- PS 4 is not applicable as there are no adverse impacts on the health and safety of communities as the site is located in an industrial zone and nearest community is 8.5 km away. EVTL is itself guarded by Pakistan Marine Navy as Port/ Harbor security comes under their jurisdiction as per Port Qasim security plan and as per PakMaritimeSecurityAgency Rules. The water front is under surveillance by naval intelligence guards and coast guards. As part of the previous IFC investment, EVTL has assessed the risk of having different layers of armed security forces at its facilities and developed an armed security usage policy and procedures into its EHS management system aligned to Voluntary Principles and complies with the requirements of this performance standard.

PS5: Land Acquisition and Involuntary Resettlement does not apply as the project will be located on the land within the current footprint of the company which is leased for a period of 30 years from the Port Qasim industrial area and Right of Way to EPCL for the new pipeline has been issued by the port authority;

PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources is not applicable given that the project is located in an industrial zone and does not have an impact on biodiversity and ecosystem services. 

PS7: Indigenous Peoples does not apply as none are present in the project vicinity; and

PS8: Cultural Heritage does not apply given the use of the site currently operated by the Company and there are no impacts on cultural heritage.                                             

 This is category B project according to IFC’s Policy on Environmental and Social Sustainability because the project will result in limited potential adverse E&S risks and/or impacts that are few in number, generally site-specific, largely reversible and readily addressed thorough mitigation measures. The proposed LPG storage and handling facility will be built inside the existing terminal which is operational for the past 20 years. Around 1000 meters of the new pipeline and two pumping stations will be constructed inside the terminal, while the rest of the pipeline (about 6000 m) will pass through the PQA industry zone. The pipeline and the pumping stations will be constructed by an EPC contractor (GASCO, https://gascoengineering.com.pk/) hired jointly by EVTL and EPCL. According to the agreement among parties, the responsibility of the EVTL will end at the fence of its terminal whereas EPCL will be responsible for both construction and operation of the rest of the underground EDC pipeline.

Based on the review of available information, key EHS risks and impacts include the following: ; contractor management during the construction phase of the new underground pipeline and the installation of the new LPG bullets ; ensuring that the company continues to maintain good occupational, health and safety, operational safety, fire prevention and emergency response management; the labor and working conditions of the permanent and contracted employees; resource efficiency measures in compliance with local laws and regulations and the objectives of the Performance Standards.

Environmental and Social Assessment and Management System

The company has an established and robust Integrated Management System (IMS) certified to ISO 9001, quality management system, and 14001, environmental management system, as well as OHSAS 18001, occupational health and safety management system standards. These certifications are audited by Bureau Veritas. Furthermore, the company is certified to the European based international Chemicals Distribution Institute for Terminals (CDI-T). EVTL has comprehensive EHS management programs and operational procedures comprising of: equipment operation safety procedures, emergency preparedness and response, ship unloading/loading and road tanker EHS management, EHS requirements for contractors, hazardous material management, solid and industrial waste management etc. On site observation confirmed an effective and robust implementation of the IMS on the ground.

Policy

EVTL’s corporate E&S policy states its commitment to protect the environment, safety and health of its employees, customers, contractors, interested parties and the community. The policy promotes process safety management to prevent major accidents and ensure a health and safety environment for all workers, visitors and contractors.

Identification of Risks and Impacts

Assessment and management of EHS risks for any new projects are initially identified and mitigated during preparation phases in accordance with the company’s risk management approach and host country regulations. During operational phases, EHS risks are identified through formalized auditing programs and informally through frequent inspections. All these audits and inspections are summarized with corrective actions to mitigate the EHS impacts and the progress followed by top management. As part of its hazards and effects management process, EVTL conducts Hazard and Operability Study (HAZOP), Quantitative Risk Assessment (QRA), and Job Hazard Analysis to identify operational safety risk and develop mitigations and implement them effectively. 

