The project is not expected to result in risks and impacts that must be managed in accordance with PS7: Indigenous Peoples as no Indigenous Peoples had been identified within the project area.

 The proposed investment is a Category A project in accordance with IFC’s Policy on Environmental and Social Sustainability. The project is expected to contribute to cumulative regional impacts (mainly relating to air quality, water quality and availability, ecosystem services, noise and vibrations from quarrying operation and land use restriction for host communities) due to similar limestone quarrying and cement production activities in the same general location as the new cement plant in Senegal within the Thies Forest. As such, the project is expected to result in significant, diverse and some irreversible E&S impacts. 

The key E&S risks and issues related to the project include: i) the adequacy of the Group’s E&S policies and procedures for effective and systematic assessment and management of E&S risks and impacts during construction and operations; ii) management of the workforce and working conditions including occupational health and safety, grievance management and management of third party workers; iii) resource use efficiency and greenhouse gas emissions, iv) hazardous materials management; v) management of wastes and emissions; v) security management; vi) impacts on biodiversity; vii) impacts on communities livelihoods, health safety and security, including influx management and traffic impacts and viii) stakeholder engagement.

 Environmental and Social Assessment and Management System

CIMAT, which operates two integrated cement plants in Morocco, has implemented a robust Integrated Management System (IMS) comprising the following certified  management systems: ISO 9001:2015, a Quality Management System; ISO 14001:2015, an Environmental Management System; ISO 18001 (now referred to as 45001:2018), an Occupational Health and Safety Management System; and ISO 50001:2018, Energy Management System. The OIP Group goal is to onboard all CIMAF operating companies (OPCOs) into the IMS as well to standardize E&S risk management across the business lines. This will be done through gradual upgrade of E&S risk management systems at each of CIMAF OPCOs to align with the IMS. The mode of application of this IMS to CIMAF is discussed in the following sections.

Policy

CIMAT has a Quality, Health, Safety, Environment and Energy (QHSEE) Policy, which will be adopted by CIMAF Senegal. Mali and Ghana as part of the IMS. Although the policy commitments address most key E&S risk areas in the business and are consistent with PS 1 requirements, CIMAF Senegal and Mali will revise the QHSEE Policy Statement as part of the adoption process to incorporate commitment to addressing social risks, including continuous engagement with local stakeholders, and surrounding communities; similar to what has been done in CIMAF Ghana (ESAP #1).

Identification of Risks and Impacts

An Environmental Impact Assessment (EIA) was undertaken in 2019 for the Senegal clinker plant and quarry and an EIA permit obtained from the national environmental authorities. The 2019 EIA report has been disclosed with this ESRS. 

Following review of the EIA by IFC, it was agreed with the Sponsor to upgrade the assessment to meet IFC’s Performance Standard (PS) requirements, which is currently being undertaken by an international consultancy firm. To date there has been consultation with stakeholders and communities as part of the ESIA and the upgraded thematic studies covering air quality, biodiversity, social, water supply and availability, noise, traffic, cultural heritage, geology and climate change, as well as the key E&S constraints report, are still ongoing and will be disclosed at a later stage when completed Final results of these assessments are in the process of being finalized, the findings herein are based on draft review results and professional opinion of qualified experts. These findings will be updated once the specialist relevant studies are available.

The key preliminary E&S risks already identified and being evaluated include: livelihood and other impacts to pastoralists and community members benefiting from ecosystem services in the project area, risks to the nearby communities due to the project induced traffic, impacts of noise and vibrations from blasting and quarrying activities, air emissions from the project, project impacts on biodiversity, water sustainability and influx of people due to the project construction and operation. 

The project will also contribute to cumulative E&S impacts as there are two existing cement plants within 5 km, a phosphate quarry 1.5 km from the plant site and the recently constructed international airport and national highway. Such impacts will likely include those related to air quality, ecosystem services, water extraction, noise and vibration from quarrying services and land use restrictions for host communities. A cumulative impact assessment (CIA) is being undertaken as part of the ESIA and the findings in relation to this, and as with the thematic studies referenced above, are based on an initial assessment and qualified professional opinion; these findings will be updated once the CIA is finalized. 

The updated finalized ESIA report for the proposed Senegal cement plant together with detailed mitigation measures summarized in E&S Management Plans (both for construction and operational phases) for the integrated cement plant will be disclosed in June 2021. Following completion of the ESIA, CIMAF will implement the recommendations from the assessment and agree with IFC on a time-bound schedule for implementation of these recommendations (ESAP #2).

CIMAF Senegal has applied for a regulatory permit to construct a grinding plant as an additional component of the Senegal clinker plant within the confines of the project footprint.  While the PS compliant ESIA currently being undertaken includes an assessment of impacts associated with the grinding plant, once the permit is received, CIMAF will still need to address any national requirements to conduct additional EIA studies and secure an environmental permit for this component of the project. 

For the planned grinding capacity expansion, CIMAF Mali will conduct an ESIA as a regulatory requirement and this will be aligned with the PS requirements as will the ESMP for the construction and operational phase. The regulatory requirements in Ghana do not oblige CIMAF Ghana to undertake an ESIA; but rather an Environmental and Social Management Plan (ESMP) is required by the local authorities.  Nonetheless, an ESIA will be undertaken to ensure the CIMAF Ghana expansion project aligns with IFC’s PS requirements. (ESAP #3).

