PS5: Land Acquisition and Involuntary Resettlement is not applicable to the scope of this project; however, in the future the company may look for a new site for expansion of operations and if this were to happen, the parcel of land would be secured on a willing-buyer, willing-seller commercial basis for which the company will pay prevalent market rates and it is not expected that this would entail the removal of tenants or persons using the land. PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources is not applicable as the project does not entail the cultivation of living natural resources nor the conversion of natural habitat. PS7: Indigenous Peoples is not applicable as no Indigenous Peoples have been identified within the company’s operational footprint. PS8: Cultural Heritage is not applicable as there are no cultural sites within the company’s operational footprint and no cultural heritage has been identified.

In the event that issues anticipated by these PSs arise including land acquisition, CBC will promptly inform IFC. Screening and assessment of these issues against the requirements of the PSs will be done through the company’s E&S management system (ESMS).

If IFC’s investment proceeds, IFC will periodically review the project’s ongoing compliance with the Performance Standards.

    This proposed investment is expected to have limited environmental and social impacts, which are expected to be site-specific and none is expected to be significant. Those impacts can be avoided or mitigated by adhering to recognized performance standards, procedures, guidelines and design criteria as described in the following sections. Thus, this is a Category B project in accordance with IFC’s Environmental and Social Sustainability Policy. The project is designed to avoid, minimize and manage E&S risks and impacts of the company’s operations in compliance with Haitian legal and regulatory requirements, IFC’s Performance Standards (PSs) and applicable World Bank Group (WBG) General and sector-specific (Food and Beverage Processing) Environmental, Health and Safety (EHS) Guidelines.

The key E&S risks and impacts associated with this investment include CBC’s capacity for managing water and energy consumption in an efficient manner; ongoing implementation of the quality management system and traceability/product recall mechanism; solid waste and wastewater management; and emergency preparedness and response. These E&S risks can be expected to be managed by the company through implementation of adequate mitigation measures as described in the sections below. Nonetheless, residual business risks related to the long-term availability of groundwater (upon which the project is reliant) remain as all water withdrawal practices from the aquifer (i.e. not just those related to the proposed project) are unregulated, and areas of the aquifer are starting to show signs of overexploitation.

  E&S Assessment and Management System

Currently, CBC does not have an environmental and social management system. However, CBC has developed a draft quality management system for addressing product quality issues, which currently only applies to the production of 12-ounce and 20-ounce water bottles. The company has initiated the process to obtain ISO 9001:2015 certification. The company plans to complete a pre-audit in March 2019 and achieve certification later on in the year. In the future, the company also intends to comply with the requirements of ISO 45001 (replacing OHSAS 18001) for occupational health and safety management. The specific elements of the quality management system are described in further detail in each of the sections below and by addressing the action items as outlined in the ESAP, the management system can be expected to be in compliance with this Performance Standard.

Policy

CBC does not currently have an overarching policy defining environmental and social objectives that guide the company for achieving sound environmental and social performance consistent with the principles of the Performance Standards. The company has a quality policy, which reflects the company’s commitment to provide products that meet the quality expectations of clients. The policy has been approved by the CEO and is posted in various locations around the facility. As stated in ESAP action #1, CBC will revise its existing policy to also reflect the company’s commitment to comply with all applicable laws and best practices, minimize its impact on the environment and promote good occupational health and safety practices.

Identification of Risks and Impacts

The Haitian decree on environmental management and sustainable development (enacted on 12 October 2005) outlines the requirement to conduct an environmental impact assessment for certain types of projects but does not provide further specifications on the list of such projects nor the review and approval process for doing so, which is to be reflected in another regulation that has not yet been developed. Although CBC has not undertaken a comprehensive environmental and social impact assessment of its operations, the company initiated an assessment of the operational risks related to product quality in the context of the work leading up to achieving ISO 9001 certification. This includes a limited overview of occupational health and safety of workers, which CBC plans to do develop further by undertaking a job risk analysis as well as assessing the environmental risks of its operations. Per ESAP action #2, CBC will assess the environmental, occupational health and safety, and social risks of its operations and develop the necessary corrective actions to mitigate these risks through implementation of management programs following the mitigation hierarchy of avoiding, minimizing, rectifying, reducing, and offsetting worker exposure to such risks. Any gaps in mitigation measures are described in further detail in each of the sections below and will be reflected as action items in the ESAP.

Management Programs

CBC currently does not have management programs in place for addressing E&S risks in its operations. However, the company’s Quality Management System manual lists procedures and processes for managing identified risks and impacts to product quality by operational area as organized in three levels of company operations: i) management (company operations, quality system, and external communications/clients); ii) production (procurement of raw materials, production process, and sales and distribution); and iii) support (human resources, facilities management, and accounting). For each operational area, the procedure outlines identified risks and mitigation measures, roles and responsibilities as well as objectives and indicators. Implementation is verified on a regular basis through an internal audit process to identify non-compliances with procedures and develop corrective actions for follow up. This existing framework can be further strengthened based on the requirements of each of the Performance Standards (as described in the following sections), by developing additional management plans to address the findings of the E&S risk identification process mentioned in the above. Per ESAP action #2, CBC will develop and implement management programs as described in further detail in each of the sections below and as reflected as action items in the ESAP.

