91509 Environmental and Social Management System Toolkit and Case Studies FOOD & BEVERAGE Revision 1.0 October 21, 2013 Although the environmental and social management system described in this publication is based on IFC Performance Standard 1, the process outlined herein may not provide for meeting all the requirements of IFC Performance Standard 1, or any other IFC Performance Standard. The purpose of this publication is to demonstrate a technical means of integrating environmental and social concerns into company management, so that a business can become more effective in reducing its impact on the environment, its workers and its neighboring communities. The publication is provided “AS IS” and is provided without warranty of any kind, either express or implied, including, but not limited to, implied warranties of merchantability, fitness for a particular purpose or non- infringement. Development of an environmental and social management system based on this publication does not imply any type of certification or compliance with any IFC Performance Standards, including but not limited to IFC Performance Standard 1, nor does it imply endorsement by or affiliation or sponsorship with IFC. The publication is distributed with the understanding that neither the authors, nor the organizations and countries they represent, nor the publisher, are engaged in rendering technical advice. The publication is intended as a reference and for informational purposes only, and is not to be relied upon for operational or any other purposes. Implementation of the publication is solely the responsibility and risk of the final users. The material in the publication is set out in good faith for general guidance, and no liability can be accepted for any possible loss or expense incurred as a result of relying on the information contained herein. Neither IFC nor any other member of the World Bank Group shall be liable for any direct, indirect, incidental, special, consequential, punitive or exemplary damages, including, but not limited to, damages for loss of profits, goodwill, use, data or other intangible losses (even if IFC has been advised of the possibility of such damages) in any way arising or resulting from use or reliance on the publication or any such conclusion or determination. The publication is distributed subject to the condition that it shall not by way of trade or otherwise be sold, or otherwise circulated on a commercial basis without IFC’s prior written consent. IFC does not guarantee or provide any warranties as to the accuracy, timeliness, completeness, reliability or usefulness of this publication ’s content, and is not responsible or liable for any such content or your use thereof. The views, advice, opinions and other statements herein are not reviewed or endorsed by, and do not necessarily represent the views and opinions of, IFC or its Board of Directors, the World Bank or its Executive Directors, or the countries they represent. Table of Contents Contents Welcome and How to Use This ESMS Toolkit and Case Studies........................................................... 4 Section I: ESMS Toolkit ........................................................................................................................ 6 1. Policies .......................................................................................................................................... 7 Checklist for Developing a Company Policy Statement .................................................................... 8 Sample CEO Letter Announcing the ESMS - Internal ...................................................................... 11 2. Identification of Risks and Impacts ............................................................................................. 12 Risk Identification Worksheet ........................................................................................................ 13 Process Mapping Tool ..................................................................................................................... 20 Physical Mapping Tool .................................................................................................................... 22 Risk Assessment Form .................................................................................................................... 24 3. Management Programs .............................................................................................................. 25 Action Plan Chart ............................................................................................................................ 26 Outline of Procedure ...................................................................................................................... 27 Sample Procedure – Flowchart....................................................................................................... 28 4. Organizational Capacity and Competency.................................................................................. 30 Training Plan Worksheet................................................................................................................. 30 Roadmap and Time Estimate for Developing and Implementing an ESMS .................................... 31 5. Emergency Preparedness and Response .................................................................................... 37 Sample Fire Response Procedure ................................................................................................... 38 Sample Ammonia Leakage Preparedness and Response Procedure - Flowchart .......................... 41 6. Stakeholder Engagement ........................................................................................................... 43 Stakeholder Mapping Tool – Identification and Analysis ............................................................... 44 Impact Zoning Tool for Identifying Affected Communities ............................................................. 46 Stakeholder Engagement Plan Worksheet ..................................................................................... 47 7. External Communication and Grievance Mechanism ................................................................ 49 Checklist for Effective Grievance Mechanism ................................................................................ 50 Grievances Log................................................................................................................................ 51 8. Reporting back to Affected Communities .................................................................................. 53 Format and Venues for Ongoing Reporting.................................................................................... 53 9. Monitoring and Review .............................................................................................................. 54 Monitoring Plan .............................................................................................................................. 54 Auditing Guidance .......................................................................................................................... 55 Section II: ESMS Case Studies ............................................................................................................. 64 ABC FOOD COMPANY ..................................................................................................................... 67 XYZ FOOD COMPANY .................................................................................................................... 103 Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 3 Welcome & How to Use This ESMS Toolkit and Case Studies Environmental and social responsibility is becoming more and more important in today’s global economy. There are thousands of environmental and social codes and standards in the world today. The codes and standards define the rules and the objectives. But the challenge is in the implementation. An environmental and social management system helps companies to integrate the rules and objectives into core business operations, through a set of clearly defined, repeatable processes. In the following pages, we provide tools to build or enhance your environmental and social management system (ESMS). Section I is the Toolkit – sample documents, blank forms, flowcharts, checklists and templates. There are tools for each of the nine elements in your ESMS. Section II is the Case Studies – examples of how two different companies used the tools and developed and implemented an ESMS appropriate to the size and nature of their business. As you go through the Toolkit and Case Studies, you may want to refer back to the companion publication, the ESMS Handbook, which gives more background on each of the nine ESMS elements. It is important to remember that simply creating a book of policies and procedures is not the end - just the beginning. They need to be implemented and turned into consistent processes. Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 4 Continual improvement requires people that are committed to the effort. It requires trained people that have the right attitude, skills and knowledge. It requires leadership. Our hope is that, with this in mind, a company can use our ESMS tools to help accelerate the journey of continual improvement, for its own benefit and that of its employees and stakeholders. Quick Reference for Using the ESMS Toolkit and Case Studies Section I - Toolkit This section provides tools, including forms, templates, checklists and other useful documents, to help you develop and implement an ESMS. Section II - Case This section presents the stories of two companies Studies in the food and beverage industry that implemented an ESMS. These cases illustrate how the two companies used the tools presented in Section I – Toolkit. ESMS Self-Assessment This companion publication contains a questionnaire, and Improvement maturity matrix and improvement tips to help you Guide measure the maturity of your ESMS and develop a plan for improvement. ESMS Handbook This companion publication provides background on environmental and social management systems in a particular industry and offers step-by-step instructions on how to develop and implement an ESMS. Acknowledgments Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 5 I ESMS Toolkit FOOD AND BEVERAGE Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 6 1. Policies - Toolkit Introduction Policies are the foundation of your Environmental and Social Management System (ESMS). They are the rules that you expect your people to follow and the public statement you make about what your company believes in and how you strive to conduct your business. The process of adopting environmental and social policies provides a company with an opportunity to think about and discuss what is important. Ultimately, it also enables you to gain the commitment and support of senior management as they approve and communicate the policies. We present two tools related to this element: • Checklist for Developing a Company Policy Statement • Sample CEO Letter announcing the ESMS Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 7 1. Policies - Toolkit Checklist for Developing a Company Policy Statement Instructions: Use this checklist to make sure that you are considering the relevant issues in your environmental and social policy. Environment • Environmental laws and regulations • Resource efficiency and cleaner production principles in product design and production processes • Emissions and effluents Resource efficiency • Consumption of energy, water and other important input materials • Greenhouse gas (GHG) emissions Pollution prevention • Release of pollutants to air, water and land • Generation of hazardous and non-hazardous waste materials • Recovering, reusing, treating and disposing of waste • Emissions and residue • Pests and vectors • Pesticide effects on non-target species and the environment, and development of resistance Labor and Working Conditions Human resources policies and procedures • Labor standards policies and procedures • Clear communications throughout the company Working conditions and terms of employment • Collective bargaining agreement, if applicable • Reasonable working conditions and terms of employment • Protection for migrant workers • Clean and appropriate accommodations, if applicable Workers’ organizations • Workers’ rights to form and to join workers’ organizations Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 8 1. Policies - Toolkit • Non-discrimination against those who organize Non-discrimination and equal opportunity • Hiring, promoting and compensating workers • Training, tools and opportunities for advancement • Freedom from harassment by management or other workers • Positive discrimination, if applicable Retrenchment • Consideration of alternatives and mitigation in case of retrenchment • Payments and benefits Grievance mechanism • Transparent process for receiving and resolving worker complaints • No retaliation or discrimination Child labor • Minimum age • Conditions for young workers Forced labor • Freedom of movement, freedom to resign • No retention of identification papers or money to detain workers Occupational health and safety • Safe work environment and dormitories, if applicable • Emergency prevention and response system • Personal protective equipment and appropriate training • Document and report accidents, diseases and incidents Workers engaged by third parties • Extension of labor policies to labor contractors, recruiting agencies and other third parties • Grievance mechanism for contracted workers Supply chain • Extension of policies and monitoring of supply chain with respect to child labor, forced labor and worker safety to supply chain Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 9 1. Policies - Toolkit Community Health, Safety and Security Community health and safety • Food and consumer safety • Health, safety and security of the public from activities, equipment and infrastructure • Design, construct, operate and decommission equipment and infrastructure in a way to avoid the occurrence of incidents and injuries • Potential community exposure to hazardous materials and substances • Delivery, transportation and disposal of hazardous wastes • Impact or reliance on ecosystem services • Community exposure to water-borne, vector-borne and communicable diseases that may be associated with company activities • Communicable diseases that may be associated with the influx of temporary or permanent project labor • Emergency situations caused by activities, equipment and infrastructure Security personnel • Screening, training, equipping and monitoring direct or contracted workers providing security services • Grievance mechanism for workers and the community to express concerns about the security system and personnel Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 10 1. Policies - Toolkit Sample CEO Letter announcing the ESMS - Internal To all employees of our company: Our vision for our company is to become one of the most respected and admired food and beverage companies in our area. We aspire to conduct ourselves in an ethical and responsible manner. Corporate social responsibility, which spans environmental, human rights, labor and social issues, is a growing concern to investors, consumers and to all of us as people. To integrate corporate social responsibility into our day-to-day business activities, we are developing and implementing an environmental and social management system (ESMS). A management system is trained, committed people routinely following procedures and continually improving. I ask for your full cooperation in this important initiative. We believe that corporate social responsibility must be a foundation of our long-term growth and profitability. Not only is it an integral part of our overall business strategy, but it is also the right thing to do. It is the right thing for our customers, our suppliers, our shareholders, our communities and for you, as a core part of this company. As we strive to successfully implement our ESMS, we will train and involve you throughout the process. [Person’s name and title] is in charge of this corporate social responsibility initiative. Each of you has a direct line of communication with [person] for any suggestions or concerns. I thank you for your efforts and your continued dedication to our success. Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 11 2. Identification of Risks and Impacts - Toolkit Introduction Identifying your risks can seem like a daunting task, but don’t be overwhelmed. Scale your program as appropriate for the size and complexity of your company. But remember, small companies can have the same risks and potentially severe environmental and social impacts as large companies. Think of your risk identification and assessment as a value-added activity, an opportunity to gather information that will help to effectively improve your operations. A risk identification and assessment is an ongoing process; situations change over time, so it should be repeated at regular intervals. When identifying your risks, be mindful of the different risks that may be faced by women and men. Also, consider the risks to people outside your company – your external stakeholders. We present four tools related to this element: • Risk Identification Worksheet • Process Mapping Tool • Physical Mapping Tool • Risk Assessment Form Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 12 2. Identification of Risks and Impacts - Toolkit Risk Identification Worksheet Instructions: Complete the worksheet to help you focus on the areas where your company might have potential risks. This is not designed to tell you whether your company actually has this problem; it is just used to point you to areas where problems are more likely to happen, allowing you to pay more attention to those areas. Consult with appropriate people inside and outside your company to complete the worksheet. For each line, circle the appropriate answer. LABOR AND WORKING CONDITIONS RISKS RISK FACTORS My company has the Potential negative impact following conditions (A “yes” response means that (circle the appropriate there is a potential negative answer) impact) There is a difference in nationality, race or Yes/No Discrimination. Disciplinary religion between workers and managers. abuse and harassment. Our managers and supervisors are not Yes/No Discrimination. Disciplinary aware of the workers’ rights under the abuse and harassment. national labor law or collective agreements. Excessive overtime. We have an apprentice program that Yes/No Forced labor. Child labor. provides young workers with training and work experience. We routinely use recruiting agencies and Yes/No Inadequate wages, benefits and contract workers. contracts. Forced labor. We routinely use homeworkers or Yes/No Inadequate wages, benefits and contractors that use homeworkers. contracts. Forced labor. Child labor. We routinely use seasonal or temporary Yes/No Inadequate wages, benefits and workers. contracts. Excessive overtime. Some of the workers in my company are Yes/No Forced labor. Discrimination. migrants from another area. We provide a dormitory for some or all of Yes/No Lack of freedom of movement. our workers. Lack of clean adequate space. Excessive charges for the use of the dormitory. Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 13 2. Identification of Risks and Impacts - Toolkit There are security guards at our company. Yes/No Lack of freedom of movement. Harassment. We are located in a free-trade zone. Yes/No Inadequate wages, benefits and contracts. There is a large fluctuation in orders Yes/No Excessive overtime. No and/or seasonality of production. payment of overtime due to hour-averaging. Layoffs. There is a labor shortage in my area. Yes/No Child labor. There is no history of collective bargaining, Yes/No Lack of freedom of association. unions or other forms of worker representation at our company. There is no procedure for workers to Yes/No Discrimination. Disciplinary express their complaints (grievance abuse and harassment. Worker mechanism). injuries and chronic conditions. Our processing activities include significant Yes/No Worker injuries and chronic lifting, carrying or repetitive motions. conditions. Our processing activities involve workers Yes/No Worker injuries and chronic routinely interacting with machinery, conditions. equipment with sharp edges and/or slippery work surfaces. Our processing activities involve elevated Yes/No Worker injuries and chronic levels of noise, dust, vapors, smoke, conditions. chemicals (e.g., preservatives, cleaning agents), radiation and/or temperature extremes. Our processing activities involve hazardous Yes/No Worker injuries or casualties. materials or processes that could cause fires or explosions. Our processing activities involve the Yes/No Worker illnesses. handling of living and dead animals that can transmit diseases to humans. Our workers don’t have access to separate Yes/No Worker illnesses. and clean areas for eating and changing clothes. Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 14 2. Identification of Risks and Impacts - Toolkit Bathrooms are not properly cleaned and Yes/No Worker illnesses. often lack running water, soap and toilet paper. The companies in our supply chain would Yes/No All of the above. probably answer “Yes” to most of the questions above. ENVIRONMENTAL RISKS RISK FACTORS My company has Potential negative impact the following (A “yes” response means that there is a conditions (circle potential negative impact) the appropriate answer) Our operations require large quantities Yes/No Groundwater depletion in the region. of fresh water. Contamination of ground or surface water sources in the region due to discharge of effluent. High energy consumption for treatment of raw or process water. We don’t have sufficient fresh water Yes/No Groundwater depletion in the region. supplies to meet our requirements. Our operations have high requirements Yes/No High energy consumption. for power supply. We require large quantities of fuel Yes/No Air emissions. Solid waste (fly ash if coal (gas/diesel/coal/etc.) for our is used). operations. We have various process and utility Yes/No Air emissions. Solid waste (e.g. waste equipment which may generate air from equipment maintenance, fly ash emissions (e.g. boiler, diesel from coal-based boilers). Hazardous generator set, incinerator, grinder, waste (e.g., waste oil, oil-soaked filters etc.). and rags). Liquid waste (e.g. boiler blow-down, waste oil). Noise generation. Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 15 2. Identification of Risks and Impacts - Toolkit We need to store large quantities of Yes/No Solid waste due to possible raw materials at site. contamination or deterioration of raw materials. High energy consumption or emissions due to cold storage. We generate large (or significant) Yes/No Solid waste. Liquid waste. quantities of solid or liquid waste due Contamination of land, groundwater to poor quality of raw materials or and/or surface water due to improper rotting of material due to prolonged disposal of solid and liquid waste. storage. Wastewater from cleaning. High energy consumption or emissions due to cold storage. We generate large (or significant) Yes/No Solid waste. Liquid waste. quantities of solid or liquid waste from Contamination of land, groundwater our manufacturing process, which are and/or surface water due to improper not reprocessed into byproducts, disposal of solid and liquid waste. fertilizers or energy. Wastewater from cleaning. The quantity of solid/liquid waste from Yes/No Solid waste. Liquid waste. rejected finished product due to Contamination of land, groundwater contamination, rotting, expiry, etc. is and/or surface water due to improper high (or significant) at our facility. disposal of solid and liquid waste. Wastewater from cleaning. High energy consumption or emissions due to excess or extra production. We dispose of our solid waste in our Yes/No Contamination of land, groundwater landfill or city’s landfill facility. (due to leachate) and/or surface water (due to run-off). Impact on wildlife or fisheries if exposed. Diseases through vectors, foul smell, GHGs generation (e.g. methane). We provide our solid waste to the Yes/No Contamination of land, groundwater community or general public to be (due to leachate), surface water (due to used as fertilizer. run-off) and/or crops if toxic chemicals are present in the solid waste. Our operations generate large (or Yes/No Contamination of ground and/or surface significant) quantities of wastewater water due to improper disposal of (e.g. raw material washing, processing, wastewater. floor cleaning, bottle washing, etc.). Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 16 2. Identification of Risks and Impacts - Toolkit We discharge our wastewater (process Yes/No Contamination of receiving water body effluent) in a nearby river/lake/or any and aquatic life. Eutrophication due to other water body. high BOD or COD. We treat our wastewater (process Yes/No Energy consumption. Solid waste effluent) before discharge. generation (e.g. sludge from treatment process, membrane concentrated waste discharge from reverse osmosis, treatment chemicals). Land and/or water contamination due to improper disposal of waste. We treat our sewage (from toilets, Yes/No Energy consumption. Solid waste washrooms, etc.) before discharging it generation (e.g. sludge from treatment in the city’s sewer line. process, membrane concentrated waste discharge from reverse osmosis, treatment chemicals). Land and/or water contamination due to improper disposal of solid waste. We utilize our treated wastewater Yes/No Contamination of land, groundwater (process effluent) for irrigation (either (due to leachate), surface water (due to by ourselves or provide it to run-off) and/or crops if toxic chemicals community). are present in the treated wastewater. We generate some hazardous or toxic Yes/No Contamination of land, groundwater waste (e.g. waste chemicals, (due to leachate) and/or surface water used/waste oil/sludge from (due to run-off) if disposed improperly. wastewater treatment plants based on chemical treatment, etc.). We require a large land area for our Yes/No Loss of natural habitats or agricultural industrial operations. land. Air, water and/or land pollution based on expansion requirements and infrastructure development. Our operations may have an impact on Yes/No Loss of native species. Impact the surrounding forest or wildlife. on biodiversity. Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 17 2. Identification of Risks and Impacts - Toolkit We use some banned Yes/No Non-fulfillment of regulatory chemicals/materials in our processes. requirements. Air, land or water pollution depending on current usage. Exposure of workers or consumers to banned chemicals. We face problems related to Yes/No Use of chemicals. Chemical exposure pests/vectors. to workers. Land or water contamination due to disposal of infested material. COMMUNITY HEALTH, SAFETY AND SECURITY RISKS RISK FACTORS My company Potential negative impact has the (A “yes” response means that there is following a potential negative impact) conditions (circle the appropriate answer) Our processing activities involve organic Yes/No Food contamination/food safety issues. matter that needs to be washed, treated or stored to ensure food safety. Our processing activities and Yes/No Exposure of community to foul odors. treatments involve biomass or other liquids or solids that may lead to foul odors. Our operations involve air emissions, Yes/No Air, water or land contamination, which water discharge, solid waste disposal, can affect the health and livelihood of leakage of chemicals or gases, etc., that local communities. may pass on to the surrounding community. We plan to develop new infrastructure, Yes/No Exposure of communities to air buildings, equipment and other emissions, noise and accidents due to facilities. equipment and vehicular movement. Impact on wildlife, biodiversity and local livelihoods due to natural habitat conversion. Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 18 2. Identification of Risks and Impacts - Toolkit We plan to decommission and dispose Yes/No Health risks to communities due to of old infrastructure, buildings, exposure to toxic substances (e.g. from equipment and other facilities. chemicals, heavy metals, asbestos, etc.), and air emissions and noise due to equipment and vehicular movement. Impact on wildlife and biodiversity. There is significant movement of Yes/No Exposure of communities to air vehicles in and around our facility due emissions, noise and accidents due to to our operations (e.g. vehicles carrying vehicular movement. raw material or finished products, movement of water tankers, etc.). We store hazardous chemicals or Yes/No Health risks to communities and hazardous waste in our facility. negative impacts on wildlife and biodiversity due to the intentional or unintentional (spills) release of hazardous or toxic substances contaminating air, land and/or water. We discharge water from our plant, Yes/No Negative impacts on local food security which may have an impact on and income generation due to surrounding water bodies. contamination of aquatic life. Diseases/illness among local communities due to the use of contaminated water. We hire temporary and migrant Yes/No Communicable diseases brought or workers. spread by the influx of workers. We hire private security personnel Yes/No Conflicts with communities and indigenous people. We normally have conflicts/complaints Yes/No Conflicts with communities and with the local community. indigenous people. Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 19 2. Identification of Risks and Impacts - Toolkit Process Mapping Tool Instructions: A process map or flowchart visually describes the flow of activities of a process, from beginning to end. Below is an example of a process map for a poultry processor. Inputs (raw materials, water, heat, refrigerant, packaging) and outputs (waste, air emissions) are also listed for each activity. Process maps are particularly useful in identifying environmental risks, occupational health and safety hazards and areas for process improvement. They are also helpful to identify whether you can improve the work flow, which can benefit the workers. After you write down your process map, look at each activity and think of: • the occupational health and safety hazards; • the environmental and community risks; and • the opportunities for waste reduction and energy savings. It is very important that people at all levels in your company participate in the identification of risks, opportunities and possible solutions. Supervisors and workers are a valuable resource in helping you learn about the way things actually work on the production floor. If you can’t have all the necessary people in a room, you can ask supervisors to provide you the information for the activities they are responsible for after consulting with the workers in their area. After you have identified the risks and opportunities for each step, you can think of the possible solutions. These can range from replacing and installing new equipment, to revising your work flow procedures to better control the risks, to improving the use of personal protective equipment by your workers. This will form the basis of the action plan you will prepare in the Management Program chapter. Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 20 2. Identification of Risks and Impacts - Toolkit Opportunity for waste Potential negative Potential negative impacts - Environment and reduction/energy & Inputs Process Outputs impacts - OHS community water savings Materials, Operational Product, Injuries, long-term Discharge, contamination, pollution, Improved process, re- labor, activity waste, by- illness shortage purposing and recycling resources product by-products Large solid waste volume, high nitrogen and pathogen content in solid waste, leading to: Excreta, egg - potential contamination of land and surface shells, waters Lairage of mortality Worker exposure to - water oxygen depletion and death of aquatic life Chicken feed chickens waste, litter disease vectors - unpleasant odors Compost ▼ Hanging chickens Worker injuries from Manual labor on conveyor belt repetitive motion ▼ Stun and kill Worker injuries from Manual labor chickens cuts, abrasions ▼ Worker injuries from cuts, abrasions from Leakage, leading to knives; falls on slippery - potential contamination of ground and surface Manual labor Bleed chickens Blood floors waters Compost; biogas ▼ High water demand, leading to: - diminishing groundwater and decreased access to potable water for the community High wastewater volume, leading to - potential contamination of ground and surface Worker injuries from waters Hot water Scald chickens Wastewater burns - water oxygen depletion and death of aquatic life Recycle water ▼ Worker injuries from repetitive motion; Organic waste, leading to: exposure to allergens - potential contamination of ground and surface Manual labor Pluck feathers Feathers and particulates waters Compost; by-products ▼ Organic waste, leading to: Worker injuries from - potential contamination of ground and surface Compost; biogas; by- Manual labor Remove head Heads cuts, abrasions waters products ▼ Organic waste, leading to: Eviscerate Worker injuries from - potential contamination of ground and surface Compost; biogas; by- Manual labor internal organs Organs cuts, abrasions waters products ▼ High water demand, leading to: Worker injuries from - diminishing groundwater and access to potable Water Wash carcass Wastewater falls on slippery floors water for the community Recycle water ▼ Organic waste, leading to: Worker injuries from - potential contamination of ground and surface Compost; biogas; by- Manual labor Remove feet Feet cuts, abrasions waters products ▼ Worker exposure to preservatives, Inadequate or broken temperature controls, refrigerants such as leading to: ammonia and other - not meeting food safety requirements potentially allergenic or Runoffs and leakage of preservatives and Water; Chill to prevent toxic substances; refrigerants, leading to: refrigeration bacterial exposure to extreme - damage to aquatic ecosystems systems poisoning Wastewater temperatures - decrease in potable water Insulation ▼ Plastic bags; Worker injuries from manual labor Package repetitive motion Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 21 2. Identification of Risks and Impacts - Toolkit Physical Mapping Tool Instruction: Prepare a map of the layout of your plant. The map should include equipment (e.g., conveyors, washing and sieving drums, heaters, drying machines, boilers, cold rooms, pipes, etc.) and mark stairs and exits. You can use this map again later when you do your emergency preparedness plan. Once you have the physical map, do a walk-through to observe existing or potential problems. Whenever you encounter a problem, write it down and mark it on the map (see example for a fruit processing company in the figure below). The walk-through needs to be done during working hours, and you should be accompanied by a small team, including supervisors and workers; they often know what the problems are and have ideas of how to improve. • Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 22 2. Identification of Risks and Impacts - Toolkit Here are some things to look for: 1. Where are people most likely to get injured (e.g., falls, cuts, burns, strains)? Identify trip, slip and fall hazards - wet floors, obstructions, etc.? 2. Are exit doors unobstructed and well-marked? Unchained? Equipped with panic bars to allow escape from within but deny access from outdoors? 3. Are any passages blocked due to the layout or improperly stored materials? 4. Is the process laid out efficiently to reduce worker strain and workspace clutter? 5. Where could explosions, fires or the accidental release of hazardous materials occur? Is there adequate and appropriate response equipment close to those areas? 6. Are chemicals labeled and stored with compatible materials, where combustion or cross- contamination with product cannot occur? What is the likelihood and consequence of an accidental spillage? 7. Are there existing or potential leakages from rusted pipes, gaskets and drums? 8. What is overhead that could break or drop and cause food adulteration: e.g. lights without shields, fluorescent tubes, birds and bird feces, rodents, flies, etc. 9. Where does there seem to be high levels of water consumption or discharge? Identify all water outlets, hoses, etc. and flag those without spring closures. Basins, sinks, tubs should only be filled to needed levels. 10. Where is most of the waste produced and what is done with it? 11. Are raw materials being used most efficiently? Where is there wasting of materials? 12. Where are workers exposed to bad odors, loud noises, excessive dust or extreme high and low temperatures? Do workers have appropriate personal protective equipment? Are they using it correctly? 13. In general, are there places or work processes where it is clear there are bad habits? After the walk-through, meet with the team and discuss what has been observed. Also, talk about previous incidents or accidents that have occurred in the plant and what have been the consequences. The information you collect in the walk-through will form the basis of the action plan you will prepare in the Management Program chapter. Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 23 2. Identification of Risks and Impacts - Toolkit Risk Assessment Form Instructions: It might not be feasible or practical to address every risk. Where it is necessary to prioritize your actions, try to avoid or minimize the most potentially severe risks. Complete this form based on the risks that you identified using the previous tools. Identify the probability of a certain risk occurring and the severity if it did happen. For example, a major explosion may be unlikely to occur (low probability), but the damage to your people and facility could be extremely high (high impact). When prioritizing issues to be addressed, consider opportunities for cost reduction through reduced water and energy consumption, reduced waste generation and similar considerations. Company Risk Probability of Severity if Notes area or occurring occurred department (low, medium, (low, medium, high, extreme) high, extreme) Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 24 3. Management Programs - Toolkit Introduction A management program is centered on the action plans and improved procedures to help you to avoid, minimize or compensate for the risks and impacts you’ve identified. We present three tools related to this element: • Action Plan Chart • Outline of Procedure • Sample Procedure - Flowchart Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 25 3. Management Programs - Toolkit Action Plan Chart Instructions: Use the Action Plan Chart to identify the actions you will take concerning the risks and how the actions will be managed. List each risk that you identified and prioritized in the previous section. Write down the actions that you could take to avoid, minimize or compensate/offset the risk. Assign a responsible party and a deadline. Identify the resources required and the operational procedures you will need to adopt. Risk: High volume of wastewater with BOC and COD from organic waste entering and contaminating surface waters used by nearby communities Mitigation Action Objective and target Deadline Responsible Resources Operational hierarchy staff required procedures Avoid Install effluent treatment plant Objective: Meet IFC EHS 6 months EHS manager Wastewater treatment Procedure for operation and ensure it is operated and Guideline values for plant: USD 10K – 20K and maintenance of maintained according to effluent levels for food effluent treatment plant. recommended operating criteria and beverage processing Operation and Procedure for analysis of and standards Target: Maintenance: to be treated wastewater. DOB 50 mg/l determined COD 250 mg/l Minimize Install traps at drains to prevent Same as above 2 months Production Traps: USD 1K-2K Procedure for cleaning solid material from entering the manager traps. effluent treatment plant Reduce soil debris in raw material Same as above 3 months Sourcing Training program on Procedure for raw sourced from local suppliers manager harvesting practices for material inspection. suppliers Compensate Provide drinking water to Objective: Meet drinking Immediate CSR manager Estimated: USD 6K None /Offset affected communities on weekly water needs until to month 6 basis installation of effluent treatment plant Target: 2l/person day Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 26 3. Management Programs - Toolkit Outline of Procedure As you implement the Action Plan, it is helpful to define procedures that clearly systematize the actions into routine, daily processes and practices. Procedures can be text, flowcharts, pictograms – whatever you find to be the most effective communication tool for your company. Below is an outline of the important components of a well-defined procedure. Title: Procedure number: Number of pages: 1.0 Purpose: 2.0 Scope: 3.0 Definitions: 4.0 Responsibilities: 5.0 Work instructions: 6.0 Reference documents: 7.0 Records: 8.0 Approving authority: 9.0 Issue date: 10.0 Revision date: Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 27 3. Management Programs - Toolkit Sample Procedure – Flowchart Title: Water Conservation Procedure Date issued: February 15, 2011 Date revised: March 1, 2012 Purpose: Measure total demand, identify overage sites and reasons for water use, eliminate outlet if feasible to improve water conservation Process Responsible person Documentation Measure total flow of potable Engineering and Maintenance Potable water total flow water to plant operations and estimated cost/m3 Inventory all water distribution Area supervisors, Engineering Potable water outlets points in plant and Maintenance map and flow Map all potable water outlets Area supervisors, Engineering Potable water outlets on facility plan; assign outlet and Maintenance map and flow number and flow Show outlets that are left open Operations manager, area Complete annotated and those without control supervisors, Engineering and water map, outlets, valves (pistols) Maintenance estimated flows and determination of need Review process and define Area supervisors, Engineering specific purpose of water use; and Maintenance indicate taps to replace with a dry process, or retrofit with controls Obtain benchmarking data for Area supervisors, Engineering Facility benchmarking processes and poultry industry; and Maintenance report; compare existing compare benchmark water use operations with several m3/KG product benchmarks Advise operations manager and Operations manager, area area supervisors of need to supervisors, Engineering and eliminate water usage and Maintenance convert to dry cleaning Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 28 3. Management Programs - Toolkit Review outlets and water uses; Operations manager, Update annotated water mark outlets that can be Engineering and Maintenance map, outlets, estimated eliminated; remove outlets and flows date of closure seal piping Measure total flow of potable Engineering and Maintenance Update total potable water to plant operations water flow; calculate estimated revised flow and total cost reduction Repeat the process Engineering and Maintenance Update total potable water flow; calculate estimated revised flow and total cost reduction Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 29 4. Organizational Capacity - Toolkit Introduction A well-implemented ESMS is ultimately about trained, committed people. Senior management commitment is critical, but beyond that you need people throughout the company who take responsibility for the ESMS. This does not mean that the ESMS becomes everyone’s full-time job. You should scale the system to meet your company’s size and structure. Remember that there needs to be a progression from awareness to commitment to implementation. Think about this as you plan the relevant training. For each training module, think about whether the goal is to raise awareness, gain commitment or give people the knowledge and skills they need to implement. We present two tools related to this element: • Training Plan Worksheet • Roadmap and Time Estimate for Developing and Implementing an ESMS Think about ways to adapt these for your company. Training Plan Worksheet Instructions Look at your action plans and improved procedures to identify which training managers and workers will need to be able to correctly implement these. Identify who in the company will need basic and advanced training on the ESMS elements. Sample Training Plan Worksheet Department Module 1 Module 2 Module 3 Module 4 Senior Introduction to IFC Performance Objectives of E&S management ESMS Standards management review ESMS team ESMS elements Identification of Preparing a Internal auditing risks and impacts management review Root-cause analysis meeting HR Department Introduction to Non-discriminatory Complaint ESMS hiring practices management and Labor standards resolution procedure Production Introduction to Identification of Water conservation Waste reduction Department ESMS risks and impacts procedures procedures All workers and ESMS policies Health and safety Non-discrimination Worker-manager managers and emergency and disciplinary communications response procedures procedures Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 30 4. Organizational Capacity - Toolkit Roadmap and Time Estimate for Developing and Implementing an ESMS Instructions The roadmap below lists the activities that a company commonly needs to put in place to set up an ESMS. This table will help you develop a timeline for action and estimate the staff time required to develop and implement your ESMS. MONTH ACTIVITY Time spent 1 2 3 4 5 6 Senior Mid- Super- Work 1. Policy mgt mgt visors ers time time time time Kick-off meeting at sr. management level to discuss ESMS implementation Selection (including communication/coordination) of ESMS core Developing team (personnel from different key departments) Appreciation/awareness workshop for senior management and core team on ESMS requirements Review/upgrading of existing environment and social policy/formulation of organization’s env. & social policy Design, printing and display of ESMS policy in key areas Implementing Uploading of ESMS policy on company website Communication of ESMS policy to key external stakeholders Training & awareness of employees on ESMS policy and information dissemination Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 31 4. Organizational Capacity - Toolkit MONTH ACTIVITY Time spent 1 2 3 4 5 6 Senior Mid Super- Work 2. Risk and Impact Identification mgt mgt visors ers time time time time Mapping of activities, processes and key stakeholders, including the suppliers & contractors Developing Identification and compilation of regulatory and other requirements, including stakeholder expectations Initial environment & social review, identification & evaluation of environment and labor risks (including supply chain) Training & awareness of employees on environmental, social and labor risks and risks identification process Implementing Training & awareness of employees on regulatory and other requirements, including stakeholder expectations Training & awareness of employees on environment, social and labor risks and information dissemination Senior Mid Super- Work 3. Management Programs mgt mgt visors ers time time time time Preparation of ESMS manual (formulation and documentation of procedures related to ESMS) Formulation, compilation of environmental Developing objectives/targets and social performance improvement measures Formulation and development of environment and social action plans Development of operational procedures Communication, awareness and training of me ple nti Im ng employees on ESMS procedures Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 32 4. Organizational Capacity - Toolkit MONTH ACTIVITY Time spent 1 2 3 4 5 6 Communication and awareness of employees on environmental objectives and social performance improvement measures Communication and awareness of employees on environmental and social action plans Training of employees on environmental and social operational procedures Senior Mid- Super- Work 4. Organizational Capacity and mgt mgt visors ers Competency time time time time Environmental and social awareness program for middle management Developing Environmental and social awareness program for workers Competency program for ESMS core team Internal auditor training for the organization’s ESMS assessors/auditors General awareness and training on environment, social and labor issues/ESMS for Implementing senior and middle management Environmental and social awareness program for workers Competency program for ESMS core team Internal auditor training for the organization’s ESMS assessors/auditors Senior Mid- Super- Work 5. Emergency Preparedness and Response mgt mgt visors ers time time time time Review key risks and existing emergency Developing preparedness plan Upgrade/prepare the emergency preparedness plan Communicate to workers, potentially affected Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 33 4. Organizational Capacity - Toolkit MONTH ACTIVITY Time spent 1 2 3 4 5 6 communities and relevant government agencies (if required) Awareness and communication to employees Implementing and affected communities on key risks and emergency issues and emergency planning Training of employees on emergency preparedness plan Communication and awareness on emergency procedures to affected communities and relevant authorities (if required) Senior Mid- Super- Work 6. Stakeholder Engagement mgt mgt visors ers time time time time Mapping of all stakeholders, stakeholder Developing analysis and engagement planning Develop/upgrade stakeholder communication/consultation; information disclosure and engagement strategy/program Communication to employees on key Implementing stakeholders and their environment and social/labor expectations Communication, awareness and training of employees on the strategy/program for stakeholder engagement/consultation/communication and information disclosure Senior Mid Super- Work 7. External Communication & Grievance mgt mgt visors ers Mechanism time time time time Review external communication system, Developing including receiving and handling feedback, concerns and complaints Develop/upgrade system for regular engagement, receiving, documenting and Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 34 4. Organizational Capacity - Toolkit MONTH ACTIVITY Time spent 1 2 3 4 5 6 responding to feedback and grievances Review external communication, feedback, Implementing stakeholder concerns and complaints and communicate to key personnel Training, awareness and implementation of stakeholder engagement, receiving, documenting and responding to feedback and grievances Senior Mid Super- Work 8. Ongoing Reporting to mgt mgt visors ers Affected Communities time time time time Review existing system for reporting and Developing disclosure Develop/upgrade system for external reporting and disclosure (including collection, validation and verification of information) Communication and disclosure to key external Implementing stakeholders and affected communities Communication, awareness and training on external reporting and disclosure (including collection, validation and verification of information) Senior Mid Super- Work 9. Monitoring and Review mgt mgt visors ers time time time time Establish procedure to monitor and measure ESMS performance, compliance and stakeholder requirements Developing Implementation of ESMS monitoring program, establishing benchmarks and integration with existing system Final review and complete ESMS documentation Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 35 4. Organizational Capacity - Toolkit MONTH ACTIVITY Time spent 1 2 3 4 5 6 Conduct internal audit/evaluation of ESMS performance against the management program requirement/benchmarks Establish relevant operational controls and formulation of corrective & preventive actions Review by the senior management to assess performance and effectiveness of ESMS Documentation and communication on ESMS conformance, regulatory compliance and stakeholder requirements Communication, awareness, training and implementation of ESMS monitoring program and established benchmarks Communication of internal audit/performance Implementing measurement findings and ESMS performance to the employees Communication, awareness and training of employees on operational controls and corrective & preventive actions Communication on outcomes of review of the ESMS performance by senior management and key decisions taken TOTAL Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 36 5. Emergency Preparedness and Response - Toolkit Introduction Even with good systems in place, emergencies can and do happen. The key is to plan in advance – try to prevent as much as you can, and train your employees to know what to do in case something does happen. Don’t be overwhelmed by the thought of planning for every single possible accident or emergency. Look at your risk assessment and focus on the areas where emergencies are most likely to happen or cause significant harm. Develop and implement a suitable “emergency preparedness and management plan” for the identified emergency situation. As part of the plan, you need to have detailed procedures on the steps to prepare and respond. Here we provide samples of procedures for responding to two of the most common emergencies in the food and beverage industry – fire and toxic leakage chemical spillage. We present two tools related to this element: • Sample Fire Response Procedure • Sample Ammonia Leakage Preparedness and Response Procedure - Flowchart Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 37 5. Emergency Preparedness and Response - Toolkit Sample Fire Response Procedure Title: Fire Response Procedure Procedure number: EM001 Number of pages: 3 pages 1.0 Purpose and Scope: 1.1 Purpose: Set out responsibilities and activities in order to respond to emergency resulting from fire. Identify the roles, responsibilities and authorities to effectively facilitate the site’s emergency preparedness and response. 1.2. Scope: This procedure applies to all activities and processes of at [Name of Company]. 2.0 Definitions: Emergency: Situation that poses immediate threat of:  injuries and damage to health;  fatalities;  damage to property; or  damage to environment. Fire emergency: Situation that poses or signals immediate threat in the form of:  uncontrolled fire or imminent threat of uncontrolled fire;  smoke or burning;  uncontrolled release or spillage of flammable or combustible substance; or  sounding of fire alarm. 3.0 Responsibility and Authority: This procedure is the responsibility of the operations manager or designate. The operations manager shall report to the president in matters related to emergency preparedness, and shall have total authority during emergency situations. The operations manager shall have the authority to declare a state of emergency. In the absence of the operations manager, these authorities shall revert to the president. 4.0 Work Instructions: FIREFIGHTING PROCEDURE i. The cardinal rule in firefighting is to preserve life, and then property. ii. Call for in-house assistance immediately upon discovering the fire. Do not enter a burning room or building without another qualified person to assist. iii. Alert other employees immediately. iv. Determine if the fire can be extinguished with the portable equipment in the building. If it can be used, do so. If not, call the fire department, activate an alarm and evacuate the building. v. The person discovering the fire should notify the telephone operator, giving exact location and nature of fire. vi. The telephone operator will notify the following in turn: a. engineering control room; b. time office; c. operations manager; d. maintenance department; Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 38 5. Emergency Preparedness and Response - Toolkit e. safety manager/fire safety officer; f. all other heads of departments; and g. house doctor. vii. The telephone operator will remain on duty as an information and control center unless instructions or condition dictate otherwise. viii. As soon as the electrical department is notified, the electrician shall cut off the power supply of the affected area, landing down the elevators (if available) to the ground level and provide adequate lighting (emergency lighting if extra required) arrangement for firefighting or evacuation. ix. The maintenance department or the plumber shall reach the fire hydrant pump room (if safe) for smooth pump operation. x. The emergency controller (operations manager or the shift in-charge) will take appropriate decisions regarding building evacuation, firefighting with the help of internal trained team and/or notifying the city’s fire department. BUILDING EVACUATION A quick decision and effective evacuation operation is of utmost importance in order to prevent loss of lives. The procedure of evacuation should be handled with expertise and without loss of time. When evacuation of a building is necessary, everyone must leave by the nearest exit or as advised. i. Close but do not lock doors behind you as you leave. ii. Employees and visitors are to gather near the designated muster point in a safe area that is upwind from smoke or toxic gases and in an area that will not hamper emergency vehicles or services when they arrive. iii. A head count must be done to ensure that everyone is accounted for. iv. Employees are not to re-enter the evacuated building until so advised by the designated officer (operations manager or safety manager). v. In case a rescue operation for a trapped employee/visitor is required, it must be performed by trained and competent personnel equipped with suitable PPEs. MEDICAL AID Get first aid treatment for all minor injuries; first aid is only temporary. First aid is the immediate treatment needed before you get a doctor to the victim or the victim to a doctor. What you do in the critical moments after an injury occurs could save a life. Know the basic first aid procedures. Review them often so you will be prepared if you suddenly find yourself in an emergency situation. The most important things you should do when someone is injured is to survey the scene to determine if the situation is safe or the victim is required to be moved from a dangerous location to a safe place. Call for emergency medical help immediately for all life-threatening situations. Send people to guide the emergency team to the victim. FIRST AID FOR FIRE INJURIES AND BURNS i. Move patient to fresh air. ii. Move the patient from the heat of fire. iii. Do not allow crowding around the patient. iv. Remove or cut away clothes from affected parts of the body. v. Open buttons and loosen clothing. vi. Pour chilled water on the affected parts. vii. Apply any antiseptic cream. viii. Get a doctor. Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 39 5. Emergency Preparedness and Response - Toolkit ASPHYXIA If the patient has difficulty breathing or there are symptoms of collapse: i. Give artificial respiration with respirator or mouth-to-mouth respiration. ii. Give oxygen. iii. Take the patient to the hospital or medical help. SHOCK If the patient perspires, body is cold and has a low pulse: i. Cover with a blanket. (Do not touch burned parts.) ii. Keep the victim lying down. iii. Elevate feet if you do not suspect head or neck injury or leg fracture. iv. Get medical help. v. Monitor vital signs. vi. Prevent loss of body temperature. vii. Take the patient to a hospital immediately. 5.0 Emergency Response Team: The purpose of the Emergency Response Team is to deal with catastrophic accidents within the company. The team’s responsibilities are to immediately meet when an emergency situation is reported and to determine the course of action. Emergency Response Team members NAME TITLE HOME PHONE CELL PHONE President Operations manager Shift-in-charge Chief security officer OHS manager Firefighting team member 1 Firefighting team member 2 Firefighting team member 3 Emergency Response Team members may be called upon on short notice 6.0 Reference Documents: Evacuation plan, plant map with locations of emergency exits, firefighting equipment and first aid stations. 7.0 Records: Training logs, drill logs, firefighting and medical equipment maintenance and inspection logs; water gauge and pressure inspections logs 8.0 Approving Authority: Operations manager 9.0 Issue/Revision Date: November 27, 2012 Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 40 5. Emergency Preparedness and Response - Toolkit Sample Ammonia Leakage Preparedness and Response Procedure - Flowchart Hazard risk: Ammonia is a health hazard that is toxic and corrosive to skin, eyes and lungs. It is a liquid that quickly turns to a flammable gas (anhydrous ammonia) when in contact with air. It makes an excellent refrigerant in food processing. Install power source Install refrigeration separate from machine Isolated machinery in No Separate power Yes refrigeration No detached building room power so that source for shutting down power to locations? or cut off room ventilation? with doors leading machine room does not affect ventilation systems directly outside Qualified operators in refrigeration systems? No Yes Hire qualified refrigerant operators who can Designate and train recognize the problems employees as emergency before system breakdown response team Hazard materializes: Faulty valves, pipe or compressor failure. Human detection: ammonia pungency means Automated detection No through ammonia Yes it can be detected at low System detects hazards concentration (5 ppm sensing alarms upwards) Emergency response team informed (continued next page) Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 41 5. Emergency Preparedness and Response - Toolkit Emergency team informs fire brigade or if no fire brigade takes the following action for fires: for small fire use dry chemical or carbon dioxide; for large fire use water spray (no direct jet). Fight fire from maximum distance using unmanned hoses. Emergency team identifies ammonia hazard, establishes wind direction, sets up isolation zone (at least 300 feet from spill or leak), tailors evacuation plan accordingly Put on personal protective equipment appropriate for ammonia, including self- contained breathing apparatus Decontaminate any Emergency team rescues spillage area (e.g., do Specialist and removes any person not walk through spill, contractor in leak area and treats for stop leak and prevent effects short-term effects of spillage into waterways, repairs ammonia poisoning divert vapor cloud) Decontaminate victims and administer first aid where necessary: for eyes, skin, inhalation or ingestion exposure Keep an eye out for long- term/delayed effects (over eight hours) of exposure to ammonia Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 42 6. Stakeholder Engagement - Toolkit Introduction Your company interacts with many different groups of stakeholders. A stakeholder is any person or organization that has an interest in or is affected (or perceives to be affected) by your company. Engaging with stakeholders will help you understand how to avoid or minimize any negative impact and reduce the risks to your business from anti-company sentiments and negative campaigns that could affect your company’s reputation. We present three tools related to this element: • Stakeholder Mapping Tool • Impact Zoning Tool for Identifying Affected Communities • Stakeholder Engagement Plan Worksheet Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 43 6. Stakeholder Engagement - Toolkit Stakeholder Mapping Tool – Identification and analysis Instructions 1. Ensure you have a cross-functional/departmental team to start the exercise. 2. List relevant stakeholders for your company (e.g., those directly and indirectly affected by your company, those that have an interest in your company operations, those that have an ongoing relationship with the company, those that have the ability to influence your company operations). Provide as much detail as possible (i.e. name your main suppliers independently; disaggregate communities by identifying local leaders or other relevant actors). 3. Next to each stakeholder group, discuss and list their key concerns, issues, interests. Stakeholder Issues/concerns/interests 4. Place these stakeholders on the stakeholder map according to the degree to which they are impacted by your operations and their capacity to influence your company operations. Quadrant 1= Quadrant 2= High Involve as needed Proactively approach and support them Capacity to influence Quadrant 3= Quadrant 4= Keep them informed Respond to their concerns Low Low High Degree impacted by the company 5. Classify stakeholders according to their current relationship with the company: supportive, supportive with conditions, neutral, negative. The purpose of stakeholder engagement is to keep supportive stakeholders happy and help address the concerns of less-supportive stakeholders. Remember that stakeholders’ relationships with the company may change over time. We recommend that you analyze their current position to the company. Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 44 6. Stakeholder Engagement - Toolkit 6. Identify the groups that represent a high priority for engagement. 7. Define strategies to engage with the prioritized stakeholders. When defining engagement strategies, keep in mind current initiatives of the company. Engagement strategies should be differentiated, based on where stakeholders are located on the map:  Quadrant 1: Involve them as needed  Quadrant 2: Proactively approach and support them  Quadrant 3: Keep them informed  Quadrant 4: Respond to their concerns 8. Review the map at regular intervals and when there are major changes. It is advisable to review the stakeholder map with external groups to get their feedback. Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 45 6. Stakeholder Engagement - Toolkit Impact Zoning Tool for Identifying Affected Communities Instructions Affected communities are defined as any people or communities located in the near proximity of the company’s facilities who are subject to direct company-related actual or potential adverse impacts on their environment, health and livelihood. A quick and practical technique for identifying affected communities is “impact zoning mapping” (see box below). By mapping the sphere of influence of different types of environmental and social impacts, the company can begin to identify distinct groups by impact area, and from this prioritize stakeholders for consultation. While priority should be given to individuals and groups who are directly and adversely affected, drawing a line between who is affected and who is not can be challenging. Communities lying just outside of the designated impact area can “perceive” impacts or feel they have been arbitrarily excluded from the engagement process. HOW TO IDENTIFY STAKEHOLDERS THROUGH IMPACT ZONING 1. Draw a sketch map (see figure below as an example) of the key design components of the project, both on- and off-site, that may give rise to local environmental and social impacts (e.g. the project site; ancillary infrastructure such as roads, power lines and canals; sources of air, water and land pollution). This may be performed more efficiently by using aerial photographs or satellite images. 2. Identify the broad impact zones for each of these components (e.g. the area of land take, air and water pollution receptors, etc.). 3. After identifying and mapping broad stakeholder groups, overlay those groups with the impact zones. 4. Through consultation with relevant stakeholder representatives, verify which groups are potentially affected by which impacts. Source: Doing Better Business Through Effective Consultation and Disclosure. IFC (1998). Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 46 6. Stakeholder Engagement - Toolkit Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 47 6. Stakeholder Engagement - Toolkit Stakeholder Engagement Plan Worksheet Instructions After the identification of your most important stakeholders, the next step is to develop a plan for how to engage with the groups that you listed. Engagement should be stronger and more frequent with those groups that are most affected and those that have a greater ability to influence your business. At a minimum, you should always implement an external communication procedure to receive communications from the public and accordingly adjust your management program. In the presence of adversely affected stakeholders, you should implement a grievance mechanism and actively engage them in consultation, regularly disclosing clear and meaningful information and providing communities with opportunities to express their concerns and suggestions. Finally, you should report back to them on the actions your company has put in place to address the issues identified during the process of consultation. Stakeholder engagement plan for affected stakeholders Stakeholder Concerns Engagement method Information to Most disclose and report valuable info back to obtain Farmer Groundwater - Grievance mechanism - Level of water Exact threat, association X supply: possibly - Quarterly meetings with consumption at the damage, (Quadrant 2) diminishing and members of the association plant possible contaminated by and more frequently as - Progress on water solutions, saltwater has demand requires saving/recycling actions costs of these caused crop failure - Participatory monitoring at the plant and cattle loss of groundwater level - Results of groundwater - Annual perception survey level monitoring Local village Water supply - Grievance mechanism - Progress on water Identification population (especially falling - Biannual meetings with saving/recycling actions of areas (Quadrant 2) groundwater levels) community leaders at the plant where to build and quality for - Annual perception survey - Plan to build 50 deep deep wells consumption wells in most affected areas Consumers Food safety - Grievance mechanism - Progress on actions to - Consumer (Quadrant 4) through telephone hotline improve quality of concerns - Well-briefed process water and food - Ways communications team to safety competitors address consumer concerns are addressing the issue Stakeholder engagement plan for interested stakeholders Stakeholder Interests Engagement method Information to Most communicate valuable info to obtain Labor rights Migrant workers - Quarterly updates through - Progress on directly Local promotion discrimination email contracting migrant information network workers (reduce use of on workers’ (Quadrant 3) contracting agencies) rights Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 48 7. External Communication and Grievance Mechanism - Toolkit Introduction Grievance Mechanism The purpose of a Grievance Mechanism is to establish a way for an individual or a group within communities affected by your business to contact you if they have an inquiry, a concern or a formal complaint. It provides people with an alternative way of communicating with your company as part of your formal stakeholder engagement process. External Communication Even if affected communities per se are not identified, you should always establish and maintain a publicly available and easily accessible channel for the public to contact you (e.g., phone number, website, email address, etc.). External stakeholders can provide valuable information such as suggestions on product improvement, feedback on customers’ interaction with your employees and comments from regulators, NGOs and individuals regarding your company’s environmental and social performance. We present two tools related to this element: • Checklist for Effective Grievance Mechanism • Grievances Log Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 49 7. External Communication and Grievance Mechanism - Toolkit Checklist for Effective Grievance Mechanism Instructions The following checklist will guide you on the key aspects that an effective grievance mechanism should have. We list here some illustrative examples; consider adapting these to your company’s size, complexity and local context. Key aspects of effective Company’s method grievance mechanisms Provide ease of access to Form and instructions on website that people can fill in and submit online confidentially Email address communicate or file Telephone hotline complaints, including anonymous ones Suggestion boxes located outside the company gate and in strategic places (e.g., churches, municipality, civic centers) Weekly visits by a designated community liaison to affected villages to register complaints Publicize the system so Distribution of brochures at churches, schools and civic centers highlighting that stakeholders know it company profile and operations and including instructions for how external exists and how to access it stakeholders can communicate or file complaints, and the procedure to handle them Written procedure is explained by general manager/designated community liaison when meeting with community leaders and other stakeholders Foster sense of legitimacy Major cases reviewed by a formal multi-stakeholder oversight body (i.e., and trust; encourage company, representatives of affected communities, NGOs, university, dialogue and shared municipality) responsibility for Provision of transparent funding for expert resources, so that any collection of outcomes evidence is independent and unbiased Most serious claims resolved through independent mediation Be transparent about the All cases are summarized with details about whether the complaint is accepted or process and outcomes not and what is the process and timeline for investigation and resolution Summarized cases are posted on the company website and/or reported back to the complainant through letter/email/community liaison Implement a predictable Company assigns an employee or team to record complaints and then work with and defined process that relevant staff and external stakeholders to investigate, determine actions and includes assignment of report back outcomes responsibility, time limits and monitoring of outcomes Make the system a source Complaints are systematized and reviewed periodically with the management of continual learning team to check for effectiveness of the system and cumulative learning that can be integrated into the company systems Company performs perception surveys among affected stakeholders regarding the awareness, accessibility and trustworthiness of the grievance mechanism Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 50 7. External Communication and Grievance Mechanism - Toolkit Grievances Log Instructions: Keeping a logbook or database of grievances allows you to monitor their state of resolution. Also, when grievances are systematized, the information can be analyzed and used as a feedback mechanism for improving operations. This tool provides an illustration of useful information to annotate when recording a grievance. 1. Grievance identification number 2. Details of complaint 2.1 When it occurred 2.2 Where it occurred 2.3 How it occurred and who was involved 2.4 Complainant(s)’s story and expectation 2.5 Date grievance was recorded 2.5 Place/method grievance was received 3. Profile of complainant(s) 3.1 Gender 3.2 Age 4. Contact information of complainant(s) 4.1 Anonymous (Y/N) 4.2 Phone 4.3 Email 4.4 Address 5. Complaint accepted (Y/N) 5.1 Complaint NOT ACCEPTED 5.1.1 Action taken Clearly not related to the operations of the organization – rejected  Labor-related grievances – transfer to HHRR  Commercial disputes – transfer to commercial dispute resolution mechanisms or civil court  Related to governmental policy and institutions – transfer to authorities  Other  5.1.2 Complainant notified (Y/N) 5.1.3 Method of notification 5.1.4 Date of closure 5.2 Complaint ACCEPTED 5.2.1 Category of complaint Particulate emissions to air  Odor  Noise  Effluents  Company vehicles  Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 51 7. External Communication and Grievance Mechanism - Toolkit Influx of migrant workers  Security personnel  Other  5.2.2 Photos and documentary evidence of legitimacy 5.2.3 Resolution instance First: Internal  - Responsible people/division: Second: Multi-stakeholder oversight body  Third: Independent mediation  5.2.4 Resolution/corrective action taken 5.2.5 Complainant notified (Y/N) 5.2.6 Method of notification 5.2.7 Complainant(s) satisfied or appealed 5.2.8 Photos and documentary evidence of closure 5.2.9 Resources spent 5.2.10 Date of closure 5.2.11 Days from complaint to closure Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 52 8. Reporting back to Affected Communities - Toolkit Introduction Affected stakeholders will want to know what actions your company has put in place to resolve the issues identified when communicating with them. Keeping them informed of what you are doing is the final critical piece in building and maintaining a good relationship. We present one tool related to this element: • Formats and Venues for Ongoing Reporting Format and Venues for Ongoing Reporting Instructions Look at the list to brainstorm ideas on ways you could communicate back to affected stakeholders on actions taken and monitoring results in their areas of interest. - Open houses - Banners outside the company gate - Brochures distributed in churches, schools, civic centers - Website - Town hall meetings at the local municipality or civic center - Meetings with representatives of the affected stakeholders - Letters to representatives of the affected stakeholders and complainants - Emails - Phone calls - Sustainability reporting (e.g., GRI) Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 53 9. Monitoring and Review - Toolkit Introduction Monitoring and review are critical because this is how you check and adjust your ESMS. You need to monitor whether your action plans are being implemented, procedures are followed and whether your ESMS is addressing the relevant risks and providing lasting improvements. The goal of the ESMS is to shift from corrective actions to preventive actions. Monitoring and management review is what gives you the information to do this. We present two tools for this element: • Monitoring Plan • Auditing Guidance Monitoring Plan Instructions Look at your action plans and think about process and performance indicators that will tell you if the actions are being implemented and if they are achieving your targeted objectives. Example Objective: Reduce water consumption by 30% Actions: - Replace taps and washing hoses/nozzles with high-efficiency ones - Implement dry cleaning procedures Performance indicators Monitoring Indicators Monitoring records Monitoring equipment Freshwater - Water meter reading logs at all intake points - Sealed water meters consumption in kl per by department per shift (to be recorded as at all intake points ton of processed “initial reading” and “final reading”) product - Record of product processed per shift in tons Process indicators Monitoring indicators Monitoring records % taps and washing hoses/nozzles with high- - Maintenance records - leaking and replaced faucets, efficiency taps/nozzles hoses and nozzles % of cleaning staff trained on housekeeping - Training records and dry cleaning procedures Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 54 9. Monitoring and Review - Toolkit Auditing Guidance Instructions Go through all the areas highlighted in the Auditing Guidance – this will help you to get a broad view of all potential risk areas and elements of the ESMS beyond those that you may have targeted in your initial risk assessment.  A. Preparation Collect audit reports for the factory on environmental performance, labor standards performance and community stakeholder engagement, for the previous two years. Collect corrective action plans generated from previous audits and review the status of each action item that was agreed from previous reviews. Are all closed out? Focus review on open items and the underlying reason(s) for incomplete status, and ensure that the audit considers the underlying issues for the upcoming audit. Focus should be on the underlying limiting factors that prevent completion. Ascertain the general level of PPE used in the plant; ensure that what employees are required to wear (head, hearing, eye, skin protection), protective boots, clothing, etc. is applied to auditors; do not allow any auditor to enter work areas without the clothing/gear required for the operations activity and that employees are required to wear. Obtain facility floor plans designating work areas, break areas, activities underway, flow of materials, clean areas, dirty areas, location of fire extinguishers, fire exits, emergency lighting and protective covers, restrooms, cleaning and cross-contamination prevention areas (boot, hand wash and disinfection), principal water outlets and drains, any non-potable water outlet (e.g. fire water) clearly marked as non-potable and for emergencies only, skylights and other roof penetrations status, and prohibitions and barriers to entry for vermin, birds and animals. Ensure auditing team has a working knowledge of the facility/operation to be evaluated. Research and refer to current local environmental and labor laws and regulations. Basic labor code issues: (i) regular weekly work hours, (ii) labor contract provisions, (iii) rest periods, lunch, etc., (iv) overtime requirements, limits and exceptions, (v) hour averaging and banking hours, (vi) minimum wage, (vii) social system payment liability, (viii) annual leave, (ix) laws to protect disadvantaged workers, (x) severance pay. Basic environmental code issues: (i) wastewater, (ii) storm water, (iii) spill prevention and response, (iv) construction/demolition/remodeling, (v) hazardous materials, (vi) hazardous waste, (vii) toxic chemical release, (viii) air emissions, (ix) solid waste. Review regulatory permit(s) conditions and specific requirements along with most recent review and corrective action reports. Review certification(s) audit reports (e.g. HACCP) for nonconformance, mandatory remedial actions, recommendations, etc. Summarize status of items (open or closed). Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 55 9. Monitoring and Review - Toolkit Review any government inspection reports, third-party audit reports, etc. Review the stakeholder engagement plan and records of grievances by external stakeholders. Pay attention to emergency preparedness and response capability to include the community if necessary; use of pesticides and drift to communities; accidental releases of hazardous materials, e.g. chlorine; discharges of wastewater or other wastes to areas affecting local communities; exacerbation of flooding; limits of water availability use and physical access; diminution of quality of life due to the operation. Pay special attention in observation/document review/interviews to issues identified in previous reports. Research and understand the national and local context of labor union rights and activity, local environmental groups and community activist organizations. Schedule sufficient time to conduct the scope of the audit. Announce the availability of confidential meeting schedules with employees; schedule, arrange and conduct while protecting employee confidentiality.  B. Introductory Meeting with Management Meet with the senior management and department managers before conducting audit activities to review ESMS issues and the purpose of the audit. Share an agenda for the meeting and itinerary with senior management and department managers. With department managers, review the prior audit reports and performance to date in meeting corrective actions. Discuss non-retaliation against cooperating workers; inform management that future audits will include reviews of the continued employment of workers interviewed.  C. Operational Walk-Through Conduct operational walk-through following the flow of production from receipt of raw materials to shipment of finished goods. Refer to previous relevant physical walk-through assessments of the facility; determine if all previous nonconformance/action items are closed out; if not, why not? Minimize the number of managers that accompany you on the walk-through. One or two escorts based on knowledge/responsibilities are usually sufficient. During the walk-through, be aware of your body language and the message this sends to workers; ensure that you are equipped with/wearing the same PPE required of employees. Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 56 9. Monitoring and Review - Toolkit Take note of all things observed that require attention: (i) water used indiscriminately for washing/cleaning, water wasting (open taps on floor); (ii) energy wastage; (iii) evidence of spillages; (iv) floor status: slippery, wet, etc.; (v) dry cleanup and collection of organic solids; (vi) harborage or other unorganized storage of materials; (vii) wastes and discards; (viii) workplace availability of data on hazards/chemicals in use (MSDS/ICSC); (ix) movement of materials: hand trucks, forklifts, etc. Are the passageways and transit routes clearly marked; is color-coding used for non-pedestrian movement?; (x) obvious hazards for heads, hearing, sight, life and limb: Workplace hazards attenuated; employee awareness?; (xi) PPE used as prescribed, available, replaced at no cost; employee awareness; (xii) Are employees able to explain jobs and responsibilities?; and (xiii) evidence of QA team activity. Verify that fire exits exist and open on demand; no means to prevent exit; panic bars in good working order; clear egress once exit opened; emergency exits clearly marked; nearest exits clearly marked; hose cabinets equipped with hoses, nozzles, etc.; prohibited areas clearly marked; electrical cabinets closed and sealed; lockout tag out procedures and tools (tags, locks, warning labels and signs) clearly available near electrical cabinets; first aid cabinets and equipment; emergency lighting; emergency preparedness and evacuation plans in place; employees trained. Ambient conditions should be verified for adequacy if potential for risks such as air quality, noise, etc. Use measuring devices to determine air quality, noise level, temperature and adequate lighting. This is a good/easy thing to do. For dusty operations or potentially dusty areas there should be LEL (lower explosive limit) meters and alarms installed; this is not so important for food manufacturing, but products such as sugar dust when ignited can lead to catastrophic explosions, loss of life and the end of the manufacturing facility. Following the facility walk-through, conduct a walk-through of the dormitory facilities, canteens, washrooms, change rooms. Note location of same and if there are flow crosses with clean to dirty flow; for example, if an employee needs to leave the production area to use the toilet is he/she required to clean and disinfect boots, wash and disinfect hands, etc. or does he/she just return to work without sanitary precautions? Similar situations? (if applicable) Suggest best practice to supervisors and department managers during the walk-through; ensure that the suggestion is filtered by processes/operations practicalities. Give sufficient attention to all ESMS elements during the operation/dormitory walk-through. Knowledge of procedures, training using the procedures, awareness of complaints management and resolution procedure, employment rights, HR policy and provisions, etc. Identify all incidences of non-conformance with ESMS issues, both major and minor. Pay special attention to areas identified in previous corrective action requests. Focus on open non-conformances from previous audits: why? Elucidate the underlying cause and make an Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 57 9. Monitoring and Review - Toolkit effort to diagnose and prescribe preventive, ameliorative measures. The individual who is responsible is not as important as why and how to prevent non-conformances and unplanned events in the future.  