UABL has ESHS policies, plans, and procedures (ESHS Management System - SMS) which are coherent with good international industry practices and commensurate to the potential impacts and risk. The company has plans, procedures, and a team of professionals to address environmental and social impacts to ensure that the proposed project will comply with the applicable national laws and regulations and with IFC’s Social and Environmental Performance Standards. The following sections summarize how these potential impacts and risks will be addressed by the Company, as well as the Environmental, Social and Health and Safety Action Plan (ESAP) agreed with the IFC to close any pending compliance gaps.
PS1: Social and Environmental Assessment and Management System:
UABL mainly transports soy products, iron ore, petroleum products, vegetable oils, cement, fertilizer, and flour.
On-shore facilities on the Paraná River include: Tres Fronteras and Dos Fronteras Ports in Paraguay, and the Wanda Port, Pueblo Esther Shipyard, and Puerto Martins Shipyard in Argentina.
As of June 30, 2011 UABL operated a fleet of 621 barges and 33 pushboats. Over the last five years, and as part of IFC previous investments, UABL has continued to upgrade and renew its fleet. On December 15, 2009, the Company additionally inaugurated a barge-building shipyard at Punta Alvear, Argentina to inject new transport capacity into the Hidrovia. In 2010, a total of 13 new barges were purchased, 52 barges were re-bottomed, and 10 new engines were delivered and will be progressively installed until end of 2012.
The company has an ESHS Management System (SMS) consistent with the voluntary standards of conduct established for the Responsible Carrier Program (RCP) by the American Waterways Organization (AWO), which cover terminals, shipyards, and river operations. This SMS includes environmental and health and safety policies, occupational health and safety procedures, training, safety of fleet operations, waste management, dangerous cargo handling (e.g. flammable materials), emergency response, and maintenance and repairs. Additionally, to the extent applicable to inland river transportation and as enacted by the operation’s host country, the SMS also covers IMO standards such as the ISM Code, SOLAS, MARPOL, the Code of Safe Practice for Cargo Stowage and Securing (CSS Code), and the Code of Safe Practice for Solid Bulk Cargoes (BC Code).
As part of the environmental licensing process for each terminal and shipyard UABL has prepared environmental impact assessments and corresponding management plans. These plans include provisions for waste management, occupational health and safety, and spill control measures, among others. The development or operation of the terminals and shipyards do not require dredging. UABL’s operations are continually supervised by Argentinean and Paraguayan authorities. The SMS was approved by the Argentinean Coast Guards until 2013. Additionally, barges and terminals carrying hydrocarbons and grains undergo inspections by oil and agribusiness clients to ensure compliance with their own ESHS, food safety, and cargo handling specifications.
UABL has an ESHS organization with a total of three full time professionals. In addition, the company relies on external expertise to cover specific environmental and safety issues on an as needed basis.
ESHS performance is monitored through the company’s general internal control process and reports are produced annually. Non-conformities and accidents are investigated and corrected, as necessary. Senior management reviews performance results annually and ensures that appropriate adjustments to procedures are made.
As part of the agreed ESAP, UABL will (i) enhance organizational structure commensurate to the continued increase in operations and in-line with industry practices, and (ii) integrate quality, environmental, social and health and safety procedures into a complete Integrated QESHS management System.
PS2: Labor and Working Conditions:
At the time of appraisal, UABL had a total of 505 employees, 480 males and 24 females; 406 on-board and 98 land base.
UABL has a Human Resources (HR) policy in place that is consistent with Argentinean and Paraguayan labor laws and, in general, aligned with IFC’s PS2. The Company’s HR policy includes requirements for employee training, health benefits, safe work environment, non-discrimination, freedom of association and equal opportunity. In addition, it must be noted that UABL’s SMS takes into consideration ILO Convention 147 on shipboard labor practices and the Standards of Training, Certification & Watch-keeping (STCW) for on-board crew, to the extent they are applicable to inland river transportation. In order to improve its HR policy, as part of the agreed ESAP, UABL will develop an Internal Grievance Redress Mechanism for all its employees.
The greatest emphasis of UABL’s SMS is on occupational health and safety and risk management, and thus extensive procedures have been developed and are currently being implemented. The SMS manual includes an occupational health and safety policy, as well as operational priorities and safety rules, based on risk-per-task approach, continuous training, and use of appropriate personal protection equipment. Additionally, contractors are required to show risk insurance covering their employees in UABL’s service, provide personal protection equipment (PPE) and follow UABL’s ESHS procedures in accordance as required for the service being performed.
