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.
Policy. CBC has an overarching policy defining environmental, health, and safety (HSE) objectives consistent with the IFC Performance Standards (PSs) principles.
Management System. CBC has established an ISO-certified quality management system (QMS) to address product quality issues. The company also established an occupational health and safety (OHS) Program (“Programme de Santé et Sécurité au Travail”), per national law outlining objectives, roles and responsibilities, general OHS risk management considerations, and supporting management procedures. As part of the previous investment (#40610), the company developed an E&S management system aligned with the objectives of IFC PSs. Due to the country’s contextual situation, CBC is still in the process of enhancing its ESMS with a focus on water and energy efficiency, wastewater management and improving its effectiveness.
Identification of Risk and Impacts. 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. The company has assessed operational risks related to product quality as part of its QMS. The assessment includes an overview of the occupational health and safety of workers. Nevertheless, CBC will undertake an EHS risks assessment focusing on the installation and operations of the rooftop PV and battery storage system; (ESAP #1).
Organizational Capacity and Competency. CBC has a dedicated environmental, health, and safety (EHS) officer and established a health and safety committee to oversee the implementation of the ESMS and OHS Program.
Emergency Preparedness and Response. CBC’s Emergency Preparedness and Response Plan (EPRP) prepared per national law, includes separate procedures for different scenarios such as floods, earthquakes, spills, hurricanes, medical emergencies, and fires. CBC hired a specialized contractor to augment the EPRP regarding life and fire safety measures, such as identifying emergency routes and exits, posting evacuation instructions, installing smoke detectors, and providing First Aid training to the staff. Under ESAP #2, CBC will update and strengthen the efficiency of its EPRP to address risks from the new rooftop PV and battery storage system.
Monitoring and Review. CBC’s monitoring activities focus on production data related to the volume of finished product, raw materials used (including water), quality, consumer satisfaction/complaints, and OHS incidents. As part of strengthening ESMS procedures, CBC is currently developing procedures for monitoring specific energy and water consumption and managing wastewater and waste.
External Communications. CBC has developed an external communication procedure in the context of the Quality Management System, which applies to distributors, consumers, and surrounding communities. The procedure outlines steps for the company to receive information from distributors and consumers through questionnaires, surveys, and client complaint forms. It has been adapted to receive communications from the general public. Complaints can be captured through several channels, sorted, and assigned to the relevant department so corrective actions are taken and reported back to the relevant stakeholder.
PS2: Labor and Working Conditions
Human Resources Policies and Procedures. In 2023, CBC employed 504 workers, of which 47 were women, with a turnover rate of 1%. CBC occasionally hires 6-7 seasonal workers on 3-month contracts depending on production needs. Protection of the workforce in Haiti is detailed in the national Labor Code, which specifies the core rights and responsibilities of an employer and employees, prohibits discrimination in employment based on gender, race, age, ethnicity, religion or nationality, and describes basic terms of employment including minimum age (18 for full-time work; 15-18 if certain conditions are met).
CBC has a human resource (HR) policy compliant with national law and aligned with the requirements of IFC PS2. The company also has an internal code of conduct (CoC). This describes basic rules for employment (hiring process, promotions, working hours, leave, overtime, and salaries), rules governing absences, worker responsibilities at the workplace, including health and safety, prohibitions, rules for a respectful workplace environment, and disciplinary action. CBC ensures equal opportunity employment and does not hire workers under the age of 18. Nevertheless, CBC will augment its HR procedures per the requirements of IFC PS2 related to child labor (ESAP #3).
Working Conditions and Terms of Employment. All CBC employees have individual open-ended written contracts, with benefits according to local laws, and CBC does not restrict freedom of association. By law, there is no limit to the maximum number of overtime hours per week, but workers are required to have a day off after 6 consecutive days of work. Given the security concerns around the greater Port-au-Prince metropolitan area, CBC provides two small passenger buses to transport workers at the end of their shift from the facility to taxi stands.
Grievance Mechanism. CBC’s CoC defines workers’ grievance procedures. This procedure entails weekly meetings between management and supervisors who discuss any concerns raised by workers. CBC has developed a template for recording grievances and a log for tracking them. Nevertheless, CBC will enhance its internal grievance mechanism to receive and process grievances related to Gender-based Violence and Harassment (GBVH) (ESAP #4).
Occupational Health and Safety. CBC’s OHS Program provides the basis for the management of workplace OHS risks. CBC is developing a comprehensive job risk analysis to identify types of workplace hazards, the likelihood and severity of risk, and corresponding mitigation measures (substitution and engineering controls) based on job function/position.
The company established an OHS committee, which consists of 5 members and meets regularly, led by the EHS manager, who oversees the implementation of the annual health and safety plan. CBC recorded 12 non-fatal incidents/injuries in 2023, which resulted in 32 lost workdays as well as two vehicle accidents, and the Lost Time Injury Frequency Rate (LTIFR) was 9.82 lost time injuries per million man-hours, which is slightly above the benchmark for the sector (Bureau of Labor Statistics, USA) of 8.0. Nevertheless, with the development of the Job risk analysis (JRA), the LTIFR is expected to improve.
Contractor Management. As part of its ESMS, CBC is currently developing procedures to assess and manage contractors' E&S risks. As part of the ESAP #5, CBC’s will develop a contractor management plan (CMP) to address E&S risks related to contractor management, including training, job risk analysis, access to grievance mechanisms, management of child and forced labor risks and monitoring and reviewing of contractor’s EHS performance.
