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
Environmental and Social Policies and Management Systems. APRAN currently does not have E&S policy in place. Standard operating procedures for the farms have been developed which include certain aspects of E&S, such as waste management. As part of this investment, APRAN will develop and implement a site specific PS-compliant E&S Management System (ESMS) for the feed mill to include the following elements: (i) E&S Policy, (ii) Procedures for identification and assessment of E&S risks and impacts; (iii) E&S management programs and supporting procedures, (iii) E&S organizational capacity and competency; (iv) Emergency preparedness and response, including L&FS and dust explosion provisions, (v) Stakeholder engagement and community grievance mechanism; and (vi) E&S monitoring/reporting procedures, including Key Performance Indicators (KPIs) (ESAP#1).
Identification of E&S Risks and Impacts. APRAN identified E&S risks and impacts in line with the local regulation, therefore an ESIA was developed for the feed mill. This report identifies the risks and impacts associated with the construction of the new silos, new mill facility, and administrative building. A copy of the draft ESIA is enclosed with this disclosure.
E&S Management Programs. The E&S risk assessment as defined in the ESIA includes framework E&S management plans (ESMPs) for the proposed mill during the construction and operation phases, including E&S monitoring and review. As part of the ESMS (ref. ESAP#1), APRAN will develop E&S management programs and supporting procedures including: occupational health and safety, energy efficiency, prevention of dust explosion and fire, water management, waste management, pollution prevention, food safety, traffic and transport safety management, community, health, safety and security management, and management of security personnel.
Organizational Capacity / Competency. Main E&S responsibilities related to permitting is ensured by an E&S consultant who currently reports to the Director. There are no internal EHS resources to oversee the day-to-day management of the E&S aspects during construction and operations phases. APRAN will recruit a EHS manager who will be reporting to the Director (ESAP#2). The EHS Manager will have the responsibility of overseeing the development and implementation of the ESMS, including actions to close PS gaps as identified in the attached ESAP, and conducting monitoring of E&S performance and reporting to APRAN management team.
E&S Training Plan. APRAN provide E&S training to its staff and employees as part of the employee onboarding process. The company will provide specialised training to E&S personnel as part of the organisational capacity building with ESMS implementation (ref ESAP#1). Safe systems of work training and spill response as well as training on standard operating procedures will be included in the E&S training plan and implemented across the feed mill and warehouses.
Emergency Preparedness and Response. APRAN will develop and implement a site-specific emergency preparedness and response plan for the feed mill which will identify potential emergency situations and accidents that could occur at the feed mill complex; potential impact on the environment and outlines the necessary response actions and responsibilities (ref ESAP#1). The plan will include measures to prevent or mitigate accidents, fire outbreaks, electrical shocks, spillage and pollution prevention and other potential hazards like climate risk, pest infestation and contamination of finished products.
Monitoring and Review. As part of its PS1-compliant ESMS (ref. ESAP#1 above), APRAN will develop an E&S monitoring/reporting procedure which will specify Key Performance Indicators (KPIs), including occupational health and safety (OHS) leading and lagging indicators (incident records, near miss, hazard reporting and other workplace monitoring data), resource (water and energy) usage and efficiency, pollution prevention and control (air emissions, noise, effluents, solid/hazardous waste management) and food safety.
PS2: Labor and Working Conditions
At the time of the appraisal, APRAN was employing 52 staffs in its poultry farms, comprising of 50% male and 50% female workers. For the proposed mill, the company intends to recruit around 60 additional staffs for the operation phase. For the construction phase, which will last around 7 months, around 60 workers is estimated to be deployed by the EPC contractor.
Human Resources Policies and Procedures. APRAN’s Human Resource (HR) management system is based on its HR manual (internal regulation) and the Senegalese labor laws. The internal regulation cover worker’s responsibilities and includes processes related to discipline and dismissals. The company will update its Internal Regulations (HR manual) to align with statutory and IFC PS2 requirements. The manual will include policies and procedures on non-discrimination, equal opportunity, prohibition of harassment including sexual harassment, freedom of association, retrenchment, prohibition of child and forced labor, and workers' grievance mechanisms. The manual will also include policies and procedures for recruitment and hiring, training and career progression, compensation and benefits (working hours, overtime payment rate, insurance, leave policies), occupational health and safety, workplace conduct, disciplinary procedures and termination. Human Resources policies will be communicated to employees regularly and at the time of hiring. For contracted workers, the company will implement a system to verify statutory compliance requirements (wages, overtime, safety, etc.), and will allow them access to the company's workers' grievance mechanism (ESAP#3).
