Key issues include environmental, health and safety management; labor and working conditions during construction and operation; maintenance dredging and dredge spoil disposal; storm-water management; liquid, solid and hazardous waste disposal; oil/hazardous materials storage and handling; handling and storage of dangerous cargoes; ship support operations such as sewage disposal, bilge waste effluent; fueling services and spill response; employee health, safety and training programs during construction and operation; and emergency response planning and preparedness (all of were assessed in the context of the first investment), in addition to assessing the process of acquiring land for the CFS and ICD.
Environmental, Health, Safety and Social Management
In accordance with requirements established by the Pakistan Environmental Protection Agency (EPA), the Company retained an independent consultant in 2010 to conduct an Initial Environmental Examination (IEE) for the ICD. The IEE report assessed environmental and social impacts during both construction and operation of the proposed expansion, and proposed mitigation measures to address these, along with an Environmental Management Plant (EMP) to manage and monitor impact mitigation activities. An IEE was not required for the CFS.
From an operational perspective, QICT complies with the Safety & Environment Policy of its majority shareholder, DP World, which is committed to “providing a safe workplace and ensuring that all business activities are conducted in a manner that minimizes any adverse environmental impact.” QICT’s existing operations are carried out in accordance with a corporate environmental management system based on this Policy, which has been certified against ISO 14001; and an occupational health and safety management system certified against OHSAS 18001. ISO certifications were originally obtained from Lloyd's Register Quality Assurance (LRQA) in 2006 and were renewed in 2009 by DNV. The same system has been adopted at the CFS and ICD. Both the Policy and the monitoring and performance standards established by DP World under the auspices of the Policy are substantively comparable to the applicable IFC PSs.
QICT has a full-time Safety and Environment manager, responsible for safety and environmental matters at all QICT operations, who supervises a team of Safety and Environment Officers and reports directly to senior management. Management and supervisory staff in each business unit are responsible for implementing and maintaining the safety and environmental management systems necessary to comply with this Safety & Environment Policy, and are held accountable for compliance and performance, which is reported quarterly to QICT’s senior management team. A key element of its Safety and Environment management systems is a detailed set of emergency response procedures, operational manuals and emergency checklists. All employees and contract workers are trained on these management systems at the time of hiring, with mandatory annual refresher courses.
Labor and Working Conditions
QICT currently has 490 employees working over two shifts. Non-essential functions (catering, office cleaning, routine equipment maintenance) are contracted out. Security personnel are employed by QICT directly, and are on duty 24 hours a day, 7 days a week. QICT’s Human Resources (HR) department oversees all aspects of employee recruiting, hiring, training, evaluation, remuneration and promotion, in conformance with DP World’s corporate HR policies. These conform to the relevant requirements of IFC’s PS2, 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.
As required by DP World policy, QICT has an established Health, Safety and Environment (HSE) program to ensure workplace safety of all employees, including pre-employment and regular medical evaluations, provision of personal protective equipment (PPE), and regular training in workplace hazards, safe work procedures, and emergency response activities. DP World reviews its corporate HSE policies on an annual basis in order to improve the workplace environment at all of its facilities. QICT’s S&E Manager coordinates an interdepartmental Safety Committee to review practices and performance on a monthly basis. Policies and supporting documentation (i.e., a detailed health and safety manual) were provided to IFC during the site visit. EHS performance is tracked monthly by monitoring and reporting lost time injury frequency rates (LTIFRs) against annual targets set by DP World. Pakistan labor law incorporates all major International Labor Organization (ILO) treaties. QICT complies with all national laws and regulations, including those relating to employment of minors. The minimum age of employees at all its operations is 18 years of age, including contractor employees and casual workers. QICT’s security staff check the national identity cards of workers entering any QICT premises to verify that they are at least 18 years old. Lost time injury (LTI) rates for 2009 and 2010 were 0.4 and 0.2 respectively.
HSE performance during construction of the ICD is being managed jointly by QICT and its main construction contractor, M/S The Technologist. The HSE team holds weekly project progress meetings, including a thorough review of HSE performance, which, to date, has been strong. M/S The Technologist currently employs no construction workers: at the peak these numbered 8. The LTI rate during construction to date has been 0.
Pollution Prevention and Abatement
Electricity demand for normal terminal operations is 5400 kVA, sourced from the Karachi Electric Supply Company (KESC), whose thermal power plants operate largely on high speed diesel oil, with some recently added gas-fired generation capacity. KESC also supplies power to the CFS facility. QICT has standby diesel generators for use during interruptions to the KESC grid; these are used infrequently and usually for short durations. Electricity for the Lahore ICD during both construction and operation is being sourced from the Lahore Water and Power Development Authority (WPDA) grid, with use of standby diesel gensets in the event of supply interruptions.
Water for port operations and for the CFS is provided by the Karachi Water and Sewerage Board (KW&SB); QICT filters and treats incoming KW&SB water to provide adequate supplies of potable water. Water supplies for the ICD, largely for domestic uses, during both construction and operation activities are drawn from the WPDA system, with filtering and treatment to ensure sufficient potable supplies. QICT monitors both electricity and water consumption and provides these figures to IFC annually. The Company has in place ongoing programs to identify energy efficiency opportunities. As the CFS & ICD have just started operations, power and water consumption data will be provided in the next AMR submitted to IFC.
