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.
PS 1: Assessment and Management of Environmental and Social Risks and Impacts
Policy. As part of the conditions agreed upon for this IFC financing, SFPL will develop and implement an Environment, Health, Safety, and Social (EHSS) Policy to align the plant’s E&S performance with Bangladesh’s legal and regulatory requirements and IFC Performance Standards, including ancillary facilities (ESAP#1). Upon approval of the policy by SFPL CEO, SFPL will develop an Implementation Plan, including display of the EHSS policy within the plant, induction training course to employees, contractor and service providers, and annual internal verification audit of implementation of the EHSS policy.
Identification of E&S Risks and Impacts. SFPL commissioned an ESIA Study for the construction and operation of the project in accordance with local and IFC PSs requirements, including applicable and relevant sections of the WBG General and Sector-Specific Environmental Health & Safety (EHS) Guidelines (Vegetable Oil Processing; Ports, harbors and terminals). The plant-level ESIA study was informed by the ESIA study prepared by BEZA for the establishment of the MEZ-II. The ESIA study for the project addresses key E&S risks and impacts during the construction and operation phase, including, among others, dust, emissions to air, air quality, noise and ambient conditions; cumulative impacts of the existing and proposed industrial and developmental activities near the project; greenhouse gas (GHG) emissions; flooding; water and wastewater; runoff management; handling, storage and use of hazardous materials; solid waste; ecology and biodiversity; ecosystem services; vehicular emission; land/sea traffic safety; handling, storage and disposal of solid and hazardous wastes; fire risk in switchyard and gas facilities; worker accommodation during construction and operation; facilities and amenities to be made available to workers; working at height; working in confined spaces; electrical safety; child and forced labor; Gender Based Violence and Harassment (GBVH) impacts due to workforce influx and trucking/logistics. Aside from the ESIA disclosed along this ESRS, SFPL will complement the ongoing ESIA process with the preparation of a Hazard and Operability (HAZOP) and update of the QRA (already completed as part of ESIA) upon the final design of the project (ESAP#2). SFPL will assign Capital Expenditure (CAPEX) and Operational Expenditure (OPEX) (and factor in the project cost) for the effective/timely implementation of the project’ ESIA Study, resulting ESMP, HAZOP/QRA study and recommendations.
E&S Management System and Programs. As this proposed investment is still in the final design stage, SFPL has yet to start the development of its E&S Management System (ESMS). Upon completion of the E&S policy framework (ref. ESAP#1), the ESIA Study and the HAZOP study/QRA update (to be completed prior to the construction stage), SFPL will establish a PS-compliant ESMS at the proposed crushing plant which will include the construction and operation phase. The E&S Management Plans (ESMPs) from the ESIA process, including time-bound implementation schedule, and the recommendations from the HAZOP Study will be integrated within the scope of this ESMS. SFPL will, prior to start of construction, develop and implement (a) a construction stage ESMS (ESAP#3), including the ESMP’ mitigation measures from the ESIA process and the recommendations of the on-going HAZOP study; and (b) contractually require the construction contractors to adopt and implement the company’s E&S policy (ref. ESAP#1), the ESMP from the approved ESIA Study and the recommendation from HAZOP study (ref. ESAP#2) and SFPL’s ESMS (ref. ESAP#3). The construction phase ESMS will include, among others, (i) EHSS policy and objectives; roles and responsibilities; (ii) project site EHSS management plans in accordance with WBG EHS Guidelines and GIIP. In addition, SFPL will (a) develop and implement an operations phase ESMS which shall include the ESMP from the ESIA Study and recommendations of the HAZOP study; and EHS SOPs for the crushing plant and all ancillary facilities, in alignment with WBG EHS Guidelines and GIIP (ESAP#4); and (b) in case SFPL chooses to sub-contract the operations, contractually require the O&M contractor (if any) to implement the operational phase ESMP and SFPL’s ESMS, the latter in alignment with IFC PSs requirements. The operations stage ESMS will include SOPs that will be developed to address mitigation measures defined in the ESMP, HAZOP and as per relevant sections of the WBG EHS Guidelines, such as monitoring of: air emissions; noise; ambient noise; ambient air quality; water consumption; operations and domestic wastewater quality, treatment and disposal; hazardous material and hazardous waste handling, storage and disposal; OHS; fire prevention, detection and control; operation and domestic waste management; operation, cleaning and repairs of equipment; storm drainage and contaminated runoff management; solid waste; and transport management plan (including road transport and vessel movement). SFPL will ensure annual budgetary allocation to the E&S management team to implement the ESMP, the HAZOP recommendations, the E&S Action Plan attached to this ESRS and the maintenance of the plant-level ESMS.