An environmental and social impact assessment (ESIA) is not required for the project being contemplated (i.e. an expansion of LPG storage capacity). Previous chemical storage expansions were subject to ESIAs that were carried out with in compliance to the national law.

Management Programs 

The company has established management programs that describe mitigation and performance improvement measures and actions that address the identified environmental and social risks and impacts of the project which include detailed technical standards, standard operating procedures (SOPs), work instructions and inspection/audit program. Systematic monitoring of environmental performance and process safety measures are in place for air emissions/liquid effluent, solid and hazardous waste management, and occupational health/safety. Non-conformities to the technical standards are monitored and extensively followed up by the management. Also, procedures and instructions are communicated to relevant personnel and appropriate training is provided to all employees.

As part of the IFC investment, EVTL will revise and update leak testing and Walk the Line operating procedures to cover new EDC pipeline and maintain process safety (ESAP item#1).

Organizational Capacity and Competency

EVTL has a well-articulated detailed organization chart with clearly defined roles and responsibilities to implement the management of environmental, occupational health and safety (OHS), and social matters, and reporting lines for staff managing the EHS issues with the ultimate oversight by the Terminal Manager. Daily EHS management is handled by the EHS unit, staffed by full-time safety and environmental engineers. At each operational unit, there are part-time EHS coordinators, who support the fulltime EHS manager/engineers for operational EHS managements.

Emergency Preparedness and Response

Based on identified hazard and risks, the company has well documented on-site emergency preparedness and response plan (EPRP); the structure is defined in the associated EHS manual and is consistent with IFC PS1 requirements. EPRP generally addresses all emergency scenarios, their consequences, communications channels, roles and responsibilities etc. for chemical spills (e.g. toxic chemical release); fire and/or explosion; evacuations; natural disasters etc. EVTL strictly implements safety procedures to avoid any fire or so, for example, personal electronics are not allowed in storage area and all vehicles within this area are equipped with spark arrestors. There are fire and toxic gas detectors, and detection of temperature, smoke, explosion level, and toxic chemical concentrations at all high - risk areas. The site is monitored 24/7 through closed circuit TVs (CCTV) which also feeds information to emergency response center of PQA.

In case of major fire, the fire system will be automatically transferred to sea water firefighting. Sprinkler systems and foam firefighting equipment are installed at all tank farms and other potential fire sources. Toxic gas detectors at all critical locations, which are connected to the central control room. All firefighting equipment is routinely inspected by the EHS unit. EVTL has its own fire brigade, which is supported by PQA fire brigade. PQA fire team is available 24/7 which has both ground and seaward fire support to industry zone. EVTL has an onsite clinic for emergency treatment and a major hospital is approximately 12 km away. Material safety data sheets (MSDS) for all toxic chemicals handled by the terminal are located at the facility. Copies of these MSDS are also kept at the ER clinic.

EVTL holds weekly firefighting drills, quarterly company level drills, which involve the PQA fire brigade, neighboring facilities, and the local hospital according to a scenario. All staff receive appropriate training on the implementation of EPRP.

Ships carrying the chemicals and LPG are controlled for complying IMO regulations prior to entering to the port. EVTL asks from its clients to contract transportation companies that is responsible for road tankers have adequate defensive training programs and safe driving records etc.

Monitoring and Review

Systematic monitoring of environmental performance and process safety measures are in place for toxic gas, vehicle gas emissions, equipment exhaust gas, sewerage/effluent waste, disposal of solid and hazardous waste etc. The company reports on standard safety related key performance indicators (KPIs) such as (lost time accidents, work permits review, etc.) and safety inspections are done periodically.

