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
Environmental and Social Policies. The HSE policies (2022) applying to its poultry farming and processing operations (layers and broiler farms, and slaughterhouse) commit TND to compliance with country-level E&S legal and regulatory requirements. TND will upgrade the draft policies to benchmark all operational E&S performance against IFC PS requirements (ESAP#1).
Identification of Risks and Impacts. TND commissioned an ESIA for Quad Naga operations (layers & broiler farms and slaughterhouse) as required by national environmental and social laws. The ESIA was approved by the Ministry of Environment and Sustainable Development in 2019, with conditions of implementation of the Environmental and Social Management Plans (ESMPs). As part of this project, TND will commission an IFC-compliant ESIA for the proposed feed mill and implement the ESMPs resulting from these assessments for both Quad Naga and Rosso Road sites (ESAP#2). The ESIA reports will be disclosed locally as per national requirements and TND’s Stakeholder Engagement Plan.
Environmental and Social Assessment and Management System. TND developed a corporate Health, Safety, Security, Quality and Environment (HSSQE) management framework comprising of (i) EHS management and planning, (ii) workplace hazard analysis, (iii) risk prevention and control systems, and (iv) health safety and environment training. To adequately manage E&S risks in all operations, TND will update the HSSQE to include all the elements of an E&S management system (ESMS) that will align with IFC PSs and comply with Good International Industry Practices (GIIPs) as per applicable WBG EHS Guidelines. The updated HSSQE will include (i) E&S policy, (ii) procedures for identification of risks and impacts, (iii) management programs and procedures for all operations, (iv) EHS function, (v) emergency preparedness and response plan, (vi) monitoring and reporting procedures, including key performance indicators (KPIs), (vii) Stakeholder Engagement Plan, including an external grievance mechanism, as per PS1 requirements (ESAP#3). As part of the overarching ESMS, TND will develop an E&S risk assessment procedure that describe, in detail, the mechanism by which TND identify, assess, and evaluate E&S risks associated with existing layers facility and proposed greenfield operations. The procedure will be relevant to local, national, and aligned to GIIPs, such as those of the IFC PSs requirements, WBG EHS Guidelines, and Global GAP. The scope of the procedure will include E&S risks associated with the company’s third-party suppliers of maize and soya for the feed mill inputs. The procedure will provide requirements for E&S risk assessment prior to the development of a new greenfield or brownfield project. Given its tenure in poultry production, TND is yet to adopt environmental, OHS, or food safety management programs. However, the company is committed to operate according to GIIPs and sector standards. To achieve this commitment, TND will develop manual of standard operating procedures (SOPs) for each risk identified across its operations, including each class of assets (feed mill, breeder / layer farms, hatcheries, slaughterhouse). TND will also implement an animal welfare management system for all layer/broilers farms and slaughterhouse, as per Global GAP for livestock (ref. ESAP#14).
E&S organizational capacity and competency. TND uses a registered EIA consultant to assess the environmental risks and a maintenance officer for OHS risks management. Going forward, TND will establish a Quality, Heath, Security and Environment (QHSE) department to be headed by a manager reporting to the operations director, and assisted by quality, security, and biosecurity officers. The company will ensure the positions are filled with competent personnel and develop and implement an EHS training plan for the QHSE team and for TND’s workforce at the farms, slaughterhouse, and feed mill, based on regulated ESMPs and workplace risk assessment (ESAP#4).
Emergency preparedness and response plan. TND will assess potential emergencies in all its poultry production and processing operations which could include dust explosions at feed mills, poultry disease break-out at farms, leakage & spillage of fuels at all sites, fires, fatal or serious workplace accident, traffic accident and strike/riots civil unrests and bio-security emergency. This will include the slaughterhouse refrigeration system which will use ammonia. This system will be installed as per https://www.iiar.org/ requirements. Based on assessment results, TND will develop and maintain site specific Emergency Preparedness and Response Plan (EPRP) for the construction or expansion, and operation for each facility which will be applicable to all employees, contractors, and visitors (ESAP#5). As part of EPRP implementation, TND will conduct scheduled emergency drills once a year in all operational facilities and involving local fire brigades. Records of the fire drills will be documented. In addition, internally assigned staff will be identified at all facilities to form emergency teams and their roles and responsibilities will be explicitly defined. TND will have an agreement with Mauritania Government’ Emergency Services and raise neighbouring communities’ awareness on emergency response. All employees and contractors are responsible for reporting any emergency incident to the QHSE team for assessment and rapid intervention.
