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Environmental & Social Review Summary
Project Number
34394
Company Name
Delta Sucroenergia S/A
Date ESRS Disclosed
Aug 18, 2014
Country
Brazil
Region
Latin America and the Caribbean
Last Updated Date
Oct 2, 2022
Environmental Category
B - Limited
Status
Completed
Previous Events
Approved : Oct 24, 2014
Signed : Feb 24, 2015
Invested : Mar 24, 2015
Sector
Sugarcane and Beets
Industry
Agribusiness and Forestry
Department
Regional Industry MAS LAC & EUR
Project Description
Created in October 2012 as a spin-off of Usina Caeté S.A., a traditional player in Brazil’s sugar and ethanol industry, Usina Delta S.A. is a privately-held company (the ”Company”) with a crushing capacity of 10.5 million tons of sugarcane per year.
Delta’s three mills are located in a geographically concentrated cluster in the “Triângulo Mineiro” region of southwestern Minas Gerais state. The mills are: Delta (located adjacent to the town by the same name), Volta Grande (approximately 15 km away from the town of Conceição das Alagoas), and Conquista de Minas (approximately 10 km outside of the town by the same name). The latter mill is on a long-term lease from a bank. All three mills produce sugar (capacities of about 613,000 tons/year in Delta, 429,000 tons/year in Volta Grande and 98,000 tons/year in Conquista de Minas). Ethanol and energy are produced only in Delta and Volta Grande (capacities of about 147,000 m3 of ethanol and 30MW of power at Delta – of which about 8MW are sold – and [245,000] m3 of ethanol and 45MW of power – of which about 22MW are sold – at Volta Grande). In 2013, the company sourced sugarcane from around 156,122 hectares of nearby land, including approximately 66,14 percent from its own or leased lands (of which the company farms itself) and 33,86 percent from independent suppliers (many of whom also farm Delta lands as sharecroppers). In the 2012-13 harvest, Delta S/A milled 9.27 million tons of sugarcane and produced 15.3 million sacks of sugar (69 percent of company revenues) and 278,000 m3 of ethanol (25 percent). The remaining 6 percent of revenue came from energy co-generation (from the bagasse produced as a by-product of crushing cane) and soybeans, cultivated for crop rotation purposes.
IFC Loan of up to US$ 80 million is part of a financing package for Delta’s 3 year capital improvement program. During this period Delta will invest to expand energy co-generation at the Delta mill and production capacity of anhydrous ethanol, as well as increasing agricultural and productive efficiency and storage capacity, thereby helping the company to expand its revenue streams, which rely primarily on sugar and ethanol production. This $208 million investment program includes: (i) installing a new fluidized bed boiler of 330tv/h and a power generator of 70MW expanding energy external sales from 8MW to approximately 50 MW), including civil works, a substation (138kV), and a transmission line (138kV, 15km) to connect to the grid at Unit Uberaba 5, which belongs to CEMIG-MG (ii) to acquire new equipment to increase anhydrous production capacity in the Delta sugar mill, (iii) replanting 35,000 hectares of sugarcane in order to reach full crushing capacity, (iv) purchasing agricultural equipment to increase the level of harvest mechanization, (v) increase sugar storage capacity at the Volta Grande sugar mill building one new warehouses of 7,750 m2, and (vi) upgrading some mill rollers mills to increase sugar recovery rates (the project).
Delta’s three mills are located in a geographically concentrated cluster in the “Triângulo Mineiro” region of southwestern Minas Gerais state. The mills are: Delta (located adjacent to the town by the same name), Volta Grande (approximately 15 km away from the town of Conceição das Alagoas), and Conquista de Minas (approximately 10 km outside of the town by the same name). The latter mill is on a long-term lease from a bank. All three mills produce sugar (capacities of about 613,000 tons/year in Delta, 429,000 tons/year in Volta Grande and 98,000 tons/year in Conquista de Minas). Ethanol and energy are produced only in Delta and Volta Grande (capacities of about 147,000 m3 of ethanol and 30MW of power at Delta – of which about 8MW are sold – and [245,000] m3 of ethanol and 45MW of power – of which about 22MW are sold – at Volta Grande). In 2013, the company sourced sugarcane from around 156,122 hectares of nearby land, including approximately 66,14 percent from its own or leased lands (of which the company farms itself) and 33,86 percent from independent suppliers (many of whom also farm Delta lands as sharecroppers). In the 2012-13 harvest, Delta S/A milled 9.27 million tons of sugarcane and produced 15.3 million sacks of sugar (69 percent of company revenues) and 278,000 m3 of ethanol (25 percent). The remaining 6 percent of revenue came from energy co-generation (from the bagasse produced as a by-product of crushing cane) and soybeans, cultivated for crop rotation purposes.
IFC Loan of up to US$ 80 million is part of a financing package for Delta’s 3 year capital improvement program. During this period Delta will invest to expand energy co-generation at the Delta mill and production capacity of anhydrous ethanol, as well as increasing agricultural and productive efficiency and storage capacity, thereby helping the company to expand its revenue streams, which rely primarily on sugar and ethanol production. This $208 million investment program includes: (i) installing a new fluidized bed boiler of 330tv/h and a power generator of 70MW expanding energy external sales from 8MW to approximately 50 MW), including civil works, a substation (138kV), and a transmission line (138kV, 15km) to connect to the grid at Unit Uberaba 5, which belongs to CEMIG-MG (ii) to acquire new equipment to increase anhydrous production capacity in the Delta sugar mill, (iii) replanting 35,000 hectares of sugarcane in order to reach full crushing capacity, (iv) purchasing agricultural equipment to increase the level of harvest mechanization, (v) increase sugar storage capacity at the Volta Grande sugar mill building one new warehouses of 7,750 m2, and (vi) upgrading some mill rollers mills to increase sugar recovery rates (the project).
Overview of IFC's Scope of Review
IFC’s review of the project consisted of on-site visits conducted in January 2014 to assess the company’s operations and to review information submitted by the company on the following: environmental, occupational health and safety (OHS), and social management policies and procedures; environmental and social management plans; water consumption and quality, wastewater generation and quality and energy generation and export monitoring data; emergency preparedness and response, including life and fire safety (L&FS) systems; human resource policies, procedures and statistics; and presentations about the company’s actual and planned business activities. This also included a review of the company’s future plans and commitments. In company’s direct operations, cane harvest is 95 percent mechanized and harvested in green, reducing OHS risks in the workforce associated with manual cutting (for example cuts due to use of machetes, dehydration during field work etc.). A review of company records on occupational health, revealed no occurrence of Chronic kidney disease (CKD) or Chronic Renal Insufficiency (CRI) in company’ employees. Moreover, there is no trace of knowledge of the disease in any sugar cane operation in Brazil. Additionally, IFC personnel interviewed key senior managerial staff, including those related to corporate management, new project development, legal affairs and external relations, environment and occupational safety, quality assurance, communications, operations; and human resources and staff training. In addition, IFC staff met with external stakeholders, such as local authorities, leaders of the unions representing the vast majority of the workforce, and people residing directly adjacent to one of the company''s sugar mills.
IFC’s appraisal considered environmental and social management plans for the project and gaps if any between these plans and IFC requirements. The IFC Global Map of Environmental and Social Risk in Agro-Commodity Production (GMAP) have been used as part of the screening process. Where necessary, corrective measures intended to close these gaps within a reasonable period of time are summarized in the paragraphs that follow and in the agreed Environmental and Social Action Plan (ESAP) disclosed together with this review summary. Through implementation of these management plans the project is expected to be designed and operated in accordance with Performance Standards objectives.
IFC’s appraisal considered environmental and social management plans for the project and gaps if any between these plans and IFC requirements. The IFC Global Map of Environmental and Social Risk in Agro-Commodity Production (GMAP) have been used as part of the screening process. Where necessary, corrective measures intended to close these gaps within a reasonable period of time are summarized in the paragraphs that follow and in the agreed Environmental and Social Action Plan (ESAP) disclosed together with this review summary. Through implementation of these management plans the project is expected to be designed and operated in accordance with Performance Standards objectives.
E & S Project Categorization and Applicable Standard
While all Performance Standards are applicable to this investment, IFCs environmental and social due diligence indicates that the investment will have impacts which must be managed in a manner consistent with the following Performance Standards. If IFCs investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards
PS 1 – Assessment and Management of Environmental and Social Risks and Impacts
PS 2 - Labor and working conditions
PS 3 - Resource Efficiency and Pollution Prevention
PS 4 – Community Health, Safety and Security
PS 6 – Biodiversity Conservation and Sustainable Management of Living Natural Resources
PS 8 – Cultural Heritage
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards
PS 1 – Assessment and Management of Environmental and Social Risks and Impacts
PS 2 - Labor and working conditions
PS 3 - Resource Efficiency and Pollution Prevention
PS 4 – Community Health, Safety and Security
PS 6 – Biodiversity Conservation and Sustainable Management of Living Natural Resources
PS 8 – Cultural Heritage
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards
This is a Category B project according to IFC’s Policy on Social and Environmental Sustainability because a limited number of specific environmental and social impacts that may result can be avoided or mitigated by adhering to generally recognized performance standards, applicable World Bank Group (WBG) Environmental, Health and Safety (EHS) General and sector-specific (Sugar Manufacturing, Thermal Power Plants, Plantation Crop Production) Guidelines and design criteria as is described in the following sections.
PS5 Land Acquisition and Involuntary Resettlement does not apply since Delta’s land acquisition process of its owned lands was carried out on a willing buyer/willing seller basis, and no conflict for land or involuntary resettlement are expected from this project. The Project envisions no new land acquisition/leasing, and it will not lead to any displacement, whether physical or economic, of local residents. As part of its contracting process with local growers who supply approximately one-third of the sugarcane for Delta’s operations, Delta requires the farmers to submit extensive documentation, including proof of land title, payment of rural real-estate taxes, and related documents. There have been sporadic attempts by some local residents to illicitly claim land owned by Delta or its suppliers, and the Company has developed a rapid-reaction methodology to engage appropriate judicial and police authorities to prevent or stop illegal land occupation. The IFC is otherwise not aware of any significant risks or impacts related to land use and acquisition/leasing that would trigger PS5 requirements. PS7 Indigenous Peoples (IP) does not apply since no IP groups have been identified in the areas of influence of the Project. According to the client, there has been no interaction at any of their farms with Indians or Quilombolas (traditional communities of slave descendants enjoying certain legal protections in Brazil).
The Company has presented extensive information on its current EHS practices and procedures to address environmental and social (E&S) risks and impacts as well as to ensure that the proposed Project currently complies with or will, upon implementation of specific additional agreed measures spelt out in the attached Environmental and Social Action Plan (ESAP), comply with Brazilian laws and regulations, IFC Performance Standards and applicable WBG EHS Guidelines. Information about how these potential impacts are or will be addressed by the Company is summarized in the paragraphs that follow. Additional actions are summarized in the attached Environmental and Social Action Plan (ESAP).
PS5 Land Acquisition and Involuntary Resettlement does not apply since Delta’s land acquisition process of its owned lands was carried out on a willing buyer/willing seller basis, and no conflict for land or involuntary resettlement are expected from this project. The Project envisions no new land acquisition/leasing, and it will not lead to any displacement, whether physical or economic, of local residents. As part of its contracting process with local growers who supply approximately one-third of the sugarcane for Delta’s operations, Delta requires the farmers to submit extensive documentation, including proof of land title, payment of rural real-estate taxes, and related documents. There have been sporadic attempts by some local residents to illicitly claim land owned by Delta or its suppliers, and the Company has developed a rapid-reaction methodology to engage appropriate judicial and police authorities to prevent or stop illegal land occupation. The IFC is otherwise not aware of any significant risks or impacts related to land use and acquisition/leasing that would trigger PS5 requirements. PS7 Indigenous Peoples (IP) does not apply since no IP groups have been identified in the areas of influence of the Project. According to the client, there has been no interaction at any of their farms with Indians or Quilombolas (traditional communities of slave descendants enjoying certain legal protections in Brazil).