Organizational Capacity and Competency

CBC recently hired a dedicated environmental, health, and safety (EHS) officer and established a health and safety committee (see section below on Occupational Health and Safety). CBC has established an organizational structure that defines roles and responsibilities for implementing the company’s Quality Management System. To this end, CBC has designated a Director of Quality Control/Research and Development who is supported by quality officers (totaling 4 people) with primary oversight for overseeing implementation of the system on a day-to-day-basis. The Director of Quality reports to the COO who in turn reports to senior management (the CEO, who approves all procedures including budget allocations related to quality aspects of company operations) and her responsibilities are described in the Quality Management System. Her responsibilities also include overseeing the annual training plans corresponding to the needs of each department to ensure that all staff are appropriately trained on relevant quality issues as reflected in their job descriptions. Moving forward, the existing organizational structure could be leveraged further to also oversee E&S risks across operations. Responsibilities for human resources and health and safety of workers (see section below on Labor and Working Conditions) have been assigned to the Director of Human Resources who also reports directly to the COO. During IFC’s site visit and based on discussions with key individuals, staff were generally found to be knowledgeable of health and safety aspects of operations.

Emergency Preparedness and Response

The CBC facility is located in a mixed-use zone (as there are no zoning laws in Haiti); immediate neighbors include an NGO, a window manufacturer and propane gas distributor, a residential community, and food manufacturing companies. The existing buildings did not sustain any structural damages during the 2010 earthquake nor recent hurricanes and the new buildings consist of pre-fabricated metallic structures, which are imported from the U.S. and considered to be secure.

The overall level of risk of CBC’s operations is not considered to be significant. Electrical faults in equipment (office and production lines) could pose a potential fire risk though likely very low as equipment is regularly serviced. Only small quantities of flammable material (such as chemicals used for machine and vehicle maintenance) are stored on-site.

CBC currently does not have a comprehensive Emergency Preparedness and Response Plan. However, as part of the company’s occupational health and safety procedures, an external contractor has been hired to advise on identifying emergency exits, preparing instructions for evacuation, installing smoke detectors and fire alarms, designating an assembly point, visibly posting emergency phone numbers, and training on First Aid (22 workers were trained in 2016). The facility is equipped with fire extinguishers (currently 24) located in strategic locations, which undergo monthly servicing through an external service provider. Currently, no emergency evacuation training exercises are being undertaken (the last one was 5 years ago) but the company plans to do so once it has developed its Emergency Preparedness and Response Plan. CBC has approached an external service provider for assistance with this. Per ESAP action #3, CBC will develop an Emergency Preparedness and Response Plan, which will first identify areas where accidents and emergency situations may occur and communities and individuals that may be impacted. Based on that, the plan will describe response procedures, provision of equipment and resources, designation of responsibilities, communications with potentially affected communities and periodic training to ensure effective response.

Monitoring and Review

The current focus of CBC’s monitoring activities is on production data related to volume of finished product, raw materials used (other than water), quality, and consumer satisfaction/complaints. Nonetheless, CBC also tracks diesel consumption, plastic bottle waste (from on-site blowing operation), estimated generation of chips from plastic bottle shredding, and the number of accidents. CBC has not yet established procedures for monitoring energy and water consumption by production line, wastewater generation, and solid waste. Per ESAP action #4, CBC will develop and implement procedures for monitoring energy and water consumption by production line, wastewater generation, and waste. Trends in data will be assessed regularly to evaluate the effectiveness of efforts to manage identified environmental, health and safety, and social risks across company operations.

External Communications

CBC does not have a written procedure reflecting the process for communicating with surrounding communities on E&S issues. To date, direct interactions between CBC and the neighboring community have been undertaken on an informal basis in response to concerns as they came up. One such example was a complaint by the community related to the discharge of wastewater, which flooded the road adjacent to the processing facility; in response, in 2017 the company installed a 1-km underground pipeline to discharge the wastewater into the Riviere Grise instead. CBC has developed an external communication procedure in the context of the Quality Management System, which applies to distributors and consumers only, and could be revised to include surrounding communities. This outlines steps for the company to receive information (satisfaction and complaints) from distributors and consumers by means of questionnaires, surveys, and client complaint forms. Per ESAP action #5, CBC will develop and implement an external communication mechanism to: i) undertake and record stakeholder engagement activities; ii) receive and register external communications from the general public and potentially affected communities; iii) screen and assess the issues raised and determine how to address them; iv) provide, track, and document responses, if any; and v) adjust aspects, as appropriate, of company operations.

  In 2018, CBC employed 407 people of which 10 were in mid- or high-management positions, 69 were skilled labor, and 327 were unskilled labor; 69 of the 407 were women. The turnover rate is 1%. CBC also employs 3 contractors (Dominican nationals) who work as equipment technicians and has a contract with an external security firm. CBC occasionally hires 6-7 seasonal workers on 3-month contracts depending on production needs.

