Review of Environmental, Social, and Labor Issues
Environmental and Labor Issues
Environmental Classification and Issues: This is a category III project according to the IIC’s environmental and labor review procedure because it could produce certain effects that may be avoided or mitigated by following generally recognized performance standards, guidelines, or design criteria. The main environmental, labor, and social considerations related to the project are environmental management; liquid effluent and solid and hazardous waste management; noise and air emissions; occupational health and safety; and labor practices and corporate social responsibility.
Environmental Management: Since mid-2008, INCA has been implementing environmental management systems, designed with the help of a specialized consulting firm, at its La Isabela industrial area (ZILI) and Duarte industrial park (PID) facilities. Its goal in so doing is to ensure compliance with domestic environmental regulations and international guidelines and prevent, control, or mitigate its operations’ negative environmental impact. INCA’s environmental management plans were submitted to the Ministerio del Ambiente for consideration and approval. In the medium term, INCA plans to obtain ISO 14001 environmental management system certification for its rolling mill. INCA is implementing the relevant environmental management plans at its ZILI and PID industrial facilities. INCA has an industrial safety and environmental department, composed of a head consultant, four professional area managers, and ten qualified technical coordinators, that is in charge of implementing the environmental management plans.
Liquid Effluent and Solid and Hazardous Waste Management: Almost all of the production processes at INCA’s ZILI facilities generate industrial wastewater, most of which is recycled. Wastewater from the galvanizing process is not recycled; this acidic water is treated in a wastewater treatment plant that, according to analyses carried out in late 2008, generally complies with domestic regulations. INCA’s PID rolling mill has a recycling system in place for cooling water from the rolling process; wastewater is treated at an on-site treatment plant. Sewage from the restrooms and water from food preparation need to be treated before discharging. Therefore, in 2009 INCA will install package sewage treatment plants for all of its facilities’ domestic wastewater.
INCA collects and sorts its waste into hazardous, non-hazardous, and special waste. The company also has programs for recycling paper, cardboard, metal, and iron shavings (a byproduct of the rolling process). Paper and cardboard are collected and sent to a paper manufacturer for reuse. Metal is temporarily stored in an authorized warehouse for subsequent export. Iron shavings are sent to a cement company, where they are used as raw material. An authorized contractor collects and transports the remaining non-hazardous waste for final disposal in sites authorized by the municipality. INCA generates several kinds of hazardous and special waste, such as fluorescent lamps, batteries (lead/acid), and used lubricants, grease, and oil. Some of the waste is returned to suppliers for reuse. An authorized service provider collects, transports, and treats hazardous and special waste that cannot be recycled or reused.
Noise and Air Emissions: In areas with high noise levels employees must use hearing protection equipment provided by INCA. Air emissions mainly include gases (carbon monoxide, sulfur dioxide, and nitrogen dioxide) and particles from burning fossil fuel (Bunker C, diesel, and gasoil) to operate reheating furnaces in the rolling process, main and emergency power generators, and forklifts. Ambient air quality sampling carried out in 2008 near INCA’s ZILI and PID industrial facilities indicated that ambient air quality parameters comply with Dominican regulations. The stacks of INCA’s PID facilities’ three main generators are suitable for emissions sampling (isokinetic sampling); however, the reheating furnace must be adapted to enable the required sampling. INCA is adapting all of its stacks and installing sampling points and platforms so isokinetic sampling can be performed in all of them. In the medium term, INCA is also considering replacing bunker C fuel with natural gas, as per the Clean Development Mechanism under the Kyoto Protocol and in order to obtain carbon credits. The IIC has offered to provide INCA with support for this undertaking using its technical assistance funds available for this type of project.
Occupational Health and Safety: INCA’s industrial facilities have medical personnel, nurses, and ambulances to cover workers’ medical needs twenty-four hours a day, seven days a week. INCA also has the support of a service network that meets workers’ healthcare needs through several programs, including occupational medical monitoring with audiometric, respiratory capacity, and blood lead tests; disease treatment; and vaccination drives. INCA’s safety policy stresses the safety of its workers, employees, contractors, and visitors to its facilities. Programs being carried out in 2009 include handling chemicals and substances appropriately; improving accident and incident investigation procedures; training on industrial safety and the environment; providing personal protective equipment by area and controlling its use; and establishing a contingency plan and organizing emergency brigades. INCA will also install air extractors to improve ventilation in the machine room. This will lower the temperature in the processing areas, where more heat is generated due to the furnaces and other equipment. As per Dominican regulations, INCA has an industrial health and safety committee. ZILI and PID industrial facilities have fire detection systems, including alarm panels with photoelectric and heat detectors, sirens and strobe lights. All of the areas in both industrial facilities have fire extinguishers, signage, and established evacuation routes. To ensure proper system operation, INCA engages specialized companies to perform maintenance. Bunker C, diesel, and gasoil storage tanks have safety signs and leak containment dikes.
Labor Practices and Corporate Social Responsibility: INCA is in compliance with domestic labor laws and International Labour Organization (ILO) guidelines. There is no union; workers can join the employees’ cooperative if they wish. Under its corporate social responsibility program, INCA provides support for the education of gifted students and for nonprofit institutions.
Monitoring and Compliance: INCA will continue to implement its Environmental Management Plans at ZILI and PID covering the environmental protection, safety, and labor issues discussed herein. The Company will submit an annual report summarizing tracking data on liquid effluent treatment, handling and disposal of solid and hazardous waste, air emissions, occupational health and safety, fire prevention and firefighting, and labor and corporate social responsibility practices. During the life of the project, the IIC will monitor ongoing compliance with its own environmental and labor review guidelines by evaluating monitoring reports submitted annually to the IIC by the company and by conducting periodic site visits as part of the project supervision process.