PS5: Land Acquisition and Involuntary Resettlement is not applicable. The proposed project interventions are to be carried out within the company premises on its 23 acres of land situated at Chang’ombe in the Industrial Area of Dar es Salaam (https://goo.gl/maps/UsvYAUNLL9S2) operational since 1963. The 280 acres land for the sand quarry was acquired through an open market process (willing buyer willing seller) in Mkuranga District, Vianzi Ward, 35Kms South of Dar es Salaam along Kilwa Road.

As the factory site is located in well-developed industrial zone for the past 53 years, PS6: Biodiversity Conservation and Sustainable Management of Living Resources does not apply. The sand mine is located in peri-urban rural / agriculture area characterized by dominant species of deciduous coastal shrubs with scattered Boabab trees (Adensonia digitata) and planted trees such as Cassia sp., cashew nut and coconut trees. The sand mining area has been subjected to various disturbances from previous anthropogenic activities – farming and grazing. Findings of the due diligence confirmed no presence of indigenous people or cultural heritage and hence PS7: Indigenous Peoples and PS8: Cultural Heritage do not apply.

This project involves the installation of new machinery, rebuild of furnaces, and upgrading of an existing glass bottle manufacturing plant with increased output, better energy and water efficiencies plus reduced emissions within the same surface footprint. Glass bottle manufacturing mainly uses silica sand, which is relatively abundant and easy to mine. The production process generally does not generate much waste. The investment is expected to have limited E&S impacts which are site-specific, and temporary in nature. Accordingly, this is a Category B project as per IFC’s Environmental and Social Sustainability Policy.

Key environmental and social issues and risks for this investment are: assessment and management of E&S impacts associated with the project, management systems and practices for E&S and OHS; working conditions and terms of employment; resource efficiency, water use; air emissions from the furnaces; supply chain; traffic management / impacts on communities and land acquisition for sand mines.

Environmental and Social Assessment, Policy and Management System

Kioo engaged a Consultant in 2014 to undertake an Environmental Impact Assessment for the 160 acres sand mine. The EIA was submitted to National Environmental Management Council (NEMC) for approval. As at appraisal, Kioo had not received the EIA approval from NEMC. The EIA identified the following key issues (i) loss of vegetation (ii) soil erosion due to loss of ground cover; (iii) dust and air pollution from moving trucks (iv) occupational health and safety of workers and (v) community safety. For these, appropriate mitigation measures were identified. These include (i) prepare a rehabilitation plan (ii) cover stored overburden to avoid erosion (iii) the company to constantly sprinkle water on the access road and cover trucks with tarpaulin (iv) provision of personal protective equipment to staff (v) develop and maintain stringent access control entry protocols to the mine site. As observed during appraisal the company was implementing some of these measures; (i) progressive rehabilitation of the mined out areas (ii) regular maintenance and compaction of the access road to minimize dust (iii) provision of PPE to staff on site and (iv) controlled access to the mine site through a fence.

However, the EIA does not provide adequate baseline assessment nor cover the entire sand mine site (i.e. excludes the additional 120 acres). Thus as stipulated in ESAP 1, the company will commission a suitably qualified and experienced consultant to undertake anEnvironmental and Social Impact Assessment (ESIA) for the entire 280 acres of the sand mine to address these gaps and develop the ESIA report compliant with the requirements of PS1. Kioo will share the Terms of Reference for the ESIA with IFC for review and agreement.

Kioo factory operations received certification for ISO 9001:2008 Quality Management System in 2013; ISO 14001:2004 Environmental Management System in 2013; OHSAS 18001:2007 Occupational Health and Safety Management System in 2014; and re-certification of ISO 14001:2004 EMS in 2016. The company has also received certification for Food Safety Management System ISO TS 22002 and FSSC 22000:2013. The company has integrated the systems and established an Integrated Management System Policy covering Quality, Food Safety, Environment and Occupational Health &Safety as well as an Integrated Management System Manual to guide staff and company operations.