D. Interviewing Workers Select at least 5 percent of workers. Cap at 100 workers. Conduct individual and group interviews for balanced response. Select workers who are representative of the workforce population (gender, race, age, religion, functional departments, etc.). If the factory has contracted or migrant workers, make sure to select from all groups. Do not allow supervisors or managers to influence selection of workers for interviews or the interviews. Conduct on-site interviews in areas that protect worker confidentiality and where the worker would feel comfortable. Make sure supervisors or managers are not in or near the space where the interviews are conducted. Keep them away from the selection and interview process. Conduct interviews early in the audit to allow for follow-up. Make sure to tell the workers that everything they say is confidential and that management has been warned against retaliation. Be sensitive to cultural and gender issues. Plan for an average of fifteen minutes per interview; however, use common sense in terminating interviews that are becoming nonproductive and extending interviews with people who are candid or openly addressing critical issues. Formulate questions prior to the interviews to make sure you cover all specific areas of the ESMS review through the aggregated interviews. Always ask employees how processes may be improved, water use reduced, energy saved, waste reduced, etc. If you plan to take notes, ask the workers if it is OK and clearly explain reason for taking notes. Try to minimize note taking as much as possible during the interview. Finish writing your notes immediately after the interview, so you have accurate documentation. Have your worker representatives recommend a preferred approach to building rapport with workers. Ask workers specifically about follow up on previous corrective action plans. What non- conformances remain open; what issues presented through the complaints management and resolution mechanism remain open? Make sure your questions address the following: Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 58 9. Monitoring and Review - Toolkit LABOR ISSUES  Do workers know about and understand your policies related to labor and working conditions?  Do workers understand their rights under the law related to freedom of association and collective bargaining?  Do workers understand how their wages are calculated, for base time, performance and overtime?  Are workers aware of any dismissal, transfer, demotion or other punitive action against workers due to their exercising their rights under either their contracts or local or national law?  Ask workers about the status of trade unions, worker committees or other worker groups in the factory and whether there is management interference.  Ask questions to determine conformance to discrimination and sexual harassment policies.  Do workers understand the company’s grievance mechanism, and do they feel it is operational and free from retaliation? OCCUPATIONAL HEALTH AND SAFETY ISSUES  Do workers feel safe and protected in their jobs? For example, are they provided with PPE that is appropriate and works? Is their physical environment free of hazards and obstructions? Are they expected to reduce physical hazards or are engineering controls in place? Are there job hazards assessments done routinely and when the processes or materials change? Have issues submitted through the complaints management and resolution mechanism been addressed?  Do they feel there is adequate safety equipment and safety drills if an emergency were to arise such as working fire escapes, extinguishers, first aid kits? Ask employee to show you how to get out of the area through a planned and well-lit emergency exit; follow the employee and observe shortcomings; ask employee to pretend he/she has just been injured and explain what to do next.  Are they instructed and trained on these risks at regular intervals?  Have any workers been involved in accidents at the facility and, if so, what happened afterwards?  Is the environment comfortable to work in, in terms of air quality (no coughing), ventilation, adequate illumination for the task at hand, natural light wherever and whenever possible, light, oppressive humidity or heat?  Do they feel that chemicals, waste and other substances are stored or disposed of safely and appropriately at the facility? Access to and training using Material Safety Data Sheets (MSDSs) and/or International Chemical Safety Cards (ICSCs)? Response to any expressed issues through the complaint management and resolution mechanism? If the organization employs contract workers, make sure to ask questions that address possible violations and areas of abuse. Do you feel different from a permanent employee? Why? Conduct some worker interviews off-site if possible. Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 59 9. Monitoring and Review - Toolkit  E. Interviewing Affected Communities and Other Stakeholders The stakeholder mapping exercises and stakeholder consultation meetings should help identify the relevant population that is affected by the facility and its activities. Select a sample of individuals that represent the views of this affected community. It may include members of the public as well as NGOs, campaign groups, trade unions, local businesses and government authorities. If possible, target NGOs that are industry-specific. Filter out disgruntled former employees or those with an axe to grind. Do seek out former employees if possible. Gauge awareness of the grievance mechanism. Has it been tested? Does it work? Is it a sham and the company ignores it? Or is it taken seriously? Be sure to include representatives from indigenous or marginalized groups in these interviews. Make sure your questions address the following:  How have the facility's operations affected the physical environment (air, water, land) near them?  Has this resulted in either air, land or water contamination?  Has wildlife been affected by the facility's activities?  Has the facility's business impacted local livelihoods, access, traditional hunting/fishing/breeding/religious/other grounds due to natural habitat conversion?  Have any health risks or deterioration to well-being been associated with the facility from exposure to toxic chemicals, from air emissions or noise pollution? Awareness of any neighbors or employees with sick kids, notable abortion rates.  Have any contagious illnesses been on the rise due to an influx of workers to the plant? Malaria or other local vector-borne disease; is the community aware of an increase in the rat/mouse or other vermin population?  Have these affected groups had any clashes with security hired at the facility?  Have any of these groups consumed goods or products from the facility that have had a deleterious effect on their health? Any level of awareness of company's refusal to replace questionable goods?  Have any of these groups been approached or invited by the company running the facility to discuss their concerns at meetings or had any of their grievances addressed and investigated or had any follow up to their questions?  F. On-site Document Review LABOR ISSUES: Make sure you review the relevant documents for the following areas: Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 60 9. Monitoring and Review - Toolkit 1. Human resources: Management-worker committee meeting minutes, memos and letters, budgets related to implementing labor policy, training material, logs and curricula or written communications to workers that address all issues, training records and instructor qualifications. 2. Working conditions: Contracts for all workers; policies and procedures related to wages, benefits, hours and leave; evidence of communication and training on wage calculation; personnel files; time cards; payroll records and pay stubs (selected without management interference); criteria used to set performance pay bonuses; and employment and termination records. 2.5 Are employee payment methods secure? Are employees able to have monies deposited into an account, or are they burdened with cash payment at the facility and risk life and limb getting home on pay day? 3. Collective bargaining: Collective bargaining policy, agreement and documentation (such as minutes and records of collective bargaining sessions). 4. Discrimination: Discrimination policy; related procedures; documentation handling discrimination issues; diversity training and attendance log; hiring, promotion and termination records; gender demographics in facility at worker and manager levels. 5. Retrenchment: Policies and procedures for workforce reduction, severance and transition; documentation of prior workforce reductions; minutes of management meetings and communications to workers on this issue. 6. Complaint management and resolution mechanism: Documented procedure, communications, records and logs of grievance handling. 7. Child labor: Procedure for age verification, documentation of apprentice program, birth and medical records and school records of workers. 8. Forced labor: Employment contracts (as well as for those workers hired through recruitment agencies), payroll records, timesheets and wage deduction, worker passports and IDs. 9. Health and safety: Accident and medical treatment logs, equipment safety logs, logs of fire and safety drills, health and safety risk analyses, government health inspection reports, safety certificates and training curriculum and logs, and evidence of changes to all of this when company processes, methods, chemicals, materials, etc. are changed, reordered, etc. Select files and/or records at random to generate a representative sample of the workforce population and functional distribution in the factory. Seek some files to corroborate interviews conducted earlier. Balance your time and effort investigating all areas of labor standards at work. Document review is particularly critical for wages, working hours, health and safety, use of sub-contractors, hiring and termination. If the operation employs contract workers, address potential areas of abuse in the document review. Specifically review the contract with the workers. Identify all significant incidences of non-conformance in preparation for your management meeting. ENVIRONMENTAL AND OSH ISSUES: Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 61 9. Monitoring and Review - Toolkit Make sure you review the relevant documents for the following areas: 1. Emergency response and preparedness: Examine the facility's emergency response procedures and accident reports, as well as documents indicating that workers have been trained on these issues. Ask the employee to show you how to get out, assuming that there is now a fire; follow the employee; ask another to tell/show you what happens if he/she was just injured. 2. Environmental management: Examine any company environmental policies and environmental management system policies and reports, including sustainability reports, energy consumption records, guidelines and monitoring, resource use and waste generation. Status of previously noted non-conformances. 3. Insurance: Identify documents that indicate legal permits have been obtained, insurance policies are in place and the relevant legal authorities notified of the facility's activities. 4. Technical: Documents on production processes, and storage, purchase and maintenance of facility equipment. Availability of MSDS/ICSCs and employee training and orientation to the specific risk posed by materials in use; response to submissions through the complaint management and resolution mechanism. 5. Waste disposal: Policies, procedures, guidelines on elimination and recycling of waste emissions and effluents to air, water and land, including monitoring of the quantity and quality, treatment and disposal of all waste, including wastewater and solid waste; are employees/area supervisors queried for opinions on improvements? 6. Hazardous material: The storage of chemicals and toxicology sheets (MSDS/ICSCs from ILO/WHO/EU/UNEP, etc. Avoid total reliance upon manufacturer's statements). Does procurement mandate furnishing such materials? 7. Health and safety: Check for the existence of logs of accident and fatality rates, health and safety guidelines or handbooks for workers and monitoring of these statistics, including the job hazard analyses and engineering corrections to eliminate hazards at the source, as opposed to requiring employees to mitigate environmental hazards; provision of appropriate PPE that cover actual, defined technical, physical, biological and chemical hazards in the workplace; Tool Box safety meetings records. 8. Work environment: Look for guidelines, reports, logs and "ecomaps" of the facility work environment that monitor emissions of dust, odors, sources of noise and vibrations and worker exposure to heat and cold. LEL meters and audible and visual alarms are mandatory wherever there may be accumulations of dust or ambient dust. 9. Sanitary: Review policies, procedures, guidelines and reports (including from relevant government departments), as well as training manuals and logs on staff hygiene and food safety management. Ask to use the toilet; be shown where and how to access for both men/women; asses the reentry procedures.  G. Closing Meeting with Management Conduct a closing meeting with senior management and department managers. Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 62 9. Monitoring and Review - Toolkit Present your preliminary findings with particular emphasis on the positives as well as areas for improvement. All new and previously existing non-conformances must be addressed. Seek clarification on any findings or issues raised during the audit. Work with the department managers and supervisors on a corrective action plan that details specific actions to be taken and timelines for their completion. Go over any outstanding corrective action requests from previous audit reports. Make sure senior management signs off on the corrective action plan. Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 63 II ESMS Case Studies FOOD AND BEVERAGE Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 64 ABC Case Study – ABC Food Company, Thailand ABC Food Inc. (ABC Company), established in January 2001, is a regional poultry producer, processor and marketer. It is located in Thailand. The factory has a production capacity of 65 tons per day and a work force of over 400, with three shift operations. It primarily exports to Japan and other Asian countries, but also has recently started to attract new customers in Europe, the Middle East and South America. With a strong eye on the export market, the company is committed to high-quality production. The company focuses on quality controls and consistent product development to comply with international standards and the requirements of its customers. The company also works closely with numerous local farms to ensure an adequate supply of poultry. This helps the company to reduce the high costs of transportation and to ensure freshness, in order to maintain high quality and competitive prices. ABC is concerned because of a recent product recall involving another local poultry processor that was sourcing from many of the same suppliers. Someone involved in the inquiry has told ABC that this was most likely from the small farms using well water from their properties for animal and equipment sanitation. On-site sanitary waste facilities (privies) are typically located upstream of the water wells and the farmers’ water is frequently contaminated with fecal coliform bacteria and an array of pathogens. Moreover, the processing facility’s source of water was contaminated as well, so that production and machine cleaning was leading to unacceptable levels of bacteria in the processed meat. ABC recently received a multinational fast food restaurant chain endorsement to be a supplier of chicken nuggets. Typically, multinationals issue very large orders but mandate reduced unit rates. The company’s vision of profits was slightly diminished knowing that a major expansion of all aspects of its integrated business was needed, especially the processing facility. Nevertheless, they accelerated construction of a new facility and commenced operations. A poultry processing operation requires significant volumes of potable water. This proved to be a challenge, as ABC was so focused on expansion to meet the market demand and did not have a plan for dealing with sustainability considerations. After six months of operations, local communities and community leaders are expressing concern about diminishing groundwater that virtually all local communities rely upon. The outcry has increased significantly as communities closer to the coast are complaining about salty water in their supply wells, crop failures and afflicted animals. Due to attention from local and international press, the multinational is aware of the situation and is asking ABC to take necessary steps. An NGO contacted by community leaders has brought in a hydrogeologist to assess the situation. Her conclusion is that the poultry operation is pumping so much groundwater that the groundwater surface (water table or piezometric surface) has fallen significantly below the level of most regional wells, thereby denying local residents potable water. Furthermore, the hydrogeologist has concluded that coastal area residents’ experience with salty water in their wells occurred as a result of water table depression from over-pumping, allowing a salt water wedge to enter the aquifer thereby contaminating coastal area groundwater. Raw water quality at the plant is deteriorating. ABC’s high water usage creates large volumes of effluent (wastewater). Disposal of feathers, chicken parts and waste create high volumes of solid waste that is high in nitrogen and pathogens. Discharge of biodegradable organic compounds may cause a strong reduction in the amount of dissolved oxygen in surface waters, which in turn can lead to reduced levels or death of aquatic life. Macronutrients (nitrogen, phosphorus) may cause eutrophication of the affected water bodies. Excessive algal growth and subsequent dying off and mineralization of these algae may lead to the death of aquatic life because of oxygen depletion. ABC also faces challenges with production technology and labor concerns in Thailand, including higher labor costs and a labor shortage. The food industry in the country relies significantly on the immigrant workers who mostly come from Myanmar, followed by Cambodia and Laos. However, a recent news report from one of the leading news media expects a looming labor shortage in the country, linking it to the reforms in Myanmar and related growth in employment opportunities there. It is expected that the economic reforms in Myanmar will tighten the labor market in Thailand over the next few years. Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 65 ABC Case Study – ABC Food Company, Thailand About 40 percent of the total workforce at ABC consists of migrant workers, who are mostly employed at the lower levels. The migrant workers are brought to ABC by a recruitment agency, which handles all of their contracts and payment. Female workers constitute about 35 percent of the total employees in the company. Typically they come with a lower skill level and perform lower-paying jobs. In general, the workforce seems to get along well with each other and with management, but recently there have been a growing number of disputes between workers and also between workers and supervisors. Though the company never had major worker unrest in the past six years, there have been many recent labor disputes in other companies in the region, resulting in strikes and lockouts. The worker turnover rate in the region is high. Another major issue faced by the industry in the country is a recent hike in the average basic minimum wage by the government, making it more than double the average minimum in neighboring countries such as Cambodia, Laos, Myanmar and Vietnam. This has put significant pressure on the industry to stay competitive in the international market. Experts anticipate that the hike in wage costs may increase production costs in the food industry by 5-20 percent, depending on the intensity of labor. Using machinery to replace workers is not a viable alternative, as the poultry processing sector requires human labor, especially for slaughtering, cleaning, trimming, cutting and packaging. The nature of the work also poses challenges for worker health – bodily stress and injuries from machinery and repetitive motion, and exposure to poultry feces and other contaminants. As the company expands, it has noticed an increase in absentee days due to worker illness or injury. To address the labor and productivity issues, as well as the growing concerns and expectations of the local communities, regulators and the international market, ABC aims to establish a fully functional environmental and social management system (ESMS) based on international standards by the end of current fiscal year. Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 66 ABC 1. Policies – ABC Case Study ABC FOOD COMPANY Policy Statement Environment Our company will comply with applicable environmental laws and regulations. We will monitor our emissions and effluents. Resource Efficiency Our company will take feasible and cost-effective measures to improve efficiency in our consumption of energy, water and our most important input materials. Pollution Prevention Our company will avoid or minimize and control as much as possible the release of emissions and pollutants to air, water and land from routine, non-routine and accidental circumstances. Labor and Working Conditions Human Resources Policies and Procedures Our company will have documented policies and procedures related to our labor standards code, in keeping with international standards and national labor law. We will inform workers of their rights under our code as well as national labor and employment law. Working Conditions and Terms of Employment We will provide reasonable working conditions and terms of employment, at a minimum complying with the national labor law. Workers’ Organizations Our company will comply with national laws that recognizes workers’ rights to form and to join workers’ organizations. We will not interfere with or discriminate against workers who choose to organize. We will negotiate in good faith and respect any collective bargaining agreements that we sign. Non-Discrimination and Equal Opportunity Our company will hire, promote and compensate workers solely based on ability to do the job. All workers will be given equal access to training, tools and opportunities for advancement. We will ensure that all workers are free from harassment by management or other workers. Retrenchment If we have a large number of layoffs, workers will receive notice and all due back pay, severance and benefits as required by law. Grievance Mechanism Our company will establish a transparent process for workers to express concerns and file grievances, including anonymous complaints. Management will treat the grievances seriously, take prompt, appropriate action and ensure there is no retaliation. Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 67 ABC 1. Policies – ABC Case Study Child Labor Our company will not employ workers under the minimum age for employment as defined by national law. Workers between the minimum age and 18 will not be employed in dangerous work or work that interferes with their education or development. Forced Labor Our company will not employ forced labor. We will respect workers’ rights to retain their personal documents and money. We will respect workers’ rights to leave the workplace after work. Occupational Health and Safety We will take all necessary precautions to prevent and mitigate work-related risks and develop an emergency prevention and response system. Workers will be provided personal protective equipment and appropriate training at our company’s expense. We will document and report accidents, diseases and incidents. Workers Engaged by Third Parties Our company will extend our labor standards performance policies and procedures to our contractors hired directly or through employment agencies. Supply Chain Our company will extend our principles concerning child labor, forced labor and worker safety to our suppliers, as feasible. Community Health, Safety and Security Our company will take every precaution in our sourcing, production and storage to provide our customers with food that is safe to consume. We will avoid or minimize as much as possible any potential community exposure to health and safety risks from our operations. Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 68 ABC 2. Identification of risks and impacts – ABC Case Study ABC FOOD COMPANY Risk Identification Worksheet LABOR AND WORKING CONDITIONS RISKS RISK FACTORS My company has the Potential negative impact following conditions (A “yes” response means that (circle the appropriate there is a potential negative answer) impact) There is a difference in nationality, race or Yes/No Discrimination. Disciplinary religion between workers and managers. abuse and harassment. Our managers and supervisors are not Yes/No Discrimination. Disciplinary aware of the workers’ rights under the abuse and harassment. national labor law or collective agreements. Excessive overtime. We have an apprentice program that Yes/No Forced labor. Child labor. provides young workers with training and work experience. We routinely use recruiting agencies and Yes/No Inadequate wages, benefits contract workers. and contracts. Forced labor. We routinely use homeworkers or Yes/No Inadequate wages, benefits contractors that use homeworkers. and contracts. Forced labor. Child labor. We routinely use seasonal or temporary Yes/No Inadequate wages, benefits workers. and contracts. Excessive overtime. Some of the workers in my company are Yes/No Forced labor. Discrimination. migrants from another area. We provide a dormitory for some or all of Yes/No Lack of freedom of movement. our workers. Lack of clean adequate space. Excessive charges for the use of the dormitory. There are security guards at our company. Yes/No Lack of freedom of movement. Harassment. We are located in a free-trade zone. Yes/No Inadequate wages, benefits and contracts. There is a large fluctuation in orders Yes/No Excessive overtime. No and/or seasonality of production. payment of overtime due to hour-averaging. Layoffs. There is a labor shortage in my area. Yes/No Child labor. There is no history of collective Yes/No Lack of freedom of association. bargaining, unions or other forms of worker representation at our company. There is no procedure for workers to Yes/No Discrimination. Disciplinary express their complaints (grievance abuse and harassment. mechanism). Worker injuries and chronic conditions. Our processing activities include Yes/No Worker injuries and chronic significant lifting, carrying or repetitive conditions. motions. Our processing activities involve workers Yes/No Worker injuries and chronic routinely interacting with machinery, conditions. equipment with sharp edges and/or Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 69 ABC 2. Identification of risks and impacts – ABC Case Study slippery work surfaces. Our processing activities involve elevated Yes/No Worker injuries and chronic levels of noise, dust, vapors, smoke, conditions. chemicals (e.g., preservatives, cleaning agents), radiation and/or temperature extremes. Our processing activities involve Yes/No Worker injuries or casualties. hazardous materials or processes that could cause fires or explosions. Our processing activities involve the Yes/No Worker illnesses. handling of living and dead animals that can transmit diseases to humans. Our workers don’t have access to Yes/No Worker illnesses. separate and clean areas for eating and changing clothes. Bathrooms are in cramped spaces and Yes/No Worker illnesses. lack access to running water. The companies in our supply chain would Yes/No All of the above. probably answer “Yes” to most of the questions above. ENVIRONMENTAL RISKS RISK FACTORS My company has Potential negative impact the following (A “yes” response means that there is a conditions (circle potential negative impact) the appropriate answer) Our operations require large Yes/No Groundwater depletion in the region. quantities of fresh water. Contamination of ground or surface water sources in the region due to discharge of effluent. High energy consumption for treatment of raw or process water. We don’t have sufficient fresh water Yes/No Groundwater depletion in the region. supplies to meet our requirements. Our operations have a high Yes/No High energy consumption. requirement for power supply. We require large quantities of fuel Yes/No Air emissions. Solid waste (fly ash if coal (gas/diesel/coal/etc.) for our is used). operations. We have various process and utility Yes/No Air emissions. Solid waste (e.g. waste equipment that may generate air from equipment maintenance, fly ash emissions (e.g. boiler, diesel from coal-based boilers). Hazardous generator set, incinerator, grinder, waste (e.g., waste oil, oil-soaked filters etc.). and rags). Liquid waste (e.g. boiler blow- down, waste oil). Noise generation. We need to store large quantities of Yes/No Solid waste due to possible contamination raw materials on site. or deterioration of raw material. High energy consumption or emissions due to cold storage. We generate large (or significant) Yes/No Solid waste. Liquid waste. Contamination Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 70 ABC 2. Identification of risks and impacts – ABC Case Study quantities of solid or liquid waste of land, groundwater and/or surface due to poor quality of raw material water due to improper disposal of solid or rotting of material due to and liquid waste. Wastewater from prolonged storage. cleaning. High energy consumption or emissions due to cold storage. We generate large (or significant) Yes/No Solid waste. Liquid waste. Contamination quantities of solid or liquid waste of land, groundwater and/or surface from our manufacturing process, water due to improper disposal of solid which are not reprocessed into and liquid waste. Wastewater from byproducts, fertilizers or energy. cleaning. The quantity of solid/liquid waste Yes/No Solid waste. Liquid waste. Contamination from rejected finished product due of land, groundwater and/or surface to contamination, rotting, expiry, water due to improper disposal of solid etc. is high (or significant) at our and liquid waste. Wastewater from facility. cleaning. High energy consumption or emissions due to excess or extra production. We dispose of our solid waste in our Yes/No Contamination of land, groundwater (due landfill or city’s landfill facility. to leachate) and/or surface water (due to run-off). Impact on wildlife or fisheries if exposed. Diseases through vectors, foul smell, GHGs generation (e.g. methane). We provide our solid waste to the Yes/No Contamination of land, groundwater (due community or general public to be to leachate), surface water (due to run- used as fertilizer. off) and/or crops if toxic chemicals are present in the solid waste. Our operations generate large (or Yes/No Contamination of ground and/or surface significant) quantities of water due to improper disposal of wastewater (e.g. raw material wastewater. washing, processing, floor cleaning, bottle washing, etc.). We discharge our wastewater Yes/No Contamination of receiving water body (process effluent) in a nearby and aquatic life. Eutrophication due to river/lake/or any other water body. high BOD or COD. We treat our wastewater (process Yes/No Energy consumption. Solid waste effluent) before discharge. generation (e.g. sludge from treatment process, membrane concentrated waste discharge from reverse osmosis, treatment chemicals). Land and/or water contamination due to improper disposal of waste. We treat our sewage (from toilets, Yes/No Energy consumption. Solid waste washrooms, etc.) before discharging generation (e.g. sludge from treatment it in the city’s sewer line. process, membrane concentrated waste discharge from reverse osmosis, treatment chemicals). Land and/or water contamination due to improper disposal of solid waste. We utilize our treated wastewater Yes/No Contamination of land, groundwater (due (process effluent) for irrigation to leachate), surface water (due to run- (either by ourselves or provide it to off) and/or crops if toxic chemicals are Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 71 ABC 2. Identification of risks and impacts – ABC Case Study the community). present in the treated wastewater. Impact on crop productivity. We generate some hazardous or Yes/No Contamination of land, groundwater (due toxic waste (e.g. waste chemicals, to leachate) and/or surface water (due to used/waste oil/sludge from run-off) if disposed improperly. wastewater treatment plants based on chemical treatment, etc.). We require a large land area for our Yes/No Loss of natural habitats or agricultural industrial operations. land. Air, water and/or land pollution based on expansion requirements and infrastructure development. Our operations may have an impact Yes/No Loss of native species. Impact on on the surrounding forest or biodiversity. wildlife. We use some banned Yes/No Non-fulfillment of regulatory chemicals/materials in our requirements. Air, land or water processes. pollution depending on current usage. Exposure of workers or consumers to banned chemicals. We face problems related to Yes/No Use of chemicals. Chemical exposure of pests/vectors. workers. Land or water contamination due to disposal of infested material. COMMUNITY HEALTH, SAFETY AND SECURITY RISKS RISK FACTORS My company has Potential negative impact the following (A “yes” response means that there is conditions a potential negative impact) (circle the appropriate answer) Our processing activities involve organic Yes/No Food contamination/food safety matter that needs to be washed, issues. treated or stored to ensure food safety. Our processing activities and Yes/No Exposure of community to foul odors. treatments involve biomass or other liquids or solids that may lead to foul odors. Our operations involve air emissions, Yes/No Air, water or land contamination, water discharge, solid waste disposal, which can affect the health and leakage of chemicals or gases, etc. that livelihood of local communities. may pass on to the surrounding community. We plan to develop new infrastructure, Yes/No Exposure of communities to air buildings, equipment and other emissions, noise and accidents due to facilities. equipment and vehicular movement. Impact on wildlife, biodiversity and local livelihoods due to natural habitat conversion. Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 72 ABC 2. Identification of risks and impacts – ABC Case Study We plan to decommission and dispose Yes/No Health risks to communities due to of old infrastructure, buildings, exposure to toxic substances (e.g. from equipment and other facilities. chemicals, heavy metals, asbestos, etc.) and air emissions and noise due to equipment and vehicular movement. Impact on wildlife and biodiversity. There is significant movement of Yes/No Exposure of communities to air vehicles in and around our facility due emissions, noise and accidents due to to our operations (e.g. vehicles carrying vehicular movement. raw material or finished products, movement of water tankers, etc.). We store hazardous chemicals or Yes/No Health risks to communities and hazardous waste in our facility. negative impacts on wildlife and biodiversity due to the intentional or unintentional (spills) release of hazardous or toxic substances contaminating air, land and/or water. We discharge water from our plant, Yes/No Negative impacts on local food security which may have an impact on and income generation due to surrounding water bodies. contamination of aquatic life. Diseases/illness among local communities due to the use of contaminated water. We hire temporary and migrant Yes/No Communicable diseases brought or workers. spread by the influx of workers. We hire private security personnel Yes/No Conflicts with communities and indigenous people. We normally have conflicts/complaints Yes/No Conflicts with communities and with the local community. indigenous people Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 73 ABC 2. Identification of risks and impacts – ABC Case Study ABC FOOD COMPANY Process Map Opportunity for waste Potential negative Potential negative impacts - Environment and reduction/energy & Inputs Process Outputs impacts - OHS community water savings Materials, Operational Product, Injuries, long-term Discharge, contamination, pollution, Improved process, re- labor, activity waste, by- illness shortage purposing and recycling resources product by-products Large solid waste volume, high nitrogen and pathogen content in solid waste, leading to: Excreta, egg - potential contamination of land and surface shells, waters Lairage of mortality Worker exposure to - water oxygen depletion and death of aquatic life Chicken feed chickens waste, litter disease vectors - unpleasant odors Compost ▼ Hanging chickens Worker injuries from Manual labor on conveyor belt repetitive motion ▼ Stun and kill Worker injuries from Manual labor chickens cuts, abrasions ▼ Worker injuries from cuts, abrasions from Leakage, leading to knives; falls on slippery - potential contamination of ground and surface Manual labor Bleed chickens Blood floors waters Compost; biogas ▼ High water demand, leading to: - diminishing groundwater and decreased access to potable water for the community High wastewater volume, leading to - potential contamination of ground and surface Worker injuries from waters Hot water Scald chickens Wastewater burns - water oxygen depletion and death of aquatic life Recycle water ▼ Worker injuries from repetitive motion; Organic waste, leading to: exposure to allergens - potential contamination of ground and surface Manual labor Pluck feathers Feathers and particulates waters Compost; by-products ▼ Organic waste, leading to: Worker injuries from - potential contamination of ground and surface Compost; biogas; by- Manual labor Remove head Heads cuts, abrasions waters products ▼ Organic waste, leading to: Eviscerate Worker injuries from - potential contamination of ground and surface Compost; biogas; by- Manual labor internal organs Organs cuts, abrasions waters products ▼ High water demand, leading to: Worker injuries from - diminishing groundwater and access to potable Water Wash carcass Wastewater falls on slippery floors water for the community Recycle water ▼ Organic waste, leading to: Worker injuries from - potential contamination of ground and surface Compost; biogas; by- Manual labor Remove feet Feet cuts, abrasions waters products ▼ Worker exposure to preservatives, Inadequate or broken temperature controls, refrigerants such as leading to: ammonia and other - not meeting food safety requirements potentially allergenic or Runoff and leakage of preservatives and Water; Chill to prevent toxic substances; refrigerants, leading to: refrigeration bacterial exposure to extreme - damage to aquatic ecosystems systems poisoning Wastewater temperatures - decrease in potable water Insulation ▼ Plastic bags; Worker injuries from manual labor Package repetitive motion Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 74 ABC 2. Identification of risks and impacts – ABC Case Study ABC FOOD COMPANY Risk Assessment Prioritization Form ABC used the Risk Assessment Form to prioritize which risks to address through their action plans. Company Risk Probability of Severity if Notes area or occurring occurred department (low, medium, (low, medium, high, extreme) high, extreme) Production Excess water usage from Extreme Extreme Ongoing issue that Department increased production and community has already (scalding, groundwater pumping. brought to our attention evisceration, Leads to inaccessibility of packaging potable water by Areas) homeowners and communities and brine contamination of coastal area wells. Production High volume of wastewater Extreme Extreme Process wastewater has Department is discharged to surface high biochemical and (scalding water without treatment. chemical oxygen and It immediately consumes demand (BOD and COD) evisceration available oxygen in surface due to organic materials, areas) waters, rendering the including blood, fat, receiving water anaerobic, flesh, and excreta; high malodorous and unfit for levels of nitrogen, human consumption. phosphorus and chemical residues such as chlorine, pathogens (salmonella and campylobacter) especially without treatment. Sourcing Solid wastes from stock, High High Managed solid wastes Department bedding, mortality, litter can be used to produce Production and manure. salable by-products, Department If not managed, can lead to such as organic fertilizer, high volumes of nitrogen, soil amendment, etc. pathogens and organics that cause odor problems for neighbors and contamination of product and surface waters. All Discrimination, disciplinary High High Particular problems abuse and harassment due between supervisors to growing number of and migrant workers disputes between workers due to language issues. and supervisors. HR Inadequate contracts and High Medium Use of recruitment protection for migrant agency increases risk. workers due to the use of recruitment agency. Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 75 ABC 2. Identification of risks and impacts – ABC Case Study Production Worker injuries and Medium Medium Biggest area of concern Department illnesses due to bodily is in the stun/kill, stress and injuries from bleeding and scalding repetitive motion and areas machinery and exposure to poultry feces and other contaminants. Supplier Lack of process control, Medium High Recent case of product farm leading to contamination contamination and recall of equipment and at a competitor using machinery from the same supplier contaminated well water. Production Contamination of product Low High Department due to (i) contamination of (evisceration source water, (ii) and deterioration of raw water packaging quality at the plant. areas) Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 76 ABC 3. Management Programs – ABC Case Study ABC FOOD COMPANY Action Plan Based on its Risk Assessment Form, ABC prioritized the following five key risks:  excess water usage, leading to inaccessibility of potable water by homeowners and communities and brine contamination of coastal area wells;  high volume of wastewater, with biochemical and chemical oxygen demand from organic waste, entering and contaminating surface waters;  high volume of solid organic waste with pathogenic content, affecting ground and surface waters and food safety;  inadequate contracts and protection for migrant workers due to the use of recruitment agency; and  discrimination, disciplinary abuse and harassment due to growing number of disputes between workers and supervisors. RISK 1: Excess water usage, leading to inaccessibility of potable water by homeowners and communities and brine contamination of coastal area wells Mitigation Action Objective and target Deadline Responsible Resources Operational hierarchy staff required procedures Avoid - Given the production process, it is not possible - Procedure for to completely avoid water usage. However, 80- monitoring of fresh 95 percent of water used is discharged as water consumption effluent. Therefore, the organization should consider reducing/recycling water. Before implementing “flow reduction,” review local regulatory requirements pertaining to poultry inspection. Minimize - Install high-pressure, low-volume spray nozzles Objective: Reduce facility 3 months - Production Staff time for cleaning fresh water demand manager intensity: Low - Use offal transport systems that avoid/minimize Target: 30-40% reduction in - Maintenance Capital intensity: use of water total water use High supervisor - Use automatic control systems to regulate and optimize flow of water in knife sterilizers, hand wash stations and table wash sprays - Replace single-skinned knife sterilizers with high-efficiency sterilizers (e.g. water jacket sterilizers) - Optimize water flow rates for viscera table wash Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 77 ABC 3. Management Programs – ABC Case Study sprays - Use and maintain air chillers for carcass cooling to minimize water usage Minimize - Use dry cleaning techniques (broom, scraping, Objective: Reduce facility 1 month - Cleaning and Staff time - Procedures for etc.) to clean floors, transport trucks, process water demand sanitizing staff intensity: Low housekeeping and areas and equipment prior to washing with water cleaning Target: 30-40% reduction in Capital intensity: total water use Low Minimize - Install water recycling systems at points of use; Objective: Reduce facility 3 months - Production Staff time - Procedures for reuse water at specific locations water demand manager intensity: High recycling and reuse - Reuse final rinse water from cleaning operations of treated Target: 15% of wastewater is - Maintenance Capital intensity: for the initial rinsing on the following day wastewater reused or recycled supervisor Medium  - Reuse relatively clean water from cooling systems, boiler condensate, vacuum pumps, etc. Compensate/ - Drill and provide adequate number of deeper Objective: Increase water 6 months - Maintenance Staff time - Procedure for offset wells for affected community members to ensure access for community supervisor intensity: High monitoring access to potable water community access to Target: 30% of families with Capital intensity: water scarcity problems now High safe and adequate have deeper wells water supply Compensate/ - Develop rain water harvesting farms Objective: Store water for 3 months - Maintenance Staff time offset - Install Ranney collector wells in gravel banks of facility use and for injection in supervisor intensity: High regional surface water and store produced water coastal area wells to prevent Capital intensity: in reservoirs further salt water intrusion High Target: 20% of water under reserve Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 78 ABC 3. Management Programs – ABC Case Study RISK 2: High volume of wastewater, with biochemical and chemical oxygen demand from organic waste, entering and contaminating surface waters Mitigation Action Objective and target Deadline Responsible staff Resources Operational hierarchy required procedures Avoid - Given the production process, it is not - Procedure for possible to completely avoid water usage. sampling and However, 80-95 percent of water used is analysis of treated discharged as effluent. Therefore the wastewater organization shall prevent water contamination. Minimize - Maximize segregation of blood and water by Objective: Reduce 3 months - Production manager Staff time intensity: - Procedures for designing suitable blood collection system wastewater pollution - Maintenance Medium washing and - Use screens or traps at drains to prevent load supervisor Capital intensity: cleaning of viscera solid material entering effluent treatment Target: 20-30% and poultry carcass - Scalding area Medium system reduction in pollution supervisor - Procedures for - Maintain water temperature below 30 load for the select disinfection of - Evisceration area degrees C and pressure at less than 10 bar for wastewater wastewater supervisor carcass washing to reduce fat removal from parameters: BOD, the surface COD, TSS, oil and grease, total nitrogen - Segregate high-strength effluent streams and total phosphorus, (e.g. rendering, casings, etc.) and treat them total coliform separately bacteria, antibiotics, - Implement appropriate disinfection (e.g. pH, temperature chlorination, ultraviolet irradiation, ozonation, increase etc.) of wastewater Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 79 ABC 3. Management Programs – ABC Case Study RISK 3: High volume of solid organic waste with pathogenic content, affecting ground and surface waters and food safety Mitigation Actions Objective and target Deadline Responsible Resources Operational hierarchy staff required procedures Avoid - Work with suppliers to minimize risk of Objective: Reduce 12 months -Sourcing Staff time intensity: - Procedure for poultry poultry condemned as unfit for human bedding, litter, manure manager High (changing purchase consumption entering the supply chain and dead chicken waste supply chain and - Procedure for (poultry dead before slaughter or suspected Target 1: 20% reduction production scope) inspection of incoming of carrying diseases) in total waste poultry - Eliminate lairage time (receive chickens in Target 2: 50% reduction - Procedure for managing two daily shipments) in high-risk organic waste high-risk organic waste Minimize - Optimize process yields during manual Objective: Reduce 3 months - Evisceration Staff time intensity: grading and cutting through staff training process waste area supervisor High (oriented to Target: 10% reduction in - Packaging area behavior changes) process waste supervisor Capital intensity: Medium Minimize - Explore market for by-products (e.g., Objective: Reduce 3 months - General Staff time intensity: Procedures for storage, chicken organs and feet, poultry by-product process waste manager Medium handling and disposal of meal and fat from rendering, feathers) Target: 10% reduction in - Marketing Capital intensity: by-products - Segregate and store all by-products to process waste manager Low prevent cross-contamination - Production manager Minimize - Monitor and regulate refrigeration and Objective: Reduce 6 weeks - Maintenance Staff time intensity: - Procedures for chilling cooling systems during storage processing to product waste supervisor Low and freezer operations minimize product loss Target: 50% reduction in Capital intensity: - Procedures for storage product loss Low operations - Procedures for packing of finished product Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 80 ABC 3. Management Programs – ABC Case Study RISK 4: Inadequate contracts and protection for migrant workers due to the use of recruitment agency Mitigation Action Objective and target Deadline Responsible staff Resources Operational hierarchy required procedures Minimize - Review labor policies and Objective: Check for inadequate 3 months - HR manager Staff time - Procedures for procedures of recruitment contracts and protections for - Production intensity: Medium screening, selecting, agencies migrant workers manager training and auditing - Communicate company’s policies Target: 100% of migrant workers of recruitment regarding terms of employment have contracts with recruitment agencies for migrant workers (recruitment, agencies defining terms and - Procedure for working hours and overtime, conditions that comply with complaint wages, wage deductions, leave, company’s policies management and benefits) to recruitment agencies resolution - Inform terms of employment to migrant workers - Audit migrant workers contracts with recruitment agencies Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 81 ABC 3. Management Programs – ABC Case Study ABC FOOD COMPANY Complaint Management and Resolution Procedure ABC was concerned about the growing number of disputes between migrant workers and supervisors due to language issues. Here we present the Complaint Management Resolution Procedure that ABC adopted. Title: Complaint Management and Resolution (Internal Grievance Procedure) Procedure number: HR001 Number of pages: 2 1.0 Purpose and Scope: 1.1 Purpose: Establish a transparent process for workers to express concerns and file complaints, including anonymous complaints. Ensure there is no retaliation or discrimination against those that express concerns or file complaints. Ensure good worker-manager communications to enable workers to raise concerns before they become serious grievances. 1.2 Scope: Any complaint or dispute that may arise from a worker or worker organization. All individual complaints shall be initiated at Step 1 and shall, if necessary, proceed step by step to Step 5 where the resolution proposed shall be final and binding. Collective complaints and disputes will be handled in the same step-by-step approach as that for individual complaints, but shall begin at Step 2. Issues will inevitably arise from time to time, but since disputes are potentially harmful to the company, its workers, supervisors and managers at every level, all parties will be expected to resolve all but the most complex difficulties without recourse to Step 5 of this procedure. The worker organization filing the complaint or representing the worker filing the complaint shall have the right to be notified and be present at all steps of the procedure. Every effort should be made to settle the issue at each step and until this procedure has been completed there shall be no threats of “go-slows,” partial or general stoppages of work or other illegal action or lock-out. 2.0 Definitions: 2.1 Grievance: Specific violation or feeling of having been wronged – the reason for filing a complaint. 2.1 Complaint: The formal communication of a grievance to the appropriate parties. 3.0 Responsibilities: HR Department 4.0 Work Instructions: Step 1: 4.1 The worker presents the complaint or grievance verbally to the most immediate supervisor, who has the authority to make adjustments in the matter, within 14 days. Explanations of responses to complaints, even if only to alert workers to a delay in the process, are key to ensuring workers understand their complaints are respected and taken seriously. 4.2 The supervisor records the complaint or grievance and the action taken in the complaints log. Step 2: 4.3 If a satisfactory settlement is not reached in Step 1 within three days, or if the worker fears making the complaint directly to the most immediate supervisor, then a worker representative may present the complaint verbally to the supervisor concerned. The worker may choose to remain anonymous. Step 3: Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 82 ABC 3. Management Programs – ABC Case Study 4.4 If a satisfactory settlement is not reached in Step 2 within three days following its completion, the worker or his or her chosen representative for the case may present the complaint to the department head. The complaint shall be in writing and shall state the complainant(s) or grievant(s) name(s). Step 4: 4.5 If a satisfactory settlement is not reached in Step 3 within five days of the date of submission of the written complaint or grievance to the department head, the worker or his or her chosen representative for the case may present the complaint or grievance to the head of the Human Resources Department. 4.6 The head of the Human Resources Department or his/her designee shall schedule a meeting to be held within fourteen days of the receipt of the complaint or grievance with the worker or his or her chosen representative, for the purpose of attempting to resolve the complaint or grievance. 4.7 The worker can bring one or two peers for support during this meeting; those workers will also be covered under the non-reprisal clause. 4.8 The head of the Human Resources Department or his/her designee shall respond in writing within seven days of the date of the meeting. Step 5: 4.8 If the complaint or grievance is not resolved at Step 4, and it is clear that resolution within the company is impossible, the worker or his or her chosen representative may refer the complaint or grievance to the Labor Ministry for resolution. Monitoring: 4.9 The Human Resources Department will conduct a quarterly review of all complaints and actions taken. It will review the complaint logs of each supervisor and department head to evaluate the effectiveness of the grievance procedure and resolutions. 4.10 As part of the quarterly review, the Human Resources Department will follow up directly with the worker or his or her chosen representative to make sure there has been no retaliation. 4.11 The Human Resources Department will maintain a central record of all complaints and resolutions. 