PS4 (Community Health, Safety and Security) is not applicable. The new plant will be located in an industrial zone, far from any local community. The client makes reasonable inquiries to ensure that those providing security are not implicated in past abuses. Security is currently provided by the client’s own unarmed employees.

PS5 (Land Acquisition and Involuntary Resettlement) is not applicable. The land for the new site will be purchased through a market-based willing-buyer willing-seller transaction, and there will not be any economic or physical displacement.

PS6 (Biodiversity Conservation and Management of Living Natural Resources) is not applicable. The project site is located in modified habitat, in an industrial zone, and there will be no impacts on biodiversity.

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 aligned to generally recognized performance standards, guidelines, or design criteria.

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 associated land and surface water pollution. These impacts are expected to be temporary and will be minimized via implementation of the construction E&S management plan. Key risks and issues during operation relate to the Groups’ capacity to: i) adequately manage environmental and social impacts of the  operation and expansion; ii) ensure that the design and construction of all facilities complies with recognized building codes and life and fire safety standards; iii) maintain fair, safe and healthy working conditions during construction and operations of facilities for direct employees as well as for contract workers; iv) water availability for the new project, and implementing measures to ensure efficiency and sustainabilty; v) establish and implement  food safety standards (e.g. HACCP) in preparation, storage, and delivery of food products and beverages; and, vi) manage solid waste and effluents in line with good international industry practice.

Environmental and Social Assessment and Management System

IBS and Sosagrin maintain ISO 9001 quality management certification. Sosagrin has an ISO 14,001 environmental management certification. IBS has plans to obtain ISO 22000 certification following the investment. This food safety management system certification is required by one of the brands under which the client sells its products.

As outlined in the ESAP (ESAP#1), the Group will develop an overarching E&S policy defining the environmental and social objectives and principles that guide diverse Group operations to achieve sound environmental and social performance. This policy will be submitted to management for approval; then it will be shared with all employees and institutionalized in all operations.

Identification of Risks and Impacts

In line with the Senegalese Environmental Law of January 15, 2001, the new recycling plant for  glass mustard jars is required to prepare an environmental and social impact assessment (ESIA). In 2013, an ESIA was conducted for the IBS facility, and in 2015, environmental audits were conducted for both mustard and beverage facilities. One of the main impacts of the new project will be ground water extraction.  The Group will commission an impact assessment, develop, and implement a management program to mitigate the effect of ground water extraction on the water reserve and other users (ESAP #2). 

As part of the Environmental and Social Management System (ESMS), identification of risks and impacts and management plans to ensure that gaps are closed will be regularly implemented throughout the life of the project. All identified actions are assigned to specific staff along with a required implementation schedule. In case of major material changes to operations and changes to E&S risks and impacts, quality, food safety, OHS management, environment, and other staff will review and provide input prior to final design.

Management Programs

Beverage and mustard processing are undertaken according to the principles and practices of Hazard Analysis and Critical Control Points (HACCP) certification. Sosagrin and IBS are presently institutionalizing all HACCP prerequisites, including sanitation and good-management practices.  Other associated activities including, implementation of integrated pest and vector management programs, allergen control, customer complaints mechanism, traceability and product recall are being implemented. Completion of the HACCP program will be demonstrated through an audit performed by an external consultant (ESAP #3).

Organizational Capacity and Competency

The Group hired two Quality, Health and Safety Officers to assist with the development and implementation of quality, health and safety, and environment management programs. Training programs are available for each company including topics such as health and safety, food safety, OHS and environmental issues.

Emergency Preparedness and Response

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

 The Group will ensure that the design and construction of all facilities complies with recognized building codes and life and fire safety standards. The Group will develop an emergency preparedness and response plan that will include the following elements: identification of emergency scenarios; specific emergency response procedures; training of emergency response teams; emergency contacts and communication systems protocols; procedures for interaction with government emergency, health, and environmental authorities; permanently stationed emergency equipment and facilities including first aid stations, firefighting, spill response, personal protective equipment for emergency response teams, protocols for the use of emergency equipment; clear identification of evacuation routes and muster points; and, emergency drills as well as required frequency and follow-up activities based on assigned emergency levels (ESAP #4).

Monitoring and Review

As part of the ESMS, the Group has already adopted a structured EHS monitoring and reporting system for its operations. The procedure incorporates Key Performance Indicators (KPIs) related to E&S aspects associated with its activities, including: a) Safety – Lost Time Injury Frequency Rates (LTIFR), and Accident Free Days; b) Resource Efficiency – water usage, energy usage, and cleaning products consumption; c) Waste – quantity per type. Monitoring frequencies and methodology are specified  considering the risks and impacts. The monitoring data is compiled in a centralized database for development of summary reports, and regularly presented to senior management. Corrective measures are defined and implementation is agreed upon.

The Group has 204 full time employees comprising 100 at Sosagrin and 104 at IBS, including 40 women. There are about 5 daily workers used mainly for unloading/loading trucks. Third party contractors are hired to carry out maintenance works, and fire equipment maintenance.  For the new recycling plant, it is expected that 50 new workers will be hired over the next 5 years.

 All regular employees receive a contract registered at the “Inspection Régionale du Travail et de la Sécurité Sociale de Dakar” (Labor Ministry). The company is in compliance with the local labor code, which defines the various work categories, employee benefits, as well as minimum salary to be paid for each type of work. The company contributes to workers’ social security; and, both the Group and full-time employees contribute to the ‘’Institut de prévoyance médicale’’ (medical insurance for employees and families) as well as to the ‘’Caisse nationale de sécurité sociale’’ (CNSS) or social security in case of work accidents. In line with legal requirements, daily workers are equally entitled to CNSS partly paid by the employer and partly by the laborer. The Group ensures that all daily worker are registered and up to date in their payments to the CNSS.

