Page 1 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 1 *8<$1$\0368*$5\03&25325$7,21\03,1&\11\03 6.(/'21\0368*$5\0302'(51,6$7,21\03352-(&7\03\0b6603\0c\03 (19,5210(17$/\030$1$*(0(17\033/$1\03)25\037+(\036.(/'21\0368*$5\03 )$&725<\03$1'\03$662&,$7('\03&$1(),(/'\03(;3$16,21\11\03\03 1. PURPOSE AND SCOPE \03 This Environmental Management Plan (EMP) serves as the basic statement of policy and direction for the administration of the Skeldon Sugar Modernisation Project (SSMP) in relation to the reduction or avoidance of the negative environmental consequences identified in the Environmental Impact Assessment Report prepared by Ground Structures Engineering Consultants Ltd (Guyana) and approved by the Guyana Environmental Protection Agency (GEPA) in July 2003. As part of the project, GuySuCo has legal responsibility for the management of the Halcrow Conservancy (~6,000 ha) and GuySuCo Conservancy (mini-conservancy) (~1,500 ha). These conservancies comprise state-owned land under GuySuCo management. In the case of the Halcrow Conservancy, GuySuCo’s management responsibilities are outlined in a long-term agreement dated in November 2005 between GuySuCo and the National Drainage and Irrigation Board (NDIB) [Appendix 1]. \03 The Halcrow Conservancy was not considered a project element when the EIA commenced, and was therefore not included in the initial scope of the EIA. Both conservancies will serve mainly as water storage areas for sugar cane and other nearby cultivations, and will be managed by GuySuCo in a manner that will minimize changes to their natural characteristics. The EMP, will therefore encompass the expansion of the sugar cultivation; the new sugar factory, including the cogeneration facilities; and effective wildlife conservation for the Halcrow and GuySuCo Conservancies. Guysuco completed in 2006 a rapid biological assessment (RBA) to obtain baseline data on the animal and plant life of the two conservancies. The relevant management recommendations included in the assessment have been incorporated in this EMP. In addition, the RBA serves to increase awareness, within Guyana and internationally, of the biodiversity significance of these two conservancies. Furthermore, the EMP also encompasses the rehabilitation and expansion work to be carried out at the Manaribisi pasture, the alternate grazing location identified for the cattle farmers that used to graze their cattle in Block 2, one of the areas planted with sugar cane as part of the SSMP expansion. Guidance for the compilation of this EMP, was obtained from sections of the Environmental Impact Assessment Report pertinent to environmental management, and E1751 v3 Page 2 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 2 Environmental Permit (Reference No. 19990204 – GSEPO) issued to GuySuCo for the SSMP by the GEPA [Appendix 2]. The permit is valid for the period July 15, 2003 to May 31, 2008. Pertinent actions to renew this permit will be taken as necessary. In keeping with the permit, the Corporation has initiated plans to establish a sanitary landfill for waste generated during construction and operation of the project. Guysuco has completed a landfill site selection study in accordance with GEPA guidelines. In compliance with the permit, Guysuco has also finalized the baseline testing of pesticide residues in drainage water and has appointed a Project Environmental Officer. The EMP consists of five (5) components. The plan identifies mitigation measures and monitoring activities for specific aspects of ecosystem management. Mitigation measures currently exist at Skeldon and the remaining four estates at GuySuCo for a number of the environmental consequences identified. These would be extended to the project with enhancement for greater effectiveness where necessary, as they are all compliant with the environmental permit. The EMP also describes the roles and responsibilities of GuySuCo personnel, SSMP personnel and contractors. An organogram, monitoring protocols to assess EMP effectiveness and an implementation plan have also been incorporated into the plan. GuySuCo will execute the EMP in compliance with applicable laws and regulations governing safety, health and environmental protection. It is to be noted that the Corporation is currently at the planning stage of the development of an environmental management system (EMS) in conformance with ISO 14001requirements. The Skeldon project will be included in the requisite EMS activities. 2. MITIGATION MEASURES AND MONITORING ACTIVITIES FOR CONSTRUCTION, LAND PREPARATION AND OPERATION PHASES \03 D\11\0c\03&RQVWUXFWLRQ\03DQG\03/DQG\033UHSDUDWLRQ\03 Environmental Concern Aspect Mitigation Monitoring 1. Water Quality 1.1 Outflow Water 1.1.1 Sediment Inflows a.) Water from construction operations would be routed to temporary sediment ponds for a 48-hour detention period. 1. Monitoring of TSS levels 2. Monitoring of loading and release records. Page 3 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 3 b.) Water would be discharged via spillway and an additional sediment removal system consisting of a mixture of gravel, sand and grass, into the drainage system. 1. Monitor the effectiveness of the additional sediment removal system for maintenance and replacement. c.) The bases of stockpiles of dust-generating construction materials would be enclosed in wooden or other suitable support structures. 1. Monitor compliance with protocols. d.) Material would be stockpiled in a way to reduce slope failure. e.) Bush clearing debris would be kept away from watercourses. 1. Compliance Monitoring as per contract specifications. a.) There would be no contamination of canals by solid and liquid waste. 1. Monitor compliance with protocols. b.) There would be no washing of machinery in canals 1. Compliance Monitoring as per contract specifications. a.) Hazardous waste materials (fuel, grease, oil and paints) would be kept away from surface water. 1. Monitor compliance with protocols. 1.1.2 Canals 1.1.3 Hazardous Waste b.) These materials would be stored in bunded areas and/or on impervious surfaces away from watercourses. 2. Wildlife Management 11fi\03/DQG\03 DUDWLRQ\03\03 194.5 216.4 8.0 2.6 0 : \03 a.) Bush clearing of remaining blocks, and of the expanded Manaribisi pasture would proceed in a direction that would facilitate the exit of wild animals towards remaining areas of natural habitat. 1. Monitoring wildlife movement, and rendering assistance where appropriate to reduce injury. Page 4 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 4 b.) Wildlife movements would be facilitated by including the placement of temporary log bridges across canals to facilitate the exit of terrestrial wildlife, both in the new blocks and in the expanded Manaribisi pasture. Tree stands would 1. Maintenance of records of wildlife encounters. c.) also be maintained for this purpose. d.) No hunting, wildlife capture or fishing would be allowed by contractors and /or GuySuCo personnel and their employees. 1. Compliance monitoring as per contract specifications. e.) Machines used for bush clearing will be washed in a designated area away of the water bodies or at the state workshop before departing the estate compound in order to safeguard against the inadvertent introduction of alien weed species outside Guysuco’s landholdings 194.5 731.1 8.0 2.6 0 : \03 f.) Herbicide use (if any) during bush clearing in remaining blocks and in the expanded Manaribisi pasture would be done by GuySuCo personnel or under their supervision in accordance with GuySuCo Protocols 1. Monitoring for compliance with GuySuCo’s Agrochemical Policy (Appendix C), GuySuCo’s Integrated Pest Management System (Appendix D) and “”The Safe Use of Pesticides”” (GuySuCo, 1996). 3. Health and Safety 11fi\03 *HQHUDO\03\03 194.5 234.3 8.0 2.6 0 : \03 194.5 222.1 8.0 2.6 0 : \03 194.5 209.7 8.0 2.6 0 : \03 194.5 197.5 8.0 2.6 0 : \03 194.5 185.1 8.0 2.6 0 : \03 194.5 172.9 8.0 2.6 0 : \03 194.5 160.5 8.0 2.6 0 : \03 194.5 148.3 8.0 2.6 0 : \03 a.) The Contractor shall address health and safety issues in accordance with the Occupational Safety and Health Act 1997. Use of the Corporation’s protocols can also be made, as these are also compliant with the Act. 1. GuySuCo’s existing monitoring programme would be extended to construction activities where appropriate (Appendices 3 and B). Page 5 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 5 a.) Fugitive and wind-blown dust would be controlled by vehicular water sprinklers, to within a 100-200 m distance of the construction site. 1. Visual monitoring of fugitive and wind-blown dust to determine sprinkling frequency. 11ffl\03 'XVW\03\03 194.5 718.9 8.0 2.6 0 : \03 194.5 706.5 8.0 2.6 0 : \03 194.5 694.3 8.0 2.6 0 : \03 194.5 681.9 8.0 2.6 0 : \03 194.5 669.7 8.0 2.6 0 : \03 194.5 657.3 8.0 2.6 0 : \03 194.5 645.1 8.0 2.6 0 : \03 194.5 632.7 8.0 2.6 0 : \03 194.5 620.5 8.0 2.6 0 : \03 b.) Employees would be provided with eye protection such as goggles and eye-wash lotion 1. Monitor the wearing of eye protection and use of eye-wash lotion. 11ffi\03 1RLVH\03 194.5 577.6 8.0 2.6 0 : \03 194.5 565.4 8.0 2.6 0 : \03 194.5 553.0 8.0 2.6 0 : \03 194.5 540.8 8.0 2.6 0 : \03 194.5 528.4 8.0 2.6 0 : \03 194.5 516.2 8.0 2.6 0 : \03 194.5 504.0 8.0 2.6 0 : \03 194.5 491.6 8.0 2.6 0 : \03 194.5 479.4 8.0 2.6 0 : \03 194.5 467.0 8.0 2.6 0 : \03 194.5 454.8 8.0 2.6 0 : \03 194.5 442.4 8.0 2.6 0 : \03 194.5 430.2 8.0 2.6 0 : \03 194.5 417.9 8.0 2.6 0 : \03 194.5 405.6 8.0 2.6 0 : \03 194.5 393.3 8.0 2.6 0 : \03 a.) The following measures would be implemented to ensure that ambient noise remains below the World Bank industrial threshold of 70 db (A):- · Installation of sound proofing devices on equipment. · Use of equipment and machines that will not result in the violation of the World Bank Standard. · Provision of employees with hearing protection by contractors 1. Monitoring of ambient noise levels. a.) The contractor would provide portable toilet facilities for employees. 1. Monitor the removal of waste and supply of fresh treatment chemical. 11ff\036DQLWDWLRQ\03 b.) If portable systems are unavailable, pit latrines would have to be constructed and used with the approval of the regional health authorities. 1. Monitor for compliance with approved protocols. Page 6 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 6 1fi\035HIXVH\03 194.5 718.9 8.0 2.6 0 : \03 194.5 706.5 8.0 2.6 0 : \03 194.5 694.3 8.0 2.6 0 : \03 194.5 681.9 8.0 2.6 0 : \03 194.5 669.7 8.0 2.6 0 : \03 1ffl\033DSHU\03DQG\03 HU\03 a.) Refuse would be collected in garbage bins, then be disposed of in the Corporation’s existing land-fill site at Skeldon Estate or the new site when completed, designated by Skeldon estate management for construction and operation refuse. a.) Paper and Timber would be incinerated using procedures approved by the relevant regional authorities. 1. Monitor for compliance with GuySuCo’s protocols. 1. Monitor for compliance with protocols. 4. Waste Management 1ffi\032WKHU\03:DVWH\03 197.0 497.0 8.0 2.6 0 : \03 a.) Other construction waste materials must be sorted by type, stockpiled in designated areas, then disposed of in designated land-fill sites. Paper and timber would be similarly managed if incineration is not permissible. 1. Monitor for compliance with GuySuCo’s Standard Operational Procedures (SOP). e\11fi\036WRUDJH\03 194.5 428.7 8.0 2.6 0 : \03 194.5 416.4 8.0 2.6 0 : \03 194.5 404.1 8.0 2.6 0 : \03 a.) All hazardous materials would be protected from the elements during storage. e\11ffl\03$VEHVWRV\03 194.5 379.0 8.0 2.6 0 : \03 194.5 366.7 8.0 2.6 0 : \03 194.5 354.4 8.0 2.6 0 : \03 194.5 342.1 8.0 2.6 0 : \03 a.) Asbestos would be handled in accordance with the GuySuCo’s SOP. The new factory would have non- asbestos insulation. 1. Monitor for compliance with GuySuCo’s SOP. a.) Waste oil would be disposed of in accordance with the Corporation’s protocol. Contractors would therefore be obligated to purchase oils from GuySuCo’s suppliers. 1. Monitor for compliance with GuySuCo’s SOP. 5. Hazardous Material Management 194.5 328.2 8.0 2.6 0 : \03 e\11ffi\032LO\0f\03*UHDVH\03DQG\03 W\030DQDJHPHQW\03 194.5 291.3 8.0 2.6 0 : \03 194.5 279.0 8.0 2.6 0 : \03 194.5 266.7 8.0 2.6 0 : \03 194.5 254.4 8.0 2.6 0 : \03 194.5 242.1 8.0 2.6 0 : \03 194.5 229.8 8.0 2.6 0 : \03 194.5 217.5 8.0 2.6 0 : \03 194.5 205.3 8.0 2.6 0 : \03 194.5 192.9 8.0 2.6 0 : \03 a.) Grease and Paint would be disposed using methods approved by the EPA. 1. Compliance monitoring Page 7 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 7 e\11ff\033HVWLFLGHV\03 HUELFLGHV\0f\03 LWLFLGHV\03DQG\03 QWLFLGHV\0c\03 194.5 681.9 8.0 2.6 0 : \03 194.5 669.7 8.0 2.6 0 : \03 194.5 657.3 8.0 2.6 0 : \03 194.5 645.1 8.0 2.6 0 : \03 a.) Pesticides would be managed in accordance with GuySuCo’s Agrochemical Management Policy 1. Monitor for compliance with GuySuCo’s Agrochemical Policy (Appendix C) and GuySuCo’s Integrated Pest Management System (Appendix D). e\11ff\03%DJDVVH\03\03 194.5 620.0 8.0 2.6 0 : \03 194.5 607.6 8.0 2.6 0 : \03 03 a.) Bagasse would be stored in well ventilated logies supplied with appropriate fire fighting equipment in accordance with Corporate practice. 1. Compliance monitoring 6. Vehicle Maintenance 194.5 535.5 8.0 2.6 0 : \03 a.) Vehicle Maintenance would only be allowed in designated service areas or workshops. 1. Compliance monitoring 7. Cultural and Archeological Resources 194.5 485.9 8.0 2.6 0 : \03 a.) Sub-surface foundations, dumps, bottles, weapons, ceramic shards, stone axes, beads, human remains and burial sites would be reported by contractors to the Project Manager on duty. 03 1. Compliance monitoring b.) Operation Environmental Concern Aspect Mitigation Monitoring 1. Water Quality 1.1 Inflow Water 1.1.1GuySuCo Conservancy and Halcrow Conservancy a.) No aerial spraying within a 240 m wide vegetation buffer zone around the perimeter. 1. Acquisition of baseline data on pesticide residue levels. 2. Measurement of TSS, pH, DO, COD, N, P, and ECw. Levels 3. Review of SATLOC GPS database. 4. Development of and review of species check- list for aquatic plants and animals. Page 8 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 8 b.) Water would be pumped into the GuySuCo and Halcrow conservancies from the drainage canal when water levels are low. 1. Water level measurement. 2. Analysis of source water for TSS, pH, DO, COD, N, P, and ECw. 1.1.2 Factory Process Water 1.2 Outflow Water 1.2.1 Cultivation 1.2.2 Factory Discharges (including fly ash water and floor wash water) c.) Aquatic weeds would be managed by manual and/or mechanical removal or by the application of approved herbicides during periods of proliferation in accordance with GuySuCo’s Integrated Pest Management (IPM) Plan a.) No aerial spraying within a 240 m distance of the source canal b.) No aerial spraying within a 240 m distance of the source canal . a.) Weed-free drainage canals would be maintained by manual, mechanical or chemical or combined methods of removal of aquatic weeds. b.) Sediment inflows would be minimized by construction of revetments, and the planting of YHU\03 grass for erosion control. a.) Would be routed to the sugar factory’s new effluent treatment plant. 1. Monitor weed cover levels. 2. Liaise with the EPA and the Pesticide & Toxic Chemicals Control Board for updates on herbicide use status. 3. Monitor compliance to GuySuCo’s IPM Plan (Appendix D) 1. Measurement of TSS, pH, DO, COD, N, P, and ECw levels. 1. Monitor weed cover levels. 1. Acquisition of baseline data on pesticide residue levels. 2. Measurement of TSS, pH, DO, COD, N, P, and ECw. 1. Measurement of DO, COD, TSS, pH, ECw, N and P in treated and untreated discharge. 2. Sensitive 11fi 210.5 116.4 8.0 2.6 0 : \03 X&R\03 Page 9 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 9 Ecosystems HUYDQF\\03 03+DOFURZ\03 HUYDQF\\03 197.7 694.3 8.0 2.6 0 : \03 2.1.1 Flooding 197.7 669.7 8.0 2.6 0 : \03 197.7 657.3 8.0 2.6 0 : \03 197.7 645.1 8.0 2.6 0 : \03 197.7 632.7 8.0 2.6 0 : \03 197.7 620.5 8.0 2.6 0 : \03 197.7 608.2 8.0 2.6 0 : \03 197.7 595.9 8.0 2.6 0 : \03 197.7 583.6 8.0 2.6 0 : \03 197.7 571.3 8.0 2.6 0 : \03 197.7 559.0 8.0 2.6 0 : \03 197.7 546.7 8.0 2.6 0 : \03 2.1.2 Wildlife Management 2.1.3. Natural forest preservation 2.1.4. Cattle ranching 2.1.5. Fire control a.) These areas would not be flooded, drained nor cleared by GuySuCo as part of its operations. a.) Signs would be erected indicating that all hunting and wildlife capture are strictly prohibited, and that small- scale fishing would be allowed only by permit. b.) GuySuCo would enforce these prohibitions. a.) GuySuCo will not allow any logging nor other wood extraction from the Halcrow and GuySuCo conservancies a.) Cattle will not be allowed in the conservancies as cattle disturb the vegetation leading to a decrease in biodiversity a.) The grassland and forest should not be burned. A ban on setting fires in and around the conservancies will be strictly enforced. 1. Monitoring extraction and filling in accordance with approved water levels. 2. Review of species check-list for aquatic plants and animals, and monitoring of sightings. 1. Monitoring and controlling vehicular and pedestrian access in, out and within the project area via roads that traverse GuySuCo- managed roads. 1. Deployment of conservancy rangers to assist in the enforcement of the prohibitions. 1. There is presently neither logging nor other wood extraction. Conservancy rangers will enforce this policy. 1. Deployment of conservancy rangers to monitor the enforcement of this prohibition 1. Deployment of conservancy rangers to monitor the enforcement of this prohibition 3. Wildlife Management within the cultivation 197.7 152.8 8.0 2.6 0 : \03 a.) Erecting and maintenance of no hunting signs. 1. Monitoring access in, out and within the cultivation. Page 10 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 10 197.7 731.1 8.0 2.6 0 : \03 b.) Enforcement through various disciplinary actions. 2. Maintenance of records on hunting incidents. 4. Pasture management at Manaribisi 1.1. Land management a.) No plowing, b.) No deliberate seeding with non-native species c.) Little or no burning 1. Continuation of existing practices 5. Pest Management 197.7 603.0 8.0 2.6 0 : \03 a.) Weeds and insect pests would be managed in accordance with the Corporation’s Integrated Pest Management (IPM) System, which includes careful selection of compounds, and safe pesticides use and storage. b.) The use of thickeners would be investigated for aerial operations to increase the droplet size (and thereby reduce drift). 1. Monitor for compliance with the Corporation’s IPM System (Appendix D) and “”The Safe Use of Pesticides {GuySuCo, 1996) a.) A re-training policy would be developed. 1. Rigorous monitoring of personnel undergoing re-training. n\11fi\03/DERXU\03 03 197.7 381.2 8.0 2.6 0 : \03 197.7 368.8 8.0 2.6 0 : \03 197.7 356.6 8.0 2.6 0 : \03 197.7 344.2 8.0 2.6 0 : \03 b.) Recruitment of employees from the Skeldon Area 6. Socioeconomic Conditions n\11ffl\03&RPPXQLW\\03 VLRQ\03 197.7 278.6 8.0 2.6 0 : \03 6.2.1 Community Interests. 197.7 192.6 8.0 2.6 0 : \03 a.) GuySuCo estate management would establish a committee representing various interest groups to address community concerns. 1. Monitor feedback from the Company appointed liaison. Page 11 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 11 6.2.2 Population Growth 228.4 718.9 8.0 2.6 0 : \03 b.) GuySuCo will collaborate closely with the regional and other relevant authorities to ensure that there is conformance to regional development plans with respect to infrastructure and publice services. 1. Monitoring management of manpower needs for conformity to regional development plans. 7. Noise a.) The following measures would be implemented to ensure that the World Bank industrial area ambient noise standard of 70 db (A) is not exceeded:- · Installation of sound- proofing devices on equipment. · Acquisition of equipment that will not cause the standard to be violated. · Provision of hearing protection. 1. Monitoring of ambient noise levels. 2. Medical screening of employees working in noisy environments for hearing impairment. a.) Fugitive and wind-blown dust emissions would be controlled vehicular water sprinklers operating within a 100-200 m distance of the factory, estate workshops administrative buildings and estate entrance. 1. Visual monitoring of fugitive and windblown dust to determine frequency of sprinkling. ccent\11fi\03)XJLWLYH\03DQG\03 \10EORZQ\03'XVW\03 197.7 421.1 8.0 2.6 0 : \03 197.7 408.8 8.0 2.6 0 : \03 197.7 396.6 8.0 2.6 0 : \03 197.7 384.2 8.0 2.6 0 : \03 197.7 372.0 8.0 2.6 0 : \03 197.7 359.6 8.0 2.6 0 : \03 197.7 347.4 8.0 2.6 0 : \03 197.7 335.0 8.0 2.6 0 : \03 197.7 322.8 8.0 2.6 0 : \03 197.7 310.4 8.0 2.6 0 : \03 197.7 298.2 8.0 2.6 0 : \03 197.7 285.9 8.0 2.6 0 : \03 197.7 273.6 8.0 2.6 0 : \03 197.7 261.3 8.0 2.6 0 : \03 197.7 249.0 8.0 2.6 0 : \03 197.7 236.7 8.0 2.6 0 : \03 197.7 224.4 8.0 2.6 0 : \03 197.7 212.1 8.0 2.6 0 : \03 b.) Provision of employees with eye protection such as goggles and eye-wash lotion or eye-wash stations. 1. Monitor the wearing of eye protection and use of eye-wash lotions or eye-wash stations. 1. Medical surveillance of employees at risk for respiratory, dermal and eye irritation caused by dust. 8. Air Quality 197.7 195.7 8.0 2.6 0 : \03 ccent\11ffl\03&DQH\03%XUQLQJ\03 UH\10KDUYHVW\03 LQJ\0c\03 197.7 146.5 8.0 2.6 0 : \03 197.7 134.3 8.0 2.6 0 : \03 197.7 121.9 8.0 2.6 0 : \03 197.7 109.6 8.0 2.6 0 : \03 a.) Burning would be conducted taking cognizance of wind direction, time of day and location of proximal communities. 1. Monitoring of the activity and continual review of data on wind direction, time of day and the location of proximal communities. Page 12 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 12 197.7 731.1 8.0 2.6 0 : \03 ccent\11ffi\03)DFWRU\\03 GLQJ\0bV\0c\03 197.7 694.3 8.0 2.6 0 : \03 197.7 681.9 8.0 2.6 0 : \03 197.7 669.7 8.0 2.6 0 : \03 a.) Ambient Particulate Matter levels would be maintained below the World Bank standard of 20 mg/Nm 3 by using electrostatic precipitators and by means of a more efficient combustion.. 1. Monitoring ambient particulate matter levels. a.) Chemical Scrubbers would be used to reduce stack emissions to levels below the World Bank standards for NOx, CO 2 and particulate matter. 1. Monitor operation efficiency and stack emissions 197.7 644.6 8.0 2.6 0 : \03 ccent\11ff\036WDFN\03(PLVVLRQV\03 b.) Boiler Ash and Fly Ash would be recovered from the scrubbers and for possible use as road stabilizing materials. 1. Monitor for compliance with protocols. 9. Health and Safety arumlaut\11fi\03*HQHUDO\03 197.7 491.0 8.0 2.6 0 : \03 197.7 478.8 8.0 2.6 0 : \03 197.7 466.4 8.0 2.6 0 : \03 197.7 454.2 8.0 2.6 0 : \03 197.7 441.8 8.0 2.6 0 : \03 197.7 429.6 8.0 2.6 0 : \03 9.1.1Non- hazardous Waste Management 9.1.2 Hazardous Material Management a.) The Company’s existing Health and Safety Policy would be extended to the Project Area. a.) Refuse and office waste would be disposed of in designated non-engineered land-fill sites within the confines of the estate in accordance with the Company’s current waste Management Policy. b.) Fertiliser Bags and Filter Press mud would be re-cycled in accordance with the existing protocols. c.) Sewage would be treated in septic tanks as is done currently. 