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
E&S Policy:
BML has a corporate Code of Conduct (CoC) & ethics, and corporate policies on environmental management and biodiversity, human rights and social accountability, and OHS, covering all the company’s operations.
Identification of E&S Risks and Impacts Assessment:
The company identifies and manages E&S risks and impacts associated with vessel and port operations to ensure compliance with applicable national E&S requirements, and compliance with international standards such as those related to IMO, MARPOL, ISM and ISPS, The company has procedure for risk management, including risk identification, analysis, evaluation and register, reporting and monitoring. The risk register covers, office operations, transport and stevedoring, cargo storage, etc. The shipping routes for the new vessels are domestic only and none of the routes are subject to requirements related to Marine Protected Areas (MPAs), Particularly Sensitive Sea Areas (PSSAs), or the National Maritime Safety Authority (NMSA).
E&S Management System and Program:
The company has a corporate safety management system (SMS) in compliance with the ISM Code requirements that includes corporate E&S policies and procedures on risk identification, ERP, and monitoring and review that are applicable to all the Company’s operations.
All the larger multipurpose vessels and some of the tugs and barges are classified by recognized multinational maritime classification society confirming the ship’s safety management compliance with ISM Code. LCTs are classed by PNG’s NMSA and operates in accordance with the national legislation and IMO conventions.
As part of ESAP1, BML will update and expand the scope of the corporate SMS to develop an ESMS aligned with IFC PSs and relevant World Bank Group (WBG) EHS Guidelines. The update will include specific procedures with respect to shipping route plans and protection of marine mammals, MPAs and other internationally recognized areas for biodiversity importance. It will also include key performance indicators (KPIs) for monitoring the management of all significant E&S aspects.
Organizational Capacity and Competency:
BML has a dedicated EHS management team with 16 corporate staff headed by a EHS Director, together with a Quality Manager are in charge of risk identification and evaluation. At least one OHS manager in charge allocated at each port facility. On each vessel, the safety and technical manager is responsible to taking measures to ensure EHS management at all times, in cooperation with the corporate vessel safety and technical department.
Emergency Preparedness and Response:
As part of corporate SMS, BML has a documented ERP (ERP) for serious injury, fire emergencies, natural disasters, oil spillage, chemical leakages, etc. The procedure indicates methods of communication, incident reporting, timeline, and persons in charge.
Monitoring and Review:
The company monitors all operations in accordance with KPIs such as resource efficiency (e.g. water consumption, GHG emission, wastewater reduction, waste reduction), accident frequency and severity, provision of trainings, number of grievances etc. The KPIs are reported on a monthly basis to the corporate EHS management team. The company has monitoring and reporting procedures, including critical incident management, work/minor incidents management, and procedure for handling of nonconformities. The company has an internal audit procedure to verify the safety and pollution prevention activities to meet the national and international requirements including audit plan, audit checklist, and reporting.
PS2: Labor and Working Conditions
As of 2023, BML has 825 employees including about 130 contract workers. The land-base staff gender split is ~85% male and ~15% female. The company has an all-male seafarer crew. All the BML’s employees and seafarers are employed direct and recruitment through recruiting agents.
Human Resources Policies and Procedures:
The company has an HR Manual applicable to all workers, including office, port, and ship crew. The Manual includes working hours, salary, leave, health care coverage, and termination. The Manual for seafarers is in compliance with ILO’s Maritime Labour Convention (MLC).
BML’s HR Manual and policies is aligned with IFC PS2 and local labor laws, and include aspects related to human rights and social accountability, the prohibition of child or forced labor and human trafficking, anti-discrimination, and gender-based violence and harassment (GBVH). The Manual also recognizes freedom of association and collective bargaining rights.
Working Conditions and Terms of Employment:
All employees are provided with a written appointment letter explaining their employment terms and conditions. The company monitors compliance with minimum wage, working hours, and benefits requirements, as well as the minimum age for employment to be in line with local laws and ILO standards.
Accommodation is provided for expat and key local staff at company compounds or rental accommodations, which have access to utilities such as power and water and internet connection for land-based staff. The vessel accommodation design follows MLC’s requirement.
As per ESAP 2, BML will review and update the HR Manual and worker’s contracts in line with prevailing national laws, MLC, and IFC PS2 requirements.