The Company has presented extensive information on its current EHS practices and procedures to address environmental and social (E&S) risks and impacts as well as to ensure that the proposed Project currently complies with or will, upon implementation of specific additional agreed measures spelt out in the attached Environmental and Social Action Plan (ESAP), comply with Brazilian laws and regulations, IFC Performance Standards and applicable WBG EHS Guidelines. Information about how these potential impacts are or will be addressed by the Company is summarized in the paragraphs that follow. Additional actions are summarized in the attached Environmental and Social Action Plan (ESAP).
Environmental and Social Mitigation Measures
IFC's appraisal considered the environmental and social management planning process and documentation for the project and gaps, if any, between these and IFCs requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and (if applicable) in an agreed Environmental and Social Action Plan (ESAP). Through the implementation of these measures, the project is expected to be designed and operated in accordance with Performance Standards objectives.
PS1: Assessment and Management of Environmental and Social Risks and Impacts
Delta manages EHS issues of its operations mainly through achieving compliance with Brazilian legal and regulatory requirements. The Delta and Volta Grande mills have had a quality assurance (QA) management system based on ISO 9001 since 2003 (re-certified in 2012). Delta has started the process of complying with the BONSUCRO sustainable sugarcane certification initiative (total area subjected to certification at a first phase would be of 104,523 hectares) and, as such, building an integrated environmental, social and quality assurance management system to achieve the ISO 14001 certification, but these efforts were on hold at the time of appraisal. However, the company is carrying out internal actions to address the gaps identified in an effort to comply with these standards.
Delta has adopted a corporate E&S policy, including provisions for its implementation by developing appropriate organizational capacity, risk assessment, management programs, monitoring, training and reporting. The scope of the policy also includes some OHS issues.
Environmental and Social Assessment and Management System - Due to the nature of the sugarcane, ethanol and thermal energy co-generation businesses, Brazil’s state regulatory agencies usually require an environmental impact assessment (EIA) or similar study aimed at identifying, analyzing and managing risks and impacts in order for necessary environmental licenses to be issued. The company is obliged to comply with Brazilian procedures and requirements to obtain the necessary permits and authorizations at local and/or regional levels as part of its normal operations and as part of any expansion plans.
In the case of the process whereby it leased Conquista de Minas unit, Delta has to comply with an Environmental Term of Agreement (TCA – Termo de Compromisso de Ajustamento de Conduta) signed in 2009 by Usina Mendonça, the former owner. The agreement includes provision of information and commitment to develop and implement some environmental mitigation measures as well. All requirements, including environmental operation license renewal, list of independent suppliers, provision of information related to dams, water intake permits, monitoring systems, containment of wastewater tanks, etc. were met, with the exception of L&FS system design approval and permit.
As part of its Environmental Risk Prevention Plan (Programa de Prevenção de Riscos Ambientais, or PPRA), Delta identifies the most relevant impacts and risks from its operations as stemming from air emissions, effluents, solid waste and all occupational health and safety (OHS) risks.
Delta does not yet have a formalized Environmental and Social Management System (ESMS). In accordance with the attached ESAP, Delta will further implement its existing management practices through the consolidation of an integrated Environmental and Social Management System (ESMS) at the corporate lev
el consistent with Brazilian laws and regulations, IFC Performance Standards, applicable WBG general and sector-specific EHS Guidelines and the international sugar sector standard mentioned above. However, the company closely monitors environmental, occupational health and safety and resource (water and energy) efficiency aspects at all its operations following applicable Brazilian legal requirements. The company has adopted several policies and procedures to manage human resources and OHS, including, among others, specific procedures for hazardous works (working at heights, working with heat, working with electrical systems, working in confined spaces), which must be followed by the hazardous works permitting procedure. Delta conducts preventive/corrective inspections, analysis of accidents and incidents, and develops and implements mandatory OHS programs, such as the above-mentioned Environmental Risk Prevention Plan (Programa de Prevenção de Riscos Ambientais, or PPRA) and a Health Monitoring Plan (Programa de Controle Médico da Saúde Ocupacional, or PCMSO). The legally required safety committees (CIPA, or Comissão Interna de Prevenção de Acidentes) with representatives from the workers and management are responsible for conducting preventive OHS inspections, reporting on health and safety issues encountered during work, investigating and analyzing occupational accidents, incidents, and health issues and helping to ensure that the OHS training activities are completed.
Delta also implements a set of management programs to avoid (if possible), minimize and mitigate identified negative impacts from its operation units. These plans often include wastes streams monitoring and management programs, noise and air quality monitoring, surface water quality monitoring, vinasse application program (in case of sugar mills), traffic safety and control, among others. Delta has also put in place environmental programs and procedures to reduce the amount of industrial wastes and effluents, converting them into fertilizers for the sugarcane plantations. As part of a broader transition in the Brazilian sugar sector from reliance on manual agricultural labor, Delta achieved 93% mechanized harvesting in 2013. Manual harvesting has been continued only where it is not possible to use mechanized equipment. The company will eliminate the use of large-scale fires at harvest by 2014 following state requirements (DN 133/2009).
Organizational Capacity and Competency – Responsibility for EHS management is concentrated at the corporate level within a number of key personnel: a Corporate Affairs Manager (responsible for communication with government agencies and external stakeholders), a Legal and Sustainability Manager (responsible for legal and environmental compliance), an Environmental Coordinator, a Corporate Administrative Manager, a Human Resources Manager and a Corporate OHS Coordinator. This corporate body is structured to deal with EHS issues. Environmental issu
es are handled by an internal team of 5 people responsible for industrial processes, licensing and replanting activities (handled by a team of 37 people), who report to the Corporate Environmental Coordinator.
Aside from carrying out internal EHS inspections, the company also hires two environmental consultancy companies to conduct monthly inspections. The results are consolidated in monthly reports and discussed in weekly meetings at a rotating basis at each operating unit. These meetings will be replaced this year by a face-to-face discussion between corporate-level environmental and sustainability personnel and the manager(s) of the department(s) involved in the issue(s). Responsibility for monitoring the Action Plan lies with an Internal Environmental Commission (Comissão Interna de Meio Ambiente - CIMA). In cases of recurrence, the environmental team develops awareness campaigns among workers. The external consultants also support the company in environmental licensing processes and additional requirements.
Each unit has a dedicated team OHS team of Occupational Safety Engineers, Occupational Safety Technicians and a medical team comprising Doctors, Occupational Nurses, Nurse Technicians and ambulance drivers (20 people in Delta, 22 in Volta Grande and 11 in Conquista de Minas).
Training – Delta has established structured training programs that includes an EHS induction for new employees (and contractors), as well as specific trainings, as needed for the job, such as working at heights, working in confined spaces, machine operators, boiler operators, pesticides use and handling, vinasse irrigation, and traffic safety. These are handled by the HR Department, which maintains registries of the training courses, recording attendance, topics covered and a Training Matrix for each employee. Capacity building trainings are focused on the cane cutters and residents. Going forward, as set forth in the ESAP, the company will amend its induction training to management and staff on EHS aspects applicable to the job tasks focusing on aspects, such as management of hazardous materials and hazardous wastes, solid waste recycling management, gas cylinder management, housekeeping practices and electrical safety.
Monitoring and Reporting – Delta monitors some indicators of their farming operations, such as soil quality, wastewater conductivity and potassium, field application of vinasse, pesticide consumption, water usage at processing and farm operations, energy generation and usage, solid waste generation and disposal, work related injuries etc. The company reports requested indicators to the environmental agency. Also, as condition of its environmental licenses, Delta monitors some fauna indicators within the influence area of its plantations twice a year, during dry and wet seasons (Delta unit); limnology and water quality in 5 sample stations during dry and wet seasons (Delta unit); industrial effluents from the Effluent Treatment Plan (ETP) and wa
ter-oil separation boxes of the agricultural area and workshop (quarterly in Delta and biannually in Volta Grande); ground water at five points on a quarterly basis (Delta unit); boiler emissions of inhalable particulates (PM10) and total suspended particulates (PTS) annually in Delta and biannually in Volta Grande; NOx emissions from the boilers, biannually in Volta Grande; air quality concerning particulates, monthly (Delta unit); waste management results biannually in Delta and annually in Volta Grande; noise at 8 points around the perimeters of its sites (corporate program); and black smoke emissions from vehicles using the Rigelmann Scale annually (corporate program).
Delta will define a comprehensive set of Key Performance Indicators (KPIs) in order to monitor on a monthly/annual basis the following EHS parameters: a) Safety – Lost Time Incidence Frequency Rate (LTIFR), Accident Free Days; b) Sustainability – Carbon (kg/ton), Water Usage (kiloliters/ton) at processing and farm operations, Energy Usage (kWh/ton), wastewater monitoring effluents, noise, air emissions parameters from boiler/genset in line with WBG’s General and Sector specific EHS Guidelines, use of fertilizers and pesticides, solid and hazardous waste management and disposal, customers and community complaints, supplier performance and community engagement activities, quantifiable indicators reflecting the implementation progress of the Housing Improvement Program (HIP) on an on-going basis; c) Staff - Retention and training days.
In addition, the EHS officer will define an integrated EHS report format and based on critical EHS key performance indicators (e.g., compliance with Brazilian legal and regulatory requirements, EHS management system progress report and certification). The company will also report annually to relevant Brazilian authorities and IFC as part of the Annual Monitoring Report (AMR). Annual EHS review will be discussed during the company’s planning and budgetary management review.
As set forth in the ESAP, Delta will build an internal report in order to track its Key Performance Indicators.
External Communications and Grievance Mechanisms - Delta has significant elements in place for effective communications with stakeholders and an external community grievance mechanism. The company has a toll-free relationship management telephone number to which the general public, including any stakeholders with grievances, can call, but this number has not been broadly publicized as a grievance mechanism (it serves primarily as a customer service number for retailers or final users of its sugar). As set forth in the ESAP, Delta will restructure its current external relationship management system into a formal grievance mechanism and publicize the multiple channels for accessing it, including the toll-free number.
Emergency Preparedness and Response - Delta has Emergency Preparedness and Response Plans (PAE - Plano de Ação de Emergência) covering scenarios of em
ergency situations such as fires, explosions, and leaks to the environment for all its units. The company complies with the life and fire safety requirements of the state of Minas Gerais and keeps the record of permits related to the L&FS systems (Auto de Vistoria do Corpo de Bombeiros - AVCB, issued after the design approval and inspection of the installed L&FS systems by the authority) at two units: Delta and Volta Grande. The project of the L&FS system of Conquista de Minas was being analyzed by the authorities during the appraisal. The L&FS equipment includes fire detectors, alarm systems, hydrants, foam chambers, and portable extinguishers.
Delta manages EHS issues of its operations mainly through achieving compliance with Brazilian legal and regulatory requirements. The Delta and Volta Grande mills have had a quality assurance (QA) management system based on ISO 9001 since 2003 (re-certified in 2012). Delta has started the process of complying with the BONSUCRO sustainable sugarcane certification initiative (total area subjected to certification at a first phase would be of 104,523 hectares) and, as such, building an integrated environmental, social and quality assurance management system to achieve the ISO 14001 certification, but these efforts were on hold at the time of appraisal. However, the company is carrying out internal actions to address the gaps identified in an effort to comply with these standards.
Delta has adopted a corporate E&S policy, including provisions for its implementation by developing appropriate organizational capacity, risk assessment, management programs, monitoring, training and reporting. The scope of the policy also includes some OHS issues.
