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
OCP has a group-level ESMS structure aligned to the requirements of ISO 14001:2015 for Environmental Management Systems. Each site whether operational or under development, is required to develop and implement an ESMS following this framework. The Project Consultant has developed an HSE Project Execution Plan which incorporates OCP policy requirements and sets out its own ESMS to be implemented for the construction phase. The Project Consultant also has a set of minimum HSE requirements, that were included in the request for proposals and in the contracts for the construction contractors. The OCP and the Project Consultant requirements will be referred to as the project requirements. The sections below outline OCP’s and the Project Consultant’s ESMSs as applied to the project during the construction and operations phase.
Policy: OCP has in place a sustainability strategy, supported by several group-level policies (last updated in April 2020) including sustainability, environmental management, and occupational, health and safety (“OHS”). These policies apply to all OCP sites and facilities including this project and are publicly disclosed on OCP website: https://www.ocpgroup.ma/sustainability/policies-and-standards.
Identification of Risks & Impacts: OCP has undertaken an EIA for the project in accordance with Moroccan legislative requirements and is in line with IFC PS requirements. Considering that the pipeline will be buried, the main impacts are associated with the construction phase and include potential contamination of soil and water resources, air and noise pollution, waste management, increased traffic during construction and biodiversity aspects. Furthermore, in line with project requirements, construction contractors carry out a HSE risk assessment for construction activities, identify suitable control measures and develop and maintain a risk register.
The Wave II site is located within the Jorf Lasfar industrial complex. No land acquisition will be needed, and the nearest area of biodiversity importance is located 2 km away. As with the existing units, brine water will be blended with source seawater to dilute salinity to a level that is safe for direct discharge (=40g/L) without need for further diffusion. The blended seawater is used for the industrial cooling system at the complex and ultimately discharged into the sea after cooling. Wave II is expected to use the existing intake, outfall/ basin, and discharge infrastructure used for Wave I, subject to the findings of a feasibility study. OCP will undertake an ESIA for Wave II in compliance with the IFC PS requirements and WBG EHS General and Water and Sanitation Guidelines. This will include an assessment of impacts to the marine environment, and a Cumulative Impact Assessment. (ESAP# 1).
Management Programs: The project EIA includes a framework EMP, which provides the organizational structure for E&S management, mitigation measures, and monitoring requirements applicable to the construction and operation phases of the project and is aligned with the WBG General Environment, Health, and Safety (“EHS”) Guidelines. Based on this, the construction contractors have developed a construction Environmental Management Plan (“C-EMP”). This plan is supported by several associated “sub” plans including: emergency preparedness and response; health and safety; waste management; and traffic management.
Organizational Capacity & Competency: Both OCP and the Project Consultant have strong HSE and social management capabilities. For the construction phase, the Project Consultant has a construction management team covering the three sections of the pipeline route, where construction works are taking place in parallel. Each section has a HSE Manager, supported by a team of HSE personnel to monitor, act and report on the activities of the construction contractor. Additionally, as required by the contract, the construction contractors have counterpart HSE personnel including managers and supervisors. As per the project requirements, the contractors implement an appropriate HSE induction and ongoing training program for all workers on site. OCP also has a lands management team that was involved in securing access to the corridor and is involved in managing land related aspects including engaging with communities.
Emergency Preparedness & Response: OCP has a corporate standard on emergency response planning. All facilities in Morocco have a Crisis Management Plan in place. In line with the project requirements, the construction contractor has an Emergency Preparedness and Response Procedure (EPRP) in place for all the works sites.
Monitoring & Review: As part of its project ESMS, the Project Consultant has outlined specific processes to monitor and measure the effectiveness of their and their contractor’s management plans / programs as well as compliance with relevant Moroccan legal requirements. the Project Consultant reports monthly on a set of Key E&S Performance Indicators (“KPIs”) based on information derived from construction contractor reporting requirements including, the contractor progress reports and on-site inspections.