Human Resources Policies and Procedures

Protection of the workforce in Haiti is specified in the national Labor Code (dated 12 September 1961, modified by decree on 24 February 1984), which specifies core rights and responsibilities of an employer and employees, prohibits discrimination in employment based on gender, race, age, ethnicity, religion or nationality, and describes basic terms of employment including minimum age (18 for full-time work; 15-18 as long as certain conditions are met).

CBC’s Quality Management System manual addresses the management of human resources, which outlines operational risks related to the management of human resources in terms of skills, worker rights, occupational health and safety, and internal communication process. This stipulates indicators and targets related to accident (zero major accidents and two minor accidents per month) and worker retention (above 95%). The company also has an internal code of conduct (dated May 2013), which applies to all workers and is displayed in several locations around the facility. This is available in French (and pending translation into Creole) and a copy is given to every employee. This describes basic rules for employment (hiring process, promotions, working hours, leave, overtime, and salaries), rules governing absences, worker responsibilities at the workplace including health and safety, prohibitions, rules for a respectful workplace environment, and disciplinary action. CBC ensures equal opportunity employment and does not hire people under the age of 18, but this is not specified in the HR procedure. The company’s HR policies and procedures were recently submitted for review and approval by the national authorities and are pending feedback. By addressing the action items as outlined in the ESAP, CBC’s HR policies and procedures can be expected to be in compliance with this Performance Standard.

Working Conditions and Terms of Employment

All CBC employees have individual written contracts, which are open-ended (CDI, Contrat à Durée Indéterminée). CBC deducts 6% from the salary to pay for pension fund (ONA) and contribute 6% for ONA (altogether 12%) and 3% to the national insurance (OFATMA) and for all employees and provides paid and maternity leave in accordance with national law. As part of their benefits package, some of the staff are also covered under CBC’s private health insurance policy. CBC does not currently have an on-site infirmary although there is a clinic within 5 minutes of the facility. The company plans to set up an infirmary with permanent medical staff as required under the national labor code (applicable to any employer with more than 200 workers) and all workers will have yearly medical checkups.

All workers are paid above the national minimum wage, which is 12,000 Gourdes ($150) per month and have the opportunity to earn as much as 12% more based on meeting certain performance criteria that are established on a quarterly basis. Furthermore, by law, everyone is paid a 13th-month of salary annually. CBC employees work in different types of shifts depending on the business area in which they work (administration, sales, and production). Shifts vary depending on production needs. According to the internal code of conduct, any workday beyond 8 hours in duration is considered to be overtime. By law, there is no limit to the maximum number of overtime hours per week, but workers are required to have a day off after 6 consecutive days of work.

CBC provides an on-site cafeteria with a shaded seating area where workers can either eat the lunch they bring themselves or purchase food cooked on-site, which is subsidized by CBC. There are on-site bathrooms with changing room and lockers, separated for men and women, but the condition of these needs to be improved. In the future, CBC also plans to purchase two small passenger buses to transport workers at the end of their shift from the facility to taxi stands, given the security concerns around the greater Port-au-Prince metropolitan area. Per ESAP action #6, CBC needs to renovate the toilets and changing rooms for men and women, ensuring that there is at least 1 toilet for every 25 men and 1 toilet for every 15 women (as stipulated in the Haitian Labor Code), and that these are kept clean and in good working order.

Workers’ Organizations

There is no union activity at CBC (in Haiti, this is typically the case in other sectors such as textile) but worker freedom of association is not restricted by CBC. There are regular team meetings and management maintains an open-door policy to meet with workers.

Grievance Mechanism

CBC’s internal code of conduct describes the process by which workers can share their grievances and suggestions. This entails weekly meetings between management and supervisors who discuss any concerns raised to them by workers. Current worker complaints revolve around pay roll errors, overtime calculations, and conflicts between workers. There currently is no anonymous process (such as suggestion boxes) or other channel for workers to raise concerns. In case of a conflict between workers or with a supervisor, this is mediated and resolved with the input of the Human Resources Director. CBC recently developed a template for recording grievances as well as a log for tracking these but there is no comprehensive procedure that states what the different channels are for workers to submit a grievance, the time frame in which management commits to resolve these, and the recourse a worker might have in case of he/she is not satisfied with the outcome of the resolution. Per ESAP action #7, CBC will need to design and implement a grievance mechanism accessible to all workers, which will need to include i) procedures for documenting, managing, and monitoring their resolution; ii) involvement at appropriate level of management (including designated staff and accountability); iii) clear and timely management of grievances; iv) allow for anonymous complaints to be raised and without fear of retribution; and v) inform access to other judicial and regulatory mechanisms available under the Haitian Labor Code. The mechanism will need to be accessible by all workers and CBC will need to inform all workers about the objectives and procedures for the workers’ grievance mechanism and how it operates.

Occupational Health and Safety

The facility’s processing activities include unloading and washing of returned 5-gallon plastic jugs before loading washed or new jugs on a conveyor belt where they are filled and capped through a partially automated process. Full bottles are manually removed from the conveyor belt at the end of the process before being loaded into storage racks for transport. The 20-ounce production lines are fully automated, although at various parts of the process some handling/manual input by workers is required before bottles are packaged and loaded onto palettes, enabling them to be more easily moved with a forklift.

