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
Fatima Fertilizer has established an overarching corporate Quality, Health, Safety and Environment (QHSE) and social policy defining the company’s environmental and social objectives and commitment to conduct business in a manner that promotes environmental protection and protects the health and safety of its employees and other stakeholders.
The company has established a site-specific E&S management systems (ESMSs) for the Sadiqabad plant, including relevant operational monitoring and management programs and plans. The site-specific ESMSs are aligned with national law and certified as per ISO 14001 (environmental management) and ISO 45001 (occupational health and safety management). The ESMSs are commensurate with the E&S risks of plant operations, and largely consistent with the requirements of IFC PSs.
The company identifies and manages E&S risks and impacts associated with its operations through compliance with applicable national standards and E&S regulatory permits and requirements. As part of the ESMS, the company has developed a procedure for identification of risks and impacts and process hazard analysis, to identify E&S risks as well as occupational health and safety (OHS) issues from plant operations. This procedure is consistent with national law and good international industry practices. Moreover, an annual E&S Aspect and Impact Register has been established which monitors operational activities, outlines the E&S risks of these activities, and proposes relevant pollution control measures. A Process Hazard Analysis is used to identify, evaluate, and develop methods to control significant risks associated with operations which may represent the potential for fires, explosions or release of toxic materials.
The company has established a HSE (Health, Safety and Environment) organizational structure with competent personnel. At the Sadiqabad plant, the HSE division is headed by the Manager HSEQT (Health, Safety, Environment, Quality, Training) who is supported by unit lead Health, Safety and Environment (HSE), environment lead, as well as the learning and development lead. Plant level HSE engineers and field staff ensure on the ground implementation of the company’s ESMS procedures. The HSE performance of the plant is reported to the corporate HSE division in the head office and any issues are discussed in quarterly HSE steering committee meetings.
The company's HSE compliance team at each plant conducts regular internal audits to review the effectiveness of the HSE management programs and procedures and proposes changes based on the monitoring. Third-party ISO and DuPont audits are conducted at regular intervals for continual improvement. HSE performance is monitored monthly at the plant level and quarterly at the corporate level and analyzed through HSE corporate committee meetings.
The company has an Emergency Response Manual for the project site, which includes hazards and emergency handling techniques for chemicals encountered during fertilizer production, such as ammonium nitrate, sulfuric acid, caustic soda, and nitric acid. The manual also includes procedures and handling techniques for fires, natural disasters, natural gas hazards, and radiation emergencies. Life and fire safety is well managed at the Sadiqabad plant. Fire alarms, smoke detectors, fire hydrants, and fire deluge systems have been installed. The roles and responsibilities of various team members responsible for the implementation of the emergency response procedures are well defined, and training is provided to relevant staff. Quarterly drills are conducted to evaluate the readiness level of the plant emergency response team for different emergency scenarios. The company also addresses social dimensions of emergency preparedness by incorporating considerations for vulnerable groups such as women, children and the elderly in its emergency response planning.
PS2: Labor and Working Conditions
The company has documented HR policies and procedures that are largely consistent with the national law and broadly aligned with the requirements of IFC PS2, including policies to prevent child labor, forced labor as well as harassment and discrimination. There is also a code of conduct for employees. As per ESAP#1a, the company will update its policies, and code of conduct to ensure compliance with all PS2 requirements, and national laws, by including specific references to freedom of association, zero tolerance towards gender-based violence and harassment (GBVH) and child abuse. The company will also develop a policy for retrenchment to mitigate adverse impacts on workers in case of workforce reductions. The company’s policies will apply to all direct, contracted and third-party workers.
The company has 856 direct, and 920 contracted workers at the Sadiqabad plant. A formal employment contract stating the terms and conditions of employment is issued to all workers, including contracted workers. The company works in three shifts. The workweek is five days, with eight hours a day, and overtime is paid to all employees per the provisions of national law. The company has an effective mechanism to manage and monitor third-party workers to ensure they receive their salary, overtime, and other monetary benefits in line with their contract and regulatory requirements. The company has a process of vetting third-party workers and requires that third-party workers receive terms of employment and working conditions equivalent to those of direct workers.
