UKPF has presented plans to address the impacts of the project and to ensure that the existing and proposed operations will, upon implementation of the specific agreed measures, comply with the environmental and social requirements - the host country laws and regulations and the IFC environment and social Performance Standards and Environmental, Health and Safety Guidelines. Information about how these potential impacts will be addressed by the Company is described in the paragraphs that follow and ameliorative measures required to close observed gaps is incorporated into the attached Environmental and Social Action Plan (“ESAP”).
- PS1: Social and Environmental Assessment and Management System
UKPF is carrying out, on a regular basis, environmental, health and safety reviews in line with Kazakhstan legislative requirements. The company outsourced the preparation of an Environmental Impact Assessment Study in 2007, which has been reviewed and approved by the East Kazakhstan Oblast Territorial Department of Environmental Protection. The document defined the company’s main impacts on the environment, and established limits for air emissions, waste water effluents, and solid waste generation. UKPF’s performance against those limits is monitored quarterly, recorded in monitoring reports, and the company pays emission fees to the Oblast budget accordingly. With the commissioning of the new slaughterhouse and meat processing and packaging facility, UKPF will develop a new EIA and the Environmental and Social Management Plan (ESMP), which will incorporate the new plant and other changes that have occurred over the last 3 years. Furthermore, the Company will prepare an EIA document and ESMP for each new operation/facility it is going to launch, and will be maintaining this practice in the future.
In addition, UKPF will hire a full-time environmental officer to take over the duties for monitoring and managing the company’s environmental performance as compared to the EIA/ESMP and applicable IFC environmental, social and health and safety requirements. This officer will report to the director of the Technical Department, who is currently responsible for this area of work. The environmental officer will develop a corporate environmental policy, environmental management program and action plans, and other documents instrumental in managing the company’s environmental issues, will organize and carry out training on environmental issues, will ensure regular monitoring and reporting of the company’s environmental performance, and will, in general, systematize the work on improving UKPF’s social and environmental performance.
The Company has steadily grown in recent years. Since its first engagement with IFC a year ago, the Company has developed a Hazard Analysis and Critical Control Points (HACCP) program and received ISO 22000:2006 certification (for quality assurance and food safety management system) for the production of commercial, stock and incubation eggs, one-day chickens, poultry feeds, poultry meat and processed products (valid through February 16, 2013). The company has also received ISO 9001:2009 certification for its quality management system (valid through February 16, 2013). The Company obtained Halal certification in May 2009. The Company will maintain and further develop it present food safety management system to reduce risks or adverse impacts from its operations on local communities and to limit the impact of any allegations of adulterated food distribution.
This year the company plans to compete for the Altyn Sapa award – a national state award based on Food Quality Management (FQM); and later to obtain the internationally recognized FQM. In the future, the Company would like to obtain certification with OHSAS 18000 and ISO 14000.
- PS2: Labor and Working Conditions
Human Resource Management: UKPF has approximately 780 staff, of which 40% are women. As the Company is expanding, it is not anticipated to have any redundancies in the near future, and should potentially increase its staff to approximately 1,000 employees within the next 2-3 years. Of the 780 employees, 140 are members of the trade union. The current salary structure consists of base salaries which are double the local minimum wage, as defined by law, for both administrative and productive functions; matches average wages in the area; and includes social security contributions. All workers are paid for overtime; however, there is a limit of overtime hours that can be worked per week. The Company budgets for additional expenses on employees’ training, meals, transportation and medical services, and pays for accommodation for select production staff recruited to work for the Company from other regions of Kazakhstan.
Labor management tools are being progressively developed to facilitate labor relations and workforce flexibility. The company’s HR department is adequately structured and staffed following a re-organization as part of last year’s efforts for ISO 9001 certification. As part of this effort, many new documents and procedures that govern HR work were prepared. The procedures cover recruitment and hiring, discipline, compensation, promotion, access to training, retirement, and termination. UKPF has standard templates for labor contracts for both permanent and seasonal workers. The management confirmed that the employee and management relationship is conducted in compliance with Kazakhstan laws. The last State Labor Inspection was carried out in March 2010, which did not reveal any serious violations of Kazakhstan labor law.
The company’s management is well aware of IFC requirements in terms of non-discrimination and equal opportunities and protection of the workforce, including child labor, and confirmed that they are complying with these requirements and Kazakhstan laws, and that they are willing to develop further these tools during project implementation.
HR documents and procedures are available to staff upon request, but are very detailed and might be difficult for workers’ comprehension. Therefore, the Company will develop an HR Policy Statement which sets out its approach to managing employees in a manner consistent with the requirements of national legislation and IFC Performance Standards. The Policy Statement will be clear and understandable to employees and will be explained or made accessible to each employee upon taking employment.