Through the Integrated Management System Policy, the company commits to providing services and products to their customers with minimum consumption of resources; setting and reviewing their objectives periodically; ensuring periodic audit of effective implementation of the system; continual improvement; effective communication to all stakeholders; training, educating and motivating staff to contribute towards effective implementation of the system; and developing & maintaining mutually beneficial relationships with suppliers to meet Kioo’s requirements.

During appraisal there was evidence of implementation of the management system across the various departments. There were generally good housekeeping practices being observed in all production areas; walkways were clearly marked and staff observed the use of designated walkways. Names and photos of safety staff on duty and safety notices were displayed at various locations around the factory, most staff had appropriate safety gear and hazardous materials were clearly marked and stored in separate stores.

Management Programs

The company has established a robust Risk Assessment and Mitigation Program; OHS Management Program; a Permit to Work Program for Confined Space Entry, Hot Work, Work at Heights and Electrical Work; Waste Management Program which involves waste segregation and recycling; Energy Efficiency Program; Air Quality Measurements Program and Wastewater Management Program; Emergency Preparedness and Response Plan; Security Plan and Traffic Management Plan for the factory site. However, some of the programs and plans have results and measurements but the procedures and plans are not documented. These are addressed in the subsequent sections of this summary.

Organizational Capacity and Competency

The company has a qualified HSE Department Head (HOD) who works with his team of two safety officers and four trained safety representatives to cover for the three shifts. The position of one safety officer was vacant at the time of appraisal and a process was in place to fill the vacancy. The HSE HOD co-ordinates with the Heads of Department of all Technical Departments. The HSE HOD reports to the Plant Manager who in turn reports to the General Manager. The HSE HOD is responsible for developing and implementing HSE policies and procedures and supervises all activities related to HSE within the company. The HSE HOD and his team are also responsible for HSE training for all staff members such as HSE Induction Training; Basic Safety Training; Permit to Work System; Hygiene and Sanitation and so on.

The Training Plan for workers is developed by the HR Department annually after a Training Needs Assessment (TNA) for all workers. Some of the training is conducted internally by the HSE HOD and his team whereas mandatory regulatory training such as First Aid, Fire Wardens Training, Fire Exit Training are done by external persons from the Vocational Education Training Authority. The HSE HOD is working on developing training modules for contractors and visitors to the factory. There was no documentation for EHS trainings for staff at the sand mine and the truck drivers.

Emergency Preparedness and Response

The company has developed an Emergency Preparedness and Response Procedure as part of the Integrated Management System Manual. The plan identifies the events that would trigger an emergency situation. The company undertakes emergency mock drills at the factory twice a year, an Emergency Escape Route Plan which provides the factory layout and indicates the locations of fire extinguishers; fire hydrants; fire buckets; fire escape routes, fire assembly points, First Aid boxes and the location of the dispensary is displayed. Emergency telephone numbers for internal and external emergency responders are also displayed. However, the appraisal identified gaps between the displayed information, documented emergency procedure and areas of coverage.  The Company will update the Emergency Procedure in compliance with IFC PS requirements (ESAP 2) and include the information displayed at the Gate, the sand mine site, traffic management, the logistics operations for silica transport to the factory and products transport to customers.

The company has a fire suppression system and different types of fire extinguishers and hydrants installed at strategic locations around the plant. The emergency exit signs and fire assembly points were visibly posted. The inspection of the fire suppression equipment is done twice annually by an approved Fire Safety Company in compliance with local fire safety regulations. The company has 10 trained First Aid Staff and 10 trained Fire Wardens.