PS2: Labor and Working Conditions
The project is expected to employ up to 600 workers at the peak of the construction phase. Most of these workers will be employed by the construction contractors and are being sourced from Morocco. Up to 100 skilled migrant workers have been sourced from India for specialized pipe welding work. Workforce needs during the O&M phase of the project are expected to be up to 100 workers. Both the contractors and the OCP have HR teams responsible for management of the workforce during construction and operations.
OCP has publicly disclosed corporate policies that describe the Company’s commitments to freedom of association, elimination of all forms of forced labor, abolition of child labour, elimination of discrimination in employment. OCP also has a Code of Conduct with a zero tolerance of violence, intimidation, bullying, or harassment and a Responsible Community relations policy aimed at conducting activities in a way that respects the dignity, rights, aspirations, culture and livelihoods of the local communities. OCP’s corporate policies and Code of Conduct are aligned with PS2 requirements and are applicable to the construction and O&M phases of the project.
All workers are issued with written employee contracts covering the terms and conditions of employment such as contract duration, wages and benefits, hours of work, overtime arrangements and overtime compensation, etc., in line with Moroccan legislation. Migrant workers are sourced and recruited by an agency but contracted directly by the construction contractors with similar terms and conditions of employment. In addition to their wages, the contractors cover all logistic, living and accommodation expenses of expatriate workers. No recruitment related fees were paid by the workers and neither the contractors nor OCP retains any identification documents. Going forward, the project will develop a Migrant Worker Policy with provisions against forced labor and human trafficking and a Sexual Harassment Policy, in line with PS 2 requirements. (ESAP # 2 and 3).
Accommodation camps to house expatriate and management staff have been constructed for each works section. The accommodation, services and welfare facilities reviewed by IFC are consistent with PS2 requirements and in line with the IFC/ EBRD guidance note on Workers Accommodation: Process and Standards.
Grievances at OCP are managed through channels designed to raise concerns, seek resolution and provide feedback. Going forward. the project will develop and implement a Labor Grievance Procedure accessible to all workers including the expatriate workers for both the construction and operations phases, in line with PS2 requirements. (ESAP # 4).
Occupational Health and Safety: Key OHS risks for this project include slips and falls, potential hazards from on-site moving machinery, heavy load lifting, and traffic accidents, and safety issues related to pipeline assembly. To manage these risks, the construction contractor has in place a Health and Safety Plan in line with IFC PS2 and relevant WBG EHS Guidelines. The plan covers key aspects such as: Job Safety Analysis and Risk and Hazard Assessment and associated management procedures for work activities, Protective Personnel Equipment, Permit to Work System, OHS signage; training; incident recording and investigation, etc. The contractors have also deployed a suitable number of appropriately qualified supervisors to manage the OHS risk. At the time of appraisal, the project had achieved a zero Lost Work Case Frequency rate since the start of construction. An OHS plan will also be developed for the O&M phase by the project (ESAP # 5).
PS3: Resource Efficiency and Pollution Prevention
Greenhouse Gases: Greenhouse gas emissions (“GHG”) from the project during construction are predominantly associated with the use of fuels such as in generators, transport of pipeline sections and on-site equipment and machinery and are expected to be less than 25,000 tones CO2 equivalent (tCO2eq/year). Energy to power the pumping stations during operations will be sourced from OCP’s renewable energy program.
Water Consumption & Availability: For the construction phase, it is estimated that approximately 1600 m3/of water, would be required for the duration of civil works and is brought in using bowsers from municipal water sources. Community water supplies are not affected. Water use during operations will be limited to domestic needs.
Pollution Prevention – Waste: The EIA identified both non-hazardous solid wastes, such as paper, wood, plastic, scrap metals and glass, and a limited quantity of potentially hazardous materials such as transformer oils, lubricants, paints, etc. The overall volumes of both solid and hazardous waste generated by the project during both phases are expected to be low. The contractors have developed a Waste Management Plan for the construction phase, aligned with local legal requirements, the EMP, and IFC PS3 and WBG EHS general provisions.