Furthermore, the company adopts Center of Chemical Process Safety direction which is a not-for-profit organization that identifies and addresses process safety needs for a variety of facilities involved with handling, storing, using or processing, and transporting hazardous materials. In addition to that VOPAK conducts routine Terminal Health Assessment (THA) and EHS audits. The company received 99% score from the latest VOPAK audit in 2017. EHS unit records any non-compliances identified during audits/ inspections, develop corrective action plan and the progress is monitored by the top management at periodic EHS meetings. EVTL will ensure that the engineering, procurement, contract (EPC) contractors and sub-contractors follows EVTL’s ESHS requirements and IFC provisions during the construction phase of both LPG bullets and the underground pipelin through integrating the ESHS risk management requirements of the contractor into the contract by including Contractor ESHS requirements or/and Contractor ESHS management plan and provide necessary training, guidance and supervision for the contractors as per ESAP item#2.

 EVTL currently employs a total of 82 direct employees, 4 trainees and 7 contractor employees for janitorial service, maintenance and operational service, admin services, security services, transport services etc. There are 6 female employees recruited for administrative tasks and 1 engineer working at terminal. While the project does not require significant new recruitment of new employees, no retrenchment is also expected at EVTL in the foreseeable future.

Human Resources Policies and Procedures

EVTL has a Human resources (HR) policy and HR procedures that are consistent with local labor laws and provision of IFC PS2. The HR policy defines general principles of freedom of association, training, and development, equal employment opportunities, performance management and non-discrimination, non-engagement of child labor and forced labor. The HR procedures are related to recruitment, probation, job descriptions, training, performance review, promotion, health benefits (insurance), salary and compensation working hours, resignation, lay-off and firing, internal grievance mechanism etc. HR policy and procedure trainings are incorporated in the new employee induction and are also available on intranet.

Working Conditions, Term of Employment, and Worker’s Organizations

EVTL respects the staff’s freedom of association, and, yet none of the company’s personnel is member of worker’s association or labor union. All employees receive a copy of their employment contract at time of employment that includes basic terms of employment such as contract duration, annual leave, wages and benefits and term for termination of the employment.

Non-discrimination and Equal Opportunity

The company’s HR policy specifies non-discrimination and equal opportunity. No procedures and and/or practices have been identified as discriminatory. All hiring, and promotions are merit-based.

Grievance Mechanism

The company strives to maintain a good working environment by encouraging open and direct communication between management and employees through Whistleblower policy by the name of “Speak Out”. Anonymous workplace concerns can be raised through an email acknowledgeable to all employees. All emails are automatically forwarded to General Management Corporate Audit, Engro Corporation Ltd. Each complaint is investigated, and a report is issued within two weeks of its receipt. A final investigation report is submitted to the CEO and the progress is followed by General Management Corporate Audit and the Board until it is resolved. An explanation of the grievance process is included in the induction plan for each employee and accessible to both direct and third-party employees.

Protecting the Work Force

The company has corporate policies against hiring of workers below the age of 18 years and forced labor. HR teams check birth and school certificates during the hiring process. These requirements also applicable to EPC Contractors and subcontractors.

Occupational Health and Safety

Like all Vopak group subsidiaries, EVTL follows Vopak Standards and is fully compliant with all Vopak Standards and as part of the corporate commitment on safety, an elaborate OHS management was observed at the site. The OHS management includes OHS permits, personal protection equipment, material/tool handling, hazard communication, etc. The company conducts a detailed job hazard analysis for all the key jobs and accordingly develops risk mitigation measures including appropriate personal protective equipment (PPE) and training. These have been documented through work instructions and SOPs and are prominently displayed throughout the facility – with a strong emphasis on visual communication (illustrations, photos etc). The terminal has routine OHS training, including new employee training and annual refreshers. There have been no fatal or serious accidents involving any employee at operational history and those have occurred, relate to minor incidents involving first aid and restricted lost time injuries. There is an incident reporting mechanism in place which records all reportable injuries, first aid cases, near misses and lost time accidents along with cause of accident, immediate action taken, and correction actions planned and implemented.

Appropriate personal protective equipment (PPE) is available at each position and employees all wear proper PPE. The company has comprehensive OHS procedures including PPE rules that relate to toxic chemical handling, heat protection, cryogen protection, operation at height, confined spaces, etc. EVTL regularly monitors workplace air quality and noise levels for key hazards such as chemical exposure and they are in compliance with the local regulations and WBG General EHS Guidelines. The OHS procedures are applied to the contract workers as well.

