This is a Category B project according to IFC's Policy on Environment and Social Sustainability (2012). Based on information reviewed by IFC, the proposed project will have limited adverse environmental and social (E&S) impacts that are few, site specific, largely reversible, and readily addressed through existing mitigation measures and good international industry practices (GIIP). 

Identification of Risks and Impacts: In accordance with applicable legislation, Environmental Impact Assessments (EIAs) have been completed for the new propane storage facility and the fuel retail stations. For the proposed Propane storage, the EIA identified potential noise, air pollution and traffic impacts during construction and fire and explosion and gas leaks during operation. The EIAs include Environmental and Social Management Plans (ESMPs) covering these potential impacts. Required environmental approvals have been obtained from the authorities based on these EIAs. Zener will ensure implementation of ESMPs for all these facilities.

As part of the emergency response planning, Zener has completed a basic risk assessment for the operational Butane storage and filling operations which also estimated probability and significance of impacts (thermal and pressure) due to boiling liquid expanding vapor explosion (BLEVE) of the bullet tanks. The expected zone with thermal and pressure effects leading to significant damage to structures and fatalities has been identified in this assessment and control measures identified.

Considering that with addition of the Propane storage, the cumulative significance of risks and impact zones would change, the company has also completed hazard operability (HAZOP) studies and a Quantitative Risk Assessment (QRA) to assess the level of safety risks from both the existing Butane and proposed Propane storage and pipeline operations. The QRA has been completed in line with good international industry practice and includes hazard identification, frequency assessment, consequences assessment and risk assessment in the form of iso-risk contours/impact zones and significance of the risks (e.g., fatality, serious injury or damage). The QRA concludes that the overall risk level to both workers within the plant and community are within the tolerability limit i.e., as low as reasonably practicable (ALARP) region. However, the QRA does identify a scenario that generates a risk level above the ALARP limit which is in the scenario of a flash fire.  Therefore, as per the ESAP (#1), the company will need to develop and implement an off-site emergency plan as well (in addition to on-site plans discussed below). The plans will need to be prepared and implemented in coordination with the neighbouring facilities and local authorities to deal with any major event.

Also, as per ESAP(#1) and in line with the QRA recommendations, the company will need to implement (a) risk-based inspection, testing and maintenance strategy for all installed safety critical safeguards (active fire protection systems, shutdown valves, etc.) to ensure their operational reliability meets required performance standards in order to avoid operational delays or failure in mitigating the risks associated with major accident events; (b) provide training for operators on prevention and response to major fire and explosion events; and (c) develop an on-site  emergency response plan.  The off and on site emergency plans will have a similar scope to the similar plans as referred to below in relation to the service stations. For the project i.e., Propane storage operations and fuel retail stations, environmental and occupational, health and safety risk (OHS) assessment have not been completed. As per the ESAP (#2), environmental and OHS risk assessments will be competed for all operations covered in the project and required preventive and mitigation measures will be implemented at all facilities within agreed timelines based on corrective actions to be defined in the assessment.

E&S Policy, Management Systems and Programs: Zener has a documented Health, Safety, Security and Environment (HSSE) Policy with commitments to zero-work related incidents, non-discrimination, full compliance with its internal and legal requirements across its operations, provision of adequate training and collaboration with clients and suppliers on HSSE issues.

To implement the policies, the company has prepared a HSSE manual for its existing operations i.e., the Butane storage and filling plant. The manual describes HSSE roles and responsibilities, communication, participation and consultation mechanism, prevention and control measures, prevention of emergencies, verification, and management review. Also, operating procedures have been developed for the filling of cylinders and loading of tankers. Further, a work permit system and accident-incident investigation system has been implemented. Weekly toolbox talks are conducted which cover basic awareness on HSSE issues. During appraisal discussions, Zener has mentioned that the company is working to develop additional documents to implement environmental and OHS management systems as per ISO 14001 and ISO 45001 requirements for its Butane storage and filling operations by 2023. Based on appraisal observations, the approach described in the manual is not fully implemented at the Butane storage and documentation on implementation of the manual allied to verification of implementation needs significant improvement. As per the ESAP#2, based on the environmental and OHS risk assessments, specific E&S procedures will be developed and implemented for operations under the project which will include: (a) life and fire safety (LFS) management programs for all facilities; (b) emergency preparedness and response; (c) pollution prevention processes including chemical management, solid and hazardous waste management plans (as discussed under PS3); (e) tanker loading and unloading processes for Propane and Butane and storage, and that related to the fuel retail stations; (f) OHS management programs commensurate to the risk posed by the activities (as discussed under PS2); (g) community grievance mechanism; (h) training plans with roles and responsibilities for its employees, seasonal and contract workers; (i) monitoring and reporting framework including regular audits/inspections, key E&S performance indicators for effectiveness and compliance status of all operations and regular environmental and OHS monitoring; and (j) periodic review by senior management/board.