CBC’s Quality Management System manual includes limited reference to managing occupational health and safety of employees; the focus is primarily on hygiene (to mitigate potential quality risks in the finished product). The company has yet to conduct a comprehensive job risk analysis to identify types of hazards (for example, impacts of splashes or volatility to workers involved in handling liquid chlorine during the raw water treatment process), likelihood of risk, and how to mitigate the risk by job function/position in order to implement the necessary safety measures (for example, changes to machinery, work place practices, posting of hazard signs, employee training on hazards, and use of personal protective equipment (PPE) such as gloves, face mask, and rubber boots). Some signage related to quality and food safety (such as use of required PPE, hand washing, and prohibited behaviors) was noted around the factory. This is further supported by regular internal inspections to verify the cleanliness and good functioning of the work environment so that any potential risks related to the quality of the product as well as to workers can be addressed right away.

Per ESAP action #8, CBC will develop a comprehensive job risk analysis to identify types of work place hazards, likelihood of risk and severity of risk (for example, based on information reflected in the Material Safety Data Sheets of chemical products used), and how to mitigate the risk by job function/position in order to implement the necessary safety measures. Procedures will also need to reflect steps to follow in case of an accident or injury, including documenting the occurrence of the injury and corrective measures to prevent reoccurrence, and tracking accident and injury statistics.

The company established a committee for health and safety in October 2018, which consists of 5 members and meets on a regular basis (once a week for one hour). Members of the committee are in the early learning phase and require capacity building and training to become more effective in their role. The committee will be headed by the EHS manager that CBC just hired, who will oversee implementation of the annual health and safety plan. The roles and responsibilities of the committee are reflected in an internal code of conduct and include: i) preparing a health and safety plan; ii) coordinating all health and safety activities across company operations; iii) improving awareness and understanding of health and safety issues; iv) proper use of PPE; and v) preventing physical risks (for example due to slipping or heavy lifting), working at heights, and those due to chemical exposure.

Per ESAP action #9, CBC will develop a training plan for the health and safety committee to improve their understanding of health and safety issues and capacity to help them support and implement mitigation measures through a combination of job risk analysis to identify and eliminate risks, development of training programs and proper use of PPE.

The company tracks accidents and incidents. CBC recorded 7 incidents/injuries in 2018 (6 were due to slipping and minor cuts while 1 was due to a nail piercing a worker’s foot), which resulted in 10 lost work days as well as 10 accidents related to vehicles (resulting in minor vehicle damage). There are First Aid kits in various locations around the facility.

Supply Chain

CBC’s fruit flavored beverages and iced tea contain sugar as a primary raw material as well as a number of other ingredients in smaller quantities such as flavor concentrate, preservatives, and vitamins in addition to water. These raw materials are imported to Haiti by suppliers with which CBC has contracts in place that stipulate the quality requirements and technical specifications.

   The operations of CBC that have a risk of polluting the environment are related to the discharge of untreated wastewater (high loads of dissolved salts from the reverse osmosis water purification process and limited loads of sugar from cleaning production lines) and possible diesel and oil spills. These impacts can be mitigated through effective implementation of management programs. With regards to consumption of natural resources, the company does not yet measure its efficiency in the use of energy or water but plans to do so in the future and to benchmark itself against the performance of other similar companies in the sector.

Energy and Resource Efficiency

CBC operations are powered by electricity generated on-site by 3 x 500-kW generators and 1 x 80 kW generator. Starting in 2019, the company will lease new generators from an external service provider that will charge CBC for the generation of electricity and also oversee all regular maintenance activities; existing generators will be kept for back-up power. CBC will procure and pay for the diesel fuel to power the new generators. In 2018, the total energy consumption was 2,803,171 kWh with peak usage in May-September (plant operating 24 hours per day and 7 days per week compared to 6 days per week during the off-season). This also included the production of ice, which the company has now ceased to do and which is expected to reduce the current energy consumption by 15%. With the new production line, it is expected that the monthly energy consumption would increase by 66,400 kWh, resulting in an overall projected annual consumption of 3,582,695 kWh. CBC currently does not have electricity meters in the different production zones and has not undertaken an energy efficiency audit to identify potential improvements in energy consumption. In 2014 and 2016, CBC benefited from an assessment to determine the financial viability of installing solar power, which entailed a site audit of electricity usage and inefficiencies at that time. At the time, the company deemed it was not financially viable to proceed with this investment.

Per ESAP action #10, CBC will install electricity consumption meters and develop an energy management plan to monitor energy consumption by processing line and identify opportunities for reducing energy consumption (including energy efficiency initiatives as well as possible alternative energy sources).

Water Consumption

CBC’s operation is located in the Plaine du Cul-de-Sac, where it extracts water from the Cul-de-Sac aquifer, which extends to the east of Port-au-Prince and is bordered to the north by the Chaine of Matheux mountain range and to the south by the Massif de la Selle mountain range. The aquifer borders to the east with Lac Azuei (a pond consisting of brackish water and believed to have once been connected to the sea), adjacent to the border with the Dominican Republic border, and Port-au-Prince Bay to the west. The principal rivers that discharge into the Cul-de-Sac watershed are the Rivière Grise and the Rivière Blanche, which are perennial and disappear in the Plaine du Cul-de-Sac during low flow but reach the sea during floods.