Management Programs

CIMAF Senegal, Mali and Ghana are progressively implementing IMS procedures and will be fully onboarded by 30 June 2022. To adequately address key E&S risks, consistent with PS requirements, CIMAF will upgrade the Procedure on Processing of Stakeholder Requests (PR-SMI-C-09) (for Mali and Senegal operations); develop a Security Management Procedure in line with PS 4 requirements; upgrade the Chemical and Inflammable Product Storage Procedure; upgrade the Contractor Management Procedure; upgrade the Procedures for the Assessment of Environmental and OHS risks; and develop a Chance-Find Procedure for the Senegal cement project (ESAP#4). 

For the Senegal project a dedicated Stakeholder Engagement Plan (SEP) will be developed.  An output of the ESIA will be a Stakeholder Engagement Framework and this will then be further refined into a SEP. Further details on this component and the associated action item are provided in the Stakeholder Engagement section below. 

During construction, CIMAF Senegal, Ghana and Mali will implement the ESMPs and other management plans developed for their respective sub-projects to manage key E&S risks.

Organizational Capacity and Competency

At the Group level, CIMAT/CIMAF have retained a joint Director who is responsible for the Integrated Management System. The Director leads the design, implementation, and monitoring of the system across the business. Each OPCO (including Ghana and Mali) also has a Quality Control Manager and a Health, Safety and Environmental (HSE) Manager who have relevant training to fulfill their tasks, a HSE committee (comprising the General Manager, Quality Control Manager, Production Manager and Maintenance Manager, some staff HSE representatives and the HSE Manager); they report to the IMS Director.  The in-country HSE committees hold weekly and monthly performance review meetings and whenever significant developments or incidents occur. CIMAF Senegal will also have an EHS Manager and supporting team inclusive of a Community Liaison Officer to oversee EHS performance during the construction and operational phases of the project; and apply the same risk management and reporting structure outlined above (ESAP#5).

Emergency Preparedness and Response

The Group’s IMS includes an Emergency Preparedness and Management procedure (PR-SMI-C-10) that covers key emergencies including fire and explosions, serious accidents, chemical spills, spillage of hot fluids, natural disasters and external attacks. CIMAT implement this procedure and have developed site-specific Emergency Preparedness and Response Plans (EPRP) (plan d’operation interne) for their Morocco sites; the plans require emergency drills to be conducted twice a year. All CIMAF OPCOs observe respective government regulations on COVID-19 risk management.

CIMAF Ghana has an EPRP adequate to their operations. The Plan addresses fire, slips and fall and spillage emergencies. The CIMAF Ghana team reported that they conduct periodic simulations. CIMAF Mali have the necessary and appropriate emergency detection, alarm, and response equipment (fire detectors, fire extinguishers, sprinklers, first aid kits etc.), which are tested periodically, though do not conduct training and drills on emergency response. CIMAF Mali will thus align to the group procedure and develop an EPRP and implement a formal emergency drills and emergency training program and appropriately record all drills and training events. CIMAF Senegal will adopt and modify the CIMAT emergency preparedness and response plan to fit the scale of risks in the new cement plant and implement an EPRP. All three operations i.e., Senegal, Ghana and Mali, will also ensure their EPRPs are inclusive of communications procedures/requirements with emergency services and communities; and address relevant off-site risks posed emergencies, including through engagement with adjacent communities to the extent necessary so as to socialize them on such risks and any actions required by them in such instances, as well as through joint drills with local emergency services (ESAP #6).

Monitoring and Review

The IMS Manual has a provision for regular EHS monitoring and for analysis of EHS data via monitoring templates. These templates adequately cover key environmental parameters (stack emission and ambient air quality, noise, vibration, water consumption and waste) as envisaged in the World Bank Group (WBG) EHS Guidelines, including at contractor operation areas within the sites (including quarrying). The Manual also provides for identification and assessment of HSE non-conformities, and design, implementation, and monitoring of corrective actions. CIMAF monitors HSE performance through the quarterly corporate Quality and HSE performance reviews and internal audits as provided for in their internal audit procedure, including in CIMAF Ghana and CIMAF Mali. The findings of these audits are discussed, at management and Board level and improvements made where required. The audit reports contribute to the annual Group Sustainability Reports. Director review meetings are held annually to review the performance of the IMS and associated elements (e.g. policy, objectives etc.). To ensure labor and social related aspects are adequately monitored and reported upon, CIMAF will amend their internal audit procedure to incorporate labor and social related aspects including grievance management.  (ESAP#7).

 The CIMAT/CIMAF Group employs about 1,300 workers in the entire business. CIMAF Senegal will employ an estimated 800 workers during construction, and approximately 300 staff including 150 in direct employment and (30 skilled; 120 semi-skilled) and 150 contracted workers will be employed during operation phase. 

CIMAF Mali retains a workforce of 171, of which 73 are in direct employment (including 10 women staff, four of whom occupy management positions) and 98 are contract workers. An additional 15 workers will be employed following the expansion. CIMAF Mali employs about 50 of the direct employees from the nearby villages and some subcontractors are also hired from these villages. CIMAF Ghana currently employs 206 workers comprising 65 direct workers (58 male and 7 female); 4 expatriate consultants; and 17 contracted workers. Additionally, there are some 124 (107 male and 7 female) supervised contracted workers at the Tema port. Additional workers will be employed following the expansion.

