Environmental and Social Management System: MPS has a Health, Safety, Security and Environmental (HSSE) overarching Policy, HSSE Management Plan and relevant procedures and guidelines to comply with the Ghanaian requirements and in line with good international industry practice.
The HSSE Policy emphasizes preventative safety measures, training and awareness, emergency response, monitoring and documenting performance. The policy is communicated to employees and contractors.
The HSSE Management Plan provides a management framework for the current terminal operations. Even if MPS is not ISO certified, its management system has been designed to be consistent with requirements of ISO 14001 for environmental management, OHSAS 18001 for occupational health and safety in the workplace, and the International Labour Organization (ILO) Code of Practice in Safety and Health in Ports. As indicated in ESAP action # 1, the company’s HSSE Management System (HSSE MS) and the relevant management plans will be revised and updated for the new terminal. In compliance with IFC’s Performance Standards, management of social aspects and potential impacts will be integrated in the updated HSSE MS. The HSSE MS will take into account the conclusion of the Tema Port ESIA and supplemental E&S studies carried out by the company during the FEED and as agreed with IFC, and will integrate the management programs that will be developed for the construction and operational phases of the project. The key E&S issues and areas to be managed during construction and operations include: i) shoreline management and mitigation of potential erosion and accretion impact in the project area of influence, in coordination with GPHA, including preventing any impacts to the Sakumo Lagoon outfall; ii) capital and maintenance dredging and reclamation - transport and disposal of dredge spoil; iii) storage, handling and disposal of raw material, fuel, chemicals, and waste from construction and operations; iv) air emissions management; v) effluent treatment and discharge; vi) occupational health, safety and security; vii) staff and contractor training; viii) marine ecosystem protection, including sea turtles; ix) contractors’ and subcontractors’ compliance requirements and auditing (particularly working conditions and occupational health and safety issues); x) spill prevention, emergency preparedness and response; xi) stakeholder engagement and grievance mechanism; xii) traffic impact management; xiii) community health, safety and security, including fishermen safety; and xiv) monitoring and reporting on E&S performance.
Environmental and Social Assessment: An Environmental and Social Impact Assessment (ESIA) study of the Tema Port Infrastructure Development was submitted by GPHA to the EPA. The scope of the ESIA was broader than the new terminal development, because it included all the infrastructure expansions which are part of the GPHA’s port master plan. In compliance with EPA requirem
ents, the ESIA study provided a description of the environmental conditions of the area, an assessment of impacts, the identification of the impact mitigation and management measures, environmental monitoring and the definition of a preliminary environmental management plan. On July 28, 2015 the EPA granted GPHA the Environmental Permit (No. C10025240102) to commence the infrastructure development and dredging of the Port of Tema. The permit defines all the required construction and operations phase conditions.
A preliminary sedimentological assessment and a wave sediment transport model were performed during the FEED by Artelia, the company’s engineering consultant. The assessment indicated that the rocky shore and the existing port of Tema located respectively west and east of the project site appear to limit the longshore transport in very shallow waters. In deeper waters, the seabed material is generally made of silty to fine sand, and fine sediments are transported by coastal currents. The yearly longshore transport is oriented east and equals to 81,000 m3/year. According to the study, each year about 80% of the transported volume accumulates west of the existing Tema port main breakwater, while about 10% potentially settles in the access channel and the remaining 10% bypasses the port further offshore. According to the model, the project breakwater should affect the wave driven sediment transport which takes place at shallow water depths, and cause an advance of the shoreline in the range of 1 to 7 m/year west of the breakwater. The maximum advance rate modeled was 7 m/year in the immediate proximity of the breakwater, with an estimated 70,000 m3 of sediment accumulation per year. The model predicted the effects to be localized within 2 km of shoreline west of the breakwater. As indicated in ESAP action # 2, the company will ensure that, during detailed design, current and sediment measurement campaigns (both along the shore and suspended sediment concentrations nearshore) are carried out, and, as needed, the sedimentological model, including the effects of waves and currents, is refined, in order to predict the sediment transport along the profile, the impact on the port bottom evolution and the consequent sedimentation within the dredged areas. The sedimentological impact study will specifically focus on the assessment of the potential coastal impacts and the protection of the Sakumo Lagoon outfall, as discussed below under PS 6 below and will inform the definition of an adaptive coastal monitoring and management plan (Shoreline Management Plan, ESAP action # 7) needed to avoid significant erosion and accretion impacts on this ecologically sensitive part of the shoreline.
Fishing is a major economic activity in Tema involving about 5,000 artisanal fishermen. West of the project area in the Sakumono community, five nets, being operated at the beach, are owned by long established families and rented to local fishermen, each net requ
iring about 60 to 70 fishermen to operate. Sakumono fishermen have been consulted and received some information about the project and, as reported by the ESIA, they expressed limited concerns regarding disruption of their fishing activities due to the port construction. The project site, where the reclamation and dredging will be carried out, is located on the opposite end of the existing fishing port and is rocky, making fishing activities almost impossible due to potential damage to the nets. Fishing activities occasionally extend close to the Sakumono beach, about 2 km west of the port. Though minor potential impacts on fishing activities are expected by the artisanal fishermen, MPS will focus their stakeholder engagement and communication plan on the Sakumono fishing community in order to address any potential concerns during construction, for example, fishermen safety, increased traffic in the area, impacts from dredging and reclamation activities, and rocky bottom blasting, as needed.