Grievance mechanism: The Company implements a simple grievance mechanism for workers to raise reasonable workplace concerns. HR is responsible for anaging grievances, the Company adopts an open door policy and employees can directly raise concerns to their managers. The company has committed to develop a formal employees’ grievance mechanism. External worker protection mechanisms are ensured by national labor laws.
Workers’ Organizations: The Company has a trade union, which is a part of the Trade Union of Workers of Small and Medium Sized Business of East Kazakhstan Oblast. Membership in the trade union is voluntary. The Collective agreement, dated September 23, 2005, is available and signed by the UKPF general director, the chairperson of UKPF trade union, the state labor inspector and registered in the Trade Union of Workers of Small and Medium Sized Business of East Kazakhstan Oblast. The Collective agreement is annually revised and the additional agreements are attached.
Retrenchment: Due to the decommissioning of the old slaughtering plant and building and launching of the new plant, UKPF transferred and laid off workers last year, implementing a retrenchment plan in accordance with national law requirements and in consultation with the worker representatives.
Occupational Health and Safety: According to the Kazakhstan labor law, the company is obliged to perform risk assessment and certification of all working places for occupational health and safety, make third party liability insurance agreements with an insurance company for all its workers, have an OHS unit/officer in its organizational structure, provide all workers with personal protection equipment, ensure healthy and safe working environment according to the requirements, conduct regular OHS training, organize medical examinations, ensure good quality food and milk supply for workers, and pay damage reimbursement in the case of damage to workers’ health or life. The company maintains the OHS system to ensure its compliance with the requirements, and fulfillment of those requirements is periodically checked by the Labor Inspectorate as part of planned regular inspections or against complaints filed by workers, if any.
The company’s management is committed to playing a responsible role in protecting the health and safety of the workforce, providing them with appropriate and compliant working conditions and terms of employment, and in protecting the environment.
Last year, UKPF hired a new Occupational Health and Safety (OHS) manager to oversee occupational safety, fire safety and emergency response procedures, who has since established a functioning system to ensure proper workplace monitoring and implement all appropriate management procedures. The OHS manager interacts with municipal authorities on OHS, fire safety and emergency response issues; organizes fire safety trainings and drills; develops and updates OHS instructions and carries out induction and regular OHS training for UKPF’s workers; develops action plans and reports on OHS, fire safety and emergency response. All management staff is periodically sent to OHS training organized by pertinent government agencies. Fire safety training is organized on the company’s premises by external trainers. UKPF has an agreement with a medical hospital located in a nearby village to perform medical examinations of UKPF staff. Additionally, the Company employs a part time medical nurse, who examines drivers and workers upon arrival at the facility. The OHS officer develops annual action plans to address OHS and fire safety issues.
The total recordable accident rates and the total lost time accident rates are recorded. Accident investigations are performed both internally and externally and documented accordingly. A basic emergency plan to respond to major accidents is in place. Drills are conducted with the assistance of external government bodies, and included in the action plan. Fire detection and alarm systems are installed in the plants, and are being currently tested and serviced/replaced. Fire drills are conducted.
The OHS officer is scheduled to leave her position in May 2010; however, UKPF will ensure that human and technical resources are consistently allocated to manage OHS and fire safety issues, and the agreement with the external medical center is maintained until the recruitment of a suitable replacement. The new OHS officer will facilitate the completion of risk assessment and the certification of the new Slaughterhouse and Meat Processing and Packaging Facility and will maintain the standards set by the risk assessment and certification of working places in other poultry operations to make sure that the workers have a safe and healthy working environment, and all poultry sector specific risks are accounted and sufficiently mitigated. The OHS engineer will continuously monitor OHS and fire safety risk management.
- PS3: Pollution Prevention and Abatement
Poultry operations include a feed mill, a parent stock farm, a hatchery, five broiler farms, a slaughtering and meat cutting and packaging plant, and a bone flour production (rendering) plant. In addition, the company has auxiliary services – one large boiler (which serves the nearby village as well), and two smaller boilers to supply heat and hot water; a water well with a chlorination station to supply water to the nearby village and the facility; a wastewater treatment facility, which services the village and the farm; metal works shops; vehicle garage and maintenance shops; fuel station; and laundry.
The main sources of emissions to the environment and the risk of environmental contamination emanate from the liquid effluents, organic waste, accumulation of ash, air emissions (mainly from coal fired boilers), and solid waste. Other point sources of emissions include a feed mill (dust), maintenance shops, a vehicle fleet, and a rendering plant.
