IFC’s appraisal considered the environmental and social management planning process and documentation for the Project and gaps, if any, between these and IFC’s requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and (if applicable) in an agreed Environmental and Social Action Plan (ESAP). Through implementation of these measures, the Project is expected to be designed and operated in accordance with Performance Standards objectives.
PS1: Assessment and Management of Environmental and Social Risks and Impacts
E&S policy and management systems: Yara has a Quality, Safety, Security and Environment (QSSE) Policy which includes its commitment to the environment, occupational health and safety (OHS) , compliance with the national laws and stakeholder engagement. This policy applies to all its operations and encourages its stakeholder to have similar system in place. The company has an integrated E&S management system, which is generally in line with IFC PSs requirements (considering the level of risks) and that is certified according to ISO 9001:2015 international standard for quality management system; ISO 14001: 2015 international standards for environment management systems and ISO 450001:2018 international standard for OHS management system, at the time of the appraisal. Relevant procedure for service station operations e.g. on spill control, oil trap cleaning and maintenance, eco driving and emergency response have been documented. Any additional procedures required have been included in the ESAP as described in the relevant sub-sections.
Identification of the E&S risks and impacts: The company identifies E&S risks and impacts of a station during the land purchase phase through environmental and social risk assessment process that includes compliance with permitting requirements. For operations, the company identifies and manages E&S risks and impacts associated with its operations through compliance with applicable national laws and regulation; E&S regulatory permits; OHS risk assessments; internal and external E&S audits.
E&S Organization: The E&S team of the company is managed by head of Quality, Safety, and Environment (QSE), who is supported by a Health Safety and Environment officer, a QSE assistant and network inspectors. The head of QSE reports directly to managing director. At the level of the stations, E&S is the responsibility of the station manager and the station supervisor in-charge.
Emergency response plan: Yara has an Emergency Preparedness and Response Plan (EPRP) which applies to all of its operations, including the fuel stations. The EPRP details the roles and responsibilities for implementation of the plan, the major emergencies such as fire, oil spill, tanker accidents, security incidents among other. the EPRP describes procedures to be followed in each situation, the resources required such as spill kits and extinguishers; drills to be carried out; the trainings to be given to staffs and communication with external stakeholders.
Monitoring and review: As part of the EHS management, the company monitors key performance indicators (KPIs) such as accidents, loss time injury (LTI), hydrocarbon spills, fire incidents, road accidents, near misses, security incidents, trainings and safety committees. Yara will additionally include energy consumption and solid and hazardous wastes generated among its KPIs and ensure appropriate benchmark indicators are established for all OHS-related performance indicators as part of ESAP#1.
PS2: Labor and Working Conditions
At the time of the appraisal, the company employed about 330 direct full-time employees of which 15% are females.
Human Resource policies and working conditions: Yara has a documented Human Resource (HR) internal regulation that is consistent with the national labor regulations and applies to all direct employees and indirect employees. Each worker receives a written contract that describes the working conditions and terms of employment, and a copy of the HR manual is affixed at each work location. The HR manual covers various operational matters, however, it does not include policies on non-discrimination, freedom of association, prevention of child labor and forced labor or a grievance mechanism. As per the ESAP(#2), Yara will include these commitments into its HR manual, in line with PS2 requirements and ensure their communication to all employees.
Grievance mechanism: Yara has an undocumented grievance process, where grievances are collected through dialogue boxes and investigated by the HR team. Going forward, the company will document the grievance mechanism procedure that will include response and handing timelines and tracking; recording all grievances; and ensure anonymity and confidentially is maintained throughout the whole process in accordance with PS2 (ESAP#2).
Freedom of association: The national law recognizes workers’ rights to form and to join workers’ organizations of their choosing and the company has committed to comply with national law. As per the ESAP(#2), Yara will update its HR manual to include commitment to the right to freedom of association, collective bargaining and workers' right to form and join workers organization.
Prevention of child and forced labor: As mentioned above, commitments to prohibiting engagement of child, forced or bonded labor practices consistent with national labor laws and IFC PS2 requirements will also be added to the HR manual.