Human Resources Policies and Procedures

Human resources (HR) is managed by the group Director in charge of HR and the respective OPCOs have HR designates, including CIMAF Mali and Ghana.

CIMAT/CIMAF have developed a Human Resource Procedure Manual and a Code of Conduct Handbook as the set of policies and procedures for managing all employees within the company. The Code of Conduct Handbook is designed to provide employees with the basic guidelines on working conditions, terms of employment and rights and responsibilities of employment. Amongst other, the Handbook covers personal and family details/beneficiary entitlement, working hours, overtime, holidays, insurance scheme/workmen’s compensation, performance management, remuneration, sexual harassment, grievance redress procedures, resignation and termination and business ethics.

So as to align the Group approach to human resources with the PS’s, CIMAF will update the Human Resource Procedure Manual and Code of Conduct Handbook and related procedures where necessary to address aspects related to equal opportunity, prohibition of child labor forced labor, and all forms of workplace harassment and discrimination, including gender management related aspects and gender based violence, freedom of association, management of third party (access to grievance mechanism and HSE  management) aligned with PS2 and ensure all staff at CIMAF Senegal, Mali and Ghana are aware of these.(ESAP #8).

Working Conditions and Terms of Employment

The Group implements a clear recruitment procedure which outlines tasks needed to request a new position, advertise for and source candidates (internal and external), interviewing and evaluation guidelines of candidates, employee contract terms and related administrative steps. The Recruitment Procedure (PR-RHU-C-01) provides a clear flow chart on how new employees are recruited, interviewed and become permanent staff. All CIMAT/CIMAF employees benefit from an open-ended contract (CDI), social security and social benefits. The benefits include adequate health insurance; transport for workers; meals for on-site workers; compassionate and religious leave days and allowances.

Workers’ Organizations

CIMAF does not restrict workers from joining unions.  While workers are not members of a formal worker union, the workers elect worker representatives (6 in total) who then negotiate relation to workers conditions. Workers meet every month with management to discuss working conditions and worker concerns.

In Senegal the approach is still to be defined, however as noted CIMAF will allow for unions and this similarly is the approach in accordance with national legislation.

Non-discrimination and Equal Opportunity

Although there is a clear Employee Recruitment Procedure at the Group level, CIMAT/CIMAF do not have an explicit and documented non-discrimination and equal opportunity policy. In CIMAF Ghana, job opportunities are provided on the principles of equal opportunity and fair treatment. Based on interviews with staff in CIMAF Mali, there is no discrimination, and recruitment and promotion are competency based.

As indicated in ESAP #6 above, CIMAT/CIMAF will incorporate a policy on non-discrimination and equal opportunity and prohibition of all forms of workplace harassment and discrimination, including gender-based violence, in their HR procedure / Code of Conduct and ensure all employees are aware of this. 

Grievance Mechanism

CIMAT/CIMAF have a Group Grievance Management Procedure for employees where they can raise workplace concerns. The grievance redress process covers grievance registration, redress decision, feedback and implementation, satisfaction and alternative action.

In line with the Group level grievance mechanism, CIMAF Ghana has adopted this procedure and implements a grievance mechanism to review and address employee’s complaints and all workers are aware of the existence of the mechanism. There is a designated person responsible for reviewing complaints and follows up on them in a timely and transparent manner.

In CIMAF Mali, the grievance mechanism is not formalized, and grievances are resolved informally. In the event of a worker complaint, the complainant confides in the workers’ representatives who meet with HR to explain the issue and seek solutions.

CIMAT/CIMAF will update the Grievance Management Procedure to facilitate anonymous reporting and cover third-party workers within their premises should such workers not have access to a grievance mechanism; the changes will then be implemented accordingly across all the project facilities in Senegal, Mali and Ghana and all the workers shall be made aware about the availability of such grievance mechanism.  In addition, this will be updated to clearly define the approach to addressing all forms or harassment (including sexual harassment and gender-based violence) (ESAP #9).

Protecting the Work Force 

As indicated in the CIMAT/CIMAF Human Resource Procedure Manual child and forced labor are strictly prohibited in the business. However, there is no formal system for verifying the age of workers who access the site, especially truckers and their apprentices. As part of the ESAP #8 above, the OPCOs will implement a system to manage the potential for under age workers to be employed at the site and this will include a mechanism to vet transporters’ apprentices accessing the operations and restrict the use of child labor by these transporters.

Occupational Health and Safety

CIMAF is in the process of implementing the IMS in its operations in Ghana and Mali. Ghana is expected to receive ISO 45001 certification by the end of 2021 while Mali will be certified in due course. Similarly, the Senegal plant will also be certified against this ISO standard.