EHS Organizational Capacity/Competency. Samuda Group recently appointed a Sustainability Director. At Group-level, an E&S regulatory team reporting to the Director of Regulatory Affairs is responsible for securing regulatory permits for all Samuda Group operations, including for this project. Prior to the start of the construction phase, SFPL will appoint an experienced E&S team for this project. This team will be staffed, at the minimum, with one full time and competent environmental specialist (responsible for the development of SPFL’s ESMS and implementation of the ESMP/HAZOP recommendations), two full-time occupational health and safety (OHS) officers (one responsible for the development of SPFL’s OHS Management System, and one overseeing the enforcement of contractor’s management plan), and one social/community liaison officer (ESAP#5). Each contractor will be required to deploy at least [1 or more depending upon workforce mobilized] appropriately qualified EHS personnel. Prior to the commencement of operations, SFPL will obtain applicable clearances, permits, consents, authorization, and all regulatory approvals under all the relevant legislation.
E&S Training. SFPL will establish an EHS training program including but not limited to ESMS policies & procedures, fire safety, emergency preparedness, food safety & hygiene (especially for staff engaged in food processing operations) on regular basis to ensure that staff competency levels are maintained and address any gaps. SFPL HR shall update the training plan, as needed, to include new training needs identified during the normal course of operations. The construction and operation ESMS (ref. ESAP#3&4) will include a training matrix on E&S policies, procedures, management plans, emergency preparedness to be delivered to the workforce during construction and operational phase.
Emergency Preparedness and Response Plan. As part of the construction phase ESMS which will include the construction EHS management plan (ref. ESAP#3), a construction stage Emergency Preparedness and Response Plan (ERP) will be developed/implemented addressing all possible emergency scenarios. Emergency response procedures, periodical training, and monthly fire/mock drills involving all direct and contractor workers will be implemented. During the O&M phase of the project (ref. ESAP#4), SFPL will establish and maintain ERP in line with national requirements and applicable and relevant section of the WBG EHS Guidelines. Periodic training and drills of all staff on different shifts (day and night) will take place for effective response. SFPL, with the technical assistance of expert service providers and the recommendations from the HAZOP study (ESAP#2), will identify processes and facilities where accidents and emergency situations may occur and implement needed mitigation measures. The ERP (for the construction and operation phase) will include mandatory establishment and maintenance of buffer zones and green belts around the site restricting activities near the plant; and plan to stop critical operations in case of strong wind/cyclones. The ERPs prepared for both the construction and operation stages will define the roles and responsibilities of employees, who are part of the ERP team and responsible for evacuation, rescue, and firefighting. The roles, names of the ERP team members and their contact numbers will be displayed at various locations across the site. Evacuation route maps, assembly point signs, and water hose reels will be placed at appropriate locations. Trainings and drills related to implementation of safety measures will be conducted on a regular basis.
Monitoring & Reporting. During the construction phase, SFPL will monitor ESMP implementation, material environmental events and lagging and leading OHS indicators (ref. ESAP#3). During O&M, SFPL will establish an E&S monitoring and reporting procedure, as part of the PS-compliant ESMS and OHSMS, for the E&S performance of the plant and continuous improvement (ESAP#4). Key Performance Indicators (KPIs) for environmental, OHS and resource efficiency parameters will be identified and continuously recorded. SFPL’s E&S performance will be reviewed by the Board of Directors on a quarterly basis. SFPL will recruit a third party EHSS auditor, acceptable to lenders, to undertake 3 plant-level quarterly audits during the construction phase and then annually for the first two years after plant commissioning (ESAP#6). The scope of these audits will include the implementation of the plant-level ESMS, with specific review of the ESIA/ESMP (including Terms and Conditions of the Environmental License), the recommendations from the HAZOP study and implementation effectiveness of the EHS SOPs. Afterward, Samuda Group will undertake annual verification audit of the EHSS policy, under the leadership of the Sustainability and Regulatory Affairs Directors.
