The Project’s principal risks and impacts will be associated with the operation and maintenance of the Company’s pushboats and barges, including but not limited to: management of fuels and lubricants; solid and liquid wastes; effluents and emissions; occupational health and safety; navigational safety and collision prevention; human resource policy and working conditions of employees; and emergency preparedness and response planning. Key mitigation measures are described in the following sections of this summary.
PS1: Social and Environmental Assessment and Management System
Policy – The Company is presently in the early stages of developing an E&S management program which includes a corporate E&S Policy that will apply to HDB’s operations in the river. The Company will develop an E&S Policy consistent with the requirements of the applicable Performance Standards to be signed by HDB’s CEO and EHS Manager who will both ensure conformance with the policy and be responsible for its execution. The E&S Policy will be communicated to all levels of HDB prior to the start of operations.
Identification of Risks and Impacts – HDB has recently commissioned the preparation of a scoping study, as part of the development of an E&S management system, to map potentially applicable risks and impacts of HDB’s future barge transport activities and identify applicable regulatory requirements. The Company will ensure that the risk identification process to be developed as part of the E&S management program covers navigational and land-based activities of the company including, for example, inclusion of EHS considerations in the design of project equipment and an E&S due diligence prior to the acquisition of land (if any), considering the applicable aspects of Standards 2 through 8.
Management Programs – Based on the results of the scoping study and according to common principles of environmental management applicable to river transport operations, the Company will develop an operational E&S Management Program (ESMP) with supporting plans and procedures covering applicable environmental aspects (i.e. wastes and effluents), occupational health and safety aspects (i.e. accident and illness prevention, etc), and social aspects (i.e. labor management, community engagement, etc). The ESMP will be consistent with the applicable aspects of IFC Performance Standards and World Bank Group (WBG) Environmental, Health, and Safety (EHS) Guidelines; environmental, social, health and safety (ESHS) legal requirements across all operational jurisdictions; and any ESHS contractual obligation of the Project.
Organizational Capacity and Competency – The Sponsor has recently hired a qualified and experienced ESHS Manager who is in charge of developing HDB’s ESMP (supported by qualified external consultants) and who will oversee HDB’s ESHS performance. To ensure adequate support of the newly designated EHS Manager, HDB will clearly define his responsibilities and communicate these to the rest of the Company and site operating staff. The corporate HSSE department will also be provided with sufficient authority and resources to achieve effective and continuous E&S performance at the operational level. This may include in-house staff, as well as external consultants.
Monitoring and Review – The Company has indicated that it plans to select indicators and reporting formats that are initially consistent with the Global Reporting Initiative (GRI, Level C reporting format) and Brazil’s Bovespa Environmental Sustainability Index (ISE). Applicable indicators may include EHS aspects such as: fuel consumption; volumes of wastes and effluents generated and treated; occupational accident rates; accidental spills of fuels or waste oils (if any); navigational incidents (if any); community complaints (if any); etc. In addition to recording information to track performance, the Company will conduct internal inspections and audits against applicable ESHS criteria consistent with applicable IFC Performance Standards and WBG EHS Guidelines.
PS2: Labor and Working Conditions
Human Resources Policies and Procedures – By the time it becomes operational the Company intends to have a workforce of approximately 200 employees in operational and administrative functions. The majority of these employees are expected to be Paraguayan nationals for the navigation crews operating in the Paraguay River. The Company will develop and implement a human resources policy that sets out its approach to managing workers consistent with the requirements of IFC Performance Standard 2 and national law. The human resource policy will make explicit reference to the Company’s commitments to non-discrimination and equal opportunity in the hiring process; minimum work age requirements (to avoid child labor); workers’ rights to form or join workers organizations of their choosing (freedom of association); respect for collective agreements, if any; and maximum working hours consistent with local law and international practice. As will be defined in the Company’s Human Resource Policy, the Company will provide reasonable working conditions and terms of employment where these are not already outlined in a collective agreement. The Company will provide workers with documented information that is clear and understandable, regarding their rights under national labor and employment law and any applicable collective agreements, including their rights related to hours of work, wages, overtime, compensation, and benefits upon beginning the working relationship and when any material changes occur.