287.0 208.3 8.0 2.6 0 : \03 287.0 196.0 8.0 2.6 0 : \03 a.) Wherever possible, hazardous materials would be stored in secure facilities on- site on constructed on impervious surfaces to minimize contamination of surface and ground water 1. The Company’s existing monitoring programme would be extended to the Project Area. 1. Monitor for compliance with associated protocols. 1. Monitor for compliance with protocols. 1. Facilities would be inspected on a regular basis, and a maintenance programme would be adopted to ensure the integrity of the impervious surfaces. Page 13 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 13 9.1.2.1 Asbestos 9.1.2.2 Agrochemical Waste 9.1.2.3. Fuel Oil Management 9.1.2.4. Spill Contingency Plan arumlaut\11ffl\11\03+HUELFLGH\03 \LQJ\03 pollution. a.) Asbestos would be handled in accordance with the Company’s SOP. Replacement of asbestos insulation materials would be done suitable non-asbestos material. a.) Agrochemical Waste would be managed in accordance with GuySuCo’s Agrochemical Management Policy. a.) Fuel oils would be stored, and waste oils disposed off in accordance with the Company’s existing protocols. b.) Oil water separators would be used to trap surface run-off in the vicinity of the workshops. Trapped water would be skimmed prior to discharge. a.) GuySuCo will establish a spill contingency plan for fuel oil. a.) Guysuco will follow the communications strategy included in the Pest Management Plan in order to prevent accidental poisonings of field workers or other people 1. Handling would be monitored as per the SOP. 2. Adherence to the SOP would also be monitored. 1. Monitor for compliance with associated protocols. 2. Monitoring of agrochemical waste for pH, DO, COD, ECw, N and P. 1. Monitor for compliance with associated protocols. 1. Monitor for compliance to plan. 1. Monitor for compliance to strategy (in Appendix C) 10. Water Related Health Hazards \11fi\033RWDEOH\03:DWHU\03 The source of potable water would be the existing well and treated raw surface water. 1. Monitor well water and treated raw water for total coliform bacteria content. Page 14 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 14 Page 15 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 15 3. Personnel and Contractor Roles and Responsibilities \03 a.) GuysuCo and Project Personnel fi\11\03 0DQDJHU\03²\03&HQWUDO\03$QDO\WLFDO\03DQG\03(QYLURQPHQWDO\030RQLWRULQJ\036HUYLFHV\03\0b&$(06\0c\03DQG\03WKH\03 &RPSDQ\\03+HDOWK\03DQG\036DIHW\\032IILFHU\11\03 The Manager-CAEMS and the Company Health and Safety Officer will report to the Project Development Committee, Loan Agencies, and the Regulatory Authorities as stipulated in loan agreements and operating permits with respect to Project EMP activities. a.) Role To implement the Environmental Management Plan (EMP) in collaboration with Estate Agriculture, Factory, Human Resource and Finance personnel, personnel assigned to the Project from the Corporation’s Skeldon Sugar Modernisation [Expansion] Project (SSMP) Department, Project Environmental Officer and the Project Health and Safety Officer. b.) Responsibilities 1. Co-ordinate the EMP during Project implementation. 2. Oversee the development of procedures and guidelines to facilitate implementation of the EMP. 3. Monitor the implementation and operation of the EMP. 4. Review, analyse and interpret data and records emanating from monitoring activities to assess the effectiveness of the monitoring processes and that of the over all EMP, for continual improvement. 5. Incorporate the aspects of the EMP in the EMS currently being developed in conformity with the ISO 14001 Standard to facilitate certification across the industry. 6. The Manager-CAEMS will also be responsible for physico-chemical monitoring of inflow and outflow water quality and air quality. ffl\11\03 3URMHFW\03(QYLURQPHQWDO\032IILFHU\03 An Environmental Officer would be employed specifically for assignment to the Project during the implementation phase. His/her contract would be terminated when the Project becomes fully operational. The Project Environmental Officer would report to the Manager – CAEMS through the Project Director. Page 16 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 16 a.) Role To implement the Environmental Management Plan (EMP) in collaboration with Estate Agriculture, Factory, Human Resource and Finance personnel, personnel assigned to the Project from the SSMP Department, Manager – CAEMS and the Company Health and Safety Officer. b.) Responsibilities 1. Sensitise employees to the importance of and need for an EMP. 2. Develop procedures and guidelines to facilitate implementation of the EMP. 3. Assist in the monitoring of the implementation and operation of the EMP. 4. Assist in the review, analysis and interpretation of data and records emanating from monitoring activities to assess their effectiveness and that of the over all EMP, for continual improvement 5. Assist in the development of emergency preparedness and response procedures where appropriate, and coordinate these when necessary. 6. Ensure adherence to associated monitoring protocols and programmes. 7. Maintain a repository of material safety data sheets. 8. Coordination of hazardous material management. 9. Liaise closely with the Project Health and Safety Officer with respect to areas of overlapping concern in the EMP. 10. Contribute to training and capacity building in the area of Environmental Management at Skeldon Estate and possibly the other estates. ffi\11\03 3URMHFW\03+HDOWK\03DQG\036DIHW\\032IILFHU\03 A Health and Safety Officer would be employed specifically for assignment to the Project during the implementation phase. His/her contract would be terminated when the expansion area becomes fully operational. The Project Health and Safety Officer would report to the Company Health and Safety Officer through the Project Director. a.) Role To implement all aspects of the Environmental Management Plan (EMP) pertaining to Health and Safety, in collaboration with Estate Agriculture, Factory, Human Resource and Finance personnel, and personnel assigned to the Project from the SSMP Department. b.) Responsibilities Page 17 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 17 1. Develop procedures and guidelines to facilitate implementation Health and Safety aspects of the EMP. 2. Monitor the implementation and operation of the Health and Safety aspects of the EMP. 3. Ensure adherence to associated monitoring protocols and programmes. 4. Assist in the review, analysis and interpretation of data emanating from monitoring activities to assess their effectiveness and that of the overall EMP, for continual improvement. 5. Assist in the development of emergency preparedness and response procedures where appropriate. 6. Liaise closely with the Project Environmental Officer with respect to areas of overlapping concern in the EMP. 6. Contribute to training and capacity building in the area of Environmental Management at Skeldon Estate and possibly the other estates. ff\11\03 (VWDWH\03+HDOWK\03DQG\036DIHW\\032IILFHU\0f\03(VWDWH\03$JURQRPLVW\03DQG\03(VWDWH\03)DFWRU\\033URGXFWLRQ\03 0DQDJHU\03 The scope of responsibility of the Estate Health and Safety, Project Health and Safety Officer and Company Health and Safety Officer would be extended to include the Project area following the departure of the Project Environmental, and Health and Safety Officers. They will be responsible for ensuring that the EMP requirements are met and maintained, and for reporting on environmental performance to top management. They will also be responsible for addressing other environmental concerns that may arise out of the operations of the expanded estate through the EMP. breve\11\03 3URMHFW\03&LYLO\03(QJLQHHU\03 A Civil Engineer currently employed in the SSMP Department would report to the Manager – CAEMS through the Projects Director. a.) Role To ensure that EMP activities requiring the civil engineering expertise are carried out in a satisfactory manner. This will be done in collaboration with the Contractors, Estate Agriculture, and Factory personnel, personnel assigned to the Project from the SSMP Department and Project Environmental and Health & Safety Officers. b.) Responsibilities Page 18 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 18 1. To review and provide oversight to, the design, construction and use of civil engineering controls and devices required for mitigation purposes. 2. Assist in the review, analysis and interpretation of data emanating from monitoring activities to assess the effectiveness of the monitoring processes and the overall EMP, for continual improvement. 3. Contribute to training and capacity building in the civil engineering component of Environmental Management at Skeldon Estate and possibly the other estates. caron\11\03 (VWDWH\033HUVRQQHO\030DQDJHU\03DQG\03)LQDQFH\030DQDJHU\03 The Estate Personnel Manager and the Finance Manager Department would report to the Manager – CAEMS through the Project Director. a.) Role To ensure that EMP activities pertaining socio-economic concerns are carried out in a satisfactory manner. This will be done in collaboration with the Contractors, Estate Agriculture, and Factory personnel, personnel assigned to the Project from the Corporation Projects Department and Project Environmental and Health & Safety Officers. b.) Responsibilities 1. To ensure that there is an effective re-training and recruitment policy to meet the demand for new skills. 2. To establish a stakeholder committee to address socio-economic concerns relating to community cohesion. 3. Contribute to training and capacity building in the socio-economic component of Environmental Management at Skeldon Estate and possibly the other estates. \1a\11\03 $JULFXOWXUH\030DQJHU\03 \03 a.) Role To oversee the adherence to existing environmental management protocols and EMP activities pertaining to land preparation, crop cultivation and management, conservancy management. This would be done in collaboration with the Contractors, other Estate Agriculture personnel and the Project Environmental and Health & Safety Officers. \03 \03 Page 19 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 19 dotaccent\11\03 (VWDWH\03$JURQRPLVW\03 a.) Role To ensure that the existing monitoring programmes for inflow and outflow water with respect to agriculture operations are extended to the Project. This will be done in collaboration with the Project Environmental and Health & Safety Officers. b.) Responsibilities 1. To ensure that existing protocols are adhered to and that adjustments are made as stipulated in the EMP as advised by the Manager-CAEMS. 2. To maintain records of analytical data. hungarumlaut\11\03 (VWDWH\03)DFWRU\\030DQDJHU\03 \03 a.) Role To ensure that the existing environmental management protocols and EMP activities pertinent to sugar-cane processing are adhered to. This will be done in collaboration with the Project Environmental and Health & safety Officers. \03 \03 fifl\11\03(VWDWH\033URGXFWLRQ\03\0bLQ\03IDFWRU\\0c\030DQDJHU\03\03 a.) Role To ensure that the existing monitoring programmes for outflow water with respect to agriculture and factory operations and factory process water are extended to the Project. This will be done in collaboration with the Project Environmental and Health & Safety Officers. b.) Responsibilities 1. To ensure that existing protocols are adhered to and that adjustments are made as stipulated in the EMP as advised by the Manager-CAEMS. 2. To in collaboration with the Manager- CAEMS and the Project Environmental and Health & Safety Officers develop protocols for monitoring ambient air quality in the factory building(s) 3. To maintain records of analytical data. fifi\11\03&RQVHUYDQF\\030DQDJHU\03 \03 Page 20 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 20 a.) Role To ensure that the existing environmental management protocols are extended to the GuysuCo and Halcrow conservancies, and that pertinent EMP activities are adhered to. This will be done in collaboration with the Estate Agronomist and the Project Environmental Officer. \03 \03 fiffl\11\03&RQVHUYDQF\\035DQJHUV\03 \03 a.) Role To ensure that wildlife in the GuySuCo and Halcrow conservancies, is effectively conserved and that there is no logging or other habitat degradation within the conservancies. This will be done in collaboration with the Project Environmental Officer and the Conservancy Manager. b.) Responsibilities 1. To enforce the restrictions stipulated in the EMP aimed at conserving wildlife and natural habitats within the conservancies (consistent with their water supply functions). 2. To be engaged in wildlife monitoring to enhance conservation management. 3. To maintain conservation management records. \03 \03 fiffi\11\030DQDJHU\03²\03$LUFUDIW\03'HSDUWPHQW\03 a.) Role To ensure that existing protocols pertaining to aerial application of agrochemicals are adhered to and that adjustments are made as stipulated in the EMP as advised by the Manager-CAEMS. This will be done in collaboration with the Project Environmental and Health & Safety Officers. fiff\11\03(VWDWH\030HGLFDO\032IILFHU\03 a.) Role To ensure that the existing medical surveillance programmes for workers deployed in high risk areas as stipulated in the EMP are extended to the Project. This will be done in collaboration with the Project Environmental and Health & Safety Officers. Page 21 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 21 b.) Responsibilities 1. To ensure that existing protocols are adhered to and that adjustments are made as stipulated in the EMP as advised by the Manager-CAEMS. 2. To maintain medical surveillance records. 3. To advise on the suitability of employees to jobs following review of medical conditions and/or medical history. b.) Contractor The Contractor would report to the Project Environmental Officer and the Project Health and Safety Officer a.) Role To ensure that the construction and land preparation activities are conducted in accordance with the EMP as stipulated in the contractual agreement. He/she will also adhere to any existing environmental management protocols where appropriate as stipulated in the contractual agreement. This will be done in collaboration with Senior SSMP Department personnel initially, then with the Project Environmental and Health & Safety Officers. b.) Responsibilities 1. To duly designate an Environmental and a Health & Safety liaison to assist with the implementation of the EMP and to ensure that the relevant existing protocols are adhered to as advised by the Manager- CAEMS. 2. To maintain manifests of materials disposed. 3. To provide a list of hazardous materials along with material safety data sheets (MSDSs) to be used in construction activity, one (1) month prior to use. Page 22 G u y S u C o I n c E n v i r o n m e n t a l M a n a g e m e n t P l a n f o r t h e S k e l d o n S u g a r M o d e r n i s a t i o n P r o j e c t ( S S M P ) ; V e r s i o n : 3 R e v i s i o n S t a t u s : 0 P r e p a r e d b y F . H o m e r ; X X D e c e m b e r , 2 0 0 7 2 2 4 . O R G A N O G R A M F O R T H E E N V I R O N M E N T A L M A N A G E M E N T P L A N * D i r e c t o r s ( P r o j e c t s , A g r i c u l t u r e a n d T e c h n i c a l ) a n d E s t a t e G e n e r a l M a n a g e r F . H o m e r , H . D a v i s , J u l y 2 5 , 2 0 0 5 C : \ W o r k \ S W R I I E M P O r g a n o g r a m . . d o c P r o j e c t D e v e l o p m e n t C o m m i t t e e – A g r i c u l t u r e a n d F a c t o r y * M a n a g e r – C e n t r a l A n a l y t i c a l & E n v i r o n m e n t a l M o n i t o r i n g S e r v i c e s ( C A E M S ) a n d C o m p a n y H e a l t h a n d S a f e t y O f f i c e r P r o j e c t C i v i l E n g i n e e r P r o j e c t E n v i r o n m e n t a l O f f i c e r P r o j e c t H e a l t h a n d S a f e t y O f f i c e r E s t a t e A g r i c u l t u r e M a n a g e r a n d E s t a t e A g r o n o m i s t E s t a t e F a c t o r y M a n a g e r a n d P r o d u c t i o n M a n a g e r E s t a t e P e r s o n n e l M a n a g e r E s t a t e F i n a n c e M a n a g e r M a n a g e r A i r c r a f t D e p t . C o n s e r v a n c y M a n a g e r C o n s e r v a n c y R a n g e r s Page 23 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 23 breve\11\03021,725,1*\0335272&2/6\03\03 D\0c\03 &RQVWUXFWLRQ\03 The time scheduling and frequency of monitoring activities during the construction phase of the Project cannot be determined at this point in time due to the unavailability of the following information: 1. Exact time of construction commencement (only tentative times are available) 2. The frequency, intensity and extent of the activities that will require monitoring. E\0c\03 2SHUDWLRQ\03 The Corporation will use existing protocols for physico-chemical testing during the operational phase. Testing would therefore be conducted as follows:- 1. Agriculture 1.1 Inflow Water Thrice yearly; once during the First Crop (February to April); Out-of-Crop season (May to July) and Second Crop season (August to December.) 1.2 Outflow Water As per 1.1 for the cultivation, and once a month for the agro-chemical tailings pond. 2. Factory 2.1 Process Water At least four times a year; twice during the First and Second Crop Seasons. F\0c\032WKHU\037HVWLQJ\033URWRFROV\03 Testing protocols for the effluent treatment plant, the potable water treatment plant, the electrostatic precipitator, the scrubber and the new agrochemical waste treatment plant cannot be determined at this point in time as those systems have not yet been installed and there has therefore been no opportunity to observe their operation and the degree of mitigation. G\0c\03%LRGLYHUVLW\\03PRQLWRULQJ\03LQ\03WKH\03+DOFURZ\03DQG\03*X\VXFR\03&RQVHUYDQFLHV\03 Guysuco will make the area of the conservancies available to scientists (i.e. from universities and/or NGOs) for biological monitoring on an DG\03KRF\03 basis and will facilitate, upon request and availability, housing and transportation to the scientists. Research and biodiversity monitoring activities by these scientists should follow as closely as feasible the guidelines initially established by EMC (Environmental Management Consultants) in its Rapid Biological Assessment report from January 2006. \03 \03 Page 24 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 24 \03 H\0c\03&RPSOLDQFH\03ZLWK\03(QYLURQPHQWDO\033HUPLW\031R\11fihungarumlauthungarumlauthungarumlautflfflflff\10*6(32\03 Guysuco will ensure compliance with Environmental Permit No.19990204 dated July 15, 2003, observing all the terms and conditions specified therein, including those that may not have been explicitly addressed in this EMP. In addition, Guysuco will specifically ensure that the effluent treatment plant and the landfill comply both with the (a) Environmental Permit and with (b) applicable World Bank environmental standards. Finally Guysuco will take the appropriate actions to renew Environmental Permit No.19990204-GSEPO permit as needed. caron\11,03/(0(17$7,21\033/$1\03\03 fi\11\03 7LPH\036FKHGXOLQJ\03 The Environmental Management Plan (EMP) would be implemented at the commencement of the construction phase of the Project. Full use would be made of existing environmental protocols, programmes, systems and recording systems where appropriate. ffl\11\03 6WUXFWXUH\03DQG\035HVSRQVLELOLW\\03 2.1 The Corporation will employ a Project Environmental Officer and a Project Health and Safety Officer. The services of these persons would be terminated when the project is operational. Their responsibilities would be shared by the Estate Health and Safety Officer, the Estate Agronomist and the Estate Factory Production Manager, all of whom are part of the existing estate management structure. 2.2 The Project Officers (2.1) will work in collaboration with the Project Department Committees for Agriculture and Factory and other management representatives as indicated in the accompanying EMP document RE: Personnel and Contractor Roles and Responsibilities. ffi\11\03 7UDLQLQJ\03DQG\03$ZDUHQHVV\03 3.1 The Corporation will ensure that the Project Environmental and Health and Safety Officers contribute to the training of the Estate Health and Safety Officer, the Estate Agronomist and the Estate Factory Production Manager. This will be augmented by participation in any relevant training sessions or short duration courses held within or outside of Guyana. This additional training would be extended to the EMP Co-ordinators. 3.2 GuySuCo will establish and maintain procedures to make employees serving various functions at various levels, and contractors aware of:- a.) The Environmental Policy and the commitment to the development of an Environmental Management System (EMS) for field and factory operations in accordance with the ISO 14001 standard b.) The importance of the EMP to EMS development. Page 25 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 25 c.) EMP requirements. d.) The roles and responsibilities for achieving conformance with the EMP. e.) Potential consequences of deviation from specified operating procedures. ff\11\03 &RPPXQLFDWLRQ\03 GuySuCo will establish and maintain procedures for the following:- a.) Internal communication between various functions and levels b.) Receiving documenting and responding to external party interests breve\11\03 'RFXPHQWDWLRQ\03 5.1 The Corporation shall maintain information relating to key elements of the EMP in hard copy and electronic format. 5.2 A documentation control system would be established and maintained to ensure that documentation is prepared in a standardized manner, stored and retrieved for use and review. caron\11\03 (PHUJHQF\\033UHSDUHGQHVV\03DQG\035HVSRQVH\03 The Corporation will identify activities with a high potential for accident and emergency situations, and develop emergency preparedness and response procedures for such activities where none exist currently. \1a\11\03 0RQLWRULQJ\03 GuySuco will establish and maintain documented procedures for monitoring activites. These will include performance tracking, measurement and use of equipment. dotaccent\11\03 $XGLWLQJ\03 The Corporation will establish and maintain programme and procedures for auditing the EMP to ascertain whether or not the EMP has been conformed to and has been properly implemented and maintained. hungarumlaut\11\03 5HFRUGV\03 The Corporation will establish and maintain procedures for identification and maintenance of EMP records. Page 26 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 26 \1a\11\03(19,5210(17$/\030$1$*(0(17\033/$1\03%8'*(7\03 \03 *8<$1$\0368*$5\03&25325$7,21\03,1&\11 6.