PS5: Land Acquisition and Involuntary Resettlement is not triggered as the land used for the Project is being leased from the National Ports Authority with no encumbrances. PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources is not triggered given the Plant is located on a modified habitat with no ecologically sensitive flora or fauna. Should the jetty be rehabilitated, the applicability of this Performance Standard will be considered at the time. PS7: Indigenous Peoples is not applicable as no Indigenous Peoples have been identified within the Project’s operational footprint and environs. PS8: Cultural Heritage is not applicable as there are no associated impacts because of the Project

 This is a Category B project according to IFC’s Environmental and Social Sustainability Policy. Based on information reviewed by IFC, the investment will have limited adverse environmental and social risks and impacts that are few in number and site-specific with construction impacts mainly being short term and not significant. Operational impacts are expected to be generally 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 and include, amongst other, national laws and regulations, the World Bank Group (WBG) General Environment, Health and Safety (EHS) General Guidelines and the sector specific EHS Guidelines for Cement and Lime Manufacturing.

The key E&S issues associated with the Project include; (a) adequate E&S assessment of the operational phase impacts; (b) adequacy of Fouta Cement’s E&S management systems (ESMS)  manage Project related E&S risks and impacts; (c) assurance of fair, safe and healthy working conditions for employees and contract workers in line with IFC PS2 and legal requirements (including gender based violence) during operation; (d) management of air emissions, noise, waste and wastewater in line with the WBG EHS Guidelines; (e) community safety and health management, especially related to transportation; and (f) stakeholder engagement.

 Environmental and Social Assessment

Fouta Cement conducted an ESIA for the Project in October 2019 and obtained an EIA license from the Liberia Environment Protection Agency (EPA). The ESIA was then revised in April 2021 to update project information and detail in anticipation of IFC’s involvement in the Project. Since construction has significantly progressed and the Project is now nearing completion, IFC’s review of the ESIA focused primarily on the operational phase related risks, though the remaining construction activities were also considered when reviewing the assessment.

As noted, the Company is evaluating the feasibility of rehabilitating an existing jetty located some 1 km from the Project site to receive clinker in future. Once the decision is made to proceed with this activity, an ESIA will be completed for this activity in compliance with IFC PS requirements and all the requisite EPA licenses obtained prior to commencement of works (ESAP #1a). In doing so, the ESIA terms of reference will be agreed with the IFC prior to the assessment commencing and the ESIA report reviewed and agreed to by IFC before being finalized.  Thereafter, the Company will agree with IFC on the ESIA recommendation to be implemented and the associated timing. As similar approach will also be applied to activities associated with connecting the Project to the national grid (ESAP #1b).

Environment and Social Management System and Management Programs.

Fouta Cement has developed an environment and social policy, a health and safety policy and an environment and social management system manual and a set of supporting procedures (on health and safety, labor, construction contractor E&S management, traffic, emergency response, hazardous materials, and waste management). Although the policy commitments are comprehensive and cover the expected E&S risk aspects of the business, the ESMS manual and supporting procedures were focused primarily on the construction phase activities. Thus, they need to be upgraded to adequately address the scope of E&S risks and impacts associated with the operational phase of the Project. Fouta Cement will therefore upgrade the ESMS Manual to adequately address operation-phase E&S risks of the Project  and develop supporting plans and procedures focused on the following; i) occupational health and safety (OHS) ; ii) environmental risk management (to cover water, solid waste and wastewater, hazardous materials management); iii) air quality management and monitoring, noise monitoring and water quality monitoring iv) traffic and transportation ; v) emergency preparedness and response; vi) stakeholder engagement; vii) security management; viii) contractor E&S management; ix) supplier E&S screening and monitoring; and x) monitoring and review (ESAP #2).

