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
Kioo has established an Integrated Management System (IMS) that covers quality, environment, and safety aspects, and includes an E&S policy. The IMS was certified as per ISO 9001:2015; ISO 14001:2015, ISO 45001:2015 and FSCC 22000:2013. The IMS is broadly aligned with IFC PSs requirements and is commensurate to the E&S risks and impacts of Kioo’s operations.
Identification of E&S risks and impacts for any expansion is done through Environmental and Social Impact Assessment (ESIA) process that includes compliance with permitting requirements. The Company as part of the IMS has established a Hazard Identification and Risk Assessment procedure (HIRA) that is used to identify E&S risks and impacts associated with compliance with applicable national laws and regulation; E&S regulatory permits; occupational safety and health (OSH) risk assessments; internal and external E&S audits, including customer audits. The Company will for the expansion of the Dar es Salam facility perform the E&S impact assessment (ESIA) and cumulative impact assessment in line with the requirements of IFC Performance Standards (PSs) (ESAP#1).
The E&S organizational structure of the Company is headed by the Health, Safety, and Environment (HSE) Manager, who is supported by two safety officers. Additionally, each head of department is required to organize proper HSE management within its department. The HSE manager reports directly to the General Manager. At the silica sand quarry, HSE is the responsibility of the mine manager and the mine engineer.
Kioo has dedicated Emergency Preparedness and Response Plans (EPRP) for the factory and quarry site. The EPRP details the roles and responsibilities for implementation of the plan, the major emergencies such as fire, furnace leakage, release of gas, natural disasters among other, the different procedures to be followed in each situation, the resources required such as spill kits and extinguishers, drills to be carried out and communication with external stakeholders.
As part of the IMS, the Company monitors KPIs such as accidents, work related loss time injury (LTI), hydrocarbon spills, fire incidents, emergencies, water used and recycled, energy used, solid and hazardous wastes generated, among others. Performance of these KPIs is earmarked against set targets and monitored monthly and reported to the senior management quarterly.
To meet its future raw material demand, land acquisition may be required given the expansion of the production capacity. All land acquisition has been and will be performed through ‘willing buyer and willing seller’ process. Going forward, Kioo as part of the IMS, will develop a land acquisition procedure in line with the requirements of IFC PSs that will require it to screen E&S risk such as resettlement, conversion of natural habitat, impact on ecosystem services among others prior to any acquisition and additionally require an ESIA and based on outcomes site specific E&S management plan prior to start of sand quarry operations. Kioo will also update its stakeholder mapping and consequently its stakeholder engagement plan (SEP) to account for engagement of stakeholders relevant to management of land acquisition process and related risks (ESAP#2).
As part of its sand quarry site closure procedure, Kioo is also undertaking rehabilitation of the quarry areas. Around 45% of the extracted quarry area is already rehabilitated by backfilling and planting of several types of fruit trees and other local species. The rehabilitation program is an on-going effort for which the Company has set-up a nursery that produces 6000 tree seedlings annually.
Kioo has an economic initiative with local community members whereby the community negotiated with the company to allow them to work as sand loaders at the sand mines for payment on a piecemeal basis, namely on volume of sand loaded onto the trucks. The company makes payments to the community as a group at an agreed rate per load of sand while the community members individually decide on when and how they would undertake the tasks. The company will: (i) strengthen the oversight of community members during their work on quarry site to ensure that they completed onboarding and site specific EHS training and use adequate PPE(ii) enhance its record keeping processes to ensure that all payments made to the community are formally recorded for internal monitoring if necessary. (iii) incorporate capacity building and training of community members working on these premises through trainings and toolbox talks on individual and company requirements and responsibilities on OHS, applicable financial management skills including record keeping on payments made to each individual community member (ESAP #3).
PS2: Labor and Working Conditions
At the time of the appraisal, the Company had approximately 600 direct full-time employees with 18% female. Around 60 third party contracted workers are employed for cleaning and security services.
Kioo has a documented HR manual that is consistent with the national law and applies to all direct employees. Each worker receives a written contract that describes the working conditions and terms of employment. Employees are required to work 45 hours per week normally with a maximum of 60 hours per week inclusive of overtime. The factory operates 24/7 for three shifts of 8 hours per day, while the mine sites operate 6:00am to 5:00pm. Any excess hours are accounted as overtime with accordance to the rates set in the voluntary agreement with the Tanzania Union of Industrial and Commercial workers (TUICO).
Kioo has a documented grievance mechanism for workers, where grievances are collected through head of department, HR manager and suggestion boxes and investigated by the HR team. Records of all grievances are kept, and period reports are made to the management. The HR manual further includes policies for right to freedom of association, collective bargaining, anti-harassment and anti-discrimination commitments, prohibiting engagement of child, forced or bonded labor practices including in the supply chain consistent with national labor laws and IFC PS2 requirements.
The Company has a supplier code of conduct which requires from its suppliers to perform their operations in an ethical and legal manner, and taking in consideration OHS aspects. Additionally, the Company has a child labor policy which applies to all supplier and sub-contractors.