As set forth in the ESAP (#2), Zener will engage a qualified consultant (acceptable to IFC) for supporting development of these E&S procedures. The consultant will complete a risk assessment for all its operations against IFC PSs requirements and good international industry practice for the sector and prepare a corrective action plan with timelines, which will be shared with IFC. Zener will ensure implementation of the corrective action plans as well as E&S procedures within agreed timelines. Also, as per the ESAP, the company will prepare guidelines and training for its distributors and transporters on safe transportation and storage of gases (Propane) and Butane cylinders, as applicable.  

E&S Organization Capacity: Zener currently has a team of two people responsible for safety management i.e., a Safety Manager and an assistant, who are based at the Butane storage facility. As Zener has now an expanded operational footprint, the E&S organizational structure needs to be strengthened. As per the ESAP (#3), Zener will appoint an appropriately qualified E&S professional(s)for E&S management of the fuel retail stations.

Also, as part of implementation of procedures, Zener will develop and implement a structured E&S training curriculum based on regulatory requirements, findings of the risk assessments (EIAs, QRA, environmental and OHS risks assessments) and E&S performance (e.g., OHS statistics, internal audits and inspections). The training will cover employees, seasonal and contract workers.

Emergency Response Planning: As mentioned above, Zener has completed a basic risk assessment and QRA for the operational Butane storage and filling operations including the probability and significance of impacts (thermal and pressure) due to a BLEVE.  Expected impact zones and control measures have also been identified. The butane storage terminal has fire hydrants, water monitors, sprinklers (on the bullet tanks), fire extinguishers, dedicated fire water storage and pumping system. Additionally, Butane leakage sensors and alarm system have been installed.  The internal operational plan has documented responsibilities, instructions, and facilities for preventing and managing disasters and emergencies. All tankers to be loaded at the facility are connected to the earthing system before loading. Based on appraisal observations, emergency response drills have not been conducted this year. Also, maintenance of fire safety systems needs to be strengthened to ensure that systems are always kept operational, and tankers should be fitted with a flame arrestor before loading.

The operational fuel retail stations were noted to have been provided with fire extinguishers.

Going forward, as per the ESAP (#4), the company will; (a) develop emergency response plans for the fuel retail stations. The plans should consider all potential emergencies (e.g., fire, fuel/gas leakage, explosion, spills, medical emergencies) and describe detailed roles and responsibilities for relevant personnel (as well as their back-up), training needs and their frequencies. Regular classroom training and mock drills shall be conducted for all operations. Coordination with neighbouring facilities and local authorities that may be potentially impacted will also have to be described in the offsite emergency response plans where applicable.

Further, as per the ESAP(#4), the company will ensure that the proposed Propane storage and fuel retail stations have appropriate earthing facilities and flame arrestors for the tankers. 

Monitoring and Review: Based on the appraisal observations, accident-incidents records are maintained at the Butane storage and filling. Though internal inspections are conducted, they are not documented. No environmental monitoring is being conducted at any of the facilities, Therefore, as set forth in the ESAP(#2), Zener will develop a monitoring and reporting framework at both corporate and facilities levels. The monitoring and reporting framework will describe: (a) key performance indicators (KPIs) on E&S compliance and performance for all operations (e.g., air emissions, OHS data, waste generation and disposal, spills, mock drills and training, accidents and incidents); (b) monitoring processes (e.g., inspections, internal/external audits); (c) reporting requirements in specific formats; and (d) process of regular management review for all operations by senior management. The framework will specify KPIs to be monitored at the facilities, monitoring frequencies, type of monitoring and the definition of thresholds that signal the need for corrective actions. In addition to applicable legal requirements, the monitoring thresholds will include thresholds specified in the WBG EHS Guidelines (both general as well as sector specific).

As of December 2021, 150 people are working at the Butane storage and filling operations including 50 employees and 91 contract workers (hired through a third party contractor). Also, seasonal employees are hired in the peak season directly based on daily wages (paid weekly). For Propane storage, additional 30employees and 50 contract workers are expected to be hired.

Currently, Zener has 5 women employees, but it intends to increase the women workforce to 25% by, for example, having women employees for quality control and finishing work.

