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KIRIBATI: PACIFIC ISLANDS REGIONAL OCEANSCAPE PROGRAM

World Bank: P165821

Environmental and Social Management Framework

VERSION: Final, February 2020

Kiribati PROP (P165821) – Environmental and Social Management Framework | February 2020

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Table of Contents

1 Introduction .................................................................................................................................... 6

2 Purpose and Scope of the ESMF....................................................................................................... 7

3 Description of the Project Components and Typology of Sub-Projects ............................................. 8

3.1 Project Subcomponents ........................................................................................................... 8

3.2 Types of Subproject Activities................................................................................................. 11

4 Environmental and Social Context ................................................................................................. 12

4.1 Coastal and Marine Ecosystems ............................................................................................. 12

4.2 Fisheries ................................................................................................................................. 13

4.2.1 Commercial Fisheries...................................................................................................... 13

4.2.2 Subsistence Fisheries ...................................................................................................... 14

4.3 Aquaculture ........................................................................................................................... 15

4.4 Recreational Fishing ............................................................................................................... 15

4.5 Marine Pollution .................................................................................................................... 16

4.6 Marine Protected Areas and Wildlife Sanctuaries ................................................................... 16

4.6.1 Phoenix Islands Marine Protected Area .......................................................................... 17

4.6.2 Kiritimati Wildlife Sanctuary ........................................................................................... 17

4.7 Socio-Economic Environment ................................................................................................. 17

4.8 Gender Roles in Fishing .......................................................................................................... 18

4.9 Climate Change and Natural Hazards...................................................................................... 19

4.9.1 Climate Change .............................................................................................................. 19

4.9.2 Natural Hazards .............................................................................................................. 20

5 Legal, Policy Framework and Regulatory Requirements ................................................................. 21

5.1 World Bank Policies ................................................................................................................ 21

5.2 Applicable Legislation, Policies and Regulations...................................................................... 22

5.2.1 International Context ..................................................................................................... 22

5.2.2 National context ............................................................................................................. 24

5.3 Gap Analysis ........................................................................................................................... 29

6 Potential Environmental and Social Impacts and Measures to Mitigate.......................................... 32

6.1 Cumulative Impacts ................................................................................................................ 43

7 Environmental and Social Screening of Subprojects ....................................................................... 44

7.1 Overview of Screening Process ............................................................................................... 44

7.2 Screening of Subprojects ........................................................................................................ 44


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8 Responsibilities for Safeguards Implementation ............................................................................ 48

8.1 Key Safeguards Responsibilities .............................................................................................. 48

8.2 Capacity Building .................................................................................................................... 49

9 Consultation and Disclosure .......................................................................................................... 51

10 Grievance Redress Mechanism ...................................................................................................... 52

11 Annexes......................................................................................................................................... 53

Annex I Kiribati PROP Project Stakeholder Engagement Plan.............................................................. 54

Annex II Land Access and Resettlement Policy Framework ................................................................. 63

Annex III Checklist 1 – Screening Process ........................................................................................... 80

Annex IV Checklist 2 - Construction and Renovation Screening Checklist............................................ 81

Annex V Checklist 3 – All Other Projects Screening Checklist .............................................................. 84

Annex VI Environmental and Social Management Plan (ESMP) Template ........................................... 89

Annex VII Construction and Renovation Environmental Code of Practice (ECOP) Template ................ 91

Annex VIII Terms of Reference for Technical Advisory ........................................................................ 92

Annex IX Guideline 1 - MFMRD Vessels .............................................................................................. 93

Annex X Guideline 2 – Outer Island Investments ................................................................................ 94

Annex XI World Bank Group Good Practice Note: Asbestos ................................................................ 97

Annex XII World Bank Group EHS Guidelines for Fish Processing ........................................................ 98

Annex XIII World Bank Group EHS Guidelines for Aquaculture ........................................................... 99

Annex XIV Grievance Mechanism ..................................................................................................... 100

Annex XV Physical and Cultural Chance Find Procedure ................................................................... 103

Annex XVI Pre-Appraisal Stakeholder Consultation Reports ............................................................. 104


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List of Abbreviations

BEIA Basic Environmental Impact Assessment CBD Convention on Biological Diversity CCPL Central Pacific Products Limited EA Environmental Assessment ECD Environment and Conservation Division ECOP Environmental Codes of Practice EEZ Exclusive Economic Zone EHS Environment, Health and Safety EIA Environmental Impact Assessment EMP Environmental Management Plan ESIA Environmental and Social Impact Assessment ESMF Environmental and Social Management Framework ESMP Environmental and Social Management Plan ESSIP Environmental and Social Safeguard Instruments for Pacific Island Countries FAO The Food and Agriculture Organization of the United Nations FFA Pacific Islands Forum Fisheries Agency GDP Gross Domestic Product GRM Grievance Redress Mechanism GOK Government of Kiribati IDA International Development Association IPF Investment Project Financing IUU Illegal, Unregulated and Unreported (fishing) KDP Kiribati Development Plan 2016-2019 KFL Kiribati Fish Limited KFSU Kiribati Fiduciary Services Unit KV20 Kiribati Vision 2020 MCS Monitoring, Control and Surveillance MELAD Ministry of Environment, Lands and Agricultural Development MFED Ministry of Finance and Economic Development MFMRD Ministry of Fisheries and Marine Resources Development MLPID Ministry of the Line and Phoenix Islands Development MPA Marine Protected Area NBSAP National Biodiversity Strategies and Action OP Operational Policy (of the World Bank) PDO Project Development Objective PEO Principal Environment Officer PIC Pacific Island Countries PMU Project Management Unit PNA Parties to the Nauru Agreement PROP Pacific Islands Regional Oceanscape Program RPF Resettlement Policy Framework SEP Stakeholder Engagement Plan SPC Pacific Community TA Technical Assistance/Advisory TOR Terms of Reference UNCLOS United Nations Convention on the Law of the Sea WB World Bank


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List of Figures

Figure 1 - Adult milkfish collecting behind a sluice, Kiritimati ................................................................. 15 Figure 2 - Kiribati Environmental Approvals Application Process ............................................................ 26 Figure 3 – Key Subproject Screening Steps ............................................................................................. 44 List of Tables

Table 1 - Proposed Subproject Activities under Kiribati PROP ................................................................ 11 Table 2 - Fisheries employment information by sex, age, and job category (2010) ................................. 19 Table 3 - Gap Analysis ............................................................................................................................ 30 Table 4 - Ineligible Activity List ............................................................................................................... 47


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1 Introduction The Government of Kiribati (GOK) is seeking funding from the World Bank for the Kiribati: Pacific Islands Regional Oceanscape Program (Kiribati PROP) (World Bank P165821) to enhance the sustainable value of large-scale oceanic fisheries, diversify sustainable marine-based sources of revenue for coastal communities, and strengthen coastal and marine pollution management capacity in Kiribati.

The Kiribati PROP’s Project Development Objective (PDO) is to improve management of selected fisheries and seafood safety in the Recipient’s territory.

The Project reflects key elements of the Government’s Kiribati Vision 2020 and will contribute to implementation of the Kiribati Development Plan 2016-19 (KDP) that identifies key priority areas for the medium term. The Project also supports the Kiribati’s National Fisheries Policy (2013) and Integrated Environmental Policy (2012).

The project is proposed to be financed through an International Development Association (IDA) grant and credit resources: USD 19.5 million in Regional IDA.


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2 Purpose and Scope of the ESMF This Environmental and Social Management Framework (ESMF) sets out the principles, policies and procedures for environmental and social protection that the GOK will employ in the context of the Kiribati PROP Project. The rationale of using an ESMF is that specific activities for all sub-projects were not fully identified during the project preparation and therefore, not all of the environmental and social impacts are known. The Environmental and Social Safeguard Instruments for Pacific Island Countries (ESSIP) were used to guide the development of this ESMF.

The purpose of this ESMF is to provide a framework to guide the environmental and social screening of project activities during project preparation and implementation. This is to ensure that potential adverse environmental and social impacts that may be generated as a result of each project activity are identified, and appropriate safeguard instruments are prepared to avoid, minimize, mitigate and, in such cases where there are residual impacts, offset adverse environmental and social impacts.

The ESMF outlines the project, its components, the environmental and social context, possible environmental and social impacts, and their management. It provides an overview of the types of subproject activities to be assessed, the environmental and social screening process, and the subproject-specific safeguard instruments that will be prepared once the project locations and other details are known. Monitoring and reporting is also addressed to ensure ongoing adherence to environmental and social safeguards. Annexes include a Stakeholder Engagement Plan (Annex I), a Land Acquisition and Resettlement Policy Framework (Annex II), and Screening Forms, Templates, and Guidelines for Activities (Annexes III-X). The Ministry of Fisheries and Marine Resource Development (MFMRD) has the overall responsibility for ensuring that environmental and social issues are adequately addressed within the project cycle.

The ESMF meets the requirements of the relevant World Bank Operational Policies and laws of Kiribati to describe the procedural responses to identifying and managing impacts throughout the project. The World Bank safeguard policies are available at www.worldbank.org/safeguards.

http://www.worldbank.org/safeguards


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3 Description of the Project Components and Typology of Sub-Projects The Project Development Objective (PDO) of the Project is to improve management of selected fisheries and seafood safety in the Recipient’s territory. The Project is designed as a six year, USD 19.5 million Investment Project Financing (IPF) operation organized in four components.

3.1 Project Subcomponents The proposed project components and sub-components are:

Component 1 (comprised of USD 2.20 National IDA and USD 4.42 Regional IDA). This component will support MFMRD to strengthen management and compliance of large-scale oceanic fisheries which, in turn, will function to strengthen Kiribati’s participation and contribution to the PNA VDS and meeting its obligations with WCPFC. The activities in this Component are organized in two sub-components: Sub-Component 1.1 Strengthening Monitoring, Control and Surveillance Capacity (USD 1.44 million) The rapid growth of the Kiribati offshore fishing fleet has placed significant pressure on MFMRD to meet its national and regional obligations for effective MCS of fishing activities in its EEZ. This Sub-Component will finance a package of TA to strengthen Kiribati’s capacity to carry out its MCS duties. TA for capacity building and training to support effective implementation of MFMRD IUU counter measures and refinements to the Legal and Policy Framework will include the following:

a. The Project will finance activities to strengthen the capacity of officers to implement MCS activities

to improve IUU countermeasures, in compliance with international law. Specifically, this TA will support: (a) strengthening the Recipient’s capacity to implement monitoring, control and surveillance activities to improve illegal, unreported and unregulated fishing countermeasures in accordance with international law, including: (i) evaluating observed and unobserved fishing trips; (ii) carrying out studies, training and capacity building activities on compliance with the Recipient’s obligations under Article 73 of UNCLOS and on market state measures under international law, including implementation of the FAO Port State Measures Agreement; (iii) reviewing, updating and publishing a national plan of action on illegal, unreported and unregulated fishing; and (iv) reviewing the Recipient’s legislation and procedures, drafting and submitting updates of legislation for approval, and drafting and adopting updated procedures, for compatibility with Article 73 of UNCLOS.

b. The Project will finance legal and policy work to support EM roll-out to the longline fleet, including through developing: (i) a legal and policy framework for the use of the electronic monitoring and reporting systems provided for under Part 1.2(b) of the Project, including both regulatory and procedural reform; (ii) clear and transparent criteria for the application of reporting requirements and a template of the memorandum of understanding to be entered into with vessel operators for installation and operation of such systems; (iii) plans for sustaining the electronic monitoring and reporting systems beyond the life of the Project; and (iv) arrangements to integrate external information and communications technology support.

Sub-Component 1.2 Investing in Improved MCS Enforcement (USD 5.18 million) Implementation of the activities indicated under this Sub-Component will be conditional upon the Kiribati fisheries laws and regulations being consistent with provisions of Article 73 of UNCLOS, which will be supported through the set of Project-financed activities indicated in Sub-Component 1.1. Once Kiribati is found to be fully compliant with the conditions set out in Article 73 of UNCLOS, the Project will invest in the following activities:


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a. Establishment of fit-for-purpose MCS facilities in Betio and Kiritimati. The Project will finance designing, constructing and equipping two fisheries monitoring, control and surveillance facilities, one in Betio and the other in Kiritimati.

b. EM/ER for vessels operating in Kiribati’s EEZ. The Project will finance installing, operating and maintaining electronic fish catch monitoring and reporting systems in domestic Longline Vessels whose operators have signed a memorandum of understanding based on the template referred to in Sub-Component 1.1(b)(ii) and training MFMRD officers in respect of such systems

c. Enhancing the regional observer program to facilitate boarding inspections of fishing vessels in Betio and Kiritimati. To expedite boarding and inspections in the two designated transshipment ports, the Project will finance providing tender craft to facilitate boarding inspections of fishing vessels, one in Betio and the other in Kiritimati.

Component 2: Diversifying Marine-Based Revenue Streams for Outer Island Coastal Communities (USD 5.97 million). The Kiribati Fisheries (Conservation and Management of Coastal Marine Resources) Regulation 2019 provides the framework for improved coastal fisheries management and community participation in Kiribati. This Component aims to strengthen coastal community participation in new and existing sustainable marine-based revenue streams in the Gilbert and Line Islands in support of the Kiribati Fisheries (Conservation and Management of Coastal Marine Resources Regulation 2019 by:

a. Securing the ocean economy of Kiritimati. To support development of Kiritimati’s ocean economy,

this Component will include: (a) developing a Kiritimati ocean resources master plan; (b) developing a Kiritimati sport fishing management plan; and (c) supporting implementation of the Kiritimati Island Marine Aquarium Trade Management Plan 2017; including, in each case, identifying viable options for generating long-term and meaningful employment of women and youth in Kiritimati’s ocean economy.

b. Strengthening evidence-based decision-making and compliance for coastal fisheries management. The Project will carry out capacity building activities to: (a) strengthen national coastal resource licensing systems; (b) enhance community participation in coastal resource management; and (c) increase the capacity and operational effectiveness of MFMRD’s Coastal Fisheries Division including providing equipment and software for electronic reporting.

c. Accelerating development and diversification of sustainable supply chains in the Gilbert Islands. This activity will provide a package of technical assistance and capacity building activities to identify and catalyze sustainable fisheries supply chains in selected outer islands within the Gilbert Islands, selected from a menu of potential activities which includes: (a) establishing a marine spatial plan for Tarawa; (b) identifying up to four candidate outer islands for selection in accordance with the POM and preparing and implementing sustainable supply chain development plans for such selected outer islands in accordance with the Fisheries (Conservation and Management of Coastal Marine Resources) Regulations 2019; and (c) providing training and capacity support to catalyze development of sustainable supply chains in accordance with those plans, including providing relevant materials and facilities, and through targeted conservation and management measures in the Nearshore FAD Fishery.

d. Accelerating development and diversification of sustainable supply chains within the Line Islands. To facilitate development of the small-scale fisheries sector in the Line Islands, the Project will carry


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out studies to evaluate economic viability of small-scale fisheries supply chains within the Line Islands and barriers to such viability, including a needs assessment and costing exercise for a small-scale fisheries development and production center to be operated by Central Pacific Producers Limited.

Component 3: Improving Seafood Toxicology and Safety Measures in Selected Fisheries (USD 4.97 million). This Component will finance a core set of TA and civil works designed to reduce the risk of contaminated seafood and seafood products from entering domestic and international markets. The five activities financed under this Component include: a. Development of a pollution and seafood toxin assessment and ecosystem management plans for

Tarawa lagoon and coastal fisheries, including studies to identify the primary affected fish species and the sources of toxins, and implementation by MFRMD of certain actions under those plans. The Project will develop a pollution and seafood toxin assessment and ecosystem management plans for Tarawa Lagoon and coastal ecosystems in Tarawa and Kiritimati, including studies to identify the primary affected fish species and the sources of toxins, and implementing activities identified in such management plans that are within MFMRD’s remit.

b. Seafood toxicology training and capacity building program. This activity will finance developing and carrying out a training and capacity building program for MFMRD technical staff working on seafood toxicology and coastal fisheries seafood safety, including: (a) assessing the capacity needs of such staff to operate the MFMRD laboratories and to implement seafood safety schemes; and (b) designing and carrying out a capacity building and training program to meet the assessed capacity needs

c. Design, Construction and Outfitting of the two MFMRD laboratories on seafood toxicology and

coastal fisheries research within the centralized Kiribati One Health Support Institute (KOHSI) to be located in Betio. The Project will: (a) carrying out a feasibility study for designing and constructing two MFMRD laboratories on seafood toxicology and coastal fisheries research; and, (b) if determined to be feasible and following partial implementation of the training and capacity building program under Component 3.2 of the Project, designing, constructing and equipping the MFMRD laboratories.

d. Improved Seafood Safety Legal and Regulatory Framework. This activity will enhance the Recipient’s

seafood safety legal and regulatory framework including by drafting: (a) a seafood safety policy; (b) amendments to relevant fisheries and food safety legislation to incorporate seafood safety measures; and (c) legislation to support implementation of the seafood safety scheme.

e. Development of a Kiribati Seafood Safety Scheme. The Project will develop a national seafood safety scheme for selected fish and shellfish species consumed domestically or exported, including: (a) designing and carrying out risk assessments; (b) developing guidance and advisory materials; (c) costing and developing a business model for operation of the seafood safety scheme; (d) developing promotional and awareness raising materials; (e) developing a staffing structure and work program for operation of the seafood safety scheme; and (f) developing protocols and procedures for new MFMRD laboratories.

Component 4: Delivering Effective Project Management (USD 1.94 million; comprised of USD 1.06 National IDA and USD 0.88 Regional IDA). This Component will provide operational and technical assistance to the Project Management Unit and Ministry of Finance and Economic Development on Project management and implementation, including planning, reporting and auditing.


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3.2 Types of Subproject Activities The general types of subcomponent activities can be summarized into the following general activities which will be assessed and screened for their environmental and social risks:

Table 1 - Proposed Subproject Activities under Kiribati PROP

Project Subtype Description Technical Advisory (TA) These may include the development of monitoring and management

plans, training and capacity building programs, community education and outreach programs, needs assessments, gap analyses, and policy and legislation development. Specifically, these include: ▪ Preparation of a Kiritimati Ocean Resources Master Plan; Kiritimati

Sport Fishing Management Plan; and supporting implementation of the Kiritimati Island Marine Aquarium Trade Management Plan 2017.

▪ Marine Spatial Planning for Tarawa. ▪ Needs assessment for a CPPL operated small-scale fisheries

development and production centre. ▪ Development of a Kiribati Seafood Safety Scheme and Health Impact

Assessment. ▪ e-monitoring system installation. ▪ e-monitoring and UNCLOS (73) legislation. ▪ Fisheries law amendment. ▪ Development strategy and roadmap for four outer islands. ▪ Contamination impact and risk on food safety. ▪ Establishment of a seafood toxicology training and capacity building

program ▪ Seafood safety policy.

MFMRD Assets

These may include construction activities, such as: ▪ Construction of new MCS facilities in Betio and Kiritimati. ▪ Construction and operation of the two MFMRD laboratories on

seafood toxicology and coastal fisheries research within the centralized Kiribati One Health Support Institute (KOHSI) to be located in Betio.

Purchase of compliance vessels.

Outer Island Investments

These may include relevant materials and facilities, such as: ▪ Small boats. ▪ Safety at sea gear. ▪ Small-scale onshore processing equipment and facilities. ▪ Small-scale onshore storage facilities (e.g. ice and cold stores). ▪ Packaging tools and equipment (e.g., vacuum packaging for smoked

flying fish). ▪ Aquarium fish holding facilities and equipment.


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4 Environmental and Social Context 4.1 Coastal and Marine Ecosystems Kiribati is a nation of ocean stretching over an area of more than 3.5 million km2 across the central Pacific Ocean, forming one of the biggest Exclusive Economic Zones, and encompassing some of the world’s most diverse and productive ecosystems1. All the islands are of coralline origin and are surrounded by fringing or barrier coral reefs. The country is divided into three widely separated island groups - the Gilbert Group in the west, the Phoenix Group in the centre, and the Line Islands in the east - each surrounded by their own discrete portion of the EEZ2.

South Tarawa, in the Gilbert Islands, has a large reef area and mudflat, and its lagoon, which it shares with North Tarawa, is one of the largest in Kiribati (533.91 km2). Several types of the mangroves are found, namely the white mangroves (Sonneratio alba), te tongo buangui (Bruguiera gymnorhiza), te aitoa (Lumnitzera littores), and the red mangrove (Rhizophora stylosa)3.

Tarawa’s reef, mudflat, and lagoon were at one time abundant with fish and shellfish of many sorts but now many resources are scarce. Overfishing and pollution are the main causes for the scarcity of catches on the reef and in the lagoon. Other identified marine issues for South Tarawa include:

a) Lack and cost of fishing equipment; b) Competing of local fish companies and vendors with fish from Central Pacific Products Limited

(CCPL); c) Depleting lagoon resources in the nearby sea area and in the lagoon, ’te bun and tenouo; d) Continual contamination and pollution of the lagoon and beach as it is still being used for

toileting and rubbish dumping; e) The use of newly developed destructive fishing methods such as ‘water splashing for bonefish,

gillnetting schooling fish over lagoon reefs’4.

In addition, increasing domestic sand mining and land reclamation compound the erosion and vulnerability of the coastline and coastal ecosystems.

Kiritimati Island, in the Line Islands, is the largest coral island in the world and has a unique and delicate environment – a function of its isolation, size and atoll characteristics that have resulted in a diverse ecosystem endowed with extensive biophysical resources. The fringing coral reefs and patch reefs of Kiritimati are host to 83 species of coral, 235 species of fish, two marine reptiles, and marine mammals. Kiritimati has a large shallow lagoon and complex inner lagoon system that provides habitat for key commercial species, including the milk-fish (Chanos chanos) and bone fish (Albula glossodonta), which support artisanal and recreational tourist fishing. Its off-shore territorial waters are rich in fish stocks such as tuna and bill fish. The whole Kiritimati lagoon is a spawning area for the bone fish.

1 Ministry of Fisheries and Marine Resources Development, 2013. Kiribati National Fisheries Policy 2013̶ 2025 2 Fisheries and Aquaculture Organization of the United Nations, 2010.FAO Fisheries and Aquaculture Country Profiles – The Republic of Kiribati 3 Trama Tecnoambiental TTA, 2012. Kiribati Grid Connected Solar PV Power Station Project Environmental Impact Assessment. Prepared for the Ministry of Public Works and Utilities, the Republic of Kiribati, and the World Bank 4 Office of Te Beretitenti, 2012. Republic of Kiribati Island Report Series, 6. South Tarawa


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Some marine issues identified in Kiritimati include reduction of marine resources which may be caused by overfishing in certain areas, use of gill fishing nets, and unregulated harvest of resources5.

4.2 Fisheries Fishery resources are essential to Kiribati for revenue, food security, employment and income. The combined value of all Kiribati lagoon, coastal and oceanic fisheries is estimated to exceed AU$110 million per annum. Given their significance, it is fundamentally important that these resources are managed well and sustained for present and future generations. Kiribati lagoons and rich oceanic waters are home to numerous artisanal and small-scale commercial fisheries, aquaculture operations, commercial joint ventures, and foreign distant water fishing fleets, which fish in Kiribati’s EEZ and primarily land their catch in foreign ports at markets highly competitive in price6.

Kiribati also has the highest per capita consumption of fish in the world. The Food and Agriculture Organization of the United Nations (FAO) estimates that the per capita seafood consumption in Kiribati was 76.3 kg in 2013 (the global average is 20.2 kg). Kiribati’s coastal fisheries are subsistence and small-scale commercial fisheries that occur in lagoons, reefs, reef slopes and nearshore ocean areas. The I-Kiribati rely heavily on fishing activities for subsistence and commercial purposes. Surveys by the Fisheries Division indicate 88% of the households in Kiribati participate in fishing. Of those that do fish, 17% fish commercially full time, 22% fish commercially part-time, and 61% fish only for subsistence.

4.2.1 Commercial Fisheries The Western and Central Pacific Ocean is home to some of the world’s most abundant populations of tuna representing a multi-billion-dollar industry. The main tuna species targeted in this region are skipjack, yellowfin, bigeye and albacore. Kiribati has the most productive EEZ in the Western and Central Pacific and is an important tuna fishing zone for industrial fleets from several distant-water fishing nations (DWFNs). Of the fishing nations in the Pacific, Kiribati has the highest volume of catch, contributing 28.4% to the regional total in 2016. And, since introduction of the Vessel Day Scheme (VDS) in 2007, Kiribati has enjoyed a 612% increase in revenue from fishing licenses and transshipment fees7.

However, located 4,000 kms from its nearest markets, Kiribati is faced with extremely limited growth prospects beyond fisheries8. The Kiribati Development Plan (KDP) and Kiribati Vision 2020 (KV20) emphasize that increasing sustainable returns from fisheries is critical to ensuring inclusive growth and private sector development. Fishing revenue is the main source of income for the Government accounting for 75% of total government revenue in 2016. Fisheries license fees alone represent 61 percent of GDP. In 2015, the estimated exports of fish and fishery products were valued at USD 121.4 million, with tuna as main species exported. Tuna catches increased from 30% of total catch in 2005 to 96% in 2016. In addition, the sector provides direct benefits through subsistence coastal fisheries and jobs in fishing, processing and transshipment operations.

The majority of Kiribati’s offshore catches are for export and thus not landed but rather transshipped locally at three designated ports or at overseas ports. A significant amount of tuna is caught by industrial offshore operations, with most of the catch taken by vessels based outside the country. In 2014, 81 percent of catches caught by Kiribati-flagged purse seiners were transshipped in Kiribati as frozen tuna

5 Office of Te Beretitenti, 2012. Republic of Kiribati Island Report Series, 20. Kiritimati 6 Ministry of Fisheries and Marine Resources Development, 2013. Kiribati National Fisheries Policy 2013̶ 2025 7 MFED, RBA, ABS (from PCN) 8 Australia and New Zealand (from PCN)


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while the remainder were offloaded in other ports, mainly the Marshall Islands. In the same year, all pole-and-line catches were transshipped locally, while 90 percent of longline catches were transshipped in Samoa. In 2012, the Government established Kiribati Fish Limited (KFL), a joint-venture tuna processing plant based in Betio. Catches from the company’s vessels are landed and processed at the plant and exported to the United States and Japan9.

Small-scale commercial fishing is concentrated around Tarawa, where a sizable population, cash-oriented economy, and ice and cold-store facilities provide suitable market conditions. In Tarawa, accessing lagoon and deep-sea resources requires owning a canoe or a boat, fishing gears, and other necessities. The fishing catches are generally used for subsistence, but those who go fishing using motorized skiffs are usually fishing gangs employed by boat owners, and their catch is mainly for commercial purposes on South Tarawa10. Small-scale commercial landings at locations other than Tarawa have expanded in recent years due to increased ice production in the outer islands. Many islands now have cold storage, enabling storage for local sale and shipment to Tarawa. Estimates of coastal fisheries production for 2014 was 11,440 tonnes valued at USD 16 million, and for coastal commercial fisheries of 7,600 tonnes valued at USD 15.5 million. The total number of coastal artisanal fishing vessels in 2014 was 4,766. The main trend in coastal fisheries appears to be the increased exploitation of coastal resources close to urban markets coupled with a decrease in the fisheries production of Tarawa Lagoon due to overexploitation and a decrease in the abundance of coastal fisheries resources including beche-de-mer, aquarium fish on Christmas Island and finfish on Abemama Atoll.

4.2.2 Subsistence Fisheries About 60 to 70% of coastal fisheries production in Kiribati is for subsistence purposes (livelihood), with the remainder comprising artisanal and small-scale commercial fisheries11. Subsistence and small-scale commercial fishing are conducted throughout the islands using traditional canoes powered by sail or paddle, plywood canoes with outboard motors, and larger crafts powered by outboards. In South Tarawa, fish are important as a food source and a source of income for many unemployed men and school drop-outs, fishing for owners of fishing boats around South Tarawa. Betio, Bairiki, Teaoraereke and Bikenibeu are the main fishing centres selling mainly tuna, flying fish, and lagoon fish12.

People living outside urban centres or outer islands are described as subsistence farmers or fishermen involved in growing or gathering produce or fishing to feed their families by consuming them directly or by selling them in exchange for cash to buy basic needs and essential food (rice, flour, etc.).

