As per the ESIA and the biodiversity specialist reports, there are no priority ecosystems or protected species of fauna or flora around the RSK Plant location, hence PS 6: Biodiversity Conservation and Sustainable Management of Living Natural Resources is not applicable. There are no indigenous peoples among the project affected persons, and no artefacts or sites with significant cultural heritage were identified within the project site. Therefore PS 7: Indigenous Peoples or PS 8: Cultural Heritage are not applicable.

 This is a Category B project, according to IFC’s Policy on Environmental and Social Sustainability. Based on the information reviewed during the appraisal, it is expected to have limited adverse E&S risks and impacts that are few in number, short-term and site-specific, and can be avoided or mitigated by adhering to recognized performance standards, procedures, guidelines and design criteria as described in the following sections.

The key E&S issues and risks identified for the project include: assessment of E&S risks and impacts during construction and operation phases of the project; RSK’s E&S policies and procedures and systems to manage the E&S risks and impacts related to its operations; management of workers and working conditions, especially related to recruitment, occupational health and safety (OHS), grievance handling, and management of third party workers; resource use efficiency, waste management and greenhouse gas emission management; land acquisition, engagement and compensation process for the project affected persons; stakeholder engagement during Plant construction and operations phases. 

 RSK undertook a full ESIA for the greenfield Kumasi site between August and December 2019. The ESIA report includes an E&S management plan (ESMP) outlining various measures to mitigate the identified impacts. RSK submitted the report to EPA for review and issuance of the EIA Certificate.

To adequately address the key E&S issues related to associated facilities (power and water supply) and provide better impact management measures for some key risks, the report will be upgraded to (ESAP 1);

(i)            address risks and potential impacts related to siting, drilling and operation of the 6 planned groundwater wells;

(ii)          address potential impacts related to the land acquisition, infrastructure installation and operation, for the planned 6km main water supply line to be led by Ghana Water Company;

(iii)        address potential impacts related to acquisition and maintenance of right of way (RoW) for the planned 6km long 33kV transmission line to the Plant site;

(iv)         undertake air dispersion modelling and include the findings and appropriate mitigation measures in the baseline and impacts sections, respectively;

(v)           clearly recommend measures to reduce surface erosion, manage and dispose of solid and liquid wastes, from storm water run-off, contaminated wastewaters and effluents, to mitigate against contamination of the seasonal drain (also called Atinsua Stream) running across the site, and impacts on downstream water users;

(vi)         relate the baseline ambient air quality, PM levels and noise levels to the World Health Organization (WHO) Guidelines Standards as appropriate;

(vii)       address impacts related to physical and economic displacement conducted during land acquisition and recommend appropriate management actions going forward.

The 2019 ESIA Report is attached to this disclosure, and the upgraded ESIA version will be disclosed once ready.

Policy and Management Programs:

RSK will develop an E&S Policy statement outlining RSK’s philosophy regarding management of environmental and social risks and impacts in the business. The Policy will include specific objectives set by the management regarding environmental and social performance, scope of coverage and risk management responsibilities, and will be communicated to all direct and indirect workers, as well as other primary supply chain entities (ESAP 2).

To ensure consistent management of E&S risks and impacts during the operations phase of the business, RSK will develop a corporate E&S management system (ESMS), including appropriate policies and procedures. The ESMS will include, at minimum: corporate policy statement on E&S Management; and procedures to address; occupational health and safety (OHS) management based on Hazard Identification and Risk Assessment (HIRA); wastes and hazardous materials management; stakeholder engagement; air quality management; emergency planning and response; E&S risk identification and assessment; contractor and supply chain management; and water and energy management, for its operations (ESAP 3).

For the construction phase of the project, RSK will develop and implement a Construction OHS Plan to guide the contractors on management of the safety and health of workers and visitors at the site (ESAP 4).

Organizational Capacity and Competency:

RSK Project Manager, who is also the company CEO, currently oversees all aspects of the greenfield project. During the construction phase, RSK will engage an environmental health and safety (EHS) Consultant with strong OHS competence to lead E&S risk management and oversee compliance with the Construction OHS Plan, as the company recruits a full-time competent EHS Manager (ESAP 5). Once on-board, the EHS manager will oversee the development and implementation of the corporate ESMS, and all E&S matters in the operations. RSK will engage the human resources staff at the RSG Tema Plant for the initial stages of Kumasi operations, mainly recruitment and onboarding of staff, before eventually recruiting own staff in this role.

