Environmental & Social Due Diligence Environment and ......EBRD IZMIR FERRIES PROJECT Izmir, Turkey UK14-18645 Issue: 2_ESAP_English ENVIRON 1 Environmental & Social Action Plan Tables

Environmental & Social

Due Diligence Environment and Social Action

Plan

Izmir Ferries Project

Izmir Turkey

Prepared for: EBRD

1 Exchange Square, London, UK

Prepared by: ENVIRON UK Limited Box House, Bath, UK

Date: May 2013

Project or Issue Number: UK14-18645

Contract No: UK14-18645

Project Manager/Author(s): K. Howells / R. Eyrice (signature):

Project Director: Niall Smiddy

(signature):

Date: May 2013

This report has been prepared by ENVIRON with all reasonable skill, care and diligence, and taking account of the Services and the Terms agreed between ENVIRON and the Client. This report is confidential to the client, and ENVIRON accepts no responsibility whatsoever to third parties to whom this report, or any part thereof, is made known, unless formally agreed by ENVIRON beforehand. Any such party relies upon the report at their own risk.

ENVIRON disclaims any responsibility to the Client and others in respect of any matters outside the agreed scope of the Services.

Version Control Record

Issue Description of Status Date Reviewer Initials

Authors Initials

01 First Draft to Client – English ESAP

29-April-2013 KH / RE

02 Second draft to client – English ESAP

03-May-2013 KH

EBRD

UK14-18645 Issue: 2_ESAP_English

Contents

Page

1 Environmental & Social Action Plan i

EBRD

IZMIR FERRIES PROJECT Izmir, Turkey

UK14-18645 Issue: 2_ESAP_English ENVIRON

1 Environmental & Social Action Plan Tables 8.1 summarises the action required for identified environmental, health, safety and social issues to meet applicable legislative requirements, EBRD performance requirements, IFC Performance Standards and international good practice during Izmir Metropolitan Municipality’s involvement in the project construction activities.

Table 8.2 summarises the action required for identified environmental, health, safety and social issues to meet applicable legislative requirements, EBRD performance requirements, IFC Performance Standards and international good practice associated with Izdeniz A.S operations.

Note that the World Bank Group Environmental and Health and Safety guidelines are incorporated by reference into IFC Performance Standard 3.

EBRD



Table 8.1: Environmental & Social Action Plan – Municipality – Construction and Ferry Building

No. Action Environmental Risks / Liability / Benefits

Legislation Requirement / EBRD

Performance Requirement //IFC

Performance Standard/ Good

Practice

Responsible Party /

Resources / Investment

Applicable to Construction or Operation

Timetable for completion

Target and evaluation criteria

for successful implementation

Comments

Environmental Management 1 Conduct

Environmental Impact Assessment for repair and maintenance yard

Ensure compliance with national, EU and EBRD/IFC requirements regarding identification of significant environmental impacts associated with a new development. The EIA should incorporate an alternatives assessment and an assessment of cumulative impacts. The EIA should address noise, wastewater, dust/air emissions, solid waste, dredging, historical contamination, biodiversity, resource efficiency and any other identified potential environmental interactions. Additionally, to conform with international standards (EBRD & IFC) social impacts should be identified and stakeholder engagement and consultation should form part of the EIA.

Turkish and EU regulations. EBRD PR1& PR6, IFC PSs and GIIP

Municipality

€ 100,000

to 200,000

Construction Prior to first disbursement

EIA prepared in accordance with

national regulations and EBRD

Performance Requirements (PRs) and IFC Performance

Standards and accepted by the

Ministry of Environment and

the EBRD

2 Prepare Project Description Files for the floating wharf developments

Ensure compliance with national, EU and EBRD/IFC requirements regarding identification of significant environmental impacts associated with a new development. The project description files (PDF) should address noise, wastewater, dust/air emissions, solid waste, dredging, biodiversity, resource efficiency and any other identified potential environmental interactions. Additionally, to conform to international standards (EBRD & IFC) social impacts should be identified and stakeholder engagement and consultation should form part of the PDF.

Turkish legal requirements EBRD PR1&6, IFC PSs and GIIP

Municipality

€ 50,000 to

100,000

Construction Prior to first disbursement.

Project Description Files accepted by the Municipality and the EBRD

EBRD








Practice

Responsible Party /






Comments

3 Obtain construction permits

Ensure compliance with national, EU and EBRD/IFC requirements. No construction can proceed without a construction permit.

