While all Performance Standards are applicable to this investment, IFC’s 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 

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

The existing plant is located in the industrial zone of Dakar, and the new plant will be in a similar location away from any community. The company employs unarmed security and the company’s operations do not pose major risks to the health, safety and security of any community.  PS4: Community Health, Safety and Security is therefore not applicable.

The land for the new site was purchased through a market-based willing-buyer willing-seller transaction, and there was no involuntary resettlement. Hence PS5 (Land Acquisition and Involuntary Resettlement) is not applicable.

The project site is located in a modified habitat, in peri-urban industrial area outside Dakar, and there will be no impacts on biodiversity. Therefore, PS6 (Biodiversity Conservation and Management of Living Natural Resources) is not applicable. Similarly, no indigenous people or cultural heritage will be impacted by the project, therefore PS7 (Indigenous Peoples) and PS8 (Cultural Heritage) are not applicable.

This is a Category B project according to IFC’s Policy on Environmental and Social Sustainability, because potential adverse environmental or social risks and/or impacts are limited, few in numbers, site-specific, largely reversible and readily addressed through mitigating measures. 

Key E&S issues during construction include occupational health and safety (OHS), dust  emission, noise, and vibration from vehicle transit and earth moving activities as well as the potential for soil erosion and pollution. These impacts are expected to be temporary and will be minimized via implementation of the construction E&S management plan. Key E&S risks and issues associated with operations relate to E&S management systems, OHS, management of hazardous and non-hazardous wastes and emissions, emergency preparedness and response including life and fire safety.

Environmental and Social Assessment and Management System 

Although previously ISO 9001 certified, Polykrome does not currently maintain any certification. It has plans to renew its ISO 9001 certification by 2020. Polykrome has procedures related to quality, customer claims, and HR but has no environmental policy. As such, Polykrome will develop and implement an Environmental and Social Management System (ESMS) in line with IFC’s Performance Standard (PS) 1.  

As outlined in the ESAP #1, the company, with the help of external experts as needed, will develop an ESMS, which will incorporate the following elements: (i) an E&S policy; (ii) management programs/procedures for identified E&S risks and impacts including  OHS; (iii) organizational capacity and competency; (iv) an emergency preparedness and response plan; (v) a monitoring and review procedure; and (vi) an external communications procedure to manage communication with external stakeholders, including customers and the general public. 

Identification of Risks and Impacts 

In line with the Senegalese Environmental Law of 15 January 2001, the new plant is subject to a detailed ESIA, including an Environmental and Social Management Plan (ESMP) for the different phases of the project, which will also comply with the requirements of PS1 (ESAP #2).  

As part of the ESMS described above, identification of risks and impacts and management will be regularly carried out throughout the life of the project – especially in case there are major material changes in the operations.

Management Programs 

Polykrome currently has only a few documented procedures and is yet to develop its management systems and programs for OHS, and environmental aspects. As part of the ESMS to be developed under ESAP #1, the following procedures and necessary work instructions will be developed and implemented: OHS management in the production area, hazardous and non-hazardous waste management; management of noise and air emissions, emergency preparedness and response (including life and fire safety), external communications, and monitoring and reporting. 

Organizational Capacity and Competency

Polykrome hired a Quality Manager to assist with the development of management programs related to quality, environment, and OHS. His efforts so far, have focused mainly on quality. A training framework and an action plan was drafted for 2017-2018 and includes training related to ergonomics (lifting and material handling), OHS, and waste management.  

The company currently has an organizational chart that does not include specific EHS responsibility matrix. Hence, as set forth in the ESAP #3 Polykrome will amend the chart such that to create a well-defined EHS role(s) in the organization with appropriate reporting lines. Moreover, this person/team will be responsible to develop and implement the ESMS in a holistic manner.

Emergency Preparedness and Response 

Currently, there is no formal and documented emergency preparedness and response plan validated by local authorities. Major risks for emergency situations for Polykrome’s operations include fire, and hazardous materials spills.  

Polykrome has engaged the professional service of a qualified life and fire safety professional to ensure that the project design will be done in accordance with the French Life and Fire Safety Code. There will be a sprinkler system, fire extinguishers and other fire-fighting equipment (e.g. fire hose cabinets) distributed around the plant, as well as fire alarms and detection equipment.  

 As set forth in the ESAP #1, Polykrome will develop an emergency plan, which will include the following elements: coordination and communication with other neighboring facilities, roles and responsibilities, interaction with authorities, drills and periodicity, decontamination procedures, etc.  

Monitoring and Review

As part of the ESMS, Polykrome will adopt a structured EHS monitoring and reporting system for the E&S and OHS aspects of its operations. For this purpose, it will develop a documented monitoring procedure as part of the ESMS manual. 

Polykrome will incorporate in this procedure, Key Performance Indicators (KPIs) related to E&S and OHS aspects associated with its activities, including: a) Safety – Lost Time Injury Frequency Rate, Accident Free Days; b) Resource Efficiency – water usage, energy usage, solvent consumption, etc.; c) Staff - Retention and training days, d) Workplace/indoor air quality, and temperature in the workplace. Monitoring frequencies and methodology will also be specified and shall be reflective of the risks and impacts. The monitoring data will be compiled in a centralized database for development of summary reports, which will be regularly presented to the senior management.

Communities are not likely to be significantly affected due to this project. Going forward, Polykrome as part of its ESMS, will develop and implement a procedure for stakeholder engagement and external communications that includes methods to (i) receive and register external communications from the public; (ii) screen and assess the issues raised and determine how to address them; (iii) provide, track, and document responses, if any; and (iv) adjust the management program, as appropriate (ESAP action #1).

Polykrome SA, 9 Rue Amadou Assane Ndoye BP 488 Dakar, Senegal