Environmental and Social Assessment and Management System - Due to the nature of the sugarcane, ethanol and thermal energy co-generation businesses, Brazil’s state regulatory agencies usually require an environmental impact assessment (EIA) or similar study aimed at identifying, analyzing and managing risks and impacts in order for necessary environmental licenses to be issued. The company is obliged to comply with Brazilian procedures and requirements to obtain the necessary permits and authorizations at local and/or regional levels as part of its normal operations and as part of any expansion plans.
In the case of the process whereby it leased Conquista de Minas unit, Delta has to comply with an Environmental Term of Agreement (TCA – Termo de Compromisso de Ajustamento de Conduta) signed in 2009 by Usina Mendonça, the former owner. The agreement includes provision of information and commitment to develop and implement some environmental mitigation measures as well. All requirements, including environmental operation license renewal, list of independent suppliers, provision of information related to dams, water intake permits, monitoring systems, containment of wastewater tanks, etc. were met, with the exception of L&FS system design approval and permit.
As part of its Environmental Risk Prevention Plan (Programa de Prevenção de Riscos Ambientais, or PPRA), Delta identifies the most relevant impacts and risks from its operations as stemming from air emissions, effluents, solid waste and all occupational health and safety (OHS) risks.
Delta does not yet have a formalized Environmental and Social Management System (ESMS). In accordance with the attached ESAP, Delta will further implement its existing management practices through the consolidation of an integrated Environmental and Social Management System (ESMS) at the corporate lev
el consistent with Brazilian laws and regulations, IFC Performance Standards, applicable WBG general and sector-specific EHS Guidelines and the international sugar sector standard mentioned above. However, the company closely monitors environmental, occupational health and safety and resource (water and energy) efficiency aspects at all its operations following applicable Brazilian legal requirements. The company has adopted several policies and procedures to manage human resources and OHS, including, among others, specific procedures for hazardous works (working at heights, working with heat, working with electrical systems, working in confined spaces), which must be followed by the hazardous works permitting procedure. Delta conducts preventive/corrective inspections, analysis of accidents and incidents, and develops and implements mandatory OHS programs, such as the above-mentioned Environmental Risk Prevention Plan (Programa de Prevenção de Riscos Ambientais, or PPRA) and a Health Monitoring Plan (Programa de Controle Médico da Saúde Ocupacional, or PCMSO). The legally required safety committees (CIPA, or Comissão Interna de Prevenção de Acidentes) with representatives from the workers and management are responsible for conducting preventive OHS inspections, reporting on health and safety issues encountered during work, investigating and analyzing occupational accidents, incidents, and health issues and helping to ensure that the OHS training activities are completed.
Delta also implements a set of management programs to avoid (if possible), minimize and mitigate identified negative impacts from its operation units. These plans often include wastes streams monitoring and management programs, noise and air quality monitoring, surface water quality monitoring, vinasse application program (in case of sugar mills), traffic safety and control, among others. Delta has also put in place environmental programs and procedures to reduce the amount of industrial wastes and effluents, converting them into fertilizers for the sugarcane plantations. As part of a broader transition in the Brazilian sugar sector from reliance on manual agricultural labor, Delta achieved 93% mechanized harvesting in 2013. Manual harvesting has been continued only where it is not possible to use mechanized equipment. The company will eliminate the use of large-scale fires at harvest by 2014 following state requirements (DN 133/2009).
Organizational Capacity and Competency – Responsibility for EHS management is concentrated at the corporate level within a number of key personnel: a Corporate Affairs Manager (responsible for communication with government agencies and external stakeholders), a Legal and Sustainability Manager (responsible for legal and environmental compliance), an Environmental Coordinator, a Corporate Administrative Manager, a Human Resources Manager and a Corporate OHS Coordinator. This corporate body is structured to deal with EHS issues. Environmental issu
es are handled by an internal team of 5 people responsible for industrial processes, licensing and replanting activities (handled by a team of 37 people), who report to the Corporate Environmental Coordinator.
Aside from carrying out internal EHS inspections, the company also hires two environmental consultancy companies to conduct monthly inspections. The results are consolidated in monthly reports and discussed in weekly meetings at a rotating basis at each operating unit. These meetings will be replaced this year by a face-to-face discussion between corporate-level environmental and sustainability personnel and the manager(s) of the department(s) involved in the issue(s). Responsibility for monitoring the Action Plan lies with an Internal Environmental Commission (Comissão Interna de Meio Ambiente - CIMA). In cases of recurrence, the environmental team develops awareness campaigns among workers. The external consultants also support the company in environmental licensing processes and additional requirements.
Each unit has a dedicated team OHS team of Occupational Safety Engineers, Occupational Safety Technicians and a medical team comprising Doctors, Occupational Nurses, Nurse Technicians and ambulance drivers (20 people in Delta, 22 in Volta Grande and 11 in Conquista de Minas).
Training – Delta has established structured training programs that includes an EHS induction for new employees (and contractors), as well as specific trainings, as needed for the job, such as working at heights, working in confined spaces, machine operators, boiler operators, pesticides use and handling, vinasse irrigation, and traffic safety. These are handled by the HR Department, which maintains registries of the training courses, recording attendance, topics covered and a Training Matrix for each employee. Capacity building trainings are focused on the cane cutters and residents. Going forward, as set forth in the ESAP, the company will amend its induction training to management and staff on EHS aspects applicable to the job tasks focusing on aspects, such as management of hazardous materials and hazardous wastes, solid waste recycling management, gas cylinder management, housekeeping practices and electrical safety.
Monitoring and Reporting – Delta monitors some indicators of their farming operations, such as soil quality, wastewater conductivity and potassium, field application of vinasse, pesticide consumption, water usage at processing and farm operations, energy generation and usage, solid waste generation and disposal, work related injuries etc. The company reports requested indicators to the environmental agency. Also, as condition of its environmental licenses, Delta monitors some fauna indicators within the influence area of its plantations twice a year, during dry and wet seasons (Delta unit); limnology and water quality in 5 sample stations during dry and wet seasons (Delta unit); industrial effluents from the Effluent Treatment Plan (ETP) and wa
ter-oil separation boxes of the agricultural area and workshop (quarterly in Delta and biannually in Volta Grande); ground water at five points on a quarterly basis (Delta unit); boiler emissions of inhalable particulates (PM10) and total suspended particulates (PTS) annually in Delta and biannually in Volta Grande; NOx emissions from the boilers, biannually in Volta Grande; air quality concerning particulates, monthly (Delta unit); waste management results biannually in Delta and annually in Volta Grande; noise at 8 points around the perimeters of its sites (corporate program); and black smoke emissions from vehicles using the Rigelmann Scale annually (corporate program).
Delta will define a comprehensive set of Key Performance Indicators (KPIs) in order to monitor on a monthly/annual basis the following EHS parameters: a) Safety – Lost Time Incidence Frequency Rate (LTIFR), Accident Free Days; b) Sustainability – Carbon (kg/ton), Water Usage (kiloliters/ton) at processing and farm operations, Energy Usage (kWh/ton), wastewater monitoring effluents, noise, air emissions parameters from boiler/genset in line with WBG’s General and Sector specific EHS Guidelines, use of fertilizers and pesticides, solid and hazardous waste management and disposal, customers and community complaints, supplier performance and community engagement activities, quantifiable indicators reflecting the implementation progress of the Housing Improvement Program (HIP) on an on-going basis; c) Staff - Retention and training days.
In addition, the EHS officer will define an integrated EHS report format and based on critical EHS key performance indicators (e.g., compliance with Brazilian legal and regulatory requirements, EHS management system progress report and certification). The company will also report annually to relevant Brazilian authorities and IFC as part of the Annual Monitoring Report (AMR). Annual EHS review will be discussed during the company’s planning and budgetary management review.
As set forth in the ESAP, Delta will build an internal report in order to track its Key Performance Indicators.
External Communications and Grievance Mechanisms - Delta has significant elements in place for effective communications with stakeholders and an external community grievance mechanism. The company has a toll-free relationship management telephone number to which the general public, including any stakeholders with grievances, can call, but this number has not been broadly publicized as a grievance mechanism (it serves primarily as a customer service number for retailers or final users of its sugar). As set forth in the ESAP, Delta will restructure its current external relationship management system into a formal grievance mechanism and publicize the multiple channels for accessing it, including the toll-free number.
Emergency Preparedness and Response - Delta has Emergency Preparedness and Response Plans (PAE - Plano de Ação de Emergência) covering scenarios of em
ergency situations such as fires, explosions, and leaks to the environment for all its units. The company complies with the life and fire safety requirements of the state of Minas Gerais and keeps the record of permits related to the L&FS systems (Auto de Vistoria do Corpo de Bombeiros - AVCB, issued after the design approval and inspection of the installed L&FS systems by the authority) at two units: Delta and Volta Grande. The project of the L&FS system of Conquista de Minas was being analyzed by the authorities during the appraisal. The L&FS equipment includes fire detectors, alarm systems, hydrants, foam chambers, and portable extinguishers.
Working Conditions and Management of Worker Relationship – Delta’s HR policies and procedures follow Brazilian labor regulations, which are consistent with International Labor Organization (ILO) standards (Brazil is a signatory of most relevant ILO conventions). The terms of employment, such as wages and benefits, hours of work, overtime arrangements and overtime compensation, annual and sick leave, maternity, vacation or holiday are established by national labor regulations and applicable sector specific collective bargaining agreements. Delta’s labor practices can be considered above the benchmark in the sector. Although Brazilian workers in general are familiar with the national terms of employment, the company also informs them during the recruiting phase regarding the specific terms of the job position and additional benefits. Delta has adopted a range of human resources procedures, such as those for selecting and hiring workers, terminating a contract, assessing performance and promoting personnel, paying wages and salaries and onboarding new staff, which cover most significant aspects of IFC’s labor requirements.
Delta employs 6,051 permanent workers in its three units. These are divided between roughly 5,322 men (concentrated in the agricultural and industrial sectors) and 729 women (concentrated in administration and some agricultural and sales functions). Through the mechanization of its planting and harvesting operations, Delta has sought to eliminate the use of temporary agricultural workers and transition low-skill workers (e.g. cane cutters) into higher-skill roles, such as equipment operators through an active selection, training, and retention effort. This has helped Delta to address a major source of turnover and labor grievances and to develop a stronger, long-term relationship with its agricultural workforce.
Brazil’s constitution and legal system protect the rights of workers to associate, organize, enter into collective bargaining agreements, and strike, if necessary. Delta respects worker rights and promotes an open and highly constructive relationship with its workforce. Six unions represent the agricultural workers and processing plant workers at Delta’s three facilities, and membership levels are high (85-95%). Delta seeks to avoid any adverse legal action by current or former workers and aims to settle such claims amicably.
The company earned good-practice certifications under a federal campaign known as the National Commitment to Improve Working Conditions in the Sugarcane Sector. Also, in response to detecting a problem of high turnover, the company has invested in hiring a corporate-level HR manager, launching new training programs and leadership development efforts, and seeking to retrain relatively low-skill agricultural workers as operators for mechanized harvesters and other equipment. These efforts have yielded a significant drop in Delta''s labor turnover as a result.
Worker’s Organizations - As defined by
law in Brazil, all workers have to contribute to their respective sector labor union. Annual salary increase, sector-specific minimum wage and some benefits are negotiated directly with the unions under collective bargaining agreements, but respecting the minimum standards defined by the Federal Administration. There is no evidence that the company restricts workers’ freedom of association.
Non-Discrimination and Equal Opportunity – Delta has a stated commitment to non-discrimination and equal opportunity, and it reports ongoing efforts to comply with various Brazilian legal requirements, including employment targets for persons with disabilities (according to Brazilian Federal Law 8213/1991), for which it still falls short. Its workforce is approximately 12% women, which compares favorably with other companies in the sugar and ethanol sector.
Retrenchment – No retrenchment is expected under this project, but if it were to happen, Delta would be required to follow Brazilian legal requirements that include negotiation of a collective agreement with unions.
