PS5: Land Acquisition and Involuntary Resettlement is not applicable to this project as land acquisition will entail a willing-buyer-willing-seller commercial basis for one parcel for which the company will pay the current owner market-related rates and leasing the other parcel from a private owner, and which will not entail the removal of tenants or persons using the land. A portion of the parcel of land that will be bought is still being used for commercial agriculture activities by a privately-owned company; only a small portion of the other parcel (which belongs to one of the shareholders) has been cultivated. For any additional land purchases, the company will ensure that the land is not occupied nor being used for economic purposes, and the acquisition process will follow the requirements under this Performance Standard and will screen against the requirements of Performance Standard 6.

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 no cultural sites are expected to be found within the company’s operational footprint and no cultural heritage has been identified.

In the event that issues anticipated by these PSs arise including any additional company expansions, SAF 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 Senegalese legal and regulatory requirements, IFC’s Performance Standards (PSs) and applicable World Bank Group (WBG) General and sector-specific (Annual Crop Production, and Food and Beverage Processing) Environmental, Health and Safety (EHS) Guidelines.

Key E&S risks associated with this investment are: (i) the occupational health and safety risks associated with the construction of the greenfield dehydration plant; (ii) once operational, capacity and ability of SAF to manage and monitor the EHS risks associated with producing dry onion products; (iii) occupational health and safety including life and fire safety during operations; (iv) working conditions and terms of employment; (v) surface water withdrawal and consumption; (vi) management of hazardous materials such as chlorine, on-site fuel storage, and pesticides; (vii) wastewater management; (viii) road traffic safety associated with transport of raw material and finished product; and (ix) sustainable supply chain assurance (related to the 600 smallholder farmers) including raw material quality.  

    Environmental and Social Assessment and Management System

As a greenfield project, SAF has not yet developed an integrated strategy and framework for addressing environmental, health and security, food safety and social (EHSS) issues across its operations. However, existing procedures of Dijon Céréales and those previously implemented by STL will be revised and adapted for the purposes of SAF operations in Senegal. Moving forward, an EHSS management system is expected to be developed and implemented in compliance with this Performance Standard as outlined in ESAP action #1. This shall include: i) an overarching EHSS policy; ii) process for identifying risks and impacts across company operations; iii) EHSS management programs and procedures, including energy, water, waste, and wastewater management plans; iv) implementation of the mitigation measures as identified in the ESIA and any additional aspects as contemplated under the principles of IFC’s Performance Standards (as identified in the ESAP); and v) monitoring process of EHSS parameters to track changes on a monthly/annual basis and assess the effectiveness of management programs in mitigating the identified EHSS risks across company operations.

Policy

The company does not currently have a written EHSS policy but moving forward will revise and adapt those of Dijon Céréales and STL for the purposes of SAF operations in Senegal. Per ESAP action #1, SAF will develop an overarching statement of the company’s commitment to the sound management of environmental, health and security, food safety and social issues, encompassing the dehydration plant, its own plantations, and its procurement practices across its network of onion farmers.

Identification of Risks and Impacts

SAF will revise and adapt STL’s procedure for identifying E&S risk of operations, which will also include a process for reviewing and assessing applicable national E&S laws and regulations. In accordance with Senegalese law, an Environmental and Social Impact Assessment (ESIA) for the proposed dehydration plant was already undertaken in October 2016 and was revised in September 2019 to reflect the selection of a different site than the one originally considered. Once finalized, it will be presented to the relevant authorities for approval. SAF will implement the mitigation measures stipulated in the ESIA. However, the ESIA was not undertaken according to the requirements of IFC’s Performance Standards (PSs) and applicable World Bank Group (WBG) General and sector-specific (Annual Crop Production, and Food and Beverage Processing) Environmental, Health and Safety (EHS) Guidelines. As such, the scope of proposed mitigation measures as stipulated in the ESIA and to be implemented by SAF at the processing plant are limited. Additional mitigation measures are described in further detail in each of the sections below to comply with the requirements of IFC’s Performance Standards (PSs) and applicable World Bank Group (WBG) General and sector-specific (Annual Crop Production, and Food and Beverage Processing) Environmental, Health and Safety (EHS) Guidelines will be reflected as action items in the ESAP.

STL’s dehydration plant was previously certified FSSC 22000 and ISO 22000 (the last audit was undertaken in January 2014) when it was fully operational. The design of the plant has considered the requirements of Hazard Analysis Critical Control Points (HACCP), which will be reassembled to the same standard in Senegal. The company will undertake the necessary steps for developing and implementing procedures to comply with HACCP requirements and aims to obtain FSSC 22000 certification within 3 years (see section below on PS4: Community Health, Safety and Security).

SAF will use pivot irrigation (see section below on PS3: Resource Efficiency and Pollution Prevention) and follow sustainable agricultural practices (see section below on PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources).