Monitoring and Review

Internal monitoring on the implementation of the ESMS is done by the HSE HOD in collaboration with the various Heads of Technical Departments. Monitoring is done through routine Internal Quality Audits as required by ISO and Quarterly Housekeeping Audit of all departments. There is a recognition and reward system established for the best performing department every quarter. The General Manager or his designate chairs a Monthly Plant Performance Review Meeting which includes discussion on open issues / cases, audit findings in occupational health, safety, security and environmental issues at the factory

External monitoring is done by regulators and clients annually through a surveillance audit by an ISO accredited auditing firm. An Occupational Health and Safety Audit and an Industrial Hygiene Audit to ensure compliance with the national OHS legislation is also done annually by a firm accredited to undertake regulatory audits. The OHS regulator provides compliance licenses to firms that are in full compliance with their legal provisions.  For example, in 2016, NEMC conducted an environmental audit for the factory however, the company awaits the Environmental Audit Certificate from the Minister Responsible for Environment.

Human Resources Policies and Procedures

The company’s human resource practices are based on the Tanzania Employment and Labor Relations Act 2004 (amended in 2010); the Labor Institutions Act 2004; the Code of Good Practice Rules 2007; the Guidelines on Employment and Labor Institutions Act of 2004 and the Voluntary Agreement between Kioo Limited and Tanzania Union of Industrial and Commercial Workers (TUICO). The amendment to the labor law is on mandatory leave by employees whereby employees must take annual leave and cannot replace leave for cash in excess of 56 days during the employment term.

As part of the Integrated Management System, the company has developed some HR procedures such as disciplinary, recruitment, leave procedures in sync with the workers Collective Agreement (Voluntary Agreement between Kioo Limited and Tanzania Union of Industrial and Commercial Workers (TUICO) and the national laws & regulations.

There is no Human Resource Policy or consolidated Manual. In line with ESAP 3 Kioo will develop a HR Policy and Manual consistent with Tanzania’s laws & regulations, the worker’s collective agreement and IFC PS 2. The policy and manual shall include the application of labor practices to third party / contracted workers.

Working Conditions and Terms of Employment

The company employs 749 staff of these, 654 permanent staff; 55 contractor staff for housekeeping services and 40 security staff in the factory. There are 103 female staff and 646 male staff. 43 permanent staff are expatriates and the rest are Tanzanian nationals. The sand mine site has 24 of the permanent staff in the company payroll, six casual laborers and 10 external security personnel (five in every 12-hour shift).

Permanent employees hold Employment Contracts which are renewed annually. The Contracts specify the terms of employment and employee working conditions (e.g., rights of the employees, training, remuneration, termination, working hours, allowances and compensation scheme, etc.) and benefits (e.g. loans, medical cover and insurance etc.). The contracts are consistent with Tanzania’s labor laws and aligned generally with the Internal Labour Organization (ILO). A revision to the contracts is being made to include job descriptions for each employee in 2017.

The Company has six ordinary working days in a week having 45 working hours excluding meal-breaks. There are three shifts for factory workers and overtime is paid for any extra hours exceeding 45 hours per week. All employees are entitled to annual leave in accordance with the national laws. Female employees are entitled to paid maternity leave of 84 calendar days and 100 calendar days if the employee gives birth to more than one child. Upon resumption to duty after maternity leave, a female employee who is nursing is entitled to three hours break (or early release) for three months starting from the reporting date. All male employees are entitled to seven days’ paternity leave within a 36 months leave cycle.

Workers’ Organizations

There are 594 non-managerial staff of the company who are members of the Tanzania Union of Industrial and Commercial Workers (TUICO). Kioo has signed a Voluntary Agreement with TUICO which is reviewed every two years. At appraisal the Voluntary Agreement was under review and negotiation between management and TUICO. It is anticipated that a new agreement will be in place in 2017.

Non-discrimination and Equal Opportunity

Recruitment and appraisal of employees are carried out based on equal opportunity practices. Vacancies are advertised internally and externally via print media on national newspapers. Interviews for advertised positions are done by company interview panels and successful candidates awarded appointment letters.