On Kiritimati, local households mainly fish in the lagoon, though fishing in the ocean and from the reef are also common. Marine fish provide a large portion of the island of Kiritimati's nutrition, although overfishing has caused a drastic decrease in the populations of large, predatory fish over the last several years. Fish vendors are uncommon, most of the fishing expeditions are for family consumptions or for drying and sending to relatives in the Gilberts, South Tarawa in particular13.

9 MFMRD 2015 (from ISDS) 10 Office of Te Beretitenti, 2012. Republic of Kiribati Island Report Series, 6. South Tarawa 11 Ministry of Fisheries and Marine Resources Development, 2013. Kiribati National Fisheries Policy 2013̶ 2025 12 Office of Te Beretitenti, 2012. Republic of Kiribati Island Report Series, 6. South Tarawa 13 Office of Te Beretitenti, 2012. Republic of Kiribati Island Report Series, 20. Kiritimati


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4.3 Aquaculture Aquaculture in Kiribati is predominantly a livelihood-based activity. Some aquaculture activities in Kiribati in recent years have taken place on a limited scale, with only small-scale commercial production and limited export capacity. There are currently aquaculture operations in milkfish (Figure 1), pearls, seaweeds and seeding clams. While Kiribati has developed substantial knowledge and infrastructure in this area, it lacks clear strategies for development, business plans and some operational skills14.

Figure 1 - Adult milkfish collecting behind a sluice, Kiritimati

4.4 Recreational Fishing The only significant sport fishery in Kiribati is on Kiritimati. Sport fishing activities in Kiritimati involves foreign anglers visiting to fish for bonefish and large coastal pelagic species (e.g., giant trevallies, wahoo, tunas, and marlin) in the lagoons and nearshore areas. Kiritimati also attracts a small number of divers15. Sport fishing generates economic benefits of AUD 5 million/year through license fees, jobs for professional fishing guides and expenditure in hotels. The number of recreational fishermen visiting Kiribati in a given year is estimated to be around 1,200 from Australia, New Zealand and the USA suggesting opportunities for year-round revenue.

Tour guides for sports fishing generate healthy revenues with daily rates for seasoned guides amounting to USD100-150 per day while boat operators charge USD 350 per day and hotel operators charge USD140 per person per night. However, limited number of flights to Kiritimati (one per week to

14 Ministry of Fisheries and Marine Resources Development, 2013. Kiribati National Fisheries Policy 2013̶ 2025 15 Fisheries and Aquaculture Organization of the United Nations, 2010. FAO Fisheries and Aquaculture Country Profiles – The Republic of Kiribati


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Honolulu and Fiji) has constrained the numbers of sports fishers and contributed to an uncrowded unique fishing experience.

There are several existing and new nearshore ocean users including industrial transshipment vessels, fuel bunkers, container ships, subsistence fishers, small scale fishing boats and industrial fishing boats that may adversely affect the subsector if not carefully managed.

4.5 Marine Pollution The country’s transition from a traditional subsistence lifestyle to a market-based economy has brought with it several environmental challenges adversely affecting the health of Kiribati’s coastal fisheries. Key challenges include the unsustainable depletion of coastal fisheries resources and increasing waste and pollution in lagoons and coastal areas. These challenges are most evident in the heavily populated urban centers of Betio, South Tarawa, and Kiritimati Island. The main types of waste and pollutants affecting the health of Kiribati’s coastal fisheries and lagoon ecosystems and associated ecosystems are mismanaged solid waste and sewage discharge, agricultural run-off and run off from port areas. Lack of integrated waste management of these pollutants is a key threat to the marine environments of Kiribati.

One of the major concerns for fish and coral in the lagoon is the growing number of ship wrecks and the fear of oil spills from sunken vessels inside the lagoon. Disposal of wastes from mechanical shops and bus companies which directly dispose of waste oil into the ground or along the shoreline is a threat to the freshness and cleanliness of water lens across the island. In South Tarawa, sewage collected is discharged to the sea at the three main centres of Betio, Bairiki and Bikenibeu. However, the beach is still being used as toilet by many people, even by those that have flush toilets or pit latrines16. Furthermore, the habit of disposing of rubbish, especially into the sea, is also polluting beaches, coastal waters and the lagoon. Solid waste is now collected by the two South Tarawa local councils within their respective jurisdictions, but a lot of community education on proper disposing of rubbish is still required to ensure a healthy and clean environment17.

Although work in this area has advanced, there is limited knowledge on the impacts of pollution on the status of coastal ecosystems and fisheries. The Kiribati Integrated Environment Policy (2012) specifies some actions to address coastal and marine pollution, including establishment of a National Marine Pollution Advisory Committee that has prepared a national marine spill contingency plan to address the discharge of oils, chemicals and hazardous and noxious materials into the marine environment. However, further attention on the impacts of pollution from all sources on the health of coastal fisheries and the ecosystems upon which they depend, will be essential to ensuring the long-term viability of these resources and the health of the population that consumes them.

4.6 Marine Protected Areas and Wildlife Sanctuaries An Ecological gap assessment undertaken by MELAD showed that there is only one protected area in Kiribati that is formally gazette and recognized (the Phoenix Islands Marine Protected Area) and 9 wildlife sanctuaries located in Kiritimati island. The current national target for protected areas (which is

16 Office of Te Beretitenti, 2012. Republic of Kiribati Island Report Series, 6. South Tarawa 17 Office of Te Beretitenti, 2012. Republic of Kiribati Island Report Series, 6. South Tarawa


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inclusive of both marine and terrestrial) is 10% for each of the 3 island groups that make up Kiribati – i.e. 10% Gilbert Group, 10% Line Group, and 10% the Phoenix group18.

4.6.1 Phoenix Islands Marine Protected Area Kiribati’s only protected area, the 408,250km2 Phoenix Islands Protected Area (PIPA), covering about 11% of Kiribati’s EEZ, hold some of the world’s most pristine coral reefs as well as a great abundance and diversity of tropical marine life. The PIPA was established in 2010 to fulfill Kiribati’s commitment under the Convention on Biological Diversity. It is one of the Earth’s last intact oceanic coral archipelago ecosystems and the largest marine protected area under the World Heritage List and the second in the world. It is also the first reserve to place such a large area of open - ocean off-limits to commercial fishing. This coverage alone exceeds the current 10% national target for Protected Areas19.

4.6.2 Kiritimati Wildlife Sanctuary The entire island of Kiritimati is a Wildlife Sanctuary and access to five particularly sensitive areas is restricted. Kiritimati is a sanctuary and breeding ground in the Pacific for seabirds, supporting 18 different species of birds, including the endemic Christmas Island Warbler. The island is home, and a population stronghold, to the endangered Phoenix Petrel and the White Throated Storm Petrel. Nine protected zones are designated to support the breeding and nesting of the various bird species20. Motu Tabu has the world’s largest populations of Phoenix Petrel and White-Throated Storm Petrel, as well as high diversity and abundance of other seabirds. Cook Island is important for many species, with the Phoenix Petrel recolonizing since the island was made pest-free in 2009. Some areas have also been designated by government as ‘marine parks’ to protect them from excessive fishing by villagers using gill nets21.

4.7 Socio-Economic Environment Ninety percent of the total I-Kiribati population is of indigenous origin, the remaining proportion being non-indigenous Chinese and Europeans, many of whom have married indigenous partners. Of the population over the age of 3 at the time of the 2010 census, 92% read Kiribati (Gilbertese), and 76% read English. Some in-married individuals of Tuvaluan origin might speak Tuvaluan with each other, but there is no distinct discrete group that speaks another language.

No tribal groups exist in Kiribati. Clans comprise extended families. There is no island where those who are other than I-Kiribati reside as a block; residence is a random mix that relates to marriage and custom. Islands may have local myths and cultural practices regarding land ownership and inheritance that have evolved in earlier isolation but cannot be construed as discriminatory on the basis of indigeneity/ethnic status, which is specifically prohibited under Article 15 of the Constitution.

Poverty trends in Kiribati are difficult to assess given the infrequency of data collection. The 2006 Household Income and Expenditure Survey (HIES) showed that the poverty rate was 34.6 percent based

18 MELAD, 2012, Action Plan for Implementing the Convention on Biological Diversity’s Programme of Work on Protected Areas (Kiribati) 19 MELAD, 2012, Action Plan for Implementing the Convention on Biological Diversity’s Programme of Work on Protected Areas (Kiribati) 20 Trama Tecnoambiental TTA, 2012. Kiribati Grid Connected Solar PV Power Station Project Environmental Impact Assessment. Prepared for the Ministry of Public Works and Utilities, the Republic of Kiribati, and the World Bank 21 Office of Te Beretitenti, 2012. Republic of Kiribati Island Report Series, 20. Kiritimati


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on the lower MIC poverty line and 12.9 percent based on the international poverty line. Poverty rates were relatively higher in South Tarawa (24.2%) and the rest of the Gilbert Islands (22%) compared to the Line and Phoenix Islands (8.9%). The Gini Coefficient was 37, which is below the regional average.

Importantly. Kiribati is experiencing an acute rise in environmental and socio-economic problems caused by over-population, while at the same time lacking a sufficient population with the necessary qualification base to readily support the development of high-level skills in government and industry22. The population of South Tarawa is growing very rapidly. It grew by almost 10,000 people between 2005 and 2010, an annual population growth of 4.4%23. Overpopulation on South Tarawa is a growing concern as the population density is now reaching a level of 3184 people/km2 (2010 census), which is about 22 times the national average of 142/km2. The high population of South Tarawa, particularly on Betio, is a key driver of over-fishing in the Tarawa lagoon24.

4.8 Gender Roles in Fishing Almost all I-Kiribati have some form of involvement in fishing activities, whether it be artisanal, subsistence, boat-based, shore-based, harvesting, reef gleaning, processing or aquaculture. Traditionally, men have dominated fishing activities at sea while women have been heavily engaged in shore-based harvesting and processing activities. With the commercialisation of the artisanal fishing, especially on South Tarawa, the contribution made by women has increasingly become part of the daily management and running of fish outlets. Today, women are regarded as team players for their major role in the development and support of Kiribati fisheries, especially in the marketing and sale of fish. Because of the danger of handling unfriendly species at sea (sharks, swordfish, etc.) and the risk of going adrift when there is sudden change of weather or breakdown, women are not expected to fish at sea25.

In terms of gender considerations in the sector, fisheries employment information based on the Kiribati 2010 census is presented in Table 2 and illustrates clearly that men hold the vast majority of jobs across all categories in the sector.

22 Ministry of Fisheries and Marine Resources Development, 2013. Kiribati National Fisheries Policy 2013̶ 2025 23 Office of Te Beretitenti, 2012. Republic of Kiribati Island Report Series, 6. South Tarawa 24 Ministry of Fisheries and Marine Resources Development, 2013. Kiribati National Fisheries Policy 2013̶ 2025 25 Ministry of Fisheries and Marine Resources Development, 2013. Kiribati National Fisheries Policy 2013̶ 2025


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Table 2 - Fisheries employment information by sex, age, and job category (2010)26

Total Male Female Age → Job category ↓

All 15-24 25-34 35-49 50+ 15-24 25-34 35-49 50+

Fishing guides 14 3 4 4 3 0 0 0 0 Seaweed farmers 126 22 18 29 11 16 9 15 6 Coastal fishers 2730 707 715 787 362 44 34 58 23 Other fisheries workers

152 31 39 27 12 6 10 16 11

Deep-sea fishers 122 29 32 42 12 1 2 3 1 Other fisheries workers

7 1 4 0 0 1 1 0 0

Fishery assistants 27 5 6 6 2 0 3 5 0 Total 3178 798 818 895 402 68 59 97 41

4.9 Climate Change and Natural Hazards 4.9.1 Climate Change It is widely recognized that Pacific island nations are among the world’s most physically and economically vulnerable to climate change and extreme weather events and Kiribati is one of the most vulnerable countries in the world. The effects of sea level rise, storm surge, extreme precipitation and flooding, coastal erosion and saltwater intrusion increase Kiribati’s vulnerability given that most of its atolls are only 1.8 meters above sea level. A 2000 World Bank study showed that the percent change in groundwater thickness was projected to decrease by 12% with a 0.4-meter sea level rise and 10% reduction in rainfall. However, factoring in a reduction in island width, holding other parameters stable, groundwater thickness fell by 38%. Such that sea-level rise threatens to render Kiribati uninhabitable (through loss of its freshwater lens) well before it is submerged.

Climate change will make current development challenges worse throughout Kiribati, but this is especially true in South Tarawa. Climate change issues identified by the South Tarawa community include:

• Coastal erosion • Depletion of marine resources • Overcrowding • Lack of water and poor water quality27.

Forecasts from recent scientific studies show that climate change is also likely to have substantial impacts on Kiribati coastal and oceanic fisheries, their habitats and reefs, and the little land available to I-Kiribati (811 km2). Climate change is projected to alter ocean temperatures and currents, with resulting impacts on oceanic marine ecosystems28.

In 2008, SPC released a policy brief that summarised the findings of an ongoing study into climate change impacts on Pacific fisheries. The policy brief noted that national plans to optimise benefits from

26 Gillett (2016) from Kiribati 2010 Census 27 Office of Te Beretitenti, 2012. Republic of Kiribati Island Report Series, 6. South Tarawa 28 Ministry of Fisheries and Marine Resources Development, 2013. Kiribati National Fisheries Policy 2013̶ 2025


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fisheries should be adapted to the likely changes in environmental conditions caused by climate change. Three key challenges for Kiribati are:

• Changes to the distribution and abundance of tuna. Climate change would result in alterations to water temperatures, currents, and marine food chains. This is projected to affect the location and abundance of tuna species. The policy brief suggested that concentrations of skipjack tuna would likely be located further to the east than in the past (with potential benefits for Kiribati).

• Decline in coral reefs and coastal fisheries. Rising sea surface temperatures and more acidic oceans will likely impact on the growth of hard corals (and their complex fish habitats). Degraded coral reefs are likely to support different types of fish and perhaps lower yields. This may be a significant concern for Kiribati as it is likely to result in reduced catches of reef fish, with significant ramifications for food security and fisheries development.

• Damage to infrastructure. More powerful storms are predicted, with increased risks of damage to wharfs and essential infrastructure. This may also create higher financial risks for coastal aquaculture due to more frequent damage to equipment29.

4.9.2 Natural Hazards Unlike many other Pacific islands, Tarawa rarely experiences cyclones as it lies outside the main cyclone belt. However, it is susceptible to storm surges and to droughts, particularly during La Niña events. Rainfall is much higher than normal during an El Niño event and much lower during a La Niña event. Prolonged drought periods were encountered in 1988 to early 1989, followed by another in 1998 extending into mid-1999 and resulting in the loss of many valuable food crops including coconuts (Cocos nucifera) and breadfruits (Artocarpus sp.).

Despite its proximity to the Intertropical Convergence Zone (ITCZ), Kiritimati is located in an equatorial dry zone and rainfall is rather low, except during El Niño years, at 873 mm (34.4 in) on average per year. In some year’s rainfall can be as little as 177 mm (7.0 in) and much of the flats and ponds can dry up such as in late 197830. Kiritimati is thus affected by regular, severe droughts. They are exacerbated by its geological structure. As Kiritimati is a raised atoll, and although it does occasionally receive plenty of precipitation, little is retained given the porous carbonatic rock, the thin soil, and the absence of dense vegetation cover on much of the island, while evaporation is constantly high. Consequently, Kiritimati is one of the rather few places close to the Equator which have an effectively arid climate.

29 Ministry of Fisheries and Marine Resources Development, 2013. Kiribati National Fisheries Policy 2013̶ 2025 30 Teeb'aki in Scott, Derek A. 1993. Republic of Kiribati. International Waterfowl and Wetlands Research Bureau


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5 Legal, Policy Framework and Regulatory Requirements 5.1 World Bank Policies The Kiribati PROP project has been screened as Category B as the environmental and social outcomes are mostly beneficial and the residual risks are low to moderate and readily mitigatable. Safeguards and Stakeholder risks are deemed to be Moderate. Relevant Bank policies triggered for the program include OP 4.01 Environmental Assessment; OP 4.04 Natural Habitats; and OP 4.12 Involuntary Resettlement. Detailed information on Bank safeguard policies are available at http://go.worldbank.org/4D2JSWFIW0.

The safeguard operational policies (OPs) that apply to the program are:

• OP 4.01 Environmental Assessment – This policy requires the conduct of an environmental assessment (EA) of projects/programs proposed for Bank financing to help ensure that they are environmentally and socially sound and sustainable. This is the umbrella policy for the Bank's environmental and social safeguard policies.

The project objective is to enhance the safety and value of selected fisheries and will involve various technical assistance components as well as some minor construction activities. The construction activities have the potential to cause a number of environmental and social impacts such as land access and acquisition, gender issues, resettlement, land disturbance and construction worker occupational health and safety which will be addressed through the ESMF and Land Access and Resettlement Policy Framework (RPF). Technical assistance projects will consider the potential impacts from over fishing as well as contamination and the associated fish toxicology issues.

The Kiribati PROP is expected to have overall positive environmental and social impacts on the coastal community and natural habitats through improved marine management practices, improved compliance and improved food safety. Due to the uncertain nature of the specific sub-projects and the scope of the proposed TAs, and as with the other PROP projects in the Pacific Island Countries (PIC) region, a project-specific ESMF has been developed to provide guidance on due diligence requirements for sub-projects as they are defined.

• OP 4.04 Natural Habitats – This policy aims to support the protection, maintenance and rehabilitation of natural habitats and promotes the conservation of natural habitats for long-term sustainable development through a precautionary approach. The project physical activities will take place within the marine and coastal zones of Tarawa lagoon and Kiritimati Island where there is also a bird sanctuary. The project will promote the sustainable development of a shore-based value addition industry for the offshore tuna fisheries sector. It will also identify and promote other sources of blue revenue for coastal communities, which all depend on the sustained presence and health of coastal and marine habitats. In addition, the project will seek to reduce coastal and marine pollution impacts on the fisheries sector. No critical natural habitats will be impacted. All TA activities will be planned in a manner to preserve natural habitats.

• OP-4.12 Involuntary Resettlement - This policy aims to restrict the involuntary taking of land or any form of economic displacement of populations affected by or participating in World Bank financed activities; and where displacement is unavoidable, to assist persons to improve (or at least restore) their incomes and standards of living; and to identify and accommodate the needs of vulnerable groups. The construction projects may require resettlement triggering OP 4.12. An RPF has been prepared to manage potential impacts.

http://go.worldbank.org/4D2JSWFIW0

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5.2 Applicable Legislation, Policies and Regulations 5.2.1 International Context Kiribati is a signatory to a number of international agreements. Listed below are some of the more applicable agreements to the type of activities of the PROP project. This list is not exhaustive:

Convention for the Protection of the World Cultural and Natural Heritage (2004). This convention founded the UNESCO World Heritage Site List (the List). To be a site on the List, it must be a place of special cultural or physical significance. The programme catalogues names and conserves sites of outstanding cultural or natural importance to the common heritage of humanity. Kiribati became a signatory to this convention in 2000. The Phoenix Islands Protected Area was the first site in Kiribati to be inscribed on the World Heritage List in 2010.

Convention on Biological Diversity (CBD) (1998). The CBD has three main goals: conservation of biodiversity; sustainable use of biodiversity; and the fair and equitable sharing of benefits arising from the use of genetic resources. The CBD was opened for signature at the Earth Summit in Rio de Janeiro in 1994 and was ratified by Kiribati in 1998. As part of its obligations to the CBD, Kiribati has developed the Biodiversity Strategy and Action Plan (K-NBSAP), in which Kiribati commits to meeting the Convention on Biodiversity (CBD) Achi goals of 10% land and marine conservation by 2020.

FAO Agreement (1993). The 1993 FAO Compliance Agreement seeks to encourage countries to take effective action, consistent with international law, and to deter the reflagging of vessels by their nationals as a means of avoiding compliance with applicable conservation and management rules for fishing activities on the high seas. Kiribati signed the treaty in October 1993.

Forum Fisheries Agency Convention (1979). The FFA Convention is the founding document of the Pacific Islands Forum Fisheries Agency, which was established and signed by 12 countries in 1979 in Honiara, Solomon Islands. Since its inception, this membership has increased to 17 countries. The FFA consists of the governing body - the Forum Fisheries Committee (FFC), which meets annually to approve the budget and work programme, and the FFA Secretariat. The central function of the FFA is to enable member countries to manage, conserve and use the tuna resource through enhancing national capacity and strengthening regional solidarity. Kiribati is a member of the FFA.

Parties to the Nauru Agreement (1982) (PNA). In February 1982, the Nauru Agreement Concerning Cooperation in the Management of Fisheries of Common Interest was opened for signature. The Nauru Agreement had been negotiated by seven Pacific Island states – Federated States of Micronesia, Kiribati, the Republic of the Marshall Islands, Nauru, Palau, Papua New Guinea and Solomon Islands. This group of countries (later joined by Tuvalu) is known collectively as the Parties to the Nauru Agreement (PNA)31.

The Nauru Agreement began a new era in Pacific Island cooperation in the management of the region’s tuna stocks. It was an important milestone in the exercise of coastal states’ sovereign rights over their 200-mile EEZs. The PNA group accounts for most of the tuna catch in the Pacific Island region. In 1999, it produced 98 percent of the tuna catch taken from the EEZs of Pacific Island Forum Fisheries Agency (FFA) members; 70 percent came from three PNA members: PNG, FSM and Kiribati. The group also

31 Fisheries and Aquaculture Organization of the United Nations, 2010. FAO Fisheries and Aquaculture Country Profiles – The Republic of Kiribati


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accounted for 94 percent of the access fees paid to FFA Pacific Island states. The most important fishery management tool of the PNA is the Vessel Day Scheme (VDS)32.

United Nations Convention on the Law of the Sea (UNCLOS) (1982). Kiribati signed the treaty in 2003 but has not yet ratified the agreement. The convention lays down a comprehensive regime of law and order in the world’s oceans and seas establishing rules governing all uses of the oceans and their resources. It enshrines the notion that all problems of ocean space are closely interrelated and need to be addressed as a whole. With specific regard to the protection and preservation of the marine environment, Part XII includes the following Articles:

• 192: a general obligation of States to protect and preserve the marine environment. • 204: requires States to endeavour, as far as possible to monitor the effects of any activities that

they permit in order to determine whether these activities are likely to pollute the marine environment.

• 206: provides for States to conduct Environmental Impact Assessments of planned activities that have the potential to cause substantial pollution or significant and harmful changes to the marine environment.

Western and Central Pacific Fisheries Convention (WCPFC). Kiribati is a member of the Western and Central Pacific Fisheries Commission that was established by the Convention for the Conservation and Management of Highly Migratory Fish Stocks in the Western and Central Pacific Ocean33. The Convention entered into force in June 2004. The WCPFC entered into force on 19 June 2004 and is based on the 1995 UN Fish Stocks Agreement. It addresses the specific characteristics of the western and central Pacific Ocean tuna fisheries and established conservation and management measures by consensus of if members. Kiribati is a member of the convention and is an active participant in the Commission and its scientific and technical committees.

32 Ministry of Fisheries and Marine Resources Development, 2013. Kiribati National Fisheries Policy 2013̶ 2025 33 Fisheries and Aquaculture Organization of the United Nations, 2010. FAO Fisheries and Aquaculture Country Profiles – The Republic of Kiribati


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5.2.2 National context 5.2.2.1 Fisheries Management Fisheries Act 2010. The basic fisheries law of Kiribati is the Fisheries Act and its amendments. In this legislation the “Minister may take such measures FAO Fisheries and Aquaculture Department as he shall see fit to promote the development of fishing and fisheries in Kiribati to ensure that the fisheries resources of Kiribati are exploited to the full for the benefit of Kiribati.”

Important aspects of the Act are:

- The Minister is empowered to appoint a Chief Fisheries Officer and licensing officers for the purposes of carrying out the provisions of the Act.

- The President, acting in accordance with the advice of the Cabinet, has wide powers to make regulations relating, inter alia, to the licensing of foreign fishing vessels, the conditions to be observed by foreign fishing vessels, the conservation and protection of all species of fish, prohibited fishing gear and methods and the organization and regulation of marketing, distribution and export from Kiribati of fish and fish products.

- A regulatory framework for the operation of fish processing establishments is created. - There is a provision to prohibit the taking of fish in any sea or lagoon area or on any reef

forming part of the ancient customary fishing ground of the people except by members of the concerned group or under a licence granted by the Minister in his discretion.

- There is a prohibition on the use of explosives, poisons and noxious substances for the purpose of catching fish34.

Other legal instruments relevant to fisheries include:

• The Marine Zones (Declaration) Act (1983) which defines and establishes a twelve nautical mile territorial sea and a 200 nautical mile exclusive economic zone.

• The Fisheries (Pacific Island Parties’ Treaty with United States of America) Act (1988) implements the Treaty on Fisheries Between the Governments of Certain Pacific Island States and the Government of the United States of America.

• The Native Lands Code gives legal recognition to ownership of fish traps, reefs and fish ponds. Many of the island councils throughout Kiribati have rules concerning fishery practices.

• Local Government Act (1984) is also significant due to the involvement of Island Councils in the management of coastal fisheries within three nautical miles.

• The Environment Act (1999) also provides significant provisions to promote resource conservation and protection of marine biodiversity.

5.2.2.2 Environmental Legislation The Environment Act 1999 (and 2007 Amendments) is the primary environmental legislation of Kiribati which provides for the protection, restoration and enhancement of Kiribati’s natural, social and cultural environment.

The objects of the Environment Act 1999 were -

34 Fisheries and Aquaculture Organization of the United Nations, 2010. FAO Fisheries and Aquaculture Country Profiles – The Republic of Kiribati


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a) to provide for and establish integrated systems of development control, environmental impact assessment and pollution control;

b) to prevent, control and monitor pollution; c) to reduce risks to human health and prevent the degradation of the environment by all practical

means, including the following — i. regulating the discharge of pollutants to the air, water or land; ii. regulating the transport, collection, treatment, storage and disposal of wastes;

iii. promoting recycling, re-use, reduction, composting and recovery of materials in an economically viable manner; and

iv. to comply with and give effect to regional and international conventions and obligations relating to the environment;

d) protecting and conserving the natural resources threatened by human activities, particularly those resources of national and ecological significance as may be classified under the categories of terrestrial vegetation, coral, fish and marine life.

The 1999 Act established the Environment and Conservation Division (ECD) within the Ministry of Environment, Land and Agricultural Development (MELAD) as the line Division with the mandate for environmental protection, resource conservation and sustainable development. The ECD must respond to all environmental safeguard issues arising in Kiribati. This includes advising project proponents on environment license requirements including need for environmental impact assessment (EIA), inspecting environmental violations and compliance issues and enforcing non-compliance. The ECD must also deliver environmental communication, education and public awareness on Kiribati’s environment protection and management and protection requirements at the local, national, regional and international level.

The Act outlines requirements for impact assessment and statements relating to development. Activities are ‘scheduled' according to their environmental significance. Activities that are considered to create a significant environmental impact require application for environmental license. Some activities further require an EIA report. The decision to grant the license and the provision of conditions are set out in Section 38 of the Environment Act 2007, are made according to the principles of sustainable development and with any international obligations or agreements to which Kiribati is bound, and any other prescribed requirements. The environmental licensing process is detailed next.

5.2.2.2.1 Environmental Licence Process Environment licenses are required from MELAD for all activities that are deemed environmentally significant. When a proponent wishes to undertake a project, the Schedule of Environmentally Significant Activities should be consulted to determine if the activity might trigger an environmental assessment. Any construction work designed to enable an ESA also requires an environment licence. If the type of work is not found in the Schedule and if it does not involve permanent loss of land or coastline, or deal with any polluting materials, no further environmental considerations are needed. However, if it does match one or more of the activities on the list a license application must be completed and submitted to ECD.

The environmental licence application process is outlined in Figure 2.


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Figure 2 - Kiribati Environmental Approvals Application Process35

35 MELAD, 2019. ECD Environment Licence Application Guideline – Version 4


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If there are no objections within the 30-day period, the license is issued, construction can begin, and the assessment process is essentially complete. The ECD is then responsible to monitor the activity’s progress to ensure compliance with the license conditions.

