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
IZMIR FERRIES PROJECT Izmir, Turkey
UK14-18645 Issue: 2_ESAP_English ENVIRON
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
IZMIR FERRIES PROJECT Izmir, Turkey
UK14-18645 Issue: 2_ESAP_English ENVIRON
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
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
IZMIR FERRIES PROJECT Izmir, Turkey
UK14-18645 Issue: 2_ESAP_English ENVIRON
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
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
Construction Contractor
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
IZMIR FERRIES PROJECT Izmir, Turkey
UK14-18645 Issue: 2_ESAP_English ENVIRON
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
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
Construction Prior to tender documents
being issued
1 month prior to construction commencing
and continuous afterwards
Implementation of CESMP and
periodic updates as applicable.
Municipality to monitor to confirm
compliance
Use of internal personnel and external specialists.
EBRD
IZMIR FERRIES PROJECT Izmir, Turkey
UK14-18645 Issue: 2_ESAP_English ENVIRON
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
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.
EBRD PR1 and PR3, IFC PSs and GIIP
Municipality
Construction Contractor
Mgt cost
Construction Prior to tender documents
being issued
Before construction commences
Appointment of an Environmental
Officer/Manager. Municipality to
monitor to confirm compliance
The post could be fulfilled by either an internal appointment or external expert.
EBRD
IZMIR FERRIES PROJECT Izmir, Turkey
UK14-18645 Issue: 2_ESAP_English ENVIRON
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
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
Construction Contractor
and consultant
support
Indicative annual cost €40,000 to
€60,000
Construction Prior to tender documents
being issued
Within 2 weeks of construction commencing
and continuous afterwards
Commencement of monitoring
programme and revision for operation to
incorporate any permit
requirements. Municipality to
monitor to confirm compliance
EBRD
IZMIR FERRIES PROJECT Izmir, Turkey
UK14-18645 Issue: 2_ESAP_English ENVIRON
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
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
Indicative annual cost €10,000 to
€15,000
Construction ( repair and
maintenance yard, wharves and vessels)
Within 2 weeks of contracts commencing
and continuous afterwards
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
Construction contractor and
consultant support
€10,000 to
€30,000
Construction Prior to tender documents
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.
Municipality to monitor to confirm
compliance
To include project specific issues, the CEMP/ EMP and emergency spill response. Use of internal and/or external expert.
EBRD
IZMIR FERRIES PROJECT Izmir, Turkey
UK14-18645 Issue: 2_ESAP_English ENVIRON
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
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
Construction contractor and
consultant support
€10,000 to
€15,000
Construction Prior to tender documents
being issued
2 weeks prior to construction commencing
and continuous afterwards
Develop and implement WMP and update for
operation and as required.
Municipality to monitor to confirm
compliance
Use of internal and/or external specialists.
EBRD
IZMIR FERRIES PROJECT Izmir, Turkey
UK14-18645 Issue: 2_ESAP_English ENVIRON
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
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
Construction contractor and
consultant support
€15,000 to
€25,000
Construction Prior to tender documents
being issued
2 weeks prior to construction commencing
and continuous afterwards
Develop and implement ERP
and update whenever necessary.
Municipality to monitor to confirm
compliance
Use of internal and/or external specialists.
EBRD
IZMIR FERRIES PROJECT Izmir, Turkey
UK14-18645 Issue: 2_ESAP_English ENVIRON
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
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
Construction Contractor
and consultant
support
€10,000 to €15,000
Construction Prior to tender documents
being issued
1 month prior to construction commencing
and continuous afterwards
Develop and implement HMMP
and update as required.
Municipality to monitor to confirm
compliance
Use of internal and/or external specialists.
EBRD
IZMIR FERRIES PROJECT Izmir, Turkey
UK14-18645 Issue: 2_ESAP_English ENVIRON
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
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
Construction Contractor
and consultant
support
€5,000 to €10,000
Construction Prior to tender documents
being issued
1 month prior to construction commencing
and continuous afterwards
BCMS in place and implemented. Municipality to
monitor to confirm compliance
Use of internal and external specialists.
EBRD
IZMIR FERRIES PROJECT Izmir, Turkey
UK14-18645 Issue: 2_ESAP_English ENVIRON
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
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
Construction Prior to tender documents
being issued
1 month in advance of construction commencing
and continuous afterwards
Chance finds procedure.
Municipality to monitor to confirm
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
Construction Contractor Mgt cost
Construction Prior to tender documents
being issued
Before construction commences
Appointment of a qualified H&S
expert in accordance with
Turkish regulations. Municipality to
monitor to confirm compliance
Consider appointment of external H&S advisor in short term.
EBRD
IZMIR FERRIES PROJECT Izmir, Turkey
UK14-18645 Issue: 2_ESAP_English ENVIRON
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
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
Construction Contractor
€20,000 to
€40,000
Construction Prior to tender documents
being issued
1 month before construction commences
and continuous afterwards
Develop and implement HSMP and update the
plan as necessary. Municipality to
monitor to confirm compliance
Use of internal and/or external specialists.
EBRD
IZMIR FERRIES PROJECT Izmir, Turkey
UK14-18645 Issue: 2_ESAP_English ENVIRON
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
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
Construction contractor and
consultant support
Indicative
annual cost €30,000 to
€50,000
Construction Prior to tender documents
being issued
Within 1 month of construction commencing
and continuous afterwards
Commencement of monitoring
programme. Municipality to
monitor to confirm compliance
Use of internal and/or external specialists.