Grievance Mechanism – Delta has channels for worker grievances through anonymous suggestion boxes and through recourse to confidential workplace counsellors in the event that a worker does not feel comfortable raising grievances directly with a supervisor. Grievances can also be submitted externally through either the labor unions or the public labor rights system (Justiça do Trabalho). As part of the ESAP, Delta will formalize its current internal grievance practices as a holistic worker grievance mechanism and publicize its functioning, including confidentiality provisions, widely among the workforce.
Protecting the Work Force – With the mechanization of the planting and harvest of sugarcane, which has now reached some 95 percent within Delta’s operations, the company no longer has to hire temporary agricultural workers, such as cane-cutters. In the past such workers would often come from other parts of Brazil (especially northern Minas Gerais and states in the Northeast) and were traditionally the most vulnerable to forced labor by third-party foremen who organized and transported work crews from elsewhere. In order to avoid such problems, Delta has in recent years established an in-house recruitment team in labor-sending regions for identifying potential recruits, conducting all pre-employment screening (including medical exams), securing the necessary permits from local Ministry of Labor offices for contracting migrant workers (the so-called Certidão Liberatória), and transporting workers to southwestern Minas Gerais (and paying for their return travel at harvest’s end). In 2014, Delta will discontinue hiring migrant labor, and it intends to hire locally the 100-150 temporary agricultural workers it estimates it will require.
The company is among those at the forefront in setting progressive labor standards in Brazil. They have established labor requirements, already included in the
contracts with its suppliers, and set up a lodge to accommodate the relatively few migrant workers hired by the company. Out-growers and independent suppliers are required to respect Brazilian legal prohibitions against child labor, and Delta Group ensures that no child labor is used at its operations through the company''s hiring and selection procedure. Specifically, the company complies with legal minimum age of work requirements by requesting valid documentation of age in the employee contracting process. IFC noted that the company appears to be rigorous in providing appropriate personal protective equipment (PPE), food services, rest locations, transportation and similar services for its personnel. In addition, both Delta’s own farms and those of suppliers are regularly audited by state and federal labor inspectors, and relatively few and relatively minor infractions have been noted. Regarding its supply chain, Delta is in constant dialogue with suppliers providing technical assistance and monitoring compliance regarding labor and environmental issues. Delta checks if its suppliers are on the so-called "black list" for forced labor or other inhumane working conditions (the Brazilian Ministry of Labor discloses a list of companies engaged in forced labor or other inhumane practices every six months). The company conducted a supplier baseline E&S assessment and database through a questionnaire and a workshop, which led to the inclusion of specific E&S provisions in the contracts with suppliers. The company also developed a code of conduct for suppliers to sign as part of their purchasing agreements.
Occupational Health and Safety – The company implements Brazilian Regulatory Norms (NRs) applicable to its operations including those related to the identification and monitoring of environmental hazardous agents through a Workplace Environmental Risk Prevention Program or PPRA (Programa de Prevenção de Riscos Ambientais), use of Personal Protective Equipment (PPE), emergency preparedness and response, and medical surveillance (PCMSO or Programa de Controle Médico de Saúde Ocupacional), besides trained people to help in emergencies. The legally required safety committees (CIPA and CIPATR or Comissão Interna de Prevenção de Acidentes and Comissão Interna de Prevenção de Acidentes no Trabalho Rural, respectively), which include representatives from workers, responsible for conducting preventive OHS inspections, reporting on health and safety issues encountered during work, investigating and analyzing occupational accidents, incidents, and health issues and helping ensure that the OHS training activities are completed. The Lost Time Injury Frequency Rate (LTIFR) considering number of injuries with lost days per 1 million worked hours at the three mills (1.94 at Delta mill, 5.91 at Volta Grande mill and 3.04 at Conquista de Minas mill) are below the international reference for the sugar manufacturing sector of 7.0. Delta has also adopted comprehensive
procedures for hazardous materials and pesticides. Delta developed a procedure for working inside confined spaces consistent with Brazilian safety requirements (NR33) and WBG’s EHS general guidelines. The company had also done an inventory of pressure vessels, has the technical specifications and maintains maintenance books for individual pressure vessels in accordance with the relevant Brazilian safety standard (NR13). Besides, Delta conducted a safety assessment for working with electrical facilities (according to Brazilian standard NR10) and kept the electric installment archives for all units. However, as set forth in the ESAP, these baseline assessments will be updated and the investments needed to fill the gaps will be planned by the company. For the units owned by Delta (Delta and Volta Grande mills), Delta will develop a corrective action plan including activities, responsibilities and due dates to achieve compliance with Brazilian legal OHS standard requirements (NRs). Also, the company will conduct an OHS risk assessment in Conquista de Minas mill and provide a corrective action plan, to be agreed with IFC, of the risks identified in the order of priority. The local fire department approved the firefighting project design for two of Delta mills. At the time of the appraisal the approved projects for Delta and Volta Grande units were being implementing. In the case of Conquista de Minas mill, Delta submitted the firefighting system project for approval.
Workers Engaged by Third Parties - Delta does not outsource workers for any significant portion of its own operations. For example, the company does not outsource the little manual cutting that is still required for harvesting cane on its land. The principal employers of third-party workers in its supply chain include independent cane growers (see below under “Supply Chain”) and specialized workers engaged in maintenance and refurbishment of Delta’s plants, including boilers, particularly in the non-harvest season. All third-party workers engaged at Delta’s plants undergo a one-day orientation on EHS policies and worker safety and occupational health procedures. Delta requires proof of appropriate training or certification for third-parties hired for specialized skills or to carry out hazardous activities (work in high temperature settings, work at heights or in confined spaces etc.), and it has a comprehensive system for issuing, supervising, and verifying work involving hazardous activities.
Supply Chain – As indicated above, Delta sources approximately one-third of the sugarcane processed at its mills from third-party growers, who plant sugarcane both on their own land and on land ceded to them by the company under multi-year leasing contracts. These growers in turn hire and manage their own workforce and machinery. Third-party growers have also undergone the above-mentioned transition to mechanization, eliminating the need for temporary (often migrant) manual labor for planting an
d/or harvesting sugarcane. As part of its contracting process, Delta screens its third-party growers and requires them to submit valid documentation regarding land ownership, conformity with state and federal environmental regulations, and compliance with Brazilian labor law and worker health and safety regulations. It assists growers to remain in compliance with such laws and regulations in the event they change by providing information and directing them to appropriate professional services (for example, the Brazilian forest code has recently been revised, which will affect some growers). Growers who are not in compliance with such requirements are not contracted, or their contracts are not renewed. Delta does hire third-party contractors to carry out large-scale maintenance and refurbishment of its plants, particularly during the periods between harvests.
Delta employs 6,051 permanent workers in its three units. These are divided between roughly 5,322 men (concentrated in the agricultural and industrial sectors) and 729 women (concentrated in administration and some agricultural and sales functions). Through the mechanization of its planting and harvesting operations, Delta has sought to eliminate the use of temporary agricultural workers and transition low-skill workers (e.g. cane cutters) into higher-skill roles, such as equipment operators through an active selection, training, and retention effort. This has helped Delta to address a major source of turnover and labor grievances and to develop a stronger, long-term relationship with its agricultural workforce.
Brazil’s constitution and legal system protect the rights of workers to associate, organize, enter into collective bargaining agreements, and strike, if necessary. Delta respects worker rights and promotes an open and highly constructive relationship with its workforce. Six unions represent the agricultural workers and processing plant workers at Delta’s three facilities, and membership levels are high (85-95%). Delta seeks to avoid any adverse legal action by current or former workers and aims to settle such claims amicably.
The company earned good-practice certifications under a federal campaign known as the National Commitment to Improve Working Conditions in the Sugarcane Sector. Also, in response to detecting a problem of high turnover, the company has invested in hiring a corporate-level HR manager, launching new training programs and leadership development efforts, and seeking to retrain relatively low-skill agricultural workers as operators for mechanized harvesters and other equipment. These efforts have yielded a significant drop in Delta''s labor turnover as a result.
Worker’s Organizations - As defined by
law in Brazil, all workers have to contribute to their respective sector labor union. Annual salary increase, sector-specific minimum wage and some benefits are negotiated directly with the unions under collective bargaining agreements, but respecting the minimum standards defined by the Federal Administration. There is no evidence that the company restricts workers’ freedom of association.
Non-Discrimination and Equal Opportunity – Delta has a stated commitment to non-discrimination and equal opportunity, and it reports ongoing efforts to comply with various Brazilian legal requirements, including employment targets for persons with disabilities (according to Brazilian Federal Law 8213/1991), for which it still falls short. Its workforce is approximately 12% women, which compares favorably with other companies in the sugar and ethanol sector.
Retrenchment – No retrenchment is expected under this project, but if it were to happen, Delta would be required to follow Brazilian legal requirements that include negotiation of a collective agreement with unions.
Grievance Mechanism – Delta has channels for worker grievances through anonymous suggestion boxes and through recourse to confidential workplace counsellors in the event that a worker does not feel comfortable raising grievances directly with a supervisor. Grievances can also be submitted externally through either the labor unions or the public labor rights system (Justiça do Trabalho). As part of the ESAP, Delta will formalize its current internal grievance practices as a holistic worker grievance mechanism and publicize its functioning, including confidentiality provisions, widely among the workforce.
Protecting the Work Force – With the mechanization of the planting and harvest of sugarcane, which has now reached some 95 percent within Delta’s operations, the company no longer has to hire temporary agricultural workers, such as cane-cutters. In the past such workers would often come from other parts of Brazil (especially northern Minas Gerais and states in the Northeast) and were traditionally the most vulnerable to forced labor by third-party foremen who organized and transported work crews from elsewhere. In order to avoid such problems, Delta has in recent years established an in-house recruitment team in labor-sending regions for identifying potential recruits, conducting all pre-employment screening (including medical exams), securing the necessary permits from local Ministry of Labor offices for contracting migrant workers (the so-called Certidão Liberatória), and transporting workers to southwestern Minas Gerais (and paying for their return travel at harvest’s end). In 2014, Delta will discontinue hiring migrant labor, and it intends to hire locally the 100-150 temporary agricultural workers it estimates it will require.
The company is among those at the forefront in setting progressive labor standards in Brazil. They have established labor requirements, already included in the
contracts with its suppliers, and set up a lodge to accommodate the relatively few migrant workers hired by the company. Out-growers and independent suppliers are required to respect Brazilian legal prohibitions against child labor, and Delta Group ensures that no child labor is used at its operations through the company''s hiring and selection procedure. Specifically, the company complies with legal minimum age of work requirements by requesting valid documentation of age in the employee contracting process. IFC noted that the company appears to be rigorous in providing appropriate personal protective equipment (PPE), food services, rest locations, transportation and similar services for its personnel. In addition, both Delta’s own farms and those of suppliers are regularly audited by state and federal labor inspectors, and relatively few and relatively minor infractions have been noted. Regarding its supply chain, Delta is in constant dialogue with suppliers providing technical assistance and monitoring compliance regarding labor and environmental issues. Delta checks if its suppliers are on the so-called "black list" for forced labor or other inhumane working conditions (the Brazilian Ministry of Labor discloses a list of companies engaged in forced labor or other inhumane practices every six months). The company conducted a supplier baseline E&S assessment and database through a questionnaire and a workshop, which led to the inclusion of specific E&S provisions in the contracts with suppliers. The company also developed a code of conduct for suppliers to sign as part of their purchasing agreements.