Management Programs 

The construction of the dehydration plant will be undertaken under the oversight of Biaugeaud technicians from France, making use of locally contracted construction staff. As per ESAP action #2, SAF will ensure that the necessary contractual clauses are included in EPC contracts, stipulating that labor and occupational health and safety measures and controls are in place at the construction site to mitigate the risk of labor non-compliances, accidents and injuries. Furthermore, SAF will have monitoring oversight and require regular reporting on occupational health and safety statistics from contractors during the duration of the construction phase.

As part of the ESIA, SAF will be required to implement general corrective measures for managing environmental and social aspects of operations in order to reduce impacts related to: ambient air quality, noise, chemical spills, waste, wastewater, occupational health and safety, traffic safety, and community outreach. Based on the requirements of each of the Performance Standards described in the following sections, SAF will be required to develop additional management plans or to further expand the scope of the corrective measures listed in the ESIA as reflected in the ESAP.

Organizational Capacity and Competency

SAF has prepared an organizational structure, which includes a position for an EHS officer who would report directly to the Chief Executive Officer of the company as well as a quality control function who would report to the Chief Technical Officer. The Chief Executive Officer and the Chief Technical Officer are expected to be expats, while to the extent possible, all other staff will be local hires. SAF has already hired an experienced agronomist (expat) on the ground in St. Louis who has been involved in the design of the nuclear farm and the out-grower program. SAF is already in the process of developing a comprehensive and detailed training plan, which will be implemented with the assistance of Dijon Céréales and STL once key staff (supervisors and technical) will have been hired. As per ESAP action #3, SAF will recruit a suitably qualified EHS officer whose responsibilities will include the development and day-to-day oversight of the implementation of the EHSS management system, assigning responsibilities to staff for implementing the necessary tasks required, and tracking all EHSS performance indicators, including accident statistics, water and electricity consumption as well as waste disposal.

Emergency Preparedness and Response

The site of the dehydration plant and nucleus farm is on a 270-hectare land-parcel that is pending acquisition by the company and is located in an area designated for agricultural use, approximately 20 km from St. Louis. The industrial activities of neighboring properties entail agricultural use. The company will also develop a 360-hectare parcel that will be leased from a private owner and is located in an area designated for agricultural use, approximately 75 km north east of the primary parcel, near Lac Guiers and south of the town of Richard Toll. The industrial activities of neighboring properties entail agricultural use.

The biggest risk associated with the operation of the dehydration plant is fire from operation of the oven if proper safeguards are not in place. The design of the dehydration plant follows best international practices. All structures will be equipped with the necessary life and fire safety and emergency prevention measures. SAF will implement an emergency preparedness and response plan.

As per ESAP action #4, SAF will be required to retain the services of a qualified life and fire safety engineer to verify the design of the proposed life and fire safety systems, in particular related to the operation of the oven. SAF will also retain the services of a qualified external company to complete a risk hazard assessment of the types of incidents to which the company may be exposed (ranging from power and water outages, fire, explosions, and flooding), identify required emergency response systems (alarms/detectors, fire extinguishers, pressurized water hose system, etc.), procedures to be followed in the event of an emergency, and the regular training. Once construction of the dehydration plant has been completed, SAF will request an inspection by the national fire authorities to confirm the safety of the operations and compliance with national law.

Monitoring and Review

SAF will develop and implement key E&S performance indicators for its operations, which will include tracking accidents, electricity and water consumption, and wastewater discharge. In compliance with Senegalese law, SAF would be required to undergo an environmental audit by relevant authorities in case activities were not undertaken in compliance with the corrective measures for managing environmental and social aspects stipulated in the ESIA. Furthermore, the main off-takers will undertake regular compliance audits to ensure that the finished product meets their quality requirements as well as some EHSS parameters. Per ESAP action #5, SAF will develop procedures for monitoring EHSS aspects of operations, including a clearly defined plan for regular monitoring and inspection of hygiene conditions at critical control points of the dehydration plant as well as overall conditions of the building and equipment, operation of the wastewater treatment unit, accident statistics, and grievances related to labor. Water and energy consumption will be tracked to set consumption reduction targets. Trends in EHSS data will be assessed regularly to evaluate the effectiveness of efforts to manage identified environmental, health and safety, and social risks across company operations.                                               

   It will require 12 months to dismantle, move, and reassemble the dehydration plant in Senegal. Construction and reassembly of the dehydration plant will be undertaken under the oversight of Biaugeaud technicians from France, making use of local construction staff (which will be contracted through various local firms). It is estimated that it will take 10 months to construct and reassemble the dehydration plant, requiring 30-60 local workers, and up to five foreign workers on site. It is not envisaged that worker accommodations will be required during this period; expat technicians will be accommodated in designated local hotels or guest houses as necessary.

