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Initial Enviromental Examination Report
A. DESCRIPTION OF THE ULAANBAATAR CARPET PROJECT The Ulaanbaatar Carpet factory, one of the largest carpet manufacturer, established back in 1971 as the first carpet factory in Mongolia by the technical and economic assistance of former German Democratic Republic. Initially the company was operating with 800 workers and had production capacity of 450,000 m2 carpets (in 2 production shifts). The company was exporting 98% of its products to former socialist countries. Due to the collapse of former socialist system with planned economy the company was nearly bankrupt in early 1990s lacking both the sales market and the market of core and auxiliary raw materials. In 1992 Ulaanbaatar Carpet was privatized and restructured into a Joint Stock ownership. The company had succeeded to recover from the recession and has gradually attained the current production level and market position. At present the company produces about 90,000 m2 of wool carpets in one shift. It has 160 employees, 80% out of which is women. The Ulaanbaatar Carpet has connected to the centralized system of power, heating, electricity and water supply, and sewage treatment. It has 4 shops and felt production unit: 1. Yarn spinning shop with annual capacity of 240 ton wool; 2. Dyeing shop with annual capacity of 240 ton wool; 3. Carpet weaving shop with annual capacity of 180.000 m2 of carpets; 4. Finishing shop with annual capacity of 180.000 m2 of carpets; 5. Felt production unit with capacity of 8100 m (with 2 m width). The company currently produces 3 local brands of carpets: Altanbulag, Altai, Ulaanbaatar. The company main customers are: (i) state agencies, (ii) business companies, (iii) private customers, and (iv) export markets. About 40% of total sales originates from export. Ulaanbaatar Carpet exports its carpets to China, Russia, Kazakhstan. About 90% of total exports go to markets of China. The main export product of the company is “Altanbulag” brand (its 30-40% is exported to China). On the domestic market, the company sells its products through 2 retail outlets in Ulaanbaatar city and distributors in 8 aimags. Relatively high product quality and well-known brand carpets of Ulaanbaatar Carpet are recognized among the office of President of Mongolia, Parliament and Government palace, ministries and public agencies, foreign embassies, as well as a number of large Mongolian companies. The main domestic competitor of the company is ErdenetCarpet PLC, Mongolia’s largest carpet company. ErdenetCarpet PLC produces about 90% and Ulaanbaatar Carpet produces about 10% of total carpets produced domestically. Ulaanbaatar Carpet products have perceived as higher quality (higher density, better finishing and colorfulness) compared to ErdenetCarpet, and still maintains good reputation and image among both private and state customers. The core raw material for the carpet production is sheep wool. Due to harsh climatic conditions, most Mongolian sheep wool is coarse and semi-coarse wool that is ideal for the production of carpets. It is supplied from Ulaanbaatar raw material market and by intermediate traders. Also it procures scoured wool from other companies which are specialized in wool scouring such as “MogolNoos” LLC and “NoosIreedui” LLC. Currently, Ulaanbaatar Carpet procures in average of 500 tons of wool annually. In 2010 it purchased 32% of wool from these wool scouring companies and 68% from raw material market. In nearest further it will continue to outsource the wool scouring operation to “NoosIreedui” LLC. The company purchases auxiliary materials such as linen yarns, dyes and other chemicals from Switzerland, China and Bangladesh. Currently Ulaanbaatar Carpet faces following particular problems connected to its equipment and technology, management, quality of raw material and supply chain: - The most of the production equipment and machines of the factory are outdated. Most of these were renovated in 1979 and 1989 except few ones which were renovated recently. It has impact on operation productivity, product quality and work condition negatively; - Current operation technology does not allow the factory to produce high density carpets in varieties of color to meet requirements of western markets. The maximum density of carpets that the current equipment can reach is 520 thousand points per 1 square meter.  