5.2.2.3 Land Acquisition and Lease Approvals Native Lands Act and Amendment 2011 and The Native Lands Ordinance (Cap. 61, 1977) provides for native land and registration of title thereto and as well regulates (restrictions to) alienation of native lands. Native in this context generally refers to any aboriginal inhabitant and descendants thereof, whether wholly or partly of aboriginal descendant. The State Acquisition of Lands Ordinance (Cap. 95B) 1979 is a current law that regulates compulsory acquisition of land by the Republic for public purposes absolutely or for a specified term. Thus, the Native Lands Ordinance and State Acquisition of Lands Ordinance provide for land alienation (native or non-native) and acquisitions.

The Land Planning Ordinance (Cap.48, 1977) is the legal instrument that allows for the designations of land for specific purposes (e.g. water reserve protection) and defines a general land use plan as “indicating the use or class of use to which every part of the land depicted thereon maybe permitted to be put on for development or redevelopment”.

The Environment Act 1999 (amended 2007) recognized the culture and traditions of the people in decision making and the application of traditional knowledge in the conservation and sustainable use of biodiversity in Kiribati. Administration of land titles and land registration are responsibilities of the Land Management Division (LMD) within the Ministry of Environment, Land and Agricultural Development (MELAD). The Land Information & Administration Section within LMD is responsible for undertakings related to the State acquisition of land under the Native Lands Ordinance. In some cases, the Land Planning & Development Section and the Land Survey & Technical Section are also involved. The Chief Lands Officer is responsible for determining boundaries and compensation.

Kiribati appears to have two levels of government - central government, based in Tarawa, and Island Councils.

5.2.2.4 Health and Safety The Kiribati Occupational Health and Safety Act 2015 intends to achieve the intended purposes inherent in the Occupational Safety and Health Convention 1981, the 2002 Protocol on Occupational Safety and Health, and the Promotional Framework for Occupational Safety and Health Convention 2008. The 2015 Occupational Health and Safety Act set the country’s first comprehensive framework for occupational safety and health standards for the workplace. The Ministry of Labor and Human Resources Development is responsible for enforcing the standards. Employers are liable for the expenses of workers injured on the job. By law workers may remove themselves from situations that endanger their health or safety without threat to their employment 36.

5.2.2.5 Wildlife/Biodiversity Conservation The Wildlife Conservation Ordinance, Chapter 100, revised edition 1977, provides legal protection to Kiribati’s wildlife, under the responsibility of the Ministry of Environment, Lands and Agricultural Development.

36 United States Department of State Bureau of Democracy, Human Rights and Labor, 2017


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The Wildlife Conservation Ordinance (1977) allows the Minister to declare areas as wildlife sanctuaries and protection of specific animal and bird species. Within a wildlife sanctuary no person shall hunt, kill or capture any bird or other animal (other than a fish) or search for, take or wilfully destroy, break or damage the eggs or nest of any bird or other animal. “Closed areas” are wildlife sanctuary areas which are only accessible by license holders, wildlife wardens and public officers.

MELAD are also responsible for administering the Biosecurity Act 2011 which controls the movement of plants and animals and their products in order to prevent the establishment and spread of animal and plant pests and diseases that can harm human health and the agricultural economy of a country. The Biosecurity Act 2011 establishes a regime to control the import and export of regulated pests and diseases (Parts 2, 3, 4 and 5). The biosecurity functions of the Government are set out in section 6. The key administrative feature is the provision in Part 10 for the designation of a Director of Biosecurity and biosecurity officers for Kiribati.

Land put aside for reserves has three main pieces of legislation. The Recreational Reserves Act 1996 allows for land owned or leased by the Government to be reserved for recreational purposes for the use and enjoyment of the people of Kiribati. The Prohibited Areas Ordinance 1957 provides for certain islands and their territorial waters to be prohibited areas, set aside for conservation purposes. The following islands and territorial water are declared prohibited areas: Birnie, Canton, Enderbury, and Hull. The Closed Districts Act 1990 allows for parts of islands to be declared for conservation purposes.

5.2.2.6 Other relevant legislations, plans and policies: Kiribati Biodiversity Strategy and Action Plan (K-NBSAP) (2005). Governmental commitments to site conservation include the K-NBSAP, which commits Kiribati to meeting the Convention on Biodiversity (CBD) Achi goals of 10% land and marine conservation by 2020. Government of Kiribati is a CBD signatory which enjoins Parties to establish “a system of protected areas or areas where special measures need to be taken to conserve biological diversity”37.

Kiribati Development Plan (KDP) (2016-2019) and Kiribati Vision 2020 (KV20). The KDP for 2016-19 is the guide for formulating policies and programs to advance inclusive economic development in Kiribati. The KDP and KV20 emphasize that increasing sustainable returns from fisheries is critical to ensuring inclusive growth and private sector development. The KDP focuses on six priority areas: (i) human resource development; (ii) economic growth and poverty reduction; (iii) health; (iv) environment; (v) governance; and (vi) infrastructure. Among the strategies under the economic growth and poverty reduction priority are providing for the sustainable development of the fishing industry, maximizing economic returns from marine resources and ensuring that that the most vulnerable groups in the population are cared for.

National Tourism Action Plan (2009-2014). This National Tourism Action Plan was designed to provide the necessary strategies to stimulate a sustainable tourism industry that helps support the economy, community and the people of Kiribati. The plan explored a five-year vision for the Government of Kiribati to strive to achieve by the year 2014. The plan provided the vision, goals, targets and actions necessary to meet the challenges and capitalise on the tourism opportunities available for Kiribati.

37 MELAD, 2012, Action Plan for Implementing the Convention on Biological Diversity’s Programme of Work on Protected Areas (Kiribati)


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5.3 Gap Analysis The gap analysis (Table 3) highlights the difference between the applicable Bank safeguard policies and Kiribati’s laws, standards and regulations, and relevant measures for addressing key gaps. The processes will be harmonized as much as possible, so that the requirements of Kiribati and the World Bank will be met with any safeguard instrument that is prepared. The minimum will be that Kiribati law will be adhered to and then any gap filling for World Bank policies and processes will be done.


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Table 3 - Gap Analysis

Safeguard Requirement Aspect/ Gap Proposed Project Measures Public Consultation Affected persons/communities are provided timely and relevant information and informed about their options and rights.

The Environment Act requires that during the preparation of the EIA report the applicant must attempt to consult stakeholders, potentially affected persons, and any other person who would have an immediate interest in the activity and likely to be affected by the proposal. Consultation normally takes place twice during the preparation of an EIA; once to introduce the project and secondly to present draft results. The Principal Environment Officer (PEO), at his/her discretion, can also require additional consultations as part of the first license application decision38.

Safeguard instruments prepared under the project will require consultation with all stakeholders and affected persons as per I-Kiribati requirements and as set out in the Stakeholder Engagement Plan (SEP) found in Annex I.

Public Disclosure The disclosure of all documents is required under the Bank’s safeguards policies.

Public disclosure of documents is prescribed in the Environment Act (2017). Once the ECD has cleared the EIA as acceptable it is placed in the public record or a summary is distributed for comment. However, the method of disclosure is not prescribed and is at the discretion of the PEO.

Public disclosure of safeguards documents prepared under the project is required as set out in the SEP found in Annex I.

GRM Appropriate and accessible grievance mechanisms are established for affected persons/communities.

Customary and formal grievance mechanisms are normally managed and approved on a project-by project basis. Under the Constitution, there is provision for appeal to the High Court on issues of land compensation and title. Therefore, grievance mechanisms appear to be limited to constitutional provision for appeal to the High Court on issues of compensation and title.

A Grievance Redress Mechanism (GRM) has been developed and is included in Annex XIV of the ESMF to enable issues to be addressed in a transparent and responsive manner.

Vulnerable Groups Under World Bank Safeguards particular attention is paid to the needs of vulnerable groups.

There are no specific provisions for vulnerable people in Kiribati law. However, there are practices that are embedded in the customs and traditions of Kiribati.

Activities will require participation and consultation of vulnerable groups as set out in the SEP found in Annex I.

Land Acquisition and Livelihood Restoration

The Kiribati Constitution and laws are quite explicit on the compensation for the acquisition of private land needed in the

Provide compensation to all affected persons at full replacement cost as defined in the Resettlement Policy

38 Baines, J. 2014. Kiribati: Institutional Stocktake For Environmental & Social Safeguards. World Bank Safeguards Review.


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Where physical relocation is necessary displaced persons are provided compensation, transitional assistance and support to enhance or restore livelihoods.

public interest, namely the rehabilitation of I-Kiribati adversely affected by the project. The Native Lands Ordinance and State Acquisition of Lands Ordinance provide for land alienation (native39 or non-native) and land acquisitions. However, consultations are not always required where the land is commercial and government owned and livelihood restoration appear to be limited to financial compensation for land that is legally registered.

Framework (RPF) (Annex II) and under OP4.12. Any Resettlement Policy Framework (RPF)/Resettlement Action Plan (RAP) prepared under the project will specify full compensation and measures to enhance or restore livelihoods where necessary. Activities under the project will also require participation and consultation of affected persons for prepared safeguard instruments as set out in the (SEP) found in Annex I.

Involuntary Resettlement Involuntary resettlement (and acquisition of land) should be avoided where feasible, or minimized, exploring all viable alternative project designs.

The Native Lands Ordinance and State Acquisition of Lands Ordinance provide for compensation arrangements in the case of involuntary resettlement, provided those resettled are not in default of any current law (i.e. not illegal settlers/squatters). Basic legal provisions addressing involuntary resettlement appear to be limited to financial compensation for land that is legally registered. Furthermore, evidence that alternatives have been considered is also not always required under Kiribati law.

The RPF (Annex II) states that acquisition of land will only be pursued once all viable alternatives have been considered and no other suitable sites exist. The process and agreements between the Government and the landowner will be based on an RPF/RAP prepared under the project and approved by the Bank. Activities under the project will require participation and consultation of affected persons for prepared safeguard instruments as set out in the SEP found in Annex I.

Environmental Instruments Environmental assessment of all project activities (including TAs) is required to ensure they are environmentally and socially sound and sustainable.

The Environment Act 1999 requires that an environmentally significant activity (ESA), as listed in the Schedule of the Environment Act, and the construction work designed to enable an ESA must be carried out in accordance with an environment licence. However, there are still some legislative weaknesses allowing exemptions from the Environment Act provisions allowing potentially harmful practices and omitting the specification of important requirements for good practice40. Furthermore, there are no direct safeguard requirements for TAs (plans and policies), whereas the WB requires screening for TAs for possible downstream environmental and social impacts and preparation of relevant safeguard instruments41.

The greatest requirement in terms of safeguards instruments will prevail. For example, where an EIA is required under Kiribati law, and an ESMP for the World Bank, the EIA would prevail and an ESMP integrated in the EIA. TAs will be screened for possible downstream environmental and social impacts and relevant safeguard instruments prepared.

39 Native in this context generally refers to any aboriginal inhabitant and descendants thereof, whether wholly or partly of aboriginal descendant. 40 Baines, J. 2014. Kiribati: Institutional Stocktake For Environmental & Social Safeguards. World Bank Safeguards Review. 41 All TA activities in Bank assisted projects, irrespective of their sources of financing and whether they are stand-alone or as part of an investment operation, should be reviewed for their potential environmental and social implications, risk and impacts and therefore, subject to Bank safeguard policies when applicable.


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6 Potential Environmental and Social Impacts and Measures to Mitigate

The Project is expected to have an overall positive impact on coastal communities and natural habitats in the Gilbert and Line Islands through addressing health and safety issues associated with fishing and vessel use, capacity building regarding fisheries management and prevention of IUU fishing and investigating contamination and fish toxicology with a focus on protecting local consumer health. Investments are not expected to include activities that would generate significant risk or irreversible impacts. The emphasis will be on equitable distribution of project benefits, whilst also providing opportunities for long-term, meaningful and high-quality employment for women.

However, some of the potential sub-projects identified have associated environmental risks and potential impacts, such as those resulting from short-term demolition and construction activities (hazardous materials, waste disposal, noise, dust, pollution, health and safety); toxicology sampling (safety at sea and biological sample disposal) and laboratory chemical storage and disposal. In addition, technical assistance investments will assist with optimization of commercial and subsistence fishing projects and, as such, will include an assessment of potential impacts from over fishing and propose the required control measures.

Project typologies that have been identified as requiring environmental and social screening and management during implementation include 1) Technical Advisory; 2) MFMRD Assets; and 3) Outer Island Investments. The impacts of these activities can be readily mitigated through standard mitigation measures, if they are screened and managed properly.

The following tables provide a preliminary analysis of the type of project activities identified, potential social and environmental impacts that may result from the project activities, key mitigation methods for residual impacts, and safeguard tools that may need to be required.


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Activity Significant Potential Impacts Key Mitigation Methods Safeguard Tools Technical Advisory Monitoring and management plans, needs assessments, gap analyses, and policy and legislation development.

Lack of citizen / stakeholder engagement leading to ill-informed policy not meeting the needs of the industry or communities. Longer term issues of unfair outcomes or loss of livelihoods or subsistence opportunities for vulnerable people/communities if no integrated social impact assessment or socio-economic assessment. Longer term issues such as biosecurity incursions, pressures on fish stocks, and/or ecosystem changes/impacts if there is no integrated or strategic environmental impact assessment. Recommendations for future investments in physical infrastructure that could: change land ownership and land use requiring resettlement, create ongoing water pollution, increase safety risks to water users, increase pollution from vessels, change foreshore environments, affect livelihoods and subsistence lifestyles. Changes to livelihood opportunities and subsistence sources of protein from changes in fisheries management.

As a minimum, include environmental and social safeguards clauses and the requirement for meaningful stakeholder and citizen engagement into the consultants Terms of Reference (TOR) and activities and review the approaches and outcomes for compliance with the ESMF and the World Bank policies. For TA influencing downstream physical investments e.g. sub-components 2(c) and 2(d), include environmental and social screening and scoping processes or preliminary impact assessments in the TOR, to be prepared by specialists. For fisheries management plans, include ecological impact assessment (particularly of new species) and socio-economic impact analysis (particularly of vulnerable groups) and citizen engagement in the TOR, to be prepared by specialists.

N/A

Training and capacity building programs.

Downstream impacts that are contrary to good environmental management and community well-being. Negative reaction to perceived fairness of resource distribution.

Include both environmental and social, and health and safety best practices into training and capacity building programs. Ensure training and capacity building programs are gender equitable and involve stakeholder engagement principles / are consistent with the SEP (Annex I).

N/A


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Activity Significant Potential Impacts Key Mitigation Methods Safeguard Tools Citizen engagement, using I-Kiribati cultural norms, when developing the program.

Preparation of a Kiritimati Ocean Resources Master Plan; Kiritimati Sport Fishing Management Plan; and supporting implementation of the Kiritimati Aquarium Fish Management Plan; and Marine Spatial Planning for Tarawa.

Downstream impacts that are contrary to good environmental management and community well-being. Changes to livelihood opportunities and subsistence sources of protein from changes in fisheries management e.g. the increased use of coastal fish aggregating devices (FADs). Lack of citizen / stakeholder engagement leading to ill-informed policy not meeting the needs of the communities.

Include Environmental and Social Specialist on the planning team. Safeguards Officer contributes to writing of the TOR and review of deliverables to check for compliance with ESMF and World Bank Policies. Include environmental and social safeguards clauses, the preparation of preliminary impact assessments by specialists, and the requirement for meaningful stakeholder and citizen engagement into the consultants Terms of Reference (TOR) and activities and review the approaches and outcomes for compliance with the ESMF and the World Bank policies.

N/A

Development of a Kiribati Seafood Safety Scheme and Health Impact Assessment.

Downstream impacts that are contrary to good environmental management and community well-being. Outreach campaigns do not meet the needs of the communities.

Safeguards Officer contributes to writing of the TOR. include environmental and social safeguards clauses and the requirement for meaningful stakeholder and citizen engagement into the consultants Terms of Reference (TOR). Safeguards Officer reviews outreach reports to check for compliance with ESMF and World Bank Policies.

N/A


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Activity Significant Potential Impacts Key Mitigation Methods Safeguard Tools MFMRD Assets Construction and/or renovation of existing buildings, such as: - New fit for purpose MCS facilities in Betio and Kiritimati. - Construction of the two MFMRD laboratories on seafood toxicology and coastal fisheries research within the centralized KOHSI to be located in Betio.

General construction impacts such as pollution from improperly stored and disposed waste, pollution from discharge of sediment, nuisances from dust and noise, hazardous substance spills e.g. oil. Occupational and/or community health and safety. Asbestos, lead paints, SMF, ozone depleting substances (from old air conditioning units) and PCBs may be present in old buildings or construction debris. Increase in harassment and/or gender-based violence (GBV), especially from any imported workforce who may not understand i-Kiribati cultural norms. Building designs are not climate change resilient. Permanent and/or temporary land acquisition. May require an environmental license under Kiribati law.

Construction and demolition impacts addressed in a construction environmental and social management plan (ESMP). Waste minimization and management measures detailed in Waste Management Plan. Health and safety management plans developed, and construction and demolition works completed accordingly. Hazardous material assessment & management procedure detailed in Waste Management Plan in accordance with good international industry practice (GIIP). Building inspection that identifies whether asbestos or other hazardous materials are present prior to demolition. Asbestos containing materials managed in accordance with GIIP42. No asbestos containing materials used for construction. Provide separate facilities for women & men. Define GBV requirements in construction H&S plan. Include Environmental and Social Specialist on building design team. Identify Government Land as a priority. Otherwise identify land owner willing to enter into a lease. Community

Construction EIA/BEIA (Kiribati) and/or ESMP/ECOP (WB) as defined through the screening process. Waste Management Plan. Construction Health and Safety Plan with GBV requirements defined. Renovation ECOP as defined through the screening process. Asbestos and Hazardous Materials Management Plan. Waste Management Plan. Health and Safety Plan.

42 Refer to Annex XI for World Bank Good Practice Note on Asbestos


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Activity Significant Potential Impacts Key Mitigation Methods Safeguard Tools consultation and stakeholder engagement using I-Kiribati norms when negotiating land access.

Operation of the two MFMRD laboratories on seafood toxicology and coastal fisheries research within the centralized KOHSI to be located in Betio.

Collection of specimens or samples may require an environmental license under the Environment Act 1999 – Schedule of Environmentally Significant Activities. Design not providing for chemical processing, storage and disposal. Laboratory chemical storage and disposal. Waste disposal of chemical and biological samples. Health and safety risks for laboratory workforce. Health and safety risks for vessel operators and toxicology sample collectors, especially those who work in remote areas. Vessel operators are not properly trained. Specifications of vessels used for sampling are inadequate for purpose. The environmental monitoring may identify coastal fishery products that are contaminated (e.g. with ciguatera and/or scombroid fish poisoning) and not suitable for consumption.

Follow the Kiribati Environmental License Application process if sampling is determined to be an Environmentally Significant Activity (ESA). Design should be developed for proper chemical processing, storage and disposal. Waste management plan that addresses chemical wastes, biological wastes and other solid wastes. The waste management plan should also address the storage, handling, and documentation for transfer of hazardous waste from the point of generation to the final disposal and address the following waste materials characteristics: Ignitability, Corrosivity, Reactivity and Toxicity. Health and Safety management plan for laboratory operation will be required. Vessels used must meet all requirements including safety specifications and are operated by trained and qualified persons. Sampling protocols will be developed. Vessels are maintained and stocked with international standard safety equipment e.g. flares, lifejackets and emergency locator beacons.

Environmental License for sampling and preparation of an EIA/BEIA as determined by the PEO of the ECD. Waste Management Plan. EHS Plans. Contaminant Response Plan (if required)


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Activity Significant Potential Impacts Key Mitigation Methods Safeguard Tools All users are trained to operate safety equipment, and safety procedures are followed every outing. If required, a Contaminant Response Plan will be developed based on the scale and nature of the contaminants. Potential response actions may include: TV radio campaigns to raise awareness; signage and guidance to affected communities; community engagement meetings; and fostering constructive intra-ministry dialogues and action by Cabinet in those sectors polluting the lagoon and densely populated coastal areas. The project and MFMRD might invest and source alternative supplies of fish to affected communities from outer islands (as is already part of the project design) and/or finance training and roll-out of a multi-ministerial emergency response task force to address major contamination issues.

Purchase and operation of vessels

Health and safety risks for vessel operators and users. Specifications of vessels are inadequate for purpose. Vessel operators are not properly trained. Risk of diesel spills.

Project design contains strategies to improve safety in the sector for example, the communication system identified and safety equipment for observers and fisheries officers. Vessels meet all requirement including safety specifications and are operated by trained, and where required, qualified persons. Vessels are maintained and stocked with spill and safety equipment to international standards.

EHS Plans


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Activity Significant Potential Impacts Key Mitigation Methods Safeguard Tools All users are trained to operate spill and safety equipment, and safety procedures are followed every outing.


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Activity Significant Potential Impacts Key Mitigation Methods Safeguard Tools Outer Island Investments Purchase and operation of small boats.

Health and safety risks for vessel operators and users, especially those who work in remote areas. Specifications of vessels are inadequate for purpose. Vessel operators are not properly trained.

Vessels meet all requirements including safety specifications and are operated by qualified persons. Vessels are maintained and stocked with international standard safety equipment e.g. flares and lifejackets. All users are trained to operate safety equipment, and safety procedures are followed every outing.

EHS Plan

Small-scale, onshore processing equipment and facilities e.g. smoking and ice and cold storage facilities.

If new building - general construction impacts such as pollution from improperly stored and disposed waste, pollution from discharge of sediment, nuisances from dust and noise, hazardous substance spills e.g. oil, health and safety risks for workers and/or community. Increase in harassment and/or gender-based violence (GBV), especially from any imported workforce who may not understand i-Kiribati cultural norms. If renovated building - asbestos, lead paints, SMF, ozone depleting substances (from old air conditioning units) and PCBs may be present in old buildings or construction debris. If new building - unable to find suitable land or get agreement from land owners, causing delays or conflict. Discharges from facilities.

Construction and demolition impacts addressed in a construction environmental and social management plan (ESMP). Waste minimization and management measures detailed in Waste Management Plan. Health and safety management plans developed, and construction and demolition works completed accordingly. Provide separate facilities for women & men. Define GBV requirements in construction H&S plan. Hazardous material assessment & management procedure detailed in Waste Management Plan in accordance with good international industry practice (GIIP). Building inspection that identifies whether asbestos or other hazardous materials are present prior to demolition. Asbestos

Construction EIA/BEIA (Kiribati) and/or ESMP/ECOP (WB) as defined through the screening process. Waste Management Plan Construction Health and Safety Plan with GBV requirements defined. Renovation ECOP as defined through the screening process. Asbestos and Hazardous Materials Management Plan Waste Management Plan Health and Safety Plan Operation


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Activity Significant Potential Impacts Key Mitigation Methods Safeguard Tools Transmission of communicable diseases from ice if non-potable water is used. Negative reaction from outer island communities to perceived fairness of funding allocations under the Project. Food processing facilities may require an environmental licence under the Environment Act 1999 – Schedule of Environmentally Significant Activities. Occupational Health and Safety issues during operation.

containing materials managed in accordance with GIIP43. No asbestos containing materials used for construction. Preferentially rehabilitate existing buildings. If additional buildings are required, preferentially locate them on government owned land. Otherwise identify land owner willing to enter into a lease. Community consultation and stakeholder engagement using I-Kiribati norms when negotiating land access. Treatment prior to discharge. Ice must be made with potable water. Outer-island/community selection criteria is included in the POM to ensure that the process is transparent, fair and avoids conflict. Establishment of a basic Environmental and Social Management System (ESMS) for the transfer of funds to fisheries communities. Follow the Kiribati Environmental License Application process if facility is determined to be an Environmentally Significant Activity (ESA). Health and Safety management plan prepared for operation in accordance with GIIP44.

Environmental License and preparation of an EIA/BEIA as determined by the PEO of the ECD. Waste Management Plan. EHS Plan.

43 Refer to Annex XI for World Bank Good Practice Note on Asbestos 44 Refer to Annex XII for World Bank Guidance Note on Fish Processing


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Activity Significant Potential Impacts Key Mitigation Methods Safeguard Tools Aquarium fish holding facilities and equipment

If new buildings - general construction impacts such as pollution from improperly stored and disposed waste, pollution from discharge of sediment, nuisances from dust and noise, hazardous substance spills e.g. oil, health and safety risks for workers and/or community. If renovated old buildings - asbestos, lead paints, SMF, ozone depleting substances (from old air conditioning units) and PCBs may be present in old buildings or construction debris. Increase in harassment and/or gender-based violence (GBV), especially from any imported workforce who may not understand i-Kiribati cultural norms. If new building - unable to find suitable land or get agreement from land owners, causing delays or conflict. Occupational Health and Safety issues during operation e.g. drowning in storage tanks and inadequate storage of hazardous substances. Negative reaction from outer island communities to perceived fairness of funding allocations under the Project. Pet fish collection requires an environmental licence under Kiribati law.

Construction and demolition impacts addressed in a construction environmental and social management plan (ESMP). Waste minimization and management measures detailed in Waste Management Plan. Health and safety management plans developed, and construction and demolition works completed accordingly. Hazardous material assessment & management procedure detailed in Waste Management Plan in accordance with good international industry practice (GIIP). Building inspection that identifies whether asbestos or other hazardous materials are present prior to demolition. Asbestos containing materials managed in accordance with GIIP45. No asbestos containing materials used for construction. Provide separate facilities for women & men. Define GBV requirements in construction H&S plan. Preferentially locate new buildings on government owned land or voluntary land donation.

Construction EIA/BEIA (Kiribati) and/or ESMP (WB) as defined through the screening process. Waste Management Plan. Construction Health and Safety Plan with GBV requirements defined. Renovation ECOP as defined through the screening process. Asbestos and Hazardous Materials Management Plan. Waste Management Plan. Health and Safety Plan. Operation EHS plan. ESMP. Pet Fish Collection Environmental License and preparation of an EIA/BEIA as determined by the PEO of the ECD incorporating an associated ESMP (WB).

45 Refer to Annex XII for World Bank Good Practice Note on Asbestos


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Activity Significant Potential Impacts Key Mitigation Methods Safeguard Tools Health and Safety management plan prepared for operation in accordance with GIIP46. Outer-island/community selection criteria is included in the POM to ensure that the process is transparent, fair and avoids conflict. Establishment of a basic Environmental and Social Management System (ESMS) for the transfer of funds to fisheries communities. Follow the Kiribati Environmental License Application process if the activity also involves pet fish collection.

46 Refer to Annex XIII for World Bank Guidance Note on Aquaculture


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6.1 Cumulative Impacts The project is not expected to cause any indirect or long term negative impacts. There is potential for cumulative issues to arise in the future, particularly in relation to the increased levels of commercial fishing activities. Ongoing monitoring of biological resources and fishing practices will provide insights into medium/longer term impacts and will inform any necessary management measures as they emerge, and will be based on consultation with affected communities. The Project will not involve significant changes to existing land use, and construction-related impacts can be managed through implementation of the ESMF. The project is expected to result in positive environmental impacts through improved marine management practices and engagement with local community on sustainable fishing.


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7 Environmental and Social Screening of Subprojects 7.1 Overview of Screening Process The screening process will be used to screen all subproject activities for risks and then identify the safeguard instruments that need to be prepared. The screening process may include completing a screening form, undertaking a site visit, and consulting with stakeholders. Responsibilities for implementing these procedures are outlined in Section 8 of the ESMF. The screening process and checklists/guidelines should be reviewed after 18 months of project implementation to ensure that the process is appropriate.

The project typologies identified as requiring environmental and social screening and management during implementation of Kiribati PROP project include 1) Technical Advisory; 2) MFMRD Assets; and 347) Outer Island Investments. Screening templates for specific project activities have been developed and are included in the Annexes.

7.2 Screening of Subprojects The following provides the steps in the assessment of subprojects that will be undertaken. The screening of subprojects will take place either during the annual work plan or on ad hoc basis as subprojects and activities are defined by the Project Team/s. The screening process will follow the key steps shown in Figure 3:

Figure 3 – Key Subproject Screening Steps

47 The Bank will require screening of proposed subprojects and ensure that sub-borrowers carry out appropriate EA for each subproject. Before approving a subproject, the Borrower will verify (through its own staff, outside experts, or existing environmental institutions) that the subproject meets the environmental requirements of appropriate national and local authorities and is consistent with this OP and other applicable environmental policies of the Bank.