The climate in the area of the aquifer is considered sub-tropical and the distribution of rainfall is bimodal, with most of the rain falling during the months of April-May and August-November and ranging from 850 mm/year in the aquifer plain to 1,700 mm/year in the upper elevations of the surrounding Massif de la Selle. The slopes of the Massif de la Selle are among the steepest slopes in Haiti and extremely vulnerable to soil erosion and landslides, especially as these areas are being deforested to make room for land cultivation or exploit wood resources that further expose the slopes to increased rates of runoff, which negatively impacts recharge of groundwater reserves. The flows of the major rivers (Grise and Blanche) tend to be erratic and prone to increased frequencies of disastrous flood conditions. Soil erosion further contributes to extremely high sedimentation of the coastal marine environment.

The Cul-de-Sac watershed is among the most important watersheds in Haiti in terms of supporting the water requirements of the most densely populated area of the country (the Port-au-Prince metropolitan area, home to approximately 24% of the country’s population) as well as a concentration of industrial activities, agriculture (although currently only small-scale, but historically large-scale and the second largest employer in Haiti given the highly fertile and flat nature of the Plaine du Cul-de-Sac), and commercial water distribution activities that service homes and businesses in the absence of reliable water infrastructure. Given the lack of groundwater monitoring and records, it is challenging to quantify the aquifer’s current health and sustainability. According to information in a report prepared by Northwater International and Rezodlo on behalf of the United States Agency for International Development and the American Red Cross in February 2017, the groundwater development ratio of the aquifer (using modeled recharge rates and estimated abstraction rates) is estimated to be 0.92 (i.e., 92% of the aquifer’s renewable groundwater supplies are currently being exploited) and starting to show signs of overexploitation (reports of the water table steadily decreasing). Abstraction for industrial and commercial use is expected to increase as Port-au-Prince continues to grow; agriculture demands for irrigation are currently low but could potentially increase in the future. There are concerns related to reduced recharge of the aquifer due to diversion of streams for irrigation, land-use changes (primarily deforestation) affecting streamflow, and climate change affecting rainfall patterns. Evidence of contamination of the aquifer due to saltwater intrusion (in the west), untreated human sewage, and industrial wastes further exacerbates the situation. This causes serious concerns over the capacity and long-term sustainability of the Cul-de-Sac aquifer in terms of water availability and quality.

In Haiti, there currently is no law that regulates groundwater usage other than granting a groundwater well permit (through the Ministry of Finance). However, draft legislation to manage Haiti’s water resources (ANARHY) was signed on 19 April 2017 but has yet to be enacted by the government and there is little clarity at this stage when it might come into effect given ongoing country instability. Furthermore, the government does not currently have a comprehensive inventory of the status of aquifers, groundwater conditions, and existing wells across the country. However, with the support of an on-going World Bank project, the Direction Nationale de l’Eau Potable et l’Assainissement (DINEPA—Bureau for Potable Water and Sanitation) has been working on developing such an inventory.

CBC sources all water from two on-site groundwater wells (150 feet deep, dating to 2003 and 250 feet deep, dating to 2018), respectively extracting at a depth of 100 feet and 250 feet, for which it has obtained the necessary authorizations, which are renewed on an annual basis. The company currently does not have meters in place to track the amount of water extracted from each well nor is the use of water by production line monitored other than in terms of finished product. Based on total production volumes and estimated inefficiencies in currently used equipment (ranging from 5-15% in water loss depending on the production line), the company estimated that in 2018, the total annual consumption of water was 1,593,266 hectoliters (which included the production of ice although moving forward the company has ceased this activity). With the additional production line, CBC estimates that water consumption will increase annually by 7% (equivalent to 109,652 hectoliters) with total annual consumption by 2026 projected to be 2,620,063 hectoliters. However, this does not include water usage for other activities such as washing 5-gallon jugs for reuse, clean-in-place during the product change-over in production lines, washing trucks, and employee restrooms.

Based on estimated water usage provided by the company, CBC’s current groundwater withdrawal represents approximately 0.3% of cumulative withdrawals from the Cul-de-Sac aquifer, which is expected to increase to 0.4% with the additional production line. Although CBC’s current pressure on the aquifer is comparatively low, CBC needs to improve water efficiency in its operations to minimize as much as possible any potential impacts of its operations on the aquifer. This may also include evaluating alternatives for sourcing water from a different aquifer. Regardless of the above, residual business risks related to the long-term availability of groundwater remain as current water withdrawal practices from the aquifer are unregulated and areas of the aquifer are starting to show signs of overexploitation based on the report prepared by Northwater International. As the manner in which groundwater resources outside of company operations are currently unprotected and/or consumed lies beyond CBC’s control, the extent of the risk and long-term implication on CBC’s business operations remains uncertain and cannot be quantified in absolute terms.

Per ESAP action #11, CBC will develop a water management plan to monitor water extraction by groundwater well and use by processing line to identify opportunities for reducing water consumption (such as reducing loss/leaks in the processing lines and reuse of treated water).