Loose wool/wool particles that come out of carpet during its use, particularly at the beginning is a quality problem, that needs to be solved through improvement of both processing technology and raw material,  The management capacity building and human resource development issues are important concerns at present;  Raw material supply chain is not sustainable and inconsistent to supply with quality wool because of: • The company relies on the supply of raw wool from different traders and scoured wool from specialized companies as it lacks own procurement system. It often causes inconsistent supply and quality of wool. • Low yield and poor wool quality due to lack of breeding program and poor veterinary service. Various parasites often damage wool causing certain problems in the processing of wool and in the production of yarns; • Also quality of supplied wool is often unsatisfactory due to improper handling and storing the wool. Approximately 4.5% of raw wool is lost during its initial sorting (dirt, soil and other). In order to identify their livestock, herders often apply chemical dyes directly on the wool. Also some intermediate traders acting between herders and processing companies deliberately add sand and other contaminations to increase the weight of the wool they supply. These effect on quality of wool negatively. In order to obstacle these constraints, the Ulaanbaatar Carpet plans to implement the project on modernizing and upgrading the production equipment and technology, and restructuring a raw wool supply chain and improve management capacity in order to improve carpet quality to meet increased market requirement and demand. The goals of the Bankable Proposal of Ulaanbaatar Carpet PLC are: 1). Restructuring of the supply chain; 2). Improvement of management and marketing capabilities; 3). Renovation of production equipment and technology. As a result of the project implementation: (1) supply chain of Ulaanbaatar Carpet will be restructured and developed due to an established a wool collection centers in Bayankhongor and Khuvsgulaimags. These centers will supply the company with 100% of raw material by 2017; (2) the company’s management and marketing capabilities will be improved considerably; and (3) the production equipment and technology will be renovated and upgraded enabling to produce better quality and design products, and flexible and market oriented brand carpets. In addition, environmental performance, including employees working condition at the factory will be improved due to modernization of equipment and machines, and technology. Namely, due to upgraded machines in carpet weaving factory labor organization will be improved by reducing manual work of employees, and noise will be reduced. Local community will also benefit from the project implementation as about 40-45 new jobs will be created in Bayan Ovoosoum of Bayankhongoraimag and Rashaantsoum of Khuvsgulaimag. Direct cooperation with herders will be established to supply better quality raw material the company. The company has been participating in EBRD’s Turn-Around-Management program (TAM) since 2010 and Business Advisory Services program (BAS) since June 2011 in order to improve its management and operational organization. B. FORECASTING ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES The environment specialist of Agriculture and Rural Development Project (ARDP) of ADB used the information in the reviewed documents of the company, namely, DEIA report for the existing factory (2002), GEAand DEIA report for the project (2010), internal procedures of the company, memos of government inspections, statistical data of the Ulaanbaatar city, Environmental, health, and safety guidelines for Textile manufacturing (WB), other secondary sources, and information obtained from the company top management as well as findings of company’s visit in order determine environmental impacts from the project implementation. 1. Environmental Benefits The company’s plan on upgrading equipment and technology with the investment requested in the Bankable proposal to ADB will continue improvement of environmental performance. As a result of project implementation, there will be not only improvement of production capacity and productivity, and quality and design of products, but also environmental situation at the factory will be improved. For example, due to upgraded machines in carpet weaving factory manual work of employees and noise will be reduced. In addition, as Ulaanbaatar Carpet manufactures environmentally friendly products such as wool carpets and other garments made from almost 100% sheep wool. 2. Environmental impacts The following potential environmental impacts were identified by the Ecos” LLC, assessment company for the Ulaanbaatar Carpet project.: Potential negative impacts:  Change in water resource and quality;  Soil pollution;  Impact of work condition of the plant on workers\' health;  Bad odor due to lack of disinfection of domestic waste and its disposal point etc. Positive impacts:  Increase in employment;  Increase in workers income;  Increase in local income. 