The company has developed a grievance policy and procedure whereby staff can raise concerns about their working conditions, salary, benefits, and other work-related concerns with their line manager, and if not adequately addressed, with the Group HR Manager. There is also a ‘Flag it’ policy and mechanism that allows both internal and external stakeholders to report any instance of ethical misconduct, financial inconsistencies, harassment, as well as non-compliance with company policies or local regulations. As per ESAP#1b, the company will improve the grievance mechanism of the plant, and make it consistent with IFC PSs including a special procedure for GBVH, discrimination and child protection complaints. The grievance mechanism for the plant will be accessible for all direct, contracted, and third-party workers. Regular training will be provided to the company’s staff, contracted and third-party workers on HR policies and grievance mechanisms (ESAP#1c).
The company provides accommodation facilities for management staff and workers at the plant. These facilities are well-maintained and broadly aligned with the IFC/ERBD Guidance Note on Workers’ Accommodation (2017). The company has also established a fully equipped medical facility at the site that provides occupational and primary health care and has provisions for emergency treatment.
Fatima Fertilizer does not prohibit workers’ right to form worker organizations. The company has a workers’ union or Collective Bargaining Agent. It holds regular meetings with union representatives and the union acts as an essential channel for voicing employee grievances to the management. A Memorandum of Settlement is signed every two years. Third-party workers are also unionized.
Fatima Fertilizer has established a contractors’ safety management system, that outlines the contractor pre-qualification requirements, contract administration, orientation and training requirements, monitoring and supervision, EHS requirements and post contract evaluation and records. In addition to this, EHS and general requirements are included in the purchase order issued to contractors and suppliers. As per ESAP#2, the contracts with third parties will be improved to include non-discrimination, equal opportunities, gender-based violence and harassment, and child protection clauses, access to grievance mechanisms, rights to form and join workers organizations.
To identify and manage suppliers’ risk in alignment with the requirements of IFC PS2, the company will develop a supply chain management system (ESAP#3). The supply chain management system (SCMS) should include as a minimum i) a procurement policy and supplier code of conduct that addresses child labor, forced labor and significant safety issues as per IFC PS2; ii) inclusion of contractual clauses requiring suppliers’ compliance with the code of conduct; iii) a verification process to ensure new suppliers have the policies and procedures in place to meet requirements of the code of conduct; iv) a communication strategy to inform suppliers about the code of conduct; and v) a formal process for supplier engagement, remedy or disengagement in case non-compliances that are not addressed.
The Sadiqabad plant has established an OHS management system per ISO 45001, and received excellence in DuPont Process Safety Management (PSM). Current Lost-Time Injuries (LTIs) are far below international industry benchmarks.
Fatima Fertilizer School & College (FFSC) is part of the company, and built inside the restricted access Sadiqabad plant’s township, exclusively for children of its employees. The FFSC has a developed Service Rules for its employees, as well as an anti-harassment and bullying policy. All permanent schoolteachers are considered the company’s employees. As per ESAP#4a, FFSC will develop a policy on child safeguarding and protection, Code of Conduct, and grievance mechanism clearly addressing child safeguarding and protection. Regular training will be provided to school staff and students on these topics (ESAP#4b). In additional regular emergency drills will be conducted in the school.
PS3: Resource Efficiency and Pollution Prevention
Resource Efficiency Energy and Material Efficiency Projects: The project is
powered by captive natural gas co-generation steam and power units. The company monitors the consumption of water and electricity and other material and resource inputs. The company is adapting the Energy Star System under ISO 50001 certification and working on different energy conservation and process optimization improvements to decrease use of electricity. There are also initiatives to reduce water usage. The company is guided by the Alliance for Water Stewardship (AWS) Standard 2.0 to understand water dependences and impacts, mitigate operational water supply issues, and protect water resources in use.
GHG Emissions:
The company monitors and quantifies the annual generation of greenhouse gases. According to the Annual Report 2023 , 1,166,867 (tons CO2eq per annum) of greenhouse gases were produced from Sadiqabad plant. A selective catalytic reactor has been installed on the nitric acid plant to capture emissions of oxides of nitrogen (a greenhouse gas). This clean development mechanism at the nitric acid plant in Sadiqabad captures approximately one million tons CO2 equivalent per annum (https://cdm.unfccc.int/Projects/DB/RWTUV1322686352.38 ). The company is working to reduce GHG emissions through a reduction in energy usage, increase in energy efficiency, improvement in recovery systems, and optimization projects as part of a five-year Energy Conservation Road Map.