Waste management. The Company’s waste comes from processing and consumption. The processing waste includes chicken manure, ash, and sludge from a waste water treatment facility, metal scrap, car batteries, tires, used oils, and sawdust. With the addition of sunflower to the feed, the sunflower husks would be added to the waste stream. However, those would be used for bedding material, and then disposed of according to the established practices for disposal of manure and bedding material. Organic waste from the feed mill, broilers, the slaughterhouse and meat processing are utilized at the Company’s rendering plant. General waste includes used fluorescent lamps, waste from laboratories, food waste from the kitchen, and solid waste.
Total generated waste is 33,560 tons on average, including 735 kg of fluorescent lamps, 780 kg of car batteries, 8.2 tons of used oil, 27,516 tons of manure, 180.7 tons of sludge, 5545.4 tons of ash, 78 tons of metal scrap, 251.4 tons of solid waste, 5.8 tons of tires, 12.5 tons of sawdust.
Management of solid waste. Solid waste generated by the Company is essentially plastic packaging waste from the meat processing and packaging facility, kitchen waste, used gloves, masks and other PPEs, old uniforms, laboratories, and paper and other waste from the administration building. Waste management practices observed are not appropriate. The Company acknowledges the situation, and signed a contract in March with a waste collection company to transport waste to an authorized landfill managed by the municipality. UKPF explained that the last winter was very harsh with a lot of snow that blocked the roads and made it difficult to carry the waste out to an appropriate place. The Company is going to clean up the area from waste and is committed to regular and proper waste management from now on. To avoid the repetition of the situation of last winter the Company will examine opportunities for waste reduction at source and waste compressing and proper storing options for longer periods in case of emergencies. The Company will conduct training for employees on waste management and good practices (including avoiding waste burning) and will carefully monitor the waste management implementation.
Special categories of waste. The Company has on-going contracts with external parties for utilization of fluorescent lamps and car batteries, and has allocated special places to keep those types of waste before it is picked-up. The Company will maintain those contracts, and make sure they are regularly updated in a timely manner. Used oil is utilized internally for lubricating various machines and mechanisms at the garage and car maintenance facility and mechanical workshops. Used oil is stored and handled appropriately. There is no special waste management practice established for the medical waste and waste from laboratories. The Company previously burned it in a special furnace; however, this practice was banned by the state ecological department, and UKPF was fined. Therefore, the Company committed to set up a special medical and laboratory waste management program.
Utilization of organic waste from broiler rearing and slaughterhouse operations. Deep bedding is used for broiler rearing, suing sawdust and straw. Average annual generation of chicken manure and bedding is approximately 27,516 tons. To remove the manure and bedding waste, the rearing houses are first scrapped and then flashed with cold water using high pressure, low flow nozzles. The waste is then transported to a storage place. The Company has a special storage place designed to store manure and waste water sludge, which is located 2 km from the nearest water stream, 3.5 km from the nearest residential area, and has a waterproof bottom and sides. The storage occupies 8 hectares, and is designed to hold 97,500 m3 of waste. The storage basin has high earth walls to prevent penetration of rain and melting water into the soil.
However, currently the Company is not using the location, but rather stores manure on the ground near the storage location. Such improper manure storage practices may pose a potential risk of contamination to surface or groundwater resources through leaching and runoff. The Company acknowledges the problem and is prepared to deal with it. At a minimum, the Company will relocate the manure from the ground to the available special storage. The Company will also provide the manure to local farmers either for a price or for free, and develop a plan with the local farmers to regularly move the manure. Next, the Company will develop a plan/project to compost company’s residues, i.e. chicken manure, bedding material, and wastewater sludge.
Processing waste of the feed mill and the slaughterhouse and processing and packaging plant along with poultry carcasses, waste eggs and other organic waste is rendered in the Company’s facility and returned to the feed mill for incorporation into animal feed. The Company has not encountered situations when it needed to utilize any infected carcasses as the primary poultry mortality cause was physical weakness. The Company stated that should such a need emerge, it would have to burn the carcasses in incinerators, where it currently burns medical waste. However, as waste burning practice was banned by the environmental authorities, the Company is going to develop an alternative procedure within its medical waste treatment systems.