Turkish legislation, EBRD PR1, IFC PS1 and GIIP.

Municipality

€ 20,000 to

40,000

Construction Prior to first disbursement.

Construction Permit issued by the authorities.

4 Include in tender documents that Contractor must develop and implement an EH&S Management System Develop and implement an EH&S Management System

To improve EH&S management and risk control by providing a system(s) to drive continual improvement, identify and manage key EH&S aspects and impacts, manage contractors, monitor and review performance and ensure compliance with Turkish legislation, permits and international environmental requirements (e.g. MARPOL 73/78, ISPS code etc.). The EH&S management system will act as an umbrella framework co-ordinating all management plans mentioned within the ESAP.

EBRD PR1 and PR3, IFC PSs and GIIP

Municipality

Construction Contractor

and consultant

support

€40,000 to €60,000

Operation Prior to tender documents

being issued

Start of construction

and continuous afterwards

Develop an integrated

management system to comply

with ISO 14001 and OHSAS 18001 standards, or equivalent.

Annual EH&S Report to the Bank on ESAP progress.

Municipality to monitor to confirm

compliance

Use of internal personnel and external specialists.

EBRD








Practice

Responsible Party /






Comments

5 Include in tender documents that Contractor must prepare EH&S Policies Prepare EH&S Policies

To define the environmental and social objectives and principles for the project. This should be endorsed by senior management to show the Municipality’s commitment to sound environmental and social performance

EBRD PR1, IFC PSs and GIIP

Municipality


Mgt cost

Construction Prior to tender documents

being issued

Within 2 weeks of construction commencing

EH& S policies prepared and

endorsed by senior management. Municipality to

monitor to confirm compliance

Use of internal personnel and external specialists. Implementation by the contractor should be: Within 2 weeks of construction commencing

EBRD








Practice

Responsible Party /






Comments

6 Include in tender documents that Contractor must develop and implement a Construction Environmental & Social Management Plan (CESMP) Develop and implement a Construction Environmental & Social Management Plan (CESMP)

Ensuring compliance with national and international environmental & social guidelines (e.g. MARPOL 73/78) as well as EIA commitments, by formalising environmental & social management and risk control. The CESMP would co-ordinate / dovetail with other relevant management plans, including those of contractors. CESMP would address key aspects (air, water, hazardous materials, waste, noise etc.) and impacts, identify appropriate measures and monitoring plans and promote improved performance through monitoring and evaluation of the Municipality and contractors.

Turkish legislation, EBRD PR1 and PR3, IFC PSs and GIIP.

Municipality

Construction contractor and

consultant support

€10,000 to €20,000


being issued

1 month prior to construction commencing


Implementation of CESMP and

periodic updates as applicable.


compliance


EBRD








Practice

Responsible Party /






Comments

7 Include in tender documents that Contractor must appoint a qualified and trained Environmental Officer/ Manager Appoint a qualified and trained Environmental Officer/ Manager

To ensure compliance with Turkish legislation and international guidance and oversee development and implementation of the CESMP, management system and actions identified within this ESAP in relation to the repair and maintenance yard and the floating wharves.


Municipality


Mgt cost


being issued

Before construction commences

Appointment of an Environmental

Officer/Manager. Municipality to


The post could be fulfilled by either an internal appointment or external expert.

EBRD








Practice

Responsible Party /






Comments

8 Include in tender documents that Contractor must develop and implement an Environmental & Social Monitoring Programme Develop and implement an Environmental & Social Monitoring Programme

Initially to support the CESMP and ensure compliance with national standards as well as the reduction in environmental and social impacts. Based on the results of the monitoring (e.g. air, waste and water quality, noise, vibration, light / illumination and biodiversity).

Turkish legislation, EBRD PR1, PR3, PR4 and PR6, IFC PSs, GIIP and commitments


and consultant

support

Indicative annual cost €40,000 to

€60,000


being issued

Within 2 weeks of construction commencing


Commencement of monitoring

programme and revision for operation to

incorporate any permit

requirements. Municipality to


EBRD








Practice

Responsible Party /






Comments

9 Develop and implement a Contractor Monitoring Programme

To ensure compliance with Turkish regulatory and permitting requirements, including the monitoring of housekeeping and contractor permits and contractual requirements to reduce 3rd party risk exposure. Will also support the EH&S management system compliance requirements. The contractor management programme should include monitoring of shipyard Environment and Social performance during vessel building contracts

Turkish legislation, EBRD PR1 and PR3, IFC PSs, GIIP and commitments

Municipality


€15,000

Construction ( repair and

maintenance yard, wharves and vessels)

Within 2 weeks of contracts commencing


A formalised and documented audit /

monitoring programme

implemented.