Occupational Health and Safety – The company implements Brazilian Regulatory Norms (NRs) applicable to its operations including those related to the identification and monitoring of environmental hazardous agents through a Workplace Environmental Risk Prevention Program or PPRA (Programa de Prevenção de Riscos Ambientais), use of Personal Protective Equipment (PPE), emergency preparedness and response, and medical surveillance (PCMSO or Programa de Controle Médico de Saúde Ocupacional), besides trained people to help in emergencies. The legally required safety committees (CIPA and CIPATR or Comissão Interna de Prevenção de Acidentes and Comissão Interna de Prevenção de Acidentes no Trabalho Rural, respectively), which include representatives from workers, responsible for conducting preventive OHS inspections, reporting on health and safety issues encountered during work, investigating and analyzing occupational accidents, incidents, and health issues and helping ensure that the OHS training activities are completed. The Lost Time Injury Frequency Rate (LTIFR) considering number of injuries with lost days per 1 million worked hours at the three mills (1.94 at Delta mill, 5.91 at Volta Grande mill and 3.04 at Conquista de Minas mill) are below the international reference for the sugar manufacturing sector of 7.0. Delta has also adopted comprehensive
procedures for hazardous materials and pesticides. Delta developed a procedure for working inside confined spaces consistent with Brazilian safety requirements (NR33) and WBG’s EHS general guidelines. The company had also done an inventory of pressure vessels, has the technical specifications and maintains maintenance books for individual pressure vessels in accordance with the relevant Brazilian safety standard (NR13). Besides, Delta conducted a safety assessment for working with electrical facilities (according to Brazilian standard NR10) and kept the electric installment archives for all units. However, as set forth in the ESAP, these baseline assessments will be updated and the investments needed to fill the gaps will be planned by the company. For the units owned by Delta (Delta and Volta Grande mills), Delta will develop a corrective action plan including activities, responsibilities and due dates to achieve compliance with Brazilian legal OHS standard requirements (NRs). Also, the company will conduct an OHS risk assessment in Conquista de Minas mill and provide a corrective action plan, to be agreed with IFC, of the risks identified in the order of priority. The local fire department approved the firefighting project design for two of Delta mills. At the time of the appraisal the approved projects for Delta and Volta Grande units were being implementing. In the case of Conquista de Minas mill, Delta submitted the firefighting system project for approval.
Workers Engaged by Third Parties - Delta does not outsource workers for any significant portion of its own operations. For example, the company does not outsource the little manual cutting that is still required for harvesting cane on its land. The principal employers of third-party workers in its supply chain include independent cane growers (see below under “Supply Chain”) and specialized workers engaged in maintenance and refurbishment of Delta’s plants, including boilers, particularly in the non-harvest season. All third-party workers engaged at Delta’s plants undergo a one-day orientation on EHS policies and worker safety and occupational health procedures. Delta requires proof of appropriate training or certification for third-parties hired for specialized skills or to carry out hazardous activities (work in high temperature settings, work at heights or in confined spaces etc.), and it has a comprehensive system for issuing, supervising, and verifying work involving hazardous activities.
Supply Chain – As indicated above, Delta sources approximately one-third of the sugarcane processed at its mills from third-party growers, who plant sugarcane both on their own land and on land ceded to them by the company under multi-year leasing contracts. These growers in turn hire and manage their own workforce and machinery. Third-party growers have also undergone the above-mentioned transition to mechanization, eliminating the need for temporary (often migrant) manual labor for planting an
d/or harvesting sugarcane. As part of its contracting process, Delta screens its third-party growers and requires them to submit valid documentation regarding land ownership, conformity with state and federal environmental regulations, and compliance with Brazilian labor law and worker health and safety regulations. It assists growers to remain in compliance with such laws and regulations in the event they change by providing information and directing them to appropriate professional services (for example, the Brazilian forest code has recently been revised, which will affect some growers). Growers who are not in compliance with such requirements are not contracted, or their contracts are not renewed. Delta does hire third-party contractors to carry out large-scale maintenance and refurbishment of its plants, particularly during the periods between harvests.
Resource Conservation – Sugarcane cultivation in Delta operations rely on natural rainfall and irrigation using wastewater (ref. fertirrigation) generated from its industrial processes. Water consumption for industrial purposes from surface or groundwater sources is about 222L/s at Delta Mill and the company has obtained permits from the state government of Minas Gerais (IGAM – Instituto Mineiro de Gestão das Águas) or from the federal agency (ANA – Agência Nacional de Águas) to extract the water.
Both surface and groundwater are monitored during dry and wet seasons. Water Treatment Plant (WTP) capacity at Delta mill will increase from 260m3/h to around 470m3/h with the expansion.
Water consumption per tonne of cane crushed per unit per year for the three mills is 0.75m3/ton cane, and is consistent the WBG’s EHS Sugar Manufacturing Guidelines reference and benchmark in the sector. Considering disaggregated data for each mill, water consumption at Delta mill is 0.96m3/ton cane, while at Volta Grande is 0.78m3/ton cane and at Conquista de Minas is 0.51m3/ton cane.
Wastewater – Effluents from mill include: (i) process wastewater from ethanol production (vinasse), (ii) wastewater from cane washing, (iii) wet scrubber blow down from stack gas scrubbing (circulating in a closed cycle), and (iv) miscellaneous wastewaters.
Wastewater is used as a fertilizer in the sugarcane plantations under a ferti-irrigation system. The decantation lagoons in Delta’s unit were being expanded during the appraisal. Delta will, as part of the requirements under Brazilian regulation, line all unlined ponds and vinasse channels with High Density Polyethylene blankets. At the mill, effluents are used in irrigating fields within a radius of 15 kilometers. Delta has a formal management procedure and plan for vinasse application in the field. The amount of wastewater applied in the plantations is determined by the soil characteristics and the nutrient needs of the crop.
Storm and industrial drainage systems are segregated. The company has recently obtained a permit to lowering the water table at the Delta unit to avoid impacts since there are water insurgencies near the stream Ponte Alta. Sanitary effluents are conducted to stabilization ponds (called facultative ponds) where they are monitored before reuse. The runoff is conducted to sedimentation and sugarcane water wash treatment tanks, after primary treatment systems remove of oil and grease. Wastewater from workshops is piped to primary treatment systems to separate oil and grease from water. Delta will review the dimension and maintenance of these boxes. The potential impacts related to truck washing are mitigated by segregated drainage system and safety procedures. Secondary containment systems are built around fuel tanks and fuel dispensing areas. Delta will ensure that the bagasse piles have waterproof flooring and segregated drainage system.
Delta will ensure all wastewater tanks and areas with potential to
contaminate the soil and waters are protected with waterproofed cover in the three mills.
As set at the ESAP, Delta will conduct a gap analysis comparing existing practices of storage and application of vinasse and wastewater with DN COPAM 164/2011. Also, the company will compare existing wastewater quality with World Bank Group EHS guidelines requirements and develop a Corrective Action Plan to meet the gaps.
Energy Efficiency - Energy efficiency is a key aspect of the business strategy of the company. Delta generates all its energy demands through co-generation of electricity from burning bagasse and sells the excess energy not used for its own consumption. Besides the existing substation (69kV) at the Delta sugar mill, the project includes the installation of a new substation of 138kV and its interconnection to the grid through a transmission line of 138kV and 15km long.
Solid wastes – Sugarcane bagasse is the main solid waste generated in Delta’s mills and is used as fuel (feedstock) in boilers to generate energy. Delta has put in place environmental programs and procedures to reduce the amount of industrial wastes, converting them in fertilizers for the sugarcane plantations. The company makes organic composting (approximately 20 to 40 kg of filter cake per ton of processed sugarcane) with wastes from filters, ashes from boilers and sediments from wastewater treatment systems. These are taken to a composting area where they are mixed and left to rest for 30 days and then applied to the fields. Delta will ensure that all composting areas have segregated drainage systems. Delta collects back all empty containers of pesticides and sends it to certified recycling companies. The recyclables - mainly paper and paperboard, plastic material, metal scrap, wood scrap, used lamps and tires - are segregated, stored outdoors and sold for recycling. Delta will improve solid wastes temporary storage following Brazilian standards in its units. Sanitary solid wastes are collected and disposed in an internal landfill in Delta unit following the legal requirements to the local public waste system.
Integrated Pest Management – The company has established an Integrated Pest Management plan, which is followed at all plantations. The company uses biological control techniques to control sugar cane borer population with the Cotesia flavipes parasite and engages in Drury larvae control with Metharizium fungus. Only approved chemicals and fertilizers are used, and application rates and methods are adapted to optimize usage.
Hazardous Materials – Large volumes of ethanol are stored in carbon-steel tanks grounded and protected against inadvertent ignition. The tanks have containment basins big enough to hold all the stored volume capacity. Small amounts of ethanol are contained in carbon-steel gallons, away from heat sources, in ventilated areas with protected electrical installations and grounding systems. Sugar is stored in brickwork warehouses, with waterpr
oofed floor. Aerial tanks for caustic soda, sulfuric acid, bactericidal, antifoulants, defoamers and phosphoric acid have containment basins as well as compacted and waterproofed floor. Other chemicals used in production are stored indoors, with warning signs, in areas floored with waterproofed cover, with emergency equipment and access control. The pesticides storehouse is safe, contained, with hazardous warnings and the proper PPEs are provided to the workers who handle pesticides. The MSDSs are available to the workers in the chemical storage areas. As set forth in the ESAP, Delta will ensure that all containment areas of hazardous materials are well dimensioned, will improve warning signs and floor with waterproofed cover in the three mills and guarantee access control accordingly with following Brazilian standards. Besides, gas cylinders storage areas in all units need to follow Brazilian standards.
Ambient Noise - Delta monitors the ambient noise within the perimeters of its three mills. The results are consistent with national standards.
Air Emissions – The main sources of direct air emissions are the boilers (particulates, NOx and CO). The main sources of fugitive air emissions are the unloading of sugar cane (particulates), transportation (particulates, NOx, SOx and CO) and bagasse piles (particulates). Currently, high efficiency gas scrubbers control air pollution in relation to the environmental standards for particulate matter emissions from biomass boilers. Delta monitors particulate emissions from all boilers at the Delta mill and particulate emissions and NOx at the Volta Grande and Conquista de Minas mills on a yearly basis, seeking compliance with state requirements (COPAM Resolutions 11/1986 and 01/92) that set limits for particulates at 600 mg/Nm3.
In addition to the particulate emissions that the company already monitors at the Delta mill, Delta will also monitor NOx at all its units, seeking compliance with CONAMA Resolution 436/2011 requirements that set limits for particulates at 450 mg/Nm3 for boilers with a thermal input between 50 and 100 MW and at 390 mg/Nm3 for boilers with a thermal input greater than 100 MW; and for NOx at 350 mg/Nm3 in both situations.
Greenhouse Gas Emissions – Boilers are the single largest source of air emissions from Delta’s operations. Delta generates all of its energy from sustainable resources through co-generation of electricity from burning bagasse, and some of the mills sell the exceeding energy to the national grid. Since the sugarcane biomass is a renewable source of energy, the net emissions of GHGs are minimal. Also, considering that it is renewable energy from sugarcane plantations, most of Delta’s GHGs emissions are recaptured from the atmosphere by growing sugarcane and therefore naturally offset.
Both surface and groundwater are monitored during dry and wet seasons. Water Treatment Plant (WTP) capacity at Delta mill will increase from 260m3/h to around 470m3/h with the expansion.
Water consumption per tonne of cane crushed per unit per year for the three mills is 0.75m3/ton cane, and is consistent the WBG’s EHS Sugar Manufacturing Guidelines reference and benchmark in the sector. Considering disaggregated data for each mill, water consumption at Delta mill is 0.96m3/ton cane, while at Volta Grande is 0.78m3/ton cane and at Conquista de Minas is 0.51m3/ton cane.
Wastewater – Effluents from mill include: (i) process wastewater from ethanol production (vinasse), (ii) wastewater from cane washing, (iii) wet scrubber blow down from stack gas scrubbing (circulating in a closed cycle), and (iv) miscellaneous wastewaters.