Utilization of ash accumulating from coal burning in boilers. The Company currently uses coal as a primary source of heat production to satisfy the needs of poultry rearing. The Company has one large thermal plant, which services the Company’s broiler rearing operations and supplies heat and hot water to its other facilities and the nearby village, and two smaller boiler houses, which supply heat to the parent stock. Coal burning produces ash, which the Company stores inside its facility. Annual accumulation of ash is approximately 5,545.4 tons. A special ash dump, which covers 3 hectares, is organized near the boiler house which is located 1.5 km from the nearest residential area, and 3.4 km from water bodies. The Company has all the necessary approval documents from the local environmental agency to operate the ash dump, as well as an approved plan for its reclamation. Clayey soils form the basis of the ash dump, which prevents soil subsidence and slaking. The ash dump is open, and dust rises during both processing and storing of ash. Nevertheless, ash from the boilers is presently not handled appropriately. The ash is not transported from the area around boiler houses to the ash dump, but is stored right at the boiler house. Another ash dump was formed at a place, which has not been studied for its appropriateness to hold ash. Storing of ash in inappropriate places might impact underground and surface waters through releasing such pollutants as zinc, copper, lead, nickel, cobalt, sulfates, chlorides, and solid residues, as well as negatively affecting air quality in the vicinity. The Company used to sell ash to construction companies before, but after the recent crisis in construction business that practice stopped and the ash must be dealt with differently. The Company acknowledges the problem and will put efforts to collect and transport the ash to the ash dump, and reclaim the areas under the ash, putting soil and planting vegetation on top, and providing for a leachate collection system, according to the rehabilitation plan approved with the local environmental authority. The Company will also continue selling the ash to construction companies. The Company will conduct energy efficiency audit with IFC Energy Efficiency Unit, and develop a plan for energy efficiency. Then, the Company will decommission two small boilers connecting the parent stock rearing facilities, supplied with heat from the boilers to the main power plant or finding another source of energy for the facilities as the Energy Efficiency Audit might suggest, to improve the ash handling and storage practice and OHS conditions for company’s workers.
Management of liquid effluents. Sewage from the facility goes into the wastewater collection and treatment system managed by the Company. The Company’s waste water treatment facilities are designed to provide for the full biological treatment of waste water from production and non-production areas and the village of Molodejnyi. According to the EIA Study (2007), the design capacity of waste water treatment facilities is to treat 245 m3/hour, and the capacity is utilized for around 50%. Treatment facilities include 2 horizontal sand traps with circulating water, 4 primary two-level sedimentation pools, 11 biological oxidation ponds, 8 irrigation sewage disposals, 2 grit dewatering bays, sludge drying beds, and a system of pumps to move water from one treatment stage to another. Clarified wastewater after mechanical treatment is pumped to biological oxidation ponds and then to irrigation sewage disposal fields. After self-treatment during the re-aeration process in oxidation ponds, wastewaters in the irrigation system are precipitated to the sewage disposal fields, where perennial grasses grow. Wastewaters are accumulated in biological oxidation ponds during 6 months (November – April), and are pumped to irrigation disposals during May-October. The sedimentation tanks, sand traps and ponds are emptied and cleaned regularly and the sludge and sand is put in special fields to dry and then transported to a special storage (where chicken manure is stored too). UKPF does not use antibiotics or growth hormones, so effluents are not very polluted. The Company is trying to negotiate with the local government to take the waste water treatment facility over. If there is an agreement, UKPF might construct its own pre-treatment facility in accordance with its wastewater characterization and volume. In the meantime the Company will maintain operational design of its current wastewater treatment facility, perform all necessary maintenance and improvement works, and monitor waste water parameters in accordance with EIA requirements. The Company will also undertake measures to build its internal on-site waste water pre-treatment facilities. As part of the measures the Company will develop a project design and a feasibility study for the pre-treatment facilities, and include the project into Company’s investment plan to get prepared to the time, when the current waste water treatment facility would be handed over to the local government.
Wastewater samples are taken regularly and at several locations to monitor their quality. Measurements taken in 2009 show that the Company is in compliance with IFC requirements for effluent levels for poultry production for the parameters measured, such as pH, BOD5, COD, total nitrogen, total phosphorus, and total suspended solids (oil and grease, temperature and total coliform bacteria are not measured). The Company has agreed to undertake periodic analysis of wastewater samples taken from the site, to monitor their quality, and ensure that they meet the applicable discharge requirements and IFC guidelines. In addition, the Company is going to maintain and improve its waste water treatment facilities, and has provided for it in its investment plan. The Company also commits to revise and reduce water consumption and separate run-off waters from the wastewater stream by building a run-off water collection system.