Implementation of the ISO 45001 is within the ambit of the IMS procedures, including procedures related to the identification assessment of OHS risks, working at heights, working in confined spaces, induction, incident investigation, corrective actions and improvement, amongst other. The Group Director of the IMS is the overall custodian, and through the Quality and HSE Manager at each OPCO, the respective procedures are adopted and implemented as appropriate for specific plants. The plant HSE Committees support on site HSE risk assessments, sensitization, overseeing implementation of corrective actions and reporting to OPCO management, who then report to the Group IMS team. Periodic meetings are held to evaluate HSE performance. This structure is applied at both CIMAF Mali and Ghana, where OHS committees are in place. The committees meet every quarter as well as in the case of emergency. The committees’ key activities include site inspections, observation and discussions focused on non-compliance, safety awareness (staff, subcontractor and drivers), availability of adequate Personal Protective Equipment (PPE), safety instruction to be observed etc. and usage of PPE by workers, the safety instructions to be observed. CIMAF Ghana and Mali HSE Procedures stipulate that all workers, including contractors must ensure the use of experienced personnel and provision of adequate and appropriate PPE and that workers are provided with the appropriate personal protective equipment such as safety boots, raincoats, hand gloves, earplugs and nose masks. and other facilities.

The CIMAT/CIMAF IMS also has a training management procedure via which the departmental directors draft training plans with their specific personnel and then approach the human resource department to assist in carrying out these trainings. The trainings include QHSE induction, on-the-job training, and other site risk-based E&S training. Some training is managed internally, others are undertaken by outside providers and some by equipment providers. The IMS also provides measures and templates for monitoring various HSE indicators on a regular basis and provides guidance for training on key HSE issues.  In the last year, CIMAF Ghana conducted staff trainings on HSE management, fire safety, first aid, lifting and tag-out process. CIMAF Mali conducted trainings on HSE risk management and first aid in the same period.

In CIMAF Ghana, no material OHS incidents were recorded between March 2020 to February 2021, while incidents related to equipment use (mainly small cuts); moving machinery parts; truck movement, occurred in CIMAF Mali over the same period. These accidents did not cause serious injuries, but does require further oversight which will be addressed via implementation of the IMS. At both the Ghana and Mali sites medical support is provided as required via off-site medical support teams while there is first aid support on site.

During operations at the Senegal plant OHS will be manged via the IMS and more specially via the ISO 45001 aligned component of this management system as to be applied to the project.  During construction, oversight of contractor OHS performance will be managed by CIMAF via Contactor Management Procedure; the contractor will be required to develop and implement an OHS management plan aligned with good international industry practice. 

Workers Engaged by Third Parties

The IMS has a Contractor Management Procedure to manage third party businesses and their workers, including a detailed flowchart on who assists in managing third party employees. CIMAF Senegal will engage an EPC contractor for the Senegal project construction. Also, the quarry operations will be sub-contracted. Other contractors will be engaged to provide routine operations support (security, transport etc).  There are also contract workers at the Ghana and Mali operations that provide services such as cleaning and security amongst other.

To ensure alignment of contractors with PS2 and national legislation as appliable, CIMAF will upgrade the contractor management procedure as required in ESAP #4 to ensure ongoing review of contractors in accordance with the requirements defined.

No accommodation will be provided at the Senegal, Mali or Ghana project sites during construction or operation phases of the plants.

Supply Chain

Most of the primary inputs into the CIMAF Mali and Ghana (Clinker and Gypsum) are imported. Similarly, key inputs CIMAF Senegal (pet coke, Coal, Gypsum) will be imported. However, some inputs e.g., iron ore, fuel, packing bags will be sourced locally by CIMAF Senegal.

 Resource Consumption

CIMAT/CIMAF consider energy consumption in the project design and choice of processes, technology and equipment.  CIMAT achieved ISO 5001 Energy management certification in 2020; such certification at the CIMAF plants is expected to be obtained progressively. The Senegal cement plant will be premised on these similar principles. CIMAF Ghana have decreased energy consumption levels due to process optimization (e.g., selecting clinker based on grindability).

Energy: Thermal energy consumption of the Senegal plant is within the range reflective of Best Available Techniques (BAT) defined by the 2013 EU BAT Reference Document for the sector, and within the benchmark set by the WBG EHS Guideline for Cement and Lime Manufacturing.

Petroleum coke (or Pet coke) will be the main fuel source for the kiln, but the plant design will be flexible to accommodate alternative fuels, viz. coal, natural gas (when it becomes available) and other alternative fuels. These sources are interchangeable, and price will determine fuel preference at any point in time. The actual usage of alternative fuels will be dependent on Senegalese legislation and regulations. If acceptable, alternative fuels will be phased-in gradually over a few years after plant commissioning.

The plant will incorporate best practice design solutions as already tested in the two CIMAT Morocco cement plants. It will thus be more efficient compared to other cement plants in the region, due to best practice approach to design concept (such as: 5-stage pre-heater; vertical roller-mill; reduced clinker/cement ratio; possibility to use alternative fuels, including refuse derived fuels and tire derived fuels for up to 30% of thermal substitution rate). CIMAF will explore waste heat recovery options as part of the feasibility study after the commissioning of the plant.

The project will use grid electricity.  The electricity requirement is estimated between 1-2 kWh / ton of limestone for the quarry, 60- 65 kWh / ton of clinker for the clinker production, 25-40 kWh / ton of cement for the cement grinding and +-5 kWh / ton of cement for packing and dispatch. The operations are estimated to be within the guidelines provided by the WBG EHS Guideline for Cement and Lime Manufacturing.

