Project Description
ENVIRONMENTAL REVIEW SUMMARY
Project Name ZIMBABWE: TRINIDAD INDUSTRIES (PVT) LTD
Region Sub-Saharan Africa
Sector Manufacturing
Project No. 007273
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1. Trinidad Industries (Pvt) Ltd is a long-established, Harare-based manufacturer of adhesives, sealants, bitumen roofing and waterproofing compounds, paints and coatings, plastic moldings, electrical plugs and switches, and castor oil based polyurethane systems. Trinidad management have negotiated a buy-out agreement with T&N (formerly Turner and Newell Plc) of the UK. Trinidad also proposes to commence production of urea formaldehyde resin for sale within Zimbabwe as an adhesive in particleboard and other products. IFC support is sought to assist both in completing the buy-out and in establishing the urea formaldehyde operations.
2. This is a Category B project according to IFC''s environmental review procedure because specific impacts may result which can be avoided or mitigated by adhering to generally recognized performance standards, guidelines, or design criteria. The key environmental health and safety issues that were analyzed are as follows:
• air emissions and liquid effluent;
• employee exposure to hazardous materials and dust;
• provision of employee training in environmental health and safety, as well as appropriate protective equipment;
• chemical storage, general plant safety and housekeeping issues; and
• emergency preparedness and response.
At IFC''s request, Trinidad contracted an independent consultant to undertake an environmental audit of its entire operations. IFC tasked the same consultant to prepare a supplementary environmental report on the urea formaldehyde manufacturing facility that Trinidad proposes to lease for production purposes. IFC has reviewed both of these assessments, as well as Trinidad''s Health & Safety and Environmental Action Plan. Key elements of the Plan, which addresses all of the environmental health and safety issues listed above, are described below.
3. Air emissions. The environmental audit found that ventilation systems in several of Trinidad''s manufacturing processes are either inadequate or inoperative, exposing employees to excessive levels of dust and other process emissions, including ammonia, sulphur dioxide, bitumen fumes, metal shavings, and fine sand. The review of the urea formaldehyde facility concluded that, because the ventilation hood for the reactor is situated away from the reactor opening, formaldehyde fumes escape into the workplace environment whenever the reactor is opened. In addition, the reactor is equipped with a ventilation duct that vents directly to the chimney, releasing process gases to the atmosphere when the reactor is in use.
The audit report recommended that all of Trinidad''s existing operations be equipped with appropriate ventilation systems to ensure that process emissions are captured and exhausted, thereby preventing employee exposure to excessive levels of gases and dust. The report on the urea formaldehyde facility recommended that the reactor exhaust system be redesigned to position the ventilation hood directly above potential sources of formaldehyde emissions, including the reactor opening and the weighing scale where the product is transferred to drums. The report also recommended that a scrubber be installed in the chimney to prevent formaldehyde being vented to the atmosphere; and a routine maintenance program be instituted to ensure that all systems are functioning properly.
Trinidad''s Health & Safety and Environmental Action Plan commits the firm to installing new ventilation systems in each of its existing operations, and to retrofitting the ventilation system at the proposed urea formaldehyde resin facility in accordance with the recommendations of the environmental report. Trinidad has also agreed to install a scrubber in the urea formaldehyde resin plant. Quotes for each of these systems have been obtained, and the supplier estimates that all systems will be installed and operational within six months. Routine maintenance of these systems will be performed by Trinidad in accordance with procedures recommended by the supplier.
4. Liquid effluent. Trinidad''s existing facility produces comparatively little waste water, with the exception of the mikrosil factory. Mikrosil, a silicon dioxide, is produced on site for use as a filler in adhesives manufacturing. The process involves the blending of several liquid chemicals (including sulfuric acid, calcium hydroxide, and ammonium nitrate) in 50 gallon drums, followed by filtration and washing of the gel precipitate in a filter press. Both the drums and the filter press are washed after each batch, and the waste water is channelled out of the facility and directly into the municipal sewer system. An analysis of effluent samples from this facility found that levels of total dissolved solids, total soluble solids, nitrates, and sulphates all exceed limits established by the World Health Organization (WHO); as well as high alkalinity (pH of 11.2). The report on the proposed urea formaldehyde facility found the effluent collection to be adequate, as all effluent -- including waste water from drum rinsing operations -- is collected in a single underground tank, allowed to settle, and tested for pH before discharge to the municipal sewer tank.
