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
SCCT identifies and manages E&S risks and impacts associated with its operations through compliance with applicable E&S regulatory requirements including project-specific environmental permits and by use of a corporate ESMS. To support Environmental, Health and Safety (“EHS”) policy implementation, SCCT employs a corporate EHS Management System (“ESMS”) that is overall consistent with PS1 requirements, APM Terminal global EHS operational standards, and certified to ISO 14001 (on Environment) and ISO 45001 (on Occupational Health and Safety – OHS). In accordance with regulatory requirements, SCCT completed the EIA for the proposed project, which included public consultation in Port Said city, and secured the environmental permit in March 2023.
As part of its ESMS, SCCT implements a range of EHS procedures and work instructions. The EHS procedures include risk assessments, permit to work, incident investigation, contractor management, environmental operational control, among others.
The existing terminal operations have a dedicated EHS manager, supported by a team of EHS supervisors. The expansion project will have a dedicated project management team that includes a EHS lead, supported by an EHS deputy, two EHS supervisors, and an EHS administrator. Contractors for civil and electrical works will be equally required to have an EHS team consisting of an EHS manager and a team of EHS supervisors.
SCCT has a well-established emergency preparedness and response plan with defined risk scenarios, response procedures, routine maintenance, and a response team with defined roles and responsibilities. Oil and hazardous material spill preparedness include a 200 m fence boom; sorbet booms, absorbent pads, rolls, a delta skimmer and a high pressure steam jet. The spill preparedness also includes a mobile oil spill response container and a hazardous material leakage response trailer. Firefighting preparedness measures include hydrants across the terminal connected to a pump house; automatic CO2 suppression systems; fire detection and alarm system; water sprinklers, chemical powder, and CO2 portable fire extinguishers. The terminal has a well-equipped onsite clinic, supported by two ambulances, and staffed with a paramedic & 2 nurses at day shift and a paramedic & nurse at night shift. The clinic is internationally certified for primary care. The emergency preparedness is licensed by the National Civil Protection Authority since December 2022. Emergency drills are performed on a monthly basis. SCCT will undertake a review and supplement their emergency response preparedness as required to take into account the new expansion project (ESAP #1).
As part of its ESMS, SCCT performs management site safety walks and inspections and reports on monthly EHS Key Performance Indicators (“KPIs”) that includes injuries, lost time incidents, percentage of vessel inspection, and corrective action closure. SSCT EHS function undertakes internal audits based on an audit plan and receives annual third-party certification audits for ISO 14001 and 45001.
To further align with IFC PSs, SCCT will log consumption of electricity; fuel and water; log waste generation and disposal; set waste recycling targets; adopt WBG General EHS Guideline emission parameters; and expand their leading KPIs (ESAP #2). For the expansion phase, SCCT will develop a Contractor E&S Management Plan (“CMP”) to contractually ensure that all contractors align with SCCT EHS MSs (ESAP #3).
PS2: Labor and Working Conditions
The total workforce of the existing terminal is 3057 workers, including 1453 (47.5%) direct workers. Females represent 4% of the total workforce. SCCT estimates that 1000 direct and indirect job opportunities will be added with the port expansion. No estimate is currently available for the construction contractor workforce.
SCCT aligns with Maersk’s HR Policies and Procedures which are in line with IFC PS2. SCCT will ensure that all contractors align with Maersk HR policies and procedures and IFC PS2. As per ESAP #3, the policies and procedures will be communicated to direct and third-party workers and SCCT will ensure via the CMP, that adequate resources are allocated to implement these policies and procedures. SCCT working hours are aligned with local regulations.
SCCT adheres to Maersk’s non-discrimination and equal opportunity policies with regards to recruitment and promotion which is in line with IFC PS2. SCCT contributed to government dialogue around amendments to labor law to allow females to work on night shift rotations and as RTG operators within ports. In 2019 SCCT officially requested an amendment to the labor law, emphasizing the importance of enabling women to join the workforce in operational capacities. The Ministry of Manpower issued Decree No. 44 on 19 April 2021, allowing women to work night shifts in ports. For this project, SCCT intends to improve general facilities (e.g. washrooms) to improve female participation in the workforce.
Workers are encouraged to submit grievances or suggestions by posting them on a board at the entrance of the main terminal building. A corporate whistle blowing policy is in place and is accessible to all workers. Similarly, the labor union has a grievance committee to respond to all complaints submitted by the workers.
SCCT HR handbook will be updated to include a formal workers’ grievance procedure. This grievance procedure will include various channels for complaints submission, a timeline for acknowledging and resolving grievances and provisions to appeal, if the complainant has any concerns. The grievance mechanism will provide for anonymous complaints and will include clear provisions protecting confidentiality representatives are included in this committee to address complaints related to gender-based violence and harassment (GBVH), if any. The grievance mechanism will be accessible to all workers, including contracted and third-party workers engaged in terminal construction and operation (ESAP #4).
SCCT three-year (“CBA”) with SCCT Employees Union will be renewed in 2025, which covers the entire workforce. SCCT to formalize a freedom of association policy and procedure encompassing its existing practices in line with IFC PS2 (ESAP #5).