Occupational, health and safety: The company has formulated its health and safety commitment under its QSSE policy, in which it commits to a safe working environment. Yara has established processes to ensure safety such as work permits for hazardous works, job safety analysis, procedures for managing risk related to chemical, electrical, ergonomics, security, oil spill among other. Yara has established an OHS committee, consisting of the E&S team members, heads of each unit (operation, logistics etc.), an occupational doctor and workers’ representatives. The committee meets in quarterly basis to discuss OSH issues reported, any accidents and follow-up of pending actions. Annual OHS risk assessments are also undertaken which is used to generate a risk register.
The company identified road accidents as a major risk and has developed a dedicated procedure for recruitment of drivers. This procedure details the skills and evaluation for each driver prior to recruitment. Emergencies related to road accidents are accounted for in the EPRP as well. The company also has a zero-tolerance policy for alcohol and drugs at the workplace. The company carries out regular training for first aid, use of fire extinguisher, risk analysis, awareness of employer and employee legal obligation for health and safety and bi-monthly toolbox talks of workplace health and safety. As part of ESAP#3, the company will develop a transportation and traffic safety management plan that will integrate the existing procedure and further include vehicle maintenance and inspection practices, safe driving practices such as no night driving, and defensive driving training requirements.
Third-party workers: Construction of the new fuel stations will be carried out by contractors and Yara estimated that around 20 additional workers will be required for each station. Majority of the workers will be sourced locally and if required for specific technical skill workers from other regions will be brought on site. These workers will be housed in apartments nearby the construction site. As per the ESAP(#4), the company will document specific E&S requirements aligned with national law and IFC PSs requirements and include the same in the contracts signed with the contractors. In addition, the company will ensure there is adequate oversight for the contractors to ensure compliance with the E&S requirements as to be applied.
PS3: Resource Efficiency and Pollution Prevention
Power supply and resource efficiency: The fuel station operation primarily involves the retail sale of fuel and does not result in significant quantities of wastes and emissions. Electricity is sourced from the national grid for all stations. Diesel-powered generators are installed and used for back-up purposes during power outage, thus, there are no major air emissions / pollution from the company’s operations. The company is considering installation of solar panel to complement its electricity demand, which will part of the IFC advisory program.
Water and wastewater: Water for most of the stations will be sourced from on-site boreholes. The only wastewater generated at the company fuel stations is from sanitation and cleaning. Sanitary wastewater is collected in septic tank and removed by licenced contractor for further treatment, The wastewater from cleaning and stormwater is treated through an oil interceptor prior to discharge from site. Oil and grease traps are provided in the existing service stations and similarly, for the stormwater generated, the company will provide oil and grease traps in all new service stations as well.
Waste and hazardous material management: Yara stations generate mostly paper, plastic, used oil filters and used oil as wastes. Although the company implement a segregation at source for each type of waste, it does not quantify the amount generated. Yara will develop site specific Waste and Hazardous Material Management Procedure as per ESAP#5. This procedure will include a system of appropriate sorting, handling, storage and disposal, which are consistent with applicable legal requirements.
PS4: Community Health, Safety and Security
Community impacts due to construction: The fuel stations are located along the urban and rural roads, and some are adjacent to the communities. Since the project is a greenfield requiring construction works, temporary impact on local community is expected. These impacts will be identified, and mitigation will be included in the E&S requirements to be included in the construction contracts.
Yara provides required fire safety systems at its service stations including smoke detection system, fire alarm and fire extinguishers. Workers at the stations are trained on fire fighting.
Underground Storage Tanks (USTs): The USTs to be provided at the fuel retail stations will have a concrete secondary containment and leak tested during commissioning. The manufacturer of the UST provides a certificate and it is also reviewed by a government authority. Also, a leak detection system will provided for all tanks. As per the ESAP (#6), 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.
All of Yara’s bulk fuel tankers are equipped with an onboard computer which monitors data such as speed, trip duration, dangerous bend and braking. Anything abnormal is reported and necessary measures are taken.
Security forces: To manage security across its operations, Yara will develop a Security Management Plan consistent with the requirements of Voluntary Principles on Security and Human Rights and will communicate this plan to its security service providers (ESAP#7). The Security Management Plan will include: (i) a security risk assessment to determine the risks associated with its security arrangements to those within and outside its facilities and to determine hiring, equipping, and training needs in accordance to PS4, (ii) criteria for hiring, equipping, and training of security personnel (human rights issues, proper use of force, and appropriate conduct towards workers and other stakeholders), (iii) auditing procedures of the security service provider.