HR policies, procedures, working conditions and terms of employment: Zener has a Human Resource (HR) manual which describes operational HR procedures for workforce planning, recruitment, leave, training needs analysis, disciplinary actions, redundancy and retirement. In addition to its own HR manual, Zener abides to the collective agreement for the petroleum industry in Togo (of 2013), which describes classes of employees, salary scales, promotion criteria, working hours and benefits to employees. Zener has a documented internal rules handbook which is given to all employees which describes HR policies and basic OHS guidelines for employees. All employees are provided with a written contract detailing the date of employment, salary, job description, leave allocation. Reference to the HR manual is also made in the contract.

All employees work for 40 hours (of 5 days) per week and hours worked in exceedance are considered overtime, which is compensated at a premium rate established by the national labor laws. The retail fuel stations are expected to operate 24 hours/day, with 3 staff during the day and 1 staff staying overnight. Given that Zener will be installing self-service dispensing point with a card payment system, there will continue to be limited staff required a night. Wages paid to the employee and seasonal workers are above the national minimum wage. The same HR policies and procedures will be extended to the Propane storage and fuel retail stations, as applicable. As per the ESAP (#5), the company will develop and implement specific HR policies for these operations and communicate HR policies (e.g., through the internal rules handbook) to all employees.

Also, currently, there are no place for workers to rest during the break and have meals. As pe the ESAP(#4), the company will provide such a facility at the Butane / Propane storage facility.

Currently, the HR function is under the Finance and Administration departments. Zener is planning to have a separate HR department. As per ESAP (#5), Zener will ensure appointment of suitable and qualified HR professionals to oversee HR function for all operations and ensure compliance with IFC PS2 and applicable legal requirements.

Freedom of Association: The collective agreement for the petroleum industry and national law establishes the right of employees and workers for the freedom of association. Accordingly, Zener has four employee representatives who are elected as employee representatives for the petroleum sector union to represent all employees. Similarly, employees for all new operations will be covered under the collective agreement (since it is the same industry).

Non-discrimination: As per the collective agreement, Zener has committed to ensure that there is no distinction, exclusion or preference based on race, color, sex, political or philosophical opinions, religious beliefs, national origin or social origin.

Retrenchment: The company has not carried out any retrenchment in recent years nor intends to do so in the foreseeable future considering its expansion plan. If it were to be required, the collective agreement explicitly states that any retrenchment will follow labor law. The company will have to follow PS2 requirements in this regard as well.

Grievance Mechanism: Though the company has procedures of managing disciplinary actions, currently, there is no documented grievance mechanism in place. As set forth in ESAP#5, Zener will develop and implement a grievance mechanism which will include clear procedures to receive, register, and address grievances.  This procedure will apply to employees, seasonal and contract workers alike and allow them to submit grievances anonymously and have separate grievance redressal process for any sexual harassment related grievances/complaints. Regular communication and training will be conducted on the grievance mechanism at all operations.

Protecting the Workforce: Considering the operations, Zener does not recruit anyone younger than 18 years of age. No instances of child labor or forced labor were noted at any of the facilities, however, the company does not have a specific policy on child labor or forced labor. As per ESAP(#5), the company will document a specific policy on the same.

Occupational Health and Safety (OHS): As mentioned under PS1, the company has a documented HSSE policy, through which the company commits to compliance with applicable law and continuous improvement. Zener has committed to zero accidents, incidents and damages and to collaboration with suppliers, service providers or sub-contractors. To implement the policies, the company has prepared a HSSE manual for its existing operations. Also, operating procedures have been developed for the filling of cylinders and loading of tankers and work permit system and accident-incident investigation system has been implemented. Weekly toolbox talks are conducted which cover basic awareness on HSSE issues. Safety induction is provided to all employees, seasonal and contract workers. Personal protective equipment (PPE) is provided to all employees, seasonal and contract workers. During the appraisal visit, workers at the Butane storage and filling operations were noted to be using safety helmets and shoes.

Further, as mentioned under PS1, the company needs to complete risk assessment, document and implement procedures for its proposed operations –propane storage and fuel stations. As per the ESAP(#2), the company will develop and implement OHS management programs commensurate to the risk posed by the activities; training plans with roles and responsibilities for its employees, seasonal and contract workers; and a monitoring and reporting framework. The implementation will be supported by regular training and communication covering all employees, seasonal and contract workers.  

Third-party Workers: Contract workers are employed for security and operations at the Butane storage and filling operations. Similarly, contract workers will be employed at the proposed Propane storage. These workers are also covered under the collective agreement for the petroleum industry. Zener signs a contract with the contractors, which includes requirements on provision for working at height, PPE usage, fire safety, excavations, sanctions in case of non-respect of rules and general responsibilities on OHS. All contractors must sign and acknowledge these rules and conditions prior to starting the works. Also, contractors are expected to follow the work permit systems. The HSSE manual also has a requirement for all temporary and contract workers to be covered in the training.