Grid electricity will be supplied by SENELEC (National Electricity Company of Senegal) from the existing 225kV line that crosses the project site between the plant and the quarry; or, less likely, to the existing 90kV line that runs parallel to the N2 road, 2 km away from the site. The latter option will be explored only if the ongoing discussions will SENELEC on accessing the 225kV line does not result into favorable outcome for CIMAF; E&S impacts associated with this option have been considered in the current ESIA and are considered low as there are no economic activities or physical settlements along the proposed route  i.e., no impacts associated with PS 5 or PS 6. CIMAF will subscribe to 20 MW from SENELEC. A 1000 kVA generator will be installed as well, to back up critical equipment in the event of a power cut.

In Mali and Ghana, CIMAF already has access to grid electricity to accommodate the planned milling capacity expansion. However, CIMAF has put in place back-up diesel generators for use during power outages. With the grinding plant expansion, CIMAF will expand the backup power capacity at both plants. CIMAF Ghana and Mali grinding plants will both consume between 30-45 kWh/ton of cement produced after the expansion works due to similarity of size, technology and fuel used. This consumption is within the guidelines provided by the WBG EHS Guideline for Cement and Lime Manufacturing.

Water: The Senegal cement plant water needs are estimated to be less than 50 m3 / day. The manufacturing process is essentially dry, and most of the water will be used primarily for cooling, dust suppression, in the kitchen, sanitary facilities for workers and regular use by construction staff temporarily housed on site.

To meet the water needs, CIMAF will install boreholes onsite to extract ground water. The water table is estimated at 200-meter depth, within the deeper aquifer, CIMAF will conduct a hydrogeological survey to assess potential impacts on the shallow groundwater resources as used by local communities and define mitigation measures where applicable (ESAP #10). As alternatives, water supply from SEN’EAU (Government Water Company) boreholes and water supply by tanker trucks will also be considered. As indicated in PS 2, there will be no accommodation on site during project construction or operation due to proximity of site to urban areas including communities and Dakar. Water consumption may mainly be for routine construction activities. The actual water requirements during construction will be limited and can be supplied to site by a mobile tanker if necessary. 

Water consumption will be monitored on a monthly basis, similar to the practice at the Morocco plants. In Ghana, the CIMAF grinding plant utilizes the already treated water supply from the Ghana Water Company in their operations, while an on-site borehole supplies water for process use in the Mali grinding plant. In both Mali and Ghana grinding plants water quality is monitored by the laboratories on site and in both instances this water is also used for potable purposes.  The water requirement for production processes at the grinding plants is minimal.

Air Emissions

Air quality: The plant design is not yet finalized. however, the main sources of dust at the CIMAF operations (inclusive of the Senegal facility) plant will be clinker production and grinding operations including limestone quarrying activities and transfer to site (via truck haulage), clinker discharge at the site and ports where appliable, raw material haulage including clinker to the sites, on-site storage and handling of clinker, limestone, basalt and gypsum at the plants, transfer of cement to the silos for storage, and bagging of cement. The kiln operations, back-up generators, and operation of vehicles and equipment at the integrated cement plant and quarry generate Carbon Monoxide, Carbon Dioxide, Nitrogen Oxides, Sulphur Dioxide and Particulate Matter. For the Morocco plants, CIMAT conduct ambient air quality, and monthly stack emission monitoring monthly against local and international industry standards; this similarly will apply in Senegal.

For the Senegal cement project, the air quality specialist study is underway. Ambient baseline air quality monitoring was undertaken at 12 different measuring points at the plant, proposed quarry areas, nearby N2 road and in the nearby villages during summer which is considered the worst-case scenario. Preliminary findings from the ESIA air quality modelling study indicate the project will comply with the WBG EHS Guidelines and that the plant will not contribute more than 25% to any applicable air quality standard within the airshed.  Further, and assuming the project is within in degraded airshed, it should be acknowledged that the anticipated (guaranteed) dust emissions from the stack are 10 mg/Nm3 which is a significant improvement from that as defined in the WBG EHS Guidelines.  Taking this into account and assuming effective fugitive dust control and appropriate design e.g., enclosed conveyors, it is envisaged this will align with the requirements as outlined in the WBG EHS Guidelines for operating in a degraded airshed.  

While acknowledging the above, CIMAF will install equipment based on best available technology and are committed to addressing the technical and operational recommendations from the air quality study report. Thus, CIMAF will complete this study, inclusive of the full modelling, and implement such recommended measures to ensure compliance with the WBG EHS Guidelines (ESAP #11).

CIMAF Ghana and Mali conduct monthly air quality monitoring (through a contracted third-party) and the results consolidated with all other OPCOs for the CIMAT/CIMAF periodic group reporting.  CIMAF Ghana has installed hoppers equipped with dust extractors/collectors at the clinker discharge berth in the Tema Port. At the grinding plant, the company also has two roofed sheds for the storage of clinker and gypsum. The sheds and the dust capture system (bag filters) at the cement grinding, cement storage silos, bagging and loading areas significantly contribute to the minimization of dust generation in the operations. Sampling is done at the warehouse area, loading area, weighing area, and the gypsum area. The sources of dust emissions in CIMAF Mali are the grinding section (channeled emissions), handling operations (loading / unloading) and uncovered raw material (limestone) stockpile. CIMAF Mali has built-in bag filters at the grinding section to manage emitted dust and January to December 2020 emission tests indicated concentrations below the WBG EHS Guidelines (Cement and Lime Manufacturing) for ambient PM10 and PM2.5, apart from June, July and August when the bag filters malfunctioned.