OHS risk assessment has been undertaken for all the operations including the sand quarry site and is reviewed and updated regularly. With the forthcoming expansion, Kioo will undertake an overarching and detailed OHS audit and process safety review of the whole facility prior to commissioning of the new production line (ESAP#4). Kioo 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. Training plans are developed at the start of the calendar year and training is provided to all direct and indirect workers. In 2022, the Company did not record any major accident or lost injury time.
Construction of the new furnace will be carried out by contractors. Kioo estimates that around 500 workers will be required for construction and around 100 workers will be required during operation. The majority of workers will be sourced locally and, if a specific technical skill is required, workers from other regions will be brought. A contractor management procedure is available and will be implemented during construction.
PS3: Resource Efficiency and Pollution Prevention
The main source of energy for the Kioo plant is natural gas and the plant also has with back-up generators and a diesel storage tank (35,000 l capacity) that can be used in case of emergencies. Annually, Kioo consumes around 27,640,000 m3 of natural gas and around 54,854 MWh of electricity. The upcoming expansion is expected to increase the natural gas consumption by 6,561,000 m3 and electricity by 18,000 MWh. Diesel consumption will increase from around 170,000 litres to 222,000 litres per month due to increased transport. No changes are expected in storage capacity of diesel and natural gas supply pipeline. The Company also has a 28,000l capacity HFO storage for emergency in the case of interruption on natural gas supply.
The gross GHG emissions (scope 1 and 2) are around 57,420 tCO2/year and expected to increase by an additional 33,991 tCO2/year. Kioo is currently working on a program to increase its cullet share to 50-60%, which will reduce the energy intensity and GHG emissions by 7-8% from the furnace.
The main point sources of air emissions include mainly furnace emissions. A third-party specialized and licensed laboratory has been hired by the company to perform regular monitoring of point source air emissions. Monitoring results indicate compliance with applicable national legal requirements and air emission levels provided in the World Bank Group (WBG) Environmental Health and Safety (EHS) Guidelines for Glass Manufacturing (2007). Upon commissioning of the new glass manufacturing line, Kioo will expand the monitoring of the point source air emissions including the third glass manufacturing line funded under the project and report to IFC monitoring results.
The water use relates to cooling and cullet cleaning. The plant uses four boreholes, which supply approximately 100,000 m3 of water annually. The water demand will increase by 52,000 m3 with the installation of new glass manufacturing line, however, the existing boreholes are expected to meet this additional water demand. Water used for cooling is recycled within the system. Water is also used at the cullet cleaning plant and is recycled within the process via a sedimentation pond. Process wastewater is discharged after primary treatment into a municipal sewer system for further treatment. Monitoring results of the wastewater quality indicate compliance with the national legal requirements for discharge into the sewer systems.
Sanitary wastewater from accommodation is collected in a septic tank and removed via sewer trucks on a regular basis. Stormwater generated on the site is collected via on-site drains to an oil-water separator before being disposed to the national sewer system. The on-site diesel storage tank is bunded by concrete wall and the fueling station of the trucks has concrete floors and is equally bunded for any spills.
The Company as part of the IMS has waste management plan. The plant generates mostly paper, wooden pallets, broken printed bottles and used oil as wastes. Glass waste is recycled within the process itself. Additionally, waste is sorted at source and disposed of through licensed waste recyclers where possible.
At the sand mines, mining is done manually, hence limiting noise impacts. Dust emissions are minimal since coarse sand is mined. The mined sand is washed and sieved in an automated electrical sand plant via a wet process. The water is recycled within the process after going through a sedimentation pond.
PS4: Community Health, Safety and Security
The factory is located in the industrial area of the Dar-es-Salaam port. The sand quarry sites are located near communities, however since mining is done manually and up to a depth of 1-2 m, minimal noise and dust impacts are expected to the communities. Furthermore, the mines operate only between 06:00 am to 05:00 pm, avoiding any night noise nuisances. The mine sites are also delimitated with peg and the on-site security team constantly guard the boundaries to ensure there is no unauthorised entry.
Kioo’s glass manufacturing facility is equipped with fire alarm, passive and active fire safety systems in line with the national building and fire safety codes. The facility is also regularly audited by qualified and certified fire safety professionals in line with national legal requirements. The Company organises regular induction and refresher life and fire safety trainings to its workers.
Transport safety is managed via the implementation of no-night driving, zero tolerance for alcohol, an In-Vehicle Monitoring System (IVMS), journey management, defensive driving training, daily check of all trucks entering the premises and only one-driver policies. The logistics team monitors the movement of all trucks in real time. No major road accidents have been reported. As part of the IMS, a transport related accident investigation procedure is in place, which applies to all Kioo owned and contracted vehicles.
Due to the remoteness of the sand quarry sites, Kioo utilises National police armed security personnel to manage any security risk. A group of 10 armed security personnel patrol the site regularly. Additionally, Kioo has 2 unarmed security personnel at the mine site. The Company has a security management plan in line with the requirements of Voluntary Principles on Security and Human Rights. Security risk assessment is carried out annually and refresher trainings to security personnel is also regularly provided.
