PS5 on Land Acquisition and Involuntary Resettlement does not apply as the project is occupying land already owned by Comasa, obtained through willing-buyer willing-seller transactions. PS7 on Indigenous People does not apply because impacts to indigenous people, as identified by IFC Performance Standards, have not been identified in the area of influence of the centers that will be financed under this project. PS8 on Cultural Heritage does not apply as there is no planned expansion in known cultural heritage areas.

 This is a category B project according to IFC’s Policy on Environmental and Social Sustainability because a limited number of specific environmental and social impacts may result that can be avoided or mitigated by adhering to generally recognized performance standards, guidelines or design criteria. Specific key environmental and social risks include: (i) operating with a corporate environmental and social management capacity to operate in a manner not consistent with IFC Performance Standards; (ii) inadequate provision  of working conditions and management of occupational health and safety (OHS) risks  for employees and contractors; (iii) lack of protection of supply chain workers (child, forced labor); (iv) risk of natural/critical habitat conversion on the supply chain; (v) inefficient use of energy and water; (vi) inadequate waste and wastewater management; (vii) inadequate management of hazardous waste; (viii) management of security personnel, and (ix) inadequate management of food safety.

 Environmental and Social Assessment and Management System: Comasa operates on a facility previously used for cotton storage. Comasa identified environmental and social aspects of its peanut processing operations and developed an environmental management plan (EMP) to address the relevant impacts, which has been approved by the Environment and Natural Resources Ministry, MARENA. This plan is part of the integrated Quality, Environment, Health and Safety management system implemented by the company. It addresses the main risks of the processing plants, in an adequate manner with the relevant management programs and procedures in place. Comasa’s food safety system is certified under the British Retail Consortium (BRC); has implemented: Good Agricultural Practices (GAP), Good Manufacturing Practices (GMP) and Hazard Analysis Critical Control Point (HACCP) standards; which together are part of its food safety quality system.

Policy: Comasa has an integrated Quality, Environment, Food Safety, Health and Safety that describes the principles and objectives that guide its activities, guided by the understanding of risk and impacts, such as: water end energy use, effluents management. The policy is published in the company facilities and communicated to all employees and contractors upon induction and available on the company website.

Identification of Risks and Impacts: As noted above, the key risks and impacts of each facility are identified and they provide the basis of the current EMP, which are: sanitary effluent management, air quality, water and energy use, solid waste generation and air emissions. Building upon the assessment, Comasa identified corresponding environmental objectives and indicators to manage performance. In addition to what is described on the supply chain requirement in the relevant PS6 section (ESAP #7), Comasa will extend the scope of its EMP and prioritize the identification and management of these and other key E&S risks identified on farms managed by Seragro, for which it has greater management control.

Management Programs: Comasa established management programs to address E&S risks. For example, they have put in place an annual safety training program, developed emergency response procedures, provided for the safe management and storage of hazardous materials, and undertook an energy and water saving program. In addition, several programs are in place as part of its corporate social responsibility initiative that include: reforestation, conservation, and environmental education. While the joint commission (described below) undertakes regular monitoring of E&S risks as part of its function,

Organizational Capacity and Competency: The team in charge of E&S performance is comprised by an Environmental coordinator, and a HR Manager reporting to the Plant Manager. The HR function also oversees matter of OHS, training, recruiting, and security. Knowledge, skills and experience of these individuals is deemed adequate to manage the types of risk found within Comasa’s operations. A plan for employees’ training and development on E&S matters is in place and includes EHS induction for new employees, use of personal protective equipment (PPE), working at heights, working in confined spaces, safe storage and use of hazardous chemicals, application of ergonomics, promotion of recycling, and information on reforestation, among others.

Emergency Preparedness and Response: The company has developed a comprehensive Emergency Response Plan (ERP) that encompasses guidelines to respond to the following scenarios: fire, earthquake, volcanic eruptions, hurricanes, earthquake and security threat. To support the response, each facility has an integral response brigade, who also assist in evacuation and fire prevention, and first aid. The ERP plans describe roles and responsibilities for employees and emergency brigades, and drills are performed once a year according to local requirements. Regarding fire safety infrastructure and equipment, each facility is equipped with a fire pump and control room that complies with the relevant requirements and there are hydrants distributed along the facilities and fire extinguishers that comply with local fire safety requirements.

Monitoring and Review: The company sets yearly environmental and OHS objectives for the organization that are cascaded down to each functional area’s objective. (KPIs) are updated monthly and results are presented during monthly review by management. As an example, the company set to reduce energy consumption by 15% in a 3-year period. There is a joint commission comprised of both Comasa management and employees that regularly meets and review compliance with OHS requirements as required by law (Comisión Mixta de Higiene y Seguridad).                                                  

Working Conditions and Management of Worker Relationship and Human Resources Policy and Procedures: Comasa operates with 838 employees working on its processing facility (43% female). Comasa has an Ethics Code endorsed by management and registered with the relevant government entity where it states its commitment to human rights and ethical trading initiative to respect workers right, committing to follow local labor law (El Código del Trabajo, Ley 185). It also declares that the company will not use forced or child labor, that wages and working hours will be according to law and that will provide safe and working conditions for its employees. In addition, it has a zero-tolerance for any type of harassment and discrimination. This code is provided to all employees upon hiring and they are required to sign their commitment to uphold these principles.