3. DEIA (2010) recommendation According to the Law on Environmental Protection (1995) and conclusion on the examination and observation made for DEIA (2010) on carpet manufacturing operation of Ulaanbaatar Carpet major measures were recommended to the company to include in the environmental protection and monitoring plans of the company every year and implement it to prevent, mitigate and minimize potential adverse environmental impacts from the project implementationsummarizedbelow: 3.1. Air pollution: • Ensure a proper operation of the ventilation system at the factory; • Ensure a proper operation of the ventilation system in the areas where chemicals are stored, loaded and unloaded; • Carry out air quality samplings in operation units regularly and take the necessary actions to improve it; 3.2. Soil pollution: • Take actions to prevent soil pollution from waste generated from the factory operation and domestic use, and monitor its maintenance; • Transport waste disposal to designated landfills in timely manner; • Obtain a permit and assistance from a professional agency when dispose and terminate leftover chemicals; 3.3. Water pollution: • Conduct samplings on waste water discharged from the factory operation into CSS of the city and maintain record; • Conduct inspection on maintenance of waste and clean water pipes regularly and take necessary actions; • Comply procedures and instructions when store, handle and dispose chemicals; • Ensure that chemicals are not be released into sewer, drains; 3.4. Workers’ health and safety: • Ensure hygienic conditions in the workplaces and carry out its monitoring regularly; • Identify pollutants that could impact on workers’ health with assistance of a professional agency and take necessary actions; • Organize trainings on healthy environment, safety operation and prevention from potential accidents; • Ensure and monitor workers use of occupational apparel and protective equipment; 3.5. Management and organization: • Develop company’s EPP and EMP annually and submit them to the related agency and implement them in timely manner; • Cooperate with local agencies of the district in order to contribute in local development by implementing environmental protection measures; • Monitor compliance with the procedures related to workplace hygiene and occupational safety regularly, and involve workers in health check-ups annually and take necessary follow-up actions; • Develop report on implementation of the EPP and EMP and submit it to the related agency each year; 4. Potential environmental impacts determined by the ARDP (ADB project) Based on the study of DEIA (2010) report and other documents related to the environmental issues of the project document, and observation of current operation of the factory made by the ARDP (ADB) environmental specialist during (Project management unit) PMU visits to the Ulaanbaatar Carpet, and discussions held with the management and other relevance officials of the company, it can be concluded that the Ulaanbaatar Carpet project implementation will have no significant adverse impact on the environment and human health. The following potential environmental impacts were determined and summarized by ARDP PMU along with the recommendations for their prevention and abatement. 4.1. Water pollution Ulaanbaatar Carpet company utilized7,395.0 m3 water in 2010(130 m3 water daily) for its domestic use and 12,067.0 m3 for its carpet making operation (60%). In total, it discharged19,432 m3of waste water in2010. The waste water is discharged directly into the centralized sewage system (CSS) of the city. The company has contract with the Water Management Authority of the city on water supply and sewage discharge service since 2003 which is extended every year. Waste water generated from the factory does not contain any hazardous contaminants. Content of waste water discharged from different shops of the factory differ depending its origination. For example, waste water from dyeing unit contains some dyes andfrom carpet weaving shop contains some glue etc. Table 1. Results of chemical analysis on sewage of the factory # Standards of Mongolia Parameter Acceptable level Concentration 1 MNS ISO 10523:2001 pH 6.5-8.5 6.86 2 MNS ISO 6060:2001 COD, mg/l 400-800 144 3 MNS ISO 11923:2001 Suspended solids, mg/l 407 32 4 MNS ISO 5597:2006 Sulfide, mg/l 10.0 1.35 Source: Central Lab of the Water management Authority, 2011 Water management authority of the Ulaanbaatar city is responsible for monitoring of sewage management of the company through its CSS. Its lab monitors sewage pollution level by regular samplings (twice a year). Results of the last samplings conducted in July of 2011 were satisfactory and met the national requirements (See Table 1). As it was mentioned above, the company has outsourced initial processing of raw material/ scouring of wool to other companies such as “MogolNoos” LLC and “NoosIreedui” LLC since 2006, who are known for their good performance in wool scouring. Currently, Ulaanbaatar Carpet has contract with “NoosIreedui” LLC.on wool scouring. Both companies have agreed to extend this contract through 2015. 