Cumulative impacts. In the Project area of influence, there are fishermen using 4 fishing ghats i.e. Ichakhali ghat, Bamansundar ghat (adjacent to SFPL site), Saherkhali ghat and Domkhali ghat. Based on the ESIA Study prepared for the project, Hoania ghat and Dabarkhali Ghat, are not used by the fishermen. Out of the total registered fishermen, 1,091 are specifically engaged in fishing along with an additional 200 unregistered fishermen at the Sandwip Channel (over which the jetty will be constructed and where specific fishing locations for fishermen operating from different ghats). The project ESIA included a detailed socio-economic baseline, with a survey of around 100 fisher households (HHs) covering fishery practices, number of fishermen involved at different ghats, fishing season, use of fish nets and boats, income, fishing supply chain, change in fish catch over past years, etc. According to the Department of Fisheries, MEZ authorities, and the fishermen at different ghats, hilsa and other fish catch has been decreasing over the last 5 years. Consultations suggested that this was primarily due to the release of wastewater containing harmful chemicals by the chemical factories into the Bamansundar and Ichakhali canals, the discharge of construction wastes, liquid and hazardous wastes, which has increased the turbidity levels in Sandwip channel and impacting the hilsa breeding grounds affecting overall fish catch. During the project’s ESIA consultations, the fishermen highlighted a significant decline in fish populations over the past decade due to drop in water depth of Sandwip channel from 40-45ft to 20-25ft due to sedimentation and overfishing at Chattogram (downstream of the project which supports the fishing ground population). Decrease in income at all ghats across during monsoon, post monsoon, winter and summer was reported in the HH surveys. The construction of the 23km superdyke by BEZA for the establishment of MEZ with sluice gates at each of these ghats (already constructed or under construction at two locations) has further restricted the access of the boats outside the superdyke area and exposes boats to cyclones and storms. SFPL jetty will be developed in addition to another two jetties to be developed by Basundhara Group (approximately 1.2 km west from SFPL’s jetty) and the Bangladesh Inland Water Transport Authority (BIWTA) (exact location not yet finalized), which will further increase the vessel traffic in Sandwip channel. So, sizeable impacts on fishery activity (reflected in catch and income per trip across seasons) exist as a result of the cumulative impacts of the development of MEZ-II and MEZ-I overall. During the proposed jetty construction, SFPL mentioned only a total of 4-5 barge trip movement for pile transportation; further, SFPL will put a 100 m buffer, demarcated through buoys, to help prevent damage to any fishing boats or fishing equipment during jetty construction. During the operational phase of the jetty, as per the draft ESIA study, the incremental traffic will be limited to 36 trips per month by vessels carrying soyabean from mother vessel parked at Chittagong port area. A stakeholder engagement plan (SEP) and community grievance mechanism (CGM) are already developed as part of ESIA process. As part of the proposed ESMS (ref. ESAP#3&4), a detailed stakeholder engagement strategy will be developed to ensure that fishermen are informed of vessel traffic (timing and route) for SFPL operations and other mitigation, as well as information on the use of the GM. SFPL CGM (as detailed in the ESIA study and to be implemented as part of ESMP and ESMS implementation) will have provision for fishermen to use the GM in case of any damage to fishing nets or boats due to SFPL sea traffic. SFPL will ensure that losses, if any, will be compensated by SFPL.
Supply Chain Risk Assessment and Management System. SFPL will procure soybean primarily through international commodity market (further details discussed in PS6 section below). Hexane and caustic soda will be procured from SFPL’s sister organizations - Super Petrochemical Ltd. (Super Petro) and Samuda Chemical Complex Limited, both entities of Samuda Group, while phosphoric acid will be procured from China. SFPL presently does not have any documented Code of Conduct & Code of Practice for its suppliers. This Code will be developed/implemented (see ESAP#13 below).
PS2: Labor and Working Conditions
During the construction phase, approximately 300 contracted workers will be engaged. During the operational phase SFPL will have approximately 270 permanent employees, including 50 management staff, 100 skilled and 120 semi-skilled (direct workers) including security personnel employed through third party vendors.