Use of internal personnel.

10 Include in tender documents that Contractor must develop and implement an Environmental Training Programme Develop and implement an Environmental Training Programme

To ensure compliance with national and international environmental guidelines. The environmental training should be tailored to the audience, and include senior management to ensure they are aware of their responsibilities, BAT concepts and emergency response.

Turkish legislation, EBRD PR1, IFC PS1 and GIIP

Municipality


consultant support

€10,000 to

€30,000


being issued

Within 1 month of construction start date and

continuous afterwards

Develop and implement

Environmental Training Program for various grades

of staff and contractors.


compliance

To include project specific issues, the CEMP/ EMP and emergency spill response. Use of internal and/or external expert.

EBRD








Practice

Responsible Party /






Comments

11 Include in tender documents that Contractor must develop and implement a Solid and Liquid Waste Management Plan (WMP) Develop and implement a Solid and Liquid Waste Management Plan (WMP)

To ensure compliance with national and international environmental guidelines, including MARPOL 73/78, on minimisation, segregation, use of licensed contractors and disposal facilities, consideration of waste hierarchy. The WMP should include both non-hazardous and hazardous waste and co-ordinate with other management plans. Communication of the plan and changes should be to all parties.

Turkish legislation and international requirements, EBRD PR1 and PR3, IFC PS1 & PS3 and GIIP

Municipality


consultant support

€10,000 to

€15,000


being issued

2 weeks prior to construction commencing


Develop and implement WMP and update for

operation and as required.


compliance

Use of internal and/or external specialists.

EBRD








Practice

Responsible Party /






Comments

12 Include in tender documents that Contractor must develop and implement an Emergency Response Plan (ERP) for all foreseeable emergency situations Develop and implement an Emergency Response Plan (ERP) for all foreseeable emergency situations

To ensure co-ordinated and effective responses to emergencies, both man-made and natural including fires, spills, earthquakes etc., and compliance with national and international guidelines. As well as ensuring the safety of its employees and contractors, it will also safeguard the local community and include an Oil Spill Response Plan (OSRP).

Turkish legislation, EBRD PR1, PR 2, PR3 and PR4, IFC PSs 1-4, GIIP and EIA commitments

Municipality


consultant support

€15,000 to

€25,000


being issued

2 weeks prior to construction commencing


Develop and implement ERP

and update whenever necessary.


compliance


EBRD








Practice

Responsible Party /






Comments

13 Include in tender documents that Contractor must develop a Hazardous Materials Management Plan (HMMP) Develop a Hazardous Materials Management Plan (HMMP)

To ensure compliance with national and international environmental guidelines on the management of hazardous materials including their safe storage and handling, refuelling procedures and secondary containment. Co-ordinate with other management plans (i.e. CESMP, EMP and ERP) and be communicated to all parties.

Turkish legislation, international requirements, EBRD PR3, IFC PSs 1-4 and GIIP

Municipality


and consultant

support

€10,000 to €15,000


being issued



Develop and implement HMMP

and update as required.


compliance


EBRD








Practice

Responsible Party /






Comments

14 Include in tender documents that Contractor must develop and Implement Biodiversity Conservation & Monitoring Plan (BCMP) Develop and Implement Biodiversity Conservation & Monitoring Plan (BCMP)

To ensure compliance with national and international environmental guidelines and precautionary principles, and either confirm no discernible impact or minimise any impacts to biodiversity.

EBRD PR1, PR3, PR4 and PR6, IFC PS1, PS3 & PS6 and GIIP.

Municipality


and consultant

support

€5,000 to €10,000


being issued



BCMS in place and implemented. Municipality to


Use of internal and external specialists.

EBRD








Practice

Responsible Party /






Comments

15 Include in tender documents that Contractor must prepare a Chance Finds procedure Prepare a Chance Finds procedure

In order to comply with Turkish legal requirements identify the potential for culturally significant artefacts being found during construction. Prepare a chance finds procedure.

Turkish legislation, EBRD PR8, IFC PS1 and PS8 and GIIP

Municipality

Construction Contractor Mgt cost


being issued

1 month in advance of construction commencing


Chance finds procedure.


compliance.

