The key issues associated with Gulftainer’s port and inland logistics facilities include corporate capacity to assess and manage the impacts and risks of its operations; labor policies and performance during construction and operation; maintenance dredging and dredge spoil disposal; liquid, solid and hazardous waste disposal; oil/hazardous materials storage and handling; handling and storage of dangerous cargoes; ship support operations, fueling services and spill response; employee health, safety and training programs; and emergency response planning and preparedness. Gulftainer’s plans for managing these environmental and social risks and impacts are summarized below.
Environmental, Health, Safety and Social Management
Gulftainer has confirmed that it complies in full with all host country laws and regulations related to the screening, assessment management and monitoring of environmental impacts of its facilities. Most of the operations that Gulftainer is developing as part of the proposed Project will be undertaken within existing facilities, such as the new cargo handling facility based in Sulaymaniya Airport in northern Iraq and operation and management of container and cargo berths awarded to Gulftainer at Umm Qasr Port. Where greenfield developments are planned – such as the Energy Service Centre (ESC), Gulftainer Logistics Services (GLS) and Gulfmar Solutions operations at Sulaymaniya Airport - Gulftainer will undertake environmental and social assessments in compliance with the regulations of the Kurdistan Regional Government (KRG), which require baseline land surveys, environmental impact studies, assessment of community environmental and social concerns, and compliance with building regulations. These assessments will be carried out by qualified consultants against the requirements of both host country regulations and IFC’s PSs. Gulftainer has committed to implementing all ESIA recommendations in full. Copies of clearances and permits from national and municipal government authorities will be provided to IFC, as outlined in the attached Environmental and Social Action Plan (ESAP).
Site visits carried out during the appraisal confirmed that Gulftainer has basic health, safety and environment (HSE) and community engagement programs in place at its two operations in the UAE, and that its performance at both facilities has been good. The Company has developed a number of standard operating procedures (SOPs) for its UAE facilities that cover all aspects of its operations. A key element of its SOPs is a detailed set of emergency response procedures, operational manuals and emergency checklists. All employees, contractors and contract workers are trained on these management systems at the time of hiring, with mandatory annual refresher courses. A review of Gulftainer’s incident and accident reporting statistics confirmed that these facilities have maintained strong environmental performance and safety records. The appraisal also indicated, however, that the Company does not have an integrated health and safety, environment and social (HSES) management system at the corporate level that is being consistently implemented at each of its operations. Gulftainer recognizes that development and implementation of such a system is important, given the Company’s current and proposed expansion plans. As a condition of IFC’s investment, the Company will formalize its HSES practices and requirements into a formal management system that ensures compliance with Company policies, host country laws and regulations, and IFC’s Performance Standards (PSs). The Company has already identified third party consultants, who are acceptable to IFC, to carry out the work. The HSES management system will include specific policies and procedures to assess and manage all relevant functions, including any functions that are outsourced as well as all relevant issues covered in PS2 through PS4, such as resources and waste management, accident prevention, occupational health, safety and welfare of the workforce including contract labor; and community health and safety. Gulftainer intends to develop an HSES management system in line with ISO 14001 and OHSAS 18001, and to obtain these certifications in due course. Gulftainer will utilize DNV as the certifying authority for the drafted management system.
To ensure consistent implementation of the HSES management systems and procedures at all of Gulftainer’s facilities, the Company will appoint a corporate HSES Manager, responsible for implementing, monitoring and reporting to Gulftainer’s senior management on HSES issues. In addition, the Company will designate an HSES coordinator at each of its operations, who will have a reporting line to the HSES Manager. Gulftainer has also agreed to develop and implement a corporate training program for all staff to raise awareness on HSES issues and ensure consistent implementation of the HSES management system across all of its operations. The HSES Manager and Coordinators will oversee the ongoing training of all employees in the HSES system and procedures.
Labor and Working Conditions
Gulftainer expects to employ approximately 700 full time staff once all of the proposed facilities in Iraq are fully operational. Gulftainer has no plans to use contractors to carry out any of its core activities, although some non-core functions (office cleaning, routine equipment maintenance) may be contracted out. Armed security personnel, where they are required or permitted, will be contracted out, due to local regulations requiring such companies to be licensed to carry weapons. Where not required, or otherwise not permitted, armed security will be replaced by unarmed guards in which case they may be either contracted out or directly employed, depending upon particular requirements. Security will be provided 24 hours a day, 7 days a week. Gulftainer has confirmed that it complies with all applicable host country labor laws and regulations in all of the countries in which it has operations. In addition, company policy requires that no employee below the legal employment age - or age of 18, whichever is older- may be hired. Gulftainer’s Human Resources (HR) department oversees all aspects of employee recruiting, hiring, training, evaluation, remuneration and promotion, in conformance with its corporate HR policies and practices. These conform broadly to good industry practice and IFC’s PS2. The Company is in the process of consolidating these practices into a comprehensive HR manual that will apply to all Gulftainer operations. As part of this process, Gulftainer’s labor policies will be modified to explicitly reference the key PS2 principles, including establishing, maintaining and improving employee-management relations; allowing for the formation of worker’s organizations if these are desired by its employees; promoting fair treatment, non-discrimination and equal opportunity of workers; ensuring compliance with national labor and employment laws; promoting safe and healthy working conditions; protecting and promoting the health of workers; and establishing a mechanism that allows employee grievances to be articulated and addressed, as and when they may occur. The Iraqi government has not established minimum wage requirements, but Gulftainer has confirmed that, as is its practice in all of the countries in which it operates, its wage scales are in excess of market standards for all labor categories.