5.0 Reference Documents: Related Policy: Labor and Working Conditions – Grievance Mechanism; Thai national and local labor law 6.0 Records: Complaint Log; Complaint Investigation File; Complaint Resolution Report and Communication 7.0 Approving Authority: Senior Manager of HR 8.0 Issue Date: January 1, 2011 Revision Date: February 1, 2012 Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 83 ABC 4. Organizational Capacity and Competency – ABC Case Study ABC FOOD COMPANY Training Plan Based on their Action Plan, ABC developed a simple Training Plan to raise awareness and provide the skills needed to implement the Action Plan. ABC was able to participate in a local government program that provided subsidized training in these areas. Department Module 1 Module 2 Module 3 Module 4 Human Introduction to Non-discriminatory Complaint Worker-manager Resources/EHS/ESMS ESMS; Labor hiring practices management and communications Performance team standards resolution performance procedure issues Recruitment agency Labor standards Contracts and performance payments issues Migrant workers Labor standards Contracts and performance payments issues All workers and managers Health and safety Water Non-discrimination Worker-manager and emergency conservation and procedures; communications response waste reduction Disciplinary procedures procedures procedures Senior management Introduction to Labor standards Stakeholder and ESMS performance issues community engagement and Environmental communications performance issues Production Water treatment Water Waste treatment Health and safety and recycling conservation and reduction and emergency procedures procedures procedures response procedures Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 84 ABC 4. Organizational Capacity and Competency – ABC Case Study ABC developed a Roadmap to estimate the staff time required and the timeframe to develop and implement their ESMS. They estimated a total of 167.25 days of time from senior management, middle management, supervisors and workers. Roadmap and Estimated Timeframe for Developing and Implementing ABC FOOD COMPANY’S ESMS MONTH ACTIVITY Time spent 1 2 3 4 5 6 Senior Mid Super- Work 1. Policy mgt mgt visors ers time time time time Kick-off meeting at sr. management level .5 to discuss ESMS implementation Selection (including communication/coordination) of ESMS .25 .5 .5 Developing core team (personnel from different key departments) Appreciation and awareness workshop for senior management and core team on 4 4 4 ESMS requirements Review/upgrading of existing environment and social policy/formulation of .5 1 3 organization’s env. & social policy Design, printing and display of ESMS policy .5 1 3 at key areas Uploading of ESMS policy on company Implementing .25 .25 website Communication of ESMS policy to key .5 .5 external stakeholders Training & awareness of employees on ESMS policy and information 2 3 4 10 dissemination Senior Mid Super- Work 2. Risk and Impact Identification mgt mgt visors ers Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 85 ABC 4. Organizational Capacity and Competency – ABC Case Study MONTH ACTIVITY Time spent 1 2 3 4 5 6 time time time time Mapping of activities, processes and key stakeholders, including the suppliers & .5 1 4 contractors Developing Identification and compilation of regulatory and other requirements, .5 1.5 4 including stakeholder expectations Initial environment & social review, identification & evaluation of environment 3 8 12 6 and labor risks (including supply chain) Training & awareness of employees on environmental, social and labor risks and 2 6 16 risk identification process Implementing Training & awareness of employees on regulatory and other requirements, 2 2 10 including stakeholder expectations Training & awareness of employees on environment, social and labor risks and 3 3 20 information dissemination Senior Mid Super- Work 3. Management Programs mgt mgt visors ers time time time time Preparation of ESMS manual (formulation and documentation of procedures related 3 8 16 to ESMS) Formulation, compilation of Developing environmental objectives/targets and .5 1 2 2 social performance improvement measures Formulation and development of 1 4.5 4 environment and social action plans Development of operational procedures 2 4.5 8 2 Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 86 ABC 4. Organizational Capacity and Competency – ABC Case Study MONTH ACTIVITY Time spent 1 2 3 4 5 6 Communication, awareness and training .5 4 8 12 of employees on ESMS procedures Communication and awareness of employees on environmental objectives Implementing .25 .5 1 8 and social performance improvement measures Communication and awareness of employees on environment and social .25 1 8 action plans Training of employees on environmental 4 8 26 and social operational procedures Senior Mid Super- Work 4. Organizational Capacity and mgt mgt visors ers Competency time time time time Environmental and social awareness 5 program for middle management Developing Environmental and social awareness 30 program for workers Competency program for ESMS core team 4 6 Internal auditor training for the 4 12 organization’s ESMS assessors/auditors General awareness and training on environment, social and labor 2 3 issues/ESMS for senior and middle management Implementing Environmental and social awareness program for workers 3 6 25 Competency program for ESMS core team 4 6 Internal auditor training for the organization’s ESMS assessors/auditors 4 12 Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 87 ABC 4. Organizational Capacity and Competency – ABC Case Study MONTH ACTIVITY Time spent 1 2 3 4 5 6 Senior Mid Super- Work 5. Emergency Preparedness and mgt mgt visors ers Response time time time time Review of key risks and existing .25 1 2 emergency preparedness plan Developing Upgrade/prepare the emergency .25 3 5 preparedness plan Communicate to workers, potentially affected communities and relevant .25 .5 government agencies (if required) Awareness and communication to Implementing employees and affected communities on .25 1 2 8 key risks and emergency issues and emergency planning Training of employees on emergency .25 2 4 20 preparedness plan Communication and awareness on emergency procedures to affected .25 .5 communities and relevant authorities (if required) Senior Mid Super- Work 6. Stakeholder Engagement mgt mgt visors ers time time time time Mapping of all stakeholders, stakeholder .25 2 1 Developing analysis and engagement planning Develop/upgrade stakeholder communication/consultation; information .25 3 disclosure and engagement strategy/program Communication to employees on key Implementing stakeholders and their environment and .25 1 8 social/labor expectations Communication, awareness and training of employees on the strategy/program for 1.5 3 8 stakeholder Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 88 ABC 4. Organizational Capacity and Competency – ABC Case Study MONTH ACTIVITY Time spent 1 2 3 4 5 6 engagement/consultation/communication and information disclosure Senior Mid Super- Work 7. External Communication & mgt mgt visors ers Grievance Mechanism time time time time Review external communication system, Developing including receiving and handling feedback, 1 concerns and complaints Develop/upgrade system for regular engagement, receiving, documenting and .25 2 1 responding to feedback and grievances Review external communication, Implementing feedback, stakeholder concerns and .25 2 4 10 complaints and communicate to key personnel Training, awareness and implementation of stakeholder engagement, receiving, 2 4 10 documenting and responding to feedback and grievances Senior Mid Super- Work 8. Ongoing Reporting to mgt mgt visors ers Affected Communities time time time time Review existing system for reporting and 1 Developing disclosure Develop/upgrade system for external reporting and disclosure (including .25 2 1 collection, validation and verification of information) Communication and disclosure to key Implementing external stakeholders and affected .25 2.5 communities Communication, awareness and training on external reporting and disclosure 4 6 8 (including collection, validation and verification of information) Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 89 ABC 4. Organizational Capacity and Competency – ABC Case Study MONTH ACTIVITY Time spent 1 2 3 4 5 6 Senior Mid Super- Work 9. Monitoring and Review mgt mgt visors ers time time time time Establish procedure to monitor and measure ESMS performance, compliance .25 1 .5 and stakeholder requirements Implementation of ESMS monitoring program, establishing benchmarks and .25 4 2 integration with existing system Final review and complete ESMS .25 1 1.5 Developing documentation Conduct internal audit/evaluation of ESMS performance against the management 1 2 2 program requirements/benchmarks Establish relevant operational controls and formulation of corrective & .25 .5 2 1 preventive actions Review by the senior management to assess performance and effectiveness of .25 .5 1 ESMS Documentation and communication on ESMS conformance, regulatory 2 4 compliance and stakeholder requirements Communication, awareness, training and implementation of ESMS monitoring .25 4 6 16 Implementing program and established benchmarks Communication of internal audit/performance measurement findings .5 1 4 and ESMS performance to the employees Communication, awareness and training of employees on operational controls and .5 2 16 corrective & preventive actions Communication on outcomes of review of .25 .5 the ESMS performance by senior Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 90 ABC 4. Organizational Capacity and Competency – ABC Case Study MONTH ACTIVITY Time spent 1 2 3 4 5 6 management and key decisions taken TOTAL 34 143.75 195.75 259 Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 91 ABC 5. Emergency Preparedness and Response - ABC Case study Based on their risk assessment, which identified fire as a severe-impact risk, ABC developed an Emergency Preparedness and Response Plan to identify, prevent and respond to fire emergencies. The plan includes a Fire Response Procedure. ABC FOOD COMPANY Fire Response Procedure See sample Fire Response Procedure in Toolkit. Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 92 ABC 6. Stakeholder Engagement - ABC Case Study ABC FOOD COMPANY Stakeholder Mapping – identification and analysis An ABC cross-departmental team brainstormed and listed the stakeholders that are affected by or have an interest in the company’s operations. To identify nearby villages and groups that may be affected by the company operations, the company also used a satellite image and drew the sources of pollution and the areas that could be affected (see Impact Zoning Tool for Identifying Affected Communities). The team then discussed and listed their key concerns, issues and interests. To identify those, they looked back at the environmental and social key risks and impacts previously identified and how these affect the surrounding communities. Stakeholder Issues/concerns/interests a. Chonburi farmers association (affected community) Diminishing groundwater supply b. Local village population (affected community) Diminishing groundwater supply Water quality c. Local gulf fishermen association (affected Surface water eutrophication due to wastewater community) d. Consumers in Japan, Korea, Thailand, Europe, the Food safety Middle East, South America e. ICM Chonburi communities for conservation ABC environmental performance f. Chonburi regional government Compliance with environmental regulations g. Ministry of Natural Resources and the Environment Compliance with environmental regulations h. Labor Rights Promotion Network Concerns on migrant workers discrimination Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 93 ABC 6. Stakeholder Engagement - ABC Case Study Finally, they mapped the stakeholders on a matrix according to (a) the degree to which they are impacted and (b) their ability to influence the company operations, and then (c) categorized them based on their current relationship with the company: supportive, supportive with conditions, neutral, opposed. Based on this, they identified which groups were a priority to engage. Quadrant 1= Quadrant 2= High Involve as needed Proactively approach Supportive and support them a Supportive with conditions f g Capacity to influence Neutral Quadrant 3= Quadrant 4= Opposed Keep them informed Respond to their concerns h Low Low High Degree impacted by the company ABC FOOD COMPANY Stakeholder Engagement Plan Based on the information above, ABC prepared a Stakeholder Engagement Plan. ABC prioritized engagement with those groups that are most affected. Stakeholder Engagement Plan for affected stakeholders Stakeholder Concerns Engagement method Information to disclose Most valuable and report back info to obtain a. Chonburi Groundwater - Grievance mechanism - Level of water Exact threat, farmers supply: possibly - Quarterly meetings with consumption at the damage, association diminishing and members of the association plant possible (Quadrant 2) contaminated by and more frequently as - Progress on water solutions, saltwater has demand requires saving/recycling actions costs of these caused crop failure - Participatory monitoring at the plant and cattle loss of groundwater level - Results of groundwater - Annual perception survey level monitoring Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 94 ABC 6. Stakeholder Engagement - ABC Case Study b.Local village Water supply - Grievance mechanism - Progress on water Identification population (especially falling - Biannual meetings with saving/recycling actions of areas (Quadrant 2) groundwater community leaders at the plant where to build levels) and quality - Annual perception survey - Plan to build 50 deep deep wells for consumption wells in most affected areas c. Local gulf Wastewater and - Grievance mechanism - Progress on waste Factual fishermen solid waste from - Biannual meetings with minimization and information association poultry processing affected local fishermen wastewater treatment on depletion (Quadrant 4) affecting fish stock. groups actions of fish Possible worsening resources of problem due to ABC’s recent expansion d. Consumers Food safety - Grievance mechanism - Progress on actions to Consumer (Quadrant 2) through telephone hotline improve quality of concerns - Well-briefed process water and food Ways communications team to safety competitors address consumer concerns are addressing the issue Stakeholder Engagement Plan for interested stakeholders Stakeholder Interests Engagement method Information to Most valuable communicate info to obtain e. ICM Chonburi Environmental - Biannual meetings with - Progress on ESMS Recommende Communities performance from local representatives and as environmental action d methods for for ABC and other demand requires plans environmental Conservation poultry production - Regular updates through protection (Quadrant 1) businesses quarterly newsletter (by and email) improvement f. Chonburi Possible non- - Public reporting on - Commitment to Comprehensiv provincial compliance with compliance social and e knowledge government - provincial - Quarterly phone calls environmental of relevant (Quadrant 1) environmental performance regulations regulations improvement g. Ministry of Possible non- - Public reporting on - Commitment to Comprehensiv Natural compliance with compliance environmental e knowledge Resources and national - Quarterly phone calls performance of relevant Environment of environmental improvement regulations Thailand regulations (Quadrant 1) h. Labor Rights Concerns on - Quarterly updates through - Progress on Local Promotion migrant workers email implementation of information Network discrimination grievances and non- on workers’ (Quadrant 3) discrimination rights in food procedures processing - Progress on direct industry contracting migrant workers Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 95 ABC 7. External Communication and Grievance Mechanism - ABC Key Aspects of ABC FOOD COMPANY’S Grievance Mechanism Key aspects of effective grievance ABC’s method mechanisms Provide ease of access to ABC’s website has a form and instructions that people can fill confidentially communicate or file out and submit online. complaints, including anonymous ones Publicize the system so that ABC distributes a company brochure highlighting its company stakeholders know it exists and how profile and operations and including instructions for how to access it external stakeholders can communicate or file complaints. The brochure is circulated to community leaders at churches, schools and civic centers. The system is also documented in the company procedures manual. A designated community liaison explains this further when meeting with stakeholders. Foster sense of legitimacy and trust; ABC has its major cases reviewed by a formal oversight body encourage dialogue and shared consisting of a representative from each of its key stakeholder responsibility for outcomes groups. It also provides for transparent funding of expert resources, so that any collection of evidence is independent and unbiased. It makes sure not to undermine existing legal mechanisms. Be transparent about the process All cases are summarized and posted on the company website, and outcomes with details about whether the complaint is accepted or not and what is the process and timeline for investigation and resolution. Implement a predictable and defined ABC has a procedure that designates the community liaison to process that includes assignment of receive and record the complaint and then work with relevant responsibility, time limits and staff and external stakeholders to investigate, determine monitoring of outcomes actions and report back outcomes. Make the system a source of ABC’s oversight stakeholder body meets quarterly with the continual learning management team to measure the effectiveness of the system and review complaints to check for resolution and cumulative learning that can be integrated into company systems. They agree and monitor key performance indicators and revise the mechanism as appropriate. Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 96 ABC 8. Reporting Back to Affected Communities – ABC Case study See Chapter 6. Stakeholder Engagement – XYZ Case Study and Chapter 7. External Communication and Grievance Mechanisms – XYZ Case Study. Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 97 ABC 9. Monitoring and Review - ABC Case Study Monitoring Plan for ABC ABC’s ESMS team developed a Monitoring Plan based on the action plans and their targeted objectives. Water consumption Performance indicators Monitoring indicators Monitoring records Equipment Freshwater consumption in kl per - Water meter reading logs at all intake points by - Sealed water meters at shift department per shift (to be recorded as “initial all intake points reading” and “final reading”) Freshwater consumption in kl per - Water meter reading logs at all intake points by - Sealed water meters at ton of poultry processed department per shift (to be recorded as “initial all intake points reading” and “final reading”) - Record of poultry slaughtered (dressed) and processed per shift in tons Wastewater recycled and treated - Water meter reading logs at all points of reuse - Sealed water meters at Wastewater used in kl per ton per by department per shift (to be recorded as all points of water reuse shift “initial reading” and “final reading”) % of families with water scarcity - Financial records of investment made on problems provided with deep wells providing deep wells - Records of survey/consultation with local communities on water issues - Records of complaints, grievances and disputes with local communities on water issues Water capacity from storage of - Financial records of Ranney collector wells and harvested rain water and Ranney rainwater harvesting facilities collector wells Process indicators Monitoring indicators Monitoring records % of wastewater streams analyzed for their suitability for - Wastewater sampling and analysis records recycle/reuse % taps and washing hoses/nozzles with high-efficiency - Maintenance records - leaking and replaced faucets, taps/nozzles hoses and nozzles % of cleaning staff trained on housekeeping and cleaning - Training records procedures % of production and maintenance staff trained on - Training records wastewater recycle and reuse procedures Wastewater Performance indicators Monitoring indicators Monitoring records Equipment Wastewater discharge in kl per shift - Wastewater meter reading logs per shift (to be - Calibrated water recorded as “initial reading” and “final reading”) meter(s) at all/final or records of hourly “flow rate” measurements discharge points at discharge point Wastewater discharge in kl per ton - Wastewater meter reading logs per shift or of poultry processed records of hourly “flow rate” measurements at discharge point Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 98 ABC 9. Monitoring and Review - ABC Case Study - Record of poultry slaughtered (dressed) and processed per shift in tons Effluent quality at points of - Monthly wastewater sampling and analysis - Wastewater sampling discharge records of BOD, COD, TSS, oil and grease, total equipment (analysis nitrogen and total phosphorus, total coliform performed in external bacteria, antibiotics, pH and temperature lab) increase. Volume of sludge generated from - Sludge generation and disposal records wastewater treatment plant Process indicators Monitoring Indicators Monitoring records Equipment % of production staff in scalding and - Training records evisceration areas trained on poultry washing and evisceration procedures Wastewater treatment facilities (e.g. - Financial investments made in commissioning oil and grease traps) commissioned wastewater treatment facilities for specific processes) - Energy consumption records pertaining to wastewater treatment - Records of chemical/material consumption in wastewater treatment Organic solid waste Performance indicators Monitoring indicators Monitoring records Equipment Total solid waste generation per - Shift solid waste disposal log - Calibrated weighing shift in kg machines Total solid waste generation per - Shift solid waste disposal log shift and per ton of poultry - Record of poultry slaughtered (dressed) and processed in kg processed per shift in tons High-risk material generation in kg - Daily records of dead chickens Process waste generation per shift - Shift solid process waste disposal log (product loss from manual grading, cutting, processing) in kg and % Product loss in kg and % due to - Daily/shift solid waste disposal log due to contamination, spoilage, shelf-life contamination or spoilage of finished product Solid waste processed and shipped - Daily/shift records of solid waste re- out for re-processing or alternative processed as by-product use and by-products in kg and % Process indicators Monitoring indicators Monitoring records Equipment Elimination of lairage time - Records of poultry suppliers providing lairage - Supplier schedules % of production staff trained on - Training records handling of by-products, waste handling and optimization of process yields Adequacy of refrigeration, cooling - Records of operation and maintenance of Calibrated and storage facilities refrigeration and cooling units temperature gauges/thermometers Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 99 ABC 9. Monitoring and Review - ABC Case Study Labor – Migrant workers Performance indicators Monitoring indicators Monitoring records % of migrant workers directly hired by ABC (direct - Workers’ employment contracts employment) % of migrant workers hired through recruitment - Migrant workers’ employment contracts through agencies compliant with company’s terms of recruitment agencies employment (recruitment, working hours and - Records of working hours and overtime overtime, wages, wage deductions, leave, benefits) - Records of wage payment and statutory deductions Number and type of complaints and grievances - Records of complaints, disputes and grievances raised by workers/migrant workers redressed Trend in discrimination and disciplinary abuse - Records of complaints, disputes and grievances against workers/migrant workers redressed - Hiring and termination records - Records of disciplinary actions against workers - Records of exit interviews Fair wage payment as per the local regulations/industry norms Process indicators Monitoring indicators Monitoring records % of workers surveyed/interviewed to identify their - Employee survey, feedback, consultation and concerns, feedback and grievances grievances records % of workers, supervisors and managers trained on - Training records fair labor practices (non-discrimination, disciplinary abuse, workers’ rights) Clearly defined employment contracts for workers - Workers employment contracts (especially migrant workers) Clearly defined hiring and remuneration policy for - Hiring and remuneration policy for workers workers Clearly defined policies and procedures on - Non-discrimination and disciplinary procedures discrimination and disciplinary practices Established procedures and systems to identify - Complaint management and resolution procedures worker concerns, feedback and grievances - Records of complaints, disputes and grievances redressed Clearly established contractor control plans - Records of terms and agreements with recruitment agencies - Records of monitoring/auditing of recruitment agencies by the company - Records of corrective and preventive actions implemented by the recruitment agencies Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 100 XYZ Case Study – XYZ Food Company, Tanzania XYZ Food Company (XYZ Company) was established in 1995. The company is based in Tanzania, where it processes, packages, and sells a variety of packaged and processed food products, including natural fruit jams, peanut butter, processed tomatoes, tomato sauce and tomato juice. The company sells its products directly to hotels, restaurants, tourism companies and supermarkets throughout Tanzania. The XYZ Company factory operates one shift a day and has a production capacity of 20 tons of raw materials per day. The company has 30 permanent staff, including four field officers and 20-25 casual workers. Approximately 30 percent of all employees are female workers, mostly working as laborers. XYZ Company, similar to many other small food processors, operates as an informal sector company and uses labor-intensive and old technologies, while most of the large-scale industries in the region use improved and modern technologies with large capacity output. As the country experiences more pressure from globalization, the food industry is also subjected to increased competition in the domestic market. Since the government does not impose or control the market price of products, small and medium food processors are forced to sell their products at an available market price. By doing so, the majority are running their businesses at marginal profit. XYZ generates large amounts of industrial effluent from beverage manufacturing and cleaning operations. Current practice is to rough screen the wastewater and discharge it to a local stream without further treatment. Screened solid waste, such as rejected fruit and peels are discarded to local dumping grounds for putrescence. Local community leaders, residents and farmers complain that there are foul odors from the dumping grounds and that the surface water required for their homes, agriculture and animal husbandry is being contaminated. They also complain that sludge ponds are breeding grounds for mosquitoes and other vectors, potentially leading to an epidemic of dengue fever and malaria, causing considerable morbidity and mortality. Consistent water availability from the municipal supply is not guaranteed. Therefore, XYZ Company has drilled boreholes so that it can meet its high requirements of raw water usage. In addition, reliable electricity has been a long-standing problem in the region, so most of the food processors opt to use generators during power rationing. As a result, the production cost increases along with decreasing profit margin. Unreliable electricity in the region not only affects production processes but also prolonged electricity black outs accompanied by tropical conditions conducive to microbial growth result in a great loss to the processors, wholesalers, retailers and the consumers. Neighbors also complain about the noise from the generators. XYZ Company has small storage areas and facilities that force them to pile up their products, resulting in poor ventilation and a dusty, uncomfortable working environment. Dust from the nuts often fills the air – this can be flammable and can also cause respiratory problems, such as occupational asthma and irritation of eyes, nose and skin (occupational dermatitis). Due to the confined space and the cramped layout of the machinery and equipment, there are difficulties with product flow, cluttered workspaces and inadequate separation of the products from wastewater and cleaning agents. This increases the risk of worker injuries and poor hygiene and product quality. About two years ago, XYZ Company had a product recall of about four tons of tomato sauce; this was a huge loss for the company to recover. Due to the nature of the food industry products, products Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 101 XYZ Case Study – XYZ Food Company, Tanzania are subjected to the constraints of limited shelf-life; due to poor transportation infrastructure, it is not easy to recall products whenever the expiry date is due. Therefore the company had to incur losses on costs such as labor, transportation, destruction and primary and secondary raw materials, etc. Many small companies in the region face various labor issues, including labor shortages during the harvesting seasons. Most of the workers prefer to work with big companies, as they offer regular employment, modern equipment and better working conditions. Tanzania has ratified all eight ILO core labor conventions. Approximately 27 percent of the workforce in the country that is engaged in paid formal sector employment is affiliated with a trade union. However, trade union rights are difficult to exercise in practice in many companies in the region, due to anti-union discrimination and restrictions on the right to strike. There have been recent media reports that show that some factories in the region have discouraged employees from joining a union under the threat of being fired. Discrimination is also reported to be widespread with respect to women, the disabled and people with HIV/AIDS. Child labor is common in the supply chain. Forced or compulsory labor is also common in many companies and includes overtime work with the threat of being fired. Workers can go on strike, but must go through a series of complicated and protracted mediation and conciliation procedures, which can prolong a dispute months without resolving it. Consequently, workers tend to stage illegal wildcat strikes and walkouts, because of the lengthy and cumbersome requirements for calling a legal strike. Though there have been some past incidents of employee disputes and labor unrest at XYZ Company, the company has always managed to resolve the issues before they escalated to a strike. XYZ Company is an active member of the Tanzania Food Processors Association (TAFOPA) and Small Enterprise Development Agency (SEDA,) based in Arusha, and participates in various trade shows to promote its products. During a recent international trade fair organized at Dar es Salaam, the CEO met some potential international customers who indicated that international certifications such as HACCP, Fairtrade and other environmental management system programs can offer a viable route to success in the export market for a small-scale food company like XYZ Company. To explore the international market, XYZ Company has decided to develop and implement environmental and social management systems and training programs, based on existing laws and regulations on labor, product safety, hygiene and best industry practices. Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 102 XYZ 1. Policies – XYZ Case Study XYZ FOOD COMPANY Policy Statement XYZ had a long internal debate about adopting policies, especially the ones on labor and working conditions. They felt it would be very hard to meet these requirements, given their operating environment. Finally, the CEO decided to proceed with the complete set of policies, because of his goal of selling internationally. They established a three-year plan to try and achieve compliance with the policies and gain some type of international certification or recognition. Besides the complete set of policies, they prepared a shorter version summarizing the most relevant points: XYZ - Our products, our environment, our people Together we produce safe and high-quality foods which create value and confidence for our customers and consumers. We are committed to conducting our operations in accordance with the environmental and labor laws and regulations that apply to our industry. We recognize that energy and water are valuable resources, and we commit to use them more efficiently. We commit to reuse and recycle all our organic waste. We strive for an injury-free workplace, ensuring that our workers are not exposed to dangerous situations or hazardous chemicals, and that they use the appropriate personal protective equipment. We will work with our suppliers of fruits and vegetables to gradually eliminate the presence of child labor in our supply chain. We are all - managers, supervisors and workers – jointly responsible for making our policy a reality. Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 103 XYZ 2. Identification of risks and impacts – XYZ Case Study LABOR AND WORKING CONDITIONS RISKS RISK FACTORS My company has the Potential negative impact following conditions (A “yes” response means that (circle the appropriate there is a potential negative answer) impact) There is a difference in nationality, race or Yes/No Discrimination. Disciplinary religion between workers and managers. abuse and harassment. Our managers and supervisors are not Yes/No Discrimination. Disciplinary aware of the workers’ rights under the abuse and harassment. national labor law or collective agreements. Excessive overtime. We have an apprentice program that Yes/No Forced labor. Child labor. provides young workers with training and work experience. We routinely use recruiting agencies and Yes/No Inadequate wages, benefits contract workers. and contracts. Forced labor. We routinely use homeworkers or Yes/No Inadequate wages, benefits contractors that use homeworkers. and contracts. Forced labor. Child labor. We routinely use seasonal or temporary Yes/No Inadequate wages, benefits workers. and contracts. Excessive overtime. Some of the workers in my company are Yes/No Forced labor. Discrimination. migrants from another area. We provide a dormitory for some or all of Yes/No Lack of freedom of movement. our workers. Lack of clean adequate space. Excessive charges for the use of the dormitory. There are security guards at our company. Yes/No Lack of freedom of movement. Harassment. We are located in a free-trade zone. Yes/No Inadequate wages, benefits and contracts. There is a large fluctuation in orders Yes/No Excessive overtime. No and/or seasonality of production. payment of overtime due to hour-averaging. Layoffs. There is a labor shortage in my area. Yes/No Child labor. There is no history of collective Yes/No Lack of freedom of association. bargaining, unions or other forms of worker representation at our company. There is no procedure for workers to Yes/No Discrimination. Disciplinary express their complaints (grievance abuse and harassment. mechanism). Worker injuries and chronic conditions. Our processing activities include Yes/No Worker injuries and chronic significant lifting, carrying or repetitive conditions. motions. Our processing activities involve workers Yes/No Worker injuries and chronic routinely interacting with machinery, conditions. equipment with sharp edges and/or slippery work surfaces. Our processing activities involve elevated Yes/No Worker injuries and chronic levels of noise, dust, vapors, smoke, conditions. Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 104 XYZ 2. Identification of risks and impacts – XYZ Case Study chemicals (e.g., preservatives, cleaning agents), radiation and/or temperature extremes. Our processing activities involve Yes/No Worker injuries or casualties. hazardous materials or processes that could cause fires or explosions. Our processing activities involve the Yes/No Worker illnesses. handling of living and dead animals that can transmit diseases to humans. Our workers don’t have access to Yes/No Worker illnesses. separate and clean areas for eating and changing clothes. Bathrooms are in cramped spaces and Yes/No Worker illnesses. lack access to running water. The companies in our supply chain would Yes/No All of the above. probably answer “Yes” to most of the questions above. ENVIRONMENTAL RISKS RISK FACTORS My company has Potential negative impact the following (A “yes” response means that there is a conditions (circle potential negative impact) the appropriate answer) Our operations require large Yes/No Groundwater depletion in the region. quantities of fresh water. Contamination of groundwater or surface water sources in the region due to discharge of effluent. High energy consumption for treatment of raw or process water. We don’t have sufficient fresh water Yes/No Groundwater depletion in the region. supplies to meet our requirements. Our operations have high Yes/No High energy consumption. Possibility of requirements for power supply. air emissions if sufficient power supply (electricity) from the grid (supplied by government or private companies) is not available. We require large quantities of fuel Yes/No Air emissions. Solid waste (fly ash if coal (gas/diesel/coal/etc.) for our is used). operations. We have various process and utility Yes/No Air emissions. Solid waste (e.g. waste equipment that may generate air from equipment maintenance, fly ash emissions (e.g. boiler, diesel from coal-based boilers). Hazardous generator set, incinerator, grinder, waste (e.g., waste oil, oil-soaked filters etc.). and rags). Liquid waste (e.g. boiler blow- down, waste oil). Noise generation. We need to store large quantities of Yes/No Solid waste due to possible contamination raw materials on site. or deterioration of raw materials. High energy consumption or emissions due to cold storage. Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 105 XYZ 2. Identification of risks and impacts – XYZ Case Study We generate large (or significant) Yes/No Solid waste. Liquid waste. Contamination quantities of solid or liquid waste of land, groundwater and/or surface due to poor quality of raw materials water due to improper disposal of solid or rotting of materials due to and liquid waste. Wastewater from prolonged storage. cleaning. High energy consumption or emissions due to cold storage. We generate large (or significant) Yes/No Solid waste. Liquid waste. Contamination quantities of solid or liquid waste of land, groundwater and/or surface from our manufacturing process, water due to improper disposal of solid which are not reprocessed into and liquid waste. Wastewater from byproducts, fertilizers or energy. cleaning. The quantity of solid/liquid waste Yes/No Solid waste. Liquid waste. Contamination from rejected finished product due of land, groundwater and/or surface to contamination, rotting, expiry, water due to improper disposal of solid etc. is high (or significant) at our and liquid waste. Wastewater from facility. cleaning. High energy consumption or emissions due to excess or extra production. We dispose of our solid waste in our Yes/No Contamination of land, groundwater (due landfill or city’s landfill facility. to leachate) and/or surface water (due to run-off). Impact on wildlife or fisheries if exposed. Diseases through vectors, foul smell, GHGs generation (e.g. methane). We provide our solid waste to the Yes/No Contamination of land, groundwater (due community or general public to be to leachate), surface water (due to run- used as fertilizer. off) and/or crops if toxic chemicals are present in the solid waste. Our operations generate large (or Yes/No Contamination of ground and/or surface significant) quantities of water due to improper disposal of wastewater (e.g. raw material wastewater. washing, processing, floor cleaning, bottle washing, etc.). We discharge our wastewater Yes/No Contamination of receiving water body (process effluent) in a nearby and aquatic life. Eutrophication due to river/lake/or any other water body. high BOD or COD. We treat our wastewater (process Yes/No Energy consumption. Solid waste effluent) before discharge. generation (e.g. sludge from treatment process, membrane concentrated waste discharge from reverse osmosis, treatment chemicals). Land and/or water contamination due to improper disposal of waste. We treat our sewage (from toilets, Yes/No Energy consumption. Solid waste washrooms, etc.) before discharging generation (e.g. sludge from treatment it in the city’s sewer line. process, membrane concentrated waste discharge from reverse osmosis, treatment chemicals). Land and/or water contamination due to improper disposal of solid waste. We utilize our treated wastewater Yes/No Contamination of land, groundwater (due Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 106 XYZ 2. Identification of risks and impacts – XYZ Case Study (process effluent) for irrigation to leachate), surface water (due to run- (either by ourselves or provide it to off) and/or crops if toxic chemicals are community). present in the treated wastewater. Impact on crop productivity. We generate some hazardous or Yes/No Contamination of land, groundwater (due toxic waste (e.g. waste chemicals, to leachate), and/or surface water (due to used/waste oil/sludge from run-off) if disposed improperly. wastewater treatment plants based on chemical treatment, etc.). We require a large land area for our Yes/No Loss of natural habitats or agricultural industrial operations. land. Air, water and/or land pollution based on expansion requirements and infrastructure development. Our operations may have an impact Yes/No Loss of native species. Impact on on the surrounding forest or biodiversity. wildlife. We use some banned Yes/No Non-fulfillment of regulatory chemicals/materials in our requirements. Air, land or water processes. pollution depending on current usage. Exposure of workers or consumers to banned chemicals. We face problems related to Yes/No Use of chemicals. Chemical exposure of pests/vectors. workers. Land or water contamination due to disposal of infested material. COMMUNITY HEALTH, SAFETY AND SECURITY RISKS RISK FACTORS My company has Potential negative impact the following (A “yes” response means that there is conditions a potential negative impact) (circle the appropriate answer) Our processing activities involve organic Yes/No Food contamination/food safety matter that needs to be washed, issues. treated or stored to ensure food safety. Our processing activities and 7Yes/No Exposure of community to foul odors. treatments involve biomass or other liquids or solids that may lead to foul odors. Our operations involve air emissions, Yes/No Air, water or land contamination, water discharge, solid waste disposal, which can affect the health and leakage of chemicals or gases, etc. that livelihood of local communities. may pass on to the surrounding community. We plan to develop new infrastructure, Yes/No Exposure of communities to air buildings, equipment and other emissions, noise and accidents due to facilities. equipment and vehicular movement. Impact on wildlife, biodiversity and local livelihoods due to natural habitat Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 107 XYZ 2. Identification of risks and impacts – XYZ Case Study conversion. We plan to decommission and dispose Yes/No Health risks to communities due to of old infrastructure, buildings, exposure to toxic substances (e.g. from equipment and other facilities. chemicals, heavy metals, asbestos, etc.) and air emissions and noise due to equipment and vehicular movement. Impact on wildlife and biodiversity. There is significant movement of Yes/No Exposure of communities to air vehicles in and around our facility due emissions, noise and accidents due to to our operations (e.g. vehicles carrying vehicular movement. raw material or finished products, movement of water tankers, etc.). We store hazardous chemicals or Yes/No Health risks to communities and hazardous waste in our facility. negative impacts on wildlife and biodiversity due to the intentional or unintentional (spills) release of hazardous or toxic substances contaminating air, land and/or water. We discharge water from our plant, Yes/No Negative impacts on local food security which may have an impact on and income generation due to surrounding water bodies. contamination of aquatic life. Diseases/illness among local communities due to the use of contaminated water. We hire temporary and migrant Yes/No Communicable diseases brought or workers. spread by the influx of workers. We hire private security personnel Yes/No Conflicts with communities and indigenous people. We normally have conflicts/complaints Yes/No Conflicts with communities and with the local community. indigenous people Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 108 XYZ 2. Identification of risks and impacts – XYZ Case Study XYZ FOOD COMPANY Physical Mapping A team that included supervisors and workers did a walk-through in the plant during operating hours and annotated on a sketch map all the problems they observed. Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 109 XYZ 2. Identification of risks and impacts – XYZ Case Study XYZ FOOD COMPANY Risk Assessment Prioritization Form XYZ used the Risk Assessment Form to prioritize which risks to address through their action plans. Company area Risk Probability of Severity if Notes or occurring occurred department (low, medium, (low, medium, high, extreme) high, extreme) Produce Solid organic waste from High High sorting and rejected produce, peels, processing seeds, extracts Produce High effluent High High cleaning and (wastewater) production processing Produce Excessive water High High cleaning and consumption processing All High energy consumption High High Generators – high capital and maintenance costs; noise is a nuisance to neighbors All Slip, trip, fall accidents High Medium from confined space and inefficient work flow, excessive water and slippery product waste on the floor Processing Unintended adulteration Medium to High Employees unaware of and packaging by confined physical High proper work flow to layout avoid cross- contamination All Poor ventilation and High Medium exposure to peanut dust Cooling and Confined spaces and poor Medium Extreme storage equipment maintenance – exposure to ammonia and other leakage Labor Child labor used in fruit Medium High suppliers Labor Anti-union discrimination Medium High Autoclave Steam escape and burn Low to medium High rupture during injuries for personnel cooking and packaging All Dust – combustible fire Low High hazard Autoclaving Condensate is pure water High Medium Collect autoclave condensate and can be reused. condensate; give away Disposal of clean water as clean water to Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 110 XYZ 2. Identification of risks and impacts – XYZ Case Study adds to the cost of inputs community or provide and managing wastes. for other manufacturing and processing industries in the area; reuse if possible; recycling is expensive unless included in original equipment capital costs. Labor Lack of contracts for Medium Medium temporary workers hired during labor shortages Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 111 XYZ 3. Management Programs – XYZ Case Study XYZ FOOD COMPANY Action Plan Based on its Risk Assessment Form, XYZ prioritized the following four key risks: • high volumes of solid organic waste from rejected produce, peels, seeds, extracts; • excessive water consumption and high effluent (wastewater) production; • confined space and poor process and equipment layout leading to worker injuries, exposure to hazardous materials and cross-contamination of product; and • child labor used in fruit suppliers. RISK 1: High volumes of solid organic waste from rejected produce, peels, seeds, extracts Mitigation Action Objective and target Deadline Responsible Resources Operational hierarchy staff required procedures Avoid - Work with suppliers to improve quality of incoming Objective: Reduce 6 months - Sourcing Staff time - Procedure for material (e.g. feedstock/product condition, variety, unusable produce that manager intensity: raw material ripeness and damage) turns to waste - Operations Medium purchase - Improve inventory management practices to minimize Target 1: 20% reduction manager Capital - Procedure for losses from putrefaction, especially of short-shelf-life fruit in rejected produce intensity: Low inspection of and vegetables by instituting “just-in-time” purchasing Target 2: 20% reduction incoming material - Develop new products to use the off-specification in spoilt produce - Procedure for materials and high-quality trimmings as raw material (e.g. Target 3: 20% reduction inventory salads, cut products, mixed jams, etc.) in total organic waste management Minimize - Modify process flow to minimize movement of material Objective: Reduce 3 months - Operations Staff time - Procedure for - Modify and improve slicing, cutting, peeling, sterilizing; organic waste manager intensity: material storage install motorized corer and pitters to minimize material Target: 20% reduction - HR manager Medium and handling losses during manual operations in total organic waste for improved Capital - Remove excess water from organic solid waste by skills training intensity: Low mechanical separation Compensate - Engage with local farmers/residents to identify Objective: Productive 1 month - Operations Staff time - Procedure for /Offset opportunities for use of organic waste as cattle feed, use of organic waste manager intensity: Low distribution of vermiculture, composting, etc. Find the end users and from food - Employees to medium organic waste provide the organic waste in a manner convenient to manufacturing responsible Capital among end users them Target: 100% reuse of for intensity: Low organic waste community (land lease; liaison waste Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 112 XYZ 3. Management Programs – XYZ Case Study transport) RISK 2: High water consumption and high volumes of effluent (wastewater) Mitigation Action Objective and Deadline Responsible Resources Operational hierarchy target staff required procedure Minimize - Install high-pressure, low-volume spray nozzles for Objective: Reduce 6 months - Operations Staff time - Procedures for cleaning water consumption manager intensity: initial - Investigate different blanching processes to reduce Target: 20% - Maintenance Medium processing/clean water usage and increase the process speed reduction in water supervisor Capital intensity: ing of raw - Use automatic control systems to regulate and optimize consumption High material flow of water in knife sterilizers, hand wash stations and table wash sprays - Optimize batch dump frequency (e.g. brine and caustic that may be reused in processing) - Convert wet production processes to dry conveying systems and dry methods, such as air classifiers, magnetic separation and vibration. Minimize - Use dry cleaning techniques (broom, scraping, etc.) to Objective: Reduce 1 month - Cleaning staff Staff time - Procedures for clean floors, transport trucks, process areas and water consumption intensity: Low housekeeping equipment prior to washing with water Target: 20% Capital Intensity: and cleaning of reduction in water Low process areas consumption Minimize - Install water recycling systems at points of use; reuse of Objective: Reduce 3 months - Operations Staff time - Procedures for water at specific locations water consumption manager intensity: recycling and - Reuse final rinse water from cleaning operations for the Target: 20% Medium reuse of treated initial rinsing on the following day reduction in water Capital intensity: wastewater - Reuse relatively clean water from cooling systems, consumption Low boiler condensate, vacuum pumps, etc. Minimize - Use screens or traps at drains to prevent solid material Objective: Reduce 5 months - Operations Staff time - Procedure for entering effluent treatment system pollution loads in manager intensity: wastewater - Install drip trays to catch juice/product on conveyors, effluents - Maintenance Medium collection, trimming and preparation tables to prevent entering Target: 20% manager Capital treatment and effluent treatment system reduction in pollution intensity disposal - Segregate high-strength effluent streams and treat load (COD and BOD) Medium - Procedure for them separately in wastewater (storage sump monitoring of Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 113 XYZ 3. Management Programs – XYZ Case Study or tank, wastewater transport; quality disposal fees) RISK 3: Confined space and poor process and equipment layout leading to worker injuries, exposure to hazardous materials and cross-contamination of product Mitigation Action Objective and Deadline Responsible staff Resources Operational hierarchy target required procedure Avoid Expand and improve plant layout. Make Objective: Expand 12 months - General manager Staff time sure building is big enough for production, space and separate - Operations intensity: but do not pay for extra space that is not hazardous material manager Medium required and processes Capital Target 1: Increase intensity: work and High containment areas by 25% Target 2: Facilitate access to equipment for regular maintenance Minimize - Redesign process flows to avoid Objective: Reduce 6 months Operations Staff time - Procedures for OSH obstructions that can lead to falls and risk of physical manager, intensity: training collisions hazards area supervisors Medium - Procedures for - Check machines to prevent spillage and Target: Reduce and Capital housekeeping and implement cleaning and drying schedules worker physical employees intensity: Low cleaning of process for all walking and working surfaces to injuries by 50% areas minimize slippery floors in work areas - Minimize physical injuries from repetitive tasks, such as operation of slicing and vacuum packing machines by proper design, training, job rotation and adequate resting periods - Minimize physical injuries from lifting or repetitive work (e.g. lifting and carrying awkward shaped items, maneuvering carts, manual forklifts, etc.) by proper Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 114 XYZ 3. Management Programs – XYZ Case Study design, training, job rotations and adequate resting periods - Install physical guards to separate sharp tools, moving or hot surfaces, mixers, packaging equipment, etc. -Train employees in appropriate OSH procedures and provide necessary PPE to them Minimize - Identify sources of potential hazards Objective: Reduce - Procedures for use from thermal injury (e.g. hot water, exposure of workers and maintenance of steam, refrigeration), electricity (e.g. to noise, hazardous PPE electrical shocks from live wires or poorly substances, thermal, grounded equipment) and electricity and eliminate/minimize them irradiation hazards - Minimize exposure to hazardous Target: 50% substances (e.g. cleaning and disinfecting reduction in worker- chemicals, ammonia and CFCs from related injuries refrigeration equipment, etc.) to prevent chemical contact burns, inhalation of harmful/toxic fumes and ingestion - Provide PPE to workers in high noise areas like freezers/chillers, bowl choppers, canning and bottling lines, etc. - Prevent occupational exposure to radiation from irradiation dosing Minimize Separate cleaning area from packaging Objective: Reduce 2 months Operations manager Staff time area to avoid cross-contamination cross-contamination intensity: Low Target: Eliminate Capital crossing of dirty and intensity: clean product Medium pathways Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 115 XYZ 3. Management Programs – XYZ Case Study The following are two example procedures that XYZ put in place related to key issues addressed in the Action Plan. XYZ was concerned about regional prevalence of anti-union and other forms of discrimination. Here we present the non-discrimination procedure that XYZ adopted. On the environmental side, a couple of key issues for XYZ were water consumption and solid waste. We present one water conservation procedure that XYZ adopted. XYZ FOOD COMPANY Non-Discrimination Procedure Title: XYZ Non-Discrimination Procedure Responsible Party: General Manager Date Issued: February 15, 2011 Date Revised: March 1, 2012 Related Policy Statement:  Our company will hire, promote and compensate workers solely based on their ability to do the job.  All workers will be given equal access to training, tools and opportunities for advancement.  We will ensure that all workers are free from harassment by management or other workers. Procedure Checklist Application Process  When hiring any worker, keep the original application and a photocopy of the original identification documents in the applicant’s file.  If the applicant is hired, this will be transferred to his or her personnel file.  Whether or not the applicant is hired, the application will be kept on file for a minimum of two years.  Give all applicants a sheet explaining our company’s Non-Discrimination and Equal Opportunity Policy.  The Human Resources Department staff person accepting an application will verbally explain the policy and go over the points on the cover sheet with the applicant. Orientation and Training  Provide a written copy of the Non-Discrimination and Equal Opportunity Policy to workers during orientation and explain in detail.  Provide training on filing a complaint concerning discrimination, during orientation and annually thereafter.  Provide semi-annual training to middle-level management and supervisors, about our Non- Discrimination and Equal Opportunity Policy and about how to enable a respectful and constructive workplace atmosphere. Disciplinary Actions and Complaints  If a worker engages in discriminatory or harassing behavior, the supervisor will give a written warning on the first offense and subsequent discipline following procedures outlined in the Disciplinary Practices Procedure.  