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Step 1 - Determine Subproject Category

The first step of screening is to determine what type of subproject or activity is being proposed and determine the immediate next step. To determine the subproject category, refer to Checklist 1 in Annex III. Checklist 1 will determine whether a subproject screening checklist needs to be completed or whether a subproject guideline needs to be followed.

Step 2- Screening of Risks

The next step is to complete the subproject screening checklist or refer to the appropriate subproject guidelines, as determined in Step 1. The checklists and guidelines (Annex’s III – X) will determine what safeguard tool/s are required (if any) under World Bank and Kiribati safeguards requirements (e.g. ESMP, EIA, ECOP).

Note: If Checklist 3 – All Other Projects Screening Checklist in Annex V is completed, also check Table 4 - Ineligible Activity List (end of Chapter 7).

Step 3 – Determine Safeguards Tool/s

The third step is to determine what safeguards tool/s are required, if any, under World Bank and Kiribati safeguards requirements (e.g. ESMP, EIA, ECOP) as a result of the risk screening. The subtype screening forms and guidelines (Annex’s III – X) will assist in determining the safeguard tools need to be prepared.

Step 4: Consultation with Project Team

If required, the screening outcomes will be discussed with the project team and design personnel to identify ways to reduce or avoid any adverse impacts. Any adjustments to the subproject design, categorisation or safeguard instrument can be refined following this process.

Step 5: Preparation and Disclosure of Safeguard Tools

If required, the next step is to prepare the relevant instruments, both for Kiribati and the WB processes. This process may include site visits and data gathering, consultation, and public disclosure of the documents in accordance with the SEP (Annex I). Instruments that cover groups of subprojects by geographical area or procurement may be used where appropriate e.g. EHS plans for small scale infrastructure developments on outer islands.

Step 6: Implementation of Mitigation Measures

The implementation of the safeguard’s tools and conditions of any environmental approvals will need to be implemented, monitored and enforced. For MFMRD/MLPID assets and infrastructure, training of other fisheries staff may be needed to ensure that conditions of the safeguard instruments are met. For contractors, monitoring and supervision will be needed to ensure that conditions of the safeguard instruments are met. For outer island developments, training will be needed to ensure that conditions of safeguard instruments are met.

Step 7: Monitoring and Reporting

Monitoring is required to gather information to determine the effectiveness of implemented mitigation and management measures and to ensure compliance with the approved safeguard tools. Environmental indicators will be defined in the safeguard’s tools and compliance with these indicators


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will need to be monitored. Monitoring methods must provide assurance that safeguard measures are undertaken effectively.

Regular reports on environmental indicators and any incidents that may have adversely impacted on the environment or people arising from subproject activities will need to be prepared. These will be included into semi-annual safeguard monitoring reports to the World Bank.

The semi-annual safeguard monitoring reports to the Bank will include: (i) the status of the implementation of mitigation measures; and (ii) the findings of monitoring programs (iii) any incidents with adverse impacts and the actions taken to address it and prevent reoccurrence.


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Table 4 - Ineligible Activity List

Activities will be deemed ineligible for project funding if they: 1. Are not aligned to the objectives of the project. 2. Are large-scale infrastructure projects, or studies that will lead to large-scale infrastructure projects that

would trigger Category A under World Bank Policy OP4.01. 3. Involve the conversion, clearance or degradation of any critical natural habitats (as per OP 4.04); forests

(including mangroves); environmentally sensitive areas; ecosystems of importance (especially those supporting rare, threatened or endangered species of flora or fauna); significant biodiversity; and/or protected conservation zones.

4. Will cause, or have the potential to result in, permanent and/or significantly damage non-replicable cultural property, irreplaceable cultural relics, historical buildings and/or archaeological sites.

5. Will result in involuntary land acquisition or physical displacement of affected communities. 6. Require or involve:

• Political campaign materials or donations in any form; • Weapons including, but not limited to, guns and ammunition (e.g. for maritime police or

fisheries surveillance); • Purchase, application or storage of pesticides or hazardous materials (e.g. asbestos); • Building structures that will alter coastal processes or disrupt breeding sites including sand

mining, land reclamation or seawalls; • Any activity on land or coastal areas that has disputed ownership (private, communal or

customary). • Trade in wildlife or wildlife products regulated under CITES (Convention on International

Trade in Endangered Species of Wild Fauna and Flora); • Fishing that utilizes dynamite, poison or electrofishing and or other destructive fishing

practices; • Production or activities involving harmful or exploitative forms of forced labor / harmful

child labor.


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8 Responsibilities for Safeguards Implementation The Project will be coordinated and implemented at the National level by Ministry of Fisheries and Marine Resource Development (MFMRD). The MFMRD is the Kiribati Government agency responsible for developing and managing the nation’s fisheries as well as other marine resources (marine aggregates, deep-sea minerals). The MFMRD will work in tandem with the MLPID on interventions targeted for Kiritimati Island. The Ministry will also work closely with MELAD on coastal and marine pollution reduction efforts. The MFMRD will establish a dedicated Project Management Unit (PMU) to implement the project, monitor project activities, outputs and outcomes, and manage fiduciary risks and will house a Project Manager, Gender Specialist, Private Sector Advisor, a Monitoring and Evaluation Specialist, and a Stakeholder Engagement and Safeguards Officer.

Safeguards for the Project will be managed by the Kiribati Fiduciary Services Unit (KFSU) established in Ministry of Finance and Economic Development (MFED). In order to maximise the benefits of economies of scale, the KFSU will provide centralized service for all World Bank projects in Kiribati. It is expected the KFSU will provide direct implementation of all project safeguard functions to support the MFMRD PMU beginning in July 2020.

8.1 Key Safeguards Responsibilities KFSU (Kiribati Fiduciary Services Unit)

The KFSU will be established in the MFED. This unit will house four full-time safeguards specialist positions which includes:

• Safeguards Specialist (international) • Safeguards Officer Social 1 (national) • Safeguards Officer Social 2 (national) • Safeguards Officer Environmental (national)

The Safeguards Officers in the KFSU will have the overall responsibility for ensuring that environmental and social issues are adequately addressed within the project.

Environmental and Social Safeguards Officer/s

The Environment and Social Safeguards Officers (Safeguards Officers) will ensure the implementation, monitoring, review, and update of the Environmental and Social Management Framework (ESMF), and any other instruments prepared under the ESMF such as Environmental and Social Management Plans (ESMP). These positions will be responsible for ensuring that project safeguards comply with the Financing Agreement, Kiribati’s laws, and the World Bank’s Safeguard Policies, and for implementing the SEP and the GRM.

Specifically, the Safeguards Officer’s will need to undertake:

(i) Contribution to the development of the project’s annual planning processes; (ii) Contribution to project documents (including tenders, bids, Terms of References, and

contracts) to ensure they have requisite safeguard documentation applied and attached as required;

(iii) Establishment of a basic Environmental and Social Management System (ESMS) for the transfer of funds to fisheries communities e.g. for small outer island investments.


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(iv) Screening of subproject activities for environmental and social risks; (v) Preparation of safeguard instruments, such as ESMPs; (vi) Stakeholder consultation on draft safeguard instruments; (vii) Update of safeguard instruments to reflect stakeholder input; (viii) Public disclosure of final safeguards instruments; (ix) Implementing and documenting the implementation of safeguard measures; (x) Monitoring and enforcement of safeguards compliance; (xi) Monitoring and Evaluation Reports for both safeguards work and stakeholder engagement

work; (xii) Grievance redress management; and (xiii) Updates to the ESMF, as required.

The Safeguards Officers will also ensure project staff receive appropriate safeguards and stakeholder engagement training and capacity building. For example, other fisheries officers may need to be trained to be able to liaise if stakeholder consultation meetings need to be conducted in outer islands.

MFMRD Project Management Unit PMU

In addition, to the KFSU Safeguards Officers, the MFMRD PMU will include a full time Stakeholder Engagement and Safeguards Officer to assist with roll-out of the SEP and overall project safeguards management.

World Bank Safeguards Specialists

The Bank’s Safeguard team will provide regular safeguards compliance support remote and during missions to Kiribati, and to build capacity for ESMF implementation and stakeholder engagement.

8.2 Capacity Building This will be the first World Bank project managed by MFMRD and, as such, it is not yet familiar with the Bank’s policies relating to project implementation nor the requirements for implementing agencies to comply with those policies. It will thus be necessary for the Bank to provide support to the MFMRD PMU team throughout preparation and continuously throughout early implementation to ensure successful execution of the project. To help mitigate these risks, dedicated ongoing investment will be made in building the capacity of the Ministry to manage and implement the project, including through additional human resources and training. Consideration will also be given to using non-government entities for the delivery of specific activities at the community level.

On the other hand, the ECD, the environmental regulator whose remit includes pollution management as well as management of Marine Protected Areas, has been involved with internationally funded natural resources management projects, and has the experience working with the World Bank safeguards policies. However, the ECD’s resources in terms of manpower and budget are severely constrained and activities on outer islands very often go unmonitored. Therefore, it will be important to provide the ECD with ample capacity building and budgetary support to enable them to actively participate in some of the project activities, as well as their oversight role on Kiritimati Island.

The Safeguards Officers that will be based in the KFSU may have differing level of familiarity with WB Safeguard Policies and Procedures. Furthermore, the Safeguards Officers may need support and training to implement the ESMF and prepare safeguard instruments, such as ESMPs and EIAs, during project implementation.


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The WB will provide ongoing support, as well as training sessions and technical assistance, to build KFSU, ECD, and MFMRD capacity during missions to Kiribati. The WB will also maintain a close dialogue with the KFSU Safeguards Officers and ensure implementation support for safeguards and stakeholder engagement when needed.


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9 Consultation and Disclosure A Stakeholder Engagement Plan (SEP) for the Project has been developed and is included as Annex I. The SEP includes an analysis of the main stakeholders of the Project, consultation and engagement methods, the schedule of key activities, and records keeping and reporting requirements. Public disclosure of safeguards documents prepared under the project is required as set out in the SEP found in Annex I.

A range of stakeholders were consulted as part of the development of the Project and in the preparation of the ESMF. The Safeguards team met with stakeholders during the Joint Project Safeguards Field Scoping and Programmatic Preparation Advance Planning Mission to Kiribati (Tarawa and Kiritimati) in February 2019. The summary of those meetings is included in Annex XVI of the ESMF.

Consultation sessions with stakeholders were also held in December 2019 and January 2020 for the ESMF and included discussions with relevant Government agencies, civil society groups, commercial interest groups, youth and community members. Meetings were held in South Tarawa (Betio) and Kiritimati. Summaries of the pre-appraisal consultations are included in Annex XVI. No changes were made to the ESMF as a result of the stakeholder consultations in Betio and Kiritimati.

The final ESMF was publicly disclosed in-country, and opened for comments, by the MFMRD on their website48 on January 23, 2020 and by the World Bank through the Operations Portal on January 24, 2020.

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10 Grievance Redress Mechanism The Grievance Redress Mechanism (process for managing complaints) for the project is included as Annex XIV.


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11 Annexes


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Annex I Kiribati PROP Project Stakeholder Engagement Plan Introduction This Stakeholder Engagement Plan (SEP) forms part of the Environmental and Social Framework (ESMF) for the Kiribati PROP Project. The purpose of the SEP is to identify stakeholders who may be interested in or affected by the project and identify the methods for engaging these stakeholders throughout the project lifecycle.

The SEP has been prepared to ensure ongoing consultations and engagement in the project, and provides details on how to enable women, youth and other groups to effectively participate. Stakeholder liaison, consultation, and communication involves ensuring effective engagement with all stakeholders with respect to the project, including individuals, local communities, industry groups, committees, media, and schools, through the development and implementation of the SEP, and the development of strong relationships with key stakeholders. A key role is the effective planning of stakeholder engagement for the duration of the project. This will involve a hands-on approach to the establishment of consultative forums, developing terms of reference and meeting procedures, organising meetings, reporting on outcomes, and maintaining records.

The SEP will be updated as and when specific subproject details are decided, for example the specific locations, stakeholders, and schedule of activities. The Ministry of Fisheries and Marine Resource Development (MFMRD) is responsible for updating and implementing the SEP.

Stakeholder Analysis Stakeholders with an interest in the Kiribati PROP project were identified through discussions with MFMRD and are aligned with the Fisheries Sector Plan stakeholders. Key stakeholders and their interest/involvement in the Kiribati PROP project are included in Table 1 - Kiribati PROP Stakeholder Analysis.


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Table 1 - Kiribati PROP Stakeholder Analysis

Stakeholder Involvement/Interest in project Ministry of Environment, Lands and Agricultural Development (MELAD/ECD)

- Involved in environmental approvals - Interest in activities under Component 3 - Seafood Toxicology Component.

Lands Division - Interest in infrastructure developments.

- Interest in Component 3. - Will assist with land acquisition and lease approval.

Ministry of Line and Phoenix groups (MLPID)

- Oversees all developments in Line and Phoenix Islands (including Kiritimati).

- Interest in activities under Component 3.

Ministry of Health and Medical Services (MHMS)

Interest in Component 3 activities including Seafood Toxicology training and capacity building program.

Ministry of Women Youth, Sports and Social Affairs (Youth, Women’s and Gender-Based Violence Divisions)

May be interested in business development opportunities for women and youth.

Other government ministries such as Ministry of Internal and Social Affairs (MISA), Ministry of Information Communication Transport & Tourism Development (MCCTDD), Ministry of Finance & Economic Development (MFED), Ministry of Commerce, Industry & Cooperativeness (MCIC), and Ministry of Internal Affairs (MFA)

Interest in licensing and MCS strengthening activities, infrastructure design, fisheries regulations, and improved fisheries management.

Kiribati Chamber of Commerce and Industry

Interested in training and capacity building activities, and the creation of jobs.

Island Councils (Gilbert Islands, Tarawa, Kiritimati)

- Interested in supply chain development plans on Gilbert Islands.

- Interest in the outcome of Marine Spatial Planning. - Interest in activities under Component 3.

New Zealand MFAT Interested in close synchronicity of project activities with New Zealand financed fisheries projects including the Tobwan Waara project.

Other Donors and Regional Agencies e.g. ADB, DFAT, SPC, FFA, SPREP, EU, JICA, AusAid, PIFs.

Interested in fisheries management and development.

NGOs Interest in outcomes of technical studies and economic growth.


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Small- and large-scale commercial fishers and support services e.g. Tuna fishing companies, CPPL, KFL.

- Interest in the outcome of Marine Spatial Planning. - Interest in licensing and MCS strengthening activities, infrastructure design, fisheries regulations, and improved fisheries management.

Craft fisheries and other multi-user groups

- Interest in the outcome of Marine Spatial Planning. - Interest in Component 3.

Aquaculture Industries e.g. milkfish, seaweed, and clam producers

Interested in fisheries management.

Tourism Operators e.g. sport fishing clubs and divers

Interest in the development of Kiritimati Ocean Resources Master Plan and a Kiritimati Sport Fishing Management Plan.

Pet Fish Industry

Interest in the development of Kiritimati Ocean Resources Master Plan and supporting implementation of the Kiritimati Aquarium Fish Management Plan

Other sector specific associations e.g. fisher’s associations and cooperatives

Interest in fisheries management and legislation changes and what this may mean in terms of fishing access.

Affected / Adjacent communities

Interested in land, particularly land in South Tarawa where there is high population density and land is scarce.

Women’s organizations (e.g. AMAK - the umbrella women’s NGO network)

- May be interested in business development and/or employment opportunities resulting from project activities.

- Interest in fisheries management and legislation changes and what this may mean in terms of fishing access.

-Vulnerable group.

Youth organizations and groups e.g. Kiribati Youth Peer Network

- May be interested in employment opportunities in fisheries management and monitoring, control and surveillance resulting from project activities.

- Interest in fisheries management and legislation changes and what this may mean in terms of fishing access.

- Vulnerable group.

General public

Consumer of commercial and subsistence fisheries. Interest in seafood safety component and outcomes of toxicology sampling.

MFMRD already has well-established relationships with many of the identified stakeholders through various working groups, committees, and consultations for the Kiribati National Fisheries Policy.


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Good Practice Principles for Effective Stakeholder Engagement The following key stakeholder engagement principles shall be applied to all consultation and engagement activities:

• Timing and number of engagement events are designed to maximise stakeholder involvement and to avoid disruption to the ‘daily business’ of local stakeholders and stakeholder ‘fatigue’;

• Is effective and inclusive for all stakeholders and considers the needs of different groups within the community including gender, age, and those with any form of disability or special needs;

• A senior MFMRD staff member is to be present and participate actively at all engagement and consultation events;

• Engagement events occur in line with the SEP schedule so that there is clear linkage between engagement activities and the key stages in the project;

• Ensure that engagement is managed so that it is culturally appropriate, adequate and timely information and opportunities are provided to all stakeholders to be involved/contribute;

• Ensure that engagement is free from coercion, undertaken prior to key decisions and informed by provision of objective and meaningful information, and that feedback is provided to stakeholders after engagement has concluded; and

• Stakeholders can participate in the engagement process at any time, even if they had not previously been identified as stakeholders.

Consultation and Engagement Methods When selecting an appropriate consultation technique, culturally appropriate consultation methods, and the purpose for engaging with a stakeholder group should be considered which includes translation of materials in the national language as well as in English Table 2 summarizes the engagement techniques that will be used during the project and when they will be applied.

Table 2 – Engagement Techniques

Engagement Technique How and when they will be applied Correspondences (Phone, Emails) - Distribute information to Government officials, NGOs, Local

Government, and organisations/agencies. - Invite stakeholders to meetings and follow-up.

One-on-one meetings - Seeking views and opinions. - Enable stakeholder to speak freely about sensitive issues. - Build personal relationships. - Record meetings.

Formal Meetings/Workshops

- Present the Project information to a group of stakeholders. - Allow group to provide their opinions and views. - Disseminate technical information. - Inclusive discussions. - Record discussions.

Village Council meetings - Present Project information to a large group of stakeholders, especially communities.

- Allow the group to provide their views and opinions.


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- Build relationship with the communities, especially those impacted.

- Distribute non-technical information. - Facilitate meetings with presentations, PowerPoint, posters etc.

- Record discussions, comments, questions.

Focus group meetings

- Present Project information to a group of stakeholders. - Allow stakeholders to provide their views on targeted baseline

- Information. - Build relationships with communities. - Record responses.

MFMRD communication and outreach programmes e.g. website, social media, tv, information centers

- Present project information and progress updates. - Brief updates on project. - Disclose ESMF, RPF and other relevant safeguards documentation.

- Communicate information on seafood safety.

Direct communication with affected persons

Share information on nature of impacts.

Project flyer

- Brief project information to provide regular update. - Site specific project information. - Should be written in non-technical language and translated into i-Kiribati

Signs/posters - Share information on project activities.

- Should include pictures, info graphics

Gender and Youth Considerations The proposed information sharing and participation mechanisms will be gender-and youth sensitive in their design. The MFMRD Officers undertaking the consultations will ensure they facilitate the active participation of women, youth and marginalized groups in project planning, implementation and evaluation. Some other aspects to consider during the consultation design:

• Consultations should allow for separate consultations with men and women where necessary to ensure that they can freely express their views.

• Ensure there are male/female facilitators who can disseminate information and collect feedback. Training of area coordinators and community facilitators shall include gender training and awareness raising information and materials.

• Ensure equal participation of women during project implementation including encouraging women’s equal participation in decision-making, for example by establishing targets or specific initiatives (such as skills training). Core leaders and members of the various community-decision making committees should include a significant number of women.


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• Youth groups will be included in consultations (where appropriate) and through outreach and engagement activities.

Key messages The key messages that need to be delivered include:

(a) The purpose, nature and scale of the project activities; (b) The duration of proposed project activities; (c) Potential risks and impacts of the project on local communities and environment, and the

proposals for mitigating these; (d) The proposed stakeholder engagement process highlighting the ways in which

stakeholders can participate in project design and environmental and social management processes;

(e) The time and venue of any proposed public consultation meetings, and the process by which meetings will be notified, summarized, and reported; and

(f) Their rights and the process and means by which grievances can be raised and will be addressed.

Schedule of Key Activities Before pre-appraisal Engagement before the project goes to pre-appraisal included the following:

a. Dissemination of relevant project information, including explanations of intended project benefits;

b. Stakeholder consultations on proposed project design, environmental and social risks and impacts, mitigation measures, the proposed SEP, GRM, draft RPF, and draft ESMF.

The Safeguards team met with stakeholders during the Joint Project Safeguards Field Scoping and Programmatic Preparation Advance Planning Mission to Kiribati (Tarawa and Kiritimati) in February 2019. The summary of those meetings is included in Annex XVI of the ESMF.

Formal pre-appraisal workshops/consultations were carried out by MFMRD in Betio and Kiritimati for the project and for the ESMF. The summary reports for those meetings are included in Annex XVI of the ESMF. Presentations at the consultations were given in English and translated into i-Kiribati and included visual content (MS PowerPoint in English with i-Kiribati subtitles). The outcome of the consultations was that the attendees understood the legal framework within which the project will operate, their rights, and how to make comments or register grievances about any project using the GRM. The MFMRD staff ensured ample discussion time, and the format was conducive to participation by all parties (men and women). A summary flyer of the project safeguard processes in English and i-Kiribati was shared for consultation purposes. The flyer provided the project manager’s contact information for people who have more questions or concerns.

After pre-appraisal Engagement after pre-appraisal included the following:

a. Disclosure of information on how stakeholder feedback was incorporated into project design and environmental and social risk management instruments;


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b. Stakeholder consultations on implementation and supervision issues, consultations on any new project characteristics or environmental and social risks, and consultations on progress of environmental and social risk mitigation measures;

c. Regular efforts to keep stakeholders informed on project implementation; and d. Review of the adequacy of stakeholder identification in light of project implementation and

related revisions to the SEP.

The ESMF remained draft until public disclosure and consultation was completed. The final ESMF was publicly disclosed in-country, and opened for comments, by the MFMRD on their website49 on January 23, 2020 and by the World Bank through the Operations Portal on January 24, 2020. A summary of the project is provided in English. A summary description of the grievance mechanism; and contact information and process for seeking further information should be provided in i-Kiribati. Any instruments prepared under the ESMF, for example ESMPs, will be publicly disclosed (and open for comments) on the MFMRD website. Disclosure and consultation are the responsibility of the MFMRD.

During project implementation The Kiribati PROP project will require the ongoing engagement of communities and other stakeholders at the national and community (village) level during project implementation. Extensive engagement will be carried out using customary protocols, inclusive of women and youth. Consultation sessions will include special outreach efforts and be tailored to the need of vulnerable groups such as women, elderly and disabled persons so that the process is socially inclusive, and a range of stakeholder views and perspectives are adequately represented. Consultation methods will be designed in consideration of the different sociocultural norms that inhibit the participation and input into decision-making from vulnerable groups and persons, particularly women. Engagement of communities and interested parties will be a key approach to ensuring that there is support for the projects and the projects meet the needs of the end users, with appropriate mitigation in place. Where possible, stakeholder engagement will utilize engagement structures within the national system e.g. Island Council meetings. Stakeholders should always be reminded of the availability of the grievance mechanism.

Timing of engagement/consultations

Stakeholder engagement will begin once sub-projects have been identified, but before detailed design has been completed. Following the development of the subprojects and after safeguards instruments have been drafted, formal and documented public consultation and information disclosure will be required in accordance with the World Bank requirements for public consultations with project beneficiaries, affected persons and key stakeholders on safeguard documents; and consultation and information disclosure requirements required by Kiribati law and custom. Safeguard instruments will be disclosed by MFMRD (and consulted) so that they are accessible to the public and civil society who may be interested in, or affected by, program activities.

Methods of engagement/consultations

Engagement methods will include the following:

• Continue to attend international meetings on tuna fisheries and MCS.

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• Utilize existing advisory panels or to collaborate on Government stakeholder liaison during implementation of the project.

• Develop initiatives to empower women in fisheries decision making processes such as inclusion on Island Council committees.

• EIA and other safeguard consultations, as required with particular regard for vulnerable groups.

• Provide information to commercial users e.g. through annual/quarterly reports. • Continue dialogue with other Ministries to identify areas for collaboration on project activities.

For example, opportunities to integrate with ECD pollution programs where practicable. • Continue dialogue with other donors to ensure program synchronicity e.g. with the Tobwan

Waara project. • Use the MFMRD communications and outreach programmes such as the website to

communicate key aspects of the project. • Notices/posters/brochures posted and documents available to the public in suitable locations

close to any project sites (e.g. school offices, churches).

Grievance Redress Mechanism A Grievance Redress Mechanism (complaints process) was developed for the Kiribati PROP project and is included as an Annex to the ESMF. The purpose of a Grievance Redress Mechanism (GRM) is to provide a centralized mechanism for receiving grievances, concerns, suggestions, inquiries and complaints for the Kiribati PROP project. The GRM is for people seeking satisfactory resolution of their concerns about the environmental and social performance of the project. The mechanism will ensure that (i) the basic rights and interests of every affected person by poor environmental performance or social management of the project are protected; and (ii) their concerns arising from the poor performance of the project are effectively and timely addressed. The GRM is designed to address concerns and complaints promptly, transparently and in a culturally appropriate manner with no impacts (cost, discrimination) on project affected people (APs).

The GRM is a standalone document that is publicly disclosed and widely circulated to ensure all stakeholders are aware of the process for documenting and resolving grievances arising from project works.

Record Keeping and Reporting Requirements. Pre-appraisal consultations Pre-appraisal community consultation and engagement activities were well documented, and the reports are included as annexes to the ESMF. In the reports there was a review of the engagement activities; levels of stakeholder involvement (particularly for affected communities, women and vulnerable people/groups); a summary of the issues discussed and the outcomes; and the extent to which stakeholder issues, priorities and concerns are reflected in the ESMF and RPF, particularly with respect to mitigation and monitoring strategies; and a summary of how comments were taken into account or the reasons why they were not.

Project implementation consultations Consultations held during the project will be well-documented to ensure the views of stakeholders are captured and incorporated into project design, addressed where necessary, and summarized in progress and/or monitoring reports. MFMRD staff will keep records of attendance, comments and any


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resolutions or agreements adopted at meetings of all kinds. The information will be summarized, and the document attached as an annex to the safeguard instrument e.g. EIA. These will be promptly fed back to technical team members as appropriate, reflected in project design and in reports on consultations that will form part of the regular project reporting structure. Budget provisions will be made to ensure follow-up with communities on the outcome/s of consultation and participatory activities and management decisions can occur where it is due.

SEP Updates Because project circumstances and stakeholder concerns can change, or new ones may emerge, stakeholder engagement will continue throughout the project cycle. The SEP may need to be updated during project implementation. This allows improvement to project implementation based on stakeholder feedback, and proactive management of concerns. As implementation of a project progresses, new impacts may arise, while other impacts may be eliminated. MFMRD shall provide regular updates to stakeholders on project performance and changes in scope or schedule, following the procedures agreed upon in the SEP. Whenever material changes are made, the revised SEP should be disclosed. Stakeholders should be informed of new versions of the SEP.


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Annex II Land Access and Resettlement Policy Framework Introduction The Government of Kiribati is seeking funding from the World Bank for the Kiribati: Pacific Islands Regional Oceanscape Program (Kiribati PROP) (World Bank P165821) to enhance the sustainable value of large-scale oceanic fisheries, diversify sustainable marine-based sources of revenue for coastal communities and strengthen coastal and marine pollution management capacity in Kiribati. The Kiribati PROP’s Development Objective (PDO) is to improve management of selected fisheries and seafood safety in the Recipient’s territory.

The purpose of this Land Access and Resettlement Policy Framework (RPF) prepared for the Kiribati PROP, is to assess and report on the impact of the Kiribati PROP’s subcomponent activities with regards to people’s lands, and associated assets. The document aims to ensure that impacts associated with changes in access to land or assets (including natural resources) are appropriated minimized and mitigated.

Purpose of the RPF The project triggers social safeguards policy OP4.12 Involuntary Resettlement. The objective of this policy is to ensure affected persons living standards are not adversely affected as a result of the Project or its interventions. As such, the MFMRD is required to prepare appropriate social safeguard instruments to address all adverse impacts that will be generated as a result of project activities and subprojects. The rationale of using a Resettlement Policy Framework is that specific activities for all projects/phases of the project were not identified during the project preparation and therefore, not all of the impacts to lands and assets are known.