Grievance Mechanism – The Company will provide a grievance mechanism for workers to raise workplace concerns which is consistent with the requirements of IFC Performance Standard 2 and provide information about the grievance mechanism at the time of hiring.
Occupational Health and Safety (OHS) – The Company is already considering the OHS aspects associated with the design of crew accommodations and working spaces of the pushboats which will have crews of up to 15 persons. These are being designed according to internationally applicable standards (International Convention for the Safety of Life at Sea (SOLAS) and International Maritime Organization (IMO)) including those related to the provision of sanitary facilities; ventilation; heating and lighting; control of harmful noise; sanitation of galley areas; fire prevention and control (e.g. smoke detectors, fire doors, and means of egress); life-safety equipment (i.e. lifeboats, life-rafts, life-jackets, life buoys, distress signals, survival suits, etc); and fall protection and prevention (i.e. non-skid walking surfaces and internal/external railings).
The Company will develop an operational phase OHS management program whose objective will be to prevent and manage OHS risks associated with navigation and land-based maintenance operations. OHS procedures should cover, at a minimum, applicable OHS hazards for waterside and land-based activities including physical hazards (i.e. shipboard fall protection and prevention); chemical hazards (i.e. pushboat fueling safety procedures; use of lubricants, paints, and cleaning solvents in onboard and land-based maintenance; hot-work procedures for welding repairs; lock-out-tag-out procedures for electrical maintenance work; etc); permit-required confined space entry procedures; and emergency evacuation of injured workers from remote areas during navigation.
Supply Chain – The Company plans to conduct due diligence of the environmental and OHS performance of primary contractors who will be responsible for the construction of the pushboats and barges respectively located in Turkey, Paraguay and China. The due diligence aims to identify any significant reputational risks associated with the OHS and labor practices of these contractors as well as ensure that minimum standards of occupational safety are applied during the construction of the contracted equipment.
PS3: Pollution Prevention and Abatement
Resource Conservation, Atmospheric Emissions and Greenhouse Gases – The Project will mostly rely on the operation of [8] pushboats each equipped with diesel generators fueled by heavy fuel oil (HFO), supplemented by marine gas oil (MGO). The diesel generators will supply power to the pushboats’ electric propulsion system. They are designed to comply with IMO Tier II exhaust emissions standards as set out in Annex VI of the MARPOL 73/78 convention.
When fully operational, the Project will result in approximately annual greenhouse gas (GHG) emissions of 36 kgCO2/ton of transported product.
Liquid Effluents – The Project’s liquid effluents will be mainly associated with the operation of pushboats and include sewage; grey water (galley effluents); and oily water (bilge). The oily water discharge system will be equipped with an oil / water separator designed to meet IMO/MARPOL discharge standards. Sewage and grey water effluents should also be treated on-board according to IMO/MARPOL discharge standards or else transferred to port receiving facilities with IMO/MARPOL compliant receiving facilities.
As part of the development and implementation of the ESMP, the Company will identify other sources of emissions and effluents such as those that may be related to the shore-based maintenance operations (i.e. sanitary effluents, dockside stormwater runoff (including use of dockside oil/water separators), etc) and implement procedures to ensure these are managed according to applicable IFC Performance Standards, WBG EHS Guidelines, and applicable IMO/MARPOL requirements.
Wastes – Pushboat operations will generate onboard wastes consisting of used lubricating oil; oily sludge from fuel oil and oil/water separators; sanitary wastewater treatment sludge; and galley domestic solid waste. Dockside solid wastes may include domestic wastes from base operations and industrial wastes from ship maintenance activities.
As part of the development and implementation of the ESMP, the Company will identify all types of on-shore and pushboat waste and implement procedures to ensure these are managed according to applicable IFC Performance Standards, WBG EHS Guidelines, and applicable IMO/MARPOL requirements. Pushboat waste storage systems shall be designed to meet IMO/MARPOL requirements and wastes shall only be disposed of at on-shore waste reception facilities that meet these international requirements.
