Chapter 17 Envirnmental and Scial Management System and Envirnmental and Scial Management Plan
CONTENTS 17 ENVIRONMENTAL AND SOCIAL MANAGEMENT SYSTEM AND ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN 17-1 17.1 INTRODUCTION 17-1 17.2 ENVIRONMENTAL AND SOCIAL MANAGEMENT SYSTEM OVERVIEW 17-2 17.2.1 Plan 17-3 17.2.2 Implement 17-4 17.2.3 Assess 17-4 17.2.4 Imprve 17-4 17.3 FRAMEWORK FOR IMPLEMENTATION OF THE ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN 17-4 17.3.1 Intrductin 17-4 17.3.2 Organisatin, Rles and Respnsibilities 17-4 17.3.3 Training, Educatin and Cmpetency 17-7 17.3.4 Assessment and Imprvement 17-8 17.3.5 Grievance Management 17-9 17.3.6 Incident Management 17-9 17.3.7 Reprting 17-10 17.3.8 Managing Changes 17-11 17.4 COMMUNICATION TO STAKEHOLDERS 17-11
17 ENVIRONMENTAL AND SOCIAL MANAGEMENT SYSTEM AND ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN 17.1 INTRODUCTION This chapter presents the framewrk fr implementatin f the Prject Envirnmental and Scial Management System (ESMS). The ESMS prvides the structure fr the management f envirnmental and scial impacts assciated with Prject delivery. This includes envirnmental and scial mnitring, dcumenting cmpliance (eg recrd-keeping) as required t measure the effectiveness f the mitigatin measures, reprting n envirnmental and scial perfrmance, and the prcess fr defining and implementing prcedures fr crrective actin when necessary. The ESMS framewrk enables implementatin f the Envirnmental and Scial Management Plan (ESMP), which details the actins that will be taken by the Prject t mitigate and manage envirnmental and scial impacts based n the activities described in the Chapter 4: Prject descriptin, Chapters 6-9: baseline and Chapters 10-13: impact assessment chapters f this EIA. Implementatin f the ESMP prvides tls fr auditing the Prject s mitigatin and mnitring activities, and cmmunicating mnitring utcmes t stakehlders (1). The ESMS is supprted by the fllwing annexes: Annex C: Specialist Methdlgies Annex C prvides a descriptin f the methdlgies develped and used by the varius envirnmental and sci-ecnmic specialists cntributing t this EIA t cllect, interpret and present baseline findings fr their respective specialist studies. Annex D: ESMP Tables Annex D tabulates the Prject impacts, assciated management and/r mitigatin measures as described in this EIA, and summarises key mnitring requirements and respnsibilities fr implementatin. Annex E: Waste Management Plan Annex E is the Prject Waste Management Plan (WMP), develped t facilitate evaluatin and assessment f the Prject impacts assciated with the generatin f waste. The WMP als utlines hw waste generated as a result f the Prject will be managed in accrdance with Mzambican laws and regulatins, recgnised internatinal gd practice and the Prject s general envirnmental and waste management plicies. (1) A Stakehlder Engagement Plan is being develped by the Prject t describe its engagement strategies with identified prject stakehlders. 17-1
Annex F: Decmmissining and Rehabilitatin Plan The Prject s Decmmissining and Rehabilitatin Plan (DRP) prvides a framewrk, including a set f guidelines and actins, fr facilitating decmmissining and rehabilitatin activities. The DRP will need t be updated and submitted t MICOA fr apprval tw years befre Prject clsure. Annex H: Emergency Respnse Plan Annex H prvides a representative Emergency Respnse Plan (ERP) which defines an rganizatinal structure and prvides a framewrk fr respnding t an emergency situatin. Annex I: Initial Resettlement Plan The Prject s Initial Resettlement Plan (IRP) cntains the apprach, principles and prcedures which will be fllwed in resettlement planning. The IRP prvides a framewrk fr the future develpment f a Resettlement Actin Plan (RAP). The remainder f this chapter is structured as fllws: Sectin 17.2: Envirnmental and Scial Management System Overview; and Sectin 17.3: Framewrk fr Implementatin f the Envirnmental and Scial Management Plan: Intrductin; Organisatin, Rles and Respnsibilities; Training, Educatin and Cmpetency; Assessment and Imprvement; Incident Management; Grievance Management; Reprting, and Managing Changes. 17.2 ENVIRONMENTAL AND SOCIAL MANAGEMENT SYSTEM OVERVIEW IFC Perfrmance Standard 1 requires that an ESMS be develped t supprt an rganisatin s verall management systems t address envirnmental and scial impact management effectively. The verarching management system is the Prject s Management System that: enables the Prject t manage activities in a healthy, safe and envirnmentally and scially respnsible manner; establishes a cmmn set f bjectives and expectatins; prvides a structure t rganise prcesses, prgrammes and prcedures that enable the Prject t carry ut these bjectives and expectatins; 17-2