Tema and Ashaiman towns are key areas of interest for the project in terms of community engagement, sources of employment as well as managing potential population influx during the project construction period. While during the initial consultations no significant concerns were raised by the stakeholders due to the site location within an existing port area, the company and Tema authorities consulted recognized the potential for social impacts due to influx of job-seekers, increase of already heavy road traffic during construction and operations of the terminal, and dust and security impacts, among others. The Tema Metropolitan Authority is a key stakeholder to partner with in managing these potential issues. As indicated in ESAP action # 3, the company will therefore develop an Influx Management Plan and collaborate with the local authorities in order to prevent and manage these risks in the project area of influence. As indicated in ESAP action # 4, a detailed traffic impact assessment study for construction and operations phases will be completed by the company prior to construction. Traffic management plans will be finalized by the company prior to construction and operations, respectively.
As a complement to the ESIA, MPS has committed to conduct a number of rapid assessments, focused on project construction and operations, including: (i) initial assessment of existing road infrastructure and traffic to review whether access routes would need to be upgraded to support new terminal operations; (ii) determination of the likelihood of sea turtles nesting in the project area of influence; (iii) critical review of the minor impact of the development on artisanal fishing in the immediate area of the project; (iv) precise identification of a community traditional site (a rock with cultural value) within the project footprint and relevant mitigations including approach for its relocation as needed; and (v) assessment of the cumulative impacts of the propos
ed development with respect to other development planned in the area of influence.
Management Program: As mentioned above, MPS has developed a number of policies, procedures and management plans aimed at addressing the potential E&S aspects of its operations. The company will revise and update its management system for new terminal operations in alignment with IFC’s Performance Standards.
The construction contractor(s) have not yet been selected. However, as part of the tender documents, the company has issued a series of Health, Safety, Security, Environmental and Social Performance Standards (HSSESP Standards) and a Contractor Safety Standard, which the company expects all contractors and their subcontractors to comply with. The HSSESP Standards include the following management and technical standards: Leadership and commitment; Risk management; Resources, competency, training and awareness; Communication, participation, consultation; HSSESP monitoring and reporting; HSSESP audit and review; Regulatory compliance; Emergency preparedness; Incident assessment and reporting; Contractor HSE management; Community and occupational health and safety; Vessel and vehicle transport; Security and access; Cultural heritage; Environment Management; and Contractor Safety Requirements. The company will require contractors to prepare Site HSSESP Risk Assessments to assess the hazards and risks that may arise during design, construction, operation and maintenance of the works. These risk assessments will inform the final design to avoid E&S risks as far as is reasonably practicable.
The contractors will be required to ensure that any relevant requirements under the project environmental permit (held by GPHA), the company standards and the ESIA are incorporated in their procedures with a clear description of how this will be executed during the works. Prior to the start of construction, all contractors will therefore submit their Site HSSESP Policy and Plan, including the management programs appropriate to their tasks based on the HSSESP Standards (e.g. Waste Management Plan; Emergency Preparedness and Response Plan; Traffic Management Plan; Dredging Management Plan). As part of the update of its management system for the construction phase (ESAP action # 1), the company will develop a Contractor HSSESP Assurance and Monitoring Plan in order to implement a consistent E&S management and monitoring system during construction.
Organization: The company’s HSSE team is led by the Legal and HSSE Manager, who reports directly to the company’s Chief Executive Officer and ensures implementation of the E&S management system and all regulatory requirements. MPS project management team overseeing the implementation of the project will comprise a broad range of staff with experience in large infrastructure construction and implementation and in container terminal management with a global operations experience. The project implementation organization will includ
e a dedicated HSSE manager and team in charge of the supervision of all construction contractors, the implementation of the management plans, and the coordination of the E&S assessments and studies. As indicated in ESAP action # 5, MPS will also hire a Community Liaison Officer responsible for the implementation of the social management programs and for engaging with communities and key stakeholders during project implementation. Each main contractor (marine works, land works, buildings, equipment, testing) working on the project will be required to provide a qualified and dedicated HSSE officer. They will be responsible for HSSE management of their subcontractors consistent with MPS HSSESP Standards.
Emergency Preparedness and Response: For the existing terminal operations, MPS has several emergency procedures, which include response to fire and explosions, chemical spills, hazardous goods incidents, with clear roles and responsibilities assigned within the organization. The Emergency Preparedness and Response Plan will be revised and updated prior to new terminal operations. For the project construction, MPS has developed the HSSESP Management Standard 8: Emergency Preparedness, which the contractors will need to adhere to. All contractors / suppliers involved in the project construction will comply with MPS’s (and/or GPHA) Emergency Preparedness and Response Management Plan and they will either refer to the company’s plan or have an equivalent procedure/plan which will be approved by MPS.