Health & Safety and Employment Management 16 Include in

tender documents that Contractor must employ a H&S Officer Employ a H&S Officer

To ensure compliance with Turkish regulations on the employment of a qualified and certified H&S officer/expert, and oversee development and implementation of the HSMP and actions identified within this ESAP in relation to the repair and maintenance yard and wharf construction.

Turkish legislation, EBRD PR2, IFC PSs 1-3 and GIIP



being issued


Appointment of a qualified H&S

expert in accordance with

Turkish regulations. Municipality to


Consider appointment of external H&S advisor in short term.

EBRD








Practice

Responsible Party /






Comments

17 Include in tender documents that Contractor must develop and implement a Health & Safety Management Plan (HSMP) Develop and implement a Health & Safety Management Plan (HSMP)

To ensure compliance with Turkish regulations and international H&S guidelines. The HSMP will assist with the implementation of the EH&S management system and should be communicated to all parties. The HSMP will oversee the activities of the repair and maintenance yard and the new wharves and its contractors and will also consider community H&S requirements.

Turkish legislation, EBRD PR1, PR2 and PR4, IFC PS1-4, GIIP and commitments

Municipality


€20,000 to

€40,000


being issued

1 month before construction commences


Develop and implement HSMP and update the

plan as necessary. Municipality to



EBRD








Practice

Responsible Party /






Comments

18 Include in tender documents that Contractor must develop and implement a H&S Monitoring Programme Develop and implement a H&S Monitoring Programme

To ensure compliance with Turkish regulations and international H&S guidelines. Based on the results of the monitoring, relevant preventive and corrective actions and updates should be implemented. Aspects to be monitored include accidents, incidents, training needs, contractor inspections, chemical exposure, working conditions etc. during construction activities.

Turkish legislation, EBRD PR1, PR2 and PR4, IFC PS1-4 and GIIP

Municipality


consultant support

Indicative

annual cost €30,000 to

€50,000


being issued

Within 1 month of construction commencing


Commencement of monitoring

programme. Municipality to



EBRD








Practice

Responsible Party /






Comments

19 Include in tender documents that Contractor must develop risk assessments (RAs) and safe operating procedures (SOPs) Develop risk assessments (RAs) and safe operating procedures (SOPs)

To ensure compliance with Turkish legislation and international H&S guidelines. RAs should consider all physical, chemical and biological hazards associated with the construction operation activities and its contractors. Based on the findings appropriate preventive and protective measures and SOPs should be implemented and communicated to all parties.

Turkish legislation, EBRD PR2 and PR3, IFC PS1-4 and GIIP

Municipality


consultant support

€5,000 to €15,000


being issued



Develop and implement RAs and SOPs and update

periodically as required.


compliance

Use of internal personnel and external specialist. Implementation by the contractor should be: Before construction commences and continuous afterwards

EBRD








Practice

Responsible Party /






Comments

20 Include in tender documents that Contractor must develop and implement H&S Training Programme Develop and implement H&S Training Programme

To comply with Turkish legislation and GIIP, provide a safe work environment and prevent accidents or injuries from occurring. H&S training should cover job specific hazards, as well as use of PPE, site rules and compliance with SOPs. Other specific training should also be provided (e.g. fire fighting and spills) and at least 1 in every 10 workers should receive First Aid training as a matter of urgency to comply with Turkish legislation.

Turkish legislation, EBRD PR2, IFC PS1-3 and GIIP

Municipality


and consultant

support

€10,000 to €30,000


being issued

Within 1 month of construction start date and continuous afterwards

Develop and implement training program and update the program as necessary. Municipality to monitor to confirm compliance

Use of internal and/or external trainers. First Aid training should be a short term priority.

21 Include in tender documents that Contractor must establish a H&S Committee Establish a H&S Committee

To ensure compliance with Turkish regulations and GIIP. Establishment of a H&S Committee will improve worker relations, assist with the communication of H&S issues and raise its profile. A H&S committee is also required to comply with Turkish regulations, and should be at least monthly with worker representatives.


Municipality

Construction contractor Mgt cost


being issued

Within 2 weeks of construction

start date.

All necessary actions should be taken immediately by construction contractor. Municipality to monitor to confirm compliance

Use of internal resources.

EBRD








Practice

Responsible Party /






Comments

22 Include in tender documents that Contractor must develop and implement an equipment / machinery inspection and planned preventive maintenance (PPM) programme. Develop and implement an equipment / machinery inspection and planned preventive maintenance (PPM) programme.