is designed t identify, evaluate and cntrl Prject risks in a way that prevents r mitigates incidents that culd impact peple, the envirnment r assets; and applies t the entire asset life cycle: starting with design r acquisitin, cntinuing thrugh cnstructin, installatin, start-up and peratins, and n thrugh abandnment r divestiture. The ESMS is develped in the cntext f the Prject s Prject Management System. The key steps r prcesses f the ESMS are illustrated in Figure 17.1, and each f the steps are further detailed belw. Figure 17.1 Envirnmental and Scial Management System Implementatin Prcess Plan Imprve Leadership Implement Assess 17.2.1 Plan The planning prcesses f the ESMS includes the fllwing activities and cnsideratins: defining the Prject s plicies, bjectives and requirements fr envirnmental and scial perfrmance; identifying envirnmental and scial impacts and risks f the peratins; develping mitigatins and peratinal cntrls t address impacts and risks; and develping the management plans t achieve these bjectives (that cllectively prduce the ESMP). 17-3
17.2.2 Implement Implementatin f the ESMS thrugh the ESMP identified abve will invlve: implementing varius envirnmental and scial management plan(s); and implementing mitigatin and management cntrls. 17.2.3 Assess The assessment f the ESMS includes: assessing and evaluating perfrmance against plicies and bjectives; and checking that mitigatins and management cntrls are effective. 17.2.4 Imprve Imprving ESMS perfrmance invlves: making crrectins t plans, mitigatins r cntrls in respnse t perfrmance mnitring. 17.3 FRAMEWORK FOR IMPLEMENTATION OF THE ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN 17.3.1 Intrductin Fr the ESMP t be effectively implemented, the fllwing areas need t be addressed by the ESMS: rganisatin, rles and respnsibilities; training, educatin and cmpetency; assessment and imprvement; grievance management; incident management; reprting; and managing changes. Each f these implementatin elements is described in detail belw. 17.3.2 Organisatin, Rles and Respnsibilities The Prject is ultimately accuntable fr the management and supervisin f all Prject activities. This respnsibility includes the management f all cntractrs t ensure they cntribute t helping the Prject achieve its envirnmental and scial perfrmance bjectives. Clear rles will be defined between the Prject and cntractrs t determine leadership and respnsibility fr cntributing t meeting envirnmental and scial 17-4
perfrmance expectatins, and will entail at least the brad rles and respnsibilities utlined in Table 17.1 belw. 17-5
Table 17.1 Key Prject Rles and Respnsibilities Rle Respnsibility Management Manage implementatin f the ESMS: plan, implement, assess and imprve. Oversee and mnitr implementatin f the ESMP fr the Prject. Prvide strategic envirnmental and scial directin t the Prject. Supervisin Wrk with cntractrs t achieve envirnmental and scial perfrmance by undertaking the fllwing: cnduct readiness reviews with cntractrs t ensure their ESMS implementatin meets Prject requirements; wrk with cntractrs t imprve their ESMS where gaps are identified; cnduct training and awareness prgrammes with persnnel invlved in ESMP implementatin; ensure regular mnitring and evaluatin f the Prject s perfrmance against the ESMP; maintain recrds f all nn-cnfrmances and wrk with the relevant parties t reslve within reasnable time frames; assess the efficacy f the mitigatin measures and manage cntinuus imprvement arund these measures; cllate all required Prject envirnmental and scial reprts and ensure they meet Prject reprting requirements; prvide day-t-day advice and cunselling n all Prject envirnmental and scial requirements; wrk with cntractrs t clse ut grievances ldged by cmmunities within the defined timelines; maintain accurate recrds f pen and clsed grievances, and wrk with cntractrs twards reducing the number f grievances ldged by implementing apprpriate mitigatin measures; and assist with the develpment f relevant and timely cmmunicatins t Prject-impacted cmmunities by prviding infrmatin t the Stakehlder Engagement team n upcming Prject activities. Delivery/Implementatin Mnitr and reprt n any Prject activities that culd negatively impact n cmmunities. Facilitate nging, reciprcal infrmatin sharing and cmmunicatin between the Prject and impacted cmmunities; including helping t reslve any Prject-related issues raised. Supprt the Prject s grievance prcedure by prviding nging grievance prcedure guidance and training t Prject persnnel, cntractrs and impacted cmmunities and ther relevant stakehlder grups (eg turism industry stakehlders). Cnduct regular inspectins and nte nn-cnfrmances with the Prject s envirnmental and scial requirements.