(/'21\0368*$5\0302'(51,6$7,21\03352-(&7\03\0b6603\0c\03 $118$/\03%8'*(7\03)25\03(19,5210(17$/\030$1$*(0(17\033/$1\03\03 &DWHJRU\\03 ,WHPV\03 8QLW\03 8QLW\03 FRVW\03 \0b86'\0c\03 4W\\03 7RWDO\03&RVW\03 \0b86'\0c\03 Irrigation and Drainage Canals 1 round 33 3 99 Factory Inlet and Effluent Streams 1 round 29 3 87 Halcrow Conservancy 1 round 20 3 60 GuySuCo Conservancy 1 round 13 3 39 :DWHU\034XDOLW\\03 0RQLWRULQJ\03\03\10\03 LQRUJDQLF\03 FRQVWLWXHQWV\0f\03S+\0f\03(&\0f\03 766\0f\03'2\03DQG\03&2'\03 Effluent from Factory Effluent Treatment System 1 round 5 12 60 :DWHU\034XDOLW\\03 0RQLWRULQJ\03²\03 KHUELFLGH\03UHVLGXH\03 DQDO\VLV\1e\03RYHUVHDV\11\03\03 Irrigation and Drainage Canals and Conservancies 1 round 15,000 1 15,000 \03\03 7RWDO \03 \03 \03 fibreve\0fffiffbreve \03 $XGLWLQJ\03RI\03FRPSDQ\\03 JXLGHOLQHV\03DQG\03 SURFHGXUHV\03UHODWLQJ\03WR\03 WKH\03VDIH\03XVH\03RI\03 SHVWLFLGHV\03E\\03WKH\03 &RUSRUDWH\03 $JURFKHPLFDO\036DIHW\\03 &RPPLWWHH\03 Conveyance of committee members (7 )by aircraft (20 % of the charge) return trip 89 1 289 (QYLURQPHQWDO\03 0DQDJHPHQW\033ODQ\03 ,PSOHPHQWDWLRQ\11\03\03 Employment of an Environmental Officer 1 1,193 12 14,316 7RWDO \03 \03 \03 fiff\0fcaronflbreve \03 924 11,089 0DQDJHPHQW\03RI\03WKH\03 +DOFURZ\03DQG\03*X\6X&R\03 &RQVHUYDQFLHV\03 Superintendent 1 Subtotal 12 fifi\0ffldotaccenthungarumlaut \03 Page 27 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 27 Security (10 Watchmen/Rangers) mandays 6 3,120 18,346 Subtotal fidotaccent\0fffiffcaron \03 Other Employment Costs - NIS 1 person 143 10 1,430 - Pension 1 person 238 10 2,384 - Medical scheme 1 person 15 10 148 - Xmas Bonus 1 person 71 10 705 - Night-shift Premium hr 0 2,240 366 - Protective Wear 1 person 23 10 228 Subtotal breve\0ffflcaronfi \03 Waterway Cleaning and Dam Maintenance Trench Cleaner - Labour (1 operator + 2 labourers) - Fuel (diesel) mandays 12 75 872 - Lube Oil (20 % of fuel cost) - Repairs and Spares drum 1 140 5 698 drum 140 1 140 Dragline 1,784 - Labour ( 1 operator + 1 mate) Subtotal ffi\0fffhungarumlautffi \03 - Fuel (diesel) \03 \03 - Lube Oil (20 % of fuel cost) mandays 12 84 1,026 - Repairs and Spares drum 140 4 559 Manual Weeding of Canals and Dams drum 140 1 112 - Labour 1,784 Subtotal ffi\0fffdotaccentfl \03 \03 \03 Transportation of Fuel and Equipment mandays 6 53 311 Subtotal ffififi \03 trip 51 10 510 Page 28 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 28 Boat \03 \03 Outboard Engine Subtotal brevefifl \03 Boat Crew \03 \03 Motor Oil ea 184 1 184 Fuel (Gasolene) ea 3,077 1 3,077 Repairs to Boat and Engine mandays 6 70 412 drum 244 1 122 drum 178 5 890 510 Subtotal breve\0ffihungarumlautff \03 \03 \03 7RWDO \03 \03 \03 ff\1a\0fcarondotaccentbreve \03 *UDQG\03 7RWDO \03 \03 \03 \1a\1a\0fcaronffibreve \03 1. – 45 gallon 3UHSDUHG\03E\\03)\11\03+RPHU\1e\03fflflfl\1a\10fifi\10flffl \03 Page 29 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 29 $33(1',&(6 Page 30 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 30 \03 $33(1',;\03fi\03 1',%\10*8<68&2\03+$/&52:\03&216(59$1&<\03$*5((0(17\03 \03 \03 \03 \03 \03 \03 \03 \03 \03 \03 Page 31 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 31 AGREEMENT between the National Drainage and Irrigation Board and the Guyana Sugar Corporation Inc. For the Construction and Management of the Halcrow Conservancy in Region 6 THIS AGREEMENT is entered into this day…2 nd November .2005 between the National Drainage and Irrigation Board, a department of the Ministry of Agriculture in the Government of Guyana formed under the Drainage and Irrigation Act Chapter 64:03 of 1941 and having its office at the Ministry of Agriculture, Regent and Vlissengen Roads, Georgetown (hereinafter called NDIB) and the Guyana Sugar Corporation Inc, a company incorporated under the Companies Act Chapter 89:01 and continued under Act 29 of 1991 having its registered office at Ogle Estate, East Coast Demerara (hereinafter called GUYSUCO). WHEREAS NDIB is desirous of appointing GUYSUCO to act as Conservancy Manager to construct and manage the Halcrow Conservancy in Region 6 for the mutual benefit of irrigation farmers within the Skeldon, Crabwood Creek, Jackson Creek and Moleson Creek locality under the provisions set down in this Agreement. NOW THIS AGREEMENT WITNESSETH AS FOLLOWS: DEFINITIONS AND INTERPRETATION DEFINITIONS 1. The following words and expressions shall have the meanings assigned to them except where the context otherwise requires: a) “Halcrow Conservancy” means the body of water formed after the construction of dams for the Skeldon expansion in Block 10 and the eastern dam running parallel to the link canal, all generally as described in the feasibility report by Sir William Halcrow and Partners in association with C A Liburd & Associates and entitled Crabwood Creek Water Control Rehabilitation Project, January 1985. b) “Link Canal” means the main navigation and irrigation canal extending from the Skeldon Block 10 navigation canal to the Mocane feeder canal, a distance of some eight kilometres. c) “Mocane” means the Moleson Creek Cane Farmers Inc. d) “Conservancy Manager” means the organisation appointed by NDIB to design, construct, operate and maintain the Halcrow Conservancy, which under the terms of this Agreement is GUYSUCO. The Conservancy Manager shall be a member of the Conservancy Committee. e) “Conservancy Committee” means the Committee formed from stakeholders and water users to administer the Halcrow Page 32 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 32 Conservancy in accordance with a constitution approved by NDIB. Committee members undertake their duties voluntarily without remuneration. f) “Committee Chairman” means the person appointed by NDIB to engage stakeholders and water users to form the Conservancy Committee and to undertake the Chairman’s responsibilities as defined in the constitution. g) “Primary Irrigation System” means a major water storage and distribution facility falling under the statutory authority of the NDIB. The Halcrow Conservancy and Link Canal, including offtake gates, is classified a Primary Irrigation System. h) “Secondary Irrigation System” means the irrigation canal networks located on leasehold or freehold land downstream of the primary irrigation system offtake gates. The responsibility for operation and maintenance of secondary irrigation systems resides with the relevant owner, or lessee, or legitimate occupier or water association representing a group of owners, lessees or occupiers. i) “Water User” means a navigation/irrigation water user within Skeldon, Crabwood Creek, Jackson Creek and Moleson Creek registered with the Conservancy Committee to receive water from the Halcrow Conservancy or Link Canal. The water allocation shall be calculated by the Committee based on the water user’s crop area, irrigation water requirement and seasonal water resources available in the Halcrow Conservancy. j) “Water Rate” means the annual fee payable by a registered Water User to the NDIB to cover the annual operation and maintenance cost of the Halcrow Conservancy and Link Canal. The rate shall be based on crop type and crop area and expressed in Guyana Dollars per hectare per year. INTERPRETATIONS 2. Interpretations under this Agreement are as follows: a) The headings and marginal notes in the Agreement shall not be used in its interpretation. b) The singular includes the plural, the masculine includes the feminine, and vice-versa where the context requires. c) If there is a conflict between provisions of the Agreement, the last to be written chronologically shall prevail. OBLIGATIONS OF GUYSUCO DUTY OF CARE 3. GUYSUCO shall exercise reasonable skill, care and diligence in the performance of its obligations under the Agreement. CONSTRUCTION OF HALCROW CONSERVANCY 4. GUYSUCO shall undertake and finance all necessary works required for the construction of the Halcrow Conservancy which shall include, but not be limited to, the following: a) Topographical surveys of the conservancy dam alignment. b) Geotechnical investigations to determine foundation requirement of Page 33 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 33 major hydraulic structures. c) Design and working drawings for the conservancy dam, offtake gates and spillways. The conservancy dam design shall follow the Halcrow 1985 report except where it has to be modified to suit water user’s requirements changes in topography and land tenure. The dam crest shall be retained as 63.0 feet Georgetown Datum (19.20 m GD) and the dam length shall be 14.3 kilometres approximately. Offtake gates shall be designed such that the discharge rate can be controlled and also can be measured using a water level gauge. d) Bid and contract documentation for earthworks and concrete works construction. e) Supervision of contractors engaged on earthworks and concrete works construction for the conservancy dam. FINANCE OF LINK CANAL NOT INCLUDED 5. GUYSUCO agrees to finance construction of the Halcrow Conservancy dam and hydraulic structures but the finance of the Link Canal is the responsibility of NDIB and will be included in the scope of the Guyana Drainage and Irrigation Systems Rehabilitation Project within the Agriculture Support Services Programme. MANAGEMENT OF HALCROW CONSERVANCY AND LINK CANAL 6. GUYSUCO agrees to undertake the role of Conservancy Manager providing the services defined hereunder and as may be later modified by the constitution of the Conservancy Committee or the decisions of the Conservancy Committee. a) To assign a senior manager within GUYSUCO the responsibility, authority and operating budget for managing the Halcrow Conservancy and Link Canal. This person is to represent the Conservancy Manager on the Conservancy Committee. b) To ensure that registered water users receive the water allocations requested, provided they fall within the maximum allocation defined by the Conservancy Committee for various climatic conditions. c) To ensure the upkeep, operations, maintenance and safety of the Halcrow Conservancy and Link Canal to the best of GUYSUCO’s abilities and resources. d) To provide personnel and their means of transport for monitoring and operating water control gates on a daily basis. e) To provide personnel and their means of transport for the routine inspection of the conservancy dam wall and hydraulic structures. f) To provide personnel, transport, plant and materials to undertake necessary maintenance tasks on the conservancy dam, link canal and hydraulic structures. g) To establish, monitor and maintain a water level gauge and rain gauge at the conservancy dam near to Block 10 pump station. The water level and rain gauges to be read on a daily basis. h) To maintain records of operating and maintenance costs and present Page 34 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 34 these on a monthly basis to the Conservancy Committee. i) To maintain records of discharges through offtake structures and present these on a monthly basis to the Conservancy Committee. j) To calculate a water balance of inflows and outflows on a monthly and annual basis using data collected on rainfall, evaporation, conservancy water levels and offtake discharges. k) To calculate and present to the Conservancy Committee an annual operating and maintenance budget covering the period January to December. The budget is to be submitted to the Conservancy Committee by the first day of October in the year preceding the budget year. CONSTITUTION OF THE CONSERVANCY COMMITTEE 7. GUYSUCO agrees to draft a Constitution for the Conservancy Committee subject to the following conditions: a) The Constitution is to be vetted and approved in writing by NDIB prior to formation and first sitting of the Conservancy Committee. b) The Constitution is to follow a similar model to the Conservancy Acts for East Demerara Conservancy, Boerasirie Conservancy and the MMA scheme but modified to suit the particular circumstances of the Halcrow Conservancy and to reflect modern operation and maintenance practices. c) The Constitution is to contain, but not be limited to, the following clause headings: i) The Chairman of the Conservancy Committee can only be appointed by NDIB. ii) The role, duties and responsibilities of the Conservancy Manager and the Conservancy Committee are to be defined. iii) The Committee is to appoint a Secretary to take minutes of meetings, maintain records and receive/send correspondence. iv) The Conservancy Manager is to act as Treasurer and maintain a record of operation and maintenance expenditure. v) Committee members do not receive remuneration or expenses. vi) The Committee is to maintain a register of water users and entitlement to water allocation. vii) The Committee is to establish operating rules for the Halcrow Conservancy and Link Canal to suit different climatic conditions. viii) The Committee is to promote “best practice” water management e.g. drainage recycling amongst water users to safeguard and prolong water resources. ix) The Committee is to set annual water rates to cover normal operation and maintenance expenditure and to advise these rates to NDIB for collection from registered water users. Page 35 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 35 OBLIGATIONS OF NDIB DECISIONS 8. On all matters properly referred to NDIB in writing by GUYSUCO, NDIB shall give a decision in writing within a reasonable time so as not to delay the obligations of GUYSUCO. APPROVAL OF CONSTITUTION 9. NDIB shall within a reasonable time vet and approve the draft Constitution prepared by GUYSUCO for the Conservancy Committee. APPOINTMENT OF CHAIRMAN 10. On approval of the Constitution and within a reasonable time NDIB shall appoint a Chairman of the Conservancy Committee. FORMATION OF CONSERVANCY COMMITTEE 11. NDIB, together with the Chairman, shall engage and invite representatives of stakeholder and water user groups to form the Conservancy Committee. Prospective committee members shall be given a copy of the Constitution so that they are fully aware of the duties, responsibilities and powers of the Conservancy Committee before deciding whether to accept the invitation to join. ASSISTANCE 12. NDIB shall do all in its power to assist in the provision of any specialist equipment e.g. weed cutter boats and pontoon excavators, required for extraordinary maintenance work, that is considered by the Conservancy Committee to be beyond the means of water users to pay through the water rates system. NDIB TO COVER OWN COSTS 13. NDIB agrees to meet its own costs in relation to its obligations under this Agreement and to cover the salaries and expenses of NDIB personnel attending Conservancy Committee meetings. The NDIB agrees not to make charges or deductions from water rates received for any services provided by NDIB. WATER RATES 14. NDIB shall be fully responsible for establishing and implementing all procedures necessary for the collection of water rates from registered water users in the amounts advised by the Conservancy Committee. GUYSUCO will not be liable for non-payment of water rates by any registered water user, save its own water rates. REIMBURSEMENT TO GUYSUCO 15. NDIB agrees to pay GUYSUCO in consideration of the performance of its obligations as Conservancy Manager such amounts as may become payable under the provisions of the Agreement at the times and in the manner prescribed by the Agreement. LIABILITY AND INSURANCE LIABILITY BETWEEN THE 16. GUYSUCO shall not be liable to pay compensation to NDIB nor shall NDIB be liable to pay compensation to GUYSUCO arising out of Page 36 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 36 PARTIES or in connection with the Agreement. INDEMNITY 17. So far as the Laws of Guyana permit, NDIB shall indemnify GUYSUCO against the adverse effects of all claims including such claims by third parties which arise out of or in connection with the Agreement except insofar as they are covered by the insurances arranged under the terms of Clauses 18, 19 and 20. INSURANCE OF PROPERTY 18. NDIB is the sole owner of the Primary Irrigation System known as the Halcrow Conservancy and Link Canal and shall insure the property: a) against loss or damage to the property by the Conservancy Manager or third parties. b) against liabilities arising out of the use of such property. The cost of such insurance shall be at the expense of NDIB. INSURANCE OF PERSONNEL 19. GUYSUCO shall include in its normal accident and health insurance policy for sugar estate workers the personnel assigned, either full-time or part- time, to the Conservancy Manager’s duties. INSURANCE OF VEHICLES 20. GUYSUCO shall include in its normal insurance policies the transport and equipment allocated, either full-time or part-time, to support the Conservancy Manager’s duties. COMMENCEMENT, DURATION, ALTERATION AND TERMINATION OF THE AGREEMENT AGREEMENT EFFECTIVE 21. The Agreement is effective from the date that this Agreement is signed by the parties. AGREEMENT DURATION 22. The Agreement is open-ended and has no particular completion date or duration. VARIATIONS 23. The Agreement can be varied on application by either party by written agreement of the parties. ABANDONMENT SUSPENSION OR TERMINATION 24. 1 By Notice of NDIB a) If the circumstances by which this Agreement is entered into by the parties is materially changed NDIB may suspend all or part of GUYSUCO’s obligations or terminate the Agreement by notice of at least 180 days to GUYSUCO who shall make arrangements to cease his services as Conservancy Manager and minimise expenditure. b) If NDIB considers that GUYSUCO is without good reason not discharging his obligations NDIB can inform GUYSUCO by notice Page 37 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 37 stating the grounds for the notice. If a satisfactory reply is not received within 28 days NDIB can by further notice terminate the Agreement provided that such further notice is given within 56 days of NDIB ’s former notice. 24.2 By Notice of GUYSUCO After giving at least 28 days’ notice to NDIB, GUYSUCO can by a further notice of at least 56 days terminate the Agreement, or at GUYSUCO’s discretion without prejudice to the right to terminate can suspend or continue suspension of performance of the whole or part of the services as Conservancy Manager a) when 56 days after the due date for payment of an invoice he has not received payment of that part of it which has not by that time been contested in writing, or b) when the services of the Conservancy Manager have been suspended under Clause 24.1a) and the period of suspension has exceeded 182 days. PAYMENT CONSTRUCTION OF CONSERVANCY 25. In consideration of GUYSUCO financing and implementing the Halcrow Conservancy for the benefit of the Skeldon Sugar Modernisation Project and water users in Crabwood Creek, Jackson Creek and Moleson Creek, NDIB shall waive the water rates payable by GUYSUCO on the expansion land net cane area, amounting to an estimated 4 700 ha at the time of Agreement signature, from the first day of release of water to GUYSUCO from the completed conservancy and for a period of approximately ten (10) years, but to be calculated precisely after as-built costs of the conservancy and water rates charges are determined. MANAGEMENT OF CONSERVANCY 26. NDIB shall reimburse to GUYSUCO the cost of personnel, transport and equipment required for the operation and maintenance of the Halcrow Conservancy and Link Canal provided that such cost does not exceed expenditures approved by the Conservancy Committee. GUYSUCO shall submit monthly invoices to NDIB to cover reimbursement of costs. TIME FOR PAYMENT 27. Amounts due to GUYSUCO shall be paid promptly within one month of NDIB’s receipt of invoice. If GUYSUCO does not receive payment within this period GUYSUCO shall be paid interest compounded monthly at the rate of one (1.0) per cent per month on the sum overdue. This additional interest payment shall not affect the rights of GUYSUCO under Clause 24.2a). CURRENCY OF PAYMENT 28. The currency of payment shall be Guyana Dollars. Page 38 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 38 DISPUTED INVOICES 29. If any item or part of an item in an invoice submitted by GUYSUCO is contested by NDIB then NDIB shall give prompt notice with reasons and shall not delay payment on the remainder of the invoice. Clause 26 shall apply to all contested amounts which are finally determined to have been payable to GUYSUCO. INDEPENDENT AUDIT 30. GUYSUCO shall maintain up-to-date records which clearly identify relevant time and expense. NDIB can at notice of 7 days require that a reputable firm of accountants nominated by NDIB audit any amount claimed by GUYSUCO by attending during normal working hours at the office where the records are maintained. Such audit not to be later than twelve months aft er termination of Conservancy Manager’s services GENERAL PROVISIONS APPLICABLE LAW AND JURISDICTION 31. The laws of the Republic of Guyana shall govern all matters arising from or in connection with the Agreement. Any disputes shall be resolved through arbitration under the Arbitration Act Chapter 7:03 of the Laws of Guyana. ASSIGNMENT AND SUBCONTRACTS 32. The following shall apply: a) Neither party shall assign obligations under the Agreement without the written consent of the other party. b) GUYSUCO shall not without the written consent of NDIB or the Conservancy Committee initiate or terminate any sub-contract for performance of all or part of the Conservancy Manager’s services. NOTICES 33. Notices under the Agreement shall be in writing and will take effect from receipt at the addresses stated hereunder. Delivery can be by hand or facsimile message against a written confirmation of receipt or by registered letter subsequently confirmed by letter. Director General National Drainage and Irrigation Board Regent and Vlissengen Roads Georgetown Chief Executive Guyana Sugar Corporation Inc Head Office Ogle Estate East Coast Demerara Page 39 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 39 IN WITNESS whereof the parties hereto have caused this Agreement to be executed the day and year first before written in accordance with the Laws of Guyana. FOR AND ON BEHALF OF: NATIONAL DRAINAGE AND IRRIGATION BOARD SIGNATURE NAME DESIGNATION IN THE PRESENCE OF: SIGNATURE NAME DESIGNATION FOR AND ON BEHALF OF: GUYANA SUGAR CORPORATION INC SIGNATURE NAME DESIGNATION IN THE PRESENCE OF: SIGNATURE NAME DESIGNATION APPROVED Permanent Secretary Page 40 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 40 Ministry of Agriculture Page 41 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 41 \03 \03 \03 \03 \03 \03 \03 \03 \03 $33(1',;\03ffl\03 *(3$\03(19,5210(17$/\033(50,7\0312\11\03fihungarumlauthungarumlauthungarumlautflfflflff\03)25\037+(\036.