Air Emissions

The main source of air emissions across CBC’s operations are from the operation of the three on-site generators. Starting in 2019, the generators will be used only to supply back-up power as electricity will be sourced from leased generators from an external service provider, who will also oversee maintenance activities. The company uses two small-capacity (80 BHP, equivalent to 2678 KBTU/hr), propane-powered boilers, one of which is operated about 6 hours per week for the clean-in-place process and the other one about 120 hours per week for rinsing returned 5-jug bottles. The combined capacity of CBC’s boilers and generators is below WBG’s established threshold for small combustion facilities (3-50 MWh) and therefore does not require air emissions monitoring. There is no law in Haiti governing air emissions. Annual GHG emissions are estimated to be 3,986 tonnes of CO2 equivalent.

Wastewater Treatment

Wastewater is generated primarily as a result of the water treatment process (reverse osmosis), which is estimated to represent 359,727 hectoliters (equivalent to 25% of production water) annually; additional sources of wastewater generation include product loss due to filling inefficiencies (ranging from 5-15% in water loss depending on the production line), washing 5-gallon jugs for reuse, clean-in-place during the product change-over in production lines, washing trucks, and employee restrooms.

All wastewater from the production process drains into an on-site underground, concrete storage tank (with a capacity of 20,000 gallons), which is connected by means of a 1-km underground pipe that discharges into the Riviere Grise. CBC has received the necessary authorization by the municipality to discharge but there is no regulation requiring treatment nor stipulating effluent quality criteria. It should also be noted that although the Riviere Grise is one of two main rivers within the Cul-de-Sac aquifer watershed, it is subject to extended dry periods/low water flow and furthermore, the riverbed is severely degraded due to dumping of domestic waste, domestic activities (such as washing clothes), and sand/gravel quarrying. CBC does not currently treat wastewater prior to discharge nor does it track the volume of wastewater generated. Moving forward, CBC has requested the assistance of Culligan International in developing and installing an on-site wastewater treatment option, which would treat total suspended solids, BOD, total nitrogen, and total phosphorus in the water. To this end, CBC will undertake wastewater sampling at the point of discharge into the Riviere Grise and to the extent possible (given the seasonal variability in river flow), will also sample current water quality in the Riviere Grise upstream and downstream of the discharge point. Based on such results, CBC will determine the need for and type of wastewater treatment to avoid further degradation of water quality in the Riviere Grise in keeping with the objective of the Performance Standards and EHS Guidelines.

Storm-water runs off into on-site drains and discharges into an unlined storm-water trench outside the facility. Wastewater generated from hosing off trucks flows into these drains or evaporates as there is no dedicated area for washing vehicles. There are several septic tanks on site to collect the wastewater discharge from the toilets, which are emptied on a regular basis by an external contractor and disposed of at a designated landfill.

Per ESAP action #12, based on the findings of the wastewater sampling at the point of discharge into the Riviere Grise as well as of water quality upstream and downstream, CBC will assess the need for installing an on-site wastewater treatment system to treat effluent prior to discharge to ensure that this meets IFC’s standards for discharge (as reflected in the IFC EHS Guidelines for Food and Beverage Processing). CBC will establish a vehicle washing area consisting of a paved surface area equipped with drains in which oil water separators and grease traps have been installed. Furthermore, CBC will develop a wastewater management procedure, which will include periodic testing of the quality of the effluent to ensure the on-going effectiveness of the wastewater treatment unit.

Solid Waste Management

CBC has a written waste management procedure, which reflects most of the types of waste streams generated, how these are collected on-site, and how these are disposed. The company currently does not formally track the volumes of waste generated. Waste is either re-used/recycled or disposed of through an external service provider. On-site waste storage practices could be further improved by ensuring that waste is placed into bins, equipping bins with a lid to prevent dispersal by wind, and preventing leakage and spills from drums.

CBC generates the following waste streams in limited quantities: domestic waste (associated with the on-site employee cafeteria), defective packaging waste (estimated 1-1.5% for the 20-ounce filling lines and 3-4% for the 5-gallon filling lines), and raw material packaging (paper, plastic, glass, metal). These are collected on-site in dedicated waste bins, which are emptied three times per week by an external service provider. The on-site laboratory generates limited quantities of hazardous wastes, characterized by small quantities of solvents, which are collected by an authorized external service provider and disposed of in an adequate manner. The company also performs basic maintenance activities on-site on its vehicles and equipment and has a dedicated garage/workshop area, which generates small quantities of hazardous waste such as used oil, used oil filters, soiled rags, and use batteries. Used oil is collected on-site in drums before being given away for reuse by members of the community. Currently, used oil filters are thrown into waste bins and disposed of with other solid waste.

Per ESAP action #13, CBC will revise the waste management procedure to include all waste streams and a process for recording volumes of waste generated including records of waste disposal by the external service provider. CBC will also improve on-site waste storage practices through ensuring that waste is placed into the proper bins (including the disposal of used oil filters, which should be handled as hazardous waste), equipping bins with a lid to prevent dispersal by wind, and preventing leakage and spills from used oil drums.