The dehydration plant is expected to operate 7 months out of the year (210 days) and 24 hours a day with a scheduled maintenance for 2 months. Once operational, it is estimated that the company will employ initially 25 employees and subsequently a total of 70 employees, once full operating capacity is reached. The company will also employ workers on a daily basis based on operational needs to help with the unloading of raw materials. Work will be undertaken in 3, 8-hour shifts per day and workers will rotate across shifts in 4 teams such that each team works 6 consecutive days followed by 2 days off, averaging 48 hours of work and 10 overtime hours per week; workers will be compensated in the form of a base salary and overtime pay for a maximum of 10 hours per worker per week as required by the Senegalese Labor Code.

At the farms, there will be a total of 18 permanent employees and 25 seasonal workers during the harvest season. The terms of employment for permanent employees and seasonal workers are the same. Seasonal contracts cannot exceed 10 months per year and are renewable from year to year, which is a common practice in the agribusiness sector in Senegal.

Human Resources Policies and Procedures

SAF will hire a full-time administrative director who will also have oversight of human resources management. Per ESAP action #7, SAF will develop and implement a human resources management policy and procedures in compliance with the national Labor Code and IFC PS2, which describes the employment decision-making process based on equal opportunity and non-discrimination and includes the following: terms and conditions of employment (working hours and rest time, overtime, annual and sick leave and gazetted holidays; minimum wages, termination of contract and dismissal); staff responsibilities; equality of treatment; rules against sexual harassment and a respectful workplace environment; freedom of association; prohibition of forced and child labor; right for collective bargaining; workers representation; and mechanism for workers’ grievances accessible to all workers (permanent and temporary). SAF will ensure that the human resources policy and procedures are accessible and clearly communicated to all workers (both permanent and seasonal) at all operations (in French and local language as necessary) to ensure that workers understand their rights under national labor and employment law.

Working Conditions and Management of Worker Relationship

SAF plans to employ both open-ended staff (CDI, Contrat à Durée Indéterminée) and term staff (CDD, Contrat à Durée Déterminée) depending on the required skills. All staff will have written contracts in accordance with the Labor Code in Senegal, which specify the employment duration (several months) with a possibility for renewal, paid leave, a trial period, identification of job grade and salary, including a breakdown of amount to be deducted for contributions to the national pension and social security by both staff and SAF.

SAF expects to pay salaries that are at least 20-25% above the minimum wage (which is 40,000 CFA per month), corresponding to approximately 50,000 CFA per month.

The design of the dehydration plant includes basic changing rooms with lockers and blocks of toilets and showers (separate for male and female workers) in sufficient amount for the number of workers present on site. SAF will ensure that the toilet facilities are provided with adequate supplies of running water, soap, and hand drying devices. There will not be an on-site canteen for the workers, but SAF will ensure that there is an adequate area specifically dedicated where workers can eat during their break.

Workers’ Organization

SAF will not in any way prevent workers from establishing a union at the site nor prevent workers seeking to join the union or other workers’ organizations. Furthermore, SAF will allow workers to select their own representative delegates from amongst themselves through elections to be held every 3 years with a total of 6 delegates (required by law for any company with 51 to 100 employees) for the dehydration plant. SAF management expects to hold regular meetings with union representatives or on an ad-hoc basis as might be requested by either party.

Grievance Mechanism

All workers (including both permanent and seasonal workers) will be able to voice concerns either to SAF or the union. SAF management will also maintain an open-door policy for voicing all types of grievances. Suggestion boxes will be located in strategic locations around the dehydration plant to allow for anonymous complaints. Workers will be informed of this process during regular meetings at the dehydration plant and at the farms. SAF will need to ensure that all grievances are systematically reported to company management and recorded, tracked, and addressed. Per ESAP action #8, SAF will design and implement a grievance mechanism accessible to all workers regardless of their types of contracts to ensure that a formal grievance process is followed. This will need to include: i) procedures for documenting, managing, and monitoring the resolution of grievances; ii) involvement at appropriate levels of management (including designated staff and accountability); iii) clear and timely management of grievances; iv) allowing for anonymous complaints to be raised and without fear of retribution; v) appropriate expertise to manage sexual harassment complaints; and vi) informing access to other judicial and regulatory mechanisms available under the Senegalese law for workers.

Occupational Health and Safety

Construction will be undertaken under the supervision of Biaugeaud with locally subcontracted workers. Biaugeaud has extensive experience in construction of projects similar to this one.

Per ESAP action #9, SAF will designate a health and safety officer who will be responsible for the overall OHS performance undertaking regular inspections of the construction site. Biaugeaud will also be required to designate a health and safety officer, who will be responsible for liaising with SAF’s health and safety officer and oversee health and safety at the construction site. Their responsibilities will include identifying potential hazards and risks, providing regular health and safety awareness training and reminders to workers including job hazard analysis and associated procedures, use of appropriate personal protective equipment, and site rules concerning housekeeping matters such as waste management and safety related to the movement of equipment and vehicles on the construction site. In the event of accidents and injuries, health and safety officers are required to investigate causes of incidents to prevent recurrences and report to SAF’s health and safety officer. OHS statistics will be reported to Biaugeaud and SAF on a weekly basis.