(/'21\03 (67$7(\03(;3$16,21\03352-(&7\03\0bDOVR\03UHIHUUHG\03WR\03DV\03WKH\036NHOGRQ\036XJDU\03 0RGHUQLVDWLRQ\033ODQ\03>6603@\11\03 Page 42 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 42 Page 43 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 43 Page 44 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 44 Page 45 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 45 Page 46 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 46 \03 \03 \03 \03 \03 \03 Page 47 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 47 \03 \03 \03 \03 \03 \03 \03 \03 \03 \03 $33(1',;\03ffi\03 6603\03+($/7+\03$1'\036$)(7<\03352*5$00(\03 \0bH[WUDFWHG\03IURP\03´6603\03)LQDO\03(QYLURQPHQWDO\03,PSDFW\03$VVHVVPHQW\035HSRUW\03SUHSDUHG\03 E\\03*URXQG\036WUXFWXUHV\03(QJLQHHULQJ\03&RQVXOWDQWV\03/WG\0c\03 \03 \03 \03 \03 \03 \03 \03 \03 \03 \03 \03 \03 \03 \03 Page 48 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 48 \03 caron\11dotaccent\03+HDOWK\03DQG\036DIHW\\03 GuySuCo implements a Health and Safety Program as an integral component of operations. This program was developed primarily because of the commitment of GuySuCo to the health and safety of its employees and to ensure compliance to the OSH Act (1997). Several components of the health and safety program currently implemented that would be applied to the expanded operations are as follows: 1. Continued training for all employees and especially the EHSO. Training would be a continuous process. 2. Monitoring of the effectiveness of training programmes for all categories of employees. 3. Provision of a higher weighting to OSH issues in senior and junior staff assessment. 4. Continued enforcement of OSH policies and procedures by the Estates’ Management and employees. The impacts on health and safety would be mitigated by establishing a program to identify and eliminate, all shallow pools and ponds in the Project area. Pesticides that are non-toxic to humans, fish and livestock would also be used for habitat and vector control. A body would also be established to provide health advisory and support health services and to monitor disease vector and disease incidences. A mosquito control program would be implemented to minimize breeding areas by proper drainage and periodic flushing of stagnant channels. During the operation of the facility emphasis would be placed on providing a safe and healthy environment for the workers. A health and safety plan would be implemented to enforce compliance with the regulations of the OHS Act 1997. Occupational Safety and Health plans would be implemented in the following areas: · Industrial accident prevention and management · Occupational hygiene. · Illness and infectious disease prevention and management. · Sewage and waste disposal. 6.8.1 Industrial Accident Prevention and Management Industrial accident prevention and management would be effected via a safety program. This would commence during the construction phase of the new facility and last through the operating phase. The program would include the following: · Hazard identification and control. · Monitoring and reporting of industrial accidents. · Training or education of employees in industrial first aid. · Industrial Accident Protocol. · Fire Safety and Preparation. · Hazard Identification and Control Page 49 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 49 Table 78 lists the potential hazards in different phases of the operations of the facility and the preventative and remedial activities necessary for their elimination and control. Hazard identification and reporting would not be limited to the initial phases of the operation but would constitute an ongoing activity in which the employees’ participation would be considered an integral part of his work functions. The OHS Act 1997 clearly stipulates the responsibilities of employees and supervisor/management in this regard. The supervisor/manager has the obligation to: · Inspect all machines and equipment for the existence of potential hazards and maintain them in working order. · Inform the worker of any hazards present. · Instruct the employees in the correct safe work procedure and audit compliance with those instructions · Provide the necessary safety protective gear when required. The employee on the other hand has the obligation to: · Cease work once a hazard is perceived. · Report the hazard to the supervisor who would in company with the safety representative, inspect the condition or circumstance and determine its validity. · Obey the instruction to perform alternative work or cease work completely as directed by the supervisor. · Return to the workstation or proceed once the hazard has been adequately dealt with or eliminated. GuySuCo currently maintains an industry wide system that details procedures for the following: · Hazard Monitoring and Reporting · Training and Education System for its Employees · Industrial Accident Protocol · Occupational Hygiene This system will be extended to encompass the construction activity and modified where appropriate, for improved effectiveness during the operation of the new factory and expanded cultivation. A detail of the system is presented in Appendix C. The sections below outline the minimum standards that will be adhered to. 6.8.2 Hazard Monitoring and Reporting Monitoring of hazards and work conditions would be the prime responsibility of the safety representative who would be elected from among the workers. He would be responsible for: · Performing Safety Inspections on and off the operations site on a regular and programmed basis (at least once per month) for the detection of unsafe conditions or any potential hazards and for reporting of these hazards to management. · Recording of all accidents (minor and loss time accidents) in a ledger as required by the Ministry of Labour (Table 79 shows the format to be used for recording industrial accidents). · Remitting of reports of industrial accidents or fatalities to the Ministry of Labour when required. Page 50 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 50 Table 1: Potential Hazards Phase Clearing of site: Felling trees Removal of topsoil and overlying vegetation Assembly of building Assembly of generating plant Reclamation of land for agriculture: Felling of trees Removal of topsoil and overlying vegetation Borrow pit operation and embankment fill placement Operation of heavy earth moving equipment and factory operations Maintenance operations Potential Hazard Insect bites Snake bites Minor trauma to extremities Lacerations from use of sharp tools Insect bites Snake bites Minor Trauma to Extremities Lacerations from use of sharp tools Fugitive dust blown into eyes Inhalation of fugitive dusts High noise levels from working of heavy duty vehicles – trucks, tractors etc. High noise levels High noise levels Contact dermatitis and skin irritation from exposure to grease High noise levels Protective and Preventative Safety Measures Use of insect repellants Provision of snake bite kits Use of safety shoes and gloves Use of helmets, goggles and masks Use of insect repellants Provision of snake bite kits Use of safety shoes, and gloves Use of clear goggles Use of dust/mist respirators Use of ear plugs Use of helmet Use of ear muffs Wearing of ear plugs Use of helmet, goggles and masks Use of barrier creams and detergents on hands Use of ear plugs Use of helmet, goggles and masks Page 51 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 51 Table 2: Accident Report Format Personal injury: Equipment damage: Name of person involved: Dept/Area: Name of injury: Place of injury: Description of accident: Type of accident: Loss Time: Minor: Foreman Sign ature:………………………………………………………………………………… Diagnosis:…………………………………………………………………………………………… Remarks:……………………………………………………………………………………………. In addition, all employees would be educated about their responsibility to participate in the creation of a healthy and safe environment by: · reporting unsafe and hazards conditions when detected · performing work in a safe manner by following the correct work procedure. 6.8.3 Training and Education of Employees In conformance with the objectives of the safety program the following training programs would be implemented: · Basic first aid programmes (all employees). · Advanced first aid programmes (ten employees). · Accident investigation and reporting seminars (supervisory personnel and safety reps.) The basic first aid program would be extended to all employees and would be geared to provide that in the event of an accident or injury, someone with first aid knowledge would always be present to render initial assistance until further medical attention can be made available. Qualified personnel would run seminars to impart the necessary theoretical as well as practical skills required. These courses would be scheduled depending on the employee strength and attrition. The advanced first aid program would constitute an upgrading course from the basic first aid program in which selected employees including supervisors and the Safety Representative would be exposed to advanced first aid knowledge and techniques which would enable them to participate in the recognition and the initial management of serious injuries and illnesses e.g. fractures, spinal injuries, malaria, typhoid fever etc. 6.8.4 Industrial Accident Protocol Serious injuries would be referred to a medical practitioner and medical institution. In the event of an industrial accident the following protocol would be followed: · A basic first aider would be summoned if not already present at the scene of accident. · The basic first aider would render first aid care. Page 52 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 52 · The basic first aider would summon an advanced first aider who would administer further care if necessary and evaluate the necessity for removal to the first aid centre. · The advanced first aider would summon the vehicle specifically identified for this purpose and supervise the removal of the injured to the first aid station. · The employee’s immediate supervisor would be informed. He would: 1. Make contact with the identified medical practitioner and institution and inform them of the time of arrival of the injured employee. 2. Complete the accident form and forward same along with the injured to the medical institution for completion by medical practitioner 3. Inform the Safety representative who would record the accident in the industrial accident register. A vehicle would be available at all times to respond to accidents. That vehicle would be four wheel drive and would have the following equipment: · oxygen cylinder resuscitation equipment. · a bed and accommodation for a first aid attendant to sit alongside the injured. · A flashing light attached to warn other road users. · communication equipment. 6.8.5 Occupational Hygiene The main environmental occupational hazards to which employees would be exposed during the construction phase are: · Dust. · Noise. · Heat · Fumes 57.7 299.3 8.0 2.6 0 : \03 'XVW\03([SRVXUH\03 Particulate matter dispersed into the atmosphere would be fugitive wind blown dust from the roads, construction operations and during land preparation. Sampling and analyses of surficial soils reveal that more than twenty percent (20%) of the fine crystalline silica particles are more than 2 microns in size. ILO and WHO guidelines state that the danger from silica particles occur for diameters less than 5 microns and especially those with a diameter between 0.5 and 3 microns since those particles when inhaled can reach the alveoli and lead to lung impregnated disease. Development of respiratory disease due to inhalation of respirable dust has been shown to be in direct proportion to the total load of dust inhaled over a time period. This in turn is a function of: function of: · The dust particle size · The concentration of particles in the atmosphere. · The duration of exposure Page 53 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 53 The concentration of dust particles in the air is not expected to be consistently above acceptable international standards since it is basically wind blown dust. The development of respiratory disease due to inhalation of dust is very low and would probably need exposure time far in excess of twenty five years to develop. Workers would also be exposed to wind blown/fugitive dust being blown into the eyes and causing eye irritation and conjunctivitis. These employees would be provided with clear goggles and eye wash lotion would at all times be available for washing the affected eyes. 1RLVH\03 The following measures would be implemented to address worker health and safety related to noise associated with the operation: · Control of noise levels at source via installation of silencers on exhaust system of equipment and plant. · Provision of hearing protection to employees exposed to high noise levels · Earplugs for employees who operate heavy-duty machines. · Warning signs in areas of high noise levels instructing employees to wear ear protection. Health and safety impacts would be mitigated by providing a medical doctor and ambulance for the duration of construction work. The estimated costs are forty three thousand, two hundred dollars (US$ 43, 200.00). Page 54 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 54 \03 \03 \03 \03 \03 \03 \03 \03 \03 \03 \03 \03 \03 \03 $33(1',;\03%\03 *8<68&2\03+($/7+\03$1'\036$)(7<\0332/,&<\03\03 \0bH[WUDFWHG\03IURP\03´6603\03)LQDO\03(QYLURQPHQWDO\03,PSDFW\03$VVHVVPHQW\035HSRUW\03SUHSDUHG\03 E\\03*URXQG\036WUXFWXUHV\03(QJLQHHULQJ\03&RQVXOWDQWV\03/WG\0c\03 Page 55 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 55 Legislative Framework In December 1997, the Parliament of Guyana passed Act No.32 of 1997- the Occupational Safety and Health (OSH) Act 1997.Prior to this, regulations pertaining to safety and health issues in factories were contained in the Factories Act, Chapter 95:02.The OSH Act has been enforceable since September 1999. The OSH Act (1997) is a comprehensive Act that provides for the regulation of industrial establishments for occupational safety and health of persons at work. Industrial establishments include factories, shops, offices and workplaces. Hence, the Guyana Sugar Corporation (GuySuCo), as an industrial establishment, is subject to this Act. The OSH Act (1997) sets out the duties of employers and employees, the procedures for identifying hazards, the rules for and functions of the joint workplace safety and health committees and the penalties, and is enforceable by the Ministry of Health and Labour. The primary objective of this Act is to ensure that an employer takes "every precaution reasonable in the circumstances for the protection of a worker." In accordance with the OSH Act (1997), GuySuCo, as an employer, is required to undertake a number of duties. These include: 1. Ensuring that “equipment, materials and protective devices and clothing as prescribed are provided” and maintained in good condition and used as prescribed.” 2. Ensuring that “the measures and procedures prescribed are carried out in the workplace.” 3. Providing “information, instruction and supervision to a worker to protect the safety and health of the worker.” 4. Ensuring the establishment of the joint workplace health and safety committee, unless a committee of like nature exists. 5. Preparing "a written occupational safety and health policy", reviewing it periodically and implementing it. 6. Providing and maintaining “a safe, sound, healthy and secure working environment as far as is reasonablypracticable.” 7. Establishing “a medical surveillance program for the benefit of workers,” as prescribed. 8. Ensuring that a medicine chest, first aid, including training personnel is available at the workplace. Policies Prior to the passage of the OSH Act (1997), GuySuCo, in 1994, demonstrated its proactive nature in addressing issues related toworkers' health and safety by establishing a separate department in Head Office under the Human Resources Department tocoordinate the related occupational health, safety and environment issues. Moreover, in May 1994, GuySuCo formulated anoccupational safety and health (OSH) policy that was designed to adopt “risk assessment and safety management principles andpractices in all aspects of its operations”. In August 1999, in accordance with GuySuCo’s plan to decentralize a number of its Head Office’s functions, the Occupational Health, Safety and Environment Department was restructured. The Department is currently the responsibility of the AgricultureServices Director who is assisted by one (1) Company Health and Safety Officer (CHSO). The CHSO is responsible for thecoordination of programmes of the Department and functions as the liaison between the Operations Director and the Estates’Management. From February 1, 2000, GuySuCo appointed one Estate Health and Safety Officer (EHSO) for each Estate. Page 56 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 56 The first appointees to these positions were Senior Staff Managers who were transferred from line management. They functioned in the capacity as EHSOs for a period of two (2) years. Upon successful completion of this period, they resumed line management on promotion. Theresult has been that that after a number of years there are Senior Staff in line management who have the knowledge, training and skills in addressing occupational safety and health (OSH) issues. New recruits to these positions are increasingly graduate management trainees who may wish to make Health & Safety a career. The EHSOs are responsible for administration of GuySuCo’s health and safety policies and procedures and report directly to theGeneral Manager of their respective Estates. The CHSO is responsible for training and providing technical support for Estate and more specifically the EHSOs. GuySuCo also has a medical policy which sets out the categories of employees who are required to undergo specific medicaltests and the frequency of this testing. For example, annual medical examinations are required for all employees over 40 years old. Biannual examinations, requiring specialized testing where appropriate, such as vision, hearing, spirometry and cholinesterase, are performed for all high risk employees, such as chemical workers, food handlers, drivers, and workers exposed to high frequency noise, dust and extreme temperatures. In addition, all employees are subject to a pre-employment examination. In order to fulfill its OSH policy GuySuCo has established a number of committees. At the Head Office level, there are two such committees; namely, the Agriculture Safety Committee (formerly the Agrochemical Safety Committee) initiated in 1992, and the Central Factory Safety, Health and Environmental Committee, established in 1998. The Agriculture Safety Committee has two arms: the Agriculture Operations Safety Committee and the Agrochemical Safety Committee. Its main objective is to establish and review GuySuCo’s policy, procedures and practices with respect to the agriculture operations and the usage of agrochemicals. The Committee is chaired by the Agriculture Research Director and includes the following membership: Manager, Central Analytical Services, Chief Medical Officer, Weeds Agronomist, Aircraft Manager/Chief Pilot, Manager Central Stores , and the CHSO (Secretary). The specific Terms of Reference of this Committee are in the Appendix. The Central Factory Safety, Health and Environmental Committee currently comprises the Technical Director, FactoryOperations (Chairman), the Regional Technical Services Manager, Senior Electrical Engineer, Estate Medical Officer, Manager Technical and Vocational Training – GTTC/PM, the Factory, Production and Engineering Managers of the Estate hosting theCommittee and the CHSO (Secretary). The objectives of this Committee include: 1. to create and maintain a proactive interest in OSH & E among factories management and factory workers 2. to attain zero accidents; to maintain and update the Safety Manual and 3. to maintain and update safe work practices. This Committee meets every two months and visits different Estates. The specific Terms of Reference are highlighted in the Appendix. In addition, each Estate has Departmental Safety Committees and an Estate Safety Committee. These Committees are of a similar nature to the joint workplace safety and health committees mandated by the OSH Act (1997). They report on safety hazards to management and ensure that they are remedied. Page 57 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 57 Although GuySuCo’s OSH policy does not specifically mention rotating and sharp equipment, and slip, trip and fall, burns and electrical shock, it gives GuySuCo’s commitment to create and maintain a healthy working environment and to provide work systems that are safe and free from risk for the workers. In addition, the terms of reference of the various safety committees direct its membership to ensure this is being done. GuySuCo also has trained first aiders on each shift and at each work location in the event of an accident such as a slip, trip and fall, burns or electrical shock. Because GuySuCo has been proactive in addressing its workers health and safety issues, as a consequence of the passage of the OSH Act (1997), GuySuCo now needs and has begun to ensure enforcement of its OSH policy and the Act. For example, Part IV, Section 46, Subsection 2(a) states that “after being notified by a female worker that she is pregnant”, the employer should “adapt the working conditions of such a worker to prevent damage “to her health and the health of the unborn child”. Previously, in field operations, female workers were allowed, with their permission, to work in their substantive jobs up to the sixth month of their pregnancy. However, this section of the Act is now being enforced and the worker is transferred to alternative work. Training It is part of GuySuCo’s policy that basic safety training should be provided for all workers as part of their pre-placement induction. This training should be general, i.e., the worker is introduced to OSH issues, and specific, i.e., the worker is exposed to the standard operating procedures/instructions for his/her employment. The specific contents of the training are pertinent to the nature of the persons’ employment. Each Estate’s Personnel Department should conduct this training for the Estates’ workers. The CHSO is currently putting together induction material for new employees with a view to ensuring that this training is carried out. The OSH&E Department is also responsible for coordinating a number of training sessions for various target groups in order to increase the level of safety awareness among workers already on the job. One such training programme is the Seminar on Safe Work Methods and Practices in cane cutting for the cane harvesters. The main objective of such a programme is to reduce the incidence of injury to cane harvesters and others in the workplace. Such training should assist in the reduction of accidents from slips, trips and falls and from the usage of sharp equipment. There are also current training programmes for the junior and senior staff aimed at reducing the number of accidents by increasing their knowledge of the OSH Act (1997) and highlighting their roles in issues relating to health and safety among others . This is essential since, as supervisors, they are designated specific