Both the Rosslyn and the Berlin plants are located in industrial areas that are several kilometers from the nearest residential area. Issues associated with in PS5 (Land Acquisition and Involuntary Resettlement), PS6 (Biodiversity Conservation and Sustainable Management of Living Natural Resources), PS7 (Indigenous Peoples) and PS8 (Cultural Heritage) are, therefore, not applicable to this project.  

This is a Category B project according to IFC’s Policy on Environmental and Social Sustainability, because a limited number of specific environmental and social impacts may result, which can be avoided or mitigated by adhering to generally recognized performance standards, guidelines or design criteria. 

Key E&S risks and issues related to this project include:  i) explosion risk and occupational exposure to welding fumes from the new laser welding facilities; ii) occupational health and safety risks associated with the presence of moving machinery, vehicle movement, and live circuits; iii) hazardous waste; and iv) third party risks associated with transport of raw materials.

Identification of Risks and Impacts:  MA automotive have certified environmental and occupational health and safety management systems that are ISO14001 and OHSAS18001 certified, respectively.  Within these systems are mechanisms for the identification of potential risks and impacts.  For the production plants risk assessments have been conducted on the design for occupational health and safety and environmental risks.  A second risk assessment was also conducted, when the recent BMW body part line was commissioned to ensure that no risks remained unidentified, that risk assessment focused on emergency stops and the machine-operator interface. 

Environmental and Social Policy, Assessment and Management System:  Within the certified environmental and occupational health and management systems, MA automotive has the necessary policies, risks and impacts identification procedures and management programs. 

E&S Capacity: MA Automotive has a dedicated EHS manager who is responsible for the eight South African plants, four of which are in Rosslyn, two in East London and two in Port Elizabeth.  Each plant has a dedicated safety officer per shift.   The HSE manager reported that he receives good support from the management team, and adequate financial resources are provided to implement the necessary improvement projects. The onsite H&S manager at the Berlin plant also indicated that she had received the needed staff to allow for a satisfactory oversight. Earlier this year one of the Roslyn based operations had a serious bodily injury accident at an older press line. The company analyzed the lines operation and decided to remove it due to its non-satisfactory H&S standard.

Monitoring and Review / Reporting: Being a relatively low environmental risk operation, MA Automotive monitors VOC emissions from its plants every second year, and discharge water quality every year.  The company also monitors occupational health and safety injuries and conducts frequent inspection of the plants, to assess compliance with occupational health and safety and environmental procedures.

Emergency Preparedness and Response: MA Automotive conducts annual drills for emergency response, and recognizes fire, explosion, serious injury and spills, as emergency conditions.  The company has two level-3 first aiders who are available for first line response in an emergency situation, and there is a local fire service available to respond.  MA Automotive has upgraded its emergency preparedness and response procedure to include the additional explosion risk associated with the recently installed laser welders.

Supply Chain Management:  The key suppliers are suppliers of steel and aluminum.  MA Automotive is compelled to use suppliers that have been selected/approved by its suppliers.  The company has update its supplier agreements to include checks against local labor laws (in practical terms similar to PS2) and environmental requirements identical to PS3.

Human Resources Management:  MA Automotive employs around 958 direct personnel (end 2017 data), of which 175 are women, and 15 are disabled.  According to the company’s occupational levels, ten (10) women are professionally qualified and experienced specialists, and in mid management positions, of which two (2) are African.  The company has an overarching HR strategy, which is translated into a number of individual policies, including recruitment, non-discrimination, HIV in the workplace, disciplinary procedures and others.  These policies are available on a shared drive, are summarized in a booklet that is made available to all employees, and are detailed during the induction of new staff.  The company has a staff turnover of around 10%, due to a general skills shortage, which sees competing companies recruiting MA staff. 

The workforce is heavily unionized with workers belonging to the National Union of Metalworkers of South Africa (NUMSA).  The company has a collective agreement, which applies to the motor industry component of NUMSA.  Importantly, no retrenchments are envisaged.   Over time, a progressive reduction in staff is inevitable for the company, as a whole, due to the progressive automation of the company’s operations, but it is expected that this loss of employment will be balanced by natural attrition negating the need for retrenchment.