Annually, approximately 98% of the 5-gallon jugs sold by CBC are recycled/reused while only 2% are new; some jugs end up as waste as they cannot be reused (damaged or used to store a noxious product) or are never returned to CBC. CBC has a shredding machine on-site and estimates that it shreds approximately 300,000 pounds of plastic annually, which is sold primarily to the U.S. CBC recently improved the design of its 20-ounce bottles, which resulted in a 20-percent reduction in the volume of plastic used and will be used in the new production line; the older 12- and 20-ounce production line will be retrofitted to accommodate this new bottle design.

Based on 2018 sales, the CBC indirectly generated the following waste associated with the packaging of its products: 1.5-liter PET bottles (equivalent to 9,359 pounds of plastic waste); 20-ounce PET bottles (equivalent to 406,824 pounds of plastic waste); and 12-ounce PET bottles (equivalent to 1,292 pounds of plastic waste). In Haiti, waste management practices in general are poor (both in terms of pick-up services and proper disposal methods) as evidenced by the piles of discarded waste along streets and in river beds. There are no consumer recycling initiatives that would facilitate or provide an incentive for consumers to properly dispose of recyclable waste such as PET bottles. Despite this, there is a small plastic recycling market in Haiti entailing 4-5 companies, which transform plastic waste into chips for sale primarily to the U.S. market (and previously the Chinese market, which has now closed) although the financial viability of these companies remains challenging. One such company was created in 2013 by the major bottling companies in Haiti, including CBC. In 2018, CBC as well as the other bottling companies gave up their participation as the company required additional investments to move beyond grinding plastic waste for sale abroad in order to make it financial sustainable. First as an investee company of an IFC-financed private equity fund, the company specializes in both plastic bottle recycling (to export as chips) and manufacturing plastic items (such as bottles and caps) from new PET pre-forms. Recently through a loan from IDB, the company is in the process of installing a processing line to manufacture non-food grade household items such as buckets, detergent containers, and crates from recycled plastic bottles. The company relies on a network of collectors from which it buys waste plastic bottles at a rate of 3 Gourdes ($ 0.04) per pound of plastic waste collected (equivalent to 24 20-ounce PET bottles).

Hazardous Materials Management

CBC uses the following hazardous materials in its operations: i) diesel (to power the three on-site generators); ii) caustic acid for the clean-in-place process for the 12- and 20-ounce production lines; and iii) limited quantities of chemicals (in the quality assurance laboratory). Diesel is stored in two 6000-gallon aboveground storage tanks used in conjunction with operating the generators and one 300-gallon aboveground storage tank, used in conjunction with the vehicle fuel pump. These storage tanks are filled 2-3 times per week by an external tanker truck. Fuel (diesel) consumption in 2018 was 259,251 gallons for energy generation and 129,932 gallons for operating trucks and forklifts. The storage tanks and the area around the fuel pump lacked the proper secondary containment measures to prevent ground contamination in the event of a spill; CBC currently does not have procedures for spill prevention and clean up.

Caustic acid is stored in 55-gallon drums in a dedicated storage area, which is locked; however, there currently is no secondary containment. Small quantities of chemicals (less than 1 liter) are purchased at a time and stored in a locked cupboard with controlled access and handling by trained laboratory technicians. The laboratory maintains a register of the Material Safety Data Sheets (MSDSs) for all the chemicals used on-site.

Per ESAP action #14, CBC will ensure that hazardous materials (in particular, diesel and caustic acid) are adequately stored with secondary containment measures to prevent ground contamination in the event of a spill and will develop procedures for spill prevention and clean up.

Pesticide Use and Management

CBC currently does not have a written pest management procedure. However, CBC has a contract with an external service provider, which conducted an assessment of the facility in 2017 to assess risks and prescribe prevention methods (ranging from regular maintenance activities to installation of pest control devices/traps and fumigation on a regular basis). CBC has received training in 2017 and 2018 on sanitation and good manufacturing practices from the service provider and has developed a sanitation action plan for the factory but there is no track record to reflect actions taken. The service provider undertakes fumigation and trap inspections twice a month to identify early on the potential need for more aggressive pest treatment.

Per ESAP action #15, CBC will develop a pest control and prevention procedure to fight insects and rodents. This will entail implementing an integrated management approach for maintaining a clean environment inside the facility (by preventing the accumulation of organic matter and removing all waste immediately), preventing entry (screened windows and keeping doors/windows closed), monitoring and repairing all potential cracks in walls, and keeping the exterior of the factory clear of vegetation.

  Food Safety Impacts and Management

In Haiti, the quality of water that is sold as potable water is regulated by the recently established Direction Nationale de l’Eau Potable et l’Assainissement (DINEPA—Bureau for Potable Water and Sanitation) and follows the norms for potable water as established by the World Health Organization. CBC regularly tests water at various points in the process in its on-site laboratory and also through an external laboratory in the Dominican Republic and in the U.S. for further analysis against the standards of the International Bottled Water Association (IBWA). Water is treated on-site (chlorination, 6-stage filtration system including reverse osmosis patented by Culligan International, UV treatment, and ozonation). To date, CBC has not experienced any concerns related to groundwater contamination in particular saltwater intrusion, which could become a potential concern in the future if water extraction continues to be unregulated (see section above on Water Consumption).