Legal Framework World Bank Requirements

World Bank Operational Policy 4.12 – Involuntary Resettlement.

This policy covers direct economic and social impacts that both result from Bank-assisted investment projects and are caused by (a) the involuntary taking of land resulting in (i) relocation or loss of shelter; (ii) loss of assets or access to assets; or (iii) loss of income sources or means of livelihood, whether or not the affected persons must move to another location. This policy aims to restrict the involuntary taking of land or any form of economic displacement of populations affected by or participating in World Bank financed activities; and where displacement is unavoidable, to assist persons to improve (or at least restore) their incomes and standards of living; and to identify and accommodate the needs of vulnerable groups.

This policy requires siting of project infrastructure to be so chosen as to avoid these impacts altogether or to minimise them to the extent possible. Where these cannot be avoided, the policy requires the preparation of either or both of these instruments: (i) Resettlement Policy Framework; (ii) Resettlement Action Plan; and for meaningful consultations with potentially affected people.

Kiribati Legal and Regulatory Framework The following legislation and policies provide the legal and policy framework for the acquisition of any land required, or of access and user rights. The most relevant legislation is discussed in further detail in Table 1.


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i. Constitution of Kiribati ii. State Acquisition of Lands Ordinance 1954 (rev 1979) iii. Native Lands Ordinance 1956 (rev edition 1977) iv. Magistrate’s Courts Act 1978 v. State Lands Act 2001

vi. The Land Registration Grievance Tribunal Act 2002 vii. Native Lands Amendment Act 2011

viii. Gilbert and Phoenix Islands Lands Code (1956).

Table 1 - List of relevant Kiribati legislations

Kiribati legislation Brief Description of Legislation Constitution of Kiribati.

Under the Kiribati Constitution (1979) all land in Kiribati belongs to the I-Kiribati people except for the Phoenix and Line Islands, small portions of reclaimed land owned by the Government, and lands belonging to the Catholic Church. The Constitution declares that all natural resources of Kiribati are vested in the people and their Government. Section 8 of the Kiribati Constitution provides that no property of any description shall be compulsorily acquired unless such acquisition is necessary in the interests of defence, public safety, public order, public morality, public health, town or country planning or the development or use of any property for a public purpose. Any acquisition of private land must be adequately compensated within a reasonable time. The Constitution also provides that any disagreement over the amount of compensation shall be resolved in the High Court.

State Acquisition of Lands Ordinance 1954 (rev 1979).

Section 5 empowers the Minister to acquire “…on behalf of the republic, any lands required for any public purpose, absolutely or for a term of years as he may think proper, paying such consideration or compensation as may be agreed upon or determined under the provisions of this Ordinance.” Sections 6 (1) and 6 (2) empower agents of the Minister to access land to be taken for public purposes including surveying and marking of boundaries, but also define limits to protect the privacy of land occupants in their homes. Kiribati’s policy for the determination of compensation for affected peoples and their assets is set out in Section 16 –” Matters to be considered in determining compensation.” Section 13 sets out the mechanism and process for the redress of grievances related to title and or compensation.

Native Land Ordinance 1956.

Part VI of the Native Lands Ordinance provides for leases. It reaffirms the inalienability of native land to a person who is not a native, but grants exemptions for their alienation to the State (Crown) for public purposes (Section 5(2)). The Native Lands Ordinance complements the State Acquisition of Lands Act and provides the legal basis for the State to lease native (private) lands when and if necessary.


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Magistrate’s Courts Act 1978.

Section 58 of this Act gives the Magistrate’s Court the power to hear and adjudicate in all cases concerning land matters in accordance with the provisions of the Code, and where the Code is not applicable, in accordance with customary law. Land matter s concerning land boundaries, transfers, registration of native lands and any disputes concerning the possession and utilization of native land are dealt with by the Magistrate’s Court.

The State Lands Act 2001

The State Lands Act 2001 empowers the State as the owner of land to make some of this land available for development purposes including for the permanent settlement of citizens and their families. The State is equally empowered to reverse the transfer of land back to the State, or to another party.

The Land Registration Grievance Tribunal Act 2002

The Tribunal was established to hear outstanding complaints by direct descendants of persons who were by mistake or fraud deleted from or denied entry on a land registry in the Gilbert Group. The Tribunal does not have the independent power to make awards to a successful griever without written consent, (S.4(3)). Instead, it is for the Government to consider what should be done in the circumstances of each case. The Act recognizes the legal concepts of grievance in the functions of the Tribunal.

Native Lands Amendment Act 2011

Native Lands Amendment Act 2011 amends Section 4 of the Native Lands Ordinance to address the concerns of I-Kiribati who feel they have lost their lands as a result of fraud committed by those who are currently registered over the disputed lands or by their predecessors. The amendment seeks to give aggrieved people the opportunity to challenge those titles in Lands Court.

Gilbert and Phoenix Islands Lands Code (1956).

Rights and interests in I-Kiribati land are acquired mostly by inheritance and gifting customs as codified in the Gilbert and Phoenix Islands Lands Code (1956). The various customs governing the acquisition of interests and rights to land are defined in the Code. The Code documents customs and practices as of 1956 and, despite changes to a market economy, these customs and practices continue to be highly relevant in Kiribati society today.

Gap Analysis The gap analysis (Table 3 2) highlights the difference between the applicable Bank safeguard policies and Kiribati’s laws, standards and regulations, and relevant measures for addressing key gaps. The processes will be harmonized as much as possible, so that the requirements of Kiribati and the World Bank will be met. The minimum will be that Kiribati law will be adhered to and then any gap filling for World Bank policies and processes will be done.


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Table 2 - Gap Analysis

Safeguard Requirement Aspect/ Gap Proposed Project Measures Land Acquisition and Livelihood Restoration Where physical relocation is necessary displaced persons are provided compensation, transitional assistance and support to enhance or restore livelihoods.

The Kiribati Constitution and laws are quite explicit on the compensation for the acquisition of private land needed in the public interest, namely the rehabilitation of I-Kiribati adversely affected by the project. The Native Lands Ordinance and State Acquisition of Lands Ordinance provide for land alienation (native50 or non-native) and land acquisitions. However, consultations are not always required where the land is commercial and government owned and livelihood restoration appear to be limited to financial compensation for land that is legally registered.

Provide compensation to all affected persons at full replacement cost. Any Resettlement Policy Framework (RPF)/Resettlement Action Plan (RAP) prepared under the project will specify full compensation and measures to enhance or restore livelihoods where necessary. Activities under the project will also require participation and consultation of affected persons for prepared safeguard instruments as set out in the (SEP) found in Annex I of the ESMF.

Involuntary Resettlement Involuntary resettlement (and acquisition of land) should be avoided where feasible, or minimized, exploring all viable alternative project designs.

The Native Lands Ordinance and State Acquisition of Lands Ordinance provide for compensation arrangements in the case of involuntary resettlement, provided those resettled are not in default of any current law (i.e. not illegal settlers/squatters). Basic legal provisions addressing involuntary resettlement appear to be limited to financial compensation for land that is legally registered. Furthermore, evidence that alternatives have been considered is also not always required under Kiribati law.

Acquisition of land will only be pursued once all viable alternatives have been considered and no other suitable sites exist. The process and agreements between the Government and the landowner will be based on a Resettlement Policy Framework (RPF)/Resettlement Action Plan (RAP) prepared under the project and approved by the Bank. Activities under the project will require participation and consultation of affected persons for prepared safeguard instruments as set out in the SEP found in Annex I of the ESMF.

50 Native in this context generally refers to any aboriginal inhabitant and descendants thereof, whether wholly or partly of aboriginal descendant.


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Country Context Land Tenure in Kiribati Land tenure refers to the terms and mode under which land and natural resources are held or occupied by individuals or groups. These are rules, usually formal, but informal arrangements are common, these define the nature and content of property rights in land or other resources and the conditions under which those rights are to be held and enjoyed. Key aspects of the Kiribati land and tenure system are:

• The rights of the landowner are paramount in existing land tenure and urban planning arrangements51.

• In Tarawa, the vast majority of land on South Tarawa is under customary ownership with the Government leasing portions of private land under the State Acquisition of Lands Act in the ‘public interest’. Government leased land covers approximately 30% of land on South Tarawa52 and occupies most of the lands in Betio, Bairiki, Bikenibeu, Bonriki and Buota.

• All land on Kiritimati is state land except for plots made available for freehold in Tabwakea stages 1, 2, and 3. Government has made a public commitment to release land for all types of land activities, including the acceptance of applications for leases of land from individuals53.

• Land is primarily owned by men, and greater shares of land are inherited by men, although traditions vary across islands. Women are therefore less likely to own property.

Land Leases in Kiribati

A lease is an agreement whereby the landowner (lessee) agrees to allow his/her land or part of his/her land to be used by some other person (lessee) in return for an agreed amount of money in the form of rent. A lease agreement shall be valid if it is done in accordance with the provisions of the Lands Code. The nature of lease agreements varies from agreement to agreement depending on the nature of the parties involved in the lease agreement. The common forms of voluntary land use agreements in Kiribati are the leases, subleases, licenses, house plots, renting, land purchase, and land exchanges.

The Native Lands Cap 61 distinguishes between a Native and a Non-Native Lease:

▪ Native Lease. A Native Lease is a lease of native land to another native where the term of the lease must not exceed 21 years and the size of leased land not more than 5 acres. A Native is defined in the Ordinance an aboriginal inhabitant of the Gilbert Islands or a descendant of an aboriginal inhabitant. A native lease agreement must be submitted to the Magistrate Lands Court before it is approved. The Magistrate Lands Court shall only approve the lease agreement if the Court is satisfied that the land is the registered property of the lessee, and the terms of the agreement are fair to both parties. The Court must also ensure that the lessee has sufficient land remaining to support himself and his family. A Native Lease is usually registered in the Register of Native Leases, which is kept by the Court. There is a Magistrate Lands Court and Register of Native Leases for each of the main Kiribati islands.

51 Office of Te Beretitenti, 2012. No. 6 South Tarawa Report 52 Office of Te Beretitenti, 2012. No. 6 South Tarawa Report 53 Office of Te Beretitenti, 2012. No. 20 Kiritimati Report


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▪ Non-Native Land Lease. A Non-Native Lease is any lease agreement other than a Native Lease. Non-Native leases include a lease to a native for longer than 21 years and a lease to a non-native for any period of time. Before a Non-Native lease is formally approved by the Magistrates Lands Court, the Court must be satisfied that the lessee is the registered landowner, and that the lessee is allowed to lease the land in accordance with the provisions of the Lands Code. Once the Court has approved the Non-Native Lease Agreement, the Lease Agreement must have the statutory endorsement of the Minister responsible for the Lands. The Minister must satisfy himself that the terms of the Non-Native Lease are fair to both parties, that the lease is in the correct form, and the lease fees have been paid. Compliance with these requirements ensures that lease is registered in a Register of Non-Native Leases. The Register of Non-Native Leases includes government leases, Church leases, and Council leases.

Kiribati’s Land Acquisition Process The Constitution of Kiribati and land-related legislation begin with the premise that land cannot be alienated by sale, gift, lease or otherwise to a person who is not a native. It does not, however, restrict the alienation of land to the State, Local Government Council and the Housing Corporation. The State can acquire land, by agreement or compulsorily, for public purposes.

Involuntary Resettlement The Native Lands Ordinance and State Acquisition of Lands Ordinance provide for compensation arrangements in the case of involuntary resettlement, provided those resettled are not in default of any current law (i.e. not illegal settlers/squatters). Basic legal provisions addressing involuntary resettlement appear to be limited to financial compensation for land that is legally registered. Furthermore, evidence that alternatives have been considered is also not always required under Kiribati law.

Project Description Project Components The Project is designed as a six year, USD 19.5 million Investment project financing (IPF) organized into four components:

▪ Component 1: Strengthening Monitoring, Control and Surveillance of Large-Scale Oceanic Fisheries

▪ Component 2: Diversifying Marine-Based Revenue Streams for Outer Island Coastal Communities

▪ Component 3: Improving Seafood Toxicology and Safety Measures in Selected Fisheries ▪ Component 4: Delivering Effective Project Management

Types of Subproject Activities In order to assess the applicability of OP4.12 on Involuntary Land Acquisition, project typologies have been identified under the four components which includes 1) Technical Advisory; 2) MFMRD Assets; and 3) Outer Island Investments. These project typologies and their associated land needs are discussed in detail next.

Technical Advisory


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These may include the development of monitoring and management plans, training and capacity building programs, needs assessments, gap analyses, and policy and legislation development. No land will be required for these activities. However, there is the risk that studies set up a future scenario or state where land access becomes a project delivery risk, and/or the Technical Advisory does not minimize or avoid involuntary land acquisition or resettlement, causing greater impacts in future.

MFMRD assets

These may include infrastructure developments such as new fit for purpose MCS facilities in Betio and Kiritimati, and the construction of the two MFMRD laboratories on seafood toxicology and coastal fisheries research within the centralized Kiribati One Health Support Institute (KOHSI) to be located in Betio. Land will be needed for the development of these activities.

Based on discussions with MFRMD, these developments will be located on government land and the MFMRD will facilitate this process by finding suitable government land. Early consultation with the Lands Division within MELAD will help identify suitable sites. If there is no appropriate government land, then the government will need to negotiate an appropriate voluntary lease arrangement. Consultation with the community and stakeholder engagement will be important if private land access is required. No involuntary land acquisition will be required.

Land clearance for construction may involve the loss of trees or existing structures. As Government land is preferred, private assets are considered extremely unlikely. In the event that any private assets are located on the land subject to a negotiated lease, removal, relocation and compensation will be discussed as part of the lease arrangements and agreement with affected asset owners will be reached for how such arrangements will be implemented.

Outer Island Investments

MFMRD may make targeted investments to catalyze implementation of the sustainable supply chain development plans. Investments may include small-scale infrastructure developments on outer islands such as onshore processing facilities, ice and cold storage facilities, and aquarium fish holding facilities. Investments may also include small boats designed for accessing nearshore FADs; safety-at-sea gear; onshore processing equipment such as solar smokers; packaging tools and equipment (e.g., vacuum packaging for smoked flying fish); and aquarium fish holding facilities and equipment (storage tanks, O2 injection equipment). However, these can be excluded as they will not require any land acquisition or result in restriction of access to resources.

Based on discussions with MFMRD, rehabilitation of existing buildings is being considered. If land is required for additional construction of small-scale investments, it will be government land. If there is no appropriate government land, then the government will need to negotiate an appropriate voluntary lease arrangement. All arrangements will be entered into voluntarily, as outlined in Attachment 1 and signed agreements are to be made between parties before works are carried out. If acceptable arrangements are not met, alternatives sites will be sought. No involuntary land acquisition will be required.


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Project Land Requirements and Potential Risks

Table 1 summarizes the types of subprojects and identifies the land acquisition and resettlement processes, risks, and mitigations/actions in accordance with Kiribati law and with OP4.12, and identifies where OP4.12 is triggered.


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Table 1 - Component Activities: Land Requirements and Potential Risks

Project Typology Description Land Acquisition and Resettlement Processes

Land Acquisition and Resettlement Risks

Action OP4.12 Policy triggered

Technical Advisory (TA)

These may include the development of monitoring and management plans, training and capacity building programs, needs assessments, gap analyses, and policy and legislation development.

No land acquisition will be required. However, studies must consider the implications of their recommendations on land acquisition in accordance with OP4.12.

Studies could set up a future scenario or state where land access becomes a project delivery risk, and / or the TA does not minimize or avoid involuntary land acquisition or resettlement, causing greater impacts in future.

Include safeguard clauses (Annex VIII of the ESMF) into Terms of Reference for Technical Advisory.

Yes. This activity will not cause involuntary taking of land. However, OP4.12 is triggered as a precautionary measure to ensure land issues are addressed in all future studies under Components 1, 2, and 3.

MFMRD assets These may include construction activities, such as: ▪ Construction of new fit for purpose MCS facilities in Betio and Kiritimati. ▪ Construction of the two MFMRD laboratories within the centralized KOHSI to be located in Betio

Government land will be used.

Land clearance for construction may involve the loss of trees or existing structures. It is unlikely that these will be private assets as this is existing government land. Land in South Tarawa is scarce and there is a risk that suitable government land cannot be found.

Avoid sites where significance clearance needs to take place. Any private assets on the land, if present, will be relocated in negotiation with affected people with adequate notice and stakeholder consultation. Compensation for lost assets at replacement value. Early consultation with Lands Division to identify potential sites. If there is not appropriate government land, then the government will negotiate an appropriate lease arrangement. Extensive consultation with the community and stakeholder engagement will then be required.

Yes. Infrastructure will be located on government land. However, OP4.12 has been triggered due to scarcity of available land in Tarawa.

Small-scale infrastructure

These may include small scale infrastructure

Government land will be used or, if

Land clearance for construction may involve loss

Avoid sites where significance clearance needs to take place. Avoid

No. This activity will not cause involuntary


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development on outer islands

developments or rehabilitation of existing facilities.

government land is not available, voluntary land donation agreements will be made.

of trees, crops or existing structures.

impacts to trees and crops wherever possible, otherwise compensate at replacement value. All VLD arrangements will be entered into voluntarily. (see Attachment 1). If acceptable arrangements are not met, alternatives will be sought.

taking of land. Small-scale infrastructure developments will preferentially be located on government land or obtained through voluntary land donation negotiated by the MFMRD, in line with Attachment 1.


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Project Activities Mitigation Measures In order to manage the impacts associated with accessing land required for project activities and to ensure compliance with Kiribati law and with OP4.12, the following mitigation measures will be implemented through the life of the Project.

Technical Advisory Studies must consider the implications of their recommendations on land acquisition in accordance with OP4.12 and must minimize or avoid involuntary land acquisition or resettlement or involuntary restriction of access to assets. Any potential for future land acquisition as a result of the Technical Advisory must involve relevant stakeholder consultation. If necessary, the Technical Advisory must require the preparation of a Resettlement Policy Framework (RPF)/Resettlement Action Plan (RAP) for the implementation of any relevant recommendations. These requirements will be included as clauses in the Terms of References for Technical Advisory.

Terms of Reference for TA must include the following clause: “Recommendations must consider the impacts on land acquisition and access and where necessary, include a requirement for minimizing or avoid involuntary land acquisition, involuntary resettlement or involuntary restriction of access to assets. If necessary, the Technical Advisory must require the preparation of a Resettlement Policy Framework (RPF)/Resettlement Action Plan (RAP) for the implementation of any relevant recommendations.”

Terms of Reference safeguard clauses are included as Annex VIII of the ESMF.

MFMRD assets The following mitigation measures will need to be implemented by MFMRD to ensure compliance with OP4.12 and Kiribati law:

• Preferentially locate the infrastructure on Government land. • Consult with Land Division regarding land that will be needed for infrastructure. • Identify possible sites and screen for resettlement impacts before finalizing the chosen

location. • Avoid sites where significance clearance needs to take place. • Avoid any land where private assets are present, but if this is not possible then relocation

and compensation will be discussed as part of the lease arrangements and agreement with affected asset owners will be reached for how such arrangements will be implemented.

• If government land is not available, all lease arrangements will be entered into voluntarily. Extensive consultation with affected communities will be required. If acceptable arrangements are not met, alternatives will be sought.

• Consult with all affected communities, members of the community, and vulnerable groups who may be displaced and/or lose access to resources.

• Provide an acceptable grievance mechanism for affected groups.

Small-scale infrastructure development on outer islands The following mitigation measures will need to be implemented to ensure compliance with OP4.12 and Kiribati law:

• Preferentially rehabilitate existing facilities or locate new small-scale infrastructure on Government land.


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• If required, land donation process will be facilitated by MFMRD working with the Lands Division. The process and documentation will be in line with the Bank’s Voluntary Land Donation guidelines (see Attachment 1).

• Identify possible sites and screen for impacts before finalizing the chosen location. • If acceptable voluntary land donation are not met, alternative sites will be sought. • Avoid sites that require significant clearance. • Consult with all affected communities, members of the community, and vulnerable groups

who may be displaced and/or lose access to resources. Compensate for any lost resources such as crops or small structures at replacement value.

• Provide an acceptable grievance mechanism for affected groups.

Responsibilities In respect of the Kiribati PROP project, MFMRD will be responsible for negotiating land access for any physical investments for the MFMRD and will work collaboratively with the Lands Division. Responsibility for the preparation, implementation and monitoring of any RPF/RAPs (including responsibility for meeting all associated costs with their implementation) for any project activities, in accordance with this RPF, rests with the MFMRD.

Consultation and Disclosure A Stakeholder Engagement Plan (SEP) for the Project has been developed and is included as Annex I of the ESMF. The SEP includes an analysis of the main stakeholders of the Project, consultation and engagement methods, the schedule of key activities, and records keeping and reporting requirements. Consultations and disclosure of any prepared safeguard documents will be in accordance with the SEP.

Grievance Redress Mechanism A Grievance Redress Mechanism (process for managing complaints) for the Kiribati PROP project has been developed and is included as Annex XIV of the ESMF.

Conclusion and Recommendations At this stage, the exact nature and locations of activities that will be undertaken as part of the Kiribati Pathway project is unknown, though involuntary land acquisition can be avoided. The exact impacts associated with land acquisition and changes in access to assets can therefore also not be identified but are considered unlikely to be significant, since the location of assets is flexible to some extent.

In summary, OP4.12 is triggered as a precautionary measure to ensure land issues are addressed in all future studies under Components 1, 2, and 3. Where land is required for the project activities, it will be government land allocated for this use or obtained via negotiated voluntary land donation. Land impacts will be screened at each site and this screening will be covered by the ESMF. Consultation with all affected parties will be undertaken and no one (including vulnerable groups) will be worse off.


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Attachment 1 - Voluntary Land Donation Procedures 1. Background

This Voluntary Land Donation Protocol (VLDP) has been prepared by the World Bank for the purpose of due diligence. For cases where communities and/or individual landholders have offered to donate their land for the project because it is of benefit to the broader community, the World Bank’s Voluntary Land Donation Protocol (VLDP) should be followed. The project team is to exercise their best judgment where voluntary land is offered and conduct due diligence to avoid adverse impacts and reputational risks. Donations are based on the premise that the project benefit will offset or outweigh the loss of the land donated.

VLD is only suitable for projects where the landowner and/or community wish to ‘gift’ land parcels or small areas for small-scale community infrastructure that will be of direct benefit to the donor’s community.

2. When VLD is Applicable

Voluntary donation of land by beneficiary households is acceptable where:

• It has been verified the donation did not result from any form of coercion or manipulation and is offered in good faith;

• The donation does not severely affect the living standards of the community and/or individual landholder responsible for the donation (i.e. impacts are marginal based on percentage of loss and minimum size of remaining assets);

• Alternatives and the viability of other locations or sites have been considered;

• The donation does not result in the displacement of households or cause loss of income or livelihood;

• The landholder/s making the donation will directly benefit from the project;

• Consultation has been conducted in an open and transparent manner and to a degree that the landholder/s can make an informed choice;

• The land is free from disputes regarding ownership or tenure;

• Land transactions are supported through the transfer of titles;

• Full and proper documentation of all consultations, meetings, grievances and actions taken to address grievances has been reviewed and made available;

• Where impacts are minor and other alternative sites are not viable.

3. When VLD is NOT Applicable

VLD is not applicable under the following scenarios:

• Medium/large-scale infrastructure particularly in cases where a government agency or entity that has a statutory obligation to provide the infrastructure and/or services for which the land is required


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• Where inadequate consultation with donors results in lack of understanding about the terms and conditions of the donation;

• In lieu of formal procedures for land acquisition where these do not exist;

• Where donor property owners, landowners or customary rights holders do not support, or will not directly benefit from, the Project;

• Where conflicts over land exist, including customary collective ownership;

• Conflicting land titling that make it difficult to establish with certainty who has a right to own, donate and use a specific parcel of land;

• Where donors did not provide their informed consent and were subject to political or social pressure and coerced into making the donation.

4. Process for Voluntary Land Donation

This section outlines the process that should be followed once the threshold considerations set out in Section 2 and 3 above have been considered, and it has been determined that it is appropriate for the land to be provided to the project by voluntary donation.

It is necessary to follow a clear process for the donation, and to prepare and maintain documents that demonstrate such process. Each step set out below should be addressed in the context of the specific project, and fully documented.

(i) Determine and document that VLD is appropriate in the circumstances of the project.

The team should record the reasons why it thinks that the donation of land is appropriate for the project. In certain cases, only some of the land the project requires will be donated or alternatives to land donation exist. The project team should identify (in as much detail as possible):

• What the land will be used for;

• How much land the project will require on both a permanent and temporary basis;

• How much of the land will be donated;

• What alternatives to donation exist (e.g., right of use, right of way);

• The terms of the donation;

• The identities of the parties who intend to donate;

• The beneficiary of the donation; and

• Any details that are relevant to why donation may be appropriate.

(ii) Verify the requirements to transfer, and formalize the transfer of, the land

It is important to understand the process that should be followed to transfer the land, and appropriate ways to formalize the transfer so as to achieve certainty for both the transferee of the land and the project. In many countries this will require consideration of the legal and administrative requirements but also, particularly in the case of customary land, local and community processes. In some cases these


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will constitute two different but parallel (and overlapping) systems and a process will have to be established to ensure that the requirements of each system are satisfied. An important consideration will be how transparent the process and the decision making process actually is, and what can be done to enhance the process.

(iii) Conduct due diligence on who owns and uses the land

Given the specific issues surrounding land ownership and use in the PICs, it is important that the project team carries out careful due diligence to understand the type of land rights that exist in the project area, and to identify any particular issues relating to land ownership and use. Thereafter, a more specific due diligence must be conducted on each parcel of land proposed for donation to identify:

• The owner or owners of the land;

• The users of the land, or any parties that occupy the land (either physically or through ownership of an asset or conduct of livelihood or business activities on the land);

• Any competing claims of ownership or use;

• Structures and assets on the land;

• Any encumbrances on the land.

It is important to: (a) identify the right that is being transferred (an ownership right, a use right, a right of way, etc.); and (ii) check whether the transferee actually has the right s/he claims to have. In many circumstances where careful due diligence has not been carried out, significant conflict has arisen at a later stage when another party claims that they have the same or a competing right. In some circumstances – but not all – the transferee will have documentary evidence of such right. Where no such evidence exists, the due diligence can establish rights by speaking with local community officials and neighbours.

(iv) Disclosure and Consultation

The decision to donate must be taken on the basis of a full understanding of the project and the consequences of agreeing to donate the land. Accordingly, the parties that will be affected by the donation (the owners and users of the land) must be provided with accurate and accessible information regarding what the land will be used for, for how long, and the impact the donation will have on them and their families. It is important that prior written notification indicating the location and amount of land that is sought be provided and that its intended use for the project is disclosed.

Where the intention is to deprive the parties affected by the donation of the land permanently, or for a significant length of time, this must be made clear. It should be noted that in many communities the concept of alienation of land is uncommon and difficult to understand, and care needs to be taken to ensure that the implications of this are fully understood. It is also important to decide who else should be consulted about the proposed donation; for example, spouses and older children.

There should be a clear agreement as to which party will pay the costs associated with the donated land. This could include measurement costs, documentation and notarial fees, transfer taxes, registration fees. It should also include the costs of re-measuring/re-titling the transferee’s remaining land and any new documentation relating to it.


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(v) Establishing Informed Consent

It is crucial that the project team is confident that the decision to donate was taken in circumstances of informed consent or power of choice. As discussed earlier, this means being confident that the owner(s) or user(s) of the land understand:

• What the land is going to be used for, by whom and for how long;

• That they will be deprived of the ownership or right to use the land, and what this really means;

• That they have a right to refuse to donate the land;

• Whether there are alternatives to using this land;

• What they will need to do to donate the land (e.g., execute documents, get spousal consents, pay taxes);

• The effect of the donation on their family, and what they can do if they (or their family or heirs) want the land back.

• The exact demarcation of land boundary for the project’s use;

• Whether there are proposals which would allow other land to be used;

• What they will need to do to donate the land;

• The intergenerational effect of the donation on their family, what they can do if they (or their family or heirs) want the land back.

