PS1: Social and Environmental Assessment and Management Systems:
TTS S.A (TTS) itself is a freight forwarding company with 46 employees working in Bucharest. Its operations are conducted by TTS subsidiaries consisting of the following major ones:
- C.N.F.R. Navrom S.A. Galati (“Navrom”, 81% owned by TTS) with 964 employees, providing mainly Danube river transport (navigation / barging services), and other relevant operations (ship maintenance, ship building, ferry and passenger services);
- TTS Operator S.A. Constanta (86% owned by TTS) with 154 employees, providing port operations at Constanta Port;
- Canopus Star Constanta (“Canopus”, 51% owned by TTS) with 7 employees, providing grain handling and storage, transshipping at Constanta Port;
- Trans Europa Port S.A. Galati (“TEP”, 51% owned by TTS) with 144 employees, providing port operations at Galati, Braila, Turnu Severin Ports.
TTS has a written corporate policy indicating management’s commitment to navigation safety and the protection of the environment in the conduct of their shipping activities. Objectives include compliance with relevant safety and environmental protection rules governing river transport and related activities in Romania and on the Danube River. The Group has defined and established an organizational structure with the appropriate responsibility and authority to manage EHS matters. Employees are trained at several levels to ensure they have the knowledge and skills to perform their work consistent with TTS safety and environmental policy and objectives. There are written operating procedures covering navigation safety, environmental protection and employee health and safety, and performance is monitored through a system of periodic inspections and internal audits. Non-conformities and accidents are investigated and corrected, as necessary. Senior management reviews performance results annually and ensures that appropriate adjustments are made.
Furthermore, TTS issued an “Ethic Code Guidelines” approved by its Board in 2008. This is a set of principles ruling its business operations in respect of the principles of integrating management system, quality service policy, environmental policy, occupational health and safety, and development directions of TTS integrated system of policies. As described below, TTS’s subsidiaries are implementing their EHS management systems appropriate to the nature and scope of each operation. TTS, as a main shareholder of each subsidiary company, is influencing subsidiaries’ EHS programs for improvements by using its voting right in the shareholders’ meetings, and through direct / indirect discussions and analyses with management of the subsidiaries. TTS is keen to strengthen TTS Group-wide EHS management system (e.g. group-wide EHS policy, group-wide internal auditing and reporting framework, group-wide EHS committee, group-wide communication on EHS aspect to external interested parties). This is listed as one of the actions in the Environmental and Social Action Plan (ESAP) agreed between TTS and IFC (ESAP PS1-1).
Navrom has a well-established EHS management system based on applicable Danube Commission and Romanian requirements. Navrom’s Quality Department and Safety of Navigation Department are in charge of managing EHS performance. As a leading river transport company operating in Danube River, Navrom has been making efforts to improve its management systems. Navrom was certified by ISO 9001/2008 (quality management) in December 2010, and in the process of obtaining certifications on ISO 14001/2005 (environmental management) and OHSAS 18001/2008 (occupational health and safety). Navrom’s latest corporate policy statement about integrated management of quality, environmental protection and occupational health and safety (signed by General Director on May 22, 2011) describes measures to achieve continuous improvement of river transport activities. Some of the key measures include providing top quality services designed to meet the customers’ expectations, establishing good relationship with customers, suppliers and concerned third parties aiming to improve quality of provided services, implementation of integrated management system based on competence and awareness of staff and compliance with relevant policies regarding quality, environmental protection, and occupational health and safety, providing all employees with the needed support and training, mandating department managers and heads of operational divisions to provide their staff with adequate assistance to fulfill Navrom’s objectives and tasks in the EHS fields.
Navrom has a ship repair and maintenance yard at Galati Port. Due to its inherently difficult working conditions and industrial hazard potential, Navrom started to improve its EHS management system early and in 2010, their shipyard was certified under ISO 9001(quality management), 14001 (environmental management) and 18001 (health and safety management). Based on IFC’s visit to the ship repair and maintenance yard in September 2011, there are areas for further improvement in industrial safety management. This is discussed further under PS2.
TEP conducts port operation, storage of goods including fertilizers, and conditioning and storage of cereals (corn, sunflower seeds, barley, soybean). TEP has a dedicated environmental, health and safety manager and has established environmental management systems. Their major focused areas are water pollution, soil contamination, health and safety, and food safety. Trans Europa is certified for ISO 9001:2008 (quality management), ISO 14001: 2004 (environmental management), BS OHSAS 18001: 2007 (health and safety management), and ISO 22000: 2005 (food safety management system), all certified on December 30, 2010, valid until December 29, 2013. Their relevant corporate policy statements (environment, occupational health and safety, quality management, and food safety) are posted at various facilities of the company. The latest food safety audit report conducted by an external auditor (TUV Nord) in 2011 concludes that: TEP’s food safety management system is done in accordance with ISO 22000: 2005; TEP’s food safety management system is based on the HACCP (Hazard Analysis Critical Control Points) principles, the HACCP team members working in the system have the necessary professional competence; and both in-house and external trainings are provided. The local branch of the Ministry of Environment carries out regular inspections and they take samples of soil and noise. No major non-compliance has been reported.