4.2. Solid waste Amount of solid waste generated from yarn spinning and carpet weaving operations of the factory is minor. According to the updated DEIA amount of the solid waste generated from the factory in 2010 was115 kg monthly and 1,380.0 kgper year (domestic waste was about 90 % of total waste). These solid wastes have no harmful effect on the environment. The solid waste is transported to the landfill site of the Ulaanbaatar city 2-3 times a month by contract. The company has contract on transportation of solid waste with the “Waste removal service” LLC of the Khan Uul district of the Ulaanbaatar city. It is updated on yearly basis. The landfills are located 18km from the Ulaanbaatar factoryand managed by the city government. The City Maintenance and Public Utility Agency of the cityis responsible for its daily maintenance ensuring that national standards and procedures required by the Law on Household and Industrial Wastes, 2003 are met. Ulaanbaatar Carpet factory has small unit to produce felt cover/insulation for national ger, matrass and other small garments using recycled poor qualityraw wool/waste wool which do not meet standard for carpet making. Approximately 600.0 ton of waste wool was recycled forfelt production in 2010. 4.3. Soil pollution The soil of the factory area is mostly covered by cement and occupied by other construction and facilities. According to the current DEIA, there is no adverse impact on soil from the project implementation.Ulaanbaatar Carpethas taken some measures on Greening of the surrounding area, including planting grasses, bushes and trees in front of the factory building. 4.4. Air pollution The company’s operation does not produce any substances to cause air pollution. According to the current DEIA, there is no adverse impact on ambient air from the project implementation as carpet making process is operated in closed building, and it uses electricity as a source of power for its operation. In the company’s existing warehouse where the company processes/sorts raw wool some dust is produced. The warehouse is located in Khan Uuldistrict,close to the airport ChingisKhaan, and operates seasonally (August-October). It is ventilated naturally (with open windows and doors). Workersof wool sorting unit are provided with protective masks in accordance with the company’s internal and safety procedures. Wool fibers and loose wool generated from the yarn spinning and carpet weaving factory are removed by exhaust ventilation system. Air ventilation system at the factory operated well, and maintained regularly. Filters are cleaned on daily basis. Workers in these shops are provided with masks. 4.5. Chemicals use The Ulaanbaatar Carpet factory uses some chemicals and organic substances for yarn making and carpet weaving, and for lab activity. Itpurchases all chemicals from the “Tsetsuukh Trade” LLC contract. “Tsetsuukh Trade” LLC has all necessary licenses and permissions on import and sale of chemicals. The Ulaanbaatar Carpet itself importsdye stuff for itswoolprocessing from the ClariantInternational (Switzerland) by contract. The ClariantInternationalmanufactures dyes with outstanding ecological profile as well as high performance level. There are no prohibited and with limited use chemicals among the chemicals used by the company in the production process listed in the attachment of the government resolution on Prohibition of use of Hazardous and Toxic Chemicals on the territory of Mongolia issued in 2007. Among all chemicals used for the Ulaanbaatar Carpet, only Acetic acid (CH3COOH) and Glauber’s salt (Na2SO4)are registered as toxic and hazardous chemicals according to the DEIA, 2010. These toxic and hazardous chemicals have hazardous effect on human body if they are not stored, transported and used properly. ClairantInternationalhas provided the Ulaanbaatar Carpet with Material Safety Data Sheets (MSDS) on supplied dyes which provide safety handling precautions. Although other chemicals and dyes are generally regarded as non-toxic according to the national legislation, these substances should be handled with usual precautions, and employees who handle with these substances should wear suitable personal protective apparel and equipment. The company maintains its carpet manufacturing