To ensure compliance with Turkish regulations and international H&S guidelines. Will ensure that equipment is appropriately maintained and that the periodic inspections required under Turkish legislation (e.g. every 3 months by MEC certified engineers for cranes) are completed by construction contractor and its contractors.


Municipality

Construction contracting

with specialist support

€10,000 to

€20,000


being issued

Commencement of

Construction and continuous

afterwards

Develop and implement the program and ensure that periodic inspections are up to date to comply with regulatory requirements. Municipality to monitor to confirm compliance

Use of internal resources and external specialists.

EBRD








Practice

Responsible Party /






Comments

23 Include in tender documents for scrapping vessels the requirement to comply with IMO guidelines.

To ensure conformance to international marine standards vessels that are scrapped as a result of new vessels being introduced should be scrapped in compliance with IMO Guidelines for Safe and Environmentally Sound Recycling of Ships

International Standards, EBRD PR2 & PR3, IFC PSs 1-4 and GIIP.

Municipality/ Izdeniz

Cost no known

Operation Prior to tender documents

being issued

Tender documents referencing requirements regarding IMO Guidelines for Safe and Environmentally Sound recycling of Ships. Municipality to monitor to confirm compliance.

24 Require Izdeniz to implement the Ferry and Wharf Operation ESAP

To ensure that ferry, wharf and maintenance yard operations are conducted in accordance with legislation, international standards, EBRD Performance Requirements, IFC Performance Standards and GIIP. This will also reduce reputational risks and work towards increased efficiency of operation of Izdeniz with regard to Environment, Health & Safety and Social issues.

Turkish legislation, international standards, EBRD PRs, IFC PSs and GIIP

Municipality Operation May 2013 Implementation of all elements of the ESAP within the defined timetable. Municipality to monitor to confirm compliance.

Social Management

EBRD








Practice

Responsible Party /






Comments

25 Adopt and implement the Stakeholder Engagement Plan (SEP) developed by Environ

To complement, enhance and formalize ongoing stakeholder engagement and reporting of social and environmental issues. Improved relations with the community and stakeholders and decreased complaints.

EBRD PR1 & PR10, IFC PS1, PS4 & PS5 and GIIP.

Municipality with

consultant support

€10,000 to

€20,000

Construction Q3 2013 SEP in place and implemented. A suitable set of key performance indicators (KPI) will be used by the Municipality to monitor stakeholder engagement.

Includes establishing a SEP team to oversee charge of stakeholder engagement

26 Develop and implement elements of a Resettlement Action Plan (RAP) as required under EBRD PR5 (if required)

To ensure that compensation was reasonable during expropriation of land adjacent to the terminal and that the former owners are satisfied / livelihoods restored. Requirement applies where resettlement is necessary following confirmation of development locations and if any physical or economic displacement is necessary.

EBRD PR5 and IFC PS1 & PS5.

Municipality €5,000

Construction Within 3 months after

confirmation of location of repair and

maintenance yard

RAP in place and implemented

Use of external specialists

EBRD








Practice

Responsible Party /






Comments

27 Include in tender documents that Contractor must develop and maintain HR policies and communicate terms of appointment to employees Develop and maintain HR policies and communicate terms of appointment to employees

To ensure compliance with Turkish regulations and GIIP. Establishment of a HR policy will improve worker relations, assist with the communication of work related issues such as equal opportunities and non-discrimination; worker rights; hours of work; working conditions; and anti-harassment.

Turkish legislation, EBRD PR2, IFC PSs 1&2 and GIIP

Municipality


Construction Prior to bid documents

being issued.

Within 2 weeks of construction

start date

HR policies (endorsed by senior management) and procedures prepared and terms of appointment provided. Municipality to monitor to confirm compliance

Use of internal resources and external HR advisors.

EBRD








Practice

Responsible Party /






Comments

28 Include in tender documents that Contractor must develop and implement a security plan Develop and implement a security plan

Where security personnel are being appointed conduct an assessment potential risks to those within and outside the project site

EBRD PR4, IFC PS 1& 4 and GIIP.

Municipality


Construction Prior to bid documents

being issued

Prior to construction commencing

and continuous afterwards.

Security plan agreed by senior management. Municipality to monitor to confirm compliance

Apply the principles of proportionality to preparation of this plan.

