Agrofertil has presented information on its current policies, procedures and practices that seek to address the potential impacts and to ensure that the proposed project will comply with the environmental and social requirements upon implementation of the specific agreed measures. The applicable social and environmental requirements are the Paraguayan laws and regulations, IFC’s Performance Standards, and the general WBG’s environmental, health and safety guidelines. The information about how these potential impacts will be addressed by Agrofertil is summarized in the paragraphs that follow. Additional actions are presented in the attached Environmental and Social Action Plan (ESAP).
Social and Environmental Assessment and Management System
-Social and Environmental Assessment: Agrofertil has presented to the Paraguayan authorities the required Basic Environmental Questionnaire (Cuestionario Ambiental Basico - CAB) and the Environmental Control Plans (Plan de Control Ambiental) for all its distribution centers and silos; and the company has obtained the respective licenses. Such plans and questionnaires define existing controls to mitigate potential environmental and occupational health and safety risks. The company provides reports and updates to the local regulators as defined in the granted permits.
All products distributed by Agrofertil, including fertilizers, seeds and agrochemicals have been approved by the Paraguayan authority SENAVE (Servicio Nacional de Calidad y Sanidad Vegetal y de Semillas). The transportation of products is also authorized by SENAVE and DINATRAN (Dirección Nacional de Transporte). Agrofertil reported to have all the licenses and permits required by local law up to date. Agrofertil do not develop new products, its role is limited to distribution of products already approved to be used in Paraguay.
-Social and Environmental Management Program: Agrofertil has policies and procedures to manage human resources, safe transportation of materials, emergency response, and environmental permits, among others. The company does not have a formal Social and Environmental Management program or system; however, Agrofertil has well defined responsibilities and monitor basic environmental and social elements as dictated by the Environmental Control Plans at each silo and distribution center.
-Organizational Capacity and Training: Environmental, occupational health and safety, and human resources elements are the responsibility of the Administrative Manager. Under his supervision, the E&S team includes a Coordinator for Legal Registries and Safety, a Chief for Security and Silos and an external Environmental Consultant. In addition, OHS and human resources responsibilities are shared with the local manager at each distribution center and silo. The company has relied on external experts to provide training on specific topics such as transport of hazardous materials and emergency response; however, the due diligence has identified that further OHS training at the silos will be required, in particular for confined spaces and electrical safety.
-Monitoring and Reporting:Agrofertil monitors basic environmental and social impacts according to the Environmental Control Plans presented to the local authorities. Operational controls and monitoring includes the use of fuels, verification of use of Personal Protective Equipment (PPE), presence of spills, extinguisher inspections and training programs. Agrofertil does periodic inspections through checklists to ensure proper environmental and safety conditions. The company has a tracking system for the status of the licenses and permits for the facilities and products distributed. Documentation and monitoring data were readily available during appraisal.
Labor and working conditions
-Human Resource Policy and Management: Agrofertil has a suitable code of ethics that covers key elements of PS2. The code makes explicit reference to issues such as non-discrimination and equal opportunity, grievance mechanisms to employees, protection of the workforce, and respect for human rights. The code is communicated to all employees. New employees receive a Human Resources folder (“Legajo de Recursos Humanos”) which contains: vision and mission of the company; code of ethics; internal workplace code; housekeeping policy; working contract in which wages, benefits and overtime compensation are described; roles and responsibilities; information on corporate social responsibility; and internal procedures among other documents.
-Terms of Employment: Agrofertil had a steady growth during the last years in number of employees, having currently 255 employees, who have a direct contract with Agrofertil. In addition, the company hires near 50 temporary employees during the harvest period to operate the silos. Conditions of employment are defined in the contracts and in the internal workplace code which are aligned with the local legislation. The minimum salary paid in Agrofertil is the legal minimum Paraguayan salary; the company has a defined salary scale by grade. Agrofertil does not hire workers under18 years as required by local Law. There is no evidence of child labor or forced labor in Agrofertil’s clients or suppliers. An informal grievance mechanism is in place, it will be formalized by Agrofertil at the corporate level to address and register workers grievances, and a dissemination plan of the grievance process will be developed.
-Workers Organizations: Agrofertil employees do not belong to workers organizations or unions, and there has not been such request among the employees. The management team of Agrofertil confirmed that they would not prevent employees to organize or participate in workers organization.
-Non-Discrimination and Equal Opportunity: Agrofertil has explicit codes regarding non-discrimination aspects on its operations; the company applies the principles of Equal Opportunity. There is no evidence of discrimination based on personal characteristics or gender; the female employees account for 13% of the workforce, this is mainly due to the characteristics of the agricultural sector. Fair treatment is observed in the company, including processes of hiring, promotion and termination of employment.
-Occupational Health and Safety: OHS controls are defined in the Environmental Control Plans presented to local authorities and enforced through periodic walkthroughs and inspection of the Chief for Security and Silos. The OHS program focuses on the safe handling, storage and transportation of the products, as well as on emergency response. The distribution centers are well designed with functional eye and body washers, containment kits, and natural and forced ventilation systems. Systematic use of PPE and control in the access to deposits and silos were observed. Silos are well maintained with proper housekeeping conditions. Agrofertil will implement proper controls and procedures to guarantee safe operation of the silos, including but not limited to confined spaces, dust control, work permits, fire drills and electrical safety.