Air Emissions and Ambient Air Quality: The Sadiqabad plant manufactures urea, NP and CAN fertilizers. As part of the plant-level ESMS, the company performs monthly air emission monitoring. This includes monitoring of process stack emissions and co-generation unit combustion processes. Parameters measured include oxides of nitrogen, sulfur, carbon, and particulate matter (PM). A certified and accredited third-party laboratory conducts quarterly monitoring of process air emissions, and compliance reports are submitted to the relevant government department. Continuous process air emissions monitoring is conducted at the nitric acid fertilizer plant in the Sadiqabad plant. Ambient air quality is monitored once annually, and complies with local regulatory requirements. Monitoring results show that stack air emissions are largely compliant with applicable national air emission standards. However, some parameters are not monitored at the plant in accordance with WBG EHS Guidelines for Nitrogenous Fertilizer Production (2007) and WBG EHS guidelines for Phosphate Fertilizer Manufacturing (2007) (for instance ammonia from urea plant). Hence, as per ESAP #5a, the company will augment its air emission and ambient air quality monitoring program in line with WBG requirements, and perform process air emission monitoring in line with this program.
Water Usage: Water required for operations at the Sadiqabad plant is sourced primarily from the canal and underground water. This water is pre-treated and then used as process water and cooling water. The company is implementing measures to reduce water usage, as part of its sustainability strategy.
Wastewater Treatment: The Sadiqabad plant manufactures urea, CAN and NP. The wastewater generated from the urea and ammonia facilities is treated in an on-site industrial wastewater treatment plant to comply with national effluent regulatory requirements. The treated effluent is conveyed to a government-operated water drainage system. A comparison with WBG Guidelines for Nitrogenous and Phosphate Fertilizer shows that some parameters such as total nitrogen are not monitored at the plant. As per ESAP#5b, the company will improve its effluent monitoring program as part of its ESMS to bring it in line with WBG requirements. The wastewater which cannot be treated to meet local regulatory requirements at the plant is discharged to geomembrane-lined evaporation ponds for sedimentation and natural evaporation. A system of groundwater monitoring wells has been established around the evaporation ponds in line with national standards and the company performs regular monitoring of groundwater quality to identify potential leakages. No ammonia or NOx contamination has been observed during the groundwater monitoring.
Noise Management: Workplace monitoring indicates that the noise levels in certain areas of the plant are higher than the maximum permitted in the WBG EHS General Guidelines. Ear plugs are mandatory PPEs required to be worn by all workers at the plant. Additionally, ear-muffs are provided in area of high noise impacts. An independent and certified company monitors ambient noise at the Sadiqabad plant. Results indicate compliance of ambient noise with national regulatory requirements and WBG General EHS guidelines.
Waste Management: The company has developed hazardous and non-hazardous waste management procedures as part of the ESMS. The procedure identifies the different types of hazardous and non-hazardous waste generated and provides guidance for their safe handling, storage, and disposal. All company personnel working on activities that generate hazardous waste are provided with relevant training. Non-hazardous waste is collected by contractors for disposal or recycling. Hazardous waste is managed and disposed of by government-approved certified contractors.
PS4: Community Health, Safety and Security
The Sadiqabad plant site is located on the outskirts of the Sadiqabad city. Four small villages are located within a five km radius of the plant, and there is one residential community approximately 1 km from the evaporation pond. The nearby communities have been identified by the plant E&S teams, and the Community Awareness and Emergency Response (CAER) Program is in-place to educate the surrounding community about industrial hazards and emergency response procedures. The plant has carried out a Hazard and Operability Analysis (HAZOP) study which included mapping of impact on nearby communities during different emergency scenarios. Further, Layers of Protection Analysis (LOPA) study was also carried out to establish controls for different levels of risks. As per ESAP #6, the company will develop an off-site emergency and response plan to address risks from company operations to nearby communities, including a schedule for community briefings and trainings.
Transport is outsourced to a third-party transport company. As part of the ESMS, Fatima Fertilizer has developed a Driving Policy and Driving Safety Guidelines to promote safe driving by employees and contractors. As per ESAP #7, the Company will prepare a Transport Management Plan for the Sadiqabad Plant in line with GIIP to address risks and possible emergency scenarios during transportation.
The Company has armed security personnel provided by third-party contractors supervised by a security manager who is a company employee. The Company has prepared a Security Management Plan that summarizes security rules, procedures, and roles and responsibilities for each plant. Regular training is conducted for the security workers, including on the appropriate use of force, and will incorporate GBVH and child protection.