PS4: Community Health, Safety and Security
Community Safety: Construction activities involve the excavation of 2m deep trenches along the RoW, into which the pipe segments will be placed. At the time of the appraisal, most trenching activities had been completed, and the open trenches secured by steel frame barriers on one side and an embankment made up of excavated earth on the other. Access to pathways and crossings across the RoW are maintained by the contractor, with safety signage clearly displayed. These measures are sufficient for protection against people and animals falling into the open trenches.
Road Safety & Traffic Management: The transportation of pipe segments and equipment to the RoW represents the key safety risk in relation to the other road users and communities adjacent to the roads being used. The project has developed a Traffic Management Plan for the delivery of material and equipment from the port to the RoW. At the time of appraisal, most of deliveries had been made without any significant safety incidents.
Security Personnel: No security personnel are used to secure the pipeline construction route. The trenches are fenced off on one side and protected by an earth embankment made up of excavated earth, on the other side. Access is maintained for established pathways and crossings. These measures are sufficient for protection against people and animals falling into the open trenches. The pipeline will be buried, and the RoW rehabilitated, and access re-opened after construction. The only sites that will be fenced and access controlled will be accommodation facilities during construction and the start of the pipeline route within the Jorf Lasfar facility. Security and access control to these sites is governed by OCPs’ security management policy and provided on a 24-hour basis by a third-party security company retained by OCP. Security guards are not armed.
PS5: Land Acquisition and Involuntary Resettlement
The temporary 20m-wide laydown and site access corridor along the RoW/ road reserve mostly passes through land classified as Melk. Melk land in Morocco is private, titled freehold land with the right to exclusive possession, use and sale. This is the main land tenure system of rural, agricultural lands in Morocco. Based on an assessment undertaken by the OCP lands department, the establishment of the corridor has resulted in temporary occupation of 312.5 ha of such land, made up of 1946 plots. Most of the land within the corridor is marginal with limited economic use and therefore impacts to livelihoods are not expected. There has not been any physical displacement. The plots are being leased from owners for up to a period of 5 years or for the duration of the construction phase, based on a lease value established by the provincial administrative evaluation commission. If there are any isolated crops or trees on the corridor impacted, these are compensated for using rates established by the commission. Following the completion of works, the site will be rehabilitated and handed back to the owners. OCP shall review the crop/ tree compensation rates against the replacement value criteria to identify gaps and develop an action plan to close any gaps consistent with PS 5. (ESAP # 6).
PS6: Biodiversity and Sustainable Management of Living Natural Resources
Based on the Biodiversity Assessment commissioned by OCP in 2023, most of the existing RoW/ road reserve passes through agricultural areas classified as modified habitat. A small stretch of the pipeline RoW crosses the Basse Oum Er Rbia, which is designated as a Key Biodiversity Area (KBA). In total, less that <1 ha of the total area of the RoW has been classified as Natural Habitat that will be directly impacted. This includes the bed of the Oum Er Rbia and its banks, several clusters of Acacia gummifera and Chamaerops humilis. The surveys carried out as part of the assessment recorded a small number of the European Eel (Anguilla anguilla), classified by the IUCN Red List as Critically Endangered. This species is widely distributed in marine, coastal, brackish and freshwater habitats of Europe and northern Africa with a spawning area in the Sargasso Sea. The Oum Er Rbia is unlikely to support a globally, or nationally significant population of this species and the RoW crossing is therefore not classified as Critical Habitat according to the IFC PS 6 requirements.
OCP has developed a biodiversity related construction method statement to manage construction related impacts on the areas identified as natural habitat and the crossing of the Basse Oum Er Rbia. The statement includes measures to reduce sediment release, installation of mesh nets up stream of the project site and monitoring requirements, appropriate to the nature of impacts and in line with PS6 requirements. OCP will also develop a habitat rehabilitation and restoration method statement that includes target condition criteria and post construction monitoring and adaptive management and a programme to support the conservation objectives of the KBA. OCP will engage with the relevant organizations managing the KBA over the habitat rehabilitation and restoration method statement. (ESAP # 7).