operation in compliance with the legal requirements on purchasing, storing, transporting and usage of the chemicals, particularly toxic and hazardous chemicals. These safety regulations are outlined in the Law on Hazardous and Toxic Chemicals (2006) and governmental regulations on Export, Import, Trans-boundary Transportation, Production and Trade of Hazardous and Toxic Chemicals (2008), and Storage, Transportation, Use, Disposal of Hazardous and Toxic Chemicals (2009) and other relevant procedures. The company lab keeps records on the receipt and the expenditure for chemicals and dyes regularly, and maintains their inventory on monthly basis.The company plans to terminate unnecessary and expired chemicals and dyes with assistance of local Emergency Department in 2011. In 2010 the company used 14,860.08 kg chemicals and1.055 kg dyes for its operation. According to the project estimation provided by the management, amount of the chemical substances and dyes will be increased gradually by 30% (2015) in relationship with production increase. The ARDP PMU requires the company management to improve chemicals handling practice by: 1) developing and complying procedure on safety handling of chemicals in order to provide safe use and handling of chemicals and dyes, and 2) placing detailed references on hazardous chemicals and dyes which were provided by the suppliers in the storage rooms, and 3) organize trainings for the employees on hazards of toxic chemicals and dyes, safety handling requirements, and first aid in case of emergency situation etc. regularly, and 4) report chemicals expenditure to the Emergency Department of the district in accordance with the government requirements. 5. Occupational safety and health There are some potential occupational hazards with possible effect on health of the factory employees. Specific conditions of the factory operations such as dust in the existing wool sorting unit in Khan Uul district andnoise inyarn spinning and carpet weaving shopswhich the project environment specialist witnessed during the visits to the company could have adverse effect on employee’s health. Also chemicals and dyeing substances used in yarn making process could cause some allergenic and poisonous effect on respiratory organs of the employees. In order toimprove work place condition by minimizing this impact, the company installed loose wool exhausting equipmentin 80% of carding, combing and intersecting machines and yarn spinning machines. Remaining machines will have installed this equipment in 2011. Humidifying system was installed in yarn spinning shop in 2009. It will be installed in carpet weaving shop in 2011 too. Occupational safety and hygiene were inspected annually by the Professional Inspection Department (PID) of the Ulaanbaatar city. The last inspection was carried out in June, 2011. The assessment was carried out in accordance with the Law on Occupational Safety and Hygiene (2008), and national standards such as “Occupational Safety and Hygiene. Work place environment and Hygiene” MNS 4990:2000, “Air quality. General requirements“ MNS 4585:2007, “Occupational Safety and Hygiene.Work place lighting.General requirements” MNS 4996:2000, “Occupational Safety and Hygiene.Noise.General requirements” MNS 5002:2000, “Occupational Safety and Hygiene.Dust.General requirements” MNS 5010:2001 etc. Results of the physical measurement conducted in different work places of the factory are shown in Table 2. Table2. Results of the inspection on work conditionat the factory # Shop name Temperature, oC Humidity, % Dust, mg/m3 Light, lux Noise, dB 1 Weaving shop 30.6 30.6 6.56 2.19 343 95.4 2 Blending shop 28.1 48.8 0.0 0.0 101 90.6 3 Spinning shop 26.8 54.1 6.48 0.0 89 86.9 Acceptable limits 18-27 40-65 10 ›300 80-85 Source: Inspection report of the PID of the city, August, 2011 The inspection group recommended the company to improve work place condition by taken measures to improve ventilation system and lighting, and decrease noise level at the factory units. Employees are provided with personal protective apparel and equipment in accordance with the resolution # 122 of Ministry of Health and Welfare, 2002. All employees ofthe factory are involved in general health checkups every year. In 2010 about 190employees were involved in medical check-ups. Company executes several procedures, including “Internal Procedure of the company” (2005), “Procedure on Occupational Safety and Hygiene”, “Procedure on fire prevention”, “Procedure on reuse of waste produced from a production process”, “Procedure on Organizing fire extinguishing trainings”, “Internal monitoring procedure on organization of occupational safety and hygiene”, Procedure on storing, transporting and handling of