The audit report recommended that an effluent tank be installed at Trinidad''s existing facility to collect waste water from all production processes for treatment and testing before discharge into the municipal sewer system. It also recommended that residual slurry be tested before disposal at a municipal landfill. The report on the urea formaldehyde facility recommended that water collected in the effluent tank be monitored and tested regularly for suspended solids and heavy metals, as well as pH.
Trinidad''s Action Plan states that the company will install an effluent collection and treatment tank at its existing facility within six months. Trinidad has already initiated discussions with municipal water quality inspectors and local suppliers about the type of tank to be installed. Effluent from both the existing facility and the urea formaldehyde plant will be tested by Trinidad''s in-house laboratory on a monthly basis, and the results recorded and made available to municipal authorities at their request. Slurry from these tanks will also be tested on a monthly basis prior to disposal at a municipal landfill.
5. Employee health and safety. The environmental audit found that employees are not always provided with appropriate personal protective equipment, and that the use of such equipment is not adequately enforced. Moreover, workers may be exposed to multiple chemicals, many of which present a potential health hazard, and the medical surveillance system in place does not monitor for all of the potential effects of such exposures. The audit report recommended that Trinidad''s existing program of worker training be expanded into a compulsory training and awareness program addressing all relevant environmental and occupational safety and health issues associated with the facility. It recommends that the training include topics such as types of and hazards associated with the various chemicals in use at the plant; appropriate storage, handling, and disposal of these chemicals; and proper use of protective clothing and equipment. In addition, it suggested that the existing health surveillance program provided to all employees be expanded for those employees working in higher risk operations.
Trinidad''s Action Plan states that a comprehensive employee training and awareness program covering environmental and occupational health and safety practices will be developed and implemented on an ongoing basis. Personnel at all levels and from all departments of the firm will be required to attend. Trinidad will use outside experts in occupational health and safety to develop and deliver training courses tailored to the specific conditions and issues at its facilities. With respect to medical surveillance, the current program will be modified to require employees in departments that use substances that pose a higher risk in the event of exposure (mikrosil, mastic, felt, cushion, and urea formaldehyde plants and paint shop) will be required to undergo complete annual medical examinations. Moreover, if routine environmental monitoring indicates that allowable exposure limits have been exceeded in any department(s), those employees working in the department(s) will be required to undergo an additional medical examination. Trinidad management believe that this program, in conjunction with improvements to its ventilation and effluent management systems, will address the concerns raised about the occupational health and safety of its employees.
6. Emergency preparedness and response. Trinidad recently implemented an extensive fire prevention and detection system, and plant employees have been trained and drilled in implementing the system. The audit report noted that there is no emergency response plan in place, however, in the event of other types of chemical emergencies (such as an explosion). Trinidad''s Action Plan includes a provision for developing detailed emergency response procedures for the full range of accidents and other emergencies that could occur at the facility. All employees will receive training in these procedures as part of the firm''s overall environmental health and safety training program. This activity is to be undertaken in accordance with the International Labor Organization (ILO) Convention 174 on major hazardous installations.
7. Chemical storage, plant safety and housekeeping. The environmental audit found several housekeeping issues that warrant attention. The audit report concluded that parts of the bulk storage area are crowded and, in some instances, not well organized; and contents are not always well marked as to the contents of each drum, its potential hazards, and instructions for safe storage and handling. The report recommended instituting a comprehensive system for classifying, labelling and storing all chemicals used in the facility, based on information contained in material safety data sheets (MSDSs). It also recommended that Trinidad develop a systematic housekeeping program for all its operations, including reorganizing both the bulk storage area and the flow of certain work processes; instituting a regular environmental audit program; and developing a plan for addressing any problems detected during these audits.
Trinidad is currently in the process of developing a complete data base of all chemicals used in its operations, based on information available in MSDSs and other publicly available sources. This initiative is expected to be completed in the near future and will provide the basis for both directives regarding handling and storage of materials, as well as the appropriate actions to be taken in the event of a chemical emergency. Trinidad is also revising its bulk stores warehouse in accordance with the recommendations made in the audit report, and is implementing internationally recognized hazard warning symbols on all chemical containers in both its storage and manufacturing areas.
8. Based on its review of both of the environmental audit reports and Trinidad''s proposed program for addressing the areas of concern identified in these reports, IFC concludes that the proposed project will be operated to meet Government of Zimbabwe requirements and all relevant World Bank policies and environmental, health and safety guidelines. IFC will monitor ongoing compliance with World Bank policies and guidelines during the life of the project by evaluating monitoring reports submitted annually to IFC by the sponsor, and by conducting periodic site reviews during project supervision.