Grievance Procedure:  A grievance procedure is in place that is compliant with the PS requirement.

Occupational Health and Safety (OHS):  There is a strong culture of occupational health and safety in the company, driven by compliance to the South Africa Occupational Health and Safety Act, and the demands of the parent company.  Safety risks are associated with moving machinery, all of which are safeguarded by lock out systems and physical barriers that prevent operator access to moving machinery.  The 2018 lost time injury frequency rate (LTIFR) up to end April for the South African operations is 2.35 incidents per million hours worked, indicating the strong safety culture and good operational controls that exist within the company.  The company has installed ventilation systems that serve to reduce occupational exposure for the laser weld operators to aluminum particles and minimize explosion risk by controlling airborne aluminum powder.

Contractor Management: Permanent contractors are cleaning services, scrap handling, clinic and waste management contractors.  The contractors sign a safety, health and environment (SHE) Agreement and undergo a formal safety induction program and are subject to the same labor policies that apply to the permanent work force.

Resource Conservation and Material Efficiency:  MA Automotive maintain high levels of resource conservation through the recovery and recycling of waste steel, and this process will be maintained with the introduction of aluminum parts where off-spec parts and metal off-cuts will be recycled. 

Energy Consumption and Efficiency:  MA Automotive requires small quantities of water for cooling of the welding heads, which is sourced from municipal supply.  The company uses electricity, which is also sourced from municipal supply.  The company has energy reduction initiatives in place including low energy lighting, and all of the motors on the new reduction line are modern energy efficient motors.

Air Emissions:  Air emissions, which are derived from the ventilation systems above the curing ovens, are discharged untreated into the atmosphere.  VOCs are monitored once every two years with the most recent monitoring data, showing compliance with the VOC emissions guideline value in the Metal and Plastic, as well as the Rubber Products Manufacturing EHS Guideline. 

Waste:  MA Automotive discharges small quantities of wastewater that derives principally from the cooling water blowdown, and is possibly contaminated with oil.  The company has an oil separator prior to the connection to the municipal waste water system.  Monitoring of the wastewater previously revealed exceedances of the water quality limits for oils and grease, chemical oxygen demand (COD), and suspended solids detailed in the General EHS Guidelines.  MA Automotive has lately installed new oil/grease separators and the discharges are now compliant with the EHS guidelines.  The company has limited solid waste with most being recycled.  Hazardous waste takes the form of used oil and oil-contaminated material such as rags and gloves and occasionally the sorbent used for oil spills.  The hazardous waste is removed for disposal to a licensed disposal facility.  Small quantities of health care waste are produced which are removed for disposal by a specialized waste management company.  MA Automotive will develop a suitable disposal regime for the aluminum powder that will be recovered in the ventilation system as detailed in ESAP Action #1. 

Pest Management:  Pest management is outsourced in each case, to a reputable pest control company, which monitors rodents (using bait) every month.  Fumigation for cockroaches, flies and pests is undertaken by the same company on a quarterly basis.

Vehicle/Driver safety: MA Automotive has a fleet of only three large trucks that transport blanks from Plant 5 to Plant 4 for pressing.  Again, MA Automotive benefits from being in an industrial area where there is limited accident risk.  Supply transport is mostly on open freeway with direct access from the freeway to MA Automotive.

MA Automotive has no form of stakeholder engagement as a result of operating in industrial areas where the nearest residential areas are several kilometers from the plant.  Given the nature of the operation and the type of risks, a potential impact on neighboring communities is highly unlikely.  As such stakeholder engagement is not considered practical.

Contact Person: L.Hellberg

Company Name: MA Automotive Tool and Die (Pty) Ltd

Address: 8 Matinus Ras Street, Rosslyn, 0200

Email: l.hellberg@za.ma.gruppocln.com

Phone: 0027 12 5212596