The Employment and labour laws in Tanzania prohibit discrimination in the workplace and requires that an employer register, with the Labour Commissioner, a plan to promote equal opportunity and to eliminate discrimination in the work place. According to the law, harassment of an employee shall be a form of discrimination.

Retrenchment

The Voluntary Agreement explicitly provides alternative measures to be considered prior to retrenchment or redundancy. There are no plans for retrenchment by the company in fact a few employment opportunities are likely to be created under the expansion program.

Grievance Mechanism

Kioo has documented an Employee Grievance Procedure as part of the Integrated Management System. Any staff with a grievance writes to the HR Manager who discusses the complaint with the staff and either offers counseling or conflict resolution guidance. The documented employee grievance procedure shall be updated (ESAP 4) to not only address disciplinary cases but have a clear and understandable mechanism for receiving and resolving workers’ complaints. The update of the procedure will also ensure that a mechanism is established where anonymous complaints can be submitted and resolved by management through for example suggestion boxes at strategic locations in the workplaces. The voluntary agreement also has provisions for settlement of trade disputes between Kioo and the employee(s) through meetings and refers to the dispute resolution procedures in the labour laws in the event that the dispute is not settled by TUICO.

Protecting the Work Force

Following the labour laws in Tanzania which prohibit child labour, the company does not employ young persons under the age of 18 years. Tanzania’s Employment Act also prohibits forced labour. Newly recruited staff undergo pre-employment medical examination and Induction Training prior to assignment of duties.

Occupational Health and Safety

Kioo has established an EHS Hazard Identification, Risk Assessment and Management Plan. According to the plan, the company conducts hazard identification and risk assessment as well as plan for mitigation measures annually and in case new work processes or new machinery are introduced. The plan outlines the reference documentation and national laws; states the responsible parties; identifies the hazards inherent in the processes; provides Risk Analysis decision process; provides risk classification matrix and recording forms.

The HSE HOD maintains a comprehensive Risk Register for each department/ process which is updated annually or when new machinery or processes are introduced. When an incident or accident occurs it is reported to the HSE HOD, who carries out an investigation, prepares a Flash Report that is circulated to management. The incident is then entered in the Action Track Register. All risk assessments; walk about observations of unsafe work practices; accidents, incidents and near misses from the Flash Reports are recorded in an Action Track Register with follow up actions, date for completion and verifying evidence.

There is a dispensary at the factory site manned by trained medical personnel to address workers’ medical needs. The company has arrangements for an ambulance on call and a healthcare centre where staff can be referred to for medical attention at the Company’s expense.

The combination of the process of ISO certification, risk identification and analysis of the factory operations from 2013 and automation of various processes since 2015 has led to a significant reduction of Lost Time Incidents (Lost Day Accidents). There are continuous training programs to improve safety consciousness among workers with a total of 386 workers receiving HSE Training in 2016.

The company is committed to continuous improvement of OHS standards according to OHSAS 18001. During appraisal it was observed that there is a lack of consistency in implementation and enforcement of PPE usage e.g. at the bottle labelling line – not all workers had nose masks and gloves; risk of eye injuries from flying glass particles exists at cullet washing lines and cold end inspection lines.

The OHS Program shall be updated and documentation and Training Needs Assessments done for the sand mine workers and the drivers of the trucks (Defensive Driving programs, Road Safety training, safe driving hours, Driving & Road Safety rules for the neighboring countries where products are delivered etc.) as per ESAP 5 and in accordance with IFC PS2.

Workers Engaged by Third Parties

For the construction and installation of the Project, the company shall engage contractors. In line with ESAP 6, Kioo shall develop and supervise the implementation of an EHS Management Plan for construction phase and include this in the contract agreement with the selected contractor. In addition, the company is in the process of developing EHS procedures and training requirements for regular contractors (contracted housekeeping staff, security personnel, casual laborers at the sand mine etc.).