17.3.3 Training, Educatin and Cmpetency The Prject assumes verarching respnsibility fr implementatin f the ESMP and, as such, it is imprtant that all cntractrs and persnnel respnsible fr the implementatin f the tasks and requirements cntained in the ESMP are cmpetent n the basis f educatin, training and experience. The Prject will undertake internal training and educatin activities t ensure that Prject expectatins regarding envirnmental and scial perfrmance are achieved. In additin, the Prject will prvide guidance t cntractrs regarding expectatins fr envirnmental and scial impact management training, educatin and cmpetencies. Envirnmental and scial cmpetencies will be apprpriate t the respective parties scpe f activity and level f respnsibility. Prject will undertake an initial evaluatin f training needs assciated with this ESMP and, n this basis, develp and maintain an ESMP training matrix. The Prject s envirnmental and scial training prgrammes will include several levels f cmpetency, depending n each individual s level f invlvement and respnsibility: ESMP Inductin Training and Awareness: this training will be fr visitrs r individuals wh d nt have direct rles r respnsibilities fr implementing the ESMP, and will cver basic Prject envirnmental and scial cmmitments. ESMP Management Training and Awareness: this training fcuses attentin n management, cvering key aspects f the ESMP and prviding an verview f the Prject s envirnmental and scial impact management expectatins and the supprting prcesses and prcedures prescribed in the ESMS t meet perfrmance expectatins. ESMP Jb-specific Training and Awareness: jb-specific training will be prvided t all persnnel wh have direct rles and respnsibilities fr implementing r managing cmpnents f the ESMP. This training will als include all peple whse specific wrk activities may have an envirnmental r scial impact. Onsite, these prvisins and respnsibilities will apply t all cntractrs and subcntractrs. Thse respnsible fr perfrming site inspectins will receive training by drawing n external resurces as necessary. Upn cmpletin f training and nce deemed cmpetent by management, staff will be ready t train ther peple. The Prject will require each cntractr t institute training prgrammes fr their persnnel. All cntractrs and their subcntractrs will be respnsible fr implementing relevant and adequate training prgrammes t maintain the required cmpetency levels. Cntractr training prgrammes will be subject t apprval by Prject Management and will be assessed t cnfirm that: training prgrammes are adequate; 17-7
all relevant persnnel have been trained; and cmpetency is achieved. Cntractrs will be required t reprt n their training activities, and the Prject will maintain recrds f all training delivered. 17.3.4 Assessment and Imprvement This sectin utlines the assessment and imprvement prcesses assciated with this ESMP: inspectin, mnitring, audit, crrective actin and imprvement. These activities frm an integral part f implementing the ESMP, and are necessary t: verify and dcument the management and implementatin f the mitigatin measures identified in the ESMP; mnitr and dcument the effectiveness f the mitigatin measures and assess the actual impacts; demnstrate cmpliance with applicable legal and ther requirements; evaluate the effectiveness f the ESMS; and highlight areas in need f imprvement t drive cntinuus imprvement fr all ESMP activities. Inspectin Cntractrs will be required t implement field-based inspectin prgrammes that demnstrate their implementatin f and, in sme instances, the effectiveness f the mitigatin measures. The Prject will, in turn, inspect the cntractrs dcuments t verify that they have implemented the required prgrammes. Mnitring Cntractrs will be required t implement field-based envirnmental mnitring (sampling and analysis) and scial mnitring t mnitr the effectiveness f the mitigatin measures, assess impacts and demnstrate cmpliance with legal and ther requirements. The Prject will cnduct similar mnitring events and als verify cntractrs mnitring activities. Auditing Audits will be carried ut internally by the Prject t ensure cmpliance with ESMP requirements, regulatry requirements and cmpliance with management systems, standards, plicies and prcedures. Peridic third party audits may als be required by the Prject r lender grups, as agreed t by the parties. Audits will be perfrmed by qualified staff, and results will be 17-8
described in a reprt that will determine the severity f nn-cmpliances, as well as the recmmended remedial actin. Crrective Actin and Imprvement As part f the ESMS, the Prject will implement a frmal envirnmental and scial tracking system that will include the details f all envirnmental and scial nn-cnfrmances, identify the crrective actins required, assign actins/timings t respnsible parties and indicate the status f the actins required. This will ensure a crdinated apprach between the Prject and its cntractrs, and drive changes fr cntinuus imprvement. 17.3.5 Grievance Management The Prject will develp and implement a Grievance Prcedure that is described in the Prject s Stakehlder Engagement Plan (SEP). The Grievance Prcedure describes hw cmmunity members can raise grievances regarding the Prject s activities. The Grievance Prcedure addresses verbal r written grievances, which must include sufficient infrmatin abut the cmplaint r claim s that a prper and infrmed evaluatin f the grievance can be made. When a grievance is filed, it will be lgged and evaluated using the prcess utlined in the SEP. All grievances will be tracked fr mnitring and reprting purpses and t ensure timely and prper reslutin. 