EBRD



Table 8.2: Environmental & Social Action Plan –Izdeniz– Ferry and Wharf Operation

No. Action Environmental Risks / Liability / Benefits Legislation Requirement

/ EBRD Performance Requirement / Good

Practice

Responsible Party /






Comments

Environmental Management 1 Obtain

operating permit

To ensure compliant operations of the new repair and maintenance yard.

Turkish legal requirements. EBRD PR1, IFC PSs and GIIP

Municipality Izdeniz

€

Operation Prior to commencing operation of

the yard

Operating permit covering integrated

environmental impacts.

2 Develop and implement an Environmental Management System

To improve environment management and risk control by providing a system(s) to drive continual improvement, identify and manage key Environment aspects and impacts of both off shore and on shore activities, manage contractors, monitor and review performance and ensure compliance with Turkish legislation, permits and international environmental requirements (e.g. MARPOL 73/78). The Environment management system will act as an umbrella framework co-ordinating all management plans mentioned within the ESAP.


Izdeniz and consultant

support

€25,000 to €35,000

Operation Q1 2014 Develop an integrated

management system to comply with ISO 14001 standard, or

equivalent, and seek certification.


3 Appoint a qualified and trained Environmental Officer / Manager

To ensure compliance with Turkish legislation and international guidance and oversee development and implementation of the EMS, management system and actions identified within this ESAP in relation construction and future operation.


Izdeniz

Mgt cost

Operation Q2 2013 Appointment of an Environmental

Officer / Manager

The post could be fulfilled by either an internal appointment or external expert.

EBRD






Practice

Responsible Party /






Comments

4 Develop and implement an Environmental & Social Management Plan (ESMP)

Ensuring compliance with national and international environmental & social guidelines (e.g. MARPOL 73/78), by formalising environmental management and risk control. ESMP will assist with the implementation of the Environmental management system, co-ordinating with other relevant management plans (e.g. for air, waste, water, noise, traffic, biodiversity etc.) and specifying monitoring requirements.

Turkish legislation, EBRD PR1 and PR3, IFC PSs and GIIP


support

(cost included within budget for Action 2)

Operation Q1 2014 Implementation of EMP and periodic updates as applicable


5 Develop and implement an Emergency Response Plan (ERP) for all foreseeable emergency situations

To ensure co-ordinated and effective responses to emergencies for both on shore and off shore activities, both man-made and natural including fires, spills, earthquakes etc., and compliance with national and international guidelines. As well as ensuring the safety of its employees and contractors, it will also safeguard the local community and include an Oil Spill Response Plan (OSRP).

Turkish legislation, EBRD PR1, PR 2, PR3 and PR4, IFC PSs 1-4 and GIIP


support

€15,000 to €25,000

Operation Q3 2013 Develop and implement ERP and update whenever necessary


6 Develop and implement a Hazardous Materials Management Plan (HMMP)

To ensure compliance with national and international environmental guidelines on the management of hazardous materials both on shore and off shore including their safe storage and handling, refuelling procedures and secondary containment. Co-ordinate with other management plans (i.e. ESMP and ERP) and be communicated to all parties.

Turkish legislation, international requirements, EBRD PR3, IFC PSs 1-4 and GIIP


support

€10,000 to €15,000

Operation Q4 2013 Develop and implement HMMP, including register and update as required.


EBRD






Practice

Responsible Party /






Comments

7 Develop and implement an Environmental & Social Monitoring Programme

Initially to support the ESMP and ensure compliance with national standards as well as the reduction in environmental and social impacts. Based on the results of the monitoring (e.g. air, waste and water quality, noise, vibration, light / illumination and biodiversity), review management plans and develop improvement programmes.

Turkish legislation, EBRD PR1, PR3, PR4 and PR6, IFC PSs, GIIP and commitments


support


€40,000

Operation Q4 2013 Commencement of monitoring programme and revision for operation to incorporate any permit requirements.

8 Improve the Contractor Monitoring Programme

To ensure compliance with Turkish regulatory and permitting requirements, including the monitoring of housekeeping and contractor permits to reduce 3rd party risk exposure associated with both off shore and on shore activities. Records should be retained for all contractors. Will also support the EH&S management system compliance requirements and reduce risk of reputational issues associated with employed contractors.

Turkish legislation, EBRD PR1 and PR3, IFC PSs, GIIP and commitments


support


€15,000

Operation Q4 2013 A formalised and documented audit / monitoring programme implemented.