Once operational, the main health and safety risks for workers at SAF are expected to be related to the handling of heavy bags items, potential improper handling of equipment and machinery parts, and potential exposure to heat and dust inside the dehydration plant. At the farm, harvesting will be undertaken mechanically and will entail limited risk to workers; however, there is a potential risk of exposure to chemicals from the handling and spraying of pesticides. SAF’s health safety officer will have oversight of workers’ health, safety and welfare at the dehydration plant and at both farms. SAF will develop a training plan on all aspects of worker health and safety. SAF will establish a committee for health and safety per Senegalese Labor Code, which will comprise among other members, the administrative director with oversight of HR issues, the EHS officer, an employee delegate, and a management representative; the committee will meet on a regular basis. SAF will develop an internal code of conduct for this committee, which will describe its function, roles, and responsibilities. Based on the Senegalese Labor Code, a representative from the Labor Inspectorate is expected to visit the plant and inspect the health and safety risks for workers including indoor lighting, temperature, and noise and that SAF is implementing the necessary risk prevention mechanisms.

As per ESAP action #10, SAF will develop occupational health and safety procedures for workers, which is to include a risk assessment matrix to identify types of hazards, likelihood of risk, and how to mitigate the risk through a combination of design measures, hazard signs, employee training on hazards, and use of personal protective equipment (such as gloves, face mask, and rubber boots). 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. SAF will ensure that first aid kits are available on-site and that designated staff have received basic first aid training to provide immediate assistance in case of minor injuries and workers feeling ill. In addition, a doctor will visit the dehydration plant regularly to provide consultations for all workers requiring this.

Supply Chain

Over the last 10 years, Senegal has emerged as a major consumer and producer of onions in West Africa but typically about a third (over 100,000 metric tons annually) of local production goes to waste as the consumer market cannot absorb the large surplus during the narrow window of peak harvest in the absence of well-managed storage and dehydration facilities. However, the surplus production of onions in Senegal, which currently goes to waste, is not necessarily of benefit to SAF as only specific varieties of onions (white rather than red) are best suited for dehydration based on having a higher content in solid (dry) matter. In Senegal, the production of onions is concentrated in the Senegal River Valley in the regions of Gandiolais and Fouta near the border with Mauritania, and in Niayes along the Atlantic Coast. Onion is grown as a dry season crop and is planted once the wet season (July to October) has ended. There is virtually no precipitation during the dry season and watering through flood or pivot irrigation is required. Water is extracted by pumps from the Senegal River and distributed through irrigation systems.

SAF plans to source onions from smallholders in the Fouta and Gandiolais regions, starting in 2020 with 120 small-holder farmers initially and targeting 600 by 2020. Smallholder parcels are typically 0.5 hectares in size and entail existing agricultural production. Child labor is known to occur in onion farming in the Senegal River Valley, primarily in the process of transplanting onion seedlings. SAF will sign off-taker agreements with farmers, which will include clauses to refrain from using child labor. SAF will also provide technical assistance in the form of quality seeds, training, and setting up demonstration plots to transfer knowledge to smallholders. SAF will work with smallholders to follow best practices in pesticide (herbicides, fungicides, and insecticides) and fertilizer application and dosage calculations as well as handling and storing chemicals to reduce to the extent possible impacts on the environment, workers, and surrounding communities.

SAF will revise and adapt STL’s procurement policy, which already requires suppliers to avoid the use of child and forced labor, prevent discrimination, pay above the minimum wage, and allow freedom of association. As per ESAP action #11, SAF will develop a supply chain management system including a responsible sourcing policy reflecting the company’s commitment to good agricultural practices, procurement log book to identify the procurement of onions by smallholder, and a system allowing for traceability.                                                

    Energy and Material Efficiency Projects

The largest energy needs are expected to be for operating equipment related to the dehydration process, which includes a large heating chamber and two boilers used for generating steam and water (used in the production and clean-in-place processes). The dehydration plant will operate continuously (to avoid additional energy requirements associated with frequent shut down/start up activities). The dehydration plant will require 5,760 MWh of electricity to operate in addition to 960 MWh for irrigation at both land parcels over the 7-months annual production period. Electricity consumption by the dehydration plant outside the processing period (September to January) is estimated to be 60 MWh per year.

The national electricity company (Senelec) has indicated that it cannot supply annually more than 30 MWh to SAF, which will be used primarily for powering office operations with low electricity needs outside the processing period. SAF has been in the process of exploring options for cogeneration of electricity on-site by installing a Combined Heat & Power (CHP) plant, which will produce both electric and thermal power using LPG (2,237 tons annually). To this end, SAF has received a technical proposal for the installation of a 2 MWh-gas turbine-powered CHP (requiring 0.2457 kg of LPG to generate 1 kW of electricity), which will operate only when the dehydration plant is processing onions (production period). To meet the thermal power requirements of the dehydration plant, additional heat will be generated by an LPG-powered steam boiler (requiring 1,651 tons of LPG annually). There will be one backup generator (with a capacity of 1 MWh), which will be used when power outages occur (expected to be of short duration). The electric needs of the irrigation system will be partially met by three diesel generators (with capacities of 60 kWh, 80 kWh, and 400 kWh) when the CHP is not in operation (September to January).