TTS Operator has a dedicated EHS officer providing training programs, managing procurement and preparing for ISO 14001 and OHSAS 18001 certifications targeted in 2013. TTS Operator’s quality management system was ISO 9001 certified in 2007 by Bureau Veritas. TTS Operator is implementing operations in line with various operating permits and procedures (e.g. risk evaluation procedures, prevention of explosion, fire extinguisher, crane operations). Accidents are reported, recorded and investigated. Safety equipment as well as training programs are provided adequately to workers.
Canopus’s Technical Manager in charge of EHS issues. In line with good international industry practice, and specific corporate environmental policy and requirements of Cargill, an international producer and marketer of food and agricultural products and owning 30% of Canopus, Canopus has established various EHS policies and procedures, including HACCP (Hazard Analysis Critical Control Points) practices.
PS2: Labor and Working Conditions:
TTS and its subsidiaries currently employ over 1,300 employees, of which about 960 are directly involved in river barging / sailing activities. Those companies’ human resources policies and procedures are consistent with Romanian labor legislation and IFC PS2 requirements. Addressing the principals of non-discrimination and equal opportunity, the policies are reflected in the collective work agreements registered and enforced by the Ministry of Labor. The agreements cover the obligations of the employer and employee, including: working conditions and labor protection, wages and other salary rights, holidays and time off, disciplinary procedures, individual contracts of employment, professional development, and social protection. No retrenchment is contemplated.
TTS and its subsidiaries have active occupational health and safety programs designed to comply with Romanian workplace regulations and ensure the safety of their crews and workers. The programs include a set of specific safety and health procedures for ship, shore-based activities, grain handling and storage, and port operations. Personnel are provided with appropriate personal protective equipment, and participate in extensive health and safety training programs covering fire fighting, hazardous work activities, life saving, and medical first aid. Sailors and shore staff undergo periodic medical examinations. TTS and its subsidiaries and the Romanian regulatory authorities both conduct regular inspections of the ships and the repair yard to ensure all health and safety requirements and procedures are being properly followed. Job related accidents and incidents are investigated to prevent reoccurrence. In 2008, Navrom reported two fatalities of sailors due to accidental drowning. Navrom investigated the events and took measures to prevent them from happening again. In 2009 and 2010, no serious incidents were reported by Navrom. In 2010, there was one fatality at TEP (a worker fell into Danube River and drowned), and a corrective action was implemented. TTS Operator also reported a fatality in 2008. As a holding company, TTS will continue to monitor health and safety performance of subsidiaries and provide technical, financial and managerial guidance towards improvement in this area.
As described under PS1, Navrom has a ship maintenance and repair yard at Galati Port. Although the yard is OHSAS 18001 (occupational health and safety management) certified, there are still areas for further improvement in the safety management. Areas for improvement identified during IFC’s visit in September 2011 include more safety warning signage, minimization of industrial hazards such as secure routing of gas fuel tubes for welding work, better working conditions for workers. TTS will work with Navrom to identify areas for further improvement so that the shipyard working conditions become safer and healthier. This is included in one of the actions in the ESAP (ESAP PS2-1).
TEP, one of TTS’s major subsidiaries, uses small number of prisoners (normally 10 people per day) at Galati operation sent from a nearby prison. This was arranged by a mutual agreement on a voluntary basis, between TEP, the jail, and the prisoners so that prisoners can have additional savings before they are released. They also get reduced detention days since one day of work is counted as 2 days of detention. This is not considered forced labor under IFC PS2.
TEP’s old silo constructed in 1891 at Galati has safety areas for further improvement (e.g. fixing manhole gratings, better working environment in terms of dust exposure). TTS will work with TEP to identify areas for improvement and jointly implement identified areas. This is listed as ESAP PS2-2.
PS3: Pollution Prevention and Abatement
Navrom ships are designed and operated to meet Romanian safety and pollution control requirements, as well as the international marine safety standards of the IMO. Vessels are equipped with tanks and containers for storing ship-generated wastes and effluents – domestic wastes, maintenance waste and oils, bilge waters, sanitary wastewaters, recyclable plastics, metals and glass. When accumulated, segregated wastes are separately delivered to authorized port collection centers or specialized ships for treatment and disposal. In between carrying certain cargos, barges are cleaned by licensed contractors and the wastes generated during cleaning are properly disposed by these parties.
Navrom has all necessary certificates to permit operation of its ships and barges with regard to safety and environmental protection. The ships are periodically inspected by Romanian navigation authorities for compliance with safety and environmental requirements in accordance with approved schedules.
All the Navrom ships requiring fuel are equipped with secondary containment around the fueling connection area, and associated spill collection tanks. In addition, all vessels have the requisite oil spill clean-up equipment and absorbent material on board to control spills. To meet EU requirements, sulfur content of fuel used for ships is limited maximum 0.1% or less.