Use of internal personnel.

9 Improve, develop and implement an Environmental Training Programme

To ensure compliance with national and international environmental guidelines. The environmental training should be tailored to the audience, and include senior management to ensure they are aware of their responsibilities, BAT/IMO/MARPOL concepts and emergency response. The training should be applied to on shore activities.

Turkish legislation, EBRD PR1, IFC PS1 and GIIP


support

€10,000 to €30,000

Operation Q4 2013 Develop and implement Environmental Training Program for various grades of staff and contractors for on shore activities

To include project specific issues, the EMP and emergency spill response. Use of internal and/or external expert

EBRD






Practice

Responsible Party /






Comments

10 Develop a Solid and Liquid Waste Management Plan (WMP)

To ensure compliance with national and international environmental guidelines, including MARPOL 73/78, on minimisation, segregation, use of licensed contractors and disposal facilities, consideration of waste hierarchy, incorporating both off shore and on shore activities. The WMP should include both non-hazardous and hazardous waste and co-ordinate with other management plans. Communication of the plan and changes should be to all parties.

Turkish legislation and international requirements, EBRD PR1 and PR3, IFC PS1 & PS3 and GIIP


support

€3,000 to €7,000

Operation Q3 2013 Develop and implement WMP and update for operation and as required


11 Compliance with all IMO and MARPOL requirements as they relate to passenger and vehicle ferry operations.

To ensure compliance with international marine standards/laws and EBRD Performance requirements and IFC Performance Standards. IMO and MARPOL requirements for environment and health & safety for passenger and vehicle ferries should be implemented, including elements that have not entered into Turkish law.

Turkish legislation, international standards and EBRD PR1, PR2, PR3, PR4, PR6, IFC PSs and GIIP.

Izdeniz

€10,000 to €30,000

Operation Q3 2013 Procedures that demonstrate compliance e.g. Air quality procedure to meet MARPOL Annex VI: Air pollution.

12 Develop and Implement Biodiversity Conservation & Monitoring Plan (BCMP)

To ensure compliance with national and international environmental guidelines and precautionary principles, and either confirm no discernible impact or minimise any impacts to biodiversity.

EBRD PR1, PR3, PR4 and PR6, IFC PS1, PS3 & PS6 and GIIP.


support

€5,000 to €10,000

Operation Q4 2013 BCMS in place and implemented.

Use of internal and external specialists.

Health & Safety and Employment Management

EBRD






Practice

Responsible Party /






Comments

13 Improve on the ISM extend implementation of the Health and Safety Management System (HSMS)

To improve H&S management and risk control by providing a system(s) to drive continual improvement, identify and manage key health and safety risks associated with shore based activities in addition to the ISM system for ferries, manage contractors, monitor and review performance and ensure compliance with Turkish legislation, permits and international H&S requirements (e.g. MARPOL 73/78, SOLAS). The HSMS will act as an umbrella framework co-ordinating all management plans mentioned within the ESAP.

Turkish legislation and international requirements, EBRD PR1&2, IFC PSs1-2 and GIIP.


support

€20,000 to €40,000

Operation Q3 2013 Develop an integrated

management system to comply with OHSAS 18001 standards, or

equivalent, and seek certification.


14 Develop and implement a Health & Safety Management Plan (HSMP)

To ensure compliance with Turkish regulations and international H&S guidelines. The HSMP will assist with the implementation of the EH&S management system and should be communicated to all parties. The HSMP will oversee the activities of the ferry and wharf/terminal operations and its contractors and will also consider community H&S requirements.

Turkish legislation, EBRD PR1, PR2 and PR4, IFC PSs 1-4, GIIP and commitments


support

Cost included in 11

Operation Q4 2013 Develop and implement HSMP

and update the plan as necessary


15 Improve and extend implementation of the H&S Monitoring Programme

To ensure compliance with Turkish regulations and international H&S guidelines. Based on the results of the monitoring, relevant preventive and corrective actions and updates should be implemented. Aspects to be monitored and associated records to be retained include accidents, incidents, training needs, inspections, occupational exposure, chemical exposure, working conditions etc. operation of the wharves and repair and maintenance yard.