To ensure ongoing alignment of the Mali and Ghana operations with the WBG EHS Guidelines for ambient dust emissions CIMAF will provide regular monitoring data to IFC to confirm such (ESAP #12). In the event there are exceedances, CIMAF will implement mitigation measures as required to ensure alignment.

Greenhouse gas emissions (GHG): In their standard design criteria for new cement plants, CIMAT/CIMAF have included some notable low-carbon requirements, including; low clinker/cement ratio, vertical mill, five-stage preheater, BAT standard of low thermal energy use, and potential use of alternative fuels. These provisions will be included in the Senegal plant design. The total estimated CO2 emissions of the Senegal plant are +-1,100,000 tCO2eq/year (high value), while the expanded Mali and in Ghana grinding plants are estimated at 20,000 tCO2eq/year and 17,500 tCO2eq/year respectively. CIMAT has a greenhouse gas monitoring and reporting system and this will be applied in the Senegal plant.

Noise and Vibrations

CIMAT conducts ambient noise monitoring annually at the property boundary, while occupational noise monitoring is conducted once every two months. Vibration and blast monitoring is conducted monthly. At the Senegal cement plant, noise will be managed through equipment design, plant design and layout and worker sensitization. 

Quarrying approach will be stepwise and will be by blasting. There will be one blasting event per week at the quarry. Loading and firing of the detonators will be subcontracted. There will be no storage of detonators or explosives at the site. The project is, however, in a classified forest area, and the closest dwellings are just over 1km from the plant, and more than 2km from the quarry section. The noise and vibration study for the Senegal cement plant is underway. Based on the baseline noise data and initial modelling results as part of the ESIA, noise associated with the project during the construction and operational phases is anticipated to be below the requirements for such as defined in the WBG EHS Guidelines. However, this will be confirmed following completion of this study as part of the ESIA and CIMAF will implement the recommendations / mitigation measures as may be defined to ensure ongoing compliance with the requirements of the WBG EHS Guidelines (ESAP #13).

In CIMAF Ghana and Mali, ambient noise comes from mill/grinders operation, conveyor systems, hoppers, motorized engines and loading trucks. Noise monitoring data covering the warehouse areas, loading areas, weigh bridge areas and gypsum areas are periodically conducted, and the results generally are within WBG EHS Guidelines for occupational noise level threshold, at 80 and 85 dbA. Going forward CIMAF Ghana and Mali will expand the noise monitoring to include for environmental monitoring around site boundaries and based on the results implement mitigation measures if required to align with the requirements of the WBG EHS Guidelines.

Waste Management

Solid waste: The main waste types generated in CIMAT/CIMAF operations include wooden pallets, scrap metal, e-waste from changes of computer and other electronic parts, paper waste including damaged or torn cement bags, material/equipment packaging materials, vehicle and equipment parts and raw material residues from milling operations. CIMAT/CIMAF have a Waste Management Procedure, currently applied in Morocco, that covers general and hazardous wastes and includes provisions for waste recycling where possible. This procedure will be adopted and applied in CIMAF Senegal as part of the IMS.  The type of treatment or disposal of methods of these wastes’ ranges from reuse, return to vendor and recovery back into production.

CIMAF Ghana and Mali have retained the services of regulator-approved waste contractor for both unusable or unrecyclable wastes general and hazardous wastes. However, at CIMAF Mali, some mixed waste including waste cement bags and plastics are incinerated in an on-site artisanal incinerator. CIMAF will discontinue use of the artisanal incinerator and agree with IFC on an appropriate approach to the disposal of this waste (ESAP #14).

Construction wastes at the Senegal cement project, Mali and Ghana grinding plant capacity expansions will be managed via the ESMPs to be developed for the respective projects.

Wastewater: The main wastewater sources in cement plants are sanitary facilities. The Senegal cement plant will have a wastewater treatment system that meets WBG EHS Guideline requirements. Treated wastewater will be reused where feasible.  At the Mali grinding plant, the sanitary wastewater is stored in 4 septic tanks which are emptied by a specialized and government-approved company, while the Ghana plant has connected the wastewater system to the Tema Industrial Zone sewer system. Both CIMAF Ghana and Mali have designed drainage features to manage stormwater, isolated from the process wastewater drainage and recycling structures. Stormwater is directed into a nearby drain for CIMAF Mali plant, and into Tema Industrial Zone drainage system in CIMAF Ghana. The Senegal cement plant design will include an appropriate stormwater management system.