Air emissions. Electricity to meet the Company’s demands is supplied from the national grid. Energy consumption in 2009 was 23,088,587 kWh. In addition, the Company has three coal-fired boiler houses to supply heat to the farm, as well as to the village nearby. Annual consumption of coal is 38,150 tons on average. One large boiler house supplies heat to both the village and the farm, it is equipped with a conveyor belt to feed the coal into the boilers. Two other boiler houses are manually fed and supply heat to parent stock rearing facilities only. Different types of filters and de-dusting cyclones are used to reduce air emissions. Air quality is monitored regularly in accordance with the parameters established in the EIA Study. The two smaller facilities are old, and the Company will decommission them connecting the parent stock rearing facilities to the main boiler house or finding another source of energy for the facilities as the Energy Efficiency Audit, which the Company plans to accomplish, might suggest, to improve the ash handling and storage practice and OHS conditions for company’s workers.
Other point sources of air emissions are the feed mill, rendering plant and maintenance facilities. The feed mill is equipped with 16 exhaust units, each of which has dust collectors. Stack filters are used as well. The dust emissions are monitored regularly against permissible parameters identified in the EIA. The rendering plant has 4 vacuum evaporating kettles with barometric condensers (3 operational and 1 back-up). During thermal vacuum treatment of waste organic materials, they emit a large quantity of water vapors with organic content, and then in barometric condensers those are cooled, washed with water and condensed. Non-condensed vapors are emitted into the atmosphere along with the bone meal dust through the deflector hood located at a height of 8 m. Limits for emissions are set up in the EIA and regularly monitored. Maintenance facilities emissions are also accounted for; each source of emission is monitored accordingly.
The Company will monitor air emissions from the boiler houses, a feed mill, a rendering plant, maintenance shops and other point sources to make sure they comply with the levels set up in EIA, with IFC guidelines parameter limits and will reduce them, as needed.
Water supply for chicken rearing and processing. All Company operations rely on ground water to meet facility needs. Existing water wells have been constructed to avoid contamination. Aquifers have been evaluated carefully to ensure uninterrupted supplies of water for both poultry operations, and village needs. The Company operates 7 water wells, 2 water reservoirs and a chlorination station. Total water consumption of the Company is around 2,217.3 thousand m3/year with 1,754.3 thousand m3/year for production and 463 thousand m3/year for household needs. The water is sufficiently cleaned and monitored to ensure its steady and safe supply for Company’s needs. Water quality is regularly monitored by the State Sanitary and Epidemiological Department.
The Company will ensure adequate operation of its potable water supply system at the current level, providing for all necessary maintenance work. UKPF will conduct water usage audit and attempt to recycle water. The Company will monitor water quality (chemical parameters once/year; all other bacteriological, chlorine or other disinfectants on a daily basis) and report. The Company will put efforts to negotiate an operation contract for local government to take the facility over, and insert quality assurance (QA) monitoring into the contract.
- PS4: Community Health, Safety and Security
Community Health, Safety and Security: UKPF operations are not expected to exacerbate community exposure to diseases since most facilities are located away from populated areas and far from any established social gathering places. Animals are controlled every day against diseases by the company veterinarian. Broilers are vaccinated according to the plan. Microbiological, allergy, heavy metals, pesticides, antibiotics and Salmonella analyses are performed for finished product. Traceability and recall tools have been developed within HACCP.
Potential interactions with third parties and local communities are limited to safe driving during transport of raw material, products and waste outside the Company’s area and managing food safety programs, which is done in accordance with HACCP developed and implemented by the Company. UKPF will maintain HACCP and ISO 22000 certification and continuously improve its performance in food safety and bio-safety.
Emergency Preparedness and Response: UKPF has developed a formal emergency response plan in line with PS requirements. The plan covers possible emergency situations, which could arise as a result of decompression of ammonia equipment in the meat processing and packaging plant, depressurization of cylinders with chlorine in the water supply unit, depressurization of cylinders with propane and the spill of sulfuric acid used in car batteries in maintenance facilities. The plan provides for monitoring of equipment operability and regular maintenance, training for maintenance staff and safety training for everyone, and coordinated activities with the inspecting organization and fire fighting and emergency response departments in the area. A fire safety procedure is available at the facilities. Smoke detectors, fire alarms and fire extinguishers are available and properly maintained at regular intervals. Fire extinguisher use training is provided to all workers during regular trainings carried out by a professional subcontracted company. In an emergency, UKPF can call the fire fighting department which has its own equipment. The Company is insured against fire, environmental and other accidents from a local insurance provider. The Company is committed to maintaining emergency response equipment, and procedures to identify potential emergency situations (including life and fire safety), to respond to emergencies and to mitigate any resulting safety, health and environmental impacts.
Security Personnel Requirements: The Company outsources security services from the private security firm SALANG. The firm is licensed by state authorities to provide security services; its officers are both armed and have permission to carry arms, which is renewed on an annual basis. Security manager assured us that the officers are trained to handle any accidents with workers or the community in a friendly way, and there have not been any serious accidents in the past.