While the plant was operational in Dijon, the energy consumption to finished product ratio was 2,000 kWh/tonne. The company has established the goal to reduce this ratio by 10% and is in discussions with the oven manufacturer to improve energy efficiency. As per ESAP action #1, SAF will develop an energy management plan to: i) review specifications and design of plant based on outcomes of discussions with oven manufacturer; do benchmark exercise against other dehydration plants in the same sector pending availability of energy efficiency data; and include changes to the design to improve energy efficiency; ii) monitor energy consumption; and iii) identify opportunities for further reductions in energy consumption during operations (including energy efficiency initiatives as well as possible alternative energy sources) as possible.

Water Consumption and sustainability

The operation of the dehydration plant will require an estimated 90,000 cubic meters of water per year, used primarily for washing onions prior to processing, generating steam, and periodic cleaning of the plant. The company is in the process of reviewing opportunities for water recycling in the plant’s layout design to reduce overall water consumption. As the production of onions in Senegal is undertaken on sandy soils, it is expected that a lot less water is required for washing prior to processing. Water will be sourced from the Senegal River. Raw water will be treated (chlorination, filtering, and UV treatment) to potable water quality level before being stored in an above ground storage tank (with a capacity of 80 cubic meters). The raw water storage tank will also serve as a back-up reservoir that can be used as part of the plant’s fire-fighting plan. Precipitation is negligible during the onion growing season, which therefore depends fully on irrigation. Both parcels will be irrigated through a central pivot irrigation system, which is considered to be the best type of irrigation for this type of crop, and water will be pumped via irrigation canals from the Senegal River. Annual water needs are estimated to be 3,800,000-5,320,000 cubic meters for the combined 760-hectare parcels (5,000-7,000 cubic meter per hectare for each crop cycle). The cultivation of onions also requires high intake of nutrients and SAF will develop a plan for proper fertilizer dosages and an application schedule.

In addition to SAF’s proposed project, which will replace existing tomato cultivation at the site (which had higher water needs than onion cultivation although the cultivated surface area was smaller), other agricultural activities in the area that account for most of the water withdrawn from the Senegal River are a few larger-scale industrial operators (rice, sugar, and fruits and vegetables including tomato and onion) and primarily smallholders (typically 0.5 hectares in size), cultivating rice, maize, peanuts, melons, and watermelons. Currently, there are no concerns related to water availability in the area: for the first site, water is sourced from the Senegal River via a dedicated irrigation canal and the water level in the irrigation canal is regulated by means of an upstream dam; for the site near Lac Guiers, water is sourced via an irrigation canal from the lake, which is fed by the Senegal River. Key concerns related to water resources for irrigation in the delta are potentially linked to water quality (rising salinity in groundwater and contamination of surface water from discharged agricultural wastewater) and soil salinity, which are being addressed through the installation of agricultural sewage drainage channels, multifunctional dams, and other hydraulic schemes. The National Agency for the Management of Land in the Senegal River Basin (Société Nationale d’Aménagement et d’Exploitation des Terres du Delta du Fleuve Sénégal et des Vallées du Fleuve Sénégal et de la Falémé, SAED) is the government agency in charge of overseeing agricultural development in the Senegal River basin as well as water management at the local level. Its mission includes among other to maintain an inventory of all irrigation-driven agriculture projects and farmer cooperatives in the delta and river valley to ensure water availability in the delta region for all users. As per ESAP action #12, in the context of SAF operations, the company will also engage with the SAED and/or other local and regional water user associations to promote efforts for the sustainable use of water withdrawn from the Senegal River.

As per ESAP action #1, SAF shall develop a water management plan for both its dehydration and farming operations to: i) monitor water use by the project as well as availability of water resources; and ii) identify opportunities for reducing water consumption (such as use of recycled waters (if quality permits), halting irrigation on rainy days, and implementing irrigation techniques, which minimize water losses or evaporation).

Air Emissions

The main source of air emissions from SAF operations are expected to be from operating one boiler (estimated capacity of 9 MW), operation of the CHP plant, and operation of 3 generators (capacity respectively 400kW, 80 kW, and 60 kW). While the plant was operational in Dijon, air emissions from the boilers were in compliance with French regulatory requirements, which would also have been considered to be consistent with the WBG EHS Guidelines for air emissions and ambient air quality. Annual GHG emissions are estimated to be 11,635 tonnes of CO2 equivalent.