17.3.6 Incident Management An incident is described as a specific event, sequence f events, r extended cnditin that has an unwanted r unintended impact n safety, security, health, livelihd, prperty, envirnment r regulatry cmpliance. The Prject will develp an incident management prcess that will describe the Prject s requirements fr managing safety, health, envirnment, scial and security-related incidents, including near-misses. The underpinning principles will be t: avid and reduce harm t cmmunities, persnnel, envirnment and assets; cnfirm prper remedial actin and perfrm apprpriate fllw-up surveillance t ensure injuries, damage r illnesses d nt escalate; cmmunicate incident details t internal and external stakehlders as apprpriate; and investigate all incidents t identify rt causes and implement crrective actins t prevent incident recurrence and drive cntinuus imprvement. The incident management system will invlve the fllwing, which may ccur cncurrently during implementatin: 17-9
17.3.7 Reprting securing the area; initiating emergency respnse prcedures if required; perfrming case management fr injuries r illness; incident classificatin, ntificatin and investigatin; implementing crrective actins; relevant reprting; and lessns learned. All incidents will be tracked in a Prject tracking system. This sectin utlines the reprting and ntificatin assciated with implementatin f the ESMP. The Prject and cntractrs will wrk clsely tgether t identify and agree all such Prject ntificatin and reprting requirements. It is envisaged that reprting will cver at least the fllwing areas: Cntractr Mnthly Reprting Cntractrs will wrk clsely with the Prject prir t the cmmencement f wrk t define the structure, cntent and frmat fr their envirnmental and scial mnthly reprt. This reprt will cntain key infrmatin arund the cntractrs implementatin f the envirnmental and scial requirements and mitigatin measures and will cver, amng thers: envirnmental and scial assessment and imprvement findings; incident ntificatins; nn-cnfrmances/nn-cmpliances and crrective actins; key perfrmance indicatrs; details f any envirnmental r scial surveys r studies; and envirnmental and scial training cnducted. Quarterly Reprting The Prject will prepare and submit t the relevant gvernment departments a Prject Envirnmental and Scial Quarterly Reprt. The structure, cntent and frmat will be agreed with gvernment prir t the cmmencement f wrk. This quarterly reprt will dcument key infrmatin n the Prject s perfrmance against the ESMP requirements. Incident Ntificatin and Reprting Cntractrs will ntify the Prject immediately fllwing any envirnmental r scial incident. Prject will ensure that all envirnmental and scial incidents are apprpriately dcumented, that the relevant parties are ntified, and that reprting requirements arund the incident are met. 17-10
Statutry Ntificatins and Reprting The Prject and cntractrs will meet all statutry ntificatin and reprting requirements. 17.3.8 Managing Changes Changes in the Prject may ccur due t unanticipated Prject develpments. This EIA, fr example, is being undertaken prir t the cmpletin f the FEED stage f the Prject. Wherever pssible, the envirnmental and scial mitigatin measures that have the ptential t impact design have been passed t the relevant FEED cntractrs during the EIA prcess. As the EIA prgressed, certainty regarding the nature and magnitude f impact surces became clearer t the Prject and the relevant changes were made t the EIA Reprt. Adaptive changes may als ccur during Prject cmmissining and peratins. The Prject will implement a frmal prcedure t manage changes that will apply t all Prject activities. The prcess fr dealing with Prject changes and uncertainty recgnises three levels f change/uncertainty: Level One: Minr Significance, where the change r uncertainty is largely deemed t be immaterial t the EIA findings, and des nt affect the Prject s ability t meet envirnmental and scial perfrmance requirements utlined in the ESMP. This change may require additinal but limited envirnmental r scial study r survey activities. Level Tw: Mderate Significance, where the change r uncertainty is deemed t be material t the EIA findings, but is within the bundaries f the defined Prject base-case cvered by the EIA. This may require minr changes t the ESMP and additinal surveys r envirnmental and scial assessments. Level Three: Higher Significance, where a future significant change r uncertainty leads t a departure frm the base-case, r a key aspect f it. An addendum t the EIA, r a new EIA and frmal submissin and apprval prcess, is then required. The abvementined prcess will ensure that the Prject is able t adapt t changes whilst meeting the relevant envirnmental and scial perfrmance requirements. 17.4 COMMUNICATION TO STAKEHOLDERS As nted during the EIA public meetings held in September 2013, the Prject is cmmitted t engaging with and reprting t all stakehlders. As part f the prject financing, an independent envirnmental and scial cnsultant is 17-11
anticipated t be hired by the prject lenders. Their auditing reprts will be shared with stakehlders in a transparent manner, as they becme available. 17-12