E&S Monitoring and Reporting. At the layer farm, internal monitoring is conducted daily for parameters such as food intake and mortalities. The production manager then reports the information to the management team on weekly basis. TND will develop and maintain a comprehensive corporate and individual facility-level Environmental, Social and Quality (ESQ) monitoring and reporting procedures (ESAP#6). The monitoring procedures will define KPIs to assess compliance with legal and regulatory requirements, EHS management system progress report and certification, energy and water consumption and efficiency, solid and hazardous waste management and disposal, effluent discharges, OHS requirements, including leading and lagging indicators, such as accident rates (lost-time accidents); community complaints, third-party supplier performance and community engagement activities in line with IFC PSs and WBG’s General/Poultry Production and Processing EHS Guidelines. The production managers at each site will compile a monthly monitoring report to the corporate QHSE. TND will report annually to relevant Mauritania authorities and IFC, as part of the Annual Monitoring Report (AMR).
Supply chain. The feed for the layers and broilers is currently sourced from Morocco. Upon commissioning of the feed mill, all raw materials, including vitamin/mineral premixes and soy/corn will be imported, mainly from Latin America. All premixes are imported from reputable global nutrition companies. While TND has no management control and leverage over the third-party suppliers, as part of this project, TND will only source from soy/corn traders having adopted and implemented a Supplier Code aligned with IFC PS2/PS6 requirements.
PS2: Labor and Working Conditions
Human Resources Policies and Procedures. TND has a corporate Human Resources (HR) policy, that is currently being validated by the Government of Mauritania according to the local labor requirements. The policy is managed by HR and Administration Manager. Staff receive a copy of the HR manual during induction. A review of the policy identified some discrepancies with IFCs PS2 objectives. Going forward, TND will update the HR Policy and develop procedures to include issues related to discrimination, remuneration, grievance mechanism, performance appraisals, prohibition of forced and child labor, working hours, leave and employee benefits. In addition, TND will include the commitments to communities and to prioritize local employment in the HR policy (ESAP#7).
Working Conditions and Terms of Employment. TND operations has currently 35 (90% men) direct employees of whom five (5) are expatriates, and 90 contract workers (mainly from EPC contractor, all of whom are men). With the proposed IFC investment, the number of direct workers is expected to increase to an estimated 180 direct employees. The terms of employment are included in the contract and elaborated in the HR Manual shared with workers at induction. These provisions include remuneration, allowances and benefits, training, performance management, leave, grievance redress, disciplinary measures, occupational health and safety, harassment including sexual harassment, working hours & overtime and termination. Workers at farm operations are provided with accommodation and meals, and medical provisions as stipulated in the national labor law. TND will establish and implement policies on the quality and management of the accommodation and provision of basic services in line with the IFC Guidance Note on Workers’ Accommodation (ESAP#8)
Workers Organizations. Workers’ rights to form unions or other workers’ organizations of their own choosing and to bargain collectively with their employer is recognized by Mauritanian labor law. To date, none of TND employees are part of a union. TND has no history of labor strikes and management has indicated that there are no restrictions for workers to join trade unions/organizations at will. However, this provision is not reflected in the existing HR policy. This policy will be updated to explicitly articulate that there are no restrictions on freedom of association and for workers to join trade unions/organizations. This provision will be (i) explicitly communicate through a communication plan and (ii) outlined during worker’s induction session (ESAP#9).
Grievance Mechanism. TND has a workers’ grievance procedure, as part of the HR Manual, available to every employee. The procedure is clear, provides for documented grievance reporting, alternative handling methods, regular meeting and feedback to claimants and appeal options. According to TND, the procedure allows for anonymous complaints and there is a whistleblowing system consistent with PS2 objective. This procedure is also accessible to contract workers.
Life and fire safety (L&FS). Based on the layout plans, all facilities (farms and feed mill) will have fire suppression equipment, mainly portable fire extinguishers. As discussed in the EPRS section above, fire drills will be conducted annually. TND will have an agreement with Mauritania Government’ Emergency Services and will be communicating with neighbouring communities in case of emergency response. The communities will be incorporated into emergency preparedness and response plan. TND will commission a qualified L&FS expert to conduct a L&FS audit for all its operations to comply with L&FS requirements as defined in the applicable national law. TND will timely implement the corrective action from the audit, including implementation schedule and budgeted CAPEX/OPEX (ESAP#10).