As per ESAP action #13, SAF will i) in the tender documents for the CHP plant and 3 generators, include specifications to meet air emissions quality standards as reflected in WBG EHS General Guidelines for point source emissions to air into vendor agreement (boilers, CHP plant, and generators); ii) develop and implement a written maintenance plan for the boilers and the generators to ensure that they are regularly serviced and continue to meet air emissions quality standards as reflected in WBG EHS General Guidelines for point source emissions to air. Furthermore, SAF will keep a log of hours of operation of the generators such that if it is operated for more than 500 hours per year, SAF will conduct air emissions measurements at the stack and compare parameters with WBG General EHS Guidelines for emissions (particulate matter limit (PM10) of 50mg/Nm³; NOx of 460 mg/Nm³; SOX of 2,000 mg/Nm³). If measurements exceed WBG limits, SAF will propose corrective measures.

Wastewater Treatment

The dehydration plant is expected to generate wastewater primarily from onion washing activities, steam generation, and factory cleaning activities. Based on the previous performance of the plant when it was operational in Dijon, the company projects that it will generate a maximum of 18 cubic meters of wastewater per day (equivalent to approximately 90,000 cubic meters per year). Wastewater effluent associated with dehydration operations typically contains high levels of COD, BOD, and total suspended solids; wastewater will be treated on-site through a series of filtration ponds. Sanitation wastewater (from employee toilets and showers) will be connected to an on-site septic tank, which will be emptied as necessary by an external contractor. No wastewater is expected to be generated at the farms due to runoff from irrigation as all water is expected to permeate into the ground. SAF will install lysimeters at each pivot to measure the percentage of water lost to the ground after each irrigation cycle and adjust accordingly the frequency of irrigation cycles as well as the volume of water dispensed during each cycle.

Per ESAP action #14, SAF will install an on-site wastewater treatment system, which will discharge into an on-site evaporation pond and is expected to meet the WBG General EHS Guidelines standards for effluents. Wastewater will also be available for cleaning activities to reduce overall water consumption. Furthermore, SAF 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

SAF operations are expected to generate primarily large volumes of organic waste (in the form of discarded onions, leaves, and peels as well as sludge from wastewater treatment). Based on the previous performance of the plant when it was operational in Dijon, the company projects that it will generate per year 2,000 tons of organic waste, which will be disposed of through an external service provider although this could be used as fuel in the boiler or as an organic fertilizer for agriculture.

SAF operations will also generate limited quantities of packaging material (plastic, cardboard, empty containers, and defective product packaging), used lubricants (grease, oil, and solvents for equipment and machinery), empty hazardous materials containers (pesticides), and office waste (paper and ink cartridges), which will be removed on a regular basis by an external service provider and disposed of at a site designated by the municipality.

Per ESAP action #1, the company will implement a waste management procedure to reduce the impact of its operations on the environment through proper disposal of its waste streams. This will include proper handling and storage (in dedicated bins to avoid dispersion through wind), record-keeping to track volumes of waste generated, and evaluating alternatives to disposal such as recycling (for example, for glass, metal, plastic and paper).

Hazardous Materials

SAF expects to use the following types of hazardous materials in its operations: i) diesel (as fuel to power the generators); ii) chlorine (for washing onions), iii) limited quantities of cleaning supplies; and iv) chemicals for pest control at the farms. The company estimates that annually 80,000 liters of diesel will be needed, which will be stored in a 20,000-liter above-ground storage tank, and limited quantities of chlorine gas, which will be stored as liquefied compressed gas in 30-kg cylinders. To meet the thermal power requirements of the dehydration plant, additional heat will be generated by an LPG-powered steam boiler (operating 4,800 hours per year), which will require a total of 3,888 tons of LPG per year (corresponding to 7 months of operations). SAF has negotiated an agreement with an external supplier to install and manage a 300-ton bulk LPG storage facility next to the dehydration plant. For farming operations, the company expects to use 15 liters of pesticides per hectare cultivated, corresponding to a total of 9,450 liters annually.

Per ESAP action #15, SAF will implement a hazardous material management procedure and ensure that hazardous materials are adequately stored with measures to prevent and contain spills. This will include keeping an accurate inventory of chemicals used, estimated quantities, and keeping Material Safety Data Sheets for all chemicals on-site.

Pesticide Use and Management

SAF plans to combat weed propagation prior to land preparation for onion planting to reduce competition for light, moisture, and nutrients, which are critical components for ensuring good onion bulb yields. This will be addressed primarily through physical removal and herbicide application will only occur as a last resort in case of heavy infestation. Should herbicides designated by the WHO as Class II (moderately hazardous) be used, SAF will make sure that these are stored and disposed of properly and that only personnel who have been adequately trained and equipped will be allowed to handle these. Onions are susceptible to pests such as eelworms and thrips, foliar diseases, and bulb rots. To maintain and improve soil fertility, decrease the level of detrimental nematodes, and increase the level of beneficial mycorrhizal fungi, SAF will implement rotational crop practices by planting Crotalaria (for use as green manure) following the onion crop, alternating with alfalfa after two years of onion cultivation to increase soil organic matter, decrease soil erosion, and decrease soil nitrate leaching loss. Alfalfa will be sold to farmers as fodder for livestock.