Emergency Preparedness and Response:

The project ESMP and the Construction OHS Plan will include emergency response measures to address likely unforeseen incidents, including fire, security incidents, spillage and community issues. These measures will be applied throughout the construction phase of the project. For operations phase, RSK will develop an Emergency Planning and Response Procedure (EPRP), under ESAP 3. The EPRP will entail, at minimum; processes for identification of the emergency scenarios, specific response procedures, responsible teams and their roles, emergency contacts, procedures for interaction with third parties (including government authorities), equipment and facilities, evacuation routes and muster points, and emergency drills and their periodicity. The Procedure will be communicated to all the workers and reviewed periodically to address any emerging needs.

Monitoring and Review:

The ESIA includes an E&S Monitoring Plan to guide periodical monitoring of the mitigation measures developed for the key construction-phase risks and impacts. For the operational phase, RSK will develop standard performance monitoring indicators, assign roles and responsibilities and make provisions for internal audits and management review, against each E&S risk management procedure developed under ESAP 3.

 RSK will employ, majority through contracted companies, approximately 150 workers during the project construction phase. The company will employ about 350 workers, including 10 direct staff and approximately 340 contracted workers (some by the equipment manufacturer and others through a labor outsourcing company) in the first year of operation. The operation phase outsourced workers will be undertaking core production activities, and their management is likely to follow the system applied at the RSG plant at Tema, where the RSG HR management staff and the EHS Manager oversee this workforce by interfacing with the labor company’s representatives on site regarding working conditions, labour relations, OHS and staff welfare.

The local labour recruitment process for the operation phase will target the local community and will be led by the outsourced labor company. RSK will facilitate capacity building for new workers prior to confirmation. Any required replacement workers will also be sourced in the same way. Due to the focus on local labour, labour camps and housing will not be required. RSK expects to provide transport for workers from the nearby settlements to the site as part of the non-monetary benefits to direct and indirect staff. As is the practice at the Tema plant, staff at the Kumasi Plant will work in 8 hour shifts with a maximum of 4 hours of overtime. Each shift works 4 days and takes 2 days off, and the overtime compensation is higher than that for the normal shift. This arrangement is in accordance with the local labor laws.

EHS supervision, management and training at the Plant will be coordinated between the shift supervisors, foremen and the EHS manager, with oversight support from the factory inspectorate staff.

Human Resources Policies and Procedures, and Terms of Employment

The company will develop a Human Resources (HR) Manual including policies consistent with the requirements of PS 2 and Ghana labor laws (ESAP 6). The HR policies will apply to the direct staff; and will include measures to oversee compliance of labor contractors with local labor laws and PS2 requirements. The policies will be clear and understandable regarding workers’ rights under national labor law and any applicable collective agreements, including their rights related to freedom of association, hours of work, wages, overtime, compensation, reward systems, retrenchment and benefits upon beginning the working relationship and when any material changes occur. The Manual will be communicated to all workers.

Each employee will have formal contracts that meet the minimum Ghanaian labor law requirements and will be provided with sufficient working space and minimum work requirements in terms of equipment and resources. RSK will put in place measures to ensure that the all contractor Firms and the outsourced HR Firm complies with this requirement including integration of applicable compliance requirements in the labour contracts and establishment of procedures in the RSK ESMS to monitor the same.

Non-discrimination and Equal Opportunity

To address key HR matters such as recruitment, worker training, promotion and salary increase, without any discrimination, RSK will write a non-discrimination and equal opportunity policy statement that fosters fair treatment at the workplace and commit to values that do not discriminate against employees or job applicants with regard to differences in race, tribe, color, religion, pregnancy, sex, age, national origin, marital status, or physical disability or any other protected characteristics. This policy statement will be integrated into the HR manual.

Grievance Mechanism:

For the proposed project, RSK will develop and implement a grievance process that provides channels for grievance registration, processing and feedback process, and allows for alternatives for anonymous complaints and feedback, to be included in the HR Manual. The grievance process will be designed to cover direct as well as contracted workers (ESAP 7).

Occupational Health and Safety:

During construction of the Plant, RSK will be guided by the Construction EHS Plan to implement a set of procedures and practices that safeguard safety and health of the workers and visitors. For the operations, RSK will implement the OHS management procedures (developed under ESAP 3) to ensure a safe and healthy workplace.

For the operation phase, a fitted clinic with a doctor and nurses will be established on site and a partnership established with a health facility and ambulance services in case of medical emergencies requiring specialized services. RSK will comply with industry legal requirements on medical personnel and OHS practitioners. The HR contractor will be expected to undertake the “fit for work” tests for staff at recruitment but will present his staff to the clinic for periodic medical checks. The clinic staff will also be a key resource in health outreach activities under RSK’s CSR program. RSK will monitor the contractor’s recruitment process through a procedure established in the ESMS as required in ESAP 3, to ensure that non-discrimination and equal opportunity policies are adhered to during this process.

