Environmental and Social Management System  

Sustainability is a corporate-wide priority for GMTCB.  Two policies have been developed that address Environmental, Health and Safety (EHS) matters - the ?Quality and Environmental Policy? and the ?Health and Safety Policy?.  Both policies emphasize prevention, continuous improvement and training.  As indicated in ESAP Action Item Number (#)1, TCQ will be developing its own EHS policy, adapting the GMTCB policy to its business activities in Guatemala and based on the initial EHS policy framework provided in the EIA.  Regarding management systems, GMTCB has obtained third-party certification for some of its European terminals to the European Union?s Eco-Management and Audit Scheme (EMAS), which is a voluntary scheme designed for companies and other organizations to evaluate, manage, report and improve their environmental performance.  Specifically, GMTCB have adopted the ?Eco-Stevedoring? EMAS innovation, which is adapted to the stevedoring business.  TCQ will be developing its own integrated Environmental, Health, Safety and Social (EHS&S) Management System as indicated in ESAP Action Item #2 in time for port operations in alignment with the requirements of Performance Standard 1.  The company is also considering third-party certification to ISO 9001 for quality management, OSHAS 18001 for occupational health and safety (H&S) in the workplace and ISO 14001 for environmental management .  

Environmental and Social Assessment

The Ministry of Environmental Management and Natural Resources (MARN) approved the EIA (as developed by the Guatemalan consulting company, INAFSA, final document dated 26 July 2013) through Resolution Nr. 4179-2013 on 25 September 2013, updated with Resolution Nr. 932-2014 dated 7 March 2014.  The EIA includes relevant information on the environmental baseline, a project description, the impact assessment and a framework environmental management plan for both the construction and operations phases.  The approval stipulates several conditions such as inter alia that the company must utilize all appropriate signaling to reduce potential risks during construction and operation; clearance of materials and rubbish at the end of construction; presentation of a bathymetric study; and that appropriate procedures be followed upon project closure.  

The baseline studies, also carried out by the EIA consultant, were submitted under a separate document and included ambient noise, air quality and water quality in the port basin.  The locations of the sampling points for air quality and noise were selected considering site boundaries, wind speed and direction, topography and existing infrastructure.  The limits for ambient noise and the parameters and limits for air quality are based on those established in the World Bank Group?s Environmental, Health and Safety (EHS) General Guidelines.  Exceedences of the 70dBA nighttime noise limit for industrial areas were identified at the berth area of PQ?s existing container terminal, at the PQ?s terminal entrance and along the Pan-american highway.  There were no exceedences of air quality limits.  For water quality within the port basin, samples were compared against Guatemala limits as established by MARN; parameters include suspended solids, phosphorus, nitrogen and selected heavy metals, including lead, chromium VI and mercury.  One sample showed exceedences of suspended solids and all samples detected concentrations (although no exceedences) of lead.  As indicated below in the section on Performance Standard 3, the company will be constructing two wastewater treatment plants (WWTPs) for industrial and sanitary wastewater to ensure that discharges of its own effluents are within limits.  

As indicated in ESAP Action Item #3, the company will review and confirm that the construction of the terminal will have no adverse socio-economic impacts on local communities, including fishermen.  The review will cover aspects such as the potential for increased shipping and trucking traffic associated with terminal construction and operations, and any adverse social impacts this may have on local people, e.g. any incremental disruption to fishing activities or access to fishing grounds. 

Management Program

As indicated above, a framework for the E&S management plan for both the construction phase and the operation phase is included in the EIA; the components include mitigation and monitoring measures related to air, water (including impacts on marine environment from dredging activities), soil and sediments (including dredge materials), flora and fauna (mainly due to the removal of vegetation during ground clearance), and socio-economic (which encompasses the positive impact of employment creation).  As indicated in the EIA, the requirements stipulated in the framework for the E&S management plan apply to the company as well as its contractors and its subcontractors.  The construction contractor (Copisa) and its dredging (sub)contractor will develop a self-standing EHS Management Plan based on the E&S management framework in the EIA, as indicated in ESAP Action Item #4.  The EHS Management Plan will include environmental management as well as occupational H&S and will be specific to the work program at hand.  TCQ will review and approve both the EHS Management Plans by both contractors.  