EBRD
IZMIR FERRIES PROJECT Izmir, Turkey
UK14-18645 Issue: 2_ESAP_English ENVIRON
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
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
Construction contractor and
consultant support
€5,000 to €15,000
Construction Prior to tender documents
being issued
Before construction commences
and continuous afterwards
Develop and implement RAs and SOPs and update
periodically as required.
Municipality to monitor to confirm
compliance
Use of internal personnel and external specialist. Implementation by the contractor should be: Before construction commences and continuous afterwards
EBRD
IZMIR FERRIES PROJECT Izmir, Turkey
UK14-18645 Issue: 2_ESAP_English ENVIRON
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
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
Construction Contractor
and consultant
support
€10,000 to €30,000
Construction Prior to tender documents
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.
Turkish legislation, EBRD PR2, IFC PS1-3 and GIIP
Municipality
Construction contractor Mgt cost
Construction Prior to tender documents
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
IZMIR FERRIES PROJECT Izmir, Turkey
UK14-18645 Issue: 2_ESAP_English ENVIRON
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
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.
Turkish legislation, EBRD PR2, IFC PS1-3 and GIIP
Municipality
Construction contracting
with specialist support
€10,000 to
€20,000
Construction Prior to tender documents
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
IZMIR FERRIES PROJECT Izmir, Turkey
UK14-18645 Issue: 2_ESAP_English ENVIRON
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
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
IZMIR FERRIES PROJECT Izmir, Turkey
UK14-18645 Issue: 2_ESAP_English ENVIRON
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
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
IZMIR FERRIES PROJECT Izmir, Turkey
UK14-18645 Issue: 2_ESAP_English ENVIRON
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
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 Contractor Mgt cost
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
IZMIR FERRIES PROJECT Izmir, Turkey
UK14-18645 Issue: 2_ESAP_English ENVIRON
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
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 Contractor Mgt cost
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
IZMIR FERRIES PROJECT Izmir, Turkey
UK14-18645 Issue: 2_ESAP_English ENVIRON
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 /
Resources / Investment
Applicable to Construction or Operation
Timetable for completion
Target and evaluation criteria
for successful implementation
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.
EBRD PR1 and PR3, IFC PSs and GIIP
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.
Use of internal personnel and external specialists.
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.
EBRD PR1 and PR3, IFC PSs and GIIP
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
IZMIR FERRIES PROJECT Izmir, Turkey
UK14-18645 Issue: 2_ESAP_English ENVIRON
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 /
Resources / Investment
Applicable to Construction or Operation
Timetable for completion
Target and evaluation criteria
for successful implementation
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
Izdeniz and consultant
support
(cost included within budget for Action 2)
Operation Q1 2014 Implementation of EMP and periodic updates as applicable
Use of internal and/or external specialists.
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
Izdeniz and consultant
support
€15,000 to €25,000
Operation Q3 2013 Develop and implement ERP and update whenever necessary
Use of internal and/or external specialists.
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
Izdeniz and consultant
support
€10,000 to €15,000
Operation Q4 2013 Develop and implement HMMP, including register and update as required.
Use of internal and/or external specialists.
EBRD
IZMIR FERRIES PROJECT Izmir, Turkey
UK14-18645 Issue: 2_ESAP_English ENVIRON
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 /
Resources / Investment
Applicable to Construction or Operation
Timetable for completion
Target and evaluation criteria
for successful implementation
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
Izdeniz and consultant
support
Indicative annual cost €20,000 to
€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
Izdeniz and consultant
support
Indicative annual cost €10,000 to
€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
Izdeniz and consultant
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
IZMIR FERRIES PROJECT Izmir, Turkey
UK14-18645 Issue: 2_ESAP_English ENVIRON
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 /
Resources / Investment
Applicable to Construction or Operation
Timetable for completion
Target and evaluation criteria
for successful implementation
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
Izdeniz and consultant
support
€3,000 to €7,000
Operation Q3 2013 Develop and implement WMP and update for operation and as required
Use of internal and/or external specialists.
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.
Izdeniz and consultant
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
IZMIR FERRIES PROJECT Izmir, Turkey
UK14-18645 Issue: 2_ESAP_English ENVIRON
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 /
Resources / Investment
Applicable to Construction or Operation
Timetable for completion
Target and evaluation criteria
for successful implementation
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.
Izdeniz and consultant
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.
Use of internal personnel and external specialists.
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
Izdeniz and consultant
support
Cost included in 11
Operation Q4 2013 Develop and implement HSMP
and update the plan as necessary
Use of internal and/or external specialists.
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
Izdeniz and consultant
support
Indicative annual cost €15,000 to
€30,000
Operation Q4 2013 Commencement of monitoring programme
Use of internal and/or external specialists. Should include
EBRD
IZMIR FERRIES PROJECT Izmir, Turkey
UK14-18645 Issue: 2_ESAP_English ENVIRON
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 /
Resources / Investment
Applicable to Construction or Operation
Timetable for completion
Target and evaluation criteria
for successful implementation
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
Izdeniz and consultant
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
Izdeniz and consultant
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
IZMIR FERRIES PROJECT Izmir, Turkey
UK14-18645 Issue: 2_ESAP_English ENVIRON
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 /
Resources / Investment
Applicable to Construction or Operation
Timetable for completion
Target and evaluation criteria
for successful implementation
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
IZMIR FERRIES PROJECT Izmir, Turkey
UK14-18645 Issue: 2_ESAP_English ENVIRON
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 /
Resources / Investment
Applicable to Construction or Operation
Timetable for completion
Target and evaluation criteria
for successful implementation
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.