In both phases, RSK will take steps to prevent accidents, injury, and disease arising from, associated with, or occurring in the course of work by minimizing, as far as reasonably practicable, the causes of hazards. RSK will ensure that the measures in place address; (i) identification of potential hazards to workers, particularly those that may be life-threatening; (ii) provision of preventive and protective measures, including modification, substitution, or elimination of hazardous conditions or substances; (iii) training of workers; (iv) documentation and reporting of occupational accidents, diseases, and incidents; and (v) emergency prevention, preparedness, and response arrangements.

Workers Engaged by Third Parties

RSK will engage contractor Firms for the construction activities, and an HR resourcing Firm during operations. For these Firms, and any other contacted Firms in future, the company will include, in the contracts with all third parties, minimum OHS and labor requirements, that align to Ghana labor laws and the inherent OHS risks of their contractual tasks (ESAP 8). During construction, OHS and labor compliance will form part of the project progress reports, while RSK will conduct annual HR audit of the outsourced Firm to check compliance with the requirements.

Supply Chain

Metal scrap will be collected by individuals around Kumasi area and delivered at dealers’ yards in Kumasi in carts, gunny bags or small motorcycles. Others will be delivered by trucks from neighboring countries. Once consolidated in sufficient numbers at the dealers’ yards, the scrap agent will weigh and collect them for delivery at RSK. The inherent risks in the supply process include; traffic accidents, injuries to the collectors, health risks from exposure to hazardous fumes or materials and possible engagement of child labor for scarp collection.

While RSK does not have direct control on the collections by scrap aggregators who tend to collect scrap from informal yards, the company is sensitive to the potential health and safety and harmful child labor risks in this part of its supply chain. As such, the company shall undertake supply chain mapping and develop a policy on harmful child labor in scrap collection (ESAP 9). If child labor instances are identified, the company will take appropriate steps to remedy them on the best effort basis, including moving away from aggregators found engaging child labor. RSK will also conduct need-based OHS sensitization sessions with selected scrap dealers owning collection yards and the contracted scrap aggregators to mitigate the OHS risks.

 Resource Efficiency:

Energy: The main power supply for the project will come from the government electricity company, GRIDCo. Power will be relayed to the RSK site from the power sub-station 5.1 km away. The Kumasi Plant will initially run three 20MT capacity furnaces, to be doubled in Year 3. The estimated monthly energy consumption in the first two years is projected at 8,400 MWh, and this will increase to 25,000 MWh after year 3. For roll bar reheating, about 160,000 litres residual fuel oil will be used annually, while some 10,000 litres of diesel consumed by back-up generators annually. These figures may increase significantly once all 4 furnaces are up running. RSK will include energy efficiency measures in their energy management procedures, to be developed under ESAP 3. The procedures will address processes of identification, and regular measurement and reporting of principal energy uses at every unit, and guide in setting and implementation of energy saving and cleaner production targets.

Water: The Ghana Water Company will provide piped water into the premises, at a cost. To supplement this, RSK intends to drill some 6 boreholes for use, especially when production rumps up. As part of the management measures in the water management procedures to be developed under ESAP 3, RSK will institute measures for adequate process and flood water collection, spill and leakage control, regular measurement and recording of borehole water flows and circular cooling and water reuse system.

Greenhouse Gas (GHG) Emissions: The construction phase GHG emissions will relatively be insignificant and associated almost entirely with fuel consumption by the fleet of motor vehicles and heavy equipment during construction, as well as standby diesel generators, to be utilized during outages. These emissions are expected to be less than 25,000tCO2eq/annum.

During RSK operations, the main GHG emission sources fuel used in furnace, diesel generators, and use of LPG in cutting scrap and welding purposes. The emission during operation are estimated at 95,000tCO2eq/annum after the first year of full production. By sourcing for scrap locally, the project will result in a gross avoidance of imports-related GHG emission of 330,000tCO2eq/annum.

Pollution Prevention

During construction, air, soil and noise pollution will be the main risks. Air emissions will primarily be from dust / particulate matter and fugitive emissions from moving equipment. RSK will manage these risks through implementation of the construction OHS Plan and the environmental and social management plans derived from the ESIA studies. During operations, the key risks will be from dust and fugitive emissions from the scrap sorting and cutting at the yard at heating and cooling processes.

A natural drain exists along the valley on the norther side of the project site, within its footprint. Though dry most of the year, it becomes a stream during rainy seasons. The stream flow in the rainy season joins a larger stream downstream, used for irrigation, livestock watering and some domestic purposes by the local communities. The project site layout will be designed to adequately manage process waste waters and storm water and check that their quality meets minimum legal limits before discharging into the drain.