With the exception of the ESC and GLS developments, which will require a construction workforce of approximately 200, the construction crews for the other facilities will be small (50 workers or fewer) and will be sourced primarily from nearby communities, as required by regulations of the respective Government labor departments. As a result, the Company will not be required to provide accommodation during the construction phase, as laborers will be lodged in their own residences. The HSES management system will ensure that all construction contracts and subcontracts include necessary clauses to ensure that no contractors’ employee is below the legal employment age, and that construction activities are carried out in accordance with Gulftainer’s HSES procedures.
At its existing facilities in the UAE, Gulftainer’s General Manager chairs an interdepartmental Safety Committee to review practices and performance on a monthly basis. The same practice will be implemented at the Iraq facilities, during both construction and operation. HSE performance during construction will be managed jointly by Gulftainer and the construction management contractor. During construction, the HSE team will hold weekly project progress meetings, including a review of HSE performance. HSE manuals will be translated into Arabic and/or Kurdish as appropriate and made available to all construction workers. Gulftainer will ensure that training is provided for all on-site workers, including truck drivers, and that construction contractors provide all requisite PPE to their workers.
Pollution Prevention and Abatement
Gulftainer will initially obtain power for the Iraqi operations from diesel generators, especially during construction, but eventually all of the facilities will be connected to the grid. During construction, the Company will utilize tankers to provide water but, again, all facilities eventually will be connected to the municipal water mains. Gulftainer will treat and filter incoming water if needed to provide sufficient potable supplies for staff. As part of its HSES management program, Gulftainer will monitor electricity and water consumption, in order to identify energy efficiency and water conservation opportunities.
Routine maintenance dredging of ports and harbors is typically the responsibility of the relevant port authority. At the Umm Qasr Port, these functions are the responsibility of the General Council for the Ports of Iraq (GCPI), which is more commonly known as IPA. IPA is also responsible for vessel support operations involving bilge and other ship-generated wastewaters and wastes management, in some cases relying on licensed contractors to provide these services to vessels. Ship fueling facilities are managed by the Iraqi Marine Transportation Company (IMTC). Although Gulftainer’s operations at Umm Qasr will initially be limited to one berth, these will be managed in accordance with the same SOPs and controls used in its larger operations in the UAE. Only small amounts of hazardous materials (paints, solvents, lubricants) will be held on site, and these will be stored and handled in accordance with best industry practice. Fuel tanks for standby generators and vehicle refueling will be fitted with appropriate containment features to prevent spills from being released to the environment. Gulftainer will subsequently operate two further berths in Umm Qasr North Port, which will be known as Iraq Container Terminal, and will maintain the criteria as indicated above at these new berths.
Domestic wastewater at each of Gulftainer’s facilities in Iraq will be discharged to the existing relevant municipal and port sewerage system. Sludge from septic tanks, if any are used in future, will be removed periodically and disposed of by a licensed waste removal contractor. Gulftainer will store containers in accordance with International Maritime Organization (IMO) conventions to prevent potentially dangerous combinations of goods coming into contact with one another. Customer-identified IMO dangerous and hazardous containers will be transferred to and stored in designated container sheds separated from Gulftainer''s main container storage yard.
Small increase in ambient particulates from construction activities at any of the new facilities are to be expected, primarily dust emissions from vehicle movement and excavation activities. Gulftainer will ensure that its contractors provide appropriate PPE to workers in high dust areas, and use water tankers to control dust if needed. Wastes from construction (iron cuttings, scrap metal, oil and oily soak cotton waste, wood, rubble, cardboard, etc.) will be recycled, where possible, sold to vendors or disposed of in designated landfills.
Community Health, Safety and Security
Gulftainer has confirmed that, at Umm Qasr Port, IPA will provide port-wide fire-fighting and emergency response services consistent with international maritime conventions (MARPOL 73/78). Services include harbor oil spill response and clean-up, harbor water quality monitoring, vessel surveillance and inspection, and fire fighting. As it does at its port operations in the UAE and elsewhere, Gulftainer will coordinate with IPA in responding to incidents that occur on the terminal property. Similarly, for the Gulfmar Solutions operations at Sulaymaniya Airport, the airport authorities will provide fire safety and emergency response services. Gulftainer will coordinate its own efforts with airport authorities, including carrying out jointly-sponsored and staffed fire and emergency response training and drills.
For its other operations in Iraq, Gulftainer will apply its own emergency plans and procedures and the necessary equipment for preventing and containing oil and chemical spills, fires and major accidents during normal operations. Over the last several years, Gulftainer has experienced only minor incidents – equipment fires, small oil and chemical spills – at its operations in the UAE and elsewhere, all of which were properly responded to, documented and investigated. The Company’s emergency response program includes appropriate personnel training in emergency response for all employees, quarterly fire drills, and joint exercises with local fire brigades.
Land Acquisition and Involuntary Resettlement
Gulftainer has confirmed that most of the land acquired for the proposed developments was purchased on a willing buyer-willing seller basis. The sole exception to this was 425,000 m2 (42.5 hectares) for the ESC and GLS developments is northern Iraq, which was obtained from the Board of Investment of the Kurdistan Regional Government. The land, which was government owned, has been utilized informally in recent years by local farmers for cultivation and storage purposes. The Board of Investment and Ministry of Agriculture entered into negotiations with the committee representing affected farmers. The parties have recently agreed on a compensation price to be made to the Government of Kurdistan to affected farmers. Gulftainer will provide documentation confirming that the affected farmers have received the agreed-upon compensation payments prior to disbursement of IFC’s investment, for the ESC & GLS developments.