Resource Efficiency:

EVTL’s business activities primarily include LPG and other chemicals storage and distribution. There are no manufacturing processes and thus resource consumption is very limited. The main resource consumption is electricity, which is supplied from industry zone’s grid. Sanitary, cleaning, and firefighting water is sourced from the industrial zone. EVTL built a solar energy farm inside the terminal, with capacity of 128 KW. As part of this project, the client will increase the capacity to 300 KW within the facility.

EVTL office building is Green Office certified by World Wildlife Foundation Pakistan for its environmental management system which prioritizes energy efficiency, focuses on waste reduction and ensures an environment-friendly workplace. Moreover, the company uses the treated domestic wastewater in water gardening.

Energy and GHG Emissions

The main energy use by the project is electricity which is supplied for compression and pumping. Furthermore, diesel is used for back-up generators and vehicles. In 2018, total GHG emissions for the company calculated as approximately 429,000 tonnes of CO2e/year. Once new LPG facility become operational, a relative increase in the total GHG emissions is estimated. The company will estimate the GHG emissions from the project using internationally accepted methodology and shall report to IFC annually.

Water Use and Wastewater Treatment

At EVTL, water is mainly used for domestic purposes and firefighting sourced from industrial zone. EVTL is zero effluent facility, as sanitary water is utilized for gardening. Effluents are tested periodically by authorized third party according to local regulations. Soil and ground water assessment being conducted to evaluate any contamination inside boundaries. EVTL have had no major spills at its operational history.

Air Emissions

The air emissions resulting from the facility’s operation include process vapors, combustion products, and venting gases. As the facility is located within an industrial zone, a variety of emission sources exist in the vicinity of the project from other operational facilities. The company monitors SOx, NOx, Ozone and particulate matters (PM) which are compliant with local regulatory requirements and WBG EHS guideline values.

Solid and Hazardous Waste Management

Solid waste (e.g. plastics bags) and the hazardous wastes (e.g. drums, batteries) are segregated and collected in designated bins and disposed by Sindh Environmental Protection Agency approved licensed third-party contractors.

Hazardous Materials and Operation Hazard

The company employs hazard effect management process (HEMP) standard to manage process safety. Accordingly, EVTL conducts routine internal safety inspections and also hires external experts to conduct safety auditing of all storage tanks onsite in accordance with the established procedures to handle hazardous materials. All the hazardous liquids are stored at above ground tanks with proper bottom and secondary containment. Quantitative Risk Assessment (QRA) and Fire Risk Assessment studies are conducted for storage of all hazardous materials by third party consultants/external experts to ensure safety of personnel, assets and adjacent firms. According to the report, Exclusion Zone remains within EVTL properties which means that in case of credible worst-case scenarios, there is no major impacts outside of EVTL. Electricity is mainly supplied from grid but there are standby diesel generators automatically activated when electrical power supply is interrupted. For the expansion project, Hazard operability (HAZOP) studies will be conducted and EVTL is committed to implement all its recommendations of the study.

All road tankers’ are contracted by EVTL’s clients. Each road tankers and drivers are checked by EVTL staff for safety condition and the certificates/ permits to enter the terminal and transfer hazardous chemicals. Only qualified tankers and drivers are allowed to enter EVTL sites. For long-terms contracted road tankers, EVTL pre-approves the extended contracts and reviews the insurance records periodically.

The plant is located in industrial area with other heavy industry manufacturing facilities. Affected communities and interested parties can raise and register their concerns and complaints at  http://www.engrovopak.com/contact/index.htm) and the company has documented community grievance mechanism procedure.

The company maintains social projects and supports social development initiatives in health care and education sectors. Furthermore, EVTL involved in the conservation of mangroves along Karachi’s coast through an awareness raising program. Additionally, the company works closely with WWF to combat illegal fishing and reducing pressure on marine ecosystems.