Human Resource Policies and Procedures. At the Group level, Samuda is implementing labour provisions stipulated under local laws. Samuda has formulated a Code of Conduct for employees which among others include anti-harassment policy covering sexual harassment. Besides this Code, a Group employment policy, attendance & leave policy, aligned with national statutory requirements, have been adopted by Samuda Group. However, some of the HR policies and procedures (apart from the one mentioned above), are still in the process of development and/or approval. SFPL will also be adopting these policies. SFPL will develop/ implement HR policy and procedures (while drawing upon Samuda Group policies) compliant with the host country regulations and requirements of IFC PS2 (ESAP#7). Samuda Group’ HR function will support SFPL’s HR function in the development of HR policies and procedures and in monitoring labor contractor compliance, in accordance with Bangladesh’s labor law and IFC PS2 requirements. HR manual for the plant will be communicated to the employees through an Employee portal (and other means as feasible) and will have provision for training including new employee induction and regular refresher trainings. The adequacy of the SFPL HR policies and procedures as per host country regulations and IFC PS2 requirements, and on-ground implementation (including direct workers and third-party workers) will be reviewed as part of third party EHSS audit during construction and operations stage (ref. ESAP#6). HR manual will be approved for SFPL as per the local requirements. As part of ESAP#3, SFPL will develop an enforceable worker Code of Conduct (CoC) which among other provisions, prohibits gender-based violence and harassment (GBVH) with a recurrent training program for all employees and contractors on GBVH. In addition, staff will be trained to handle GBVH complaints in a survivor centered manner. The worker CoC will be included by SFPL as part of the contractor agreement with contractors at the construction and operations stage.
Non-discrimination and Equal Opportunity, and protection of workforce. Samuda Group’ employment policy (to be applicable for SFPL) specifies provision for not employing children (workers less than 18 years of age) or forced labor in its existing operations and includes age verification process using government issued identity cards.
Worker Accommodation. Samuda has existing accommodation (for direct workers engaged in operations of other Samuda company’s operations) within the 60 acres premises. During the construction phase, SFPL will provide an area for contractors to construct accommodation for third party/contract workers staying at site (some of the workers may come from nearby areas or stay in rented accommodation in villages). Subsequently, during operations stage SFPL (directly operating the plant operations) will accommodate direct workmen in SFPL managed and operated accommodation at the site. The company, as stated under ESAP#3 and ESAP#4, will develop and implement worker accommodation standards in line with IFC and EBRD guidance on workers' accommodation: processes and standards (2009). SFPL will ensure that these standards are implemented both for: contractors operated accommodation for contract workers during construction; and SFPL managed accommodation for direct workmen during operations.
Freedom of Association. The HR policy and manual will include policy and procedures with regards to workers organization in compliance with labor law (as applicable in EPZ area), including setting up participatory committee (till the time a worker’s welfare organisation is formed and registered) where direct involvement of the workers will be ensured and meet the IFC PS2 requirements (ref. ESAP#7).
Grievance Mechanism. SFPL will, as part of its HR Policy and Procedures Manual (ref. ESAP#7), develop, communicate and establish a formal employee grievance mechanism (GM) in line with PS2 provisions which amongst other will include: adequate GM disclosure; multiple grievance reporting channels including provision for anonymous reporting without reprisal risk, and time bound redressal of grievances. Further, SFPL will, as part of the ESMS implementation, maintain grievance records for analysis and reporting to senior management. SFPL will ensure that a formal GM is accessible to all direct, indirect and contract workers during all phases and will require regular reporting from its contractors on the implementation of the mechanism(s). SFPL will also implement appropriate procedures (including policy, grievance mechanism procedure to specifically deal with sexual harassment cases).
Third Party workers. SFPL willmake the ESMP available to the owner’s project management consultant/Owners’ Engineer team (PMC), to enable effective oversight and monitoring of ESMP implementation by the contractors. As per ESAP# 3&4, SFPL will develop and implement contractor management procedures aligned to IFC Good Practice Note on Managing Contractors E&S Performance (https://www.ifc.org/content/dam/ifc/doc/mgrt/p-gpn-escontractormanagement.pdf), including review of the existing contractor management practices to cover manpower service providers and service based contractors: (a) screening process to include working conditions and OHS related risks, track record or standing of contractors; (b) contractual obligations on contractors or intermediaries; (c) regular supervision of their performance versus SFPL’s labour and working conditions, unannounced visits and visual inspections as applicable; (d) auditing the relationship and type of contract between third party and workers; protection of the workforce, including engagement of migrant workers, if any, on substantially equivalent terms as non-migrant workers performing same work, and alignment of worker accommodation with IFC-EBRD guidance; (d) training for all third-party workers to explain among others, terms of employment, GM, and workers’ Code of Conduct; (e) regular monitoring of the contractor’s legal compliance, EHS requirements, and IFC PS requirements; (f) ensuring corrective actions (in case of any identified gaps), are agreed with the vendors/suppliers/contractors and implemented in a time bound manner.