PS3: Resource Efficiency and Pollution Prevention
Energy and Resource Efficiency. CBC operations are powered by electricity generated on-site by 3 x 500-kW generators and 1 x 175 kW generator. It also leases from an external energy service provider. Installing the rooftop solar panels will keep existing generators for back-up power. In 2023, the total energy consumption was 4,045,345 KWh. In line with CBC’s resource reduction policy, it has installed electricity consumption meters in all production zones and is developing an energy management program.
Water Consumption. CBC monitors the Water Usage Ratio (WUR), defined as the amount of water used to produce one liter of product (L/L). The WUR is 4.4 liters per liter of product which is higher than WBG EHS Guidelines for water consumption in Food and Beverage Processing (2007). To reduce WUR, CBC will continue implementing water use optimization strategies, including water recycling and wastewater treatment, and periodically assess water use scenarios.
CBC operates in the Plaine du Cul-de-Sac (PCS) aquifer, about 700m from the Rivière Grise, at 40m above sea level. It draws water from two groundwater wells at depths of 45m and 75m, with a static groundwater level around 30m AMSL. The PCS aquifer, which relies on streamflow from the Rivière Grise and Rivière Blanche for about 80% of its recharge, faces sustainability challenges due to deforestation, land use, and climate uncertainty. A 2017 report by Northwater International and Rezodlo for USAID and the American Red Cross found that while the aquifer had good capacity and quality, over-exploitation risks were rising, especially if commercial agriculture resumes. Hence, as part of the ESAP # 6, CBC will assess water supply risks and undertake a water balance analysis through a Water Resources Sustainability Assessment (WRSA) in line with IFC’s PS3 and WBG’s EHS guidelines. The objective is to evaluate - quantitatively and qualitatively - the sustainability and climate resilience of the water resources exploited by the Project, and ensure that the resources will be used sustainably by taking appropriate mitigation in line with relevant national and international standards and benchmarks.
Air Emissions. The three on-site backup generators (3 x 500-kW generators and 1 x 175 kW generator) are the main source of air emissions across CBC’s operations. CBC plant uses electricity from leased generators from an external service provider. Annual GHG emissions are estimated to be 3,629 tons of CO2 equivalent.
Wastewater Treatment. Wastewater is generated primarily during the water treatment process (reverse osmosis), production, washing trucks, and sanitary employee restrooms. CBC has established on-site primary wastewater sedimentation pre-treatment. After pre-treatment effluent is discharged into the Rivière Grise river. . As part of the previous IFC investment (#40610), CBC is undertaking continuous efforts to improve design and efficiency of on-site wastewater treatment facility to meet the national effluent standards and effluent levels of WBG EHS Guidelines for Food and Beverage Processing (2007). Due to the complex country context, this effort is still ongoing. Stormwater runs off into on-site drains and discharges into an unlined storm-water trench outside the facility. Several septic tanks collect the wastewater discharge from the toilets, which are emptied regularly by an external specialized contractor.
Solid Waste Management. CBC has a written waste management procedure as part of its ESMS. This procedure reflects most types of waste streams generated, how they are collected on-site, and how they are disposed of. It also tracks the volumes of waste generated. Waste is either re-used/recycled or disposed of through an external service provider. Small quantities of hazardous waste are generated from vehicle maintenance, such as used oil, oil filters, soiled rags, and batteries. As part of ESAP #7, CBC will revise its waste management plan as part of its ESMS to adequately classify and dispose of any waste from the PV systems (packaging, damaged panels, used batteries). Annually, approximately 98% of the 5-gallon jugs sold by CBC are recycled/reused, while only 2% are new. CBC has a shredding machine on-site and estimates that it shreds approximately 160,000 Kg of plastic annually, sold to third parties.
Hazardous Materials Management. Diesel is stored in five aboveground storage tanks with a total storage capacity of 50,000 gallons used in conjunction with operating the generators and used in conjunction with the vehicle fuel pump. CBC has developed and implemented a spill response procedure. Caustic acid is stored in 55-gallon drums in a locked dedicated area but with no secondary containment. Small quantities of chemicals (less than 1 liter) are purchased at a time and stored in a locked cupboard with controlled access and handling by trained laboratory technicians. The laboratory maintains a register of the Material Safety Data Sheets (MSDSs) for all the chemicals used on-site.
PS4: Community Health, Safety and Security
Food Safety. In Haiti, the quality of water sold as potable water is regulated by the Bureau for Potable Water and Sanitation (DINEPA) and follows the norms for potable water set by the World Health Organization. CBC regularly tests water at various points in the process in its on-site laboratory. Water is treated on-site (chlorination, 6-stage filtration system including reverse osmosis, UV treatment, and ozonation).
CBC’s QMS includes procedures for verifying the quality of raw materials, quality testing during the production process, and a traceability mechanism, including a product recall process. The production process has controls in place to avoid contamination. All staff have received product quality and hygiene training and follow established procedures for hand washing and wearing proper attire. There are washing stations and signage at the entrance of each production area. CBC undertakes regular internal audits of operations according to an annual program and has designated a team of ISO-certified auditors with a plan for regular monitoring and inspection of hygiene conditions, and overall conditions of the buildings and equipment. As part of the previous IFC investment (#40610), CBC initiated work on augmenting its QMS by introducing one of the internationally recognized food safety standards. However, due to the complex country context, this effort is still ongoing.
Security forces: The CBC processing plant is secured by a 2.5-meter-high concrete wall and employs armed security guards from an external provider. Guards work in two shifts, 24/7, and are trained in the proper use of arms. CCTV and floodlights monitor the site. CBC’s security arrangements include background checks, engagement rules, and security personnel training. CBC owns a fleet of 40 delivery vehicles and its distribution capacity is supplemented by an external fleet of independent contractors. Currently, the company does not own warehouses to store finished products outside of its facilities.