SCCT implements OHS management program with standard procedures covering transportation; suspended loads and lifting; working at heights; stored energy, and control of contractors. The OHS program is rolled out as part of the global APMT safety operating standards, which is overall consistent with IFC PSs requirements and WBG EHS Guidelines. As part of ESAP#2 above, SCCT will strengthen the management of contractors’ E&S performance. SCCT monitors OHS leading and lagging indicators and Lost Time Incidents Frequency Rate (“LTIFR”). SCCT performs annual OHS measurements that include noise, heat stress, illumination, and vibration. In addition, as per the country-level regulatory requirements, SCCT has an OHS committee represented by workers and senior management, to regularly assess EHS performance.
PS3: Resource Efficiency and Pollution Prevention
The company’s operations primarily involve container transshipment, which does not result in significant quantities of waste and direct emissions. SCCT operations do not include handling ship-generated effluents such as sewage, bilge/ballast wastewater, bulk storage handling, transfer of hydrocarbons, or ship maintenance.
Electricity and water requirements of SCCT terminal are serviced from the national grid, with back-up electricity generators in the event of power cuts. Potable water is trucked from a well, treated at an in-situ water treatment plant, and regularly tested to confirm potability. SCCT will install energy-efficient LED lighting and will pilot the use of electric trucks during the operational phase of the expansion project with a view to replacing the diesel trucks that reach the end of their operational life.
APMT announced achieving a net zero Greenhouse House Gas (“GHG”) emission target by 2040, and a 70% reduction in absolute (total) emissions as an interim milestone for the period 2020-2030. SCCT’s annual GHG emissions for scope 1 and 2 for the existing operations are estimated to be 56,400 tons of CO2eq. For the expansion project, the annual GHG emissions for scope 1 and 2 are estimated to be 17,200 tons of CO2eq. As SCCT's existing and future operations are expected to produce more than 25,000 tons of CO2eq per annum, the company will report to IFC the GHG on an annual basis.
No project-related coastal erosion risks were identified, and based on a climate screening of the project’s location, two main climate-related vulnerabilities were identified: i) hotter temperatures and more frequent and intense heat waves may put workers at risk of heat-related illnesses, this risk will be addressed as part of SCCT’s existing OHS management program; and ii) continuing sea level rise may affect the project site given its proximity to the canal; however, this risk is largely mitigated by the terminal being built on an elevation of 2.5m above the sea-water level.
SCCT implements waste management measures as part of its environmental operational control procedure. This includes waste segregation of the various waste streams and collection and disposal by licensed waste contractors. The site visit identified that hazardous waste storage requires to be bunded and sheltered to secure the hazardous waste from direct sunlight, wind, and rain (ESAP #6). Sanitary wastewater is collected in a holding tank and subsequently trucked to a wastewater treatment plant outside the port located in east Qanatara city. SCCT performs an annual wastewater analysis for the wastewater collection storage tank to confirm it meets the recipient’s requirement for the wastewater treatment plant. Waste wash water from equipment and vehicles is collected in a contained pit connected to an oil/water interceptor, which is regularly emptied by a licensed waste contractor using an evacuation truck.
Containers with hazardous material are transported, handled, stacked, and stored according to the relevant codes of the International Maritime Organization (“IMO”) Convention and International Maritime Dangerous Goods (“IMDG”). As part of the ESMS, SCCT implements dangerous cargo container handling procedure to address risks of leakage and spillage, which includes container classification, inspection, and re-conditioning as required. SCCT stores chemicals in a conditioned 40-foot container provided with automated fire suppression. As part of the expansion project support facilities, SCCT will build a sheltered fit for purpose chemical storage depot, due to the risks posed by storing chemicals within an enclosed shipping container (ESAP #7).
The stormwater management of the existing terminal and proposed expansion includes using oil/water separators at a drainage basin prior to discharging to the surface water. SCCT performs an annual analysis of the drainage basin discharge to confirm it meets the regulatory requirements to release on surface water (seawater). SCCT will update the environmental operational control procedure to include testing end of pipe discharges on a monthly basis to confirm oil and greases discharged from the oil water interceptors to the environment (sea) are within WBG General EHS Guideline discharge parameters (ESAP #8).
PS4: Community Health, Safety and Security
The nearest settlement to the project is Port Fouad city 5km to the west and Bir Qatia community in the Sinai Peninsula, 50 km to the east.
SCCT has a traffic management plan covering man-machine interface, managing and regulating pedestrian access and vehicle traffic throughout SCCT premises. SCCT’s has 134 diesel trucks working within the port premises that in its vast majority (c. 95%) is a transhipment port. An additional 90 trucks will be included as part of the expansion project. For road transportation shipping containers, SCCT has a pre-entry parking area for the port with a capacity to hold 200 trucks, which is located outside the fence and managed by a third party. It includes a mosque, cafeteria, and washroom facilities for the road transportation truck drivers. Within the port premises, drivers are trained, provided with an internal license to transit, and are monitored by CCTV. Regular meetings are held to address root causes of any violations with an appropriate penalty and reward system applied. For daily transportation, workers use company ferry and third party provided buses to commute to work.
SCCT employs unarmed security guards through a security company who are supervised by security supervisors. Security is also managed by the government through the police and the military. SCCT will develop a Security Management Procedure based to manage existing security risks in collaboration with the existing layers of security within the port (ESAP #9).