The induction furnace selected for the operations is environmentally friendly since it achieves higher production yield for less heat used, hence less emission. The proposed air emissions collection and treatment system consists of a negative pressure mobile hood, settling chamber, baghouse dust collector and emissions stack. The system is designed for a 95% collection rate with an emissions concentration of less than or equal to 50 mg/Nm3. The proposed emissions concentration for particulate matter from the emissions control system of less than or equal to 50 mg/Nm3 is consistent with those established in the World Bank EHS Guidelines for Integrated Steel Milles of 20-50 mg/Nm3. The closed-hood furnace will also minimize explosion, heat and flame-related risk to workers, as well as reducing potential secondary dust.

Waste management:

During construction, the waste streams will primarily be excavated soil, vehicle/equipment parts, equipment wrappers and general paper, wooden pellets, metallic pieces, food materials and plastic materials. To manage these, RSK will implement the construction-phase Waste Management Plan developed as part of ESIA studies and in line with Ghana’s waste management Regulations. During operation, expected key solid wastes include unused scrap, furnace slag, fine dust gas cleaning; metal chlorides from precipitators; tar and other organic compounds, food wastes, medical clinic and laboratory wastes and general office wastes. RSK will implement the Waste Management Procedures to manage all streams of wastes, including biomedical wastes in line with Ghana’s waste management Regulations.

Wastewater Management:

The site is not covered by the municipal sewer system. A Wastewater Management Plan (WWMP), which includes measures for storm water management and soil erosion mitigation across the site has been developed from the ESIA. To manage grey and black water during construction, RSK will build a septic tank on site. The resulting waste sludge will be managed in line with the WWMP and Ghanaian legal requirements.

During operations, effluent will mainly be generated from site sanitation facilities. Other sources of wastewater will include the food canteen, medical clinic and stormwater. To effectively manage the wastewater and effluent, RSK will install a wastewater treatment facility on site (WWTF), where effluent will be treated and recycled (if needed) into dedicated pipes for use at selected areas or discharged once they meet the regulated quality requirements. RSK will provide documented evidence that the design of WWTF meets WBG/IFC EHS general Guidelines or Ghanaian regulations, whichever is stringent, before discharge of treated effluent to the environment. (ESAP 10).

Hazardous Materials Management:

The hazardous materials at the project construction phase will mainly comprise extracted vehicular engine parts, oils and grease, oil-contaminated cloths, paper and other materials and concrete dust. These will be managed as provided for in the construction phase Waste Management Plan. During RSK Plant operations, key hazardous materials include oil or grease-contaminated scrap, diesel and HFO cleaning and containing equipment, metallic dust and oils and grease. The Waste Management Procedures to be developed by RSK will cover all hazardous materials and wastes. No chemical or hazardous substances facing international bans or phase-out will be used in the operations.

  Community Health and Safety:

Infrastructure and Equipment Design and Safety: The steel milling equipment have been designed to reduce possible impacts to the community as possible.

To reduce traffic-related impacts, RSK conducted traffic studies and is holding engagements with the government highways authority towards redesigning the Kumasi highways to allow an extra lane for traffic related to the project. This will mitigate potential accidents and road related incidents.

Community Exposure to Disease:

The neighboring land-use consists of farmland with Ohene-Nkwata as the nearest households at 1.3km from the plant site. RSK will implement the Environmental and Social Management Plan, Waste Management Plan and Construction OHS Plan during the construction phase of the project, to ensure community (especially the households already identified at 1.3 Km from the site) exposure to dust, noise and contaminated wastes or wastewaters, or other material from the site is minimized. During operations, the effective management of the E&S Management System and related procedures will limit risks of disease to the public from wastes and effluents, emissions, traffic and fire or other emergency situations.

Security Personnel:

RSK will hire unarmed security guards from a reputable third-party contractor, for access control and emergency response. In addition, RSK will assess security related risks and develop Security Management Procedures into the EPRP The EPRP will include security staff-community engagement protocols.

  The project’s stakeholder engagement process started during the land acquisition process in 2019 and continued during the project ESIA studies, where a series of consultations and engagement with the previous occupiers of the plant site, Ohene-Nkwata settlement representatives, government agencies & departments, and non-governmental entities were held. Currently, the only formal documentation of stakeholder engagement activities undertaken are from the ESIA studies.

During project operations, RSK will develop a Stakeholder Engagement Plan (as part of the ESMS), a grievance redress mechanism and an external communications procedure to guide the systematic identification, mapping and engagement of all key stakeholders.

Contact Person: Majd I. Hawwari, PhD.

Company Name: Rider Iron and Steel Ghana Limited

Email: majd.h@ridersteelghana.com

Phone: +233 200 656 760