The terms and conditions of the land donation must be mutually agreed upon and detailing in a written agreement.

(vi) Documentation

It is necessary to distinguish between: (a) the agreement to donate the land; and (b) the document that carries out and evidences the legal transfer of the land. While it is important to have evidence of an intention and agreement to donate the land, it is equally important to ensure, where required and appropriate, that the land is legally transferred. While the process relating to the legal transfer of the land is frequently complicated and time consuming, it must be addressed. [In specific circumstances, for example where the land is being transferred to the community, it may not be necessary to legally transfer the land. However, experience indicates that lack of formal transfer can create significant uncertainty in the future, which impacts on the sustainability of the infrastructure and services, and can have a negative effect on community relations.]

To ensure that any land provided for the siting of subprojects is contributed voluntarily, in accordance with the requirements of the ESMF, two representatives of the landowners (family or clan) are asked to sign a Land Commitment Letter (see below). This certifies that the land is voluntarily donated for the purposes of the subproject and for the benefit of the community. The signature of the Letter is witnessed (as attested by their signature) by a suitable project representative.

The project team should:


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• Identify the appropriate documentation, including the agreement to make the transfer and any legal documentation that may be required;

• Ensure that the agreement:

• Refers to the consultation has taken place;

• Sets out the terms of the transfer;

• Confirms that the decision to transfer was freely made, and was not subject to coercion, manipulation, or any form of pressure;

• Attaches an accurate map of the land being transferred (boundaries, coordinates);

• Sets out who will bear the costs of the transfer (e.g., notarial fees, taxes, title issues) and documenting the residual land rights.

• Ensure that all necessary parties sign the documents, including obtaining consent from spouses and children over a certain age;

• Ensure that the transfer and title is registered or recorded; and

• Ensure that the land remaining after the donated land is excised is properly titled, registered or recorded.

It is also important to maintain a record of the process that has been followed. Such documents could include the following:

• The notification indicating the location and amount of land that is sought and its intended use for the project, with a record of when and where this was made public;

• Records of the consultations that were held and what was discussed;

• A copy of the due diligence that was conducted;

• Copies of each of the formal statements of donation, establishing informed consent as described above, and signed by each owner or user involved;

• Copies of all documents, registrations or records evidencing the legal transfer of the land; and

• A map, showing each parcel of land.

The Project implementing agency should maintain a record with documentation for each parcel of land donated. Such documentation must be available for World Bank review, and for review in relation to any grievances that may arise.

(vii) Grievance Arrangements

Grievances may be referred to customary conflict mediation arrangements where they are not directly affiliated with traditional leaders who are a party to the donation process.


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Annex III Checklist 1 – Screening Process

Is it a compliance vessel?

Refer to Guideline 1 -MFMRD Vessels (Annex IX).

Is it an outer island investment?

Is it operation of the MFMRD Laboratories? Yes

No

Is it a training or capacity building program?

No

Yes

Yes

Refer Section 6 – Technical Advisory Table in the ESMF. Include E&S clauses in the TOR (Annex VIII).

Is it a Technical Advisory e.g. Gap Analysis,

Management Plan etc.?

Yes

Is the project a new building or renovation?

Apply for Environmental Licence for sample collection. Prepare EHS & Waste

Management plans. Develop Contaminant Response Plan (if

required).

Use Checklist 2 - Construction and Renovation Screening Checklist

(Annex IV). Check Ineligible Activity List (Ch 7, Table 4 in ESMF).

Refer Section 6 – Technical Advisory Table in the ESMF. Include E&S clauses in the TOR (Annex VIII).

No

Yes

No

Yes

No

Refer to Guideline 2 – Outer Island Investments (other than construction

and renovation) (Annex X).

All other projects

No

Yes Use Checklist 3 (Annex V).

Check Ineligible Activity List (Ch 7, Table 4 in ESMF).


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Annex IV Checklist 2 - Construction and Renovation Screening Checklist

Name of the Subproject: Screening Date:

Locality: Description of the area:

Step 1. Screen for Renovation or New Build

Step 2: Land Acquisition

1. Is the land required government land or private land?

Government land. Work with Land Management Division, MELAD to acquire government land. Private land. Must be voluntary land donation only. Involuntary land acquisition is prohibited.

Exclude land with private assets or that needs significant clearance.

Step 3: Environmental Risks

2. Will the activity be undertaken within the designated foreshore? Yes – obtain the required licence from the Chief Lands Officer, Land Management Division, MELAD before you submit any require environment licence application to the ECD. No

3. Check the Schedule of Environmentally Significant Activities in the Environment Act 1999. Is the activity listed?

Yes – download the Environment Licence Application Form from the ECD website. Complete and submit to the ECD. Continue to question 4 to assess World Bank requirements. No – no further environmental action is required under Kiribati law. Continue to question 4 to assess World Bank requirements.

Is the project a new build? Yes Proceed to Step 2

Is the project a renovation? Yes

Category C. Low Risk. • Prepare ECOP. • Screen for asbestos & hazardous

materials. Prepare Asbestos and Hazardous Materials Plan (if required).

• Prepare & follow Waste Management Plan.

• Prepare Health and Safety Plan.

No


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4. Will this activity require any clearance of trees or other vegetation? Yes – Category B No

5. Will there be any negative impacts on sensitive or non-critical natural habitats i.e. those not defined as ‘critical natural habitat’ in OP4.04?

Yes – Category B No

6. Will construction be located near rivers, waterways or water bodies/ponds?


7. Will this activity require any land reclamation?


8. Will this activity result in any significant increase in pollution e.g. generation of waste etc.?


9. Will this activity result in the occurrence, or increase the chances of occurrence, of natural hazards such as soil erosion, flooding, tidal inundation or hazardous substances?


10. Are utility services unavailable and/or inadequate for the activity?


Step 4: Social Risks

1. Will this activity require compensation for crops and/or assets?


2. Will this activity impact areas, landscapes and structures of aesthetic, archeological, cultural, historical, recreational, scenic or scientific value?

Yes – Category B No – ensure chance find procedures in place. Annex XV.


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Step 5. World Bank and Kiribati Risk Categorisation and Safeguards Instrument

ESA Project (Kiribati). If identified in Step 3, apply for an environmental licence and prepare a BEIA or EIA as required by the PEO of the ECD, incorporating an ESMP (WB). Prepare Waste Management Plan. Prepare Construction Health and Safety Plan with gender base violence (GBV) requirements defined.

Category B. If yes to any of the questions in Step 3 or Step 4, but not identified as an Environmentally Significant Activity under Kiribati law, ESMP required (WB). Recommend further scoping to determine actual scale of risk and identify opportunities to reduce risks. Prepare ESMP. Prepare Waste Management Plan. Prepare Construction Health and Safety Plan with GBV requirements defined.

Minor project. If no’s to all questions in Step 3 and Step 4. Minor risks. Prepare ECOP. Prepare Waste Management Plan. Prepare Construction Health and Safety Plan with GBV requirements defined.

Step 6: Preparation of safeguard instruments

Before developing safeguard instruments, discuss design with Project Team (Step 4 of Screening of Subprojects Process, see Section 7 of the ESMF).

The subproject located has been assessed and the following safeguard documents/instruments will be prepared:

BEIA incorporating ESMP (Kiribati & WB) Date Complete: EIA incorporating ESMP (Kiribati & WB) Date Complete: ESMP (WB) Date Complete: ECOP (WB) Date Complete: Asbestos and Hazardous Materials Plan Date Complete: Waste Management Plan Date Complete: Health and Safety Plan Date Complete:


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Annex V Checklist 3 – All Other Projects Screening Checklist This form is to be used by the KFSU PMU to for screen potential environmental and social safeguards issues in subprojects, determine the level of risk and the type instrument to be prepared or follow-up action to be taken.

This form is for all ‘other’ activities not already screened in the ESMF. Before screening, check that the activity is not listed in Ineligible Activity List (Table 4 in the ESMF).

Subproject Name Subproject Location(s) Subproject Type Start/Completion Date Confirm the activity is not on the prohibited list (Table 4 in ESMF)

Screening Questions for Subproject Answer If Yes

WB Category of Risk and

Policy triggered

Actions and Safeguards Documents Required if

Yes

Yes No

Is the subproject likely to have significant adverse social or environmental impacts that are sensitive, diverse or unprecedented? Please provide brief justification. E.g. Will cause significant health and safety issues for 10’s or 100’s of people. This includes ‘downstream’ or future impacts from Technical Advisory studies.

OP 4.01 Environmental

Assessment Category A

Ineligible for funding. This subproject is

Category B and cannot fund Category A

projects. Could the

subproject be redesigned to

avoid or reduce

impacts?


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Screening Questions for Subproject Answer If Yes WB Category of Risk and

Policy triggered


Yes

Yes No

Is the proposed subproject likely to have minimal or no adverse environmental or impacts? Please provide brief justification. E.g. Providing goods (software, computers, tools, fishing rods), training, simple repairs to structures, signage).


Assessment Category C

No action needed beyond

screening.

Is the subproject neither a Category A nor Category C as defined above?54 This includes Technical Advisory. Please provide brief justification. E.g. Compensation required for loss of assets or access to access from land users (but no physical relocation), related to voluntary land donation or land leasing. Affecting livelihoods from the restriction of access to protected areas.


Assessment Category B

Further scoping

required to determine

actual scale of risk and identify

opportunities to reduce

risks. ESIA or ESMP or

mitigated through

subproject design such as

Technical Advisory TOR.

54 Projects that do not fall under Category A or Category C can be considered as Category B. Examples of Category B subprojects include small scale in-situ reconstruction of infrastructure projects such as road rehabilitation and rural water supply and sanitation, small schools, rural health clinics, etc.


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Policy triggered


Yes

Yes No

Will the subproject desecrate, destroy or damage physical cultural resources?55 Please provide brief justification.

OP 4.11 Physical Cultural

Resources

Ineligible as OP4.11 is not triggered for

this subproject.

Recommend redesigning

the subproject to avoid these

impacts.

Will the subproject involve the conversion or degradation of natural habitats (not defined as ‘critical habitat’ in the policy)? Please provide brief justification.

OP 4.04 Natural Habitats

Category B

Further scoping

required to determine

actual scale of risk and identify

opportunities to reduce

risks. ESIA or ESMP or

mitigated through

subproject design such as

Technical Advisory TOR.

55 Examples of physical cultural resources are archaeological or historical sites, including historic urban areas, religious monuments, structures and/or cemeteries, sacred locations (trees, rocks, landscapes), particularly sites recognized by the government or community, .


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Policy triggered


Yes

Yes No

Will the subproject involve the conversion or degradation of critical natural habitats?56 Please provide brief justification.

OP 4.04 Natural Habitats

Not eligible for financing under the

Policy. Recommend redesigning

the subproject to avoid these

significant impacts.

Will the subproject involve involuntary land acquisition, or the loss of assets or access to assets, or loss of income sources or means of livelihood as a result of involuntary land acquisition? Please provide brief justification.

OP4.12 Involuntary

Resettlement

Ineligible for funding.


the subproject to avoid

involuntary land

acquisition.

Will the subproject have the potential to have impacts on the health and quality of forests or the rights and welfare of people and their level of dependence upon or interaction with forests (including mangroves); or does it aim to bring about changes in the management, protection or utilization of natural forests and mangroves? Please provide brief justification.

OP4.36 Forestry

Ineligible for funding.


the subproject to avoid

impacts on health and quality of

forests (including

mangroves).

56 Subprojects that significantly convert or degrade critical natural habitats such as legally protected, officially proposed for protection, identified by authoritative sources for their high conservation value, or recognized as protected by traditional local communities, are ineligible for Bank financing.


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Questions for Kiribati Regulation Answer Actions and Documents Required if

Yes

Yes No

Is the subproject a prescribed development on the Schedule of Environmental Significant Activities of the Environmental Act 1999?

Environmental Licence

application form and EIA/BEIA

incorporating an ESMP

Conclusion and Safeguards Instruments Required

The subproject is classified as a Category ________ project as per World Bank OP 4.01, a prescribed development under Kiribati Environmental regulations and the following safeguard instruments will be prepared and / or actions taken:

1. _______________________________________________________________________ 2. _______________________________________________________________________ 3. _______________________________________________________________________ 4. _______________________________________________________________________ 5. _______________________________________________________________________


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Annex VI Environmental and Social Management Plan (ESMP) Template The Construction and Renovation Environmental and Social Management Plan (ESMP) provides guidelines for environmental management of the expected construction activities which are screened as Category B and require an ESMP during the implementation of the Kiribati PROP. The ESMPs should use the following structure as an example of the components to include, as appropriate. The ESMP should be incorporated into the contractors bidding document and/or contract.

Table of Contents Glossary and Abbreviations Executive Summary 1.0 Introduction

1.1 Background 1.2 Environmental and Social Objectives and Scope 1.3 Environmental and Social Management Plan Objectives and Scope 1.3.1 Environmental Safeguards Document Hierarchy and Development 1.4 ESMP Methodology

2.0 Project Description 2.1 Description of Works 2.2 Duration and Timing of Construction Activities 2.3 Site Plan 2.4 Alternatives

3.0 Policy, Legal and Administration Framework 3.1 National Requirements 3.2 Regional Requirements 3.3 International Obligations 3.4 World Bank Policy

4.0 Environmental and Social Environment 4.1 Physical Environment

4.1.1 Location and Geography 4.1.2 Climate and Coastal Processes 4.1.3 Soil and Geology 4.1.4 Water Resources 4.1.5 Land Use

4.2 Biological Environment 4.2.1 Marine Biodiversity 4.2.2 Terrestrial Biodiversity 4.2.3 Conservation Areas 4.2.4 Rare or Endangered Species

4.3 Socio-Economic Conditions 4.3.1 Population and Demographics 4.3.2 Education and Health 4.3.3 Livelihoods and Economic Activities 4.3.4 Land Tenure and Rights 4.3.5 Cultural Heritage

4.4 Projected Climate Changes and Impacts 5.0 Consultation and Stakeholder Engagement

5.1 Background and Approach 5.2 Outcomes of Consultation to Date 5.3 Disclosure


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6.0 Environmental and Social Impact 6.1 Overview of Impacts 6.2 Environmental Impact

6.2.1 Solid Waste 6.2.2 Water Resource Use 6.2.3 Biological Resources 6.2.4 Hazardous Substances and Materials 6.2.5 Noise and Vibration 6.2.6 Erosion and Sediment control 6.2.7 Air Emissions and Odours 6.2.8 Transport 6.2.9 Wastewater Discharges 6.2.10 Quarry and Aggregate Supply 6.2.11 Biosecurity 6.2.12 Secondary and Cumulative Impacts 6.2.14 Coastal and Marine Environment Impacts

6.3 Social Impact 6.3.1 Subsistence Economic and Cultural Change 6.3.2 Cultural Property 6.3.3 Gender Considerations including Gender Based Violence

7.0 Mitigation Measures57 7.1 Aggregate, Materials and Equipment Importation 7.2 Hazardous Substance Use, Storage and Disposal 7.3 Safety and Traffic Management 7.4 Stormwater and Water Management 7.5 Bitumen, Asphalt and Concrete Plant 7.6 Construction Camp58 7.7 Erosion and Sediment Control 7.8 Waste Water Management 7.9 Solid Waste Management 7.10 Socio-Economic Measures 7.11 Gender Based Violence Requirements 7.12 Chance Finds Procedure

8.0 Roles and Responsibilities 8.1 Institutional Capacity 8.2 Grievance Redress Mechanism 8.3 Capacity Development and Training

9.0 Compliance and Monitoring Plan59 9.1 Monitoring Plan 9.2 Reporting

10.0 Contingency Planning Appendix A ESMP Monitoring Plan Inspection Checklist Appendix B Consultation Summary

57 With Implementation Schedule and Cost Estimates 58 Include provisions for separate facilities for men and women 59 With Implementation Schedule and Cost Estimates


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Annex VII Construction and Renovation Environmental Code of Practice (ECOP) Template

The Construction and Renovation Environmental Code of Practice (ECOP) Template provides guidance for the environmental and social management of minor construction and renovation activities during the implementation of Kiribati PROP. The ECOPs should use the following structure as an example of the components to include in a construction or renovation ECOP, as appropriate. The ECOP should be incorporated into the contractors bidding document and/or contract.

1.0 Introduction 1.1 Project Description 1.2 Project Objective 1.3 Rationale of the ECOP 2.0 Applicable World Bank Safeguard Policies and Kiribati Regulations/Legislation/Standards

2.1. World Bank’s safeguard policies and guidelines 2.2 Kiribati Regulations/Legislation/Standards

3.0 Environmental Screening and Assessment 4.0 ECOP Implementation Arrangements 4.1 MFMRD PMU 4.2 DOFA KFSU 4.3 Contractor 5.0 Construction Activities and Environmental Rules for Contractors

5.1 Management of Construction Sites 5.1.1 Prohibitions 5.1.2 Working Hours 5.1.3 Good Housekeeping/General Site Management

5.1.4 Public Information and Site Access 5.1.5 Site Layout and Facilities60

5.1.6 Gender Based Violence Requirements 5.1.7 Emergency Procedures 5.1.8 Fire Prevention and Control 5.1.9 Operation of Equipment 5.1.10 Clearance of the Construction Site after Completion 5.2 Management of Environment and Sanitation

5.2.1 Nuisance, Dust and Noise Control 5.2.2 Disposal of Construction/Demolitions Waste 5.2.3 Erosion and sediment control 5.2.4 Management of Chemicals or Hazardous Wastes 5.2.5 Workforce and Workers Sanitation 5.2.6 Workforce Occupational Health and Safety During Construction 5.2.7 Community Occupational Health and Safety During Construction 5.2.8 Social Disturbance/Disruption to Existing Services 5.2.9 Community Relations 5.2.10 Physical Cultural Property Chance-finds Procedures

6.0 Public Disclosure

60 Include provisions for separate facilities for men and women


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Annex VIII Terms of Reference for Technical Advisory The Terms of Reference for any Technical Advisory contracts should contain the following safeguard clauses as a minimum:

1. Analysis should include the environmental and social aspects and impacts of the proposed TA, consistent with the safeguard policies of the World Bank and the Environmental and Social Management Framework (ESMF) of the Kiribati PROP Project.

2. Outcomes and outputs (such as design, construction methods, training materials, recommendations and advice) should be consistent with the safeguard policies of the World Bank and the Environmental and Social Management Framework (ESMF) of the Kiribati PROP Project.

3. Recommendations must avoid negative impacts of any downstream activities on critical natural habitats and forests, including mangroves.

4. Recommendations must consider the impacts on land acquisition and access and where necessary, include a requirement for minimizing or avoid involuntary land acquisition, involuntary resettlement or involuntary restriction of access to assets. If necessary, the Technical Advisory must require the preparation of a Resettlement Policy Framework (RPF)/Resettlement Action Plan (RAP) for the implementation of any relevant recommendations.

5. Free, prior and informed consultation of potentially affected people, stakeholders and vulnerable groups shall be adequately delivered, gender and youth inclusive, and well documented and in compliance with the Stakeholder Engagement Plan (SEP).

Outputs of this contract must be screened by the PMU Safeguards Officer/s.


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Annex IX Guideline 1 - MFMRD Vessels Under World Bank Policy OP4.01, vessels have been screened as a Category C. The activity is likely to have minimal or no adverse environmental impacts. No further safeguard documents are required. However, the design and purchase of vessels by MFMRD will need to follow this guideline to mitigate the health and safety risks identified through the environmental and risk screening process.

Design, procurement and operation process must ensure that:

• The vessel is appropriate for its intended use. • Vessels meet all requirement including safety specifications and are operated by trained, and

where required, qualified persons. • Vessels are maintained and stocked with international standard safety equipment and spill

equipment. • An Environment, Health and Safety (EHS) Plan is developed and shared with vessel operators. • Safety equipment, such as life jackets and flares, are provided to all operators and users. • All users are trained to operate spill equipment, safety equipment, and safety procedures are

followed at every outing. • Vessel inspection and maintenance programs are developed and implemented. • Vessel inspection and maintenance records are kept and made available upon request.


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Annex X Guideline 2 – Outer Island Investments

Applications for Outer Islands Investments will need to be screened as they are received by MFMRD prior to allocation of the funding. A basic Environmental and Social Management System (ESMS) for the transfer of funds to fisheries communities should also be developed and followed by the MFMRD.

Each time an outer island investment is proposed, the following Investment Screening Checklist needs to be completed:

Outer Island Investment Screening Checklist

Name of Outer Island: Screening Date:

Locality: Description of Investment:

1. Is the Investment already identified and screened in Section 6 – Potential Environmental and Social Impacts and Measures to Mitigate of the ESMF? Yes – proceed to question 2. No – complete Checklist 3 – All Other Projects Screening Checklist.

2. Which of the following investment is it? Boat - Use the EHS Plan for Purchasing Small Boats and EHS Plan Guideline for Boating Activities

(page 95 of ESMF). Small-scale onshore processing facility

- Complete Checklist 2 – Construction and Renovation Screening Checklist. Prepare safeguard documents as defined through the screening process. - Check the Environment Act 1999 – Schedule of Environmentally Significant Activities. If activity is listed apply for Environmental License under Kiribati Law and prepare an EIA/BEIA as determined by the PEO of the ECD. - Prepare EHS plan for operation. Refer to EHS Guideline for Fish Processing (Annex XII) for example of good international industry practice (GIIP). - Prepare Waste Management Plan for operation.

Aquarium Fish Holding Facility - Complete Checklist 2 – Construction and Renovation Screening Checklist. Prepare safeguard documents as defined through the screening process. - Complete ESMP for operation. Refer to Guideline for ESMP for Operation of Aquarium Fish Holding Facility (Page 96 of ESMF) - Complete EHS for operation. Refer to EHS Guideline for Aquaculture (Annex XIII) for a good example of good international industry practice (GIIP). - If this activity also involves the collection of aquarium fish, apply for an Environmental License under Kiribati Law and prepare an EIA/BEIA as determined by the PEO of the ECD.


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Guidelines for Purchasing Boats and Boating Activities EHS plans

EHS guidelines will be prepared by the MFMRD for purchasing of small boats and boating activities on Outer Islands under the Kiribati PROP project. The guidelines for preparing the EHS’s are as follows.

EHS Plan Guideline for Purchasing Small Boats

Under World Bank Policy OP4.01, vessels have been screened as a Category C. The activity is likely to have minimal or no adverse environmental impacts. No further safeguard documents are required. However, the design and purchase of vessels by communities will need to follow a standard EHS plan for purchasing small boats, developed by MFMRD.

The standard EHS plan for purchasing small boats should include the following:

• That the vessel is appropriate for its intended use. • Vessels meet all requirements including safety specifications and are operated by qualified

persons. • Vessels are maintained and stocked with international standard safety equipment. • Safety equipment, such as life jackets and flares, are provided to all operators and users. • All users are trained to operate safety equipment, and safety procedures are followed at every

outing. • Vessel inspection and maintenance records are kept and made available upon request.

EHS Plan Guideline for Boating Activities (including accessing nearshore FADs)

The use of vessels by communities will need to follow a standard EHS plan for boating activities developed by MFMRD for the project.

The standard EHS plan for boating activities should include the following:

• Vessels meet all requirements including safety specifications and are operated by qualified persons.

• Vessels are maintained and stocked with international standard safety equipment. • Safety equipment, such as life jackets and flares, are provided to all operators and users. • All users are trained to operate safety equipment, and safety procedures are followed at every

outing. • Vessel inspection and maintenance records are kept and made available upon request.


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Guideline for ESMP for Operation of Aquarium Fish Holding Facility

Under World Bank Policy OP4.01, aquaculture facilities are a category B and will require the development of an Environmental and Social Management Plan (ESMP) as part of a limited assessment. This guideline details how to prepare an ESMP for the operation of an Aquarium Fish Holding Facility that meets World Bank requirements:

1.0 Introduction 1.1 Project Description 1.2 Project Objective

1.3 Purpose of the ESMP 2.0 Applicable World Bank Safeguard Policies and Kiribati Regulations/Legislation/Standards

2.1 World Bank’s safeguard policies and guidelines 2.2 Kiribati Regulations/Legislation/Standards

3.0 Environmental Screening and Assessment 3.1 Environmental impacts.

3.1.1 Ecosystem impacts e.g. pressures on natural resources. 3.1.2 Water intake information such location of intake, rate of flow, and volume. 3.1.3 Wastewater discharge information such as location of discharge, nature of discharge (contaminants), treatment required, rate of discharge, volume and testing regime. 3.1.4 Solid waste disposal, including fish mortalities. 3.1.5 Hazardous materials and chemical use and storage. 3.1.6 Any long-term effects upon the environment and any identified cumulative effects.

3.2 Social Impacts. 3.2.1 Worker Health and Safety. 3.2.2 Community Health and Safety. 3.2.3 Increases in traffic flow. 3.2.4 Nuisances e.g. odor, noise.

4.0 Environmental and Social Impacts Management Measures 4.1 Wastewater treatment process 4.2 Solid waste handling, storage and disposal procedures including fish mortalities. 4.3 Storage, handling and disposal of chemicals. 4.4 Management of facility including hours of operation.

4.5 Operation of Equipment. 4.6 Inspection and maintenance procedures. 4.7 Workforce Occupational Health and Safety.

4.8 Methods for reducing nuisance from facility e.g. odor, noise, increases in traffic flow. 4.9 Emergency procedures e.g. in the event of plant failure or natural disaster. 4.10 Complaints process (grievance redress mechanism).

5.0 Institutional Arrangements 6.0 Public Consultation and Disclosure


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Annex XI World Bank Group Good Practice Note: Asbestos

World Bank Group May 2009

Good Practice Note: Asbestos: Occupational and Community Health Issues

1. SUMMARY The purpose of this Good Practice Note is to increase the awareness of the health risks related to occupational asbestos exposure, provide a list of resources on international good practices available to minimize these risks, and present an overview of some of the available product alternatives on the market. The need to address asbestos-containing materials (ACM) as a hazard is no longer under debate but a widely accepted fact. Practices regarding asbestos that are normally considered acceptable by the World Bank Group (WBG) in projects supported through its lending or other instruments are addressed in the WBG’s General Environmental, Health and Safety (EHS) Guidelines.1 This Good Practice Note provide background and context for the guidance in the WBG EHS Guidelines. Good practice is to minimize the health risks associated with ACM by avoiding their use in new construction and renovation, and, if installed asbestos-containing materials are encountered, by using internationally recognized standards and best practices (such as those presented in Appendix 3) to mitigate their impact. In all cases, the Bank expects borrowers and other clients of World Bank funding to use alternative materials wherever feasible. ACM should be avoided in new construction, including construction for disaster relief. In reconstruction, demolition, and removal of damaged infrastructure, asbestos hazards should be identified and a risk management plan adopted that includes disposal techniques and end-of-life sites. 2. ASBESTOS AND HEALTH RISKS 2.1. What is Asbestos, and Why are We Concerned with its Use? Asbestos is a group of naturally occurring fibrous silicate minerals. It was once used widely in the production of many industrial and household products because of its useful properties, including fire retardation, electrical and thermal insulation, chemical and thermal stability, and high tensile strength. Today, however, asbestos is recognized as a cause of various diseases and cancers and is considered a health hazard if inhaled.2 The ILO estimates that over the last several decades 100,000 deaths globally have been due to asbestos exposure,3 and the WHO states that 90,000 people die a year globally because of occupational asbestos exposure.4

1 http://www.ifc.org/ifcext/enviro.nsf/AttachmentsByTitle/gui_EHSGuidelines2007_GeneralEHS/$FILE/Final+-+General+EHS+Guidelines.pdf (pp. 71, 91, 94) . 2 http://www.who.int/occupational_health/publications/draft.WHO.policy.paper.on.asbestos.related.diseases.pdf. See also Stayner L, et al., “Exposure-Response Analysis of Risk of Respiratory Disease Associated with Occupational Exposure to Chrysotile Asbestos.” Occupational Environmental Medicine. 54: 646-652 (1997). 3 http://www.ilo.org/wow/Articles/lang--en/WCMS_081341 4 http://www.who.int/occupational_health/publications/asbestosrelateddiseases.pdf

http://www.ifc.org/ifcext/enviro.nsf/AttachmentsByTitle/gui_EHSGuidelines2007_GeneralEHS/$FILE/Final+-+General+EHS+Guidelines.pdf


http://www.who.int/occupational_health/publications/draft.WHO.policy.paper.on.asbestos.related.diseases.pdf

http://www.who.int/occupational_health/publications/asbestosrelateddiseases.pdf

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Over 90% of asbestos5 fiber produced today is chrysotile, which is used in asbestos-cement (A-C) construction materials: A-C flat and corrugated sheet, A-C pipe, and A-C water storage tanks. Other products still being manufactured with asbestos content include vehicle brake and clutch pads, roofing, and gaskets. Though today asbestos is hardly used in construction materials other than asbestos-cement products, it is still found in older buildings in the form of friable surfacing materials, thermal system insulation, non-friable flooring materials, and other applications. The maintenance and removal of these materials warrant special attention. Because the health risks associated with exposure to asbestos area now widely recognized, global health and worker organizations, research institutes, and some governments have enacted bans on the commercial use of asbestos (see Box 1), and they urge the enforcement of national standards to protect the health of workers, their families, and communities exposed to asbestos through an International Convention.6

BOX 1. BANS ON THE USE OF ASBESTOS AND ASBESTOS PRODUCTS

A global ban on commercial use of asbestos has been urged by the Building and Wood Workers Federation (IFBWW), the International Metalworker’s Federation, the International Trade Union Confederation, the government of France, and the distinguished scientific group Collegium Ramazzini. All member states of the European Union and over 40 countries worldwide (see Appendix 1) have banned all forms of asbestos, including chrysotile.7 In June 2006, the General Conference of the ILO adopted a resolution to “promote the elimination of all forms of asbestos and asbestos-containing materials.” • Landrigan PJ, Soffritti M. “Collegium Ramazzini Call for an International Ban on Asbestos.” Am. J. Ind. Med.