Wastewater is used as a fertilizer in the sugarcane plantations under a ferti-irrigation system. The decantation lagoons in Delta’s unit were being expanded during the appraisal. Delta will, as part of the requirements under Brazilian regulation, line all unlined ponds and vinasse channels with High Density Polyethylene blankets. At the mill, effluents are used in irrigating fields within a radius of 15 kilometers. Delta has a formal management procedure and plan for vinasse application in the field. The amount of wastewater applied in the plantations is determined by the soil characteristics and the nutrient needs of the crop.
Storm and industrial drainage systems are segregated. The company has recently obtained a permit to lowering the water table at the Delta unit to avoid impacts since there are water insurgencies near the stream Ponte Alta. Sanitary effluents are conducted to stabilization ponds (called facultative ponds) where they are monitored before reuse. The runoff is conducted to sedimentation and sugarcane water wash treatment tanks, after primary treatment systems remove of oil and grease. Wastewater from workshops is piped to primary treatment systems to separate oil and grease from water. Delta will review the dimension and maintenance of these boxes. The potential impacts related to truck washing are mitigated by segregated drainage system and safety procedures. Secondary containment systems are built around fuel tanks and fuel dispensing areas. Delta will ensure that the bagasse piles have waterproof flooring and segregated drainage system.
Delta will ensure all wastewater tanks and areas with potential to
contaminate the soil and waters are protected with waterproofed cover in the three mills.
As set at the ESAP, Delta will conduct a gap analysis comparing existing practices of storage and application of vinasse and wastewater with DN COPAM 164/2011. Also, the company will compare existing wastewater quality with World Bank Group EHS guidelines requirements and develop a Corrective Action Plan to meet the gaps.
Energy Efficiency - Energy efficiency is a key aspect of the business strategy of the company. Delta generates all its energy demands through co-generation of electricity from burning bagasse and sells the excess energy not used for its own consumption. Besides the existing substation (69kV) at the Delta sugar mill, the project includes the installation of a new substation of 138kV and its interconnection to the grid through a transmission line of 138kV and 15km long.
Solid wastes – Sugarcane bagasse is the main solid waste generated in Delta’s mills and is used as fuel (feedstock) in boilers to generate energy. Delta has put in place environmental programs and procedures to reduce the amount of industrial wastes, converting them in fertilizers for the sugarcane plantations. The company makes organic composting (approximately 20 to 40 kg of filter cake per ton of processed sugarcane) with wastes from filters, ashes from boilers and sediments from wastewater treatment systems. These are taken to a composting area where they are mixed and left to rest for 30 days and then applied to the fields. Delta will ensure that all composting areas have segregated drainage systems. Delta collects back all empty containers of pesticides and sends it to certified recycling companies. The recyclables - mainly paper and paperboard, plastic material, metal scrap, wood scrap, used lamps and tires - are segregated, stored outdoors and sold for recycling. Delta will improve solid wastes temporary storage following Brazilian standards in its units. Sanitary solid wastes are collected and disposed in an internal landfill in Delta unit following the legal requirements to the local public waste system.
Integrated Pest Management – The company has established an Integrated Pest Management plan, which is followed at all plantations. The company uses biological control techniques to control sugar cane borer population with the Cotesia flavipes parasite and engages in Drury larvae control with Metharizium fungus. Only approved chemicals and fertilizers are used, and application rates and methods are adapted to optimize usage.
Hazardous Materials – Large volumes of ethanol are stored in carbon-steel tanks grounded and protected against inadvertent ignition. The tanks have containment basins big enough to hold all the stored volume capacity. Small amounts of ethanol are contained in carbon-steel gallons, away from heat sources, in ventilated areas with protected electrical installations and grounding systems. Sugar is stored in brickwork warehouses, with waterpr
oofed floor. Aerial tanks for caustic soda, sulfuric acid, bactericidal, antifoulants, defoamers and phosphoric acid have containment basins as well as compacted and waterproofed floor. Other chemicals used in production are stored indoors, with warning signs, in areas floored with waterproofed cover, with emergency equipment and access control. The pesticides storehouse is safe, contained, with hazardous warnings and the proper PPEs are provided to the workers who handle pesticides. The MSDSs are available to the workers in the chemical storage areas. As set forth in the ESAP, Delta will ensure that all containment areas of hazardous materials are well dimensioned, will improve warning signs and floor with waterproofed cover in the three mills and guarantee access control accordingly with following Brazilian standards. Besides, gas cylinders storage areas in all units need to follow Brazilian standards.
Ambient Noise - Delta monitors the ambient noise within the perimeters of its three mills. The results are consistent with national standards.
Air Emissions – The main sources of direct air emissions are the boilers (particulates, NOx and CO). The main sources of fugitive air emissions are the unloading of sugar cane (particulates), transportation (particulates, NOx, SOx and CO) and bagasse piles (particulates). Currently, high efficiency gas scrubbers control air pollution in relation to the environmental standards for particulate matter emissions from biomass boilers. Delta monitors particulate emissions from all boilers at the Delta mill and particulate emissions and NOx at the Volta Grande and Conquista de Minas mills on a yearly basis, seeking compliance with state requirements (COPAM Resolutions 11/1986 and 01/92) that set limits for particulates at 600 mg/Nm3.
In addition to the particulate emissions that the company already monitors at the Delta mill, Delta will also monitor NOx at all its units, seeking compliance with CONAMA Resolution 436/2011 requirements that set limits for particulates at 450 mg/Nm3 for boilers with a thermal input between 50 and 100 MW and at 390 mg/Nm3 for boilers with a thermal input greater than 100 MW; and for NOx at 350 mg/Nm3 in both situations.
Greenhouse Gas Emissions – Boilers are the single largest source of air emissions from Delta’s operations. Delta generates all of its energy from sustainable resources through co-generation of electricity from burning bagasse, and some of the mills sell the exceeding energy to the national grid. Since the sugarcane biomass is a renewable source of energy, the net emissions of GHGs are minimal. Also, considering that it is renewable energy from sugarcane plantations, most of Delta’s GHGs emissions are recaptured from the atmosphere by growing sugarcane and therefore naturally offset.
Infrastructure and Equipment Design and Hazardous Materials Management Safety - Potential risks to community safety from Delta’s operations are primarily from explosions of ethanol tanks or sugar storage silos, storage and use of hazardous materials and vehicular traffic. These risks are of special concern at the Delta mill, as the plant is surrounded by a residential area. Both the Volta Grande and Conquista de Minas units are farther from more densely occupied areas, about 15 and 18 km respectively. As set above, the company will develop Emergency Preparedness and Response Plan covering all scenarios of emergency situations for each unit.
As set forth in the ESAP, Delta will develop an updated risk scenarios analysis in order to check if the distance between ethanol tanks and other hazardous storage structures are adequate to future expansion layout or it need to be re-adequate.
Delta has a fleet of 50 harvesters, 80 tractors and 250 trucks (in addition to those ones used by third party contractors) for loading and unloading of raw materials and products. The company provides periodic safe driver training. Besides, Delta will develop and implement a safe driver and transport safety vehicle procedure, including training and monitoring program for its drivers and contractors (to the extent that it is commercially feasible, for the fleet of transportation sub-contractors) emphasizing the following: safety aspects among drivers, improving driver skills, licensing of drivers, provision of this procedure in contractual arrangements, and overall truck maintenance. Delta will provide IFC with documented evidence of the safe driver and transport safety vehicle training procedure and monitoring program; and demonstrate full implementation.
Community Exposure to Diseases – Potential risks to community health from Delta’s farming and processing operations are primarily from air emissions from boilers, fugitive air emissions from trucks (dust) and bagasse piles, aerial application of herbicides (to speed the sugarcane maturation process) and potential risks of soil and water contamination. The company developed a dispersion model for air emissions at its Delta unit, as it is located in an urban setting, but this considers just concentrations of particulates. As set forth in the ESAP, Delta will develop dispersion models for air emissions including NOx and CO as well as particulates for all its operations. Based on the results of this model, the company will make its best effort to ensure that stack emissions are not impacting nearby communities’ health in levels above EHS Guidelines requirements for emissions and ambient air quality. If the results are above the limits, Delta will install and adapt its emissions control equipment to comply with the required levels and ensure no harm is caused to local communities. As stated in the General EHS Guidelines, emissions from a single project should not contribute more than 25% of the applicable ambient air q
uality standards to allow additional, future sustainable development in the same airshed.
Fugitive emissions of particulate materials from bagasse pile at the Delta mill impact residents settled across the road from the plant. The company is planning to move this pile to the opposite side of the site, as far as possible from the nearby residential zone. During the appraisal the pile was covered with a canvas to mitigate the dispersion. Storage of bagasse will be done in areas with waterproof flooring. Aside from manual application of herbicides, the company uses aerial spraying of crops by licensed companies using crop spraying airplanes which follow local regulatory requirements.
Security Personnel - Delta employs an in-house security force of approximately 100 guards (on three rotations) for guarding key access points, such as entrances to their sugar mills and controlling the entry and egress of personnel, suppliers, equipment, and materials (until late 2013, the guards for the Conquista de Minas mill were outsourced to a private security company). All guards are vetted for any past criminal activity or similar disqualifications from service, and according to Brazilian federal regulations governing private security agents, they are trained at accredited training centers and issued certificates by the Ministry of Justice and Federal Police allowing them to serve (the Carteira Nacional de Vigilante, or CNV). These guards are armed with pistols for purposes of self-defense, and as a result, they are required to undergo specialized firearm training and refresher courses every two years at government-authorized training facilities. The Delta guards follow an operational manual issued by the Federal Police governing firearm use, and any firearm discharge must be reported immediately to the police, who then investigates the incident. Aside from reliance on the police for criminal investigations, Delta does not use public security forces for guard or protection services. The company offers occasional in-kind donations (e.g., the use of a Delta water truck to wash vehicles for a parade).
The company has yet to establish a formal human rights and security policy with regard to identification, analysis, and documentation of risks associated with security providers (whether public or private), use of force, and procedures for vetting security personnel (whether in-house or third-party) for any alleged human rights violations or investigating such violations if they were to occur. While Delta does have norms for hiring, training, equipping, and supervising such personnel, as set forth in the ESAP Delta will be required to carry out a security risk assessment and develop appropriate policies and procedures for managing the company’s use of and relationship with security personnel, whether public or private (including either an in-house or third-party guard force), in light of IFC Performance Standard 4. The company is also required to have a written co
de of conduct and appropriate materials on the requirements of PS4 incorporated into the standard training of its security personnel or any third-party security providers it might employ in the future.
As set forth in the ESAP, Delta will develop an updated risk scenarios analysis in order to check if the distance between ethanol tanks and other hazardous storage structures are adequate to future expansion layout or it need to be re-adequate.
Delta has a fleet of 50 harvesters, 80 tractors and 250 trucks (in addition to those ones used by third party contractors) for loading and unloading of raw materials and products. The company provides periodic safe driver training. Besides, Delta will develop and implement a safe driver and transport safety vehicle procedure, including training and monitoring program for its drivers and contractors (to the extent that it is commercially feasible, for the fleet of transportation sub-contractors) emphasizing the following: safety aspects among drivers, improving driver skills, licensing of drivers, provision of this procedure in contractual arrangements, and overall truck maintenance. Delta will provide IFC with documented evidence of the safe driver and transport safety vehicle training procedure and monitoring program; and demonstrate full implementation.