raw material and semi-processed products” and other procedures executed at the company. Most of these procedures were developed in 2008. The PMU requires the company management to improve quality of existing procedures on occupational safety and hygiene, and develop more procedures related to handling of chemicals and dyes, supply of personal protective apparel and equipment etc. 6. Environmental management plan The company has developed and implemented the environmental management plan(EMP) for 2011 to mitigate adverse environmental impact from the factory operation. The budgets on mitigation measures were estimated and included in the business plan of the factory. Current environmental management planconsists from the Environmental Protection Plan (EPP) and Environmental Monitoring Program (EMPr) of the company for 2011 and include mitigation measures related to waste management, handling of chemicals and occupational safety and health etc., and monitoring measures on waste water, work place condition etc.These areattached in the Annex 1and 2of this introduction. 7. Monitoring During the project implementation, the company will monitor and regularly report on the project’s implementation of environmental requirements and outcomes as part of the overall reporting to Bank and ARDP PMU. The companies will report any environmental incidents, accidents, complaints, litigation, regulatory notices or fines in their operation to the ARDP PMU, the Bank and applicable professional agencies of Ulaanbaatar city immediately. The environmental specialist within the ARDP PMU will be responsible for overseeing and reviewing this monitoring to ensure that it is satisfactorily carried out. C. PUBLIC CONSULTATION AND INFORMATION DISCLOSURE As Ulaanbaatar Carpet is planning to establish wool collecting and primary processing centers in Bayan Ovoosoum of Bayankhongoraimag and Rashaantsoum of Khuvsgulaimag, the company management had meeting with owners of storagesin 2010 and agreed to rent them for wool collecting and primary processing purpose. Also the management of the company sent a letter to a governors and Citizen Representative Khural (CRKs) of these soums acknowledging the project idea, including its plan to establish wool collecting and primary processing center and develop cooperation with herders of these soums of in order to improve supply chain and wool quality, and got their positive response officially. The company managementis planning tocontinue public consultations with local community during their travel to these aimagssooner after the project approval for a loan. In accordance with the Law on Environmental Impact Assessment, the MNET shall have an obligation to disclose information on DEIA for the public. In addition, according to the law on Environmental Protection, MNET is responsible to maintain State Environmental Information Database (EID) where all summary of conducted DEIA should be placed for public access. This EID is available for public in the websites of the MNET at present. D. CONCLUSION Based on review of the environment assessment documents of the Ulaanbaatar Carpet, company’s documents related to the environmental protection, occupational safety and health, and findings from the site visits and discussions with management of the company and the outsourcing company “NoosIreedui”, as well as review of relevant documents and secondary sources, the ARDP PMU makes the following conclusions. The company is committed to improving the current environmental practices of the company. It is evident from actions and management commitment in this field. As a result of some upgrades offactory equipment, machines an occupational safety and work place condition at the factory have been improved for last two years. The project will have no significant adverse impacts on the environment and human health with implementation of the proposed mitigation plan, and recommendations provided by DEIA and PMU. The project is classified as a category B in terms of ADB environmental assessment categorization system. Therefore a full environmental impact assessment is not required, and this IEE is the final environmental impact assessment document. It is available to the public on request. The project implementing company will monitor and report on the implementation of environmental protection plan and monitoring program on semi-annual basis, and also report any environmental incidents, accidents, complaints, regulatory notes, or fines in their operation to ARDP PMU, MNET and the bank. Environmental and inspection agencies ofUlaanbaatar citywill monitor the implementation of the EPP and EMP of the factory, ARDP PMU will be involved in project reviews by evaluating project activities on environmental protection. The annual budget allocated for the environmental protection for 2011 is MNT 17,685.000 The result of the environmental protection measures will be included in the project report.   