SAF will review STL’s list of allowable phytosanitary products in accordance with the requirements of the Sahelian Pesticides Committee as well as those of Global GAP, and revise and adapt STL’s procedures for the storage and handling of phytosanitary products to follow sustainable agricultural practices for which it plans to obtain Global GAP certification. Per ESAP action #16, SAF will develop a pest control and prevention procedure to fight fungi and insects, as well as for weed control at the land parcel (fungicide, insecticide, and herbicide). This will entail implementing an integrated management approach for maintaining a clean environment inside the plant (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. Pest control devices will include the use of glue-based traps, UV fly killers, and mechanical traps inside the factory and traps with poisoned bate only outside. SAF will retain the services of an external service provider to undertake regular monitoring of traps to identify early on the potential need for more aggressive pest treatment.                                               

   The design and lay-out of the dehydration plant will integrate the principles and practices of Hazard Analysis Critical Control Points (HACCP) to reduce the risks related to hygiene and food safety, which will mitigate potential impacts to the community. As part of HACCP requirements, the design of the plant will be organized such that products move from “dirty” to “clean” areas to avoid contamination. The packaging of the finished product is done through automated filling machines, thus removing the potential for contact between workers and the finished product. SAF will implement a food safety management system and procedure on worker hygiene, which includes providing the necessary clothing and personal protective equipment to workers, training, and posting of signs.

Per ESAP action #6, SAF will undertake the necessary steps to obtain HACCP certification as soon as the dehydration plant is operational and will obtain FSSC 22000 certification within 3 years. It is also expected that off-takers will undertake regular audits of the plant to confirm the quality of the finished product. SAF will implement a quality product monitoring plan, which will entail undertaking microbial and chemical analyses of product samples in SAF’s on-site laboratory and logging results according to batch code numbers to facilitate traceability in case of a product recall.

Transportation Safety

During the construction phase, there is a potential for accidents related to the circulation and movement of heavy vehicles belonging to the subcontractor accessing the construction site. Once operational, SAF will use the services of externally contracted drivers to transport onions from collection points to the dehydration plant and the finished product off-site for distribution.

The company will be required to develop a traffic management plan as well as procedures for the safe operation of vehicles per ESAP action #17. During the construction phase, this will entail placing road signs on the access road to the site to indicate construction activities and setting a speed limit of 20 km/hour. The subcontractor will be required to ensure that all drivers obey traffic rules and provide awareness training as necessary. Once operational, SAF will develop a process for screening subcontracted 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 dehydration plant after each delivery for any evidence of having been in an accident; and overall truck maintenance to ensure good working conditions.

Security

The site of the dehydration plant will be surrounded by a 2 to 2.5-meter high perimeter fence. SAF plans to directly employ 5 guards at the dehydration plant and 15 guards at the nucleus farm, who will be on-site for 24 hours/day and 7 days/week. Security guards will carry only batons and will receive training. Per ESAP action #18, SAF will undertake as part of the hiring a process at a minimum a background check to verify criminal record and suitability for the job. SAF will develop a security procedure, which will include: i) description of responsibilities of guards such as controlling access and verification of people entering the site; ii) interactions with SAF’s workforce; iii) interactions with the surrounding community; iv) duties in case of an emergency at the site; and v) regular reporting to SAF management in case of incidents or grievances received from the surrounding community.                                                

   Protection and Conservation of Biodiversity

The Project includes three separate parcels that are planned to be acquired by SAF: i) 270-ha parcel (“Parcel 1”) currently owned by another company; ii) 360-ha parcel (“Parcel 2’) currently owned by one of the Senegalese shareholders and to be developed in 2021; and iii) 130-ha parcel (“Parcel 3”) to be acquired in 2022, and as such no information is available on this parcel. Parcels 1 and 2 are within the Senegal River Basin, a system of wetlands recognized as Ramsar sites and Key Biodiversity Areas (KBAs), some of which are legally protected.

Limited biodiversity information is presented in available ESIAs. Additional information was collected via IBAT, other publicly available information, and consultation with experts with knowledge of the Project area (e.g. BirdLife International, IUCN, the African Aquatic Conservation Fund, African Chelonian Institute).

Parcel 1 has been in use for commercial agriculture activities prior to acquisition by the Project. This parcel is considered Modified Habitat. Critical Habitat is unlikely but there is potential for occasional visits by wide-ranging priority species (for example, vultures). As per ESAP #1, the company shall develop a monitoring plan for priority species for Parcel 1 as part the EHSS management system. If such species are observed, mitigation measures will be reviewed to ensure they are adequate for any risk associated with the level of use by such species (e.g. protection of trees for roosts).