duties under Part IV, Section 48 of the OSH Act(1997). That is they have to ensure compliance with the Act by the workers under their supervision. In addition, first aiders are exposed to training at least twice per year (or upon an Estate’s request). New first aiders are provided with training in Emergency First Aid, while the previously trained first aiders are given refresher training . This assists the first aiders to successful render initial treatment in the event of injuries, such as burns, electrical shocks and due to sharp and rotating equipment. Page 58 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 58 There are also training programmes specifically designed for chemical weed control workers, the drivers and the fire fighters to ensure that these categories of workers are familiar with their work practices. Training/Communications The communication to employees on matters relating to OH&S is of great importance at GuySuCo. It has been recognized that through effective communication employees are made aware of the dangerous conditions, which exist in the work environment and are more able to act appropriately. Several measures are employed in combination at various locations to educate the employees on OH&S related issues. These measures are listed below:- • Safety News Letters • Safety Competitions • Safety Notice Boards • Safety Notices and Posters • Safety Suggestion Schemes (general & specific) Other systems adopted by GuySuCo to assist in the implementation of OH&S policy are as follows: a.) Permit to Work GuySuCo has also in place the permit system. The permit system is based on the recognition that some conditions may be unsafe for particular activities. It requires that careful evaluation be made of the activities in relation to the working environment, and that appropriate measures be taken to ensure that operating conditions are made safe before permission is granted for the activities to take place. The permit is usually signed by both the supervisor of the area and the worker, and is displayed at a conspicuous location at the work site. At the end of the shift/day a copy of the permit is usually sent to the EHSO for his records. The EHSO is expected to make random checks on permits at the work site. The permits in use presently are: Hot work Electrical work Entry into confined spaces. b.) Registers To ensure certain safety checks are being carried out at the stipulated intervals a number of registers are currently in use at GuySuCo. The registers are usually in the safe keeping of a Senior Manager. CHSO/EHSO will periodically examine the registers to ensure that the checks are done. Some registers are listed below. Training Portable Electrical Tools- Portable Access Equipment Lifting Gear Drivers/Operators Contractors Fire Extinguishers Page 59 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 59 Accident Statistics c.) Company Transportation In 2000 the company adopted the policy on the use of vehicles, including motorcycles. The policy clearly spelt out amongst other issues, the number of persons to be transported at any given time in the vehicles/motorcycle and also highlighted the mandatory use of seat belts for those vehicles fitted with belts. In instances of tractors and trailers the use of safety chains especially when towing was highlighted. Additionally, tractors/trailers must be fitted with adequate reflectors. d.) Visitor Control A Visitor Control policy is also enforced especially in the factories. All visitors, including school children must wear hard-hats before entering factories. Only school children above 12 years of age are allowed on factory sites. Other policies already in force include the mandatory use of hard-hat and overalls. e.) Fire Safety Most locations have established lists of fire fighters/ring main fire systems/fire alarm systems. All buildings are equipped with fire extinguishers, which are strategically placed. In posting of fire extinguisher the size of the building, accessibility of the equipment and the height from ground level are usually taken into consideration. Protective measures employed for company assets are dictated by the level of risk. Fire Crews are routinely exposed to training in the use/care of the fire fighting equipment, responding to fire and fire containment. Two persons per shift are designated fire crew members. In addition to their normal duties, crew members are responsible for the quarterly checks on fire extinguishers. Presently Fire Wardens are being identified and given training to handle emergencies. Dedicated assembly points (safe areas)have already been established on most locations. In the event of a fire the procedure to be followed is:- a.) On discovering an outbreak of fire:- Give the alarm by breaking the glass of the nearest alarm point Call the Radio Operator If possible and without risk, tackle the fire using the appropriate extinguisher. Leave the building via the nearest available route. Do not run. Assemble in the designated area. b.) On hearing the fire alarm:- Leave the building via the nearest available exit Assemble in the designated Performance Statistics collected on the severity and frequencies of accidents within GuySuCo for 1994 and part of 1995 (Ecologistics Ltd., 1997) indicate that: 1. For agriculture operations, the majority of accidents were due to slips, trips and falls (34.6%). Injuries were caused mainly to the foot and leg (25.7%) and hand, finger and wrist (18.9%). It is reported that these result: 2. a) during the rainy periods when conditions are poor and slippery; b) during the starting of a crop when cane harvesters are inexperienced in the use of the cutlass; and c) during the latter weeks of a Page 60 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 60 crop when it is believed that workers endeavour to utilize the National Insurance Scheme to obtain a source of income during the out-of-crop season. 3. For factory operations, injuries were caused mainly to the hand, finger and wrist (31.4%) and foot and leg (18.8%) and the main cause of accidents was due to slips, trips and falls (17.5%). These could be due to: a) the conditions of factory floors and hand rails, i.e., the presence of liquids on the floor and oil and grease on the hand rails, b) operation of unprotected rotating equipment and c) poor lightning. 3. Providing shoes with better traction and ensuring that newly recruited cane cutters are exposed to training in safe work practices could reduce the agricultural accidents. The following policy statement reflects the commitment of the Corporation to the adoption of proactive risk assessment and safety management principles and practices in all aspects of its operations including activities in its Head Office. It is the policy of the corporation, insofar as it is reasonably practicable: 1.To apply safe working procedures and practices and to act in conformity with appropriate Health & Safety Legislation. 2. To create and maintain a working environment having adequate facilities and arrangements for the health, safety and welfare of employees and any other persons. 3. To provide safe means of entry and exit and to maintain premises, plant, equipment and work systems that are safe and free from health risk. 4. To make suitable arrangements concerning the safe use, handling, storage and transport of articles and substances. 5. To provide such information, instruction, training and supervision as may be necessary to protect the health and safety of employees. 6. To provide such facilities, equipment and staff as may be necessary to deal with accidents and emergencies. 7. To encourage and promote co-operation between management and employees on all matters relating to health and safety at work, including establishing such Safety Committees as are appropriate to oversee safety matters at each location. 8. To subscribe to and participate in the activities of national and local agencies and associations promoting safety awareness and risk management. 9. To monitor the progress of Health and Safety matters in all locations. It is the responsibility of all employees to safeguard the health and safety of themselves and of other persons who may be affected by their acts or omissions at work; also to co-operate with the Corporation to fulfil any requirements imposed by any relevant statutory provisions . TOR OF AGROCHEMICAL SAFETY COMMITTEE The Terms of Reference of the Agrochemical Safety Committee include the following: 1. Review of suitability of chemicals used by GuySuCo. 2. Review of existing safety procedures, protective clothing and equipment. 3. Review of training in handling and usage of chemicals. Page 61 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 61 4. Assessment of stores, mixing plant, and application equipment. 5. Determination of standing instructions for Managers, Supervisors, and Medical Staff in dealing with accidental chemical exposure or personnel. 6. Ensuring that a full listing of chemicals in use, recommended treatment, and antidotes, is available to Medical Staff. 7. Review of safeguards in procurement procedure to ensure that only chemicals of required standard are delivered. 8. Any other matters considered relevant by the Committee. TOR FOR THE CENTRAL FACTORY SAFETY, HEALTH & ENVIRONMENT COMMITTEE The Terms of Reference for the Central Factory Safety, Health and Environment Committee include the following: a) Review and audit of existing safety procedures, protective clothing and equipment. b) Recommendations for safety training required within the various areas of work in the Factory Operations. c) Review of factories’ accidents, near misses and dangerous occurrences. d) Establishment of standing instructions for Management, Supervisory and Medical Staff in dealing with emergencies within Factories and their environment. e) Ensuring a detailed list of all chemicals and hazardous substances in use, recommended treatment, and antidotes are available to Medical Staff. f) Ensuring all statutory testing and certification of plant structures, pressure vessels and lifting devices are conducted in accordance with the established corporate and Lawful safety regulations. g) Ensuring that all machines are guarded and maintained in accordance with the established rules and regulations as well as PPE. h) Ensuring that the processing, handling, storing and loading of sugar and molasses are done in keeping with the established standards. i) Ensuring that all chemical/hazardous substances are handled, stored and disposed in accordance with the established safety regulations. j) Reviewing any Health, Safety and Environment Audits conducted from time to time by Occupational Health, Safety and Environment Estate’s Safety Committees, statutory bodies or any organization contracted by GuySuCo to do so, before any consideration is given for the implementation of recommendations arising from such audits. k) Ensuring that the Food factory, Occupational Safety and Health, and Environmental Regulations are being followed at all times. l) Review and audit of existing environmental practices within the various areas of the factory. m) Establishment of standard instructions for managing Factory Pollution, ventilation and lighting. Page 62 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 62 $33(1',;\03&\03 *8<68&2\03$*52&+(0,&$/\0332/,&<\03 \0bH[WUDFWHG\03IURP\03´6603\03)LQDO\03(QYLURQPHQWDO\03,PSDFW\03$VVHVVPHQW\035HSRUW\03SUHSDUHG\03E\\03 *URXQG\036WUXFWXUHV\03(QJLQHHULQJ\03&RQVXOWDQWV\03/WG\0c Page 63 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 63 Pesticides Transportation and Storage Types of Pesticides that will be used - Insecticides - Rodenticide - Herbicides Insect Pest % of area to be treated Type of Insecticide Formulation Hazard Class Diatraea sp. 0 Castniomera licus 0 Froghopper 0 Caterpillars 0 Termites 5% Fipronil 200g WG II Hardback beetles 0 Rodents % 0f area to be treated Rodenticides Formulation Hazard Class Holochilus brasiliensis 5.0% Klerat(brodifacoum) (2.5%) Wax blocks I Storm(flocoumafen) 2.5% wax blocks I H erbicides Formulation % of area to be treated HazardClass Ally (Metsulfuron methyl) 60 DF 40 IV Asulox (Asulam) 80 SG 20 IV Dual (Metolachlor) 960 EC 20 III Karmex (Diuron) 80 DF 80 III Igran (Terbutryn) 500 FW 20 III Merlin (Isoxaflutole) 75 DF 40 IV 2,4D Amine 40 II 2,4D Acid II Roundup (Glyphosate) L 40 III Touchdown(Glyphosate) L 60 III Starane (Fluroxopyr) L IV Tordon101(Picloram+2,4-D) L IV Velpar (Hexazanone) 75 DF III Imazapyr (Arsenal) L III Surfactant (Spreader Sticker) L 40 IV DF - Dry Flowable SG - Soluble Granule LC - Liquid Concentrate EC - Emulsion FW - Flowable Liquid WDG - Water Dispersible Granule L - Liquid. Page 64 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 64 Established Systems for the transport of Pesticides Transport of Pesticides From - Suppliers, Ports of entry to Central Stores (Coldingen) - Central Stores to Skeldon Estate Stores. - Estate Stores to the field. Will be done with minimum risk to people and the environment. STAFF INVOLVED Stores Controller : Responsible to ensure that a) all pesticides checked into and out of the store are inspected and that damaged or leaking packs are not transported further. b) Packages are properly labelled. c) Stores staff have access to the appropriate personal protective equipment (PPE) and are fully trained in clean up and decontamination procedures and in correct handling method. Transport Manager who is usually an Assistant Factory Manager has responsibility to ensure that drivers and mates are fully trained in pesticide handling and are provided with safety equipment and PPE to enable them to respond appropriately to an incident requiring containment of spillage, fire fighting or first aid. Drivers are also trained in loading the transport unit to segregate, store and secure loads and in the cleaning and decontamination of the unit after a spill and that pesticides are transported in original container and all containers are correctly labelled in English. A dispatch checklist will be completed by both the stores man and the tractor driver and then returned to the Agricultural office where pesticide record keeping forms are retained. TRANSPORTATION FACILITIES Agrochemical transportation facilities are designed to satisfy the following constraints: • The containers to be transported at the Estate will be held in a fixed container in the trailer. This container will be made with steel or fiber glass with interior container compartments lined with non-absorbent plastic foam and with a lockable lid. The trailer will be marked "Pesticide Transport Trailer" and will be used solely for this purpose. The trailer will be painted white-light grey to keep it cool and will also have hazard symbols. Such as a skull and cross-bones, "No Smoking" signs well displayed. • Pesticides will be protected from rain or direct sunlight during transportation. • Correct handling of packages will be done during loading and unloading. • All operators, drivers and mates who move pesticides will be trained in the correct procedures for loading the unit, for unloading and for emergency response procedures. • The pesticide trailer will be dedicated to the sole duty of pesticide transport. The units will be maintained regularly and security provisions put in place. The driver and mate of the tractor/trailer will also be separated from the pesticides to prevent the driver being overcome by fumes or dusts in the event of an accident or spillage. Transport units for pesticides will carry 1. First aid bag 2. Halon gas fire extinguisher 3. Emergency Protective Clothing. 4. 4 pairs microguard disposable overall 5. 4 pairs elbow length rubber gloves 6. 4 full face shields with visors. 7. 4 plastic aprons. Facilities in Place For Clean-Up Each unit will have clean-up equipment a) Bag of dry bagasse to absorb spill (4 x 50 kg bags) Page 65 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 65 b) 4 shovels c) Empty fertiliser/sugar bags (8 x 50 kg bags) for contaminated materials Stiff brush (2) The Clean-up Equipment and Emergency Protective Clothing will be in a locker on the outside of the trailer when it will be easily accessible in the event of a leak or spill. Training: Training is provided to the drivers, operators and mates in the following areas: • Corporate and legal regulations. • Load segregation and load securing • First Aid • Use of Safety Equipment and PPE • Fire fighting. Drivers and mate are subject to a medical examination prior to being allocated to pesticide transport and each will receive a medical examination every six months. Neither will work at pesticide transport for more than three years of their total working life. The driver of the tractor trailer will be instructed that units must be parked in a safe place, kept under constant supervision and must be kept locked at all times. The driver will also ensure that no unauthorized persons access the unit or its contents. People who work in or have access to the store would be trained in the following: a) Emergency arrangements b) correct handling of containers in and out of store c) Maintenance procedure in respect of the store contents, Security, Cleanliness and reduction of fire risk. d) The potential hazard of individual products e) Stacking heights and procedures f) Stock rotation and regular inspection g) Correct use of PPE. EMERGENCY PROCEDURES The following actions will be taken in the event of an accident. Prompt action will be taken to contain any leakage or spillage and as a result prevent a minor incident from developing into a serious one. In the event of a spillage or leakage immediate response procedures shall be as follows: a) Switch off transport vehicle. b) Do Not Smoke c) Driver stays with unit but upwind of any spills and keeps other traffic and people away from area. Mate goes to seek assistance. d) Do not open the doors of any unit unless so advised by a competent person and appropriate PPE is worn. If a product comes into contact with any person the immediate first aid assistance shall consist of as follows:- • Remove any contaminated clothing at once. Wash skin thoroughly. • In an emergency bathe in the nearest canal • If a product has come into contact with the eye then wash the eye with clean water for at least 10 minutes. • Seek medical help at first opportunity. Initial containment of any spill shall be the responsibility of the driver and/or mate and shall consist of the following: 1. In all cases of spills the safety equipment and PPE from the vehicle locker must be used and/or worn. 2 Contain small liquid spills by covering with earth, sand or the bagasse from the sacks on the vehicle. 3. Large spills may be contained by building an earth dam around the spill. Page 66 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 66 4. With spilled dusts or powders cover with earth or sand. 5. Place leaking packages or drums onto an empty fertiliser/sugar bags 6. Take every precaution to prevent materials from seeping into canals or drains. Clean-up and Decontaminations Clean-up and decontamination will be directed by the Senior Assistant Field Manager who must also prepare a short report on the incident and thus fully document the spill. The following minimum standards must be adhered to during cleanup. a) All those involved in the exercise at the site must wear PPE and all work should be from the windward side of the spill. b) There must be No smoking, eating or drinking during operations. c) Materials used to absorb the spilled materials, and contaminated soils must be shoveled into the empty sacks for disposal at an approved site on the Estate. d) All damaged or empty packs must be recovered for washing and disposal by the usual procedures. e) Any food, animal feed, clothing which may have been contaminated must be destroyed. Foodstuff may be incinerated (in small quantities) at the Factory boiler as may the contaminated clothing and the microguard coveralls worn in the clean-upoperation. f) Undamaged packages on the transport unit must be inspected for contamination and decontaminated as necessary. g) All clean-up equipment and contaminated vehicles must be thoroughly washed after the incident. Emergency Procedure for Agrochemical Contamination This procedure is appropriate for a higher level of contamination than that described earlier. In event of chemical contamination the procedure to be followed is listed below. 1. First aider/immediate supervisor must accompany the patient to the health care center (Estate dispensary or one of the Corporation’s Diagnostic Centres or municipal/regional health facility). 2. Senior management (Senior Asst.Field Manager) including the General Manager must be informed promptly. 3. Field Manager/Senior Asst. Field Manager must visit the health care centre to supply all information pertinent to the contamination. 4. Health center staff must play an active role in preventing panic at the facility. 5. The Estate Medical Officer (EMO) must be informed. 6. The contaminated patient(s) must be separated from non-contaminated persons. Unconscious patients must be forwarded to the Corporation’s Diagnostic Centres at Ogle or Rose Hall for investigation/treatment. 7. Where the medical officer is not on location the patient(s) must be sent to the Public Hospital, Georgetown after being initially treated. Medex/Staff Nurse and a senior manager must accompany the patient(s). 8. The doctor at the Public Hospital must be informed of the type of agrochemical involved and the treatment administered at the health care center. 