Supply Chain

Sand/ silica is sourced from the company owned and operated sand mine. Soda ash is sourced from Magadi Soda Company (an IFC Client) or from Europe while cullet is sourced from customers (the bottling companies and other users of the company’s glass products who return the broken glass as cullet) and other collections agents in the region. After the upgrade of its furnaces, Kioo will use approximately 43,000 tonnes of cullet annually of which 80% is sourced from customers and only 20% from aggregators/agents. While Kioo does not have direct control on the collections by aggregators who tend to collect cullet from informal recyclers, Kioo is sensitive to the potential risk of harmful child labour in this part of its cullet supply chain. As such, the company shall undertake supply chain mapping and develop a policy against harmful child labour for collection of cullet. If child labor instances are identified, the company will take appropriate steps to remedy them on the best effort basis, including moving away from aggregators found engaging child labor.  (ESAP 7).

Resource Efficiency

Glass manufacturing requires sand, limestone, soda ash and other raw materials. Kioo sources the raw materials locally or from neighboring countries. The company uses natural gas as the main source of energy and have adequate back up electricity from the national grid. Once the raw materials are received at the factory, they are stored in separate bins. Before melting, the raw materials are weighed and mixed with cullet in the automated batch house to ensure homogeneity. The mixture is then fed into the melting furnace which heats the raw materials at 1,500^oC and causes the materials to be transformed into molten glass. The molten glass is then cooled thermally to 1,200^oC, subjected to a forming process and then the glass is annealed to remove unwanted stress from the formed glass. This is followed by inspection, testing, packaging and storage. The process is energy intensive.

Waste glass from defective products and glass sourced from post-consumer waste (cullet) is recycled. Kioo utilizes approximately 40% cullet in its production process. The company recognizes the significant contribution that cullet makes to the success of a glass plant and in 2013 invested in two new cullet treatment lines. Post-consumer waste cullet is separated into colours, washed, sorted and crushed before it is sent to the batch house.

Kioo has increased the manufacturing efficiency in the plant to around 91% which has reduced the internally generated cullet. The company notes that unlike Europe and USA, there is no glass recovery system in place in Tanzania and the neighboring countries that the company supplies to. The company through cullet agents, actively supports the local market for cullet collection and imports cullet from the East African Region to support its commitment to reducing waste and recycling the maximum available cullet.

Every tonne of cullet recovered and recycled reduces 70% of CO₂ / tonne of glass; reduces raw material requirements by more than 1 tonne thus saving natural resources and raw virgin materials; and saves an equivalent of 42kWhr of electricity/ tonne of glass. Furthermore, glass recycling extends furnace life and produces no processing by-products.

Kioo has made significant investment in energy efficiency. Some initiatives in the program include: improving the sand grain size to reduce melting energy and improve quality; increasing the efficiency and size of the cullet treatment plant to optimize output; installing high efficiency low energy compressors and reducing leakage of compressed air in section boxes.

To improve material efficiency, Kioo is reducing the manual handling of raw materials to reduce losses and improve on health and safety conditions of employees by investing in installation of an automated batch house. The company is set to adopt technology that will contribute to reduction of raw material usage. There are also plans to reduce the existing blow-blow (BB) bottle weights through right weighting to reduce raw material consumption. The company has also invested in state of the art fully automated packaging, palletizing and shrink wrapping machinery at K1 cold end. This has reduced LTIs and breakages.

GHG Emissions

Based on the total quantity of electricity used by Kioo, the fuel used in the furnaces and the stationary and mobile uses of fuel i.e., generators and vehicles, the total quantity of CO₂ equivalent per year generated by the company is 64,716 tonnes. As and when the operations are expanded and efficiency improved so will the total quantity of CO2 equivalent generated by the company be updated.

