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
Copeval has an integrated management system (IMS) policy for quality, environment and safety covering all activities. The organizational structure in place and E&S capacity to undertake operations in line with its policy is adequate. As the project is already in operation, the assessment of risks and impacts for each facility had been undertaken following local environmental requirement. Nevertheless, Copeval is currently reviewing updating legal permitting and licensing of some of the centers that had expanded the scope of activities (e.g. additional licenses to store and distribute hazardous materials). As part of the ESAP #1, Copeval will finalize the process for the facilities in San Carlos and Los Angeles.
The IMS includes policy, procedures, and management plans that are comprehensive and commensurate with the scope of Copeval operations. The IMS was developed in alignment with ISO requirements for quality, environment and occupational health and safety. The E&S function is comprised of coordinators for OHS and Environment, reporting to the Deputy Operations Manager, leading the implementation of the ESMS across all branches. Additionally, there are safety analysts who support the implementation at the branches level, mainly by providing training to employees and auditing the system. An induction program is available for all employees and contractors. Human Resources elements are managed at corporate level by a Human Resources (HR) manager. A General Emergency Plan provides general guidelines for emergency response in terms of communications, responsibilities and emergency equipment response and training. Each center has its own emergency response plan and brigade in place for all potential scenarios (e.g. fire, flood, injury, earthquake).
Copeval defined key performance indicators and monitoring programs for human resources, environment, occupational health and emergency response. A contractors’ compliance program is in place to monitor labor and EHS performance. Copeval performs periodic internal audits, communicated to and reviewed by senior management. Nevertheless, Copeval will enhance its internal EHS inspection program to promptly identify and address substandard conditions at its facilities (ESAP #2).
Copeval sources alfalfa (3,614 ton), corn (46,150 ton), soybean flour (13,180 ton) and additives to produce animal feed products. Copeval buys these products from wholesale distributors. The origin of the alfalfa and corn is local, while soybean flour originates from soybean oil extraction plants in Bolivia. Production of soybean from Bolivia could potentially be linked to deforestation. Thus, as part of the ESAP, Copeval will implement a supplier code of conduct where it establishes a commitment to no deforestation and no conversion of natural habitats. Similarly, it will also implement a due diligence process to evaluate primary suppliers, in line with PS2 and PS6 supply chain requirements (ESAP #3).
The company’s E&S management systems were noted to be commensurate with the scale and E&S risks and impacts of its operations; and implementation at the project level is adequate.
PS2: Labor and Working Conditions
Terms of employment are provided in (i) Copeval’s labor rules and regulations booklet (“Reglamento Interno de Orden, Higiene y Seguridad”), required by local law; (ii) collective agreements with workers’ trade unions; and (iii) contracts signed between the Company and the employees. Employment conditions are clearly defined, covering all relevant aspects, and are communicated to employees during induction and through accompanying booklets. Formal procedures are in place for recruitment and training, and all employment conditions comply with Chilean law.
Copeval has signed collective agreements with four unions and negotiates with them every two or three years with conditions applied to both unionized and non-unionized employees. Copeval does not prevent employees to organize or participate in workers’ organizations. There is a formal grievance mechanism for workers to raise workplace concerns, which allow workers to submit their complaints anonymously and all complaints are treated confidentially. Grievances are addressed appropriately and in a timely manner by the top management of the company. The internal labor rules and regulations contains Copeval commitments to non-discrimination and equal opportunity. Additionally, it contains descriptions of which instances constitute sexual harassment and describes the procedure on how cases are handled, in line with local requirements. Lastly, the company does not employ people under 18 years old.
Copeval’s activities are mostly conducted by direct employees, specialized tasks such as maintenance, construction and transportation works are sub-contracted. Copeval has well documented provisions for contractors, including safety measures, access to facilities and legal compliance with labor law.
Copeval has OHS programs for safe handling, storage and transportation of materials, as well as on emergency response. Copeval has documented safety and operational procedures; topics covered include identification of hazards and risks; emergency procedures during storage and transportation; investigation of accidents; and confined spaces entries. Safety and emergency response training is provided to all employees during induction training. Copeval performs periodic monitoring of workplace exposure for noise and dust level for the operations, such measures are in compliance with local requirements. Employees are provided with personal protective equipment according to job function. The distribution centers and plants are fitted with functional eye and body washers, containment kits, and natural and forced ventilation systems, as required. Nevertheless, inspections from the regulatory agency have identified instances in few locations where dust and noise were above acceptable levels per local requirements. Thus, as part of the ESAP #4, Copeval will develop a corrective action plan to address these non-compliances.