Workers Engaged by Third Parties. TND uses third party workers for civil engineering works and construction phase of its operations. As part of HR policy and procedure review, TND will develop a contractor management and monitoring procedure to ensure that contractors apply local regulation regarding labor and working conditions, OHS management, grievance mechanisms and risk on child and forced labor in line with PS2 requirements. The QHSE department will closely monitor the implementation of the procedure (ESAP#11).
Occupational Health and Safety (OHS). The HSSQE framework has some elements of OHS management system, especially safety at workplace. The expansion of the company operations to poultry production and processing will require an OHS policy and procedures. TND will update its HSSQE framework to include OHS management procedures which will include (i) a risk assessment procedure, (ii) development of OHS SOPs, (iii) risk management for all identified risks for the operations, (iii) risk reporting framework and a risk monitoring system with KPIs on (i) exposure to dust and biological agents; (ii) exposure to low temperatures; (iii) OHS leading and lagging indicators. The OHS management procedure will apply to direct workers and contractors and aligned with the requirements of this PS, relevant sections of WBG EHS Guidelines and ISO 45001 (ESAP#12).
PS3: Resource Efficiency and Pollution Prevention
Energy use. TND poultry operations will use energy from the national grid. The company will install emergency back-up generators in case of power outage. Energy efficiency measures are embedded in the design and selection of equipment and cooling systems. The layers and the completed hatchery facility viewed are well laid out with product flow, ventilation and workflow following GIIPs. Based on these designs, the increase of the use of energy is expected to be insignificant. Energy consumption (electricity, fuel) and efficiency will be closely monitored at all sites.
Greenhouse Gases. Current GHG emissions from the layer’s operation (based on electricity and fuels) have been estimated to approximately 708 tons CO2-equivalent per year (Scope 1 and 2). Additional GHG emissions due to the proposed expansion are not expected to be significant and will be well below 25,000 tons of CO2-equivalent per year.
Water use and efficiency. All the layer and broiler farms in Ouad Naga will be supplied with water from the municipal adduction system, along the Edin reservoir - Nouakchott water pipeline. At each facility, TND has installed water storage reservoirs based on the utilization capacity. TND will monitor total water consumption at all sites and benchmark its water efficiency against industry reference as outlined in the WBG’s EHS Guidelines. Regular analysis of water quality at the farms (chemical and bacteriological) will be conducted internally and form part of the E&S monthly performance report.
Air emissions monitoring. Main sources of air emissions will be the boilers at the proposed feed mill and gensets that burn diesel to produce electricity, heat, and hot water during electricity outages. The generators and boilers will undergo periodic maintenance audits in accordance with manufactures requirements to optimize efficiency. Given their size (below 3 MWh) and frequency of usage, stack air emissions from the generators are expected to be minimal and will not be measured. Ambient air quality will be monitored every quarter to monitor the particulate levels from the boilers as part of the national requirements.
Waste Management. Non-hazardous solid waste consists of debris from the construction. The debris will be hauled by a licensed third-party contractor to a designated municipality landfill. During the operation phase, layers, hatchery, and slaughterhouse’s waste will be chicken droppings, egg debris, unhatched eggs, chicken embryo, and eggshells, vegetable, and animal matter from the slaughterhouse. Chicken dropping are bagged and sold as fertilizer. Waste from the slaughterhouse is also converted into fertilizer and sold. Dead chicken carcasses will be collected every morning and incinerated. Solid waste from the feed mill, mainly domestic waste, paper and cardboard, plastic, organic wastes, will be collected and disposed by a third-party contractor. To facilitate sorting and waste segregation at source, TND will provide adequate waste bins. Construction debris were observed at some sites. As part of contractor monitoring, TND will ensure solid debris is stored in a designated area and disposed periodically. TND will regularly audit the performance of the licensed waste management contractor to ensure waste from its facilities are disposed at approved municipality landfills.