During operations, TCQ will develop its own EHS Management Plan, including environmental management and occupational H&S, as indicated in ESAP Action Item #5 and based on the framework included in the EIA.  

As indicated in ESAP Action Item #6, the company will provide an overarching EHS training to all employees and contractors during construction and operations (on topics such as the EHS policy, emergency response plan, waste management, etc.).  Specialized training will also be provided to direct employees depending on the job description (e.g., working at height, in confined spaces, with hazardous materials).  As part of ESAP Action Item #6 the company will also ensure that the contractors are providing adequate training to ensure that all workers on site have the skills to perform their activities in a safe, healthy and environmentally responsible manner.

Organization

As the project is still in the very early stages of development, TCQ?s EHS&S Department is still to be developed.  As indicated in ESAP Action Item #7, the company will identify an EHS Manager with experience in the application of international standards to support terminal construction and operational activities.  TCQ will procure EHS support staff to ensure that contractors? EHS Management Plans are developed and implemented accordingly.  As indicated in the EIA, the construction contractor and the dredge contractor will also retain a full-time EHS coordinator to ensure development and implementation of the relevant EHS Management Plans.  TCQ will also, directly or through an external E&S consultant, conduct environmental monitoring and monitor the E&S performance of contractors during construction and dredging, including their implementation of commitments stipulated in the management plans.  

Monitoring and reporting
 
Monitoring requirements are included in the framework E&S management plan in the EIA as previously mentioned in this document in the sub-section on ?Management Program?.  During the constructions phase, the EHS Management Plan to be developed by the construction and dredging contractors as indicated in ESAP Action Item #4 will also include a component on environmental monitoring.

During operations, environmental monitoring commitments will be included in the TCQ?s EHS Management Plan.  The monitoring of air quality, noise, sanitary wastewater, industrial wastewater, stormwater, sediments and marine water in the port basin will be conducted by an external consultant.  Sampling points for noise, air quality and water quality in the port will remain the same as those identified in the baseline.  Given the existing water baseline in the marine environment (see ?Environmental and Social Assessment? sub-section in this document), the company will monitor sanitary and wastewater before and after treatment by wastewater treatment plants (and before effluents are discharged into the marine environment) with careful consideration of the parameters at or exceeding the Guatemala limits in the port basin waters.  Sampling frequencies will be quarterly for air quality, sanitary wastewater, industrial wastewater, stormwater and noise.

The company will submit quarterly monitoring reports to EPQ?s EHSS Department.  Periodic internal audits will also be performed by GMTCB on the functioning of the EHS&S Management System.  Reporting will also be submitted quarterly directly to TCQ?s Board of Directors and GMTCB?s Health, Safety, Quality and Environment Manager.   The Government of Guatemala may also conduct periodic inspections of the EHS conditions of the site, as indicated in the EIA approval.  

Emergency Preparedness and Response 

As indicated in ESAP Action Item #8, the construction and dredging contractors will have in place project-specific Contingency Plans, including spill prevention and control procedures.  

For the operations phase, a general contingency framework has been provided in the EIA.  As indicated in ESAP Action Item #9, TCQ will develop a detailed Contingency Plan, which will include an overview of risks and emergency scenarios, emergency preparedness and response procedures, spill prevention and control measures, roles and responsibilities, notifications and communications (including alarms, warning systems and back-up systems),  equipment and resources.  The Contingency Plan will also include a specific training program for employees and contractors.  The Contingency Plan will be developed in coordination with EPQ?s overall Emergency Preparedness and Response Plan and will include coordination with local authorities and awareness / notification to the community, as appropriate.  As indicated in the EIA, TCQ will also put in place an H&S Committee to comment and review on the Contingency Plan and other related occupational H&S topics, as necessary.