Pollution Prevention and Abatement
-Resource Conservation and Energy Efficiency : Agrofertil’s activities are restricted to commercialization of products and grain collection; therefore, the use of natural resources is limited. The activities do not require water use, other than for sanitary purposes. The silos have drying operations only during the harvest season; therefore, silos operate five or six months during the year. The dryers use wood, which is purchased from authorized vendors with Paraguayan permits for commercialization of wood. Total annual use of wood is near 4,000 tons per year for all the operations. Agrofertil will ensure that all the wood used is supplied by authorized vendors. Agrofertil has been proactive on setting up its own reforestation areas to provide part of the wood in a sustainable manner. Electricity is used to force air into the silos to maintain the optimal temperature to ensure the integrity of the grains and for lighting purposes in all the facilities.
-Air Emissions: Air emissions are derived from the distribution fleet, vehicles used for sales purposes and dryers on the silos. The company renovates periodically the distribution fleet and the automobiles. Agrofertil has a preventive maintenance program to ensure proper operation of vehicles, including combustion processes and safety operation. The dryers use wood as fuel, are quite small (40-60 metric ton/hr), and operates only during the 5-6 months of the harvest period for 4-5 hours per day; no air emission control is required by Paraguayan law for the dryers or vehicles.
-Hazardous materials: Agrofertil stores and transports fertilizers and agrochemicals in compliance with local and international regulations. All products are approved by the local authorities (e.g. SENAVE) and have the Paraguayan permits required to import and distribute the products. The agrochemicals classified in the red zone, under Paraguayan law, require the prescription by an accredited agronomist, Agrofertil verifies that the clients buying the products have this prescription. Agrofertil provides technical support to the clients on the application of its products, in addition information is provided in the labels which are approved by local authorities.
Near 75% of agrochemicals sales of Agrofertil correspond to products containing active ingredients that are unlikely to present acute hazard in normal use (Class U) or are slightly hazardous (Class III); based on the classification of active pesticide ingredients from the World Health Organization. Currently, the company has in its portfolio one product Class Ib, which will be phased out. Agrofertil will eliminate stocks and distribution of any products containing WHO class Ia or Ib ingredients. For products with active ingredient class II, Agrofertil will review the technical and economic feasibility to replace them with less hazardous materials; considering alternatives such as cultural practices, biological, genetic, and as last resort chemical means. In case replacement is not feasible, Agrofertil will provide proper training to its clients on topics such as: facilities to handle and store the products, equipment and conditions of application, and disposal of residuals.
-Solid Waste Management: Agrofertil operations generates mainly domestic waste. Direct use of agrochemicals products is limited to the demonstrative parcels, where containers are tripled washed and punctured. Regarding the distributed agrochemicals, Agrofertil recommends and actively promotes the triple wash and puncture of containers. Agrofertil has been working with other partners in the agrochemicals sector to promote proper handling and container disposal. During appraisal, IFC team participated in an informative meeting organized by Agrofertil, targeting farmers and aimed to promote proper disposal of the containers.
-Greenhouse Gas Emissions: Greenhouse emissions of the operations are associated with electricity consumption, the use of wood for the dryers and fuel for the fleet used to distribute the products and for technical assistance. The Greenhouse emissions of the current operations have been estimated as 7,000 tons of CO2, most of which is derived from wood use; electricity contribution is minimal, due to its hydroelectric origin.
-Pesticide Use and Management: Agrofertil does not have direct application of pesticides, other than small demonstrative parcels. Technical assistance is provided by qualified professionals and includes a proper guidance in the use and application of the products. In addition, the clients usually have its own agronomists to advise them in the use of products. Elements such as registration, labeling, packaging, and storage were observed in accordance to international codes. The company will ensure compliance with the Food and Agriculture Organization’s International Code of Conduct on the distribution and Use of Pesticides or other good international industry practice. Agrofertil is aware of the trends and benefits of Integrated Pest Management and has in its portfolio some biological products and has been proactive on replazing hazardous pesticides with products containing less hazardous active ingredients. Agrofertil will identify ways to promote Integrated Pest Management among its clients.
Community health, safety and security
-Hazardous Materials Safety: Agrofertil stores and distributes the agrochemicals in accordance to local law, which requires proper authorizations and documentation of the products, deposits and vehicles. All distributed products are authorized by the local authorities, are labeled according to local requirements, indicating hazards, emergency contacts and proper disposal. In addition the company provides technical assistance on the proper application of the products. The distribution centers have been approved by SENAVE and have controls, such as drainages with collection tanks, eye and body washers, containment kits and fire suppression equipment. Access to the deposits is restricted to authorized personnel. Agrochemicals are only transported on enclosed vehicles authorized by DINATRAN (Direccion Nacional de Transporte Terrestre). All drivers have been trained and have the permit to transport hazardous materials.
-Emergency Preparedness and Response: Agrofertil has emergency manuals for the deposits and for the transportation of products. Training has been provided to the employees in the different distribution centers. All drivers are trained on management of emergencies and phone numbers are available to report events. In addition, the vehicles have a tracking and communication system that would facilitate response in case of emergency. Agrofertil will have periodic fire drills and will include hazardous materials safety and silos safety within the emergency drills.
-Security Personnel: Agrofertil contracts security guards through three different recognized security companies, the guards are armed. The security companies trains the employees to guarantee adequate use of the arms and follow up of the procedures. There have not been complaints or reports regarding abusive behavior or improper use of the arms.
Biodiversity Conservation and Sustainable Natural Resource Management
Agrofertil does not cultivate directly any crop aside from small areas are used as demonstrative parcels at some distribution centers. Near 65% of the direct clients of Agrofertil are farmers with areas greater than 200 ha, which by Paraguayan law are required to have environmental licenses and the supervision of an accredited Agronomist. Therefore, it is unlikely that the clients of Agrofertil would clear forest to set up crops.
Agrofertil follows Paraguayan legislation regarding distribution of seeds that are approved to local authorities and have the SENAVE approval.