Hazardous Materials Management – Potentially hazardous or hazardous materials that will be used during the Project’s operation include the pushboats’ fuels including heavy fuel oil (HFO) and marine diesel oil to be stored in compartments with respective maximum capacities of approximately 500 cubic meters (m3). Pushboats will also be equipped with storage compartments for oily sludge; used oil; oily water; coolant drain and blackwater and greywater (adding to approximately 60 m3). All of these compartments will be protected by the ballast compartments which will serve as a double hull. Operation and maintenance of the pushboats will also require lubricating oil, engine degreasing and paint thinning solvents, and engine coolants, among others. Dockside maintenance activities may require the storage and use anti-fouling hull paints, chemical paint stripping agents, machine cutting oils and degreasers.
As part of the development and implementation of the ESMP, the Company will identify the types of on-shore and pushboat hazardous materials to be used in project operations and implement procedures to ensure these are managed according to applicable IFC Performance Standards, WBG EHS Guidelines, and applicable IMO/MARPOL requirements. Procedures will cover such aspects as spill prevention and response (including specific fueling procedures and proper use of on-board fuel spill kits); hazardous materials use reduction and management (including secondary containment for stored materials); and substitution of hazardous materials with less hazardous alternatives (i.e. use of water-based cutting oils, methylene chloride free paint stripping agents, use of TBT-free anti-fouling paints, etc).
PS4: Community Health, Safety and Security
Infrastructure and Equipment Design and Safety – Among the most significant potential operational hazards associated with the Project is the risk of collisions with other rivers users (commercial, recreational, etc) or riverside infrastructure (i.e. riverside bridge pilings and bridge abutments) as well as the risk of grounding and sinking due to collisions or structural failure. Pushboats and barges will be designed and constructed according to good international industry practice, taking into consideration minimum structural safety requirements and incorporating state-of-the-art control, communications, and navigation systems (including navigation aids, and signaling and communications equipment to help prevent collisions and groundings). Additionally, the Company will only hire trained and experienced crews.
As part of the development and implementation of the ESMP, the Company will develop and implement a navigation safety management program for river operations according to the provisions of an internationally recognized standard such as the International Safety Management (ISM) Code, including the preparation of a formal, written, Safety Management System (SMS). The SMS should identify the assignment of roles and responsibilities, the resources available, and emergency procedures, among others.
Emergency Preparedness and Response – Prior to the start of operations, HDB will develop and implement an emergency preparedness and response system which allows HDB, in collaboration with any relevant third parties, to respond to potential accidental and emergency situations which can be reasonably expected to be associated with HDB’s activities together with the necessary human and financial resources. HDB’s emergency preparedness and response plans will consider worst case risks (i.e. potential collision with third party shipping equipment or river side infrastructure such as bridge crossings) and their consequences including potential impacts to human settlements and infrastructure.
The approximately 2,500 kilometer stretch of the Paraguay River between Corumba, Brazil, and San Nicolas and Ibicuy, Argentina, is a traditional river transit and trading route between Argentina, Bolivia, Brazil, Paraguay, and Uruguay. This stretch of the River borders several legally protected areas under national, state, or municipal jurisdiction (i.e. provincial and municipal nature reserves and national parks) as well as areas of international importance for biodiversity conservation including at least one Ramsar wetland and one Unesco Biosphere Reserve. It also borders at least one Indigenous Peoples’ land located in the State of Mato Grosso do Sul, Brazil. The Company will consider the location and environmental characteristics of these areas in emergency planning process and will coordinate with relevant local community representatives and authorities as required (i.e. local emergency response entities). The Company will be supervised by relevant government agencies and will comply with the Paraná-Paraguay River System Agreement which regulates transit and includes specific provisions for oil spill prevention and international response coordination; vessel and cargo safety inspections; compliance with MARPOL requirements; and waste management, among others.