Fouta Cement is still in the process of developing their management team. Fouta Cement will recruit a suitably qualified and experienced EHS Manager as well as an EHS Officer. The EHS Manager will have a direct reporting line to the Managing Director (ESAP #3). The Company will also form an EHS committee that will meet regularly and comprise of worker representatives and management, the EHS Manager, Human Resources Manager and a designate of the Managing Director, to oversee day-to-day operational E&S risk management and related activities.

Emergency Preparedness and Response

The Plant is located adjacent to sensitive activities e.g., consumer goods warehouse and in proximity to the communities, although they are not adjacent.  The main potential emergencies in the operation of the Project include fire and explosions, equipment use/vehicle accidents, chemical spills, civil unrest, medical/health emergencies and natural disasters.  The ESMS Manual provides for an overview of the emergency preparedness and response process during the construction phase. Going forward, this will be enhanced to be a comprehensive Plant Emergency Preparedness and Response Plan and include provisions on: emergency risk identification, internal and external parties at risk, designated responses in respective emergency situations, resource and equipment allocation, personnel responsibilities, internal and external communication, collaboration and training protocols, requirements for mock drills and a site emergency layout map. The Plan will be communicated to all the workers and reviewed periodically to address any emerging needs (refer ESAP#2).

Monitoring and Review

The updated Fouta Cement ESMS Manual will provide for specific EHS performance indicators and reporting requirements to senior management. The ESMS will have provisions for periodic review to sustain or improve its effectiveness in addressing the E&S risks in the business.

 During the ongoing construction phase, the project contractor employed 100 workers comprising 95 males and 5 females. In the operation phase of the Project, Fouta will employ at least 250 workers, most of them as direct staff. It is expected that some contractors will be engaged for various activities during the operational period.

Human Resources Policies and Procedures.

Fouta Corporation has an Employee Handbook which acts as the human resources policy and procedure document. The Handbook provides staff with information about working conditions, employee benefits, and some of the policies affecting their employment. All staff members are required to read, understand, and comply with all provisions of the Handbook that describes their responsibilities as employees and outlines the programs developed by Fouta Corporation to benefit the employees. The Handbook provides for medical benefit as well as holidays and bereavement leave to employees and includes an anti-harassment policy, disciplinary and termination procedures and rights for workers to organize and joint unions in alignment with national legislation. The working hours are clearly indicated in the Handbook for both full-time and part-time staff. All employees are entitled to annual leave. All staff are entitled to sick leave according to national law. Fouta Cement will review the Leave Policy to clearly indicate the availability of maternity leave and that this leave is in addition to the annual leave provisions.

Fouta Cement will adopt the Handbook and update it as applicable to the Project by developing and implementing a policy on safeguarding against child and forced labor (ESAP #4).

Grievance Mechanism.

The Handbook provides a summary of the grievance mechanism. The Handbook notes that if a worker raises a grievance, priority should be given to satisfactory resolution of such grievances by the worker’s immediate line manager to the extent possible. The grievance mechanism will be improved to align with PS 2 requirements by including provisions for grievance documentation at all stages, options for grievance escalation beyond line managers, clearly detailed feedback timelines during the grievance process, and options for anonymous grievances (ESAP #5a).

The Company will also develop a Sexual Harassment Policy with a clear definition of the terms, scope of applicability and the related grievance redress mechanism that applies in such an instance. The grievance process will clearly define documentation requirements at all stages of the grievance management process and detailed feedback timelines for grievance processing including options for anonymous grievances (ESAP #5b).

The above will be included in the Employee Handbook and communicated to all employees (ESAP #5a & 5b).

Occupational Health and Safety (OHS)

The current Fouta Cement health and safety plan mainly focuses on construction phase OHS issues, details the organizational roles and responsibilities in relation to OHS management as well as a general description of some of the anticipated OHS risks in the Project’s operational phase.  The new OHS plan to be developed under ESAP #2 will be enhanced so as to cover the following, at a minimum; i) local regulatory and compliance requirements relevant to the operations and overarching objectives and targets in terms of OHS management; ii) a detailed description of the OHS risks in operation of the Project based on risk screening for all activities including actual tasks to be undertaken and the associated mitigation measures for such risks including personal protective equipment (PPE) requirements; iii) worker responsibilities including in relation to the supporting procedures and work instruction; iv) OHS training requirements; v) audit and reporting requirements; and finally; vi) all the required procedures and work instruction in support of executing the OHS Plan.