Occupational, Health and Safety (OHS). SFPL will establish an OHS management system (OHS MS) for the construction and operation phase of the crushing plant (ESAP#3&4). The construction contracts with contractors and subcontractors will specify EHS and labor compliance requirements as per SFPL’s EHSS policy, approved ESMP, HAZOP recommendations and SFPL’s ESMS. SFPL will ensure that the construction stage of the OHS MS is implemented through experienced OHS officers (ref. ESAP#5) including safety officers (as required per regulatory requirements). Effective implementation will be verified through a third party EHSS auditor (ref. ESAP# 6) (through adequately sequenced 3 visits quarterly/half-yearly covering the peak construction period- during 2 years of construction and twice annually during operation stage). SFPL will continue to undertake annual internal safety audit of the plant during the operation phase till the operational ESMS is adequately implemented.
As the crushing plant will be automated, hazard risks should be limited. Appropriate fugitive dust pollution control devices will be installed to prevent dust generation and worker exposure. SFPL will recruit an experienced service provider for the preparation and delivery of training modules and safety talks on hazard risk assessment and safety measures (including work permit system). As mentioned above, SFPL will establish an OHS MS in compliance with national law/standards, IFC PSs requirements, and applicable and relevant sections of the WBG EHS Guidelines at its plant and in ancillary facilities. Safety KPIs will be established (OHS leading and lagging indicators) prior to the construction phase and will be continuously monitored/reported on a monthly basis. Provision of regular training and emergency responses will be delivered, in accordance with the PS-compliant ESMS. In addition, the draft ESIA study - as part of QRA - has assessed the accidental release of natural gas from pipelines leading to jet fire, flash fire or vapor cloud explosion (VCE) and release of hexane from failure of loading/unloading line or hose and from storage tank leaks that may lead to pool fire and VCE (from delayed ignition). Emergency mitigation measures for these scenarios have been identified in the ESIA. Additionally, SFPL started the preparation of a hazard and operability (HAZOP) study (ref. ESAP#2), recommendations from which will be integrated into final project design. SFPL will implement the HAZOP & Risk Assessment Studies’ recommendations (ESAP#8) as part of ESMP and ESMS during the implementation of the project.
Supply Chain. Child labor forced labor and to a great extent OHS risks in the supply of soybean is low in the countries of origin (Brazil, Argentina, Canada), due to the mechanical production and harvesting methods. A Supplier Code being developed (ref. ESAP#8) will institute clear provisions against child labor and forced labor in SFPL’s supply chain, including conduct of risk assessment and due diligence of third-party suppliers for compliance with forced labor and child labor policies.
PS 3: Resources Efficiency and Pollution Prevention
Resource Efficiency. Electricity power requirements (estimated at 12MW) will be sourced from the grid until the commissioning of the 17.2 MW co-generation power plant around Sept 2026. SFPL is exploring to expand the renewable production capacity through the installation of 1 MWh from roof top solar power plants. The technical design of the SFPL crushing plant sought to maximize the integration of technically feasible and cost-effective resource efficiency measures. Two 4.3 MW diesel gensets will be installed in case of power outage. Natural gas requirement for the project is 6486 m3/hr which will be supplied by Karnaphuli Gas Distribution Company Limited (KGDCL), and pipeline will be laid till the SFPL project site boundary by BEZA or KGDCL.
GHG Emissions. The project is estimated to generate 138,730 tCO2e/year, exceeding the 25,000 tCO2e/year threshold during the operational phase of the project. Therefore, as part of the operational phase ESMS (ESAP#4), SFPL will quantify GHG emissions annually in accordance with internationally recognized methodologies and good practices and report to IFC.
Water supply. Water for domestic and process use will be sourced from a BEZA operated groundwater well and treated prior to its utilization in the crushing plant. The groundwater will be treated in a 2-stage raw water treatment plant comprising of demineralization and reverse osmosis (RO) unit. SFPL has integrated water conservation measures into the plant’ technical design, including maximum condensate recovery from the gas- fired boiler through closed loop system and recycling of 100% of the cooling water, with only the evaporation losses compensated. SFPL will develop and implement comprehensive water management (including exploring rainwater harvesting to recharge the ground water and also reduce the water demand) and monitoring programs as part of the above mentioned ESMS (ref. ESAP#4), that would comply with the water permit T&Cs, Bangladesh Department of Environment (DoE) & WHO drinking water quality standard, and WBG General EHS Guidelines.