Parcel 2 is located approximately 75 km north east of the primary parcel, in the Senegal River delta, a complex of wetlands and agricultural areas broadly characterized by Sahel thorn-bush savanna used for livestock-rearing, flood-recession agriculture (walo) and areas of irrigated cultivation. The parcel lies 2.5 km from Lac de Guiers, in an area subject to intensive agricultural activity (for example, sugar cane, tomatoes, rice, and sweet potatoes). The parcel is in an area of minimal vegetation cover and existing agricultural land. The southern part of the parcel (circa 35.5ha) overlaps with seasonally flooded areas (bas-fonds) and is supposed to be set aside and not cultivated. Given context and existing land use, the parcel is considered Modified Habitat. At least 50% of Parcel 2 overlaps the published boundaries of Lac de Guiers KBA, which was triggered due to globally significant bird concentrations (for example, IUCN Least Concern African Spoonbill, Platalea alba, and Glossy Ibis, Plegadis falcinellus). However, Parcel 2 is 2.5 km from the lake and existing land cover in the parcel is not preferred habitat for these KBA values (i.e. tree-roosting wetland birds). IFC consultation found that the rationale for boundaries defined in 2001 was not recorded and most likely based on maps showing extent of undegraded habitats within the maximum and/or average extent of the lake (i.e. during rainy seasons). KBA status was based on a lake-wide bird census in 1998 and no further surveys are known. Finally, recent human interventions in the area, in particular creation of the Diama dam (Barrage de Diama), are believed to have significantly modified the ecological conditions of the lake and its associated biodiversity. As a result, there is some uncertainty over whether KBA boundaries and status remain accurate at the current time. Parcel 2 has some potential to be Critical Habitat due to globally significant concentrations if original KBA boundaries and status are confirmed. If KBA status and overlap is confirmed, Parcel 2 will be treated as Critical Habitat. Regardless of Critical Habitat status, impacts to the KBA or potential Critical Habitat values due to land use are unlikely. The company will complete an assessment regarding overlap with and status of KBA, and any impacts to any priority species as per ESAP #19. This assessment shall be completed by a suitable international ornithologist with knowledge of the project landscape and priority aquatic bird species. Findings regarding current extent and status of the KBA with regards to Parcel 2 will be subject to consultation with BirdLife International to confirm current KBA status. Where Critical Habitat is confirmed (i.e. because original KBA extent and status are correct), a Biodiversity Action Plan and Biodiversity Monitoring and Evaluation Plan will be required.

All parcels have potential to cause downstream impacts to neighbouring wetland areas, notably via nutrient enrichment due to fertilizer run-off. These will be managed via Performance Standard 3 (see section above). Riparian buffers (minimum 50 m) will be protected and/or restored using indigenous species at all parcels. As per ESAP #1, the company shall integrate such measures into applicable land management plans for all parcels.

Protected or Recognized Areas. Parcel 2 partly overlaps the Lac de Guiers KBA, as detailed above, and is also about 2 km from the Tocc Tocc community-managed nature reserve and Ramsar site (established 2013) on the shore of Lac de Guiers. This reserve is considered one of the highest priority sites for biodiversity around Lac de Guiers. Recent surveys by NGOs (e.g. Wetlands International) confirm high biodiversity values. No impacts are expected to this site. As per ESAP #21, given the broader contextual risk with regard to multiple protected and internationally recognized areas in the landscape, the company shall document a stakeholder engagement strategy for basin-wide management authorities and the managers of the Tocc Tocc reserve to identify and align with their recommendations to manage impacts.

Alien Invasive Species. No alien invasive species issues are expected.

Management of Ecosystem Services. Given existing cultivation in the area, no impacts to ecosystem services are expected.

Sustainable Management of Living Natural Resources

STL’s onion suppliers in France followed sustainable agriculture practices, which were audited by off-takers on a regular basis. The company will apply the same principles in this project and will manage the production of onions in a sustainable manner for which it plans to obtain Global GAP certification at each parcel as per ESAP action #20.

Supply Chain

SAF plans to source approximately 30% of its total need for onions from smallholders (see section on PS 2 – Labor and Working Conditions), which typically entail small parcels of land (0.5 hectares) that are already used for agricultural production. Thus, no further conversion of Natural or Critical Habitat is expected.                                                

     In the context of the Environmental and Social Impact Assessment (ESIA), completed in September 2019, informal meetings with local communities (the villages of Mberaye, Mboubene peulh, and Ahmetou in the Commune of Diama) were held to discuss land use and employment opportunities although this was not documented. Furthermore, SAF held multiple outreach activities with smallholder farmers to inform them of the upcoming project and procurement needs. Stakeholder consultations will continue throughout the implementation of the project and engagement activities will be documented. Per ESAP action #21, SAF will designate staff with oversight of stakeholder engagement activities and to develop and implement a procedure to: i) map stakeholders; ii) undertake and record stakeholder engagement activities; iii) receive and register external communications from the general public and potentially affected communities; iv) screen and assess the issues raised and determine how to address them; v) provide, track, and document responses, if any; and vi) adjust aspects, as appropriate, of company operations.                                              

    Contact Person: Mr. Magatte WADE

Company Name: Société Africaine d’Ingrédients

Address: Bd Djily Mbaye X Beranger Feraud – DAKAR Plateau

Email: magatte.wade@assuranceslaprovidence.com

Phone: +221 33 889 90 77 / 77 639 56 42