Annex 1 Environmental protection plan for 2011 No Environmental impacts and mitigation measures Parameters Frequency Responsibility Cost /ths.MNT/ A. Water pollution: 1 Maintain, renovate water supply pipes Sewage management June Plumbers 1,500.0 2 Clean out sewage pipes; Sewage management Monthly Plumbers 1,800.0 B. Waste disposal: 3 Regular clean-up within factory site with involvement of all production units Waste management Quarterly Manager - 4 Manage solid waste removal and transportation Waste management Monthly Manager and chief accountant 2,500.0 5 Increase recycling of waste wool generated from the production by increasing felt production capacity Waste management Regularly Felt production unit supervisor - 6 Place metal container for solid waste in waste disposal point Waste management July Mechanic 200.0 C. Air pollution: 7 Install a humidifying system at the weaving shop; Air pollution management July Mechanic 1,000.0 8 Inspect and maintain a ventilation system of the factory by schedule Air pollution management Regularly Mechanic, - 9 Study on modern, energy efficient ventilation technology; Air pollution management Regularly Procurement specialist - D. Chemicals use: 10 Supply dyes and chemical substances for the carpet making operations from companies with internationally accepted licenses; Chemicals management Regularly Procurement specialist - 11 Improve chemicals storage and record keeping practices Chemicals management Regularly Warehouse stock keeper - 12 Manage termination of expired chemicals and dyes with assistance of specialized agency Chemicals management September Production manger 1,000.0 E. Soil pollution: 13 Plant flowers in front of the factory building Soil management June Manager 70.0 14 Organize cleanup of the factory area Soil management Regularly Manager - F. Occupational safety and hygiene: 15 Provide a factory with set of fire extinguishing equipment and tools, and re-establish fire fighting committee of the factory Emergency management June Occupational safety and hygiene (OSH) specialist 1,000.0 16 Re-establish a committee on OSH and emergency council OSH management July Executive director, OSH staff - 17 Involve workers in health check-ups OSH management September Finance and human resource manager 500.0 18 Involve OSH specialist in special training OSH management June Finance and human resource manager 65.0 19 Provide workers with occupational apparel and protective equipment OSH management August OSH specialist 3,000.0 20 Provide workers with free meal OSH management Beginning from May Executive director - 21 Renovate and improve workers rest room in operation shops OSH management April Executive director, manager 1,800.0 22 Purchase books, guidelines and other resource material on OSH for workers use OSH management May OSH specialist 250.0 23 Improve workers canteen OSH management September Executive director 2,000.0 24 Renovate roof of the factory building Hygiene and safety management Jun-Aug Executive director - G. Organization measures: 25 Comply with national laws, regulation and guidelines on environmental protection Environmental management Regularly Executive director, all staff - 26 Cooperate with PMU of ARDP project on environmental protection Environmental management Regularly Company project team - Total 16,685.0   Annex 2 Environmental monitoring program for 2011 # Impact Monitoring Parameters Reporting Frequency Responsibility Report to Cost, Th.MNT 1 Water pollution Monitoring of sewage water quality by analyzing sewage pH, COD, Solid substance, Sulfide Twice a year Enterprise (lab of the Water Management Authority) ED of the city, PIU 100.0 2 Soil pollution Monitoring of soil pollution by analyzing soil Chemical, biological and physical characteristics of soil (to be determined) Once a year Enterprise (Lab of the SPIA) ED of the city, PIU 100.0 3 Air pollution Monitoring of air quality by sampling SO2, NO2 Once a year Enterprise (Lab of the MNET) ED of the city, PIU 200.0 4 5 Occupational Safety and Health Workers Safety and Health Monitoring of Working condition Safety and Health records Sanitation and hygiene parameters (To, dust, humidity, noise) Employees health check-ups Once a year Once a year Enterprise (Lab of the SPIA) Enterprise (internal monitoring and reporting) ED of the city, PIU ED of the city, PIU 100.0 500.0 6 Compliance with National regulations Conditionsrequired by GEA Monitoring reports Twice a year Enterprise ADB, through PIU - Total 1,000.0
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