Hazardous Materials Management

The main hazardous materials in cement production include energy sources (coal and pet coke), fuel for the back-up generators, laboratory materials, engine oils and lubricants and the processed cement. CIMAT implements a Chemical and Inflammable Product Storage Procedure and a Chemical Register. CIMAT/CIMAF will upgrade the Chemical and Inflammable Product Storage Procedure to also provide adequate measures for handling and transportation of hazardous materials in their operations, including requirements for adequate bunding and secondary containment of hazardous materials as required in ESAP #4. The Procedure will be adopted and applied in the Senegal cement plant. Mali and Ghana grinding plants have documented spill management procedures. For chemicals used in the Mali and Ghana grinding plants, safety data sheets are available, and operators are made aware of the safety instructions relating to the products. PPE (masks, gloves, glasses, face shield) as well as safety showers are provided. To avoid cases of spillages, CIMAF Mali and Ghana will adopt and implement the revised Chemical and Inflammable Product Storage Procedure.

Quarry Closure & Rehabilitation

CIMAF propose a mixed approach to quarry operation and rehabilitation. Completed sections of the quarry will be rehabilitated \as the exploitation works progress, and complete rehabilitation will be done at the end of the quarrying. CIMAF will compile a comprehensive quarry closure and rehabilitation plan which defines a more detailed approach to rehabilitation, including associated timelines and costs. This plan should consider measures for conservation of topsoil from the cement plant area for use in rehabilitation of the quarry, allied to topsoil from the quarry itself (ESAP #15).

 The CIMAF Senegal project area already has two existing cement plants within a 5km radius, a phosphate quarry 1.5 km from the site, some nine separate villages are located between 1 km and 5 km from the proposed plant location to the north and west of the site. A national road traverses the southern part of the site, about 2km away; and an international airport is located about 7km South-west of the site.

CIMAF Ghana is located in the Tema industrial zone and clinker from the port is transported via a national highway to the site. CIMAF Mali is located in a designated industrial area in a semi-rural rural area 30 km from Bamako with the closest residence 600m from the site.  In addition, the R24 highway is located directed adjacent to the site and thus access routes to the site itself do not impact communities. However, transfer of limestone to the facility does require routing via communities.

Infrastructure and Equipment Design and Safety

The quarry and cement plant will be located in close proximity, within a fenced site. Details on the final plant design specifications are yet to be completed, but the principle in the design will be based on installation of efficient equipment with effective air, noise and vibration pollution control systems, site equipment layout that best reduces distance covered by quarry products from the quarry to the processing plants and regular monitoring of emissions to safeguard local communities and the environment. Wastewater will be treated and re-used in the cooling process to reduce consumption and eliminate discharge to nearby environment. From the studies on geology of the Senegal cement plant project area, no risk of earthquakes is reported.

Details on the impacts and risks to communities associated with blasting and associated vibration are still to be defined in the ESIA (to be included with the noise study), though it should be noted the closest village is 1.2 km from the site. Impacts because of vibration could result in damage to community structures taking into the nature thereof. As per ESAP#13, CIMAF will comply with the mitigation measures as defined in the study to ensure potential impacts on communities are at an acceptable level. The latter will include management plans and an EHS procedure for blasting in support of such which ensures effective communication with communities in relation to blasting and raising community awareness as to the risk of blasting.

CIMAF Mali and Ghana grinding plants are designed and built according to the best available technology and general industry standards.

Influx Management

Human settlement within the Thies Forest is prohibited by the Government of Senegal and as evidenced with other cement plants in the area, there is no development adjacent to the plants. However, during both construction and operation phases of the Senegal cement plant, due to the scale of the project there is the potential risk of influx people from outside the project area. These include: construction workers (during construction period), truckers during the operation phase and more generally, job seekers and related informal businesses that result from such developments. This may pose risks to these communities, including security risks and gender-based violence.

Across its operations, the Group has demonstrated adequate capacity to prevent and manage influx in its other plants in Morocco and across sub-Saharan Africa and has defined clear guidelines for subcontractors to decrease the risk of influx.  CIMAF Senegal will therefore adopt the Group’s existing best practices to manage influx at this project and adapt these so they are fit for purpose to meet the specific circumstances in Senegal and are in line with PS’s.  These practices and other mitigating actions as may defined in the ESIA will be documented into an Influx Management Plan for Senegal (ESAP #16).

Transportation Safety

The Road Safety Management System that is being applied in Morocco is being applied to some extent in CIMAF Mali and Ghana, and will be applied by CIMAF in Senegal. The system promotes communication, travel planning, vehicle management, driver certification, and appropriate infrastructure provision (e.g. driver rest areas, signage etc.). CIMAF contracts vehicle supply in its operations including haulage trucks, and implement further measures to prevent the risk of traffic accidents, including training / awareness of drivers on the rules of conduct (safe driving, safety rules to be observed), the choice of suppliers who have a fleet of trucks in good condition etc. All the trucks that transport the products are fitted with tarpaulins to manage dust. The traffic study for the Senegal cement plant project is underway, however given the national highways is some 2 km from the site, anticipated impacts associated with traffic are considered limited at this stage, though will be confirmed via the traffic study. CIMAF will complete the traffic study as part of the ESIA and implement the recommended mitigation measures inclusive of related management as required for the construction and operational phases (ESAP #17).

At both CIMAF Mali and Ghana operations, it is reported that no traffic accident related to raw material transport has occurred in the last year. To align to the Group Road Safety Management System, CIMAF Mali and Ghana will update their transport safety procedures to require closer tracking of contracted material supply trucks and documentation of all road incidents related to material loading and haulage as required in ESAP #4.

