Environmental and Social Assessment and Management System and Policy
Gtronics has a corporate OHS, Environmental and Quality policy in place adopted at all the operating sites (http://www.gtronics.com/company-policy). The policy reiterates Gtronics’ commitment to preserve the environment, maintaining natural resources, the reduction and mitigation of global warming, providing a safe work environment to employees, and energy efficiency management.
The Company has obtained regulatory permits including approval for Environmental Impact Assessment (EIA) studies for both facilities by the Egyptian Environmental Affairs Agency (EEAA). The operations in the two plants are certified compliant with international management systems standards, viz. ISO 9001:2008 Quality Management System; ISO 14001:2004 Environmental Management System; OHSAS 18001-2007 Occupational Health and Safety Management System.
For the new facility in Saudi Arabia, given the limited E&S risks an EIA was not required by the local authorities. However, prior to construction the Company obtained the necessary approvals including the environmental approvals. As set forth in the ESAP, an E&S risk assessment including hazards risk identification and risk assessment (HIRA) will be conducted prior to start of operations, and an action plan will be developed to manage the identified risks.
The Company has an environmental management system manual in line with ISO 14001 requirements. The manual covers the scope of the environmental management system, the roles and responsibilities within the Company, the OHS, environmental and quality policy, risk and opportunities planning procedures, environmental objectives, resources allocation, operational procedures and emergency preparedness, monitoring and improvement. Based on the manual the Company has detailed procedures for risk management, monitoring environment and safety process performance, human resources and training, and supplier evaluation.
Given Gtronics’ plans to expand its operations in other countries-, the Company will develop ESIA studies according to national requirements and IFC PSs and shall obtain the necessary approvals.
Additionally, Gtronics will ensure its corporate Environmental and Social Management System (ESMS) will be updated in accordance with the new developments in the Project and will include new plans and procedures (e.g., land acquisition plans, chance find procedures, biodiversity management plans, etc.). Specifically, since IFC’s proposed equity investment in the Company might be used to support future developments which are not fully defined yet, as part of the E&S management systems update, the Company shall develop a screening and due diligence procedure, to assess all relevant social and environmental risks and impacts, including the applicability of PS1 through PS8 arising due to the new business opportunities, developments, acquisitions or mergers in the Project lifespan and developing necessary mitigation and management plans. (ESAP #2).
Organizational Capacity and Competency
Gtronics has an established environmental, health and safety (EHS) organizational structure with defined roles and responsibilities and reporting lines for staff managing EHS. As per the Company’s organogram, at the facility level, the environmental, and occupational health and safety department reports to the general manager who reports to the chairman. The environment and OHS department is composed of an EHS specialist and an internal auditor, and they coordinate closely with the quality manager. The team is responsible for developing and implementing EHS policies and procedures and supervises all activities related to EHS within the Company including overseeing day-to-day operational EHS issues.
The EHS team are focused on the country level operations, and with the planned expansion of the Company, it is expected that an EHS person will be needed at the corporate level. As set forth in the ESAP, an experienced EHS person (who will also serve as the management representative for E&S management systems) would be hired at the corporate level to have an overview of the global operations of the Company and ensure that all polices, and procedures are implemented across all facilities.
Emergency Preparedness and Response
The Company has an emergency plan that was last updated in January 2018 and is approved by the civil defense authority. The plan objective is the protection of the people (workers, contractors, visitors, and surrounding community), equipment and facilities, and production against any unsafe and harmful events. The types of emergencies covered are fire, spills and natural disasters. For protection against fire, the Company has smoke detectors, and fire extinguishers and hydrants installed across the plants. The types of fire extinguishers depend on the fire risk in each area, and they include carbon dioxide, foam, and dry powder.
The Company has two emergency water tanks with a total capacity of 180 m3 in one plant and two water emergency tanks with a capacity of 120 m3 in the other plant. At each shift, there are designated employees responsible for firefighting who undertake relevant trainings. Evacuation routes and assembly points have been designated and clearly marked. Fire drills are conducted on an annual basis for each of the two plants, in coordination with the civil defense authority.
The emergency plan sets the expected scenarios for the different types of emergencies, including fire or explosion, natural disaster, tin spills, sand storms, and tin suction equipment failure. The action and procedures in each case of emergency are documented in the plan and communicated to all workers.
Monitoring and Review
The Company has procedures for monitoring environment and safety. Daily monitoring includes visual inspection of work place environment, including housekeeping, use of personal protective equipment, emissions, and electric connections. Weekly monitoring is conducted for firefighting equipment. Accidents and incidents are recorded and compiled on a semiannual basis. Environmental monitoring and workplace monitoring are conducted on an annual basis and documented in the Company’s environmental register. Noise levels and light intensity are measured in 10 locations in both plants, while heat stress is measured in the plastic injection area and the meter assembly area. In addition, formaldehyde is measured in the plastic injection area, and tin is measured in two locations in the meter assembly lines. The only source of point source air emissions in the plant is the standby generator, where combustion emissions are monitored.