CBC’s Quality Management System focuses on the 12- and 20-ounce processing lines and includes procedures for verifying the quality of all raw materials, testing product quality during the production process, and a traceability mechanism including product recall process to rapidly respond to consumer concerns. Activities at CBC’s processing facility are organized such that products move from “dirty” to “clean” areas to avoid contamination. The filling of the finished product for the 12- and 20-ounce processing lines is done through automated filling machines, thus removing the potential for contact between workers and the finished product; the filling of the 5-gallon jugs is also automated but the capping of the bottles involves a worker. This reduces the risks related to hygiene and food safety and mitigates potential impacts to the community. All staff have received training on product quality and hygiene and follow established procedures for hand washing and wearing proper attire (clothes, shoes, gloves, and hair coverage). There are washing stations and signage at the entrance of each production area.

CBC has procedures for undertaking regular internal audits of operations according to an annual program and has designated a team (4 staff) of auditors, of which 3 are ISO certified. This includes a clearly defined plan for regular monitoring and inspection of hygiene conditions of the processing facility as well as overall conditions of the buildings and equipment. CBC is working toward achieving ISO 9001 certification by 2019 CBC has not yet formally reviewed its processing lines against the principles and practices of Hazard Analysis Critical Control Points (HACCP) but plans to do so in 2020.

Per ESAP action #16, CBC will expand the scope of the Quality Management System to include all the production lines including the 5-gallon water jugs. CBC will undertake a gap analysis of its operations against HACCP and other internationally recognized certification schemes (such as ISO 22000) and take the necessary steps to be certification-ready within 3 years.

CBC has an on-site laboratory for undertaking microbial and chemical analyses of product samples at every stage of the production process. The company has procedures for product coding and traceability to quickly identify and recall a product in case it does not comply with the company’s standards. A code is assigned to each batch and displayed on the final product so that the origins of all ingredients can be traced, should there be a complaint or quality problem later on.

Transportation Safety

Vehicle traffic to and from the processing facility involves the daily movement of CBC’s own trucks as well as those of contractors to transport the finished product for distribution. CBC currently owns 34 vehicles for the transport of 5-gallon jugs and plans to buy 40 additional trucks. CBC also employs contractors: 7 for the distribution of 5-gallon jugs and 6 for transporting 12- and 20-ounce bottles directly to wholesalers and retailers. CBC has written contracts in place that include the requirement to have insurance, but the company does not verify the driver safety record. Trucks used by contractors are visually inspected for safety functions (condition of tires) and cleanliness (condition of truck bed) and if they are deemed unsuitable for transporting the product, the contractor is notified, and the trucks are turned away. CBC currently does not have a specific policy or procedure in place for ensuring the safe operation of vehicles (for example, screening drivers and providing formal training on safe driving) nor for documenting incidents and accidents. Per ESAP action #17, CBC will develop a process for screening drivers prior to hiring including verification of valid driver license and past driving record; providing driver safety training to respect speed limits, not use a cell phone while driving, use of a fire extinguisher, and vehicle maneuvering skills; procedures for limiting trip duration, duty roster to avoid overtiredness, avoiding dangerous routes and times of day to reduce the risks of accidents, use of speed control devices on vehicles; inspection of vehicles at the processing facility after each delivery for any evidence of having been in an accident; and overall truck maintenance to ensure good working conditions. The same requirements will apply to contracted drivers.

Security

The processing plant is surrounded by a 2.5-meter high, concrete perimeter wall and CBC employs security guards through an external service provider to control access to the site. Guards are present on site in 2 shifts, 24 hours a day/7 days a week, are armed, and have been trained on the proper use of arms, which in Haiti includes not being allowed to fire a shot outside the facility. The processing facility is equipped with a CCTV system, which has been partially set up and provides 70% coverage of the site as well as flood lights. CBC does not currently have a written security procedure; security guards are not vetted by CBC as they are provided by a reputable security provider. Per ESAP action #18, CBC will develop a security procedure to include i) reviewing the screening procedures of the external service provider to confirm that security guards have been properly vetted (at a minimum, background check to verify criminal record) and are suitable for the job; ii) description of responsibilities of security guards such as controlling access and verification of people entering the site; iii) interactions with the CBC workforce; iv) interactions with the surrounding community; v) duties in case of an emergency at the site; and vi) regular reporting to CBC management in case of incidents or grievances received from the surrounding community.

    CBC has gone through a stakeholder mapping exercise, which identifies key stakeholder groups (including employees, consumers, and communities) and methods of engagement with each of these. No further information was provided on regular community engagement activities reflecting dates of meetings, issues raised, and how these were addressed by the company. CBC needs to develop a mechanism for receiving and responding to any concerns or complaints from the surrounding community (see section above on External Communications).

  Contact Person: Mr. Gaetan Barrau

Company Name: Caribbean Bottling Company (CBC)

Address: Santo 17, Croix-des-Bouquets, Port-au-Prince, Haiti HT 6133

Email: gbarrau@culligan.ht

Phone: +509 2816 1701/02