Training on SMS procedures and environmental safety and accident and emergency control is intense and continuous. In 2010 alone, a total 185 crew members were trained. Additionally, a 10-day induction course is also provided to all new crew members.
PS3: Pollution Prevention and Abatement:
Fuel is UABL’s largest operating expense, and the proposed investment will improve the environmental footprint per ton-mile transported.
For instance, the engine replacement project and fleet renewal process covered by IFC’s previous and currently proposed investment, has helped replaced existing EMD Marine Gas Oil (MGO) engines for more efficient MAN Diesel A/S Intermediate Fuel Oil (IFO) engines, reducing UABL’s fuel consumption by an estimated 18% per year accompanied by a reduction of carbon dioxide emissions (CO2). Up to the June 30, 2011 and since its commencement, the engine replacement project is estimated to have generated a reduction of Greenhouse Gases (GHG) of approximately 935 tons of CO2. In addition, newer engines allow the ships to run 25% more quickly cutting down substantially on overall in-river transit time. Furthermore, the push boats with the new engines can handle 42 barge tows versus the standard 30 or 36 barge tow (@ 27% more cargo), which generates an estimated fleet-wide fuel saving 6-8%.
According to the technical specifications of the new engines, they are expected to comply with IMO’s emission standards for nitrogen oxides (NOx). The company will ensure use of low sulfur fuel oil which will also maintain sulfur oxides (SOx) emissions within IMO standards. Emissions of Particulate Matter (PM) from the new and re-engineered engines are expected to marginally increase, but this minor drawback is out-weighed by the improvement in engine efficiency and overall positive environmental footprint.
The lube system for the new engines incorporates a built-in automatic back flushing lubrication oil filter, which eliminates the need for paper filter elements that require special waste management treatment.
Slop and wastewater from vessels and shore-based repair facility waste are processed by certified third parties following national and MARPOL requirements as applicable to inland river transportation. The company has also implemented a waste segregation and recycling program for its terminals and shipyards facilities. Oil and hydrocarbon storage tanks at oil terminals are appropriately placed on second containment areas to avoid spill risks. Cleaning and disinfection procedures for storage facilities and machinery at grain handling terminals are conducted by trained staff using safe cleaning products only.
River transportation on the Paraná-Paraguay River System is regulated by an international Treaty signed by Argentina, Bolivia, Brazil, Paraguay and Uruguay. The Treaty includes specific provisions for oil spill prevention and international response coordination; vessel and cargo safety inspections; and waste management, among others. The company has Contingency and Emergency Response Plan approved by the Argentinean Coast Guard. Additionally, UABL has prepared health and safety risk assessments and corresponding contingency plans for each terminal and shipyard as part of the SMS and required for the International Ship and Port Facility Security (ISPS) Code certification. UABL has also implemented Emergency Response Committees (ERC) in all its facilities and conducts periodic drills for spill and fire control in conjunction with the relevant local government agency. Additional spill response training is provided in coordination with the Argentinean Coast Guard’s Environmental Division. Each UABL push-boat carries the appropriate inventory of oil spill response equipment and materials. In case of a significant spill the Coast Guard, or relevant country authority, will coordinate a response using equipment from facilities in closest proximity.
For 2010, UABL reported a total of 4 accidents with 354 lost-work days, 4 minor spills and 5 vehicle collisions were reported. Incidence Rate for 2010 was 100.9 (based in 100,000 MH).
PS4: Community Health, Safety and Security:
UABL has identified safety as the top priority. The SMS ensures a safe work environment for its employees and surrounding communities. The company has invested in a computerized navigation system that enables to continuously map on real time the safest routes and marks the channel with electronic buoys. This technology is supported by pilot and captain training in convoy simulators at the Center for Marine Education (Kentucky, USA).
Impacts on communities are expected to be minimal. One potentially significant project impact is related to increased short-distance truck traffic generated by increased operations. As part of the ESAP, UABL will update the existing traffic plans for all its on-shore facilities to cover measures such as driver training, speed limitations, limiting hours of facility operation, installation of cross-walks, signage, communication with communities and installation of traffic calming devices to help prevent accidents.
