The Company has presented plans to address the E&S issues and 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 relevant 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.
PS 1: Social and Environmental Assessment and Management System
IFC’s assessment considered Apollo SA’s management of its EHS performance in the establishment and operation of its facilities; compliance with national and local permit requirements; and Apollo SA’s engagement with local communities as well as its suppliers, regarding EHS performance. - Environmental & Social Assessment:
Since the proposed Project does not constitute a listed activity under South African National Environmental Management Act 1998, Apollo SA was exempted by Department of Agriculture, Environment Affairs and Rural Development, KwaZulu Natal from undertaking a formal Environmental Impact Assessment of its construction and operations. However, Apollo SA was required to submit an Environmental Management Plan (EMP) as part of the regulatory approval process.
- Management Systems:
Apollo SA has articulated Safety, Health, Environment and Quality (SHEQ) policy in its operations in South Africa. Both Durban and Ladysmith facilities have environmental management systems certified compliant with ISO14001 requirements, Occupational Health and Safety Management Systems conforming to OHSAS 18001 standard and ISO/TS16949:2009 (quality management system standard for automotive industry).
- Organization:
Both Durban and Ladysmith facilities have full-time dedicated teams in place to manage the EHS related issues, with their well defined roles and responsibilities as articulated in the EMS.
Monitoring & Reporting:
Apollo SA has a comprehensive and well documented monitoring program for the EHS aspects of their operations, in line with the regulatory requirements and Apollo SA’s EMS. Regular monitoring of effluents, stack emissions, workplace (heat stress, noise and illumination), microbiological swab testing is carried out for both the facilities and reported to the regulatory authorities.
In addition, specific water and energy consumption are regularly monitored and reports are submitted to the corporate office in India for group-wide benchmarking.
Apollo SA’s monitoring program is consistent with various IFC requirements. The review of monitoring records confirms Apollo SA’s material compliance with IFC’s relevant EHS guidelines. In case of occasional minor non-compliances, corrective actions plans were planned and implemented.
PS 2: Labor and Working Conditions
Apollo SA’s Durban facility employs approx 760 employees, while Ladysmith facility employs over 860 employees – comprising workers and management staff. Woman employees constitute approx. 15% of total workforce. Apollo SA hires very few temporary or casual workers, just to make up for absentees and any specific temporary requirement. This is also in line with the agreement with labor unions at each facility.
- Human Resource Policy, Management
Apollo SA’s HR manual articulates guiding principles, policies and operational procedures – which are in line with Apollo’s corporate policies and practices and South African labor law requirements. These are implemented across both the facilities by dedicated HR teams at each site.
The HR manual specifies the types and terms of employment, service conditions including procedures for hiring, probation, compensation and benefits, training, performance review, promotion, leave and vacation, etc. which are consistent with the national labor laws. The terms of employment and other details about the HR policies are communicated to the employees through a formal appointment letter. HR manual also includes code of business conduct, employment equity policy, grievance mechanism, disciplinary code and corrective action procedure, sexual harassment and whistle blowing policy.
Trade unions for the workmen exist at both the facilities of Apollo SA. As per the prevailing practice in South Africa, collective negotiation of wages takes place at industry level by all the unions every three years and the agreed wage levels are then binding upon all the tyre manufacturers in South Africa.
- Training and Human Resources Development
In line with Apollo’s corporate policy, Apollo SA has an extensive human resource development process and training calendar for its employees, which is managed by a dedicated team in the HR department.
Several structured training programs are developed for different levels of employees and covers behavioral/ leadership aspects as well as technical/functional training.
In addition to the EHS induction training (mandatory for all employees), the training modules range from basic soft skills such as computer skills, basic mathematics, problem solving, business finance, to specific workplace and safety related trainings such as safe operations of forklift/hoist/crane, ergonomics, process waste recycling, waste separation and disposal etc. Awareness training on ISO14001, OHSAS18001 management systems as well as training in standard operational procedures (SOPs) is also provided.
In line with the group practice, advanced leadership development programs are conducted by Apollo Laureate Academy for its managerial staff in collaboration with leading academic institutions in the country.
- Occupational Health and Safety
Apollo SA has put in place elaborate safety management system at its facilities. Safety management at each site is modeled on European standards and requirements.
Dedicated safety managers supported by safety teams are appointed at each facility. To ensure effective safety management at each site, with participation of its workforce, Apollo SA has entered into formal agreement with workers unions at each site for developing safety committees and safety stewards at each facility.
Safety monitoring is regularly conducted which includes monthly PPE audit, workplace monitoring of noise levels, illumination etc. Apollo SA records all the lost time incidents and even those requiring only first-aid. Accordingly, all injuries frequency for Durban facility is 12/200,000 hours (comprising even first aid cases as well as lost time incidents). There have been no fatalities at either of the facilities.
Fire detection and suppression equipment is fitted across the facility in accordance with the potential fire risks. This includes smoke detectors, an alarm readable in the central control room, sirens, PA system, fire extinguishers, fire hydrants as well as sprinkler system. Fire exits and the locations of fire extinguishers are clearly marked. In addition to Apollo SA’s own Fire Safety Officers and trained teams at each site, regular external review of systems is conducted by an external consultant. A formal process is in place for managing findings of this external review.
