procedures for checking the past records of security personnel and the security personnel have clear objectives and permissible actions laid out founded on the respect for human rights. Further, JISL has agreed to modify and implement its existing procedures, within a timeframe agreed with IFC, so that armed security personnel are trained in avoidance of human rights violations and the use of fire arms to comply with IFC’s PS4. The Company will also evaluate adoption of the UK Voluntary Principles on the Use of Security Forces.
PS6:- Biodiversity Conservation and Sustainable Natural Resource Management
JISL has its own mango plantations, which account for around 10-12% of raw materials for its mango processing line. As per the PS6 requirement, these plantations are already certified for EurepGAP certification. Further, JISL is exploring possibility for other certifications such as Rainforest Alliance, Organic etc.