No significant incidents or accidents were reported from the construction activities.

Workers Engaged by Third Parties and Supply Chain.

The Company engaged an EPC contractor for the design and construction of the project. The contractor has employed over 100 workers, most from local communities. During the operation phase of the Project, the Company will hire direct workers for various operational tasks while also engaging contractors for specific tasks such as raw material transportation, periodic maintenance activities etc. To address potential related E&S risks, the Company will develop and implement a contractor E&S management procedure that will include OHS and labor requirements and monitoring and audit specifications, reporting requirements, in line with PS 2 requirements. In addition, contracts with contractors will include the requirement for compliance with the contractor E&S management procedure.

The main supply chain materials will comprise clinker, gypsum, and limestone to be sourced from established suppliers in Turkey. Fouta Cement will develop a supplier E&S screening and monitoring procedure in compliance with PS 2 requirements to be administered for suppliers, notably those for raw materials and this will include periodic monitoring of supplier OHS and labor practices. These two procedures are included in ESAP #2 requirements above.

 Energy Consumption. The Project will be powered by a set of eleven 600 kVA diesel generators. All eleven generators will be required during plant startup and thereafter 5/6 generators will be required to operate the plant.  The annual energy consumption is estimated to be 9,600 MWh. This estimated energy consumption translates to 46kWh/ton of cement which is within the benchmark range provided in the WBG EHS Guidelines for Cement and Lime Manufacturing. As noted, the company plans to connect to the grid electricity from 2024 onwards. Clinker grinding is via a ball mill.

Air Emissions. Baseline ambient air quality (SOx, NOx, PM10 and PM2.5) monitoring was undertaken as part of the ESIA at the Project site and each of the four commercial installations adjacent to the site. The baseline concentrations of these parameters are aligned with that defined in the WBG General EHS Guidelines. 

During Project operation fugitive emissions from materials storage and transfer, the grinding process, as well as clinker transportation from the Port to the site will contribute to Project related air emissions. In addition, there are point source emissions from the generators. The plant design has included the installation of dust collectors at various material transfer points and dedusting equipment with the storage of clinker, gypsum, and cement in closed sheds with hard standing surfaces.  Clinker will be transferred from vessels via grabbers located on cranes and then loaded onto trucks. Fouta will ensure trucks contracted for clinker transportation are covered to mitigate against dust during truck movement.

Manufacturer emission specifications for the generators are within WBG General EHS Guideline values. As part of the Project ESIA, an air quality modeling for point source and fugitive emission was undertaken and the findings indicate that ambient air quality (PM, SO2 and NOX) is complaint with that defined in WBG General EHS Guidelines (highest concentrations for PM10 for the 24 hr averaging period being 5.05 µg/m3 and 4.28 µg/m3 for PM2.5). However, given potential inconsistencies with the methodology applied to the air quality modelling as identified by IFC, the Company will engage a suitably qualified specialist to conduct a new air dispersion modelling exercise for the Project to confirm the findings defined above. Based on the associated findings the company will agree with IFC on additional mitigation measures if deemed applicable and an ambient air quality monitoring program. (ESAP #6).

Greenhouse gas (GHG) emission from the Project is estimated at 10,132 CO2 eq annually from logistics operations and diesel fuel to be consumed at the Project and hence not significant per the General WBG EHS Guidelines. Due to the lower weight associated with importing (transporting) clinker as opposed to cement, the Project will result in a GHG emission reduction of 3,172 CO2 eq annually.