 In Senegal, the minimum age for work is 15 although harmful work is not allowed legally under the age of 18. The Group does not hire anyone under the age of 18 years.

 There is a grievance mechanism known to workers but the existing HR Policy (‘’Règlement intérieur’’) does not cover all types of workers. It lacks provisions related to non-discrimination and equal opportunity, harassment and prohibition of forced and child labor. Therefore, the Group will update its HR policy to include issues such as non-discrimination and equal opportunity, harassment and prohibition of forced and child labor (ESAP #5).  In addition, the procedures will  ensure that the management of contract labor including daily and third-party workers is fully aligned with the requirements of this Performance Standard. This will include provisions related to access to and training for use of personal protective equipment (PPE), a grievance mechanism, and OHS training and workplace safety measures.

Workers’ Organizations

As per local labor laws and regulations, all regular employees have the right of freedom of association. According to  Senegalese labor law, workers’ representatives have the following tasks: ensure that workers grievances are communicated to management and to the Labor Ministry; ensure implementation of OHS preventive measures; and propose measures to improve work organization and productivity. At the time of the appraisal, there were 6 workers’ representatives.

 Occupational Health and Safety

 Most of the operations are automated using modern machines with adequate safety features and limited moving parts. Potential risks come from lifting, repetitive work, posture injuries, falls on slippery surfaces, and burns from hazardous materials.  To minimize OHS risks and incidents, the Group conducts job hazard analyses and provides necessary PPE such as hearing protection, uniforms, masks, foot wear and gloves.

 The Group maintains records of accidents and discuss all instances in quarterly meetings of the Health and Safety Committee. Regular meetings are also held with management to discuss health and safety, quality and environmental issues. 

 During construction of the new plant, the Group will ensure that the engineering, procurement and construction (EPC) contractors comply with all applicable national safety and site requirements and this Performance Standard. Important components to include are: terms of OHS management, and access to a workers’ grievance mechanism including review and response to anonymous complaints.  These requirements will be included in the contract documents as well as the ESMP for construction (ESAP #6).

 Greenhouse Gases (GHG)

 Energy is provided by the national grid and two back-up diesel generators providing 220 and 1,000 kVA electric power for operations.  Approximately one million kWh of electricity and 60 tons of diesel are consumed annually. Fuel tanks are equipped with proper secondary containment, protection from storm water, and equipped with drains to collect spilled fuel. The existing vehicle fleet is composed of 18 trucks (5 and 30 t), and 8 forklifts. Annual GHG emissions of the operations are estimated to be 2,000 tonnes CO2-equivalent per year.

Water and Wastewater

Water comes from the municipality and is stored in 3 tanks of 30 m3 for Sosagrin and 4 tanks of 100 m3 for IBS . It is treated before being used for processing, flocculation, filtration, chlorination, and dechlorination. Total water consumption in 2016 was 1,600 m3 for the mustard plant, and 35,000 m3 for the beverage processing facility. Expected quantities of water used for the recycling plant for cleaning and reconditioning used glass mustard jars are yet unknown. In line with Senegalese Environmental Law, an ESIA for the new plant will be required. As stated above under PS 1, this will include an assessment of ground water extraction potential impacts on other users.

Wastewater is mainly produced at the beverage processing plant and is discharged to the municipal system and is partially treated and sent into the ocean. Processing effluent stream has a high biochemical and chemical oxygen demand (BOD and COD) resulting from organic material and from the use of detergents for cleaning. For the existing plants and the new jar reconditioning facility, the Group will ensure that treatment of effluents is in line with good international industry practice, and the client has planned to build a wastewater treatment plant A cleaner production assessment will also be conducted prior to building the plant (ESAP #7).

 Pollution Prevention

 The main source of air emissions is from the furnace oil-fired steam 2.5-ton boiler, providing heat and hot water, and diesel-fired generators to produce electricity. The boilers and generators  undergo quarterly maintenance inspections to optimize efficiency. The oil and grease trap at the wastewater treatment plant will be emptied regularly and cleaned weekly. The sludge is disposed by a licensed contractor.

 Caustic soda and nitric acid, used in the cleaning in place system, are stored in separate areas and have proper containment.  Procedures for use of each hazardous material including Material Safety Data Sheets (MSDS), training of workers in the use of MSDSs, safe work practices, and appropriate use of PPE are in place.

 Wastes

 Solid wastes generated from the Group’s operations include wrapping material, plastic bags, cardboard, cans, drums, palets, and few hazardous wastes (used oil, air filters, batteries). Cans, drums, palets, and hazardous wastes are resold to a local operator.  Other wastes are disposed at the municipal landfill via a licensed operator.

Communities are not likely to be significantly affected due to this project. During the ESIA and environmental audits, public consultations were held in 2013, 2015, and 2016. Environmental permits were issued in January and June 2016.  The Group has a procedure for external communications that includes methods to (i) receive and register external communications and complaints 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. No grievance has been received so far as the existing operations are in an industrial zone.

  Contact Person: Rouda El Sahili

Company Name: Sosagrin

Address: rue no 6, km 4.5, boul. du CC, Dakar, Senegal

Email: RSahili@sosagrin.com

Phone: 221-33-832-18-88

Facsimile: 221-33-832-12-08