For the installation of Propane tanks and the construction of new service stations, the company will similarly include E&S requirements in the associated contracts contract, to ensure contractors have adequate EHS management systems or where this is not the case, apply the company’s requirements in this regard.  In addition, the company will ensure there is adequate oversight to ensure compliance with the EHS requirements as to be applied.

The Finance Department also receives wage payment records for all contract workers, which are reviewed to ensure required payment. Also, all contract workers are covered with accidental insurance.                                                  

Resource Efficiency: The company has a subsidiary (BLUEN SAS) dedicated to the research, development and deployment of energy solutions based on renewable energy sources.  All fuel retail stations will also be equipped in with solar panels to reduce energy bills. 

Power Supply and Air Emissions: The main source power supply for all operations will be the grid power. Additionally, back-up diesel generator set is be provided for use in case of power breakdowns. No significant source of air emissions is expected at the propane/butane plant and fuel retail stations.

Water Supply and Wastewater Management: The propane storage and filling stations are not expected to have significant use of water. No wastewater is expected to be generated from the Propane storage except domestic wastewater from toilets (treated in the septic tanks). This applies similarly to the fuel retail stations. Stormwater contaminated with oil during rainfall events from loading areas at the Propane storage area and the forecourt area from the service stations will be discharged via oil and grease traps.  

Waste Management: The Propane storage operations are not expected to generate a significant quantity of waste. The fuel retail stations are expected to generate minor quantities of oil containing waste.

As per ESAP(#6), the company will construct a waste storage area at the Propane storage area to ensure all waste, especially hazardous and liquid waste, is stored in covered area(s) with segregation and secondary containment. Also, as mentioned under PS1, the company will develop a waste management plan for all operations which should identify environmentally suitable disposal options for all waste streams.

Hazardous Materials Management: Similar to Butane storage loading, the company will prepare procedures for tanker loading for Propane storage. Also, for fuel retail stations, tanker unloading procedures will be developed and implemented.  Integrity of Propane tanks will be checked by independent experts periodically. Any corrective actions identified based on these integrity checks will be implemented.

Also, catch-pits and oil and grease traps are provided at the fuel filling stations. However, the design of the oil catch-pits and oil and grease traps needs to be improved as the current design does not adequately result in the capture of all potential spills. As per the ESAP (#7), the company will develop a revised design for oil and grease traps for the fuel retail stations, which will capture all potential spills, notably that associated with the forecourt area.

Environmental Monitoring: The company will need to conduct regular environmental monitoring for its operations including ambient air quality monitoring, stack emissions monitoring and ambient noise monitoring to ensure compliance with national standards and WBG EHS Guidelines.

Greenhouse Gas (GHG) Emissions: Considering the operations, the GHG emissions from the project are not expected to be significant.

Off-site Emergency Response: As discussed under PS1 above, the company has completed a basic risk assessment and QRA for the proposal and butane storage facility in line with good international industry practice and this includes hazard identification, frequency assessment, consequence assessment and risk assessment in the form of iso-risk contours/impact zones and significance of the risks (e.g., fatality, serious injury or damage). The QRA concludes that the risk level for both workers within the associated plant and community are within the tolerability limit i.e. as low as reasonably practicable (ALARP) region. However, as noted the QRA also note the only scenario that generates frequency above ALARP is the scenario of flash fire. Therefore, as per the ESAP #1 and as noted above (PS1) the company will develop and implement on and off-site emergency plans. These plans will need to be prepared and implemented in coordination with the neighbouring facilities and local authorities so as to deal with any major event.

Security Management: Unarmed private security guards are employed at all operations.

Traffic Safety: Propane will be distributed through pipelines to the customers. However, some of the Propane will be exported as well through tankers. These tankers generally belong to the customers. Also, filled Butane cylinders LPG from the filling point to the distribution points is via 37 trucks, 4 out of which are owned by Zener and remaining sub-contracted from various contractors. The contractors with experience in petroleum transportation are chosen and the HSSE policy of Zener is included with their contract.

As per the ESAP, the company will develop and implement: (a) a screening system for the tankers before their entry to the Propane storage; (b) safe parking for tankers prior to loading; and (c) training on terminal safety rules, road safety, defensive driving and emergency response procedures for both Zener and contractor drivers.

Underground Storage Tanks (USTs): The USTs to be provided at the fuel retail stations will be double walled and leak tested during commissioning. An automated gauging system will be installed for real-time monitoring of in-tank product inventory.

As per the ESAP (#7), the company will implement a system for daily gauging and monitoring of tank levels to ensure that there are no leaks. Also, integrity of these tanks will be checked by independent experts periodically. Any corrective actions identified based on these integrity checks will be implemented.