9. The Corporation’s Chief Medical Officer must be briefed on the accident within 24 hours of it occurrence. STORAGE FACILITIES AT SKELDON The storage of pesticides for the SWR expansion will be the same as that currently practiced at SWR Estate. Pesticides, upon arrival on the Estate from the manufacturers/suppliers/distributors will go to the General Stores. There will be need to modify the existing structure (or build a new facility) to accommodate the increase in the quantities of the various products to be stored. Page 67 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 67 The current facility is in a secure location and poses no danger to the environment. The design is in keeping with international standards for the storage of pesticides. The storage facility at Skeldon has the following features:- • It is readily accessible for fire fighting and other emergency procedures. • The facility has fire detection and is being serviced by fire supervision capability. • The site is not subject to flooding. • The site is in a location where there is minimum potential for environmental damage to surface and ground water, threat to human health, animals, or plant life. It is situated away from normal operating facilities. • Access to the facility is limited to employees who are trained in respect of normal operating procedures and emergency response. • The facility has proper labels such as "caution - pesticide stage area", "Danger", "No entry to unauthorized personnel", "No smoking in area" which are legible from a reasonable distance. • The floor was constructed with non-absorbent non-reactive material with no drains. The permeability is not greater than 10-7 cm/s and the thickness more than 0.5 meters. • The facility has a 15cm high continuous curb around the perimeter of the floor to prevent waste from escaping. • The facility has a suitable location to load and unload containers. • The facility has secondary contaminant capable of containing 110 percent of the largest single container stores plus 10 percent of the aggregate volume of all other materials stored there in. • The facility has suitable air exchange to meet occupational health and safety requirements for worker exposure. • The facility has explosion venting to the outside • The facility is equipped with 50 kg of spill absorbent materials and all necessary PPE necessary to respond to a spill in close proximity. • The facility is inspected weekly and a log kept of the inspection findings. This inspection ensures that there is no evidence of any spillage or likelihood for spillage to occur. The day bonds (field stores) have similar characteristics as listed above. Items 1, 4, 5, 6, 9, 10, 11, 12 and 14 are the critical features in the day bond. STORAGE PROCEDURES Security: - The stores are managed to exclude unauthorized people. The doors are kept locked/bolted whenever the store is closed and only authorized personnel have access to the keys and are allowed in the store. Fire Precautions : Smoking is prohibited in the stores. Fire extinguishers are provided and these are checked monthly and kept in good working condition. Bucket of sand/earth and piped water are available. Pesticides labelled 'flammable' are held separately in a highly secure area made out of steel. Deliveries of Pesticides:- Pesticides are delivered upon notification by the supplier. At no time are pesticides left unattended outside the stores. Shelving: Pesticides are stored on pallets or shelving or in a vault. Stacking : Pesticide containers are stacked with due regard to their size and design, the material from which they are made, and in accordance with the manufacturer's advice. Products are stacked with the label clearly visible and in a way not to impede entry to or exit from the store. The height of stacking is also controlled to prevent crushing. Different types of pesticides (herbicide, insecticide etc.) are also separated Page 68 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 68 from others with flammable and/or highly toxic properties. Flammable and highly toxic materials are segregated within vaults or within the interior high security areas. First-in/First-out use of stock : Stocks are issued based on receipt so that the oldest stocks are issued first. This would require an orderly arrangement of stocks with dates of acquisition painted on the containers. Regular Inspection of stocks :- Stocks are regularly inspected for signs of deterioration or leakages. Wherever deterioration or leakage is suspected, or seen, all affected packs are removed and isolated. Emergency Precautions in Stores The Stores are equipped to deal with 1. Fire (see above) 2. Spillage and leakage If personnel contamination occurs in the stores access is provided to an emergency cabinet containing the following: a) 4 Pairs of heavy duty nitrile gloves. b) 4 PVC aprons. c) 4 Full face respirators. d) 4 Full face shields e) 8 Disposable microguard coveralls with hoods f) 4 Yard brooms g) 4 Large bin of absorbent material such as sawdust, earth, bagasse h) Large empty polythene sacks to receive wastes. A supply of industrial detergent. Should a spill occur, all unauthorized people and all animals would be kept out of the area. All persons who work on spill and leaks will use full PPE and work only upwind of the spill. The contents of a leaking drum may be decanted into a clean, properly labelled empty drum. Leakages or spills must be contained as far as possible with barriers of earth, bagasse or saw-dust placed around the spill to prevent spread and to absorb the liquid. The contaminant materials may then be shovelled into the polythene sacks for disposal. A similar procedure is followed with solid spills and in each case the floor, after sweeping, is to be washed with detergent then rinsed off with water. Hygiene and Safety - Provided that pesticide containers are kept in good condition and handled sensibly by personnel wearing the recommended protective equipment then contamination should not occur. However if it does then it will be necessary to initiate first aid and decontamination procedures. Records A record of all pesticides held in the stores is kept nearby and readily available to the appropriate authorities in case of an emergency. Associated Facilities : The following are available at the stores. 1. Personal washing facilities 2. Protective clothing 3. Overall, Glove and boots washing facilities 4. Storage for Empty Containers. The following information are also kept at the store and employees are fully briefed. 1. Product data sheets including material safety data sheet (MSDS) 2. a current stock list 3. A list of first aid procedures for the pesticides approved for use 4. A list of safety precautions and a copy of the emergency plan. Page 69 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 69 QUANTITATIVE DETERMINATION OF THE EFFECTS OF A WORSE CASE SCENARIO Off-site and on-site spill and fire event (i.e. effect of release on the most sensitive receptor). Spills and fire are emergencies. Should a spill occur during transportation or storage then all the recommended precautions must be taken into consideration. The persons are trained to handle these situations. Full use of the emergency cabinet will ensure that no contact is made. In a worse case scenario, once persons use full PPE and follow instructions such as work only upwind of the spill, then contamination is not likely to happen. In addition, the products in use are in toxicity class III - IV, non volatile and have a low flash point. The clean-up facilities are adequate and are based on the size of the containers. In the case of fire, smoke fumes from pesticides can be hazardous and once those fires are tackled by fire- fighters who have full breathing equipment then there should be no injury. DISTRIBUTION AND APPLICATION Application of Pesticides The areas where pesticides are applied are known at least one week before. The exact quantities are ordered from the general stores and placed in the field stores the day before application. On the morning of application, the pesticides are transported by the chemical trailer to the work site. The amount of pesticide applied per unit area or the rate of application is determined by a series of experiments to evaluate the efficacy of the product on the target pest and the degree of tolerance (phytotoxicity) to thecrop. Only pesticides registered with at least one of the recognized regulatory bodies such as the United States Environmental Protection Agency (EPA) or the Pesticide Directorate of the (United Kingdom) Ministry of Agriculture are recommended for use in GuySuCo. In general, pesticides in Hazard Class 1A and 1B in World Health Organization (WHO) "Classification of Pesticides by Hazard" are not used in GuySuCo. The rate of application is determined by 1. Screening the product at the recommended rate, half - and to-times the recommended rate and record efficacy and phytotoxicity of the product. 2. If the product shows promise, small plot field trials on 50-100 m 2 plots are done to compare the product with the standard treatment. 3. If the product is as good as or better than the standard in cost-effectiveness then large plot semi commercial trials or field scale trials are conducted on all Estates to compare the product with the standard treatment. 4. If the results are consistently better than the standard treatment, it is recommended for use. The application of pesticides in the Skeldon expansion will be done by i) Knapsack Sprayers ii) Tractor Boom Sprayer iii) Ayres "Thrush Commander" Agricultural aircraft equipped with Micronair Spray system. Pesticides for one day use are ordered from the General Stores one day before and placed in the Field Stores of chemical bond. Solid chemicals are pre-weighed while liquid and DF/WDG formulations are measured out at the field using a volumetric cylinder. The persons handling these concentrated products are equipped with full PPE - Page 70 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 70 overalls, apron, rubber boots, gloves, face shields, masked and hat. A scoop is used to transfer the pesticide into a bag which must be tightly secured and fully labelled. In measuring liquid pesticides, similar precautions are also taken. A pump is used to remove liquids from containers. Mixing :- Mixing is done in a calibrated mixing drum equipped with a filter by adding water, pesticide, stirring and more water to the required level. The mixture is next dispensed into spray cans. PRECAUTIONS IN HANDLING PESTICIDES IN THE FIELD 1. People applying pesticides must be trained. 2. People must not work alone when handling pesticides 3. Daily work must be organized so that spraying starts early in the morning to allow the allotted task to be completed before the day becomes too hot for comfort or for precision spraying. 4. Workers and staff must wear appropriate PPE 5. All containers must be properly labelled 6. The spray mixture must be dispensed from the mixing drum into the spray can by a small bucket for ease of handling. The spray can must be placed erect for topping up to the required mark. 7. The application equipment must be in good working order i.e. no leaks and previously calibrated with water 8. Always brush and rinse clogged nozzles. They must never be blown by mouth. 9. Avoid spraying when wind is high to prevent drift. 10. Do not spray or dust into the win 11. Do not allow other work in the field when pesticides are being applied. 12. Never leave pesticide unattended in the field. 13. Wash all equipment after use 14. All washings must be sprayed into the field. 15. Triple rinse all empty containers and pour the washings into the mixing tank for spraying into the field. 16. All chemical containers must be returned to the chemical bond for re-cycling or disposal 17. Those applying pesticides must be properly supervised and have adequate rest periods. 18. All clothes must be washed at a central point near the chemical bond. 19. A marker must be placed in a treated field. AIRCRAFT APPLICATION OF PESTICIDES Precautions :- • All ground crew must wear full protective gear • The pilot must wear appropriate protective clothing • All spray equipment must be thoroughly washed after usage. All wash waters will be collected for decontamination at the Sentinel treatment plant –Ogle Aerodrome or applied to non crop areas of the cultivation if appropriate and useful • Partly used chemical containers must be returned to the store • Empty containers and surplus or waste products must be disposed of safely. • At the end of spraying all persons involved must shower and change into fresh clothes. Planning precautions 1. No application will be done in the designated "no-fly" zones i.e. no application will be targeted to blocks at theboundary of the estate or within three fields of the extreme north-and-south of estates. 2. All power lines, trees and other obstacles to the flight path are clearly marked on the work maps. Page 71 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 71 3. Clearly identified dumping zones for each operation the application to be agreed with estate and aircraft management. These must be delineated on the operation maps GUYSUCO GUIDELINES FOR AERIAL APPLICATION OF AGROCHEMICALS GENERAL These guidelines contain the information needed for the planning, preparation and execution of Aerial Application of Chemicals and Fertilizers to sugarcane. PLANNING AND PREPARATION Estates when deciding on work areas must take the following into consideration:- (a) Safety of personnel, livestock and property in the vicinity of the area of operations, (b) Possible deleterious effects on water supplies and crops other than sugarcane or surrounding vegetation of the chemicals to be used. (c) Possible annoyance and noise to people and livestock. (d) Presence of flight obstructions such as masts, electric cables and trees. Having decided on the work areas estates are required to submit their maps and worksheets to the Agriculture Research Director, for approval a minimum of one week in advance of the date of the intended application. OPERATIONS Estates must ensure that their airstrips are properly maintained at all times and that this includes the display of a functional windsock. When fertilizers are being applied estates are to ensure that the fertilizer loader is at the airstrip with the required amount of fertilizer to complete the programme. In like manner adequate supplies of water and chemical must be available at the airstrip for spray operations. The Estate’s Field Department is responsible to ensure on the day prior to the start of operations the boundaries of the individual blocks to be sprayed/ fertilised are clearly delineated with flags. Flags are composed of flourescent orange or red material and are mounted at a height of at least 5 m. c Personnel are not permitted in the treatment Blocks during the aerial operations. A minimum boundary of 750 m (200 rods) is maintained outside of the operating area ,within which no person is permitted, is stipulated for all aerial operations Page 72 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 72 Before commencing operation the pilot will conduct a reconnaissance of the areas to be spayed to ensure that the guide flags are clearly visible and correctly placed. Way-points for the Satloc operation are fixed during the actual spraying. Estate Field Department personnel must be aware that the aircraft swath width for: Solid Fertilizers is 14.6 m Liquid herbicide, ripener and growth regulators is 18.3 m ( Piston) Liquid herbicide, ripener and growth regulator 27.4 m (Turbine) The productivity of the aircraft for operations is to be budgeted at Solid Fertilisers - 40 has per hour flying time Herbicides, ripeners, growth regulators 115 has per hour flying time /hour flying time Insecticides are not under any circumstance applied by air to Guysuco’s cultivation. All applications are flown in a straight line from one end to of a block of fields to the other end of the block parallel to the longest edge of the block. AIRCRAFT DEPARTMENT 1. The Chief Pilot/Pilot will have in his possession a map and worksheet illustrating all obstruction data and potential dumping zones to enable him to do an initial site assessment. The pilot will review all possible problems with the Field Manager at the airstrip prior to the commencement of operations. It is essential that the Field Manager or his Senior A.F.M. and not a junior manager, conduct this review. 2. It is the responsibility of the Aircraft Department to ensure that the requisite oils, fuel, support equipment and personnel are in place at the location. 3. The Aircraft Department ground staff will be on location one day before work is scheduled to commence to confirm the status of the airstrip and the state of readiness of the estate. PROTECTIVE CLOTHING AND FIRST AID 1. All personnel involved in aerial applications must at all times during the operation wear the appropriate protective clothing. 2. It is the responsibility of the Estate and the Aircraft Department to ensure that their respective personnel are in possession of the appropriate protective clothing. When chemicals (not including fertilizers) are being applied the flagmen must be provided with “Kleenguard” disposable overalls as well as the usual boots, gloves and hats. For fertilizer work the standard “Protecto” cotton/polyester overall is required together with boots, gloves and hats. 3. The estate must display at the site of operation information about the types of chemicals, handling precautions quantity of chemical and total volume to be applied per acre and type of spray equipment to be used. Page 73 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 73 4. If chemicals are changed during the course of an operation the aircraft hopper and spray equipment are flushed with copious quantities of clean water before the second set of chemicals are added. 5. There must be supply of clean water for emergency decontamination at the airstrip. The water from the clean water container must not be used for mixing any chemical. 6. A first-aid kit will be provided in the aircraft and in the ground support vehicles. The estate must arrange for a first-aid kit at the airstrip. As with all chemical use the Estate Medical Officer must be advised in advance of operations to ensure that any needed antidotes are to hand. This is especially important in the (unlikely) event that an insecticide is to be sprayed. EMERGENCIES AND MISHAPS 1. It is the responsibility of the estate to have comprehensive standing instructions on action to be taken in the event of flag and crash emergencies, or mishaps with chemicals such as dumping and accidental spraying. Matters to be covered included: (a) Procedures for emergency dumping at any time during the flight, preferably with a dump site identified. (b) Crash/rescue procedures and provision of rescue, fire fighting and first-aid equipment at the estate airfield. (c) Arrangements for emergency communications with Police, Fire and Ambulance Services. (d) Methods of isolating and neutralising poisonous chemicals when dumped from the air, spilled during ground handling or in aircraft crash. (e) First-aid to be applied in the event of suspected poisoning. This information is available from the Agrochemical First Aid Poster, a copy of which must be on hand at the airstrip together with the needed first aid equipment. COMMUNICATIONS 1. Aircraft Department personnel at the airstrip will have ground to air communication with the aircraft. 2. The Field Manager’s representative at the airstrip must have communication with Estate Control Centre by radio. 3. Field management representatives should be stationed at appropriate strategic points of the cultivation with radio contact to the airstrip to monitor progress and to enforce precautionary Page 74 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 74 rules with respect to restricted access to the area during the conduct of any aerial pesticide application 4. Aerial application on estate will be under the direction of the Field Manager or his representative. However, it must be made clear that in matters of aviation safety the Pilot has the overriding authority 5. The estate must advise neighbouring householders or farmers of the planned operations wherever there is a possibility that the operations may impinge on them. DISPOSAL Pesticides are intended to kill the target species. In the use of pesticides, it is inevitable that some wastes are produced and the disposal of these must be managed in a manner that is safe to humans and the environment. All efforts would be made to avoid and limit the volume of waste and this will reduce the problem of disposal. Under the best of circumstances, there are problems with unwanted stocks which sometimes have to be discarded and disposed of in a safe way. Unwanted stocks can be accumulated by:- • Overstocking - not likely in GuySuCo since purchases are defined by budget requirements. • Poor quality products - not likely in GuySuCo since product specifications are prepared for high quality material. • Product use approval withdrawn - not likely to happen • Lost drum labels and stock records. • Excessive storage periods - resulting from lower pest incidence, loss of efficacy. GuySuCo follows a number of basic rules to avoid this type of problem and this includes an inventory every six months. Disposal : When waste dose occur it will be disposed of by methods which: 1. Are safe for those handling the waste. 2. Leave any contaminated areas or object clean 3. Minimize the risk of environmental contamination. The disposal procedures will depend on the origins of the waste and these may be classified as follows:- 1. Unusable products from old stocks or leftovers that are no longer needed. These waste concentrates may be surplus to requirements, out-of-date with respect to shelf life, have had approval for use with drawn or have degraded containers. The system in place will produce no waste but if it occurs then the products will be returned to Central Stores for disposal by sale or return to the manufacturer. 2. Spillage and leaks and the materials used to contain these. Full PPE will be used. The usual procedures will be followed, (i) Keep all unauthorized persons away. (ii) Stop leak. (iii) Dry waste - use dry sand or earth and sweep-up/shovel into a sealed sack for subsequent disposal. (iv) With liquid waste use lime, sand or earth or bagasse to soak up the spillage. Shovel these in closable containers for subsequent disposal. (v) Wash the contaminated spillage area with water in the presence of sodium hydroxide, lime or an industrial detergent. Washings will be treated as liquid waste. 