Working Conditions and Terms of Employment. Employees are recruited under permanent or term contracts, which specify entitlements and obligations, including 40 working hours with a limit of 10 hours of overtime per week, probationary period, remuneration package including overtime allowance and leaves. Employees performance reviews are completed once a year with management and recommendations made for promotion. There are currently no labor cases pending before the court.
Grievance Mechanism. APRAN has yet to implement a formal grievance mechanism for workers. Currently, HR complaints can be reported to direct supervisor or HR manager. The company will formalize a grievance mechanism accessible to all workers, including third-party workers, indicating (i) available channels to submit grievances (including separate channels for grievances related to gender-based violence and sexual harassment, and for confidential and anonymous complaints); (ii) roles and responsibilities for treating and responding to grievances; (iii) timelines for taking action; and (iv) system to log, track and report grievances and their status in accordance with IFC PS2 requirements (ESAP#4). The mechanism will also include a differentiated procedure and management of GBV and sexual harassment related grievances. The company will sensitize its workforce and disseminate information on online platforms and notice boards with additional specialised training provided to staff managing GBV and sexual harassment grievances.
Workers Engaged by Third Parties. APRAN will hire third-party workers through service providers for security and the EPC contractor during construction. These third-party service providers are required to comply with all APRAN policies and standards, including APRAN’s code of ethics as well as national Labor Code. Also, APRAN will develop and implement a procedure to monitor labor and working conditions of third-party workers as per ESAP#1 and monitor that the EPC contractor workers and any other third-party workers perform as per its HR/OHS requirements.
Occupational Health and Safety. Handling, dust, excessive noise, suffocation, falls, slips and trips, fires, transport, electrocutions, and injuries from improperly guarded machinery are the main hazards and risks associated with feed milling operations. Inhalation of feed dust over time can produce allergic reaction and chronic respiratory disorders, including sensitization and asthma. However, feed milling is a highly automated processing, limiting workplace risks while minimizing the number of employees involved in a milling line. Currently for its existing farms, APRAN has defined it OHS commitments and requirement as part of its HR manual, which includes proper use of PPE, annual medical check-ups, training requirement for fire management and accident investigations and biosecurity. APRAN will develop an EHS management plan to manage OHS risk for the feed mill including air and noise exposure to workers as part of its ESMS(ESAP#1).
Supply Chain: The primary raw materials for the production of feed will be maize, soybeans and peanuts. Maize and soybeans will be sourced from mechanized farms in Brazil through a supplier with existing commitments against the use of child and forced labor, mitigating the risks of child and forced labor. Groundnuts will be acquired in the local market. While groundnuts are cultivated by a large percentage of smallholders, the presence of harmful form of child labor has not been reported in Senegal. Actions to mitigate the risks of child and forced labor in the primary raw materials supply chain are included in ESAP #7 under section Performance Standard 6.
PS3: Resource Efficiency and Pollution Prevention
Resource Efficiency and GHG emissions: The feed mill will rely on the national grid for its electricity with a 800kVA standby generator to be installed for use in the event of power outage. The feed mill will also use diesel to fuel a 5kW boiler that will used to generate steam to be used for drying the products. The Project’s main energy sources are grid electricity and diesel for small scale steam generation and backup generators. The Project emissions are estimated to remain below 25,000 tons of carbon equivalent per year. As part of its ESMS, APRAN will develop and implement a resource efficiency management plan to monitor, manage and establish target for resource efficiency.
Water and Wastewater management: The process being mainly a dry process limited amount of water is expected to be used in the process and no wastewater will be generated except for sanitary wastewater. Water will be supplied by APIX through the industrial zone water network, sourcing water mainly from existing boreholes on the site. Water consumption will be monitored as part of the resource efficiency management plan. The feed mill will also be connected to the industrial zone sewer network, currently under construction, which will be equipped with a wastewater treatment plant. During construction, water will be sourced from the existing boreholes on the industrial site. Stormwater and surface runoff will be channeled through drainage ditches within the industrial zone.
Noise: Due to the nature of the process, the feed mill is expected to generate a high level of noise, however the impact on neighboring communities will be limited due to the nearest closest receptor being located more that 500m from the project boundary. Additionally, APRAN will ensure low noise rating equipment are procured for the milling process. Workers will be provided with suitable hearing protection given the exposure time to the noise. As part of its E&S monitoring program, APRAN will undertake regular ambient and workplace noise monitoring and include audiometry test as part of the annual health check-up of its milling staff.