In addition, it has a Human Resource Policy where the above commitments are expanded in more detail, including procedures and commitments related to employer provided health benefits and vacations, among others. The Company’s commitment to allow employees to form unions is presented on its HR policy. Recruitment decisions regarding new employees and promotions are done without consideration of gender, as stated on the HR policy as well. Comasa has formal contractual relations with all employees and are registered with the social security administration (Instituto Nicaraguense de Seguridad Social, INSS).

Grievance Mechanism: Comasa has an internal grievance mechanism in place where employees may raise workplace concerns as well as suggestions. These can be raised through boxes placed around Comasa facilities, in person or via email. Once received, they are processed and resolved under 15 days and the company keeps track of grievances’ closure rate to ensure timely response. While anonymous complaints are allowed, the company does not have a mechanism to inform its resolutions. Thus, it will modify its current grievance mechanism to allow for the disclosure and publication of resolutions related to anonymous complaints.

Occupational Health and Safety:  At the processing facility, there is a joint commission comprised of both Comasa management and employees that regularly meets and reviews compliance with OHS requirements as required by law (Comisión Mixta de Higiene y Seguridad). An OHS supervisor leads company efforts to implement its OHS management system, and coordinates with each plant’s commission. Comasa has its license and inspection of workplace risks from the Labor Ministry and developed a policy, identified all legal requirements and monitors implementation and compliance. A workplace risk assessment exercise provides the basis of the OHS risks, impacts and mitigation measures. Among the key risk identified are: working in high ambient temperatures, excessive noise, and poor illumination, all factors stipulated by law to be controlled. In addition, the company considers the following risks: those related to mechanical equipment, ergonomics, energized equipment, and chemical and biological agents.

For the calendar year 2018, the lost time frequency rate was 14.2 injuries per million hours worked which is higher than typical values for the Agriculture industry frequency injury rate of 9.0. As part of the ESAP, Comasa will develop a plan to systematically implement measures to address recommendations arising from the workplace risk assessments, with a focus on risks identified as moderate.

Every year, the company updates its Hygiene and Occupational Health Program where activities or instances with a direct implication on safety performance are listed as activities with corresponding objectives, responsibility and completion schedules are defined. These include: work hygiene, accident prevention plan, workplace safety inspections, personal protective equipment inspection (PPE), accident investigation, emergency drills, among others. In addition, OHS coordinators monitors OHS management system’s legal requirements for each facility through periodic audits. However, capacity of the OHS function shall be strengthened by the addition of OHS personnel to adequately manage all tasks related to: communication and prevention of workplace risks, continuous monitoring and implementation of corrective actions identified in all Comasa facilities, as specified on the ESAP.

New employees are trained on workplace safety, emergency response, quality, environmental management, and company HR policy and procedures; contractors undergo HSE onboarding inductions. Moreover, Comasa has an annual program on EHS training for all employees at each facility. Some of the training topics have included use of PPE, general and specific risk of activities, housekeeping, hazards and risks for occupational health and safety, among others. Contractor employees for Comasa’s operations are hired to fulfill tasks during peak operating months of November through September. Contractor employees (personal tercerizado) support several functions, such as: preventive maintenance for forklifts, air conditioners, air compressors and canteen management at each facility, and are issued written contracts. Contractors have the same access as Comasa employees to the internal grievance mechanism.

Comasa’s agronomy team leads monitoring of Comasa supplier operations. As part of this effort, they provide support and training to suppliers on best practices for chemical handling, storage and application, as well disposal for empty chemical containers, and use of PPE. When establishing a relationship with Comasa, suppliers commit to a code of practice where they agree to use and adequately store only authorized fertilizer and chemical applications and keep a log, to provide proper PPE for employees, to perform triple-wash on empty containers and ensure adequate disposal, and to protect biodiversity, natural reserves and wildlife refugees as codified in local regulations. As part of the ESAP, Comasa will also require clients to implement the relevant measures to ensure that child labor is not being employed at supplier’s farms, and Comasa will also implement measures to educate clients on this matter and will monitor client’s compliance.

 Resource Efficiency: 

Comasa recognizes energy use as one if its key environmental impacts and has recently implemented measures that have resulted in energy savings, including: LED lightning, energy audits and action plans, among others, resulting in approximately 9% reduction in electricity consumption in the past year. In addition, they are currently in the process of implementing an energy management system based on the ISO 50001 standard for its peanut blanching operation. For efforts on this front, it has been recognized at national level twice in the past 4 years, obtaining the “Clean Production Award”. Each facility takes electricity from the grid as well as from diesel generators. Annual electricity consumption for all facilities in the past year was 4.57 GWh from the grid, 172,494 gal of LPG and 54,404 gal of diesel.