Routine maintenance dredging of the port and harbor is the responsibility of the Port Qasim Authority (PQA), which operates a fleet of dredgers and barges for this purpose. PQA is also responsible for vessel support operations involving bilge and other ship-generated wastewaters and wastes management, and relies on licensed contractors to provide these services to vessels. QICT has acquired a purpose-built spill container trailer to enable it to segregate and control material from leaking containers, which are then disposed of by a licensed waste disposal contractor. Because maintenance activities conducted at the terminal are minimal, only small amounts of hazardous materials (paints, solvents, lubricants) are stored and handled in the workshop areas. Fuel tanks for QICT’s standby generators and for vehicle refueling have appropriate containment features to prevent spills from being released to the environment. Ship fueling facilities are managed by PQA. Domestic wastewater is treated in septic tanks to meet applicable Pakistan laws and regulations prior to discharge. Sludge from septic tanks is removed periodically and disposed of by a licensed waste removal contractor. QICT stores 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 are transferred to and stored in designated container sheds separated from QICT's main container storage yard.
Fuel tanks for QICT’s standby generators and vehicle refueling have appropriate containment features to prevent spills from being released to the environment. Domestic wastewater is treated in septic tanks to meet applicable Pakistan laws and regulations prior to discharge. Sludge from septic tanks is removed periodically and disposed of by a licensed waste removal contractor. QICT stores 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 are transferred to and stored in designated container sheds separated from QICT's main container storage yard.
PQA provides 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. The equipment that PQA employs includes specially provisioned ships, skimmers, and oil containment booms. QICT coordinates with PQA for responding to incidents that occur on the terminal property. QICT has its own emergency plans and procedures and the necessary equipment for preventing and combating oil and chemical spills and fires and major accidents during terminal operation, including coordination with PQA fire and spill response brigades. Over the last several years, QICT has experienced only minor incidents – equipment fires, small oil and chemical spills – all of which were properly responded to, documented and investigated. QICT's emergency response program includes appropriate personnel training in emergency response for all employees, quarterly fire drills, and joint exercises with the local fire brigade. The same approach to life and fire safety and emergency response has been adopted for the new ICD and CFS facilities.
Community Health, Safety and Security
The QICT container terminal and CFS are situated within the Port Qasim footprint, which in turn is located in the industrial zone of Western Port Qasim. There are no residential areas in the vicinity. The industrial and commercial entities located closest to the container terminal include a KESC thermal power station, PQA facilities and storage areas, and a privately-owned steel manufacturing plant. QICT’s security and emergency response efforts take into account the proximity of other facilities and are structured and implemented to ensure that its premises and normal activities do not pose a risk to any of its neighbors. QICT participates in a forum of private sector companies with terminal operations within Port Qasim, including the Essar Bulk Terminal Ltd. (EBTL), Fauji Akbar Portia (FAP) grain storage terminal, Liquefied Cargo Terminal, ProGas Pakistan LPG terminal, Fauji Oil Terminal (FOTCO) oil handling facility, Pakistan International Container Terminal (PICT and Pakistan Steel. The forum shares information and resources on shared issues such as security and emergency response best practice, and is available to provide backup support to each other’s facilities and to PQA in the event of a large scale emergency or security incident.
In regard to the Lahore ICD, most potential adverse community health, safety or security issues are limited and confined largely to the construction period. The area surrounding the ICD development has very few residential inhabitants, as the land is used primarily for agricultural purposes. The ICD is served by a newly-constructed 3 km access road leading from the main road to the overall lCD developments (see section below on Land Acquisition for a complete discussion of these developments). The new access road parallels both a rail spur and an existing rural road, and was purposely constructed to ensure that traffic associated with the ICD developments did not impact local traffic. Nevertheless, QICT will monitor traffic on the ICD access road and, if necessary, will coordinate with PR and local inhabitants to ensure that traffic on the access road does not pose a safety risk or negatively impact local residential or commercial activities.
Land Acquisition and Involuntary Resettlement
The only land acquisition that occurred in the context of this project was the sourcing of land for the ICD. The total land requirement was 140 acres that include two separate depots (one of which will be operated by QICT and the second by another private company), a Pakistan Customs office that will be utilized by both operators, and a road spur connecting the ICDs/Customs office with the main road. The new road parallels (to the south) the rail spur by which containers will be transported to the ICDs. An existing road, used by local inhabitants, parallels the rail spur on the opposite (north) side.
Of the total land requirement, 48 acres were already in the possession of PR. The balance of 110 acres was acquired by PR through the Revenue Department of District Kasur. The acquired land had been used for agricultural purposes, and the only structures on it were temporary dwellings for livestock. The Revenue Department determined the land price based on a pre-determined formula, which was designed to ensure that a fair market price was paid. QICT has provided written documentation that no involuntary displacement, either physical or economic, has occurred as a result of land acquisition for the new Lahore operations.