3. Contaminated objects such as protective clothing - will either be washed or cut-up and burned or buried. Page 75 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 75 4. Unused spray mixtures and washings of application equipment. Dilute wastes and washings are disposed of by applying them in field or in a useful way. 5. Containers and packages such as drums, cans, bottles and bags. These are never reused except in special circumstances such as to transfer an identical pesticide from a deteriorated/leaking container. Disposal Practice Once pesticide wastes have been collected, then the alternative methods of disposal are used. These are by; i) Incineration ii) Burial - in a land fill site previously identified. These areas are sited to avoid seepage to water courses or contamination of drinking water. They are also deep enough with the site fenced and labelled to prevent intrusion by animals. MANAGEMENT OF EMPTY PESTICIDE CONTAINERS All pesticide containers and packaging must never be used for any domestic purpose. All containers are destroyed as soon as the contents have been completely used. General principles observed for container and package disposal. • Before disposal containers and packages are completely emptied and thoroughly cleaned. Dry materials are shaken out thoroughly into the mixing tank and plastic containers are triple rinsed. • Liquids are drained from containers (drums, cans, bottles) which are triple rinsed and the water added each time to the mixing tank. • After cleaning, all the containers are immediately punctured to make them unusable. The cleaning operations are overlooked by a Supervisor who also ensures that the cleaned packages are returned to the Estate store. The Estate store will then ensure that the packages and containers are returned to the Central Stores at Coldingen for destruction. • Records are kept of all containers/packages sent to and received by Coldingen where the procedure will be as follows: i) Rinsed metal containers are crushed in the drum-crusher and ii) The plastic and paper/cardboard containers are shredded in the Shredder iii) The crushed or shredded material are returned for burial at the designated land fill site at the Estate. The use of water soluble packaging in future will also reduce the scale of pesticide container management. AQUATIC WEED CONTROL Aquatic weeds in GuySuCo are important because they affect drainage, irrigation and transportation. The major aquatic weeds at Skeldon are Cabomba aquatica , Pistia stratiotes (Water lettuce) and Salvinia auriculata . Aquatic Weed Control is done manually by a special gang of persons who do repeated cleaning to effectively maintain the system. It is envisaged that the same system will be used in the Skeldon Expansion Programme. In the event that there is need for chemical control of aquatic weeds, there are USA EPA approved herbicides such as Sonar (Fluridone) and Rodeo (Glyphosate) which can be used. Both products were tested in GuySuCo and are approved for use. Manual control is currently generally more economical Page 76 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 76 $33(1',;\03\03'\03 *8<68&2\03,17(*5$7('\033(67\030$1$*(0(17\03>,30@6<67(0\03\03 \0bH[WUDFWHG\03IURP\03´6603\03)LQDO\03(QYLURQPHQWDO\03,PSDFW\03$VVHVVPHQW\035HSRUW\03SUHSDUHG\03E\\03 *URXQG\036WUXFWXUHV\03(QJLQHHULQJ\03&RQVXOWDQWV\03/WG\0c Page 77 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 77 INTEGRATED PEST MANAGEMENT AND INSECT PEST CONTROL INTEGRATED PEST MANAGEMENT As early as the 1950s pest researchers recognized the problems inherent in the reliance of a single pest control technology such as pesticides. This is not to suggest that pesticides did not or do not work and are not solving pest problems. On the contrary they do, indeed, work well in most cases and that is the main reason why they are still widely used today. However, the development of pesticide resistance in pests, concerns over environmental issues and human health, the emergence of new pest species, often as a result of over-indulgence in pesticide employment, and the ever- increasing costs of a shrinking arsenal of chemicals have prompted the re-evaluation of integrated pest management (IPM) concepts and the increasingly widespread adoption of IPM practices for pest control. Integrated pest management is a conceptual approach to pest control which deals with strategy rather than specific and exact methodology. This flexibility and adaptability are the strengths of the concept which may be most basically defined as "the balanced use of such measures, cultural, biological and chemical as are most appropriate in light of a careful study of all of the factors involved". The IPM approach is to use a series of tactics to reduce, but not necessarily eliminate, pest populations. Pesticides are applied as part of the overall strategy only after all other relevant tactics have been deployed or when their need is justified by knowledge of pest biology, established decision guidelines and the results of field surveys for pest populations. Ideally, IPM programmes consider all available management options, including taking no action. The key element in IPM systems is the concept of a "threshold level" which is the pest population density at which control measures must be applied to prevent an increasing pest population from reaching the point where crop loss would exceed the cost of control. Crop damage is tolerated until the threshold is reached. It is clear that IPM requires that surveys be carried out regularly for pest life-stage populations and for damage to the crop in order to determine whether or not the threshold level has been reached, or is likely to be reached. The survey procedures for the important pests of sugarcane in Guyana are described in detail below and it should be noted that in some cases the threshold is defined in terms of life stage populations whereas in others it is defined in terms of crop damage. It is anticipated that in the latter cases further research will enable the thresholds to be established in terms of pest population as the idea is to be able to prevent damage rather than to take action after damage has occurred. Although the determination of a control action threshold requires knowledge of pest biology and crop physiology as they relate to the particular agricultural environment, of naturally occurring biological controls and the effects of possible control action it is, in practice, more usual to set a threshold based on field experience and to refine this as the results of the IPM procedures become apparent. The current range of IPM tactics available to GuySuCo is already formidable and will become even more so as the results of several far-reaching research programmes begin to be applied in the field. The industry can, and does, employ fallow periods, predominantly with flood fallow but, it is expected, with green manure fallow on an increased scale on soils not suited to flooding, deploys resistant varieties of cane for disease management and anticipates such development for insect and rodent pest management, manipulates harvest dates, utilizes cultural practices such as flood irrigation and crop residue removal and actively pursues biological control procedures by the breeding and release of indigenous and exotic natural enemies of insect pests. Indeed, given the range of options, either alone or in combination that are already available and on the not unreasonable assumption that others will become available it is now GuySuCo's policy to aim for an Page 78 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 78 insecticide-free agriculture or at the very least an agriculture in which an insecticide, preferably a highly specific insecticide, is used only as a last resort in a clearly defined situation and only then after a review of the case by the Head of the Plant Protection Unit and with the approval of the Agriculture Director. SOME PRACTICAL CONSIDERATIONS Surveys Surveys determine not only the presence of a pest but also its present and potential damage capability and the extent to which these are likely to be limited by the presence of natural enemies. Surveys can be aided by previous knowledge of the pest's seasonality, of historically endemic areas and of conditions which predispose the crop to attack. Surveys not only define the problem but also help determine how effective any control measures which have been introduced may have been. The survey data should be assessed in terms of likely economic losses and available effective control possibilities: Pest Population/Crop Damage Level Effective Pest Control Method Not Available/ Available Non-Economic No Action Needed /No Action Needed Economic No Action Possible/ Action Required Only where there is known economic loss, or potential for loss, and an effective control method is available should any action be taken. In the majority of cases no action is needed as in the cases of leaf-eating caterpillars and thrips ( Fulmekiola serrata ) where the "pests" cause apparently spectacular damage to the crop but the damage does not result in economic losses and no control measures are required, even though a range of effective insecticides is available. Those insect pests which are known to cause significant economic loss to sugarcane in Guyana are described below, together with the relevant survey procedures, threshold levels for action and the recommended control procedures. Detailed survey procedures for assessing pest damage are available. However they have not been included in this document. Blocks The introduction and extension of rational blocking systems has simplified pest control systems and will continue to do so as further refinements to present management blocks are introduced in response to the requirements of the chemical ripening programme. Wherever possible, pest surveys, and control operations, should be planned on a block, rather than individual field, basis. Field Hygiene and Sugar Cane Variety The single most effective pest control strategy is to grow a resistant or tolerant cane variety in a weed-free, well drained field surrounded by a well managed, clean canal and road system. Many pests are encouraged to enter fields by the presence of weeds that are required for their breeding while others can find refuge from control measures in unkempt surroundings from which they may invade the cultivation. In the case of a cane disease resistant varieties are usually readily available, or may be selected fairly rapidly in the knowledge that the resistance reaction is stable. In contrast it is usually a much longer Page 79 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 79 process to develop a pest-resistant or tolerant variety and the resistance or tolerance may not necessarily be stable or absolute. Other considerations being acceptable, however, it is always better to seek even a minor benefit from the extension of a relatively resistant or tolerant variety than to forgo that benefit. PROBLEM WEEDS Antidesma ghesaembilla LOCATIONS : ENMORE, LBI, BLAIRMONT Special surveys must be done in all affected blocks within one month after planting or harvesting and repeated monthly until cane covers over. Treatment In plants to 4th ratoons, treat with Ally + Frigate at 5 grams in one 4.5 L of water on plants approximately one foot (30 cm) tall.The plants are normally wet up to the point of dripping and 15 - 20 plants can be treated with one gallon of spray. Replanting When infestation is greater than 20 plants per acre then fields must be flooded for control. Flood fallowing for 6 months has been very effective. Flooding is done in the usual way but any re-growth of Antidesma plants must be fully submerged. Tordon 101 is the alternative chemical for Antidesma control. Tordon is sprayed on the freshly cut stem at about 5cc per one 25 mm diameter of stem. Panicum maximum ( Guinea grass ) LOCATION : LBI, ENMORE The best form of management for this weed is to prevent seeding in the short term and aim at eradication from within the cultivation as a long term strategy. For post emergent control, the treatments recommended are: Round-up + Frigate at2.7L +2.7L/ ha) in non crop areas and Velpar at 400g/ha at (2.9 L/ha in crop areas as a directed spray. Echinochloa polystachya and E . pyrimidalis ( Missouri and antelope grasses ) Integrated control is recommended. Areas with mature weeds should be sprayed with Arsenal at 4.0 L per ha . When the weed is in the medium post emergent stage (approximately 30 cm high for best results) it should be sprayed with Arsenal at 4.0L) per ha or alternatively with Asulox + Ethokem at (6.6 L) + 1.4L)/ha. All affected areas in which the weeds have been killed can be planted with Leersia hexandra (fine or savannah grass) as a replacement species. All newly excavated areas must be planted with seeds of Leersia hexandra Rottboellia cochinchinensis ( Itch grass ) LOCATION : WALES Eradication : All efforts must be aimed at eradicating this noxious weed from in and around Wales Estate. Regular surveys to determine the presence of the weed before and after control must be carried out. In affected areas due for tillage, the weed must be controlled before tillage to avoid spreading the seeds. Seeds should be allowed to germinate and emerge before treatment with Round up + Frigate Delayed planting can also be done to allow repeated treatments in the affected areas. Page 80 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 80 Post-emergent control When the weed is in the medium post emergent stage and actively growing apply Dual 960 E + Igran 500 FW at 1.4L + 2.6L per ha The practice of manual roguing of Rottboellia plants should be done only as a last resort although diligent farmers who have small plots can use this method effectively. Asystasia gangetica ( Aloo weed ) LOCATIONS: LBI/GD AND WALES - CROP AREAS Blairmont (non crop) This weed has been targeted for eradication from within the cultivations at LBI/GD and Wales Estates. Early - post emergent control should be done using in combination with 2,4-D amine in all affected blocks regardless of crop cycle. Post-emergent control using 2,4-D amine must be carried out before mature seeds are produced. The number of post-emergent treatments will be determined by surveys since the number of flushes depend on weather conditions. Wild Ginger ( Curcuma Sp ) LOCATION: UITVLUGT AND ENMORE. Post-emergent control of this rhizomatous perennial weed must be carried out before tillage by applying Tordon 101 as a foliar spray. Experience at ICBU has shown that harrowing can cut the rhizomes and spread them throughout the field. This has been an effective form of propagation and should therefore be avoided at all costs. In areas where delayed planting is done (eg pegasse soil) the emerged weed can be treated before planting. Post-emergent control should be with either Tordon or Asulox as foliar sprays. Flood fallowing has been very effective in controlling this weed, particularly when Diuron has been added to the flooded area. Brachiaria radicans ( Tanner grass ) LOCATION: UITVLUGT, WALES, L.B.I. AND BLAIRMONT ESTATES This is an aggressive member of the para grass family which thrives under semi-aquatic conditions. Propagation is by stem cuttings. Best control can be achieved with:- (a) Asulam 40 + Ethokem at 5 pts (2.8 L) + 1pt (0.6L) per acre when the weed is actively growing or about one foot (30 cm) tall. (b) In non-crop areas, such as canal edges, sideline slopes, etc. with Fusilade at (0.7L)/ha or Arsenal at 4.2 litres)/ha . A tank mix of Roundup Ultra (at 1.4 L /ha and Arsenal at 2.1 L/ha is a cost effective alternative. Sporobolus indicus ( iron grass ) LOCATION : ALL ESTATES This perennial grass is difficult to control with foliar acting herbicides because of the narrow leaf blades. Best control can be achieved with Arsenal as a foliar and basal treatment. Basal treatment is when the roots are treated. The spray lance is directed to the base of the stem and a fixed quantity (equivalent to the foliar) is applied. Imperata brasiliensis ( June or juk grass ) LOCATION : ALL DEMERARA ESTATES; ROSE HALL Page 81 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 81 This rhizomatous perennial grass can spread vegetatively. It should therefore be controlled before tillage. Some control can be achieved by desiccation of rhizomes after tillage. It is als This weed is effectively managed by improving the soil pH value since the weed thrives on acid soil. In extreme cases the cane row can be treated in this way and the inter-row with herbicides. The herbicides that control the weed are not selective. Best control is achieved when the plant is storing food. Chemical control is recommended when the weed is approximately one foot (30 cm) tall. The recommended treatments are Round-up plus Frigate at (2.4L +2.4L)/ha or or Arsenal at (4.2L)/ha. Bamboo ( Bambusa Sp ) LOCATION: UITVLUGT This weed is extremely difficult to control. The only method is by sterilising the soil. This can be done with Velpar at 135 g) per square metre as a basal treatment. CHEMICAL WEED CONTROL IN PLANT CANE In plant cane those fields planted from flood fallow will require a different pre- or pre/early-post- emergent chemical weed control programme from that required for fields planted after less than six- months under water or from plough-and-plant. Flood-Fallowed Fields Fields with a good flood fallow will NOT require any pre- or pre/early-post-emergent treatment. Fields with weeds on bed tops as a result of uneven or poor submergence or disturbed/discontinuous fallowing may be treated:- a. During fallow - by application of Diuron 80DF/2,4-D Amine. b. After blowing and before planting - by hand weeding. c. After blowing and after planting - by application of Glyphosate/Frigate not later than seven (7) days after planting commenced. d. By Post-Emergent treatments as per plant cane (see below). Fields that are Plough-and-Plant or Less than Six Months Under Water. Pre-Plant Incorporation (PPI) for Plough-and-Plant Fields Pre-plant incorporation is not to be practiced on pegasse soil or on any non-pegasse soil in which there are no serious grass weed problems. Thus PPI is only to be employed on plough-and-plant fields with clay or silty clay or sandy soils and in which there is a history of serious grass weed infestation. On fields where PPI may be carried out then trifluralin (Treflan or Fluron) or pendimethelin (Prowl) are to be incorporated into the soil during the final harrowing of the tillage sequence. The use of Prowl will only continue until all remaining stocks from the discontinued "other crops" activities have been completely exhausted. Prowl is to be used at 3 pints (1.7 litres) per acre. Once present stocks of Prowl have been exhausted then trifluralin formulations will be employed for PPI treatment. Good quality land preparation and timely incorporation to the recommended depth is essential for good weed control with both herbicides. The herbicide is not to be buried too deeply and incorporation may be best achieved with light discs or even tynes. Land treated with either trifluralin or pendimethelin is not to be placed under water for any prolonged period but may be flooded for up to 48 hours if necessary to establish the crop. Pre- (Weed and Cane) Emergent Control. It is assumed that 50% of the plant cane on non-flood fallowed land will receive a pre-emergent residual chemical treatment while the remaining 50% will receive a pre/early-post-emergent treatment. the recommended pre-emergent treatment Merlin (Isoxaflutole) at 141g /ha with Diuron at 1.1 kg/ha Page 82 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 82 Pre/Early-Post Emergent Control The recommend chemicals pre- early post control would be s-metolochlor (Dual gold)at 0.62 liter/ha with terbutryn (Igran) at 2 L er ha. In areas with known histories of infestations of broad leaf weeds and Cyperus sp, Igran at 4 L er ha with 2,4 amine at 1.3 L per has and metsulfuron methyl (Ally) at 6g per ha should be applied. Application would be by knapsack sprayer, tractor mounted boom-sprayer or for larger available blocks where timing is not an issue by aircraft.Repeat applicationsof pre/early-post emergent herbicides usually call for some explanation. However, two applications of pre/early post emergent herbicides can be justified on up to 10% of the plant cane on the Demerara estates only where the first round was affected by rain or there is a second flush of weeds due to heavy weed pressure in historically weedy blocks. Post-Emergent Control In an effort to reduce the amount of prophylactic treatments, greater emphasis will be placed on post- emergent weed control. As a result the types of weed and stage of growth must be determined prior to application. The importance of inspection/survey before treatment is emphasised will also determine the type of herbicide and method of application. Estates should budget for applications of:- (a) Asulam + Ethokem and 2,4-D Amine on 25% of the area of plant cane, irrespective of planting procedure. (b) Terbutryn + 2,4-D Amine on a further 15% of the acreage of plants. The best results are obtained from (b) between the early-post emergent stages of weed growth. In cases where there is a second weed flush then Terbutryn or Gramocil can be applied when weeds are 6" (15 cm) tall. CHEMICAL WEED CONTROL IN RATOON CANE It is anticipated that only a small, and declining, fraction of the ratoon cane area will be at the fifth, or older, ratoon class. These areas will receive lower cost chemical treatments than the more productive first to fourth ratoons. Pre-/Early-Post Emergent Control All ratoon weed control with residual chemicals is to be considered as a pre/early - post emergent control and all application must have been completed within 14 days of previous harvest. (a) 1 Ratoon to 4 Ratoon Merlin + Diuron to 35% of the area (all locations) Dual + Igran or:- } for all locations Diuron + 2,4-D Amine (Diamond, Wales and Uitvlugt only). To ensure that the possibility of herbicide resistance developing in the weed species is reduced it will be preferable for All Berbice Estates, Enmore and LBI to plan on treating one-third of the 1 to 4 ratoon area with each of the three mixtures recommended for all locations. (b) 5 Ratoon and Older Budget at all locations only for the use of Diuron + 2,4-D Amine. It is not anticipated that such treatment will be required in all of these fields but it may well be useful for fields reaped towards the end of the crop and which are to be ratooned. Post-Emergence Control (a) 1 Ratoon to 4 Ratoon As per plant cane post-emergence control. Page 83 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 83 AQUATIC WEED CONTROL Manual control is to be preferred on all locations because the water may be used for domestic purposes and because the use of herbicides has caused some discomfort to workers who subsequently do manual control. Indeed, the aim should be as little manual weeding in-field as possible and as little chemical weeding in water systems as possible. Manual control of aquatic weeds is an effective procedure. The zoning system at Skeldon and Rose Hall has been very successful over the years. Other Estates are encouraged to put this system in place The only possible problem may be the build-up of floating aquatic weeds such as Salvinia auriculata and Pistia stratiotes . On Demerara Estates Cabomba aquatica is the major problem in the sidelines. Manual cleaning is not effective and these estates should budget for one round of chemical treatment during each of the two dry seasons with 2,4-D acid or amine applied to all affected sidelines at 1 ppm in the sideline water. Resurgence can then be managed by a combination of manual/chemical methods. The method for calculating the quantity of chemical to be used requires a knowledge of the length, breadth and approximate depth of the waterway to give the volume of water to be treated. This is best calculated on a metric basis but if this is not possible then as a rule of thumb a 100 rod section of 5.5 m wide and 1.2m deep canal requires 1.4 kg of a chemical to give a 0.5 ppm concentration. For the semi aquatic weeds, Antelope, Missouri and Tanna grasses apply Asulox or Arsenal and plant Leersia hexandra as a replacement species. Leersia must be planted on all newly excavated sidelines and middle walks where there is a threat by Antelope grass. FLOOD FALLOWED FIELDS Diuron plus 2,4-D Amine may be used for broad spectrum control of aquatic weeds in flooded fields at the rate of 0.5 to 1 ppm for each chemical. It is important that the chemical is introduced into the water, particularly in the case of Diuron which is taken-up by the plants' root systems. Calculate the amount of chemical required on the basis of field area and water depth. Again, metric calculations