Noise: From the baseline noise monitoring conducted as part of the ESIA, the current noise levels are within the WBG EHS Guideline requirements for industrial/commercial areas. To confirm Project related noise impacts are aligned with the guideline requirements referenced, the Company will undertake noise modeling prior to operations commencing and define mitigation measures if applicable. In addition, a noise monitoring program will be implemented to ensure ongoing compliance with the WBG General EHS Guidelines. The Company will submit monitoring results to IFC every three months for the first year of operation (ESAP #7).

Water Consumption. The Project is expected to consume some 35,000 cubic meters of water annually for general use such as sanitary, office and equipment cleaning, and irrigation purposes. Water will be sourced from a borehole, already drilled within the site. This will be supplemented by rainwater (to be collected within the site) as appropriate. There is no notable risk to other water users from this consumption due to the distance from the communities and the generally high water table in the area for most of the year. Drinking water at the offices will be supplied separately by contracted vendors.

Solid Waste Management / Wastewater Treatment. The main solid wastes to be generated by the Project include wooden pallets, scrap metal, e-waste, paper, waste from material/equipment packaging materials, vehicle and equipment parts, and raw material residues from milling operations. These wastes will be reused/recycled as appropriate and where this cannot be achieved, disposal will be via contracted companies. These waste management measures, including measures on waste minimization, segregation and quantification will be included in the Environmental Risk Management Procedure per ESAP#2.

Sewerage will be collected in an underground septic tank which will be emptied regularly by a contracted waste transporting company. Each building will be connected via the sewerage system to the septic tank. The site has been designed with a concrete drainage structure around key installations to collect and discharge stormwater from the premises. The stormwater drains will have oil / grit separation equipment to retain oils, grease, and grit (dust) at various points prior to discharge into the neighboring open land (also part of the Company’s leased land). Regular water quality tests will be undertaken at discharge points to confirm compliance with local regulatory requirements, as applicable. These measures will be documented in the Environmental Risk Management Procedure.  

The main hazardous materials in the project will be diesel for power generation, laboratory materials, engine oils, and lubricants. Diesel will be stored in two 100,000 litre above-ground storage tanks within the site. These tanks will be in a bunded area with sufficient containment capacity for spills. The Environment Risk Management Procedure (ESAP #2) will provide adequate measures for handling and transportation of hazardous materials in the operations, including requirements for adequate bunding and secondary containment of hazardous materials, and contracting of a licensed waste management company for the collection of hazardous wastes e.g. used oils.

 As noted, the company will retain significant volume of diesel fuel on site. To mitigate against life and fires risk, Fouta Cement will ensure that; i) the tank is designed, fabricated, and installed according to the appropriate industry standard and code; ii) location of the tanks maintains the minimum separation distances from all sides to other site property, public ways, and occupied buildings on the same site based on the US National Fire Protection Association (NFPA) Code 30: Flammable and Combustible Liquids Code; ii) installation of manual/fixed fire control equipment is done as per applicable fire code; and iii) there is a written bulk delivery standard operating procedure covering all aspects of diesel transportation and delivery (ESAP #8).

Clinker will be shipped to the Port of Monrovia, offloaded at the main Port harbor via existing gantry cranes (grabbers) and then transported via contracted trucks to the Project site. The transportation of clinker to the Project will all occur within the confines of the Port area and it is anticipated that some 60 trucks will be used to offload the clinker. Cement from the Project will be collected by customers directly and thus the Company will have no vehicles of their own involved this capacity. As per ESAP #2 the Company will develop and implement a Traffic and Transportation Procedure to address related risks (mainly on road safety, limitation of dust, maintenance of road quality in sections where Fouta Cement are responsible) which will include requirements for vehicle staging. 

The Project is situated in a secure Libera Ports Authority industrial zone with adequate security. The Project will, however, employ unarmed security to safeguard the premises. A Security Management Procedure will be developed as part of the ESMS (ESAP #2).

The plant is located within a controlled industrial zone and no risks related to population influx are anticipated as a result.