Community Exposure to Diseases – Potential risks to community health from Delta’s farming and processing operations are primarily from air emissions from boilers, fugitive air emissions from trucks (dust) and bagasse piles, aerial application of herbicides (to speed the sugarcane maturation process) and potential risks of soil and water contamination. The company developed a dispersion model for air emissions at its Delta unit, as it is located in an urban setting, but this considers just concentrations of particulates. As set forth in the ESAP, Delta will develop dispersion models for air emissions including NOx and CO as well as particulates for all its operations. Based on the results of this model, the company will make its best effort to ensure that stack emissions are not impacting nearby communities’ health in levels above EHS Guidelines requirements for emissions and ambient air quality. If the results are above the limits, Delta will install and adapt its emissions control equipment to comply with the required levels and ensure no harm is caused to local communities. As stated in the General EHS Guidelines, emissions from a single project should not contribute more than 25% of the applicable ambient air q
uality standards to allow additional, future sustainable development in the same airshed.
Fugitive emissions of particulate materials from bagasse pile at the Delta mill impact residents settled across the road from the plant. The company is planning to move this pile to the opposite side of the site, as far as possible from the nearby residential zone. During the appraisal the pile was covered with a canvas to mitigate the dispersion. Storage of bagasse will be done in areas with waterproof flooring. Aside from manual application of herbicides, the company uses aerial spraying of crops by licensed companies using crop spraying airplanes which follow local regulatory requirements.
Security Personnel - Delta employs an in-house security force of approximately 100 guards (on three rotations) for guarding key access points, such as entrances to their sugar mills and controlling the entry and egress of personnel, suppliers, equipment, and materials (until late 2013, the guards for the Conquista de Minas mill were outsourced to a private security company). All guards are vetted for any past criminal activity or similar disqualifications from service, and according to Brazilian federal regulations governing private security agents, they are trained at accredited training centers and issued certificates by the Ministry of Justice and Federal Police allowing them to serve (the Carteira Nacional de Vigilante, or CNV). These guards are armed with pistols for purposes of self-defense, and as a result, they are required to undergo specialized firearm training and refresher courses every two years at government-authorized training facilities. The Delta guards follow an operational manual issued by the Federal Police governing firearm use, and any firearm discharge must be reported immediately to the police, who then investigates the incident. Aside from reliance on the police for criminal investigations, Delta does not use public security forces for guard or protection services. The company offers occasional in-kind donations (e.g., the use of a Delta water truck to wash vehicles for a parade).
The company has yet to establish a formal human rights and security policy with regard to identification, analysis, and documentation of risks associated with security providers (whether public or private), use of force, and procedures for vetting security personnel (whether in-house or third-party) for any alleged human rights violations or investigating such violations if they were to occur. While Delta does have norms for hiring, training, equipping, and supervising such personnel, as set forth in the ESAP Delta will be required to carry out a security risk assessment and develop appropriate policies and procedures for managing the company’s use of and relationship with security personnel, whether public or private (including either an in-house or third-party guard force), in light of IFC Performance Standard 4. The company is also required to have a written co
de of conduct and appropriate materials on the requirements of PS4 incorporated into the standard training of its security personnel or any third-party security providers it might employ in the future.
Although no conversion of natural habitats to croplands or significant loss of biodiversity is expected from this project, the company implements a monitoring program of bio indicators as some areas of cultivation are within an environmental protected area, APA do Rio Uberaba, about 30 km distant from Delta mill, or within priority areas for the conservation of flora and avifauna. Nevertheless, Delta''s units are located in areas with low natural vulnerability and with low restrictions regarding the use of natural resources.
Delta is required to set aside 20% of its owned lands as biodiversity conservation areas and also to protect a buffer zone along rivers and water bodies. In order to comply with provisions in the Brazilian national forest code for protecting areas of native vegetation, Delta has purchased an offset area of 7,342 ha in Chapada Gaucha (in the north of Minas Gerais state) covered with intact Cerrado vegetation established as the required Legal Reserve for its three units under National Forest Code. Delta also has a program to reforest riparian areas at owned and leased farms, to monitor some fauna indicators, and to recover preservation areas aimed at creating ecological corridors.
Delta has already conducted a pre-assessment of its conformity to the Bonsucro standard but has not yet obtained independent verification or certification. As set at the ESAP, the company will prepare a gap analysis and deliver an Action Plan detailing the actions, responsibilities and due dates for closing the identified gaps for procuring a Bonsucro certification process.
Delta is required to set aside 20% of its owned lands as biodiversity conservation areas and also to protect a buffer zone along rivers and water bodies. In order to comply with provisions in the Brazilian national forest code for protecting areas of native vegetation, Delta has purchased an offset area of 7,342 ha in Chapada Gaucha (in the north of Minas Gerais state) covered with intact Cerrado vegetation established as the required Legal Reserve for its three units under National Forest Code. Delta also has a program to reforest riparian areas at owned and leased farms, to monitor some fauna indicators, and to recover preservation areas aimed at creating ecological corridors.
Delta has already conducted a pre-assessment of its conformity to the Bonsucro standard but has not yet obtained independent verification or certification. As set at the ESAP, the company will prepare a gap analysis and deliver an Action Plan detailing the actions, responsibilities and due dates for closing the identified gaps for procuring a Bonsucro certification process.
Even though no conversion of unoccupied areas is expected from this project, the Triângulo Mineiro region is noted for paleontological, archaeological and historical heritage occurrences. Studies conducted both for environmental licensing processes of the company''s projects as well as other projects in the region indicated that two paleontological sites are within the cultivation polygon area of the Delta mill, but not directly located on land cultivated with sugarcane. Also, among the archaeological sites registered by the Federal Historical and Artistic Heritage Institute (IPHAN – Instituto do Patrimônio Histórico e Artístico Nacional) in the state of Minas Gerais, there are seventeen located in Conquista municipality. One of them was encountered within the Conquista de Minas unit, and it consists of fragments of lithic ceramic (pre-colonial). These fragments were collected during the construction of the Igarapava hydroelectric power plant by CEMIG (energy company in Minas Gerais state). Delta will ensure that no activities will be conducted at known paleontological and archeological sites; in case this is unavoidable, the company will conduct additional local studies and guarantee the collection of representative fragments, its conservation and disclosure, following Brazilian standards. Delta will establish a Chance Find Procedure to be applied in these cases.
Stakeholder Engagement
Delta has a significant, multi-faceted approach to stakeholder engagement at various levels. Through its corporate affairs manager, the company maintains open, frequent contact with the mayors of the three municipalities in which it operates, and the company staff accompanies local policy discussions in the municipal councils as well. Public-private partnerships have been crafted with municipal authorities for the construction of low-income housing on land provided by Delta (under the provisions of the Minha Casa, Minha Vida federal program), and the company has donated land for a water treatment plant in Delta municipality. It has also engaged in PPPs with state and municipal transportation authorities to pave or otherwise upgrade local roads, including the construction of a by-pass on roadway MG-427 to divert the traffic of heavy trucks entering and exiting the Volta Grande mill away from non-mill traffic. The company also collaborates closely with public vocational training institutes to provide specialized training to both Delta and non-Delta on skills relevant to the sugar and ethanol sector. Through its philanthropic and community investment initiatives, the company supports a wide range of local initiatives, including a sports and cultural center in the town of Delta, adult education, and early childhood activities. In addition, as a requirement of financing received from BNDES, the Brazilian development bank, Delta is required to direct approximately R$1 million toward community investments in its area of operations.
As noted above under PS1, Delta also has developed a number of channels for communication with stakeholders, particularly via its toll-free relationship management call-in telephone number. A wide range of interlocutors, including those outside of the company, expressed great support for its activities, particularly given Delta’s important role in local employment and stimulating local commerce and economic development through the wages and taxes it pays and the goods and services it procures.
As set forth in the ESAP, Delta will develop a comprehensive Stakeholder Engagement Plan that includes (1) identification of all stakeholders in relation to the impacts and risks they face, (2) proposed communication modalities with each stakeholder category in a differentiated fashion based on impacts, risks, and needs, (3) community investment plans based on appropriate stakeholder consultation and participation and on good international industry practice, including the IFC’s own Strategic Community Investment Guide, (4) its external grievance mechanism, and (5) its external reporting plans. An updated annual Stakeholder Engagement Workplan will be elaborated in each subsequent year, including progress and shortcomings in implementing the previous year’s Workplan and concrete actions envisioned for the coming year, taking into account any need for changes in strategy.
As noted above under PS1, Delta also has developed a number of channels for communication with stakeholders, particularly via its toll-free relationship management call-in telephone number. A wide range of interlocutors, including those outside of the company, expressed great support for its activities, particularly given Delta’s important role in local employment and stimulating local commerce and economic development through the wages and taxes it pays and the goods and services it procures.
As set forth in the ESAP, Delta will develop a comprehensive Stakeholder Engagement Plan that includes (1) identification of all stakeholders in relation to the impacts and risks they face, (2) proposed communication modalities with each stakeholder category in a differentiated fashion based on impacts, risks, and needs, (3) community investment plans based on appropriate stakeholder consultation and participation and on good international industry practice, including the IFC’s own Strategic Community Investment Guide, (4) its external grievance mechanism, and (5) its external reporting plans. An updated annual Stakeholder Engagement Workplan will be elaborated in each subsequent year, including progress and shortcomings in implementing the previous year’s Workplan and concrete actions envisioned for the coming year, taking into account any need for changes in strategy.