Strict safety requirements are imposed on the contractors, following European style statutory requirements. An elaborate checklist is used in screening the potential contractors on safety aspects. Upon award of contract, the contractors are required to supply a safety plan and assign adequate resources for its implementation. For the ongoing construction work at Ladysmith facility for the Project, the contract required the construction contractor to appoint a safety manager at the site.
- On-site Emergency Response Plan:
Based on the Hazard Identification of Risk Analysis (HIRA), on-site emergency response plans have been developed for both the facilities by respective safety officers. Accordingly, potentially hazardous areas have been identified and evacuation routes and assembly points have been designated and clearly marked. Regular mock drills are conducted to ensure the emergency preparedness and emergency plans are improved based on the outcomes of the mock drills.
PS3: Pollution Prevention and Abatement
IFC’s assessment considered the Company’s operations with regard to resources consumption (water, energy, fuel), efforts to optimize resource inputs, waste minimization and management practices as well as the storage, handling hazardous materials used in the construction and operations of facilities.
The first step of radial tyre manufacturing processes is compounding and mixing elastomers, carbon black, and other chemicals such as vulcanizing agents, accelerators, plasticizers, and initiators. The mixture is extruded between pairs of large rollers to prepare it for the feed mill. As a result of the extrusion process, tread, sidewall and liner materials are prepared. The fabric and steel cord are coated with rubber. Bead wires are then processed and coated with rubber in extrusion process, followed by cutting and cooling of the various extruded and rubber-coated outputs. All the components (bead wires, coated fabrics, treads, etc.) are assembled on a tire-building machine, which is the followed by curing process, where the tyre undergoes heat and pressure treatment, before the final product is ready for final testing.
Tyre manufacturing process does not result in high volumes of wastewater. The air emissions from tyre manufacturing operations consist of dust from mixing processes, fume from vulcanization and emissions of combustion products from the steam boilers. The solid waste generated during the manufacturing process includes: non-vulcanized rubber waste, scrap rubber tyres, domestic / office solid waste and other waste such as packaging material, empty oil drums etc.
- Pollution Prevention and Resource Conservation:
Pollution prevention and resource conservation has been an important focus for Apollo group and thus, Apollo SA. Energy savings and sustainable water use are being adopted in the designs of new facilities and are further reduced in a systematic manner through continual improvements.
For instance, for the upcoming Project at Ladysmith facility, energy efficient design review was carried out. Accordingly, a few of the feasible items that were implemented include: design changes for maximizing natural lighting, proper Insulation of building (to optimize heat load), and enhanced natural ventilation through side louvers and roof vents. Further, a detailed action plan with clear targets for reduction in energy and water consumption has been developed and teams have been constituted for implementing the action plan.
In addition, key process parameters – such as Steam usage (kg steam/kg product), Electricity Usage (kWh/kg), Water usage (l/kg) - are regularly monitored, documented and internally reported at corporate level.
- Water Supply and Effluent:
The daily water consumption for Apollo SA’s Durban and Ladysmith facilities is approx. 700-800 cu.m each. The raw water is supplied by the local municipality. The process as well as domestic wastewater is discharged in the municipal sewers as per the environmental permit conditions.
- Solid and Hazardous Waste:
Apollo SA complies with all relevant regulations for the storage, handling and disposal of hazardous materials used in the production process. The notified hazardous wastes are disposed of through licensed waste management contractors, as per the regulatory authorizations.
Adequate controls during the storage and handling are in place and the quantities of solid waste thus generated and disposed of are regularly monitored and documented.
- Energy Sources and GHG Emissions:
In Durban, the primary energy source is electricity, which is procured from the national grid. The steam required for process is produced from an electrical boiler – with FDO boiler as backup.
For Ladysmith facility, the electricity required for the process is procured from the national grid, while steam is produced in the coal-fired boilers.
As the Project in Ladysmith involves improvements in productivity and production efficiency, after its implementation, while the production would increase by 30%, no substantial increase in energy consumption is expected.
The total GHG footprint of the project is expected to be around 140,000 t CO2eq/year.
- Air Emissions
Dust emissions from the process will be mitigated and controlled through ventilation and filtration systems. Solvent fume (Volatile Organic Compound) emissions will be negligible due to minimized use of solvents. Fugitive emissions from tyre vulcanization will be limited. However, because there are no permanent residential areas within the vicinity of both the plants, this will not cause significant nuisance to local population.
The main sources of air emissions are the process areas and coal fired boiler in Ladysmith. Adequate air pollution control equipment for controlling the air emissions from boiler sets has been provided for process emissions control, which meets the IFC’s relevant EHS Guidelines with regard to air emissions.
With the help of external agencies Apollo SA regularly monitors the stack emissions– from process as well as boiler – to ensure compliance with local requirements, and takes any corrective actions, as needed.
PS4:– Community Health, Safety and Security
The Durban site is located in the city of Durban, but in a primarily industrial neighborhood near the port. Ladysmith facility is spread on a large plot of land in an industrial area. As such, both the facilities are far away from the nearby residential communities and are well connected by wide roads. Hence the impact of vehicular movement on surrounding communities is expected to be minimal.
While the impacts on the nearby communities due to Apollo SA operations are expected to be minimal, all the facilities have developed detailed emergency response plans for their respective operations.
The Company contracts with a nationally certified security agency for 24 hour surveillance of the facility, with unarmed security guards.
On the basis of the above information, it is concluded that the Project has been designed and will be operated in compliance with IFC’s PS and relevant environmental, health and safety guidelines.