Pollution prevention: Predicted air emissions and cumulative impact assessment on regional air shed quality during operational phase has been analyzed, as part of the ESIA study, using air modelling tools (such as AERMET and AERMOD). The cumulative impact study indicates that concentrations of baseline PM (PM10 and PM2.5) and NOx, are within WBG EHS Guidelines’ values for air quality parameters. While an increase of the PM and NOx levels due to the present and future industrial activity may occur, the concentrations in the air shed are assessed to be within the permitted ranges. If the monitoring results indicate non-compliance with WBG EHS Guidelines’ ambient air quality parameters, SFPL will implement pollution abatement measures in line with GIIP. The co-generation power plant will run using mostly natural gas leading to the reduction in PM and SOx emissions. Operational parameters will be optimized for the reciprocating engines burning natural gas to reduce NOx emissions in the cogeneration unit. SFPL will maintain a plant efficiency/thermal efficiency of 80-85% for the whole power plant.
During the operational phase, point source air emissions are expected from utility equipment, stacks and process vents. The point source air emissions from utilities such as diesel generators, cogeneration power plant, steam boilers will be controlled through adequate stack heights for achieving maximum dispersion and as per T&Cs of the air permit. The utility air emissions will be annually monitored in line with national regulatory requirements, including ESMP and WBG EHS Guidelines. The point source emissions will be monitored for PM, NOx, SOx, Hexane and VOC emissions. The final emission levels of dust, Hexane and VOCs must comply with the WBG EHS Guidelines for vegetable oil production and processing. Dust will be generated from the conveyor belts at soybean unloading station at the jetty, during the precleaning and cleaning processes at the silos and plant. As per the available technical specifications of the plant, dust collectors/control systems will be deployed in silo elevators and conveyor belts to avoid dust accumulation in grain transferring areas which may lead to explosion risks. Noise generation is expected throughout the plant due to the operations of the crushing plant, power plant, conveyors, mixers, grinding mills, boilers, pumps, fans, dust collectors and internal transport. Engineering measures (e.g. acoustic enclosures) will be implemented at all process equipment and major noise generating equipment to reduce noise levels at source. Low vibration generating machines/equipment will be selected and equipment foundations designed to minimize vibrations and noise. Silencers to noise generating equipment (e.g. genset) will be installed to comply with WBG General EHS Guidelines. Wastewater generated due to the extraction and refining process and ancillary facility (e.g. wastewater treatment plant, process wash water, RO reject, air pollution control (APC) scrubber and cooling towers, storm water drains, and the accommodation unit) will be treated at the WWT plant. Technical specifications of this WWT plant meet WBG EHS Guidelines. Soluble wastes and sludge will be disposed of by a license service provider. Sanitary wastewater generated during the construction and operation phases will be treated in septic tanks and disposed of by licensed service provider at government approved WWT plant when full. Treated wastewater meeting WBG EHS guidelines will be used for green belt development and fugitive dust control around the crushing plant. Any remaining volume will be discharged at the BEZA storm water drain (planned to be developed adjacent to the project site). Sludge produced from the WWT plant will be disposed at government approved sites by licensed service providers.
Solid and Hazardous Wastes. SFPL will develop and implement a hazardous and non-hazardous waste management procedure, including a system of appropriate sorting, handling, storage and disposal which are consistent with applicable legal requirements and WBG EHS Guidelines (ref. ESAP#4). All hazardous and non-hazardous wastes will be collected for disposal by licensed service providers.
Hazardous materials management. Hazardous material at the project site includes natural gas (supplied by government authority in pipelines till the user end), hexane, diesel for machines and vehicles procured locally, cooking gas cylinders procured locally, Phosphoric Acid (imported from China) and Caustic Soda (supplied by Samuda Chemical Complex Limited). Hexane and Caustic Soda will be stored in Mild Steel (MS) Tanks in separate areas while Phosphoric acid will be stored in High-density Polyethylene (HDPE) jerry cans in separate chemical shed. SFPL will ensure that all HAZOP and Quantitative Risk Assessment (QRA) recommendations and mitigation measures are implemented, including display of Material Safety Data Sheet (MSDS) in storage rooms, leak detection sensors and alarms, maintenance of industrial-type fence/vapor barrier to prohibit unauthorized entrances, interlocked process equipment, periodical training/awareness, mock drills & safety audits, adequate fire-fighting systems (ref. ESAP# 9 and ESAP#10 below). SFPL will classify plant’ areas according to respective hazard classes following GIIP found in electrical codes and deploy intrinsically safe electrical circuits and anti-explosion electrical devices (including lighting) compliant to ATEX or similar certification. SFPL will develop and implement a comprehensive hazardous materials management plan, including a solvent management plan, complying with the local permit conditions, local regulations and WBG General EHS Guidelines (ref. ESAP#4 above).