Security Personnel

CIMAF have contracted a security service provider that provides unarmed security at the Mali and Ghana grinding plants. The company will contract unarmed security service providers for the Senegal cement plant. CIMAF will develop a Security Risk Assessment and Management Procedure for CIMAF Mali, Ghana and Senegal, as required in ESAP #4 to guide the conduct of the security personnel. This will include anticipated security risks associated with increased crowds around the premises in search of jobs.

 General

The Project overlaps the West Sudanian savanna ecoregion. The site is within the Foret de Thiès Forest Reserve (IUCN Cat. Not Reported). Before CIMAF interest in the area, the government has previously delimited some portions of the Forest Reserve for community and industrial developments and granted two other cement companies permits to explore the limestone reserves and set up cement plants. CIMAF Senegal signed a memorandum of understanding (MoU) in 2017 with the Department of Water, Forests, Hunting and Soil Conservation (DEFCCS) for the opening and operation of a quarry covering an area of 727 ha within the Forest Reserve. This authorization is valid for 25 years and is renewable. 

The project area is a mosaic of Modified and Natural Habitat, mostly degraded, due to significant and long-term community use (e.g., wood collection, grazing). Initial biodiversity surveys and desktop screening identified risk of vulture activity which could have triggered Critical Habitat status, but subsequent targeted surveys of project area by regional vulture experts have found no evidence of recent roosting or nesting activity. It remains possible that vultures may occasionally visit if food (e.g., livestock carcasses) is available given that they will forage over very large areas.

Baseline surveys were conducted in the dry season and supplemented by targeted dry season surveys for vultures. This is likely to underestimate biodiversity value, given wet season is associated with greater fauna and flora presence/activity, including possibility of some migrants. This greater activity is unlikely to change IFC habitat designation but may increase the area considered as natural. The Project will undertake a wet season (July - October) biodiversity survey to address current baseline gap (ESAP #19). The Project will develop, as part of its ESMP, measures to; i) monitor vulture activity on a regular and ongoing basis; ii) implement procedures to prevent attracting vultures to the project area (e.g., carcass monitoring and removal); iii) manage bird collision risks associated with project infrastructure such as transmission lines; iv) identify and avoid areas of higher value natural habitat (e.g., baobab stands) (ESAP#20). The plan is to be updated following completion of wet season surveys, and analysis of impacts. CIMAF have, as part of the permit conditions to operate within the Thies Forest, a requirement to contribute to the government (specifically the Forest Department) programs on restoration and conservation of the Thies Forest. The Project will provide evidence of implementation of these conservation actions to support the Forest Reserve as required by DEFCCS or Forest Reserve management and compensate for loss of high value species such as baobabs (ESAP#21).

Priority ecosystem services were identified (e.g., grazing lands, firewood, foods, fibers and medicine). These include cultural values associated with baobab trees. Impacts to these services will be managed under PS5, as described in ESAP #18. Impacts to baobabs will be managed as described in ESAP#20 and ESAP#21.

 Protection of Cultural Heritage in Project Design and Execution

No nationally or internationally designated cultural heritage sites were identified in the study area. However, 28 non-designated cultural heritage features were identified, mainly wood-and-earth-made temporary structures that may be associated with agro-pastoralism. The settlements comprise small villages of circular dwellings and enclosures for livestock. The structures within the settlements may be historic or modern, but importantly may form part of a larger intangible heritage in the form of traditions associated with an agro-pastoral way of life. Assessment of the features identified within the study area and review of academic records indicate that the Thies Forest lies along a transhumance corridor traditionally used by pastoralists from west to North of Senegal, influenced by seasonal weather patterns. Corridors are important, as the historic tradition is under threat by settled agricultural communities and, likely in future, industrial developments.

However, the project will exploit some 502 ha of the 8,700 ha Thies Forest land, hence while the significant of risk may not be high at the moment, it will likely change if more industrial and agricultural communities settle around the Thies Forest as the cumulative impact to the nomadic pastoralists may be higher. 

The assessment also revealed an intangible cultural heritage asset of two Baobab trees outside of the project footprint, used as a marker for a burial ritual site for the community of Soune Serer, 4.5 km from the project site.

CMIAF will develop and implement a management plan to protect non-designated cultural heritage features identified within the project footprint and a chance find procedure in the event that artifacts and objects of cultural significance are identified (ESAP #22). In relation to the Baobab as referenced above, the protection thereof will be incorporated into Baobab conservation plan referenced in ESAP #22.

Given significant project-induced and cumulative impacts on communities’ livelihood and eco system services, requirement of Broad Community Support was considered applicable and hence assessed for this project. CIMAF’s engagement and consultation process with the surrounding communities and other relevant stakeholders has been open, transparent and participatory. Engaged community representatives (traditional authorities, elders, women, youth, herders, farmers) and stakeholders expressed their support for the Senegal plant.  This community support is based on CIMAF implementing and following through with the commitments in the Livelihood Restoration Plan (LRP) in providing livelihood and ecosystem service support to affected communities. CIMAF has committed to implementation of the ESIA and E&S management plans including the LRP and remain engaged with communities/stakeholders through the construction and operations phase of its plant’s operations.