With the exception of diesel fuels and some fertilizers, the principal cargoes that the TTS Group transports are not considered hazardous or dangerous. Heavy Fuel Oil used to be transported by Navrom but not anymore. In accordance with IMO, the Danube commission recommendations, and Romanian requirements, vessels engaged in the transport of oil have plans and procedures in place for handling and storage of the material, as well as responding to emergencies, such as collisions, grounding, fire, and spills. In addition, these ships are suitably equipped with fire/spill prevention and emergency response equipment and supplies on board in the event of any accident. Crews are trained in fire fighting and hazardous cargo handling and emergency response, and provided with appropriate personal protective equipment. Training includes both class room training and emergency drills. As appropriate and depending on the size and location of a spill, the Group coordinates with, and often relies upon, the spill response resources of the ports in which it operates. As required by law, these ports have sufficient oil / chemical emergency response plans, procedures and equipment.
The Group has not experienced any oil spills or emergencies involving hazardous cargoes within the last three years.
As mentioned under PS1 and 2 above, Navrom operates a ship repair and maintenance yard at the Galati port that services the technical and maintenance needs of their river vessels (Navrom Reparatii, a subsidiary of Navrom). Activities include:
- dry-docking repairs of ship hulls, pipelines and propulsion and steering systems;
- cleaning (i.e. sandblasting) and painting of hulls and superstructures; and
- mechanical equipment maintenance (repairs of deck machinery and engine room equipment).
Ship repair necessarily involves the storage and handling of hazardous materials, like paints, solvents, and oils. Repair activities also generate effluents, emissions, and waste-waste particles from shot blasting, metal scrap, paint wastes, spent solvents, waste oils, discarded containers, other paint contaminated materials, waste scrap, and sludges. Wastes and hazardous materials are managed to avoid contaminating the environment and potentially harming the health of workers and local residents. Wastes are collected, temporarily stored, and delivered to specialized, licensed waste management contractors serving the entire port area. There is no evidence that historical operating practices at the repair yard contributed to subsurface contamination of the properties or sediments of the adjacent water bodies. Wash waters and storm water contaminated with solids will be treated for the removal of these materials prior to discharge to the Danube consistent with the regulatory requirements.
Fugitive dust emissions generated by grain terminal operations are to be controlled by the state-of-the-art ventilation systems and filters consistent with EU standards. During the site visit at Canopus Star Constanta in September 2011, IFC was informed that out of in total 60 dust removal systems installed, some dust collecting filters were not used due to some technical problems. TTS will ensure that these are properly fixed. This is included in the ESAP PS3-1.
GHG emissions: Navrom has a well-established tracking of fuel consumption and efficiency of their river ships, and associated GHG emissions. In 2010, Navrom has consumed 17,029 ton of diesel fuel oil for ships, equivalent to 55,664 ton CO2. Navrom’s overall corporate average fuel efficiency of river ships has significantly improved over the last several years. In 2005, Navrom consumed 16,754 ton of diesel to transport 5,574,414 Kilati (an indicator to measure amount of cargo and distance of transport, adjusted by barge size and river coefficiency, developed for Danube River), with corporate average efficiency of 3.01 kg fuel / Kilati. In 2010, Navrom consumed 17,029 ton of diesel to transport 7,676,630 Kilati, with corporate average efficiency of 2.22 kg fuel / Kilati, about 27 % improvement from the level in 2005, due to Navrom’s modernization program of fleet in 2006-2007, supported by IFC’s previous investment. Further improvement, to some extent, is expected due to continuing investment to upgrade fleets over the next several years, and Navrom will continue to monitor its corporate average fleet efficiency and GHG emissions performance. In line with IFC’s GHG monitoring requirements as part of this equity investment project, TTS will start monitoring the group-wide GHG emissions (ESAP PS3-2).
PS 4: Community Health, Safety and Security
TTS Group’s operations at Constanta and Galati are confined to limited areas within the larger industrialized ports, and there is no community exposure to risks or impacts.
Navrom has two subsidiaries providing ferry services: Navrom Ferry Boat S.A., mainly providing Danube crossings between Galati and I.C. Bratianu; and Navrom Delta S.A. providing passenger fleet service at Danube Delta between Tulcea and three destinations (Periprava, Sulina, and Sfantu Gheorghe). At both subsidiaries, EHS performance is managed by Navrom’s corporate management systems. Ferry boats are equipped with rescue equipment (life jackets, life buoys) and proper signage in case of emergency. Qualified personnel, radar equipment and the modern rescue systems ensure minimizing risks to passengers. Life jackets are provided on ship for the maximum number of passengers allowed to transport plus 10% additional. Crew members are trained for emergency situations regularly for such situations as fire on board, damage (hull leak), man overboard, and abandon of ships. Two subsidiaries follow relevant safety performance standards for passenger ships and ferries under the Romanian regulations and European Union requirements (e.g. 2006/87/EC Directive laying down technical requirements for inland waterway vessels, and subsequent amendments made) including requirements for periodical inspection, periodical training of boarded personnel, and detailed safety instructions. In the past 5 years, there have been no major health and safety incidents like fatalities, sunk ferries, etc.