PS 4: Community Health, Safety, and Security
Infrastructure and Equipment Design and Safety. The proposed plant is located within a designated Export Processing Zone - EPZ (MEZ-II) and not accessed by the public. Most of the MEZ-II land has been reclaimed from the sea. BEZA constructed a 23km super dyke that protects MEZ-II from the sea based on a flood design and on cyclone surge data as per Bangladesh National Building Code (BNBC). Dredged material from the sea (procured from government-authorized providers with allocated dredging areas by the Government) has been used at the project site to elevate the land. Storm water drains has been laid in the project site to prevent flooding. During operational phase, as part of the facility ESMS (refer ESAP#4), SFPL will develop and implement an infrastructure and equipment safety program/ plan, for testing the structural stability of industrial buildings; fitness of critical process equipment's that operate at high pressure, and or temperature; testing of lifting equipment's, tools, and tackles, fitness of underground hexane storage tank and piping; boilers etc., periodically in compliance to the national factory regulations, other applicable local regulations and WBG General EHS Guidelines. The facility and worker’s residential building (likely during operational phase) will be designed, constructed, operated & maintained as per BNBC requirements, local regulations and fire codes and GIIP, including IFC/EBRD 2009 Workers Accommodation Guidelines. ERP will be in place and will address all emergency scenarios. Emergency response procedures, periodical training, and monthly fire/mock drills involving all contractor workers will be implemented.
Life and Fire Safety (L&FS). Based on completion of the final plant’ design, SFPL will engage a safety and structural consultant to prepare safety drawings and obtain a fire safety permit for the project in line with the national building & fire safety code. SFPL will prepare an L&FS Master Plan for the project identifying major fire risks, applicable codes, standards and regulations, and mitigation measures that meet the requirements of L&FS guidelines such as local fire codes & regulations and internationally accepted L&FS standard, such as US NFPA & ATEX. SFPL, at the design stage will commission a suitably qualified L&FS consultant to review the site-specific designs L&FS Master Plan for the project and certify that all the L&FS-related aspects of design are consistent with an internationally recognized L&FS code, in addition to ensuring alignment with Bangladesh National Building Code requirements (ESAP#9). Further, as part of the testing and commissioning of such systems, SFPL will commission a suitable L&FS consultant to inspect the newly constructed facility and certify that the construction of such systems has been carried out in accordance with the accepted design (ESAP#10). As part of the operational phase ESMS, SPFL will develop and implement an asset integrity management plan and undertake regular safety audits of the crushing plant and ancillary facilities and critical equipment in line with GIIP, Bangladesh national building codes and standards (ref. ESAP#4). No risks or impacts are envisaged to the community due to any unforeseen catastrophic incident or accident (e.g., fire, inflammable material storage tank explosion, hazardous chemical leaks). SFPL commissioned a HAZOP study, which once completed, will be used to determine the risks followed by implementation of suggested mitigation measures before commissioning.
Hazardous Materials Management and Safety. Hazardous materials include natural gas, hexane, diesel, cooking gas cylinders. The soybean crushing plant will release dust, VOC and hexane as pollutants. Prevention systems, aligned with GIIP, like dust collectors/control measures, scrubbers, cyclone, bag filters will be implemented as per the technical design of the plant. ERP will be adopted in line with the mitigation measures suggested as part of risk assessment (as part of ESIA), ESMP’s mitigation measures and recommendations of the HAZOP (ref. ESAP#4). Firefighting facilities and fire tenders with dedicated firefighting teams will be deployed.
Food Safety Management System. SFPL will also establish a Hazard Analysis Critical Control Point (HACCP) based Food Safety Management Systems as per ISO 22000 Standards and receive HACCP/ISO certifications (ESAP#11).