Air Emissions and Pollution Prevention

The company will rehabilitate and upgrade the current K1 glass furnace. This will involve a re-design prepared based on emission requirements of the WBG EHS guidelines. This will include the replacement of burners; lifting of combustion chamber ceiling and optimization of gas flow to achieve better fuel efficiency and reduce the emission of dust, NOx, and SOx (SOx is mainly coming from the soda ash).

Kioo will rehabilitate and upgrade the current K2 glass furnace. This will involve a re-design prepared based on emission requirements of the WBG EHS guidelines. The upgrade will include, installation of electrical boosters over the melting chamber, and replacement of burners to optimize gas flow to achieve better fuel efficiency and reduce the emission of dust, NOx, and SOx.

Installation of any additional glass melting furnace will be designed according to emission requirements of the WBG EHS guidelines and by a well reputed furnace design company.

Water and Wastewater

Water for the current industrial site is sourced from five borehole located within the facility. The company uses an average of 10,000 liters of water a day. The company monitors its water consumption. 

Kioo discharges wastewater into the municipal sewerage network system for Temeke Council.

Solid Waste Management

Kioo has developed a waste segregation and recycling program at the Factory site. In 2016 from January to October, recycled waste comprised 223,390 Kg of Metal; 93,740 Kg of wood 39,430 Kg of Plastic/Nylon and 29,034 Kg of paper. Other solid waste that cannot be recycled is collected through the municipal council licensed contractor.

Hazardous Materials

The company has an above ground diesel storage tank with secondary containment. Lubricants are stored in the general store. However, there was significant spillage on the floor. There is need for the company to establish a spill prevention and control plan for fuels and lubricants (ESAP 8).

Pesticide Use and Management

At the current facilities, rodent and pest are monitored constantly and controlled.  The company has contracted a registered company to undertake the control measures. None of the fumigants used are WHO hazard class Ia or Ib.

Security Personnel

Kioo employs security personnel both at the factory site and at the sand mine. The Security Personnel are trained and vetted. The company has 24 internal security personnel and 40 external security guards at the factory provided by a contracted firm while at the sand mine security is provided by Government armed security. The security agency has standard operating procedures and provides basic training for the guards and supervisors; there has been no complains or reports regarding abusive behavior or improper use of the arms or force by the security service. However, in line with ESAP 9, the company will assess risks posed by its security arrangements to those within and outside the project site and create a complete Security Management Plan (SMP), including a training module for management and security personnel. This SMP shall be aligned with the Voluntary Principles on Security and Human Rights and with the requirements of Performance Standard 4 (paragraphs 12, 13 & 14).

As part of the Initial Environmental Impact Assessment of the sand mine, public consultations were carried out with various stakeholders. Discussions were held with groups and individuals in the vicinity of the project site, local government authorities, Government Departments and the company employees. Concerns raised by those consulted included air quality impacts, pollution of land and water resources from poor solid and liquid waste disposal, noise and vibration, public health and safety and influx of strangers into the local community.

For the factory site operations, the company through the Integrated Management System Policy has committed to ensuring effective arrangement of communication to all stakeholders, however there is no formal stakeholder engagement plan developed.

The company, in line with the ESAP 10, will develop a Stakeholder Engagement Plan (SEP) that identifies key stakeholders and provides a procedure for external communication. The SEP will include a grievance redress mechanism (GRM) to address any concerns that people living in the vicinity of the project may have. The main objective of the GRM will be to provide a mechanism to mediate concerns. The SEP will be reviewed periodically during implementation and will be updated as necessary to ensure effective ongoing engagement with stakeholders. Appropriate channels will be used to inform the stakeholders of project issues and will be part of the SEP. The company will make the ESIA, ESAP and SEP available to stakeholders to ensure that local communities are made aware of the project, its key impacts, proposed mitigation measures and the implementation timeline and methods.

Mr. Kumar Krishnan

General Manager, Kioo Limited

180, Saza Road, P.O.Box 9273

Dar es Salaam, Tanzania

Phone number: +255 22 2860 190

Email: kk@Kiooglass.com