Peanut processing at Comasa does not require water, thus, water use is limited to non-process usage. Water is sourced from underground wells, and the company has the necessary permits. The company monitors water and energy consumption in all its facilities as part of its monitoring program. Drinking water for employees is provided at dispensers scattered through the facility and its quality is periodically monitored. Water consumption monthly average has been 7500m3. At Comasa farms, irrigation is provided by rainfall.

GHG Emissions: GHG emissions for Comasa are due to electricity and fuel consumption. In the past year, emissions for all facilities are 1,940 tonnes of CO2 equivalent annually which are below 25,000 tonnes, Therefore, no reporting requirements apply to this project.

Pollution Prevention: Air emission sources at the facilities are due to exhaust from trucks, emergency electricity generation and dust. Air quality is monitored annually and reported to authorities. Due to the nature of Comasa activities, facilities’ effluent is characterized as domestic. Comasa central plant is equipped with 2 wastewater treatment plants (WWTP) one using a fixed-film activated sludge and one biodigester with artificial wetlands, with an estimated peak flow of 40 m3/d. Effluents are treated to the adequate level for use in irrigation of gardens at the facility. Performance is monitored weekly, and effluent quality is tested annually. Comasa’s smaller processing facilities use septic tanks for domestic wastewater disposal.

Conventional Wastes: Collection points for recyclable wastes are located throughout the premises and the company has an agreement with a municipal facility to recycle all paper and plastic from all its processing plants and farms. Other recyclable (metal, waste, glass) are collected and sold to recycling companies who possess the relevant permits. The remaining domestic waste is collected and disposed in the municipal landfill. Conventional (organic, aluminum, plastic, carton) wastes are properly segregated, stored and disposed according to local requirements in municipal landfills.

Peanut husks, the biggest waste flow (approximately 95 Ton/d) are collected and delivered to a nearby facility that uses it as boiler fuel for electricity generation, something that Comasa is considering doing in-house in the near future.

Hazardous Materials Management: These correspond to: batteries, used oil and lubricants, paint and solvents, which are adequately stored and disposed by licensed contractors. The company uses hazardous fumigants (Aluminum Phosphide) for its raw peanut storage barns and for finished products, if warranted. Procedures regarding the management of hazardous chemicals are based upon a risk assessment that considered handling, application, treatment and disposal, as well as handling of empty containers. While current risk assessment and management controls address major risks, as part of the ESAP, the company will expand the scope of its hazardous chemicals risk assessment and resulting management procedures to ensure alignment with IFC requirements, such as for assessment of potential accidental releases, release prevention and control planning, operators training, inspection programs, jobs safety analysis, hazard communication training and monitoring and record keeping activities. A similar exercise, tailored to level of risk, will be undertaken at Comasa farms.

 Community Health and Safety: Operation of Comasa facilities pose low health and safety risks to the surrounding communities. Potential risks that could arise during operations are related to traffic disruptions due to Comasa suppliers’ trucks entering and exiting facilities; noise and dust, for which the company has practices in place to control these risks, such as: traffic plans for peak delivery seasons, irrigation to reduce dust, among others. As described above on the management system section, the company has implemented a food safety quality system that is adequate.

Security Personnel: As mentioned above, Comasa directly hires its security personnel; some are armed. Comasa’s security personnel are hired, following standard country regulations. Guards are required to undergo background checks, training and vetting by the XX. The main responsibilities of security personnel are to ensure access to the facilities for employees and trucks, managing medical emergencies and evacuation plans. As part of the ESAP, the company will develop and implement a security management plan to ensure that its arrangements are adequate to the level of risk. (They should develop procedures to respond for the most common types of threats, with consideration of the use of force).

Supply Chain: As part of this project, which will finance Comasa processing activities, only supply chain requirements apply in Performance Standard 6. Peanuts from Comasa’s supply chain are grown on existing farms that are modified habitat. Comasa has sufficient leverage and influence over its suppliers to require supply chain management controls. The location of all supplier farms is known and production is traceable to these suppliers. The company has a set procedure for selecting the farms from which it sources peanuts. As indicated in ESAP Action Item #7, Comasa will include in this procedure the following criteria: a) farms may not be located within protected areas unless it can be demonstrated that they were legally established and their operations are consistent with the management objectives of the protected area; and, b) farms may not undertake expansions that require the conversion of areas of natural or critical habitat, within or outside of protected areas. Currently, seven farms that supply Comasa have farm boundaries that overlap with protected areas (IUCN Category IV) and will be re-evaluated for eligibility as suppliers. Comasa will develop a Geographic Information System (GIS) database to support compliance.

 For external grievances, the company can receive and address concerns from the community through its website, telephone. The company will enhance its external grievance mechanism, so it can effectively gather and timely process any concern at company gates that may arise from Comasa activities on all its facilities.

 Contact Person:

Company Name: Comasa

Address: COMASA, NIC-24A, Santa Clara, Nicaragua                                               

Email: info@comasa.com.ni

Phone: PBX (505) 226 5296