Delta Office:
Av. José Agostinho Filho, 750 - Centro
38108-000
Delta, MG - Brazil
Av. José Agostinho Filho, 750 - Centro
38108-000
Delta, MG - Brazil
Broad Community Support
Broad Community Support is not applicable for this project
Environmental & Social Action Plan
| Usina Delta(34394) Supervision Disclosure Snapshot – Version 3 | ||||
|---|---|---|---|---|
| Description | Anticipated Completion Date | Status | Comments | Completion Date |
| Consolidate an integrated Environmental and Social Management System (ESMS) at the corporate level consistent with Brazilian laws and regulations, applicable WBG EHS Guidelines and IFC Performance Standards and the Bonsucro international standards. | 31-Dec-2021 | In progress | Due date revised as agreed with IFC Client | |
| Amend induction training to management on EHSS aspects applicable to the job tasks focusing on aspects such as: hazardous materials and hazardous wastes management, solid waste recycling management, gas cylinders management, housekeeping practices and electrical safety amongst other issues. | 28-Feb-2019 | Completed | Completed | 10/28/2016 |
| Define a comprehensive set of Key Performance Indicators (KPIs) in order to monitor on a monthly/annual basis the following EHS parameters: a) Safety; b) Sustainability; c) Staff. | 29-Feb-2016 | Completed | Completed | 10/28/2016 |
| Define an integrated EHS report format and based on critical EHS KPIs (e.g., compliance with Brazilian legal and regulatory requirements, EHS management system progress report and certification). | 29-Feb-2016 | Completed | Completed | 3/30/2021 |
| Report annually to relevant Brazilian authorities and IFC as part of the Annual Monitoring Report (AMR). Annual EHS review will be discussed during the Company’s planning and budgetary management review. | 29-Feb-2016 | Completed | Completed | 10/28/2016 |
| Formalize its external reporting to affected communities, on at least a yearly basis, in relation to the identified risks, mitigation measures, regular monitoring of progress or difficulties encountered in its implementation of such measures, and other aspects of its environmental and social performance. | 29-Feb-2016 | Completed | Completed | 11/30/2020 |
| Restructure its current external relationship management system into a formal grievance mechanism and publicize the multiple channels for accessing it, including the toll-free number. | 31-Aug-2015 | Completed | Completed | 10/30/2015 |
| Formalize its current internal grievance practices as a holistic worker grievance mechanism and publicize its functioning, including confidentiality provisions, widely among the workforce. | 31-Aug-2015 | Completed | Completed | 10/30/2015 |
| Obtain the approval from the firefighting authority for the project of the firefighting system of Conquista de Minas mill. | 27-Feb-2015 | Completed | Completed | 2/16/2015 |
| Develop a corrective action plan including activities, responsibilities and due dates to achieve compliance with Brazilian legal OHS standard requirements (NRs) for the units owned by Delta (Delta and Volta Grande mills). | 31-Jul-2015 | Completed | Completed | 7/30/2015 |
| Conduct an OHS risk assessment in Conquista de Minas mill and provide a corrective action plan, to be agreed with IFC, of the risks identified in the order of priority. | 31-Jul-2015 | Completed | Completed | 7/30/2015 |
| Ensure compliance with DN 164/2011 and applicable EHS Guidelines related to ponds and vinasse channels. | 31-Aug-2016 | Completed | Completed | 9/30/2016 |
| Conduct a gap analysis comparing existing wastewater quality with World Bank/IFC EHS guidelines requirements and develop a Corrective Action Plan to meet the gaps. | 31-Aug-2016 | Completed | Completed | 11/30/2020 |
| Ensure that the bagasse piles have waterproof flooring and segregated drainage system. | 31-Aug-2016 | Completed | Completed | 9/30/2016 |
| Review the dimension and maintenance of boxes to remove of oil and grease. | 31-Aug-2016 | Completed | Completed | 9/30/2016 |
| Ensure that all composting areas have segregated drainage systems. | 31-Aug-2016 | Completed | Completed | 10/28/2016 |
| Improve solid wastes temporary storage following Brazilian standards. | 31-Aug-2016 | Completed | Completed | 9/2/2016 |
| Ensure that all containment areas of hazardous materials are well dimensioned. | 31-Aug-2015 | Completed | Completed | 10/28/2016 |
| Improve warning signs and floor with waterproofed cover and guarantee access control accordingly with following Brazilian standards. | 31-Aug-2015 | Completed | Completed | 10/28/2016 |
| Improve gas cylinders storage areas in all units to follow Brazilian standards. | 31-Aug-2015 | Completed | Completed | 10/28/2016 |
| Monitor NOx at Delta units, besides particulate emissions that the Company already monitors, seeking compliance with CONAMA Resolution 436/2011 requirements. | 27-Feb-2015 | Completed | Completed | 2/27/2015 |
| Develop an update risk scenarios analysis in order to check if the distance between ethanol tanks and other hazardous storage structures are adequate to future expansion layout or it need to be re-adequate. | 25-Feb-2017 | Completed | Completed | 3/13/2020 |
| Develop dispersion models for air emissions considering NOx and CO as well as particulates for all its operations. Based on the results of this model, the Company will make the its best efforts to ensure that stack emissions are not impacting nearby communities’ health in levels above EHS Guidelines requirements for emissions and ambient air quality. If the results are above the limits, Delta will install and adapt its emissions control equipment to comply with the required levels and ensure no harm is caused to local communities.degrading air quality (higher than those defined in CONAMA Resolution 03/90, Secondary Threshold ). As stated in the General EHS Guidelines, emissions from a single project should not contribute more than 25% of the applicable ambient air quality standards to allow additional, future sustainable development in the same airshed. | 31-Aug-2015 | Completed | Completed | 10/28/2016 |
| Develop and implement a safe driver and transport safety vehicle procedure, including training and monitoring program for its drivers and contractors (to the extent that it is commercially feasible, for the fleet of transportation sub-contractors) emphasizing the following: safety aspects among drivers, improving driver skills, licensing of drivers, provision of this procedure in contractual arrangements, and overall truck maintenance. Provide IFC with documented evidence of the safe driver and transport safety vehicle training procedure and monitoring program; and demonstrate full implementation. | 27-Feb-2015 | Completed | Completed | 2/27/2015 |
| Carry out a security risk assessment and develop appropriate policies and procedures for managing the company’s use of and relationship with security personnel in light of IFC PS4. | 27-Feb-2015 | Completed | Completed | 2/27/2015 |
| Develop a written code of conduct and appropriate materials on the requirements of PS4 incorporated into the standard training of its security personnel or any third-party security providers it might employ in the future. | 29-Feb-2016 | Completed | Completed | 3/30/2021 |
| Prepare a gap analysis and deliver an Action Plan detailing the actions and due dates for closing the identified gaps for procuring a Bonsucro certification process. | 31-Jul-2022 | In progress | Due date revised as agreed with IFC Client | 7/30/2015 |
| Establish a Chance Find Procedure to be applied in cases activities will be conducted at known paleontological and archeological sites, to conduct additional local studies and guarantee the collection of representative traces, its conservation and disclosure, following Brazilian standards. | 29-Feb-2016 | Completed | Completed | 2/24/2016 |
| Develop a comprehensive Stakeholder Engagement Plan that includes (1) identification of all stakeholders in relation to the impacts and risks they face, (2) proposed communication modalities with each stakeholder category in a differentiated fashion based on impacts, risks, and needs, (3) community investment plans based on appropriate stakeholder consultation and participation and on good international industry practice, including the IFC’s own Strategic Community Investment Guide, (4) its external grievance mechanism, and (5) its external reporting plans. An updated annual Stakeholder Engagement Workplan will be elaborated in each subsequent year, including progress and shortcomings in implementing the previous year’s Workplan and concrete actions envisioned for the coming year, taking into account any need for changes in strategy. | 31-Aug-2015 | Completed | Completed | 10/30/2015 |
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**Information on IFC's Policy and Performance Standards on Environmental and Social Sustainability can be found at www.ifc.org/sustainability
IFC supports its clients in addressing environmental and social issues arising from their business activities by requiring its real sector clients to set up and administer appropriate grievance mechanisms and/or procedures to address complaints from Affected Communities in relation to environmental and social issues arising from IFC's clients' business activities. Since 2012, IFC's Financial Intermediary clients applying the Performance Standards are required to develop External Communications Mechanisms to receive and review inquiries or complaints from any interested party regarding the E&S risks and impacts of their operations.
For IFC projects that are active or under consideration, individual(s), or their authorized representative(s), who allege they have been or will be adversely affected by E&S risks or impacts arising from IFC's clients' business activities, may submit a complaint to IFC directly for consideration. When receiving an E&S complaint, IFC engages with complainants and works with its clients to find solutions to E&S concerns as quickly and efficiently as possible.
Complaints can be submitted to IFC online at www.ifc.org/escomplaints or by email to EScomplaints@ifc.org.
IFC complaint response is separate from and complementary to IFC’s clients’ project level grievance mechanisms and IFC’s Independent Accountability Mechanism (CAO). Lodging a complaint directly with IFC does not, at any time, restrict access to CAO.
Affected communities have unrestricted access to the Compliance Advisor Ombudsman (CAO), the independent accountability mechanism for IFC and MIGA. CAO facilitates the resolution of complaints related to IFC and MIGA projects and sub-projects, undertakes reviews of IFC’s and MIGA’s environmental and social compliance, fosters public accountability for their commitments, and enhances the environmental and social performance of IFC and MIGA.
Independent of IFC and MIGA management and reporting directly to the IFC and MIGA Boards of Executive Directors, CAO helps resolve issues raised about the environmental and social impacts of projects through a neutral, collaborative, problem-solving approach via its Dispute Resolution function. It also reviews IFC’s and MIGA’s compliance with environmental and social policies, assesses related harm, and recommends remedial actions through its Compliance function. Additionally, CAO provides advice to IFC, MIGA, and their Boards to enhance environmental and social sustainability performance and minimize the risk of harm.
Complaints may relate to environmental and social harm regarding any aspect of the planning, implementation, or impact of a project or sub-project, and can be made by any individual, group, community, entity, or other party affected or likely to be affected by the environmental or social impacts of an IFC- or MIGA-financed business activity.
Complaints can be submitted by any of the following methods:
CAO receives and addresses complaints in accordance with the CAO Policy, which can be accessed at: https://www.cao-ombudsman.org/policies-guidelines.
IFC supports its clients in addressing environmental and social issues arising from their business activities by requiring its real sector clients to set up and administer appropriate grievance mechanisms and/or procedures to address complaints from Affected Communities in relation to environmental and social issues arising from IFC's clients' business activities. Since 2012, IFC's Financial Intermediary clients applying the Performance Standards are required to develop External Communications Mechanisms to receive and review inquiries or complaints from any interested party regarding the E&S risks and impacts of their operations.
For IFC projects that are active or under consideration, individual(s), or their authorized representative(s), who allege they have been or will be adversely affected by E&S risks or impacts arising from IFC's clients' business activities, may submit a complaint to IFC directly for consideration. When receiving an E&S complaint, IFC engages with complainants and works with its clients to find solutions to E&S concerns as quickly and efficiently as possible.
Complaints can be submitted to IFC online at www.ifc.org/escomplaints or by email to EScomplaints@ifc.org.
IFC complaint response is separate from and complementary to IFC’s clients’ project level grievance mechanisms and IFC’s Independent Accountability Mechanism (CAO). Lodging a complaint directly with IFC does not, at any time, restrict access to CAO.
Affected communities have unrestricted access to the Compliance Advisor Ombudsman (CAO), the independent accountability mechanism for IFC and MIGA. CAO facilitates the resolution of complaints related to IFC and MIGA projects and sub-projects, undertakes reviews of IFC’s and MIGA’s environmental and social compliance, fosters public accountability for their commitments, and enhances the environmental and social performance of IFC and MIGA.
Independent of IFC and MIGA management and reporting directly to the IFC and MIGA Boards of Executive Directors, CAO helps resolve issues raised about the environmental and social impacts of projects through a neutral, collaborative, problem-solving approach via its Dispute Resolution function. It also reviews IFC’s and MIGA’s compliance with environmental and social policies, assesses related harm, and recommends remedial actions through its Compliance function. Additionally, CAO provides advice to IFC, MIGA, and their Boards to enhance environmental and social sustainability performance and minimize the risk of harm.
Complaints may relate to environmental and social harm regarding any aspect of the planning, implementation, or impact of a project or sub-project, and can be made by any individual, group, community, entity, or other party affected or likely to be affected by the environmental or social impacts of an IFC- or MIGA-financed business activity.
Complaints can be submitted by any of the following methods:
- Online form: available at https://www.cao-ombudsman.org/
- Mail/Hand Delivery to: 2121 Pennsylvania Avenue, NW, Washington, DC 20433, USA
- Voice mail: +1 202 458 1973
- Email: cao@worldbankgroup.org
- SMS, WhatsApp, Telegram, and Signal: +1 202 650 2627
CAO receives and addresses complaints in accordance with the CAO Policy, which can be accessed at: https://www.cao-ombudsman.org/policies-guidelines.
This Environmental and Social Review Summary (ESRS) is prepared by IFC to disclose its findings and recommendations related to environmental and social considerations regarding potential investments. Its purpose is to enhance the transparency of IFC's activities. For any project documentation or data included or attached herein, whether prepared by the project sponsor or otherwise, authorization has been given for public release by the project sponsor. IFC considers that this ESRS is of adequate quality for release to the public, but has not necessarily independently verified all of the project information therein.
It is distributed in advance of IFC Board of Directors' consideration and may be periodically updated thereafter. Board dates are estimates only and this document should not be construed as presuming the outcome of the Board Directors’ decision. The following ESRS is disclosed in accordance with IFC's Access to Information Policy (AIP).
The map is for illustrative purposes and does not imply the expression of any opinion on the part of the World Bank, concerning the legal status of any country or territory or concerning the delimitation of frontiers or boundaries. Country borders or names do not necessarily reflect the World Bank Group's official position. In some cases, available project location information is limited to the country of the project's activities. Locations are approximate.
It is distributed in advance of IFC Board of Directors' consideration and may be periodically updated thereafter. Board dates are estimates only and this document should not be construed as presuming the outcome of the Board Directors’ decision. The following ESRS is disclosed in accordance with IFC's Access to Information Policy (AIP).
The map is for illustrative purposes and does not imply the expression of any opinion on the part of the World Bank, concerning the legal status of any country or territory or concerning the delimitation of frontiers or boundaries. Country borders or names do not necessarily reflect the World Bank Group's official position. In some cases, available project location information is limited to the country of the project's activities. Locations are approximate.