Individuals who believe they have experienced discrimination at the workplace should file their complaints through our company’s grievance mechanism. Management Review  General manager will conduct a spot check of all application files processed during the previous quarter, to check for evidence of discrimination.  Each quarter, the general manager will review the workplace demographics by department in comparison with the application and personnel promotion files, review any complaint records, and interview workers, in order to check for evidence of discrimination. Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 116 XYZ 3. Management Programs – XYZ Case Study XYZ FOOD COMPANY Water Conservation Flowchart Title: XYZ Water Conservation Procedure Date Issued: February 15, 2011 Date Revised: March 1, 2012 Purpose: Measure total demand, identify overage sites and reasons for water use, eliminate outlet if feasible to improve water conservation Process Responsible person Documentation Measure total flow of potable Engineering and Maintenance Potable water total flow water to plant operations and estimated cost/m3 Inventory all water distribution Area supervisors, Engineering Potable water outlets map points in plant and Maintenance and flow Map all potable water outlets on Area supervisors, Engineering Potable water outlets map facility plan; assign outlet and Maintenance and flow number and flow Show outlets that are left open Operations manager, area Complete annotated and those without control valves supervisors, Engineering and water map, outlets, (pistols) Maintenance estimated flows and determination of need Review process and define Area supervisors, Engineering specific purpose of water use; and Maintenance indicate taps to replace with a dry process, or fit with controls Obtain benchmarking data for Area supervisors, Engineering Facility benchmarking processes and industry; compare and Maintenance report; compare existing benchmark water use m3/KG operations with several product benchmarks Advise operations manager and Operations manager, area area supervisors of need to supervisors, Engineering and eliminate water usage and Maintenance convert to dry cleaning Review outlets and water uses; Operations manager, Update annotated water mark outlets that can be Engineering and Maintenance map, outlets, estimated eliminated; remove outlets and flows, date of closure seal piping Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 117 XYZ 3. Management Programs – XYZ Case Study Measure total flow of potable Engineering and Maintenance Update total potable water to plant operations water flow; calculate estimated revised flow and total cost reduction Repeat the process Engineering and Maintenance Update total potable water flow; calculate estimated revised flow and total cost reduction Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 118 XYZ 4. Organizational Capacity and competency – XYZ Case Study Based on their Action Plan, XYZ developed a simple training plan to raise awareness and provide the skills needed to implement the Action Plan. XYZ was able to participate in a local government program that provided subsidized training in these areas. XYZ FOOD COMPANY Training Plan Department Module 1 Module 2 Module 3 Module 4 Human Resources/EHS/ESMS Introduction to Complaint Freedom of ESMS in the supply performance team ESMS; Labor management and association and chain standards resolution procedure collective bargaining; performance issues Worker-manager communications All workers and managers Hygiene and food Water and energy Waste reduction; Complaints safety; Health and conservation Composting and procedure; Worker- safety; Emergency procedures recycling procedures manager response procedures communications Senior management Introduction to Labor standards Stakeholder and ESMS performance issues community engagement and Environmental communications performance issues Production Water treatment Water and energy Waste treatment and Layout and process and recycling conservation reduction procedures design procedures procedures Sourcing Introduction to Child labor issues in Supplier quality ESMS the supply chain standards and environmental management Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 119 XYZ 4. Organizational Capacity and competency – XYZ Case Study XYZ developed a Roadmap to estimate the staff time required and the timeframe to develop and implement their ESMS. They estimated a total of 167.25 days of time from senior management, middle management, supervisors and workers. Roadmap and Estimated Timeframe for Developing and Implementing XYZ FOOD COMPANY’S ESMS MONTH ACTIVITY Time spent 1 2 3 4 5 6 Senior Mid Super- Work 1. Policy mgt mgt visors ers time time time time Kick-off meeting at sr. management level .5 to discuss ESMS implementation Selection (including communication/coordination) of ESMS .25 .5 .5 Developing core team (personnel from different key departments) Appreciation and awareness workshop for 1 1.5 2 senior management and core team on ESMS requirements Review/upgrading of existing environment .5 .5 1 and social policy/formulation of organization’s env. & social policy Design, printing and display of ESMS policy .5 .5 .5 at key areas Uploading of ESMS policy on company .25 Implementing website Communication of ESMS policy to key .5 external stakeholders Training & awareness of employees on ESMS policy and information dissemination Senior Mid Super- Work 2. Risk and Impact Identification mgt mgt visors ers time time time time Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 120 XYZ 4. Organizational Capacity and competency – XYZ Case Study MONTH ACTIVITY Time spent 1 2 3 4 5 6 Mapping of activities, processes and key .5 .5 1.5 stakeholders, including the suppliers & contractors Developing Identification and compilation of .5 1 1 regulatory and other requirements, including stakeholder expectations Initial environmental & social review, 3 4 2 2 identification & evaluation of environment and labor risks (including supply chain) Training & awareness of employees on 1 2 3 environmental, social and labor risks and risk identification process Implementing Training & awareness of employees on .5 .5 1.5 regulatory and other requirements, including stakeholder expectations Training & awareness of employees on .5 1 2 environmental, social and labor risks and information dissemination Senior Mid Super- Work 3. Management Programs mgt mgt visors ers time time time time Preparation of ESMS manual (formulation 5 4 and documentation of procedures related to ESMS) Formulation, compilation of Developing environmental objectives/targets and .25 .5 1 1 social performance improvement measures Formulation and development of 1.5 2.5 environmental and social action plans Development of operational procedures 1 3 2 2 Communication, awareness and training .5 .5 1 2 me ple nti Im ng of employees on ESMS procedures Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 121 XYZ 4. Organizational Capacity and competency – XYZ Case Study MONTH ACTIVITY Time spent 1 2 3 4 5 6 Communication and awareness of employees on environmental objectives .25 .25 1 and social performance improvement measures Communication and awareness of .25 .25 1 employees on environmental and social action plans Training of employees on environmental 2 4 7 and social operational procedures Senior Mid Super- Work 4. Organizational Capacity and mgt mgt visors ers Competency time time time time Environmental and social awareness 1.5 program for middle management Developing Environmental and social awareness 5 program for workers Competency program for ESMS core team 1.5 2 Internal auditor training for the 1 2 organization’s ESMS assessors/auditors General awareness and training on environmental, social and labor .5 1 issues/ESMS for senior and middle management Implementing Environmental and social awareness 1 1.5 5 program for workers Competency program for ESMS core team 1.5 2 Internal auditor training for the 1 2 organization’s ESMS assessors/auditors Senior Mid Super- Work 5. Emergency Preparedness and mgt mgt visors ers Response time time time time Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 122 XYZ 4. Organizational Capacity and competency – XYZ Case Study MONTH ACTIVITY Time spent 1 2 3 4 5 6 Review of key risks and existing .25 .5 emergency preparedness plan Developing Upgrade/prepare the emergency .25 2 .5 preparedness plan Communicate to workers, potentially .25 .25 affected communities and relevant government agencies (if required) Awareness and communication to Implementing employees and affected communities on .25 .5 .25 1.5 key risks and emergency issues and emergency planning Training of employees on emergency .25 1 1 2 preparedness plan Communication and awareness on emergency procedures to affected .25 .25 communities and relevant authorities (if required) Senior Mid Super- Work 6. Stakeholder Engagement mgt mgt visors ers time time time time Mapping of all stakeholders, stakeholder .25 .25 Developing analysis and engagement planning Develop/upgrade stakeholder communication/consultation; information .25 1 disclosure and engagement strategy/program Communication to employees on key Implementing .25 2 stakeholders and their environmental and social/labor expectations Communication, awareness and training of employees on the strategy/program for .5 .5 1.5 stakeholder engagement/consultation/communication and information disclosure Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 123 XYZ 4. Organizational Capacity and competency – XYZ Case Study MONTH ACTIVITY Time spent 1 2 3 4 5 6 Senior Mid Super- Work 7. External Communication & mgt mgt visors ers Grievance Mechanism time time time time Review external communication system, .25 Developing including receiving and handling feedback, concerns and complaints Develop/upgrade system for regular .25 1 engagement, receiving, documenting and responding to feedback and grievances Review external communication, Implementing feedback, stakeholder concerns and .25 .25 .5 2 complaints and communicate to key personnel Training, awareness and implementation of stakeholder engagement, receiving, .5 .5 2 documenting and responding to feedback and grievances Senior Mid Super- Work 8. Ongoing Reporting to mgt mgt visors ers Affected Communities time time time time Review existing system for reporting and .25 Developing disclosure Develop/upgrade system for external reporting and disclosure (including .25 1 .5 collection, validation and verification of information) Communication and disclosure to key Implementing .25 .25 external stakeholders and affected communities Communication, awareness and training on external reporting and disclosure 1 1 2 (including collection, validation and verification of information) Senior Mid Super- Work 9. Monitoring and Review mgt mgt visors ers Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 124 XYZ 4. Organizational Capacity and competency – XYZ Case Study MONTH ACTIVITY Time spent 1 2 3 4 5 6 time time time time Establish procedure to monitor and .25 1 .25 measure ESMS performance, compliance and stakeholder requirements Implementation of ESMS monitoring .5 1 1 program, establishing benchmarks and integration with existing system Final review and complete ESMS .5 1 Developing documentation Conduct internal audit/evaluation of ESMS performance against the management 1 1 .5 program requirements/benchmarks Establish relevant operational controls .25 1 .5 .5 and formulation of corrective & preventive actions Review by the senior management to .25 .25 .25 assess performance and effectiveness of ESMS Documentation and communication on 1 1 ESMS conformance, regulatory compliance and stakeholder requirements Communication, awareness, training and .25 1 1 3 implementation of ESMS monitoring program and established benchmarks Implementing Communication of internal .5 .25 1 audit/performance measurement findings and ESMS performance to the employees Communication, awareness and training .5 1 3 of employees on operational controls and corrective & preventive actions Communication on outcomes of review of .25 the ESMS performance by senior management and key decisions taken Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 125 XYZ 4. Organizational Capacity and competency – XYZ Case Study MONTH ACTIVITY Time spent 1 2 3 4 5 6 TOTAL 22.75 53.5 42 49 Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 126 XYZ 5. Emergency Preparedness and Response – XYZ Case Study Based on their risk assessment, which identified ammonia leakage as a severe-impact risk, XYZ developed a Preparedness and Response Plan to identify, prevent and respond to leakage emergencies. The plan includes an Ammonia Leakage Response Procedure. The procedure was documented as a flowchart so that it could be posted at various workstations and understood easily. XYZ FOOD COMPANY Ammonia Leakage Preparedness and Response Procedure See sample Ammonia Leakage Preparedness and Response Procedure in Toolkit. Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 127 XYZ 6. Stakeholder Engagement – XYZ Case Study XYZ FOOD COMPANY Stakeholder Mapping – identification and analysis XYZ listed the stakeholders that are affected by or have an interest in their operations. Next to each stakeholder group, they listed their key concerns, issues and interests. To identify those, they looked back at the environmental and social key risks and impacts previously identified and how these affect the surrounding communities. Stakeholder Issues/concerns/interests a. Surrounding farmers and local village Water sources contaminated by XYZ effluents population (affected community) Putrid smells from solid waste Generator noise Disease vectors from sludge ponds b. Customers (hotels, restaurants, tourism Food safety companies, supermarkets) Unreliable quality c. Residents of Mwanza city High energy and water use strains municipal supplies d. Municipal Electricity Authority Unreliable electricity supply e. Municipal Water Authority Unreliable water supply f. Tanzania Ministry of Labor Contraventions to national and international labor laws g. Tanzania Ministry of Water and Livestock Disease threats to humans and animals from XYZ sludge ponds h. NGO Save the Children Child labor in XYZ supply chain i. Fairtrade XYZ not in position to meet standard j. Tanzania Food Processors Association (TAFOPA) Fluctuating reputation of food processors due to scandals k. Small Enterprise Development Agency (SEDA) and consequent lack of investment in the sector Finally, they mapped the stakeholders on a matrix according to (a) the degree to which they are impacted and (b) their ability to influence the company operations, and then (c) categorized them based on their current relationship with the company: supportive, supportive with conditions, neutral, opposed. Based on this, they identified which groups were a priority to engage. Quadrant 1= Involve as Quadrant 2= Proactively High needed approach and support Supportive them Supportive with conditions Neutral Capacity to influence Opposed Quadrant 3= Keep them Quadrant 4= Respond to informed their concerns Low Low High Degree impacted by the company Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 128 XYZ 6. Stakeholder Engagement – XYZ Case Study XYZ FOOD COMPANY Stakeholder Engagement Plan Based on the information above XYZ prepared a Stakeholder Engagement plan. XYZ prioritized engagement with those groups that are mostly affected. Stakeholder Engagement Plan for affected stakeholders Stakeholder Concerns Engagement Information to disclose Most valuable method and report back info to obtain a. Surrounding Local streams and water - Grievance - Progress on actions to Factual, as well farmers and local sources contaminated from mechanism reuse solid organic as reported village population XYZ effluents - Quarterly town waste information on (Quadrant 2) Putrid smells from solid hall meetings - Progress on impact of XYZ waste announced wastewater treatment activities Generator noise through local actions Disease threat to humans newspapers and animals (disease vectors of dengue and malaria) from XYZ sludge ponds b. Customers – Unreliable quality reflected - Grievance - Food safety is XYZ Trace Tanzania (hotels, in product recalls (tomato mechanism priority adulterated restaurants, sauce) (hotline number product tourism Reputational risks and and email companies, financial losses for XYZ printed on food supermarkets) customers due to clients containers) (Quadrant 2) getting sick c. Residents of High energy and water use - Grievance - Progress of Mwanza city strains municipal supplies mechanism consultations with (Quadrant 4) municipal electric and water authorities - XYZ water and energy efficiency programs Stakeholder Engagement Plan for interested stakeholders Stakeholder Concerns Engagement Information to disclose Most valuable info method and report back to obtain d. Municipal Unreliable electricity supply Frequent - State of current State of current electric leading to increased communication supply and how it electricity and authority production costs and through emails, affects regional water (Quadrant 1) possible health letters, phone economic prospects infrastructure and consequences from food calls and - XYZ programs to supply processed and stored in meetings when improve energy Actions taken to suboptimal conditions possible conservation rectify current unsustainable situation e. Municipal Unreliable water supply for - State of current water authority industrial and domestic supply and how it (Quadrant 1) consumption affects regional economic prospects - XYZ programs to improve water conservation f. Tanzania Environmental degradation Regular XYZ will work within its Extent to which XYZ Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 129 XYZ 6. Stakeholder Engagement – XYZ Case Study Ministry of and pollution: water communication powers to improve its activities impact Water and consumed by people and through email impact on water supply environment Livestock cattle is contaminated and meetings and livelihood of (Quadrant 1) Disease threat to humans livestock (dengue and malaria) and animals from XYZ sludge ponds g. Tanzania XYZ could be in Contact with XYZ prepared to work Good knowledge of Ministry of contravention of labor inspectors to improve labor labor standards – Labor international labor laws during periodic standards internally international and (Quadrant 3) (ILO Conventions), and and and in its supply chain national national labor law unannounced Tainted reputation for visits to XYZ Tanzania among international community h. Save the Child labor in XYZ supply Regular email Actions taken to tackle Preponderance of Children chain (on local supplier communication child labor issue child labor in XYZ (Quadrant 1) farms) and meetings supply chain with local representatives i. Fairtrade XYZ is not in a position to Emails by CEO Progress made and Standards required Labeling meet standards of and XYZ corrective actions to be met to Organization international certification compliance staff, taken on areas of achieve FLO (Quadrant 1) programs sharing of audit concern identified by certification reports as well FLO as public reports if available j. The Tanzania Fluctuating reputation of Regular Members to support Data collected by Food food processor members communication each other in improving TAFOPA on current Processors like XYZ, due to social or through email reputation of status and Association environmental scandals and trade Tanzanian food perception of XYZ (TAFOPA) Consequent lack of meetings processors and other similar k. Small investment in such food processing Enterprise businesses if seen as “high plants Development risk” Agency (SEDA) (Quadrant 3) Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 130 XYZ 7. External Communication and Grievance Mechanism – XYZ XYZ has implemented a grievance mechanism. The procedure is explained during the quarterly town hall meetings and is also announced on a poster outside the company’s gate. XYZ FOOD COMPANY Grievance Mechanism Poster We’re proud to be part of your community. If you have any questions, concerns or complaints, here’s how to reach us, and how we’ll respond.  You can send an email to XYZ’s administrative officer at Community@XYZ.com. Time for acknowledgment of receipt: 48 hours  You can call XYZ’s administrative officer, Monday to Friday, from 3pm to 5 pm, at 123-45-6789. Time for acknowledgment of receipt: immediate or 48 hours if left a message.  You can fill out a form and submit it to the suggestion box at the company’s gate. The suggestion box is more confidential. It will only be opened by XYZ’s administrative officer. Time for acknowledgment of receipt: 1 week. At the time of the acknowledgment of receipt, XYZ will provide an estimated date for response and request further information if needed. If the issue is not resolved by the estimated date, XYZ’s administrative officer will provide an update of the situation to the interested party. Every three months at the XYZ town hall meeting, XYZ’s general manager will present the list of questions and complaints received, their status and the actions taken by the company to address the issues. Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 131 XYZ 7. External Communication and Grievance Mechanism – XYZ XYZ Grievance Mechanism Procedure •Receive complaints from groups and individuals affected by our operations •Responsible party: Administrative officer Receive •Register complaint from the public •Responsible party: Administrative officer; Document location: Admistrative office Register •Screen the issues raised Screen and •Responsible party: Administrative officer Assess •Address the issues raised •Responsible party: Administrative officer coordinates with relevant departments Address •Document the issue and the response •Responsible party: Administrative officer; Document location: Administative office Document •Track issues raised and actions taken •Responsible party: Adminstrative officer and senior management team; Quarterly Track management review •Update management programs •Responsible party: Senior management team and department heads Update •Report to those who raised the issue and to the public •Responsible party: General manager; Quarterly town hall meetings Report Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 132 XYZ 7. External Communication and Grievance Mechanism – XYZ Key Aspects of XYZ FOOD COMPANY’S Grievance Mechanism Key aspects of effective grievance mechanisms XYZ’s method Provide ease of access to confidentially XYZ has an email address and telephone hotline communicate or file complaints, including specifically for complaints. Email is checked daily anonymous ones by the administrative office. Publicize the system so that stakeholders know it XYZ has a written procedure that the general exists and how to access it manager explains during quarterly town hall meetings. The procedure is posted on a banner outside the company’s gate. The poster is in English and the local language. Foster sense of legitimacy and trust; encourage XYZ works with the local government ministries to dialogue and shared responsibility for outcomes ensure that legal mechanisms are followed and consults with various groups to refine its system as needed. Be transparent about the process and outcomes The administrative office receives and records complaints and reports back to the complainant about whether the complaint is accepted or not and what is the process and timeline for investigation and resolution. Implement a predictable and defined process that The administrative office receives and records the includes assignment of responsibility, time limits complaint and then works with relevant staff and and monitoring of outcomes external stakeholders to investigate, determine actions and report back outcomes. Make the system a source of continual learning XYZ’s general manager and department heads meet quarterly to review complaints and check for ways to improve the mechanism and the overall company systems. Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 133 XYZ 8. Reporting back to affected communities – XYZ Case Study See Chapter 6. Stakeholder Engagement – XYZ Case Study, and Chapter 7. External Communication and Grievance Mechanism – XYZ Case Study. Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 134 XYZ 9. Monitoring and Review – XYZ Case Study Monitoring Plan for XYZ XYZ’s ESMS Team developed a Monitoring Plan based on the action plans and their targeted objectives. Solid waste and odor Performance indicators Monitoring indicators Monitoring records Equipment Solid waste generation per day and per ton of product processed - Daily solid waste - Calibrated % and volume of rejected product from suppliers generation/disposal log weighing % and volume of product loss during screening, sorting and grading machines % and volume of product loss due to contamination, spoilage, shelf-life % and volume of product loss during cutting and processing % and volume of waste composted - Records of composting % and volume of waste re-processed for animal feed and re-processing Process indicators Monitoring indicators Monitoring records Equipment % of employees trained on waste reduction - Records of operational training % of suppliers trained in product quality - Records of supplier quality management Adequacy of refrigeration, cooling and storage - Records of operation and - Calibrated facilities maintenance of refrigeration and temperature cooling units gauges/thermometers Average storage time for product Water consumption and effluents Performance indicators Monitoring indicators Monitoring records Equipment Water consumption in kl per day - Production records - Sealed water meters at all Water consumption in kl per ton of product processed - Water meter intake points Wastewater discharge in kl per day records - Calibrated water meter(s) at Wastewater discharge in kl per ton of product processed all/final discharge point % and volume of wastewater treated - Water treatment Volume of sludge generation from wastewater records treatment Quality of treated wastewater - Facility water - Water sampling and testing analysis records equipment if done in-house Process indicators Monitoring indicators Monitoring records Equipment % of wastewater streams analyzed for their suitability for recycle/reuse % of processes analyzed for use of recycled water % taps and washing hoses/nozzles with high- - Maintenance records of leaking and replaced efficiency taps/nozzles faucets, hoses and nozzles % of employees trained on: - Records of operational training - water saving techniques - water treatment and recycling - good housekeeping Areas where dry cleaning techniques are applied - Daily/shift records of housekeeping Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 135 XYZ 9. Monitoring and Review – XYZ Case Study Consultations/engagement with regulators, NGOs - Record of surveys/consultation with local and other interested parties communities on water issues Complaints or disputes with local communities on - Records of grievances water issues OSH and product contamination Performance indicators Monitoring indicators Monitoring records # of OHS risks identified - Hazard and risk analysis records % of work hours spent continuously on repetitive tasks % of processes requiring heavy lifting or tasks with ergonomic stress # of accidents, injuries and near-misses - OSH incidents records # of work hours lost due to accidents and injuries - Medical records # of incidences of "critical limits" # of incidences of exposure to hazardous materials # of contamination risks identified - Process analysis records # of incidences of product contamination - Production records % and volume of product loss due to contamination Process indicators Monitoring indicators Monitoring records Established procedures and system to identify worker concerns, feedback - Employee survey, feedback, and grievances consultation and grievances records Number of complaints and grievances raised by workers - Records of internal grievances % of workers and managers trained on OHS, hygiene and process control - Records of training provided to workers, supervisors and managers Child labor in supply chain Performance indicators Monitoring indicators Monitoring records # of hours and type of labor using minors (above school - Workers employment contracts age but below 18 years) - Records of working hours and overtime # of incidences of child labor % of incidences remediated Process indicators Monitoring indicators Monitoring records % of suppliers screened and monitored for child labor - Supplier recruitment and HR records - Supplier internal and external audits and corrective action/remediation records % of suppliers with procedures for prevention and - Supplier commitment and procedures remediation of child labor Number of complaints and grievances about child labor - Grievances records Consultations with community leaders and local NGOs - Community consultation records near suppliers % of managers and suppliers trained on child labor policy - Manager and supplier training records and procedures Revision 1.0 October 21, 2013 IFC ESMS Toolkit and Case Studies – FOOD & BEVERAGE 136