47: 471-474 (2005). • The International Ban Asbestos Secretariat keeps track of national asbestos bans. http://

ibassecretariat.org./lka_alpha_asb_ban_280704.php • General Conference of the International Labor Organization, “Resolution Concerning Asbestos,” Provisional

Record, International Labor Conference, Ninety-fifth Session, Geneva, 2006, Item 299, pp. 20/47-48. • World Health Organization: http://www.who.int/occupational_health/publications/asbestosrelateddiseases.pdf 2.2. Health Concerns Linked to Asbestos-Containing Products Health hazards from breathing asbestos dust include asbestosis, a lung scarring disease, and various forms of cancer (including lung cancer and mesothelioma of the pleura and peritoneum).8 These diseases usually arise decades after the onset of asbestos exposure. Mesothelioma, a signal tumor for asbestos exposure, occurs among workers’ family members

5 Asbestos defined in Castleman, B. Asbestos: Medical and Legal Aspects 5th Ed. New York: Aspen, 2005, 894 pp. 6 ILO Asbestos Convention No. 162, (see http:www.ilo.org/ilolex or http://www.itcilo.it/actrav/osh_es/m%F3dulos/legis/c162.htm) 7 http://www.who.int/occupational_health/publications/asbestosrelateddiseases.pdf. Directive 2003/18/EC of the European Council and Parliament amending Council Directive 83/477/EEC, and Directive 99/77/EEC 8 http://www.euro.who.int/document/aiq/6_2_asbestos.pdf

http://www.ibas.btinternet.co.uk/Frames/f_lka_alpha_asb_ban_280704.htm

http://www.ibas.btinternet.co.uk/Frames/f_lka_alpha_asb_ban_280704.htm



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from dust on the workers’ clothes and among neighbors of asbestos air pollution point sources.9 Some experimental animal studies show that high inhalation exposures to all forms of asbestos for only hours can cause cancer.10 Very high levels of airborne asbestos have been recorded where power tools are used to cut A-C products and grind brake shoes. For chrysotile asbestos, the most common variety, there is no threshold (non-zero) of exposure that has been shown to be free from carcinogenic risks. Construction materials are of particular concern, because of the large number of workers in construction trades, the difficulty of instituting control measures, and the continuing threat posed by in-place materials that eventually require alterations, repair, and disposal.11 Renovations and repairs in buildings containing A-C materials can also endanger building occupants. In addition to the problems from products made with commercial asbestos, asbestos also occurs as a contaminant in some deposits of stone, talc, vermiculite, iron ore, and other minerals. This can create health hazards for workers and residents at the site of excavation and in some cases in the manufacture and use of consumer products the materials are used to make. While asbestos is a known carcinogen when inhaled, it is not known to be carcinogenic when ingested, as through drinking water,12 although pipe standards have been issued for asbestos-cement pipes conducting “aggressive” water.13

From the industrial hygiene viewpoint, asbestos creates a chain of exposure from the time it is mined until it returns to the earth at landfill or unauthorized disposal site. At each link in the chain, occupational and community exposures coexist. Workers in the mines are exposed to the fibers while extracting the ore; their families breathe fibers brought home on work clothes; workers in the mills and factories process the fiber and manufacture products with it; and their families are also secondarily exposed. Communities around the mines, mills, and factories are contaminated with their wastes; children play on tailings piles and in contaminated schoolyards; transportation of fiber and products contaminates roads and rights-of-way.14 Tradesmen who install, repair and remove ACM are exposed in the course of their work, as are bystanders in the absence of proper controls. Disposal of asbestos wastes from any step in this sequence not only exposes the workers handling the wastes but also local residents when fibers become airborne because of insufficient covering and erosion control. Finally, in the absence of measures to remove ACM from the waste stream and dispose of them properly, the cycle is often repeated when discarded material is scavenged and reused.15

9 “Asbestos.” World Health Organization IARC Monographs on the Evaluation of Carcinogenic Risks to Humans/ Overall Evaluations of Carcinogenicity: An Updating of IARC Monographs 1 to 42, Suppl. 7. Lyon: International Agency for Research on Cancer, 1987, pp. 106-116. 10 Wagner JC, Berry G, Skidmore JW, Timbrell V. “The Effects of the Inhalation of Asbestos in Rats.” Br. J. Cancer 29: 252-269 (1974). 11 International Program on Chemical Safety, “Conclusions and Recommendations for Protection of Human Health,” Chrysotile Asbestos, Environmental Health Criteria 203. Geneva: World Health Organization, 1998, p. 144. 12 http://whqlibdoc.who.int/hq/2000/a68673_guidelines_3.pdf 13 http://whqlibdoc.who.int/hq/2000/a68673_tech_aspects_4.pdf 14 Jones, Robert “Living in the Shadow of the Asbestos Hills (The Need for Risk Based Cleanup Strategies for Environmental Asbestos Contamination in South Africa).” Environmental Exposure, Crisis Preparedness and Risk Communication, Global Asbestos Congress, Tokyo, Japan, November 19 - 21, 2004. http://park3.wakwak.com/~gac2004/en/index_abstract_e.html. See also Oberta, AF “Case Study: An Asbestos Cement Plant in Israel -- Contamination, Clean-up and Dismantling.” Hellenic Asbestos Conference, Athens, Greece, October 29 - 31, 2002. http://www.ibas.btinternet.co.uk/Frames/f_lka_hellen_asb_conf_rep.htm 15 Boer, A.M., L.A. Daal, J.L.A. de Groot, J.G. Cuperus “The Combination of the Mechanical Separator and the Extraction Cleaner Can Process the Complete Asbestos-containing Waste-stream and Make it Suitable for Reuse.”

http://park3.wakwak.com/%7Egac2004/en/index_abstract_e.html

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2.3. Increasing Use of Asbestos Fiber There is evidence that, after a decline in the 1990s, the use of asbestos fiber is increasing globally. A recent study16 shows that a 59% increase in metric tons was consumed in 12 countries from 2000 to 2004. 3. INTERNATIONAL CONVENTION AND STANDARDS FOR WORKING WITH ASBESTOS 3.1. International Convention The International Labor Organization (ILO) established an Asbestos Convention (C162) in 1986 to promote national laws and regulations for the “prevention and control of, and protection of workers against, health hazards due to occupational exposure to asbestos.”17 The convention outlines aspects of best practice: Scope and Definitions, General Principles, Protective and Preventive Measures, Surveillance of the Working Environment, and Workers’ Health. As of March 4, 2008, 31 countries had ratified the Convention;18 17 of them have banned asbestos. Some of the ILO asbestos convention requirements:

• work clothing to be provided by employers; • double changing rooms and wash facilities to prevent dust from going home on street

clothes; • training of workers about the health hazards to themselves and their families; • periodic medical examinations of workers, • periodic air monitoring of the work environment, with records retained for 30 years; • development of a work plan prior to demolition work, to protect workers and provide for

proper waste disposal; and • protection from “retaliatory and disciplinary measures” of workers who remove

themselves from work that they are justified in believing presents a serious danger to health.

Standard considerations for working with and procuring ACM are common to most projects. An overview of some basic ones is provided in Appendix 5. 3.2. International Standards and National Regulations Standards and regulations for work involving ACM have been published by nongovernmental organizations and government agencies. Appendix 3 provides a listing of some resources, including international organizations (e.g., WHO, ISO, ASTM) and national governments (e.g., UK, US, Canada, South Africa). The resources range from manuals to individual standards and cover a variety of work guidelines, including surveys, identification, inspection, maintenance, renovation, repair, removal, and disposal. Some of the key issues discussed in these standards and regulations are as follows: European Conference on Asbestos Risks and Management, Rome, Italy, December 4 -6, 2006. http://venus.unive.it/fall/menu/Boer.pdf 16 R. Virta, US Geological Survey, 2007. 17 www.ilo.org/ilolex 18 http://www.ilo.org/ilolex/english/convdisp1.htm

http://www.ilo.org/ilolex

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The scale of occupational hazards. The health risk is not simply a function of the properties

of the ACM, but also reflects the type of work being done and the controls used. Although A-C products, for example, may seem to intrinsically present less of a risk than fire-proofing, air monitoring has shown that cutting dry A-C sheet with a power saw can release far greater amounts of airborne fibers than scraping wet, saturated fireproofing off a beam. The relationship between the nature of A-C products, the work being done and the controls used to control the release of fibers and debris is important (as discussed in ASTM E2394 and HSG189/219).

Controlling exposure to airborne fibers. Because asbestos fibers are primarily an

inhalation hazard, the basic purpose of the regulations and standards is to control the concentration of asbestos fibers in the air inhaled by workers or others. Concentration limits have been set by regulations in numerous countries for workers whose duties involve contact with ACM; however, they do not purport to totally eliminate the risk of asbestos disease, but only to reduce it. Exposure limits for individuals other than workers, including occupants of buildings and facilities and the community, are lower than those for workers in deference to the very young and old as well as the physically compromised.

Measuring exposure to airborne fibers. Compliance with exposure limits is demonstrated

by air sampling in workers’ breathing zone or in the space occupied by the affected individuals, with analysis of the sample by optical or electron microscopy, as explained in Appendix 3. Abatement protocols determine whether a building can be reoccupied after asbestos abatement.

Proper disposal. Proper disposal of ACM is important not only to protect the community

and environment but also to prevent scavenging and reuse of removed material. ACM should be transported in leak-tight containers to a secure landfill operated in a manner that precludes air and water contamination that could result from ruptured containers. Similar requirements apply to remediation of sites such as mines, mills, and factories where asbestos fiber was processed and products manufactured. (See EPA NESHAP regulations, Appendix 3.)

Transboundary movement of waste. Waste asbestos (dust and fibers) is considered a

hazardous waste under the Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal. The Basel Convention imposes use of a prior informed consent procedure for movement of such wastes across international borders. Shipments made without consent are illegal. Parties have to ensure that hazardous waste is disposed of in an environmentally sound manner (ESM. Strong controls have to be applied from the moment of generation, to its storage, transport, treatment, reuse, recycling, recovery and final disposal20

Identifying asbestos products. A-C products include flat panels, corrugated panels used for

roofing, water storage tanks, and pressure, water, and sewer pipes. In some countries asbestos 19 See Appendix 3. 20 See Basel Convention Secretariat http://www.basel.int/

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may still be used in making wallboard, heat-resistant gloves and clothes for industrial use, and brake and clutch friction elements and gaskets used in vehicles.21 Thermal insulation containing asbestos and sprayed asbestos for insulation and acoustic damping were widely used through the 1970s and should be looked for in any project involving boilers and insulated pipes. Insulation dating from before 1980 should be presumed to contain asbestos unless analyzed and found not to. The microscopic methodology for analyzing bulk samples for the presence of asbestos is widely available in industrialized countries and is not expensive; it is less available in developing countries. In a developing country samples may have to be mailed out for testing; alternatively, training may be available for a laboratory in the country.

Training. It is impossible to overemphasize the importance of training for working with

ACM in any capacity—whether it involves inspections, maintenance, removal, or laboratory analysis. The duration of the training as well as the course content depends on the type of work the individual will be doing. Quality control and proficiency testing for laboratories and individual analysts are also important.

4. ALTERNATIVES TO ASBESTOS-CONTAINING MATERIALS 4.1. Growing Marketplace Safer substitutes for asbestos products of all kinds are increasingly available (see Appendix 4). These include fiber-cement products using combinations of local vegetable fibers and synthetic fibers, as well as other products that serve the same purposes.22 The WHO is actively involved in evaluating alternatives.23 4.2. Cost and Performance Issues Fiber-cement roof panels using polyvinyl alcohol (PVA) or polypropylene combined with cellulose now cost 10-15% more to manufacture than A-C sheets. Polypropylene-cellulose-cement roofing, a new product, is made at a cost of about 12 percent more than A-C roofing and has superior impact resistance. The non-asbestos fiber-cement panels are lighter, less brittle, and have improved nailability over A-C. The increase in the overall cost of building construction that such products represent is to some degree offset by the obviation of special hygiene measures in installation/maintenance/renovation, the lack of a continuing hazard to building workers and occupants, and reduced costs of waste removal and disposal. Micro concrete tiles are cheaper than A-C to produce, and can be made in a basic workshop near the building site with locally available small contractors and materials, lowering transport costs. Compared with A-C pipes, iron pipes can be transported and installed with less difficulty and breakage, take greater compression loading and last longer. 21 In 2004, Russia, China, India, Kazakhstan, Thailand, and Ukraine together accounted for about three-quarters of world asbestos consumption. Other major consumers of asbestos are Iran, Brazil, Vietnam, and Indonesia. 22 7. The U.K. Health and Safety Executive commissioned a report that concluded that the main replacement fibrous materials for asbestos in fiber-cement products and brakes are less hazardous than chrysotile asbestos. See Harrison PTC, et al. “Comparative Hazards of Chrysotile Asbestos and Its Substitutes: A European Perspective.” Envir. Health Persp. 107: 607-611 (1999). http://www.ehponline.org/members/1999/107p607-611harrison/harrison-full.html 23 http://www.who.int/ipcs/assessment/asbestos/en/

http://www.ehponline.org/members/1999/107p607-611harrison/harrison-full.html

http://www.ehponline.org/members/1999/107p607-611harrison/harrison-full.html

7

5. WORLD BANK GROUP APPROACH TO ASBESTOS HEALTH RISK The WBG EHS Guidelines are technical reference documents with general and industry-specific examples of Good International Industry Practice (GIIP).24 When one or more members of the WBG are involved in a project, the EHS Guidelines are applied as required by their respective policies and standards. The WBG’s EHS Guidelines25 specify that the use of ACM should be avoided in new buildings and construction or as a new material in remodeling or renovation activities. Existing facilities with ACM should develop an asbestos management plan that clearly identifies the locations where the ACM is present, its condition (e.g., whether it is in friable form or has the potential to release fibers), procedures for monitoring its condition, procedures to access the locations where ACM is present to avoid damage, and training of staff who can potentially come into contact with the material to avoid damage and prevent exposure. The plan should be made available to all persons involved in operations and maintenance activities. Repair or removal and disposal of existing ACM in buildings should be performed only by specially trained personnel26 following host country requirements or, if the country does not have its own requirements, internationally recognized procedures.27 Decommissioning sites may also pose a risk of exposure to asbestos that should be prevented by using specially trained personnel to identify and carefully remove asbestos insulation and structural building elements before dismantling or demolition.28

24 Defined as the exercise of professional skill, diligence, prudence, and foresight that would be reasonably expected from skilled and experienced professionals engaged in the same type of undertaking under the same or similar circumstances globally. The circumstances that skilled and experienced professionals may find when evaluating the range of pollution prevention and control techniques available to a project may include, but are not limited to, varying levels of environmental degradation and environmental assimilative capacity as well as varying levels of financial and technical feasibility 25 http://www.ifc.org/ifcext/enviro.nsf/AttachmentsByTitle/gui_EHSGuidelines2007_GeneralEHS/$FILE/Final+-+General+EHS+Guidelines.pdf (pp. 71, 91, 94) 26 Training of specialized personnel and the maintenance and removal methods applied should be equivalent to those required under applicable regulations in the United States and Europe (examples of North American training standards are available at: http://www.osha.gov/SLTC/asbestos/training.html) 27 Examples include the ASTM International E1368 - Standard Practice for Visual Inspection of Asbestos Abatement Projects; E2356 - Standard Practice for Comprehensive Building Asbestos Surveys; and E2394 - Standard Practice for Maintenance, Renovation and Repair of Installed Asbestos Cement Products. 28 http://www.ifc.org/ifcext/enviro.nsf/AttachmentsByTitle/gui_EHSGuidelines2007_GeneralEHS/$FILE/Final+-+General+EHS+Guidelines.pdf (pp. 71, 91, 94)



http://www.osha.gov/SLTC/asbestos/training.html



8

APPENDIX 1. COUNTRIES THAT HAVE BANNED THE USE OF ASBESTOS

1. Argentina 2. Australia 3. Austria 4. Belgium 5. Bulgaria 6. Chile 7. Cyprus 8. Czech Republic 9. Denmark 10. Egypt 11. Estonia 12. Finland 13. France 14. Gabon 15. Germany 16. Greece 17. Honduras 18. Hungary 19. Iceland 20. Ireland 21. Italy 22. Japan 23. Jordan 24. Kuwait 25. Latvia 26. Lithuania 27. Luxembourg 28. Malta 29. Netherlands 30. Norway 31. Poland 32. Portugal 33. Republic of Korea 34. Romania 35. Saudi Arabia 36. Seychelles 37. Slovakia 38. Slovenia 39. South Africa 40. Spain 41. Sweden 42. Switzerland 43. United Kingdom 44. Uruguay

9

APPENDIX 2. WORLD BANK GROUP ASBESTOS REFERENCES

Policy guidance References ACM should be avoided in new buildings or as new material in remodeling or renovation • Existing buildings: ACM Survey and

management plan needed • Disposal of ACM shall be carried out by

specially trained individuals only following host country requirements, or in their absence, internationally recognized procedures

Guidance: General Environment Health and Safety Guidelines April 2007, p 34 and 71.

Some examples of project requirements: • risk assessment to determine extent of

problem; surveys to abate asbestos exposure; management plan; removal by trained personnel; prohibition of ACM; procedures for handling, removal, transport, and disposal of asbestos.

• Ukraine -Equal Access to Quality Education (Project ID PO77738)

• KH- Health Sector Support (Project ID: P070542)

• ID- Health Workforce and Services (Project. ID: P073772)

• Changchun, China -TBK Shili Auto Parts Co., (IFC, 2005)

10

APPENDIX 3. LIST OF RESOURCES FOR ASBESTOS STANDARDS AND REGULATIONS NOTE: this listing is not meant to be all-inclusive, but is a sample of available information.

INTERNATIONAL STANDARDS WHO Policy and Guidelines (www.who.org) www.searo.who.int/LinkFiles/Publications_and_Documents_prevention_guidelines.pdf(p. 70) www.searo.who.int/en/Section23/Section1108/Section1835/Section1864_8658.htm

International Organization for Standardization (ISO) (www.iso.org) ISO 10312 (1995): Ambient air -- Determination of asbestos fibres -- Direct transfer

transmission electron microscopy method. [Method similar to ASTM D6281] ISO 13794 (1999): Ambient air – Determination of asbestos fibres – Indirect-transfer

transmission electron microscopy method. ISO/FDIS 16000-7: Indoor air – Part 7: Sampling strategy for determination of airborne

asbestos fibre concentrations. ISO 8672: Air quality -- Determination of the number concentration of airborne inorganic

fibres by phase contrast optical microscopy -- Membrane filter method (1993) [Method similar to AIA RTM1]

Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal Basel Convention Secretariat (www.basel.int)

International Labour Organization (www.ilo.org) Chemical Safety Card, ICSC 0014:

www.ilo.org/public/english/protection/safework/cis/products/icsc/dtasht/_icsc00/icsc0014.htm European Union (europa.eu.int/smartapi/cgi/sga_doc?smartapi!celexapi!prod!CELEXnumdoc&lg=EN&numdoc=32003L0018&model=guichett) Directive 2003/18/EC amending Council Directive 83/477/EEC on the Protection of Workers

from the Risks Related to Exposure to Asbestos at Work. (March 2003). Provides regulations including: worker protection, training and medical surveillance; inspections for asbestos-containing materials; notification of asbestos work; air sampling; exposure limits of 0,1 fibres per cm³ (8-hr TWA) measured by Phase Contrast Microscopy.

NATIONAL STANDARDS ASTM International (www.astm.org) Manual on Asbestos Control: Surveys, Removal and Management – Second Edition (March

2005). Author: Andrew F. Oberta, MPH, CIH. Discusses in detail how E2356, E2394 and E1368 are used to support an asbestos management program.

E2356 Standard Practice for Comprehensive Building Asbestos Surveys. July, 2004. Covers baseline surveys for management of ACM and includes assessment protocols to make and prioritize removal vs. maintenance decisions. ASTM E2356 provides information for long-term management of ACM in a Baseline Survey and for preparation of the plans and specifications for a removal project. It contains detailed procedures and equipment (mostly ordinary hardware items) needed to take bulk samples of common types of suspect ACM. Once materials have been identified as asbestos-containing, an assessment is made as to which can be left in place. Quantitative assessment of the Current Condition and Potential for

http://www.searo.who.int/LinkFiles/Publications_and_Documents_prevention_guidelines.pdf

http://europa.eu.int/smartapi/cgi/sga_doc?smartapi!celexapi!prod

11

Disturbance of all friable and non-friable materials allows removal priorities to be tabulated and graphically displayed. Budgetary estimates for removal can be established on the basis of the quantitative assessments.

E2394 Standard Practice for Maintenance, Renovation and Repair of Installed Asbestos Cement Products (October 2004). Describes materials, hazardous operations, necessary precautions and infrastructure requirements with detailed procedures in appendices. Not intended for installation of asbestos-cement products in new construction or renovation.

E1368 Standard Practice for Visual Inspection of Asbestos Abatement Projects (May 2005). Provides an approach to managing a removal project to enhance prospects of passing final inspections and clearance air sampling. Describes preparation, removal and inspection procedures and criteria.

E2308 Standard Guide on Limited Asbestos Screens of Buildings (2005). Provides the minimum amount of information needed to facilitate a real estate transaction.

D6281 Standard Test Method for Airborne Asbestos Concentration in Ambient and Indoor Atmospheres as Determined by Transmission Electron Microscopy Direct Transfer (TEM). A method for distinguishing asbestos from non-asbestos fibers on an air sample filter and identifying and quantifying smaller and thinner fibers than Phase Contrast Microscopy

D7201: Practice for Sampling and Counting Airborne Fibers, Including Asbestos Fibers, in the Workplace, by Phase Contrast Microscopy (with an Option of Transmission Electron Microscopy)

Combines methodology of NIOSH 7400 and 7402 Australia (www.ascc.gov.au/ascc/AboutUs/Publications/NationalStandards/ListofNationalCodesofPractice.htm) • Safe Removal of Asbestos 2nd edition [NOHSC: 2002 (2005)] • Code of Practice for the Management and Control of Asbestos in the Workplace [NOHSC:

2018 (2005)] U. K. Health and Safety Executive (http://www.hse.gov.uk/asbestos/index.htm) Asbestos Regulations (http://www.opsi.gov.uk/si/si2006/20062739.htm) Asbestos Essentials (http://www.hse.gov.uk/asbestos/essentials/index.htm). Includes sections

on manager Tasks and methods and equipment. Publications include: Working with Asbestos in Buildings INDG289 08/01 C600. An overview (16 pages) of

asbestos hazards and precautions MDHS100 Surveying, sampling and assessment of asbestos containing materials (2001).

Contains many illustrations and examples of asbestos-containing products as well as sampling and analytical methods. MDHS100 is comparable in thoroughness to ASTM in its discussion of bulk sampling techniques and equipment, organizing a survey and assessment of ACM using a numerical algorithm based on the product type, extent of damage, surface treatment and type of asbestos fiber. The document contains numerous photographs of typical ACM found in buildings.

HSG189/2 Working with asbestos cement (1999). Describes asbestos-cement products and methods of repairing and removing them, including fiber concentrations for controlled and uncontrolled operations.

The Control of Asbestos at Work Regulations (2002). Requirements for the protection of

http://www.ascc.gov.au/ascc/AboutUs/Publications/NationalStandards/ListofNationalCodesofPractice.htm

http://www.ascc.gov.au/ascc/AboutUs/Publications/NationalStandards/ListofNationalCodesofPractice.htm

http://www.hse.gov.uk/asbestos/essentials/index.htm

12

people being exposed to asbestos, including the requirement for those with responsibility for the maintenance and/or repair of non-domestic premises, to identify and manage any risk from asbestos within their premises

National Institute of Building Sciences (http://www.nibs.org/pubsasb.html) Guidance Manual: Asbestos O&M Work Practices, Second Edition (1996). Contains

procedures for small-scale work on friable and non-friable ACM including asbestos-cement products.

Asbestos Abatement and Management in Buildings: Model Guide Specification. Third Edition (1996). Contains information on project design and surveillance as well as applicable US regulations, plus removal contractor requirements for abatement work in specification format.

Austrian Standards Institute (http://www.on-norm.at/index_e.html) ONORM M 9406, Handling of products containing weakly bound asbestos, 01 08 2001. Contains a protocol and algorithm for assessing the condition and potential fiber release from friable asbestos-containing materials. International Chrysotile Association (www.chrysotile.com). [Please note this organization represents asbestos industries and businesses] Recommended Technical Method No. 1 (RTM1), Reference Method for the determination of

Airborne Asbestos Fibre Concentrations at workplaces by light microscopy (Membrane Filter Method). Method using Phase Contrast Microscopy for counting fibers on an air sampling filter that does not distinguish asbestos from other fibers

Recommended Technical Method No. 2 (RTM2) Method for the determination of Airborne Asbestos Fibres and Other Inorganic Fibres by Scanning Electron Microscopy. Method that identifies smaller fibers than Phase Contrast Microscopy and can distinguish types of asbestos fibers.

U.S. National Institute for Occupational Safety and Health (www.cdc.gov/niosh/topics/asbestos) Occupational Safety and Health Guidelines for Asbestos (www.cdc.gov/niosh/pdfs/0041.pdf) Recommendations for Preventing Occupational Exposure

(www.cdc.gov/niosh/topics/asbestos/#prevention) Method 7400, Asbestos and other fibers by PCM (1994).Phase Contrast Microscopy method

similar to AIA RTM1 that counts all fibers greater than 5µm long with a 3:1 aspect ratio Method 7402 Asbestos by TEM (1994). Method using Transmission Electron Microscopy that

identifies and counts asbestos fibers greater than 5µm long and greater than 0.25µm in diameter with a 3:1 aspect ratio

U.S. Environmental Protection Agency (www.epa.gov/asbestos) Resources include managing asbestos-containing materials in buildings, schools, and the

automotive industry. Includes procedures for inspection, analysis of bulk samples, assessment of friable ACBM, response actions (removal, encapsulation, enclosure), Operations and Maintenance, and clearance air sampling.

National Emission Standards for Hazardous Air Pollutants: Subpart M - Asbestos. 40 CFR Part 61. (1990). Regulations include: definitions of friable and non-friable asbestos-containing materials; notification requirements for renovation and demolition of buildings and facilities containing ACM; work practices to prevent visible emissions; disposal of ACM and waste material in approved landfills; and operation and closure of landfills.

20T-2003 Managing Asbestos in Place: A Building Owner’s Guide to Operations and Maintenance Programs for Asbestos-Containing Materials “Green book” (1990)

http://www.chrysotile.com/

13

Guidance document covering: organizing an Operations and Maintenance (O&M) program including training O&M workers; recognizing types of O&M; work practices and precautions for O&M work.