Worker Grievance Mechanism:
The company has a worker’s grievance handling procedure and a whistleblower policy. The procedure and policy indicate grievance lodging, investigation of reportable conduct, and protection of whistleblowers. The procedure covers employees and contractors There are no significant workers’ grievances, disputes, or court cases reported to date.
As per ESAP3, BML will update its workers’ grievance procedure for its employees and contracted workers in line with IFC PS2. The workers’ grievance procedure will, among others, include (i) measures to address GBVH grievances, and (ii) allow for anonymous grievances.
Occupational Health and Safety:
The company has documented OHS policies and procedures as part of its SMS, including on hazards and risks identification, provision of safe equipment, injury management, fatigue management, and safe hygienic workplace. BML has developed corporate safety procedures applicable to ship operations in line with international standards.
Corporate wide OHS trainings are provided to all employees on various safety related topics including safety culture, personal protective equipment (PPE) usage, falls and slips, chemical safety, heat, electrical safety, fire safety, safe driving, machine safety, etc. All new employees are required to receive induction training. All the crews must be trained and certified as per the standards of training, certification, and watchkeeping (STCW) for seafarers’ and to fulfill safe staffing certification on the vessel.
Workers Engaged by Third Parties:
BML’s internal audit team regularly performs on-site audits including confirmation on contractor’s safety and legal labor compliance. The construction of the new vessels will be supervised by the company’s technical team as well as representatives of the vessel’s classification society.
Supply Chain:
The company has a sustainable procurement policy, supplier code of conduct, including supplier requirements and risk assessment covering forced/child labor, OHS, and the environment.
PS3: Resource Efficiency and Pollution Prevention
Resource Efficiency:
BML’s E&S policies and procedures include energy conservation, minimizing greenhouse gas (GHG) emissions, and quantifying GHG emissions from the vessels and company’s operations. This includes measures such as efficient logistics planning; electricity, water and fuel use saving; and waste minimization. The company has an international energy efficiency compliance certificate by a recognized third party. The new vessels are expected to be 10% more fuel efficient than existing vessels. The estimated GHG emissions from the project vessels are estimated to be about 1800 tons CO2 eq/year.
Air Emissions and Ambient Air Quality:
Onboard vessel electricity is generated from fuel. The company has a control procedure for air pollution emission by ships and a international air pollution prevention certificated by a recognized third party, that includes confirmation that sulfur content does not exceed the limit value of 0.5%. For the port and office operations, main power is supplied by the national power supply company. There are back up diesel generators at each port.
Water and Wastewater:
Water is supplied mainly by the local water utility. The company implements water pollution control measures, including sewage management and ship ballast water management, which will be applied to the project vessels. For the vessels, bilge and other ship-generated wastewater treatment measures are consistent with MARPOL and local regulations. All new vessels will have oil/water separators, as well as onboard sanitary sewage treatment facilities, and will obtain an International Sanitary Sewage Pollution Prevention Certificate (ISPP). Septic tanks are used at all port and office operations.
Waste and Hazardous Material Management:
The company has a waste and pollution management policy, along with procedures for managing general and hazardous waste, as well as hazardous chemicals. These procedures cover the transportation, storage, use, and disposal of these substances, and include labels and safety data sheets for hazardous substances. Dangerous Cargos are carried on vessels in compliance with IMO The International Maritime Dangerous Goods (IMDG) code. BML has procedures in relation to the prevention of pollution by waste from ships in line with MARPOL. The company has a documented mechanism to control harmful anti-fouling systems on ships in compliance with IMO requirements. All the waste is collected for disposal by authorized public service external agencies or port authorities specialized in each type of waste.
Per ESAP4, BML will develop a corporate policy on ship recycling/dismantling that complies with international requirements such as the Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships.
PS4: Community Health, Safety and Security
The BML operations do not significantly impact on communities, given that they operate offshore and in port areas where community access is restricted.
Community safety management:
BML has policies and procedures related to vehicle management and safety driving, including safe driving, vehicle maintenance, compliance with drive regulations, accident reporting, and prohibition of alcohol or drugs.
The corporate SMS includes management measures to mitigate the risk of diseases during ship operations. BML has a strict shore-leave policy intended to minimize interaction between crew and the public.
Security Personnel:
BML’s operation management is in compliance with ISPS protocol. The company does not hire any armed security guards for its operations.