Land and Sea Traffic and transport network. The transport of the machinery and raw materials will mostly use road transport except for the soyabean transportation through sea route (nearest major port around 70 Km at Chattogram). Raw materials will come to Chittagong port through shipping vessels, and further transported to the SFPL jetty through smaller vessels. Finished products (soyabean cake) will be transported by road to Dhaka (~215km). SFPL estimates around 150 trucks per day to ply for transportation of finished products. The plant design included a truck parking facility within the plant premises to avoid traffic congestion. SFPL will develop and implement transport management and monitoring plan, as part of the facility ESMS, for both the road/sea traffic and jetty management to comply with the local transport regulations and WBG General EHS Guidelines (ref. ESAP#4). Road and jetty transport management and monitoring plan will focus on: road safety; risk assessment and management; vehicle and sea faring vessels related practices including ensuring proper berthing, parking, loading and unloading; verification of vehicle roadworthiness; vehicle driver and vessel’s pilots related practices including training, fitness to drive/sail and driving/sailing behavior; proper journey management plan; driving/sailing hours (and prior communication to the fishermen operating along the route); GM in case of concerns with road or vessel transportation; GBVH aspects; and questionnaire/checklist assessment for road transport monitoring.
Community health and safety. Since the project is located within an industrial complex, no significant additional impacts on the health, safety and security of the local community are expected. SFPL has assessed, as part of ESIA, the risks of GBVH perpetrated by workers and/or truck drivers who will be interacting with local communities; any complaints related to GBVH will be addressed through the community GM. Additionally, SFPL will develop and implement training program for drivers which among others will include awareness on GBVH issues (ref. ESAP#4). SFPL will have a parking space for approximately 100 trucks along with relevant facilities (rest room, toilets etc.) for the drivers to reduce the risk of truck drivers' interactions with the community.
Security Personnel. The proposed facility will have its own security workers (contracted through third parties having proper licenses) who are unarmed and also trained in emergency response. No security-worker-community conflict has been reported yet in Samuda Group’ operations at the site. SFPL will adopt a security management plan, as per IFC PS4 (ref. ESAP#4).
PS 6: Biodiversity Conservation and Sustainable Management of Living and Natural Resources
The project will be located within the Coastal Plains of Bangladesh Ecoregion. The location of the crushing plant is within a modified area on the eastern edge of the Ganga-Meghna-Brahmaputra estuary. The project is located within the Ganges-Brahmaputra-Meghna Delta Important Bird Area (IBA) which has been identified for migratory waterbirds and shorebirds, including the Bar-headed Goose (Anser indicus), IUCN LC and Spoon-billed Sandpiper (Calidris pygmaea) IUCN CR. The estuarine area, adjacent to the crushing plant, is within the Coastal Northern Marine Mammal Area which has been identified for the Irrawaddy dolphin (Orcaella brevirostris) IUCN EN, Indo-Pacific finless porpoise (Neophocaena phocaenoides) IUCN VU and Indo-Pacific humpback dolphin (Sousa chinensis) IUCN VU. The project area has been extensively cleared in 2019 of mangrove forest. Remnant areas of mangrove and mudflat habitats are present within the project’s vicinity. The jetty is in a shallow estuarine area in natural condition. A critical habitat assessment (CHA) was completed, as part of the ESIA process, for the project which did not identify any critical habitat values. Most priority biodiversity values associated with the IBA are further west of the delta, but low populations of migratory shorebirds inhabit the mudflats surrounding the project during the migratory season. Dolphin species were not identified near the project as records indicate the species’ primary habitat is 140km west of the project; however, their presence cannot be discounted. To mitigate impacts to biodiversity values, the project will prepare a Biodiversity Management Plan (ESAP#12), focusing on reducing risks to resident and migratory species as well as surrounding mangrove habitats during the construction and operation phase. Dredging and pile driving activities during construction will be managed to reduce risks to dolphins near the project. As required by IFC PS6, the project will be required to contribute to the ongoing management of the IBA.
SFPL will source agro-commodities, including soyabeans from Brazil, Argentina, and Canada through the international commodity market. Both Brazil and Argentina have high risks of deforestation (conversion of natural and/or critical habitats) within the supply chain based on jurisdictional screening using Global Forest Watch. Due to this risk, SFPL will develop and implement a Supplier Code (ESAP#13) with specific commitments for no-deforestation and conversion of native vegetation within the supply chain (in addition to commitment prohibiting child labor and forced labor and acceptable OHS practices). The Supplier Code is to be applied to all suppliers, who should maintain their own internal SC and internal risk screening platform to ensure that their soybean sourcing is compliant with commitments on no deforestation and conversion of native vegetation. Once compliant suppliers are identified, a verification process is to be established to ensure new suppliers comply with the requirements of the Supplier Code. It should be noted that most major soybean suppliers have committed to providing deforestation free soybean by 2025 in line with international regulations (and abiding to a December 2020 cut-off date).