Turkish legislation, EBRD PR1, PR2 & PR4, IFC Pss1-4 and GIIP


support


€30,000

Operation Q4 2013 Commencement of monitoring programme

Use of internal and/or external specialists. Should include

EBRD






Practice

Responsible Party /






Comments

16 Develop risk assessments (RAs) and safe operating procedures (SOPs)

To ensure compliance with Turkish legislation and international H&S guidelines. RAs should consider all physical, chemical and biological hazards associated with the ferry and terminal operation activities and its contractors. This should include a flammables/explosive atmospheres assessment (ATEX). Based on the findings appropriate preventative and protective measures and SOPs should be implemented and communicated to all parties.

Turkish legislation, EBRD PR2 and PR3, IFC PSs1-4 and GIIP


support

€5,000 to €15,000

Operation Q3 2013 Develop and implement RAs and SOPs and update

periodically as required

Use of internal personnel and external specialist

17 Improve and extend implementation of H&S Training Programme

To comply with Turkish legislation, international standards and GIIP, provide a safe work environment and prevent accidents or injuries from occurring. H&S training should extend to cover all onshore and off shore job specific hazards, as well as use of PPE, site rules and compliance with SOPs. Other specific training should also be provided (e.g. fire fighting and spills) and at least 1 in every 10 workers should receive First Aid training as a matter of urgency to comply with Turkish legislation.

Turkish legislation, international standards, EBRD PR2, IFC PS1 & PS2 and GIIP


support

€10,000 to €30,000

Operation Q4 2013 Develop and implement training

program and update the program as

necessary

Use of internal and/or external trainers. First Aid training should be a short term priority.

18 Develop and implement an equipment / machinery inspection and planned preventive maintenance (PPM) programme.

To ensure compliance with Turkish regulations and international H&S guidelines. Will ensure that equipment is appropriately maintained and that the periodic inspections required under Turkish legislation (e.g. every 3 months by MEC certified engineers for cranes) are completed by Izdeniz and its contractors.

Turkish legislation, EBRD PR2, IFC PSs1-3 and GIIP

Izdeniz with specialist support

€10,000 to

€20,000

Operation Q1 2014 Develop and implement the

program and ensure that periodic

inspections are up to date to comply with

regulatory requirements

Use of internal resources and external specialists

EBRD






Practice

Responsible Party /






Comments

19 Obtain legal authorisations for the operation of each ferry as it becomes available.

Legal compliance to allow ferries to be operational. Delivery of all ferries (passenger and vehicle) should be accompanied by the appropriate licences from international and Turkish shipping authorities.

Turkish and international legal requirements. EBRD PR1and IFC PS1.

Izdeniz Operation First vessel delivery

Operating licences for each vessel.

Social Management 20 Adopt and

implement the Stakeholder Engagement Plan (SEP) developed by Environ

To complement, enhance and formalize ongoing stakeholder engagement and reporting of social and environmental issues. Improved relations with the community and stakeholders and decreased complaints.

EBRD PR1 and PR10, IFC PS1, PS4 & PS5 and GIIP.

Municipality with

consultant support

€10,000 to

€20,000

Operation Q3 2013 SEP in place and implemented. A suitable set of key performance indicators (KPI) will be used by the Municipality to monitor stakeholder engagement.

Includes establishing a SEP team to oversee charge of stakeholder engagement

21 Develop a gender diversity plan

Currently Izdeniz has a relatively low number of women within certain positions across the company despite having women in a larger number of upper management and board level positions. A plan could include the understanding of the needs and interests of working women, current recruitment procedures, current career development for women and the possibility of mobility in order to identify whether there is progressive and adequate recruitment and/or mobility of females across the company; provision of facilities for women within the ferry and terminal operations and ferry/terminal safety and security arrangements for women travellers.

Turkish legislation, international standards EBRD PR2, IFC PS1 & PS2 and GIIP.

Izdeniz with

consultant support

€5,000 to €10,000

Operation September 2013

Gender diversity plan in place. Increase proportion of women working across the company divisions.

EBRD






Practice

Responsible Party /






Comments

22 Develop and implement a formalized internal grievance mechanism.

A formal mechanism for workers to raise reasonable workplace concerns. This should involve an appropriate level of management and address concerns promptly, be transparent and provide feedback.

EBRD PR2 and IFC PS1 & PS2.

Izdeniz

Mgt cost

Operation Q2 2013 A documented internal grievance procedure describing the process in place.

Documents

Environmental & Social Due Diligence Environment and ......EBRD IZMIR FERRIES PROJECT Izmir, Turkey UK14-18645 Issue: 2_ESAP_English ENVIRON 1 Environmental & Social Action Plan Tables