Air monitoring. The major air emissions from the feed mill will be mainly particulate matter. In order to decrease emissions, the plant will be equipped with a dust filters. Additionally, regular ambient air quality monitoring will be undertaken as part of its E&S monitoring program.
Solid Waste and Hazardous waste management. Typical wastes generated from the feed mill include packaging material, plastics, cans, paper, mill waste, food remnant, and other construction waste like concrete and rubble, while hazardous waste will be mainly used oil. Both waste streams will be collected in distinct labelled skips placed at a dedicated, well-ventilated and locked storage area. The waste will be collected on site temporarily and carted away by an authorised waste management company.
Hazardous Materials management. APRAN will have a fuel storage with a capacity of 10,000 litres on the feed mill site. The fuel tank will be installed above the ground and equipped with a secondary containment and leak tested prior to commissioning (ESAP # 5). Apart from oil and fuel, no other chemicals will be used for the operations, however maize dust can be classified as hazardous material due to being prone to start fires. As part of the IFC investment, APRAN will implement proper hazardous material storage protocols including storage of hazardous materials including fire prevention and ensure that adequate spill kits and firefighting equipment are deployed and readily available at appropriate locations (ESAP#5).
PS4: Community Health, Safety and Security
Life and Fire Safety. Control measures for the prevention and response to dust explosions are detailed in the ESIA such as the use of intrinsically safe equipment, prevention of static electricity and sparks, temperature monitoring in silos, hot work permits, prohibition of smoking and emergency response equipment. As per ESAP #6, APRAN will recruit a qualified independent LFS consultant to review the LFS design of the feed mill, including compliance with ATEX requirements, and conduct a post commissioning audit of the LFS system prior to start of operation. The consultant will also review the ESIA to determine if additional technical and operational LFS control measures are required. The client will implement a cleaning procedure to prevent the accumulation of dust.
Traffic Safety. The feed mill will be constructed in a new industrial zone located outside of Dakar, with relatively low traffic in that area. The plant does not further expect to generate high level of traffic as raw material will be brought in only twice per month, and finished products will be supplied to retailers via large trucks, hence reducing the need for large number of trucks. However, as part of its ESMS, the company will develop and implement a traffic management plan applicable to its transport fleet, its suppliers and distributors (ESAP#1). The plan will address driver fitness, competence and training, speed limits, emergency response for road accidents, vehicle maintenance and safety standards as well as alcohol and drug testing requirements. Also, APRAN will provide a detailed induction session on the E&S provisions of its Code of Conduct, including zero tolerance to gender-based violence and sexual exploitation, abuse and harassment for its own truck drivers and transport service providers.
Security Personnel. Once constructed, the company will install fences and cameras at the perimeter of the plant to prevent unauthorized access. The company will employ unarmed security personnel for access control through a third-party security agency. APRAN will establish necessary measures for background checks and training requirements for security personnel as part of its ESMS (ref. ESAP #1), as well as expand the workers grievance management to cover its third-party security agents (ref. ESAP #4).
PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resource
The proposed feed mill will be located in an industrial zone which was previously part of the gazetted forest of Diass. The forest was degazetted in 2007 for the construction of the airport, and the area was cleared by APIX in 2010 for the establishment of the industrial zone. The feed mill site occupies an area of 1.9 ha and represents only 0.26% of the total surface area of the industrial zone. Therefore, no impact to natural and critical habitat is on the project site is expected by the client activities.
Supply Chain. The primary raw materials for the production of feed will be maize and soybeans, which will be sourced from Brazil. Other feed raw materials such as rice husk, groundnuts, and fish meal will be sourced from the local market. The maize and soybeans will be obtained through an international trader that has committed to supply deforestation free soybeans and maize. Rice husk and fish meal are generally by-products from the existing rice and fish processing industry in Senegal, hence their use is not expected to drive an increase in the current demand. Senegal is one of the largest producers of groundnut. Nevertheless, the areas cultivated with groundnuts has remained stable in the last decade and the cultivation of groundnuts does not represent a major risk of natural habitat conversion. As part of IFC investment, APRAN will develop (i) a sustainable sourcing strategy for primary raw materials; (ii) a supplier screening protocol to ensure soybeans, maize, and peanuts are sourced from certified or equivalent verified suppliers compliant with IFC PS6 supply chain requirements, or from areas not at risk of natural habitat conversion; (iii) a Supplier Code aligned with IFC PS2/PS6 supply chain requirements to be signed by primary raw material suppliers as part of sales agreement, prohibiting sourcing from recently converted natural habitats and/or produced with harmful child labor or forced labor; and (iv) procedures for monitoring and independently verifying the implementation of APRAN Supplier Code (ESAP#7).