Hazardous Waste. Hazardous wastes, such as florescence light bulbs, used oil, chemical solvent used for cleaning absolute electrical equipment, car batteries, empty pesticide containers, paint containers and medical waste from laboratory will be recovered and disposed by licensed services providers. To formally guide this process, TND will develop a hazardous chemicals procedure for collection/disposal of hazardous waste (ref. ESAP#2).
Effluent Management. All sites are in rural areas not served with municipal sewerage system. Based on the designs, septic systems will be used in all sites including the the farms (layers and hatcheries) where cleaning and disinfection wastewater is channelled into septic system. The septic systems will be emptied periodically by a licensed waste disposal company and taken to government treatment sites. For the slaughterhouse, the designs include a wastewater treatment plant (WWTP) whose specifications meet WBG EHS Guidelines.
PS4: Community Health, Safety and Security
Community Health and Safety. Key community health and safety identified from the operational PK28 operations, and the proposed new operations include those related to food safety, spread of animal diseases, traffic related with transport fleet, life and fire safety, and security personnel.
Food safety. The layout plans for the slaughterhouse and the feed mill have food safety designs built in. TND will develop, adopt, document, and maintain a management system that ensures safe food practices (ESAP#13), and at a later stage achieve ISO 22000 certification process. The company will establish microbiological laboratory in the abattoir and the feed mill, to enhance the frequency of monitoring of products along the production line to ensure food safety. TND will conduct medical examination for food handlers in all food production operations regularly, in compliance with national food safety laws.
Fleet management. While the feed mill will be constructed in a designated industrial zone, there are recreational buildings adjacent to the north wall and primary residences across the Rosso Road. There are communities living close to the other sites. There are houses within 50m of the fence at PK17 and PK28, and within 500m of the fence at PK51 and 53, highlighting a traffic risk. TND will therefore develop and maintain a traffic management procedure for its operation and those of the transport service providers and include preventive maintenance program and drivers training.
Security Personnel. TND uses the services of a third-party service provider for its security personnel and monitors their performance. The company currently has eight (8) employees working at the farms, who work in shifts. The security personnel are unarmed. TND will update the HSSQE framework to include a security management procedure that will detail training needs that will be provided to security personnel (ref. ESAP#1)
PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources
Sustainable Management of Living Natural Resources. IFC’s scope of appraisal for animal welfare included verification of compliance of TND animal welfare management practices with the OIE Guidelines. Based on the layers at PK28 and the farm designs, TND complies with these guidelines. Breeder’s housing systems allow chicken to engage in natural behaviors. Well-maintained bedding, feed and water availability, disease control, adequate temperature, ventilation, and humidity are key parameters which are closely monitored. Breeders are controlled against diseases and vaccines are applied according to an agreed upon prophylaxis plan. No hormones are in use by TND. Only certified providers and approved antibiotics are applied if a disease outbreak takes place. Overall annual mortality rates at the breeder houses are less than 7%, which is considered excellent. TND has human culling procedure and conducts welfare audits. Going forward, TND will document the current management systems for animal health, including biosecurity and animal welfare. The company veterinary staff will also ensure TND undergo a comprehensive IFC’s HACCP-methodology based Biosecurity, Animal Husbandry/Welfare and Use of Antibiotics (BAWA) Audit Protocol leading to the development of BAWA management system at farm-level (ESAP#13). TND will certify its animal husbandry/welfare management practices against a recognized certification standard benchmarked against GIIP for all farms going forward (e.g., Global GAP for Livestock) (ESAP#14).
Biosafety. TND will develop and implement a Biosecurity Manual which will include a well-structured vaccination and monitoring programs to cater for any outbreaks of virulent strains for other diseases. Personnel responsible for the care and management of the chickens will be continuously trained to identify normal health and behavior of the chickens in their care to be able to recognize poor health and welfare. Chickens will be inspected regularly, at least daily, and more frequently during period of significant risk to health and welfare. Bio-security procedures include geographical isolation of the farms, limited controlled site access and suitable infrastructures (e.g., high concrete fences); entrance gates with vehicle disinfection areas, cleaning and disinfection procedures for visitors, materials, and tools (e.g., foot disinfection at the entrance of sites/houses), control of pathogen vectors (rodents, insects), and organic waste management. Workers’ clothes are kept clean, shoes are scrubbed with disinfectant, and hands are washed. As part of its bio-security procedures, any sick or dead bird is removed and reported to the veterinarian