are to be preferred for the sake of simplicity. HAND WEEDING This method of weed control has advantages and disadvantages. It can prevent seed production and reduce the level of obstacles (especially vines) at harvest (although the use of chemical ripeners appears particularly effective in this latter respect). On the other hand it is not usually considered as an especially beneficial practice since the crop will have already suffered from competition and some perennial weeds may even be propagated by hand-weeding. The quality of hand weeding may be unsatisfactory at some locations, especially in uneven plant fields, excavated dam beds, and wet conditions and is always difficult to supervise properly. This operation should be gradually replaced by more efficient methods and a reduced gang maintained on all locations to take care of situations where spot hand- weeding or roguing or rain affected control is necessary. CULTURAL METHODS Management should plan to incorporate non-chemical methods of weed control into their respective programmes. Burning is perhaps the cheapest method and can be carried out on all perimeter dams Page 84 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 84 once a year or after harvest when the adjacent canes are still young. The benefits include improved sanitation and removal of unwanted species. Other cultural methods include - Screening Irrigation water - Planting and harvesting during the dry - Selecting varieties that canopy early - Liming to change soil pH - Improve drainage - Timing of Irrigation and Fertiliser application. In addition, attention can be given to Ecological and Biological Control by the use of Vetiver grass as a physical barrier to the development of other species in non-crop areas and of Leersia hexandra as a replacement species. DISEASES AND DISEASE MANAGEMENT MAJOR AND MINOR DISEASES Major sugar cane diseases which have been identified in Guyana are: Disease Common Name Causal Organism Type of Pathogen Smut Ustilago scitaminea Fungus Common Rust Puccinia melanocephala Fungus Yellow Spot Mycovellosiella koepkei Fungus Leaf Scald Xanthomonas albilineans Bacterium Minor diseases which may be observed on occasion are:- Disease Common Name Causal Organism Type of Pathogen Pokkah Boeng Fusarium moniliforme Fungus Pineapple Disease Ceratocystis paradoxa Fungus Red Rot Glomerella tucumanensis Fungus Ring Spot Leptosphaeria sacchari (?) Fungus Sheath Rot Cytospora sacchari Fungus Basal Stem and Root Rot Marasmius plicatus Fungus Eye Spot Drechslera sacchari Fungus Red Spot Dimeriella sacchari Fungus Chlorotic Streak Undetermined poss Virus(?) Disease Management All diseases will continue to be managed by the extension of varieties with acceptable levels of resistance. This does not mean that only immune or highly resistant varieties are to be extended as it takes a considerable effort to develop a commercial variety and it certainly makes no sense not to extend an otherwise acceptable cane because of moderate susceptibility to a major disease or even a high degree of susceptibility to a minor disease. It is very important that staff develop a rational attitude to sugarcane disease, particularly those, such as Ring Spot or Pokkah Boeng, which are visually spectacular but seldom, if ever, cause any measurable yield loss in modern varieties. Indeed, even a disease such as yellow spot is easily managed in, for example, Mauritius and Australia, simply by extending the growing period of the affected crop by 4 to 6 weeks and such should be the approach adopted by GuySuCo in most situations where these symptoms occur. It may be necessary on occasion, particularly in seed cane areas, to rogue for smut Where this operation is carried out then every effort must be made to not only rogue out the mature whips but also, indeed particularly, the incipient whips rather than allowing whip development to proceed to the spore shedding stage. No estate is to apply any fungicide other than for seed cane exchange or for experimental purposes without prior consultation with the Agriculture Research Director and the Head – Breeding and Variety Selection.. Page 85 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 85 MANAGEMENT OF INSECT PESTS The presence in the cane field of many of the insect species listed in TABLE 31.2 will not normally call for any action on the part of management other than initiation of measures, such as weeding or fertilizer top-dressing, to allow the crop to recover rapidly from any damage. This will especially apply to leaf-eating caterpillars, armyworm, grasshoppers, aphids, thrips, mealy bugs, leaf-eating beetles and shot-hole borers all of which cause little damage of economic consequence and none of which are to be sprayed with any insecticide except under controlled experimental conditions and even then only in cane at age 10 weeks, or less. It is policy that no insecticide will be applied to cane at 11 weeks, or more, of age and this means that no insecticides are to be applied by aircraft. In addition no insecticides are to be applied by mistblower, either tractor-mounted or man-carried. Those insect pests for which it may still prove necessary to deploy an insecticide on occasion are shown in TABLE 31.2 which also summarizes the management techniques to be adopted for those pests for which insect deployment is inappropriate. The important pests, Diatraea spp, Castniomera licus , Aeneolamia flavilatera and Metamasius hemipterus are discussed separately in Section 31.5 (below).. It is clear from analysis of field survey data from the past three years that termite nest densities are usually low in plant to 4 ratoon cane and increase at 5+ ratoons. Simple manual destruction is all that is required in plant to 4 ratoon cane with insecticide use commencing in those fields that are carried beyond the 4 ratoon class. Obviously, if the replant target of cane area per annum is consistently achieved and if the fields with above average termite nest densities are subjected to flood fallowing prior to replanting then termites will become even more unimportant than they are at present. In the cases of leaf eating insects, particularly of leaf-eating caterpillars, there is a wide range of natural enemies that rapidly reduce pest populations to their usual, low, levels with the result that the damage to the crop is caused by a single generation of the pest only. The use of insecticides will certainly interfere with the development of the natural enemy populations and may, in consequence, allow for an extended period of crop damage over and above that which would otherwise have obtained. The best management technique for a defoliated, or partially defoliated field, is to ensure that it is kept weed-free to reduce the stress on the crop as the canopy is restored. This may require some use of a pre-emergent herbicide or may simply be achieved by the use of a quick-knock-down post-emergent spray. Each case will need to be assessed on its merits and if there is any doubt that the course to be followed then management should not hesitate to consult with the Agriculture Research Centre Page 86 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 86 TABLE 31.2 PEST CONTROL PROCEDURES Insect Pest Action Level Control Diatraea spp 5% Joints Bored Mass Release of Cotesia flavipes to damaged fields. Castniomera licus 2.5 - 3.5% of stalks population bored > 10% stalk population bored Flood field and hold water for 48 hours. Spray ratoons with Ethrel and apply additional 1cwt/acre Diammonium phosp hate. Plough out and flood fallow for replanting. Froghopper -nymphs adults 0.5 nymph/stool 10% stalk infested Inspect and improve infield drainage. Apply metarhizium inoculum Leaf Eating Caterpillars Not known. Severe damage more likely at start of rains than at any other time of year. No action except to weed field thoroughly after attack to reduce weed competition while canopy canopy. Apply urea at up to60 kg/ha Cut Worms (Spodoptera sp) Not known but are more likely to be found in plant field on flood fallowed land than anywhere else Flood field and hold water for 12 hours for ungerminated setts or very young tillers. Supply at need. For older tillers as for leaf eating caterpillars. Aphids Not known - No Surveys Required No action Hard Back Beetle (a) grub (b) adult Probably 1 grub/stool or more Not known Flood field and hold water for 48 hours. Termites Not known - Survey for nests/acre immediately after harvest. Destroy nests at post- harvest trash burning. Spray nest sites with Fipronil at 700 ml/ha Rotten Cane Stalk Weevil Not known Cane setts soaked in 4% Fipronil suspension (mainly for survey Page 87 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 87 MANAGEMENT OF MAJOR PEST SPECIES SMALL MOTH BORER Diatraea spp (Lepidoptera: Pyralidae) Stem and stalk borers are major pests of sugarcane throughout the world. The major problems in the new world industries are Diatraea species. In Guyana Diatraea saccharalis , D.centrella and D.impersonatella have been identified. D. centrella and D.saccharalis are the dominant species. Control Budgetary provision must be made for maintaining an Insectary, including Insectary assistants and field hands for collecting host larvae, releasing parasites and conducting recovery surveys. This work is the responsibility of the Estate Agronomist. Parasites are to be released to a field or block of fields, when surveys indicate joints bored at 5% or more, irrespective of the age of the cane. The current parasite being reared and released for Diatraea control is Cotesia flavipes . This has established itself to above 20% in the sugar estate cultivation. GuySuCo has evaluated s the pupal parasite Pediobius furvus in addition to Cotesia . However this potential parasite was shown to be a hyperparasite of the Amazon fly, the established parasite for Diatraea saccharalis. The programme was not continuef It should,also be noted that the Amazon fly (Metagonistylum minense) the most important parasite of D. saccharalis in Guyana was introduced to Guyana from Brazil and is considered to be a classic example of successful biological control. Previously attempted Allarhogas release programmes have been be discontinued but recovery surveys at previous release sites continue ad infinitum for this parasitoid. Current efforts emphasise the assessment of indigenous species for possible potential in biological control. Other Management Considerations In addition to the biological control programme every effort should be made to manage Diatraea population by manipulation of the harvest programme with particular attention paid to the early harvesting of cane at 9 month of age and which has 10 percent, or more, internodes bored. Management is asked to be alert to the possibility that varieties may differ in the extent to which they are attached by Diatraea and that certain areas of the estate may be more prone to suffer from severe attacks than others. The causes of those differences need not be known, it is the fact that they may exist which is important and may assist in pest management. Local knowledge of pest behaviour on each estate must be put to productive use when the annual variety extension programme is being reviewed the Breeding and Selection staff. GIANT MOTH BORER Castniomera licus (Lepidoptera: Castniidae) C. licus is, along with the savannah rat, potentially one of the most serious pest of sugarcane in Guyana and can cause severe losses if not identified and brought under control rapidly. Control By Flooding At 3.5 to 10% stalk damage flood the field for 48 hours. Enmore is to continue to use a reduced threshold level of 2.5% for flooding until the present outbreak has been brought under control. Fields with more than 10% stalk damage must be ploughed-out and flood fallowed prior to replanting.Fields which have been flooded for Castniomera control should be treated with Ethrel plant growth regulator at 940cm 3 _ per acre and Diammonium Phosphate (DAP) at 60 Kg per ha when the plants are 3 weeks old in addition to the routine fertiliser application. Page 88 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 88 Notes 1. The damage level refers to infield counts, not a combination of infield and dam bed counts. 2. "Flooding" for 48 hours in this context refers to 48 hours after the tops of the beds have been covered and not to 48 hours after the infield drains have been filled. The field should be flooded immediately after the survey if the damage level so indicates and should be flooded as quickly as possible using 2 - 3 irrigators. After the requisite flood period is finished, the water must be drained off as quickly as possible to avoid stool death. Provision must be made for fields to be surveyed after flooding to assess level of control as determined by larval and pupal mortality. Use the pre treatment survey method and check the rows adjacent to those previously surveyed. Other Control Options Although all varieties studied at Enmore have proved to be damaged by Castniomera larvae it was noted that the varieties DB 671760, DB 7047 and D 15841 suffered the least loss in tons sugar per acre per one percent of stalks damaged. With the exception of D 15841, these varieties are on the decline in the cultivation. However where varieties can be indicated to be less susceptible to damage by a particular pest, consideration must be taken account of in the distribution of the variety within a cultivation, particularly if the pest can be shown to have a bias for specific geographic situations As with all other pests the consequences of a severe attack may be reduced by the harvesting as early as possible of the damaged cane. This will also reduce the consequences of any secondary pest attack or disease development. Where there is evidence of poor ratooning following flooding the field may be sprayed with Ethrel plant growth regulator at 940mls product/ha when the shoots are about 30 cm in height to stimulate tillering. Where Ethrel is so applied the field must also be treated with 60 kg/ha diammonium phosphate in addition to any other fertilizer applied. SUGAR CANE FROGHOPPER Aeneolamia flavilatera (Hemiptera cercopidae) Froghopper damage has been restricted to Skeldon, Enmore and LBI/Diamond and in the latter two cases appears associated with sand reef soils. Full Canopy Cane In older canes (plant canes over 5 months and ratoon canes over 4 months) in particularly severe attacks of this pest, it is necessary to monitor the pest stages so as plan harvesting strategy or the use of Metarrhizium entomophagus fungus applications. Control Options There will be no insecticide spraying of any stage of froghoppers infestation . In cane at 9 months of age showing 10% or more stalk infestation the field must be harvested as early as possible and certainly must not be allowed to continue to 12 months of age given the expectation of progressive deterioration in the cane with age. Given that it is now intended to increase cane production at Enmore it is no longer possible to consider management of froghopper at this estate simply by the removal of sand reef soils from cultivation. Rather it will be necessary to manage the crop on these soils in such a way as to minimise the effects of the pest. Page 89 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 89 Green manure fallowing would appear, on the evidence to-date to give some relief from the pest to the succeeding cane crops and all fields planted to cane on sand reef soils should, therefore, be planted after a period of green manure fallowing . At the same time experience elsewhere with froghopper damage (particularly in Australia) suggests that it may l be possible to identify varieties that are either resistant to attack by froghopper life stages or are tolerant to the consequences of such attack, particularly as regards reaction to any toxin that may be injected to the leaf tissue at feeding. A number of variety trials have been established on the sand reef soils at Enmore with the aim of selecting out such resistant/tolerant varieties. Froghopper life stage populations have been low ever since these trials were established but obviously they will continue to be monitored. It is recognised that the single most valuable contribution to froghopper control at Enmore and LBI/GD would be an improvement to the drainage capability at each estate. The capacity of external drainage system in East Demerara has been improved with the implementation of a rehabilitation project to be supported via a loan from the Caribbean Development Bank. This project commened in 1996 and is now essentially complete. The occurrence of froghoppers has been of significance in recent years. . ROTTEN CANE STALK WEEVIL Metamasius hemipterus (Coleoptera: Curculionidae) Survey and Control These two operations are incorporated by placing three bud cane setts split longitudinally soaked in a 4% solution of Fipronil (Regent)in bundles of 5 setts at intervals of 10 rows along the dambeds and infield in fields known to have rat and/orn Castniomera damage. The bundles of split setts are tied by strings before soaking. These insect "traps" are examined at regular intervals (3 days) and the number of dead weevils counted. The traps must be replaced at two-week intervals if weevils continue to be caught. TERMITES Nasutitermis costalis and/or Nasutitermis corniger This species is a common, though minor pest of sugar cane in Guyana. Control The best control of N. costalis is the destruction of nests. If this can be combined with post harvest trash burning, the nests should be removed and burnt at drain edges or culverts along with trash. After removal of nest, nest sites must be treated with an environmentally safe and effective chemical. Control may also be effected by flash flooding 48 hrs. in severely infested fields or by flood fallow before replanting. RAT CONTROL Pest Description The major rodent species in sugar cane in Guyana is the savannah rat Holochilus brasiliensis BAITING Baiting must be done when % FSD 0.5 (i.e. equal to or greater than 0.5%) irrespective of cane class. Prophylactic baiting must be carried in areas known to be "at risk". This baiting is not dictated by fresh stalk damage but is done to prevent damage to areas of plants or prime ratoon canes at risk from migration from adjacent infested blocks. This is particularly important in young canes Page 90 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 90 threatened by rats migrating from harvested blocks and in canes at the estate periphery threatened by migration of rats from surrounding lands at the onset of the rainy seasons. HUNTING, BURNING AND HARVESTING Those estates with known rat problems must budget for adequate man-days for hunting. Indeed hunting must now be considered a year-round need on all estates with catch levels, even in the absence of FSD, guiding the introduction of prophylactic baiting. Provision must be made for an adequate fleet of hunting boats. Additional payment for circle burning must be addressed. Circle burning is the practice of setting the entire field periphery on fire simultaneously to prevent rats from escaping to other fields. Where a field of 9 month-old cane is, or has, been sufferingheavy damage (5% FSD) then it is better to harvest it at this age rather than endure another three months of primary and secondary damage before cutting the cane. Where it is known that rats move from the surrounding areas to the cane fields with the onset of the rains then consideration must be given to delaying the reaping of the boundary fields until very late in the harvest as the lack of cane canopy may discourage rat incursion until late in the rains. Clearly other considerations, including transport balance may have to be addressed but any estate at which rats present a severe problem must be prepared to consider some transient operational inconvenience to manage the problem. VARIETIES AND RAT MANAGEMENT Although all present commercial varieties suffer from rat damage data from variety trials and field observation suggest in areas suffering from severe rat attack that D 89138 and DB 7869 may be particularly attractive to rats. Caution should be practised in extending these varieties at estate peripheries or any area of the estate known to harbour rats Utimately, sanitation and prophylactic baiting of border areas will provide better protection from rodent invasions. VETIVER GRASS AND OTHER CONSIDERATIONS The establishment of Vetiver grass to stabilise road shoulders is encouraged ( and provision must also be made to establish Vetiver grass hedges along the "at risk" boundaries of the cultivation even in the absence of an all-weather road. It may be that the dense stalk population and the massive root development of this grass may discourage rat incursion across the boundary line. Estate should consider, too, the planting of trees along the estate boundary to encourage the nesting and/or roosting of predatory birds (as well as providing shaded areas for employees at rest) which may well feed on the rats. Page 91 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 91 $33(1',;\03\03(\03 *8<68&2\03%86+\03&/($5,1*\0363(&,),&$7,216\03)25\03&2175$&7256\03 \03 \03 \03 \03 \03 \03 \03 \03 \03 \03 \03 \03 \03 \03 \03 \03 \03 Page 92 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 92 \03 *8<$1$\0368*$5\03&25325$7,21\03,1&\11\03 6.(/'21\0368*$5\0302'(51,6$7,21\03352-(&7\03\0b6603\0c\03 (19,5210(17$/\030$1$*(0(17\033/$1\03)25\037+(\036.(/'21\0368*$5\03)$&725<\03 $1'\03$662&,$7('\03&$1(),(/'\03(;3$16,21\11\03 \03 \03 63(&,),&$7,216\03)25\03%86+\03&/($5,1*\03²\03-8/<\03fflflflbreve\03 D\11\0c\03 Movement of machines, manpower and herbicide use shall proceed in a direction that would facilitate the exit of wild animals towards remaining areas of natural habitat. \03 \03 E\11\0c\03 Temporary log bridges shall be placed across canals and other types of wildlife corridors shall be employed to facilitate the exit of terrestrial wildlife. \03 \03 F\11\0c\03 There shall be no hunting, wildlife capture or fishing by contractors and their employees. \03 \03 G\11\0c\03 There shall be no contamination of the canals by solid or liquid waste. \03 \03 H\11\0c\03 Decisions on disposal of cleared bush shall be done under the guidance of the Project Environmental Officer in consultation with the Estate Agriculture Manager and the Manager – CAEMS. \03 \03 I\11\0c\03 No vehicle washing or servicing shall be done in the field. Such activities shall be done under controlled conditions in designated service areas within the project area or at the estate workshop. \03 \03 J\11\0c\03 Machines used for bush clearing shall be washed in a designated service area or at the estate workshop before departing the estate compound in order to safeguard against the inadvertent introduction of alien weed species outside of the estate area. \03 Page 93 GuySuCo Inc Environmental Management Plan for the Skeldon Sugar Modernisation Project (SSMP); Version: 3 Revision Status: 0 Prepared by F. Homer; XX December, 2007 93