PS3: Resource Efficiency and Pollution Prevention
Copeval GHG emissions are associated with electricity consumption, the use of wood for the dryers for grains, and fuel for the fleet used to distribute the products and for technical assistance. Resource efficiency efforts are focused on electricity consumption across warehouses and distribution centers. The scope 1 Greenhouse emissions of the current operations have been estimated as 1,688 tons of CO2-equivalent.
Distribution centers and branches use electricity from the national grid and the distribution fleet mostly use diesel. Grain drying operations are fueled by wood, operating during the harvest season (3-4 moths/year). Wood is purchased from authorized vendors with Chilean permits for commercialization of wood; total annual use of wood is near 9,900 tons per year for all plants. At the Nancagua and Los Angeles plants there are small boilers of less than 3MWth. The Los Angeles plant was recently added to the regional pollution abatement plan and Copeval is the process of developing and implementing abatement system for the boilers (ESAP #5).
The activities at distribution centers and plants do not require significant use of water, other than for sanitary purposes. Therefore, no industrial liquid effluents are generated at Copeval’s facilities. Sanitary water is discharged to the municipal sewage system or treated through septic systems aligned with the requirements of water and sewage reports/permits. The exception is the Los Angeles plant that produces rolled corn for animal feed with an annual water use if 7,057 m3, with industrial effluents discharged to the municipal sewage system.
Agrochemicals distributed by Copeval are approved by the Chilean Ministry of Agriculture. Agronomists prescribe products to be used by farmers and strict controls are in place for product application and use, in particular training and PPE requirements. At distribution centers, elements such as labeling, packaging, availability of material safety data sheets (MSDS) and storage were observed to be adequate. Copeval’s employees only manipulate sealed containers and are trained on: material handling, use of MSDS and emergency response, both during storage and transportation. The Chilean Association of Producers and Distributors, supported by Copeval, has implemented various initiatives to improve product usage among users. These include training programs, an empty container collection program, and cleaner production programs, among others.
Copeval’s portfolio of agrochemicals is extensive as it services a wide range of crops, including grains, fruits, vegetables, nuts, spices, and pastures throughout Chile. Copeval does not commercialize any product classified by the World Health Organization (WHO) Recommended Classification of Pesticides by Hazard Class Ia (extremely hazardous, Ib (highly hazardous) or II (moderately hazardous). Nevertheless, the company will update and include in its Environmental and procurement policies a commitment to continue to not commercialize these types of products in the future (ESAP #6).
Waste Management: Waste produced in the branches is non-hazardous, cardboards are recycled and metal-scrap generated is collected centrally in the main distribution center (San Fernando) and sold for recycling. Small amounts of oil from the equipment and fleet maintenance are generated and disposed of using authorized vendors. Copeval does not directly use agrochemicals; however, as part of a National initiative, the Company promotes proper agrochemicals handling and container disposal and has agrochemical container collection centers in several branches. Containers are only received if they have been tripled washed and punctured; containers are made into chips and disposed through vendors approved under the Chilean agrochemicals program.
The company has hazardous and non-hazardous waste management procedures including sorting, handling, storage and disposal, which are consistent with applicable legal requirements. All hazardous and non-hazardous wastes are collected for disposal by authorized public service agencies specialized in each type of waste. At the distribution center, all hazardous materials were noted to be properly labelled and stored in the designated areas.
PS4: Community Health, Safety and Security
Copeval’s potential risks to the community relate to agrochemical handling and transportation, fire safety and driver safety. Copeval warehouses have the infrastructure required to prevent potential safety events, including designated areas for agrochemicals storage, warehouses fitted with containment basins with sufficient capacity, adequate procedures for diesel delivery and storage, containment kits and fire suppression equipment, among others.
Dust associated with grain handling and processing presents an explosion and fire risk and Copeval have dust collection systems in place to mitigate this risk. As part of the ESAP #7, Copeval will conduct a dust hazard assessment (DHA) to identify potential dust hazards, assessing the risk of dust explosions, evaluate the effectiveness of existing controls, and review/update engineering and administrative controls at grain handling and animal feed mill facilities, including the implementation of a cleaning procedure to prevent the accumulation of dust.
Delivery drivers have been trained on emergency response and all vehicles transporting agrochemicals have an emergency response kit and information regarding the products being transported. Copeval will continue to provide continuous training to all drivers, including road safety training, interpretation of MSDSs and emergency response.
Copeval employs security personnel at 10 facilities, and they are unarmed, mostly focused on controlling access, monitoring and surveillance. Security arrangements regarding hiring and training are done in line with local requirements.