EPA-600/R-93/116 Method for the Determination of Asbestos in Bulk Building Materials (1993) Polarized Light Microscopy, Gravimetry, X-ray diffraction and Transmission Electron Microscopy methods of identifying and quantifying asbestos fibers in bulk building materials. The identification of materials as containing asbestos is done by analysis of bulk samples, usually with Polarized Light Microscopy. The analytical procedures described and the equipment to perform the analyses is similar to that found in academic or commercial geology laboratories, but specialized training to identify and quantify asbestos fibers in bulk building materials is needed as well as quality control and proficiency testing programs.

Polarized Light Microscopy, Gravimetry, X-ray diffraction and Transmission Electron Microscopy methods of identifying and quantifying asbestos fibers in bulk building materials

U. S. Occupational Safety and Health Administration (Department of Labor) (www.osha.gov/SLTC/asbestos) / (www.osha.gov/SLTC/asbestos/standards.html) Occupational Exposure to Asbestos (Construction Industry Standard) 29CFR1926.1101.

(1994). Regulations for: Permissible Exposure Limits of 0.1 f/cc over a full shift (8 hr time-weighted average) and short-term exposure limit of 1.0 f/ml for 30 minutes; employee exposure monitoring for compliance with the PELs; work practices for friable and non-friable ACM; respiratory protection; worker decontamination and hygiene facilities; notification of employees and other employers of employees; medical surveillance; record-keeping and training.

OSHA Method ID 160 Asbestos in Air (1994). Phase Contrast Microscopy method similar to NIOSH 7400

Ontario Ministry of Labour (Canada) (www.e-laws.gov.on.ca/DBLaws/Source/Regs/English/2005/R05278_e.htm) Ontario regulation 278/05 Designated Substance — asbestos on construction projects and in

buildings and repair operations (2005). Regulations covering: respiratory protection and work procedures; inspections for asbestos; management of friable and non-friable asbestos; advance written notice; asbestos bulk sampling and analysis; glove bag requirements and procedures; negative air enclosures; and clearance air testing requirements (0.01 f/cc by Phase Contrast Microscopy).

WorkSafe British Columbia (Canada) (www2.worksafebc.com/publications/OHSRegulation/Part6.asp) Part 6 Substance Specific Requirements: Asbestos. Regulations covering: identification of

asbestos-containing materials; substitution with non-asbestos materials; worker training; exposure monitoring; containment and ventilation of work areas; work practices; decontamination; respirators and protective clothing.

Republic of South Africa, Department of Labour (www.acts.co.za/ohs/index.htm - type ‘asbestos’ in search box) Occupational Health and Safety Act, 1993; Asbestos Regulations, 2001.Regulations covering:

notification; assessment and control of exposure; Occupational Exposure Limit of 0.2 f/cc - 4 hr TWA measured by Phase Contrast Microscopy; training; air monitoring; medical surveillance; non-employee exposure; respirators, personal protective equipment and facilities; asbestos building materials including asbestos cement sheeting and related products; disposal.

http://www.e-laws.gov.on.ca/DBLaws/Source/Regs/English/2005/R05278_e.htm

http://www.acts.co.za/ohs/index.htm

14

APPENDIX 4. SOME ALTERNATIVES TO ASBESTOS-CONTAINING PRODUCTS Asbestos product Substitute products Asbestos-cement corrugated roofing

Fiber-cement roofing using synthetic fibers (polyvinyl alcohol, polypropylene) and vegetable/cellulose fibers (softwood kraft pulp, bamboo, sisal, coir, rattan shavings and tobacco stalks, etc.); with optional silica fume, fly ash, or rice husk ash. Microconcrete (Parry) tiles; galvanized metal sheets; clay tiles; vegetable fibers in asphalt; slate; coated metal tiles (Harveytile); aluminum roof tiles (Dekra Tile); extruded uPVC roofing sheets; recycled polypropylene and high-density polyethylene and crushed stone (Worldroof); plastic coated aluminum; plastic coated galvanized steel.

Asbestos-cement flat sheet (ceilings, facades, partitions)

Fiber-cement using vegetable/cellulose fibers (see above), wastepaper, optionally synthetic fibers; gypsum ceiling boards (BHP Gypsum); polystyrene ceilings, cornices, and partitions; façade applications in polystyrene structural walls (coated with plaster); aluminum cladding (Alucabond); brick; galvanized frame with plaster-board or calcium silicate board facing; softwood frame with plasterboard or calcium silicate board facing.

Asbestos-cement pipe

High pressure: Cast iron and ductile iron pipe; high-density polyethylene pipe; polyvinyl chloride pipe; steel-reinforced concrete pipe (large sizes); glass-reinforced polyester pipe. Low pressure: Cellulose-cement pipe; cellulose/PVA fiber-cement pipe; clay pipe; glass-reinforced polyester pipe; steel-reinforced concrete pipe (large diameter drainage).

Asbestos-cement water storage tanks

Cellulose-cement; polyethylene; fiberglass; steel; galvanized iron; PVA-cellulose fiber-cement

Asbestos-cement rainwater gutters; open drains (mining industry)

Galvanized iron; aluminum; hand-molded cellulose-cement; PVC

15

APPENDIX 5. CONSIDERATIONS FOR WORKING WITH ASBESTOS MATERIALS IN EXISTING STRUCTURES A. Evaluation of alternatives 1. Determine if the project could include the installation, replacement, maintenance or demolition of: • Roofing, siding, ducts or wallboard • Thermal insulation on pipes, boilers, and ducts • Plaster or fireproofing • Resilient flooring materials • Other potentially asbestos-containing materials 2. If the use of asbestos-containing materials (ACM) has been anticipated for new construction or renovation, provide information about alternative non-asbestos materials and their availability. For new construction, determine the expected difference for the entire project—on initial and operating costs, employment, quality, expected service life, and other factors—using alternatives to ACM (including consideration of the need for imported raw materials). 3. In many cases, it can be presumed that ACM are part of the existing infrastructure that must be disturbed. If there is a need to analyze samples of existing material to see if it contains asbestos, provide information on how and where can that be arranged. 4. Once the presence of ACM in the existing infrastructure has been presumed or confirmed and their disturbance is shown to be unavoidable, incorporate the following requirements in tenders for construction work in compliance with applicable laws and regulations. B. Understanding the regulatory framework 1. Review the host country laws and regulations and the international obligations it may have entered into (e.g., ILO, Basel conventions) for controlling worker and environmental exposure to asbestos in construction work and waste disposal where ACM are present. Determine how the qualifications of contractors and workers who maintain and remove ACM are established, measured, and enforced. 2. Determine whether licensing and permitting of the work by authorities is required. 3. Review how removed ACM are to be disposed of to minimize the potential for pollution, scavenging, and reuse. 4. Incorporate the following requirements in tenders involving removal, repair, and disposal of ACM.

16

C. Considerations and possible operational requirements related to works involving asbestos 1. Contractor qualification • Require that contractors demonstrate having experience and capability to observe

international good practice standards with asbestos, including training of workers and supervisors, possession of (or means of access to) adequate equipment and supplies for the scope of envisioned works, and a record of compliance with regulations on previous work.

2. Related to the technical requirements for the works • Require that the removal, repair, and disposal of ACM shall be carried out in a way that

minimizes worker and community asbestos exposure, and require the selected contractor to develop and submit a plan, subject to the engineer’s acceptance, before doing so.

• Describe the work in detail in plans and specifications prepared for the specific site and

project, including but not limited to the following: - Containment of interior areas where removal will occur in a negative pressure enclosure; - Protection of walls, floors, and other surfaces with plastic sheeting; - Construction of decontamination facilities for workers and equipment; - Removing the ACM using wet methods, and promptly placing the material in impermeable containers; - Final clean-up with special vacuums and dismantling of the enclosure and decontamination facilities; - Disposal of the removed ACM and contaminated materials in an approved landfill;29 - Inspection and air monitoring as the work progresses, as well as final air sampling for clearance, by an entity independent of the contractor removing the ACM.

• Other requirements for specific types of ACM, configurations and characteristics of buildings or facilities, and other factors affecting the work shall be enumerated in the plans and specifications. Applicable regulations and consensus standards shall be specifically enumerated.

3. Related to the contract clauses30

• Require that the selected contractor provide adequate protection to its personnel handling

asbestos, including respirators and disposable clothing. 29 Alternative guidance for circumstances where approved landfills are not available for disposal of hazardous substances, such as asbestos, guidance is provided in the EHS General Guideline, reference above as well as in the Guideline on Waste Management Facilities. http://www.ifc.org/ifcext/sustainability.nsf/AttachmentsByTitle/gui_EHSGuidelines2007_WasteManagement/$FILE/Final+-+Waste+Management+Facilities.pdf 30 Standard contract clauses for asbestos work exist but are too extensive for this short note. To view an example, the U.S. National Institute of Building Sciences “Asbestos Abatement and Management in Buildings: Model Guide Specification” has a complete set – in copyright form – and the clauses and instructions for using them fill a two-inch binder.

17

• Require that the selected contractor notifies the relevant authorities of the removal and

disposal according to applicable regulations as indicated in the technical requirements and cooperates fully with representatives of the relevant agency during all inspections and inquiries.

4. Related to training and capacity building • Determine whether specialist industrial hygiene expertise should be hired to assure that local

contractors learn about and apply proper protective measures in work with ACM in existing structures.

Originator: World Bank, Operations Policy and Country Services


Page 98 of 111

Annex XII World Bank Group EHS Guidelines for Fish Processing

Environmental, Health, and Safety Guidelines

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WORLD BANK GROUP

Environmental, Health, and Safety Guidelines for Fish Processing

Introduction The Environmental, Health, and Safety (EHS) Guidelines are

technical reference documents with general and industry-

specific examples of Good International Industry Practice

(GIIP) 1. When one or more members of the World Bank Group

are involved in a project, these EHS Guidelines are applied as

required by their respective policies and standards. These

industry sector EHS guidelines are designed to be used

together with the General EHS Guidelines document, which

provides guidance to users on common EHS issues potentially

applicable to all industry sectors. For complex projects, use of

multiple industry-sector guidelines may be necessary. A

complete list of industry-sector guidelines can be found at:

www.ifc.org/ifcext/enviro.nsf/Content/EnvironmentalGuidelines

The EHS Guidelines contain the performance levels and

measures that are generally considered to be achievable in new

facilities by existing technology at reasonable costs. Application

of the EHS Guidelines to existing facilities may involve the

establishment of site-specific targets, with an appropriate

timetable for achieving them. The applicability of the EHS

Guidelines should be tailored to the hazards and risks

established for each project on the basis of the results of an

environmental assessment in which site-specific variables, such

as host country context, assimilative capacity of the

environment, and other project factors, are taken into account.

1 Defined as the exercise of professional skill, diligence, prudence and foresight that would be reasonably expected from skilled and experienced professionals engaged in the same type of undertaking under the same or similar circumstances globally. The circumstances that skilled and experienced professionals may find when evaluating the range of pollution prevention and control techniques available to a project may include, but are not limited to, varying levels of environmental degradation and environmental assimilative capacity as well as varying levels of financial and technical feasibility.

The applicability of specific technical recommendations should

be based on the professional opinion of qualified and

experienced persons. When host country regulations differ from

the levels and measures presented in the EHS Guidelines,

projects are expected to achieve whichever is more stringent. If

less stringent levels or measures than those provided in these

EHS Guidelines are appropriate, in view of specific project

circumstances, a full and detailed justification for any proposed

alternatives is needed as part of the site-specific environmental

assessment. This justification should demonstrate that the

choice for any alternate performance levels is protective of

human health and the environment.

Applicability

The EHS Guidelines for Fish Processing include information

relevant to fish processing facilities, including the post-harvest

processing of fish, crustaceans, gastropods, cephalopods, and

bivalves (hereafter referred to as “fish products”), originating

from sea or freshwater catch or from farming operations in fresh

or salt water. This document does not cover primary fishery

activities2, or the production of fish in aquaculture. The latter is

covered in the EHS Guidelines for Aquaculture. This document

is organized according to the following sections:

Section 1.0 — Industry-Specific Impacts and Management Section 2.0 — Performance Indicators and Monitoring Section 3.0 — References and Additional Sources Annex A — General Description of Industry Activities

2 Overexploitation of fish stocks is a significant global issue. It is not addressed in this document, however, before a fish processing plant is established, the raw material supply situation should be considered, particularly with respect to the sustainability of the resources that will be the main input. Annex B provides a brief discussion of sustainable fishing principles and good practices.


FISH PROCESSING

APRIL 30, 2007 2

WORLD BANK GROUP

1.0 Industry-Specific Impacts and Management

The following section provides a summary of EHS issues

associated with fish processing which occur during the

operational phase, along with recommendations for their

management. Recommendations for the management of EHS

issues common to most large industrial facilities during the

construction and decommissioning phases are provided in the

General EHS Guidelines.

1.1 Environment

Environmental issues in fish processing projects primarily

include the following:

• Solid waste and by-products

• Wastewater

• Water consumption and management

• Emissions to air and energy consumption

Solid Waste and By-products Fish processing activities generate potentially large quantities of

organic waste and by-products from inedible fish parts and

endoskeleton shell parts from the crustacean peeling process.

The actual proportion depends on the edible fraction of each

species being processed. Fish waste is a rich source of

essential amino acids, and all inedible fish waste should be

converted into by-products (e.g. fishmeal or silage).

Recommended prevention and control techniques to reduce the

amount of solid waste include the following:

• Encourage fishing vessels to reduce the capture of “non-

target species” to reduce the amount of waste in the by-

product line;

• Design fish processing operations to enable the recovery of

waste streams in accordance with Good Manufacturing

Practice (GMP) and Hazard Analysis and Critical Control

Points (HACCP) food safety programs;

• Where feasible, reprocess waste into commercial by-

products.3 Off-cuts and wastes should be recovered and

taken to the by-product facility in time to prevent product

deterioration. Internal organs, blood, endoskeleton parts,

and any by-catch can be reprocessed into fish meal and

fish oil. In cases in which reprocessing for fish meal or oil

production is not an option, consider the lower-cost option

of production of fish silage;4

• Wastewater from fish meal plants often contains high levels

of proteins and oils, which makes the recovery financially

feasible. Consequently, most fish meal factories now have

stick-water evaporation plants, where the liquid fraction

after the press is evaporated and the proteins recovered.

Sludge Treatment and Disposal

The following measures reduce the volume of disposable waste

generated from waste and wastewater treatment processes:

• Sludge dewatering on sludge drying beds for small-scale

factories and dewatering using belt presses and decanter

centrifuges for medium and large-scale factories;

• Land application (as fertilizer) of wastes from on-site

wastewater treatment in agricultural production;

• Pathogens can be destroyed during controlled anaerobic

digestion (biogas) or aerobic treatment (composting);

• Disposal of wastes in landfill if not used for biogas

production or combustion.

3 Processing plants often outsource by-product processing to specialized companies that further process the waste into a dedicated fish meal product or produce other feed products for animals (e.g., mink fodder or fish silage). 4 Fish silage is a product derived from the liquefaction of whole fish or parts of fish through the action of enzymes in the fish and additional acids. Silage can be used for applications similar to those of fishmeal.


FISH PROCESSING

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Wastewater

Industrial Process Wastewater

Fish processing requires large amounts of water, primarily for

washing and cleaning purposes, but also as media for storage

and refrigeration of fish products before and during processing.

In addition, water is an important lubricant and transport medium

in the various handling and processing steps of bulk fish

processing. Fish processing wastewater has a high organic

content, and subsequently a high biochemical oxygen demand

(BOD), because of the presence of blood, tissue, and dissolved

protein. It also typically has a high content of nitrogen

(especially if blood is present) and phosphorus.

Detergents and disinfectants may also be present in the

wastewater stream after application during facility cleaning

activities. A range of chemicals is typically used for cleaning,

including acid, alkaline, and neutral detergents, as well as

disinfectants. The disinfectants commonly used include chlorine

compounds, hydrogen peroxide, and formaldehyde. Other

compounds also may be used for select activities (e.g.

disinfection of fishmeal processing equipment).

The following recommended methods may be used to enhance

the removal of solid waste prior to entry into the wastewater

stream:

• Collect internal organs and other organic materials

separately, for processing into by-products according to the

recommendations for solid waste management above;

• Design the production line so that cooling water, storm

water, and process effluents can be kept separate to permit

appropriate treatment options;

• Conduct a dry precleaning of equipment and production

areas before wet cleaning (e.g. rubber scraping of work

tables and plant floor before hosing);

• Establish procedures for the dry removal of offal, using dry

vacuum systems where feasible;

• Fit and use floor drains and collection channels with grids

and screens, and / or traps, to reduce the amount of solids

entering the wastewater;

• Equip the outlets of wastewater channels with screens and

fat traps to recover and reduce the concentration of coarse

material and fat in the combined wastewater stream;

• Avoid submersion of open products (e.g. fillets) in water, as

soluble protein may leak out and enter the wastewater

effluent stream;

• Ensure that tanks are effectively bunded and provide

overfilling protection on bulk storage tanks;5

• Choose cleaning agents that do not have adverse impacts

on the environment in general, or on wastewater treatment

processes and sludge quality for agricultural application.

Optimize their use through correct dosage and application.

Avoid cleaners that contain active chlorine or prohibited,

banned, or restricted chemicals.

Process Wastewater Treatment

Techniques for treating industrial process wastewater in this

sector include grease traps, skimmers or oil water separators for

separation of floatable solids; flow and load equalization;

sedimentation for suspended solids reduction using clarifiers or

settling ponds; biological treatment, typically anaerobic (if high in

organic content) followed by aerobic treatment, for reduction of

soluble organic matter (BOD); biological nutrient removal for

reduction in nitrogen and phosphorus; chlorination of effluent

when disinfection is required; dewatering and disposal of

residuals; in some instances composting or land application of

wastewater treatment residuals of acceptable quality may be

possible. Additional engineering controls may be required to

contain and neutralize nuisance odors.

5 Irish EPA (1996).


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Management of industrial wastewater and examples of

treatment approaches are discussed in the General EHS

Guidelines. Through use of these technologies and good

practice techniques for wastewater management, facilities

should meet the Guideline Values for wastewater discharge as

indicated in the relevant table of Section 2 of this industry sector

document.

Other Wastewater Streams & Water Consumption

Guidance on the management of non-contaminated wastewater

from utility operations, non-contaminated stormwater, and

sanitary sewage is provided in the General EHS Guidelines.

Contaminated streams should be routed to the treatment system

for industrial process wastewater. Recommendations to reduce

water consumption, especially where it may be a limited natural

resource, are provided in the General EHS Guidelines. Specific

water consumption recommendations for fish processing

operations include the following:

• Use enough ice to secure product quality and match ice

production to requirements;

• Improve efficiency by concentrating activities or certain

processes on fewer days per week, if the facility or process

is not operated at full capacity;

• Improve the process lay out to facilitate cleaning and

eliminate wet transport of wastes, thereby minimizing water

consumption;

• Dry clean with a scraper or broom before cleaning with

water. Use efficient cleaning procedures as mentioned in

the section “Industrial Process Wastewater” section above;

• Avoid recycling contact process water. Recycling of cooling

water, rinse water, and wastewater for some specific

noncritical applications may be feasible as long as hygiene

considerations are observed.

Emissions to Air Odor is often the most significant form of air pollution in fish

processing. Major sources include storage sites for processing

waste, cooking by-products during fish meal production, fish

drying processes, and odor emitted during filling and emptying

of bulk tanks and silos. Fish quality may deteriorate under the

anaerobic conditions found in onboard storage on fishing

vessels and in the raw material silos of fish processing facilities.

This deterioration causes the formation of odorous compounds

such as ammonia, mercaptans, and hydrogen sulfide gas.

Odor Prevention

The following recommended measures should be undertaken to

prevent the generation of odor emissions:

• Avoid processing batches of raw material that are of

considerably lower than average quality; this will reduce

the odor components;

• Reduce the stock of raw materials, waste, and by-products

and store this stock for short periods of time only in a cold,

closed, well-ventilated place;

• Seal by-products in covered, leak-proof containers;

• Keep all working and storage areas clean and remove

waste products immediately from the production line;

• Empty and clean fat traps on a regular basis;

• Cover all transfer systems, wastewater canals, and waste-

water treatment facilities to reduce the escape of foul

odors.

Odor Control

The recommended odor control techniques in fish processing

include the following:

• Install condensers on all appropriate process equipment

(e.g., cookers and evaporators) to treat air emissions for

odor, including sulfides and mercaptans;


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• Install biofilters as the final method of air treatment and

acid scrubbers for ammonia removal ahead of the biofilter;

• Install cyclones and filtration (fabric filters normally are

adequate) to remove particulates;

• Reduce fugitive odor sources from open doors, open

windows, and general room ventilation through the use of

negative pressure-controlled ventilation systems.

Exhaust Gases

Exhaust gas emissions (carbon dioxide [CO2], nitrogen oxides

[NOX] and carbon monoxide [CO]) in the fish processing sector

result from the combustion of gas and fuel oil or diesel in

turbines, boilers, compressors and other engines for power and

heat generation. Guidance for the management of small

combustion source emissions with a capacity of up to 50

megawatt thermal (MWth), including air emission standards for

exhaust emissions, is provided in the General EHS Guidelines.

For combustion source emissions with a capacity of greater than

50 MWth refer to the EHS Guidelines for Thermal Power.

Particulates

Particulate emissions are generally not a serious problem in the

fish processing sector. The primary process source is the fish

smoking process, which is relevant if the gas from this process

is not treated effectively in the cleaning process. The

recommended control techniques for particulate emissions

during fish smoking include the following:

• Consider use of integrated smoking units with incineration

and heat recovery;

• Clean the kiln exhaust using filters, incinerators, and / or

wet scrubbers;

• Ensure that smoke from the fish processing process is

emitted from a stack of sufficient height;

• Transfer air emissions to the boiler house for use as the

supply air for the combustion process. This method

requires that the boiler house be located parallel to the

emission sources and that the capacity (supply air volume)

matches the need for combustion process air.

Energy Consumption and Management

Fish processing facilities use energy to produce hot water,

steam, and electricity for process and cleaning applications.

Electricity is used for electrical equipment, air conditioning,

cooling, freezing, and ice production. General recommendations

to obtain energy efficiency through reduced heat loss, improved

cooling efficiency, heat recovery, and increased utilization of

energy efficient equipment are discussed in the General EHS

Guidelines.

1.2 Occupational Health and Safety

Occupational health and safety issues that occur during the

operational phase of fish processing projects primarily include

the following:

• Physical hazards

• Biological hazards

• Lifting, carrying, and repetitive work injuries

• Exposure to chemicals

• Exposure to heat and cold

• Confined space

• Exposure to noise and vibrations

Physical hazards

Causes of accidents in fish processing operations include falls

caused by slippery floors and stairs; equipment safety issues

associated with filleting knives and other sharp tools; and cuts

from sharp edges on process equipment (e.g. stainless steel

basins). In addition to general recommendations included in the

General EHS Guidelines, the following are sector-specific

recommendations for accident prevention:


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• Provide workers with training in the proper use and

maintenance of cutting equipment (including the use of

machine safety devices, handling / storage and upkeep of

knives, and emergency shutoff procedures) and personal

protective equipment (e.g. metallic gloves and leather

aprons for cutting activities, and protective footwear with

rubber soles);

• Design the plant so that different activities and the flow of

processes do not cross. In addition, clearly demarcate

transport corridors and working areas; ensure that

handrails are provided on platforms, ladders, and stairs;

and use non-slip floor surfacing;

• Use completely enclosed conveyer belts to protect hands

and fingers.

Biological hazards Workers involved in manual gutting, skinning, and general

handling of fish and shellfish may develop infections and or

allergic reactions resulting from exposure to the fish itself, or

bacteria on the fish. Water spraying processes may result in the

formation of aerosols with bacteria that can be inhaled. In

addition to general recommendations included in the General

EHS Guidelines, the following are sector-specific

recommendations to prevent exposure to bacteria:

• Consider work rotation strategies to reduce occupational

exposure to allergens;

• Wear gloves to protect hands from exposure to products,

especially when working with seafood that is known to

create allergic reactions (e.g. scallops and shrimp).

Provide food-approved shielding hand creams;

• Avoid aerosol-generating activities (e.g. use of compressed

air or high-pressure water for cleaning). Where these

activities cannot be avoided, provide proper ventilation of

enclosed or semi-enclosed areas to reduce or eliminate

exposure to aerosols, in addition to adequate distances

between workers and aerosol-generating activities;

• Ensure physical segregation of work and personal facilities

to maintain worker personal hygiene.

Lifting, Carrying, and Repetitive Work Fish processing activities may include a variety of situations in

which workers can be exposed to lifting, carrying, repetitive

work, and work posture injuries. Many of the manual operations

in less mechanized fish processing plants include lifting heavy

boxes of raw materials. Repetitive strain injuries may result from

manual filleting and trimming operations. Poor working postures

may result from the design of the workspace, furniture,

machinery, and tools. Recommended prevention and control

measures for these activities are discussed in the General EHS

Guidelines.

Chemicals Exposure to chemicals (including gases and vapors) includes

handling chemicals such as chlorine, lye, and acids that are

related to cleaning operations and disinfection in process areas.

In fish smoking facilities, workers could be exposed to smoke

particles that contains potential or confirmed carcinogens such

as polycyclic aromatic hydrocarbons (PAHs).

Recommendations to prevent and control exposure to chemicals

are presented in the General EHS Guidelines. Additional,

industry-specific recommendations include:

• Avoid locating smoking kilns in the same rooms as

processing workers. Chimney exhaust systems should

ensure that smoke is not entering the processing factory.

Respiratory protection should be used when cleaning

smoke ovens;

• Ensure that employees handling concentrated lye, acid,

and chlorine wear protective clothing and eyewear.


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Heat and Cold Exposure to extreme heat and cold is common because fish

processing is often conducted in air-conditioned plants under

low temperature, even in tropical locations. Improper work

clothes in combination with stationary work locations can result,

or be an additional factor, in respiratory and musculoskeletal

ailments.

Recommendations for the management of exposure to heat and

cold include the following:

• Set the temperature in air-conditioned processing facilities,

where stationary manual work is conducted, at a level that

is appropriate according to temperature stress

management procedures as noted in the General EHS

Guidelines. Products awaiting the next processing step

can be kept chilled without lowering the ambient

temperature through proper use of ice, slush-ice, or water-

ice mixtures;

• Equip cold stores and chill stores with strip curtains to

avoid extensive drafts when doors are open. Ensure

freezers can be opened from the inside;

• Design air-conditioning systems for processing facilities in

conjunction with strip curtain placement to minimize drafts;

• Provide protective clothing in cold environments (e.g.

refrigerated storage rooms). Process workers should

always be equipped with proper working garments,

including dry boots;

• Reduce movement of processing workers between

different temperature zones (e.g. when packing frozen

products).

Confined Space Occupational health and safety impacts associated with

confined spaces in fish processing operations (e.g. storage

areas, boat holds) are common to most industries, and their

prevention and control are discussed in the General EHS

Guidelines.

Noise and Vibrations Noise and vibration exposure may result from proximity to noisy

machinery (e.g. compressors, automatic packing machinery,

condensers, ventilation units, and pressurized air).

Recommendations for noise management are discussed in the


1.3 Community Health and Safety

Community health and safety impacts during the planning and

operation phases of fish processing projects are similar to those

of most industrial facilities, and are discussed in the General

EHS Guidelines.

During the planning phase, the facility should be located at an

appropriate distance from neighbors and access roads should

be assessed for suitable transport use. Proximity to neighbors is

an important issue, especially for the management of odor and

waste issues in fish processing operations.

Community health and safety impacts during the operation

phase are common to most industry sectors, including those

related to noise and traffic safety from the transport of raw

materials and finished product. These impacts are discussed in

the General EHS Guidelines. Industry-specific issues that can

impact the community or the public at large may include those

associated with the potential presence of pathogens or microbial

contaminants as well as other chemical or physical effects from

processed fish.

Food Safety Impacts and Management

A food product recall brought about because of contaminated or

adulterated food products found in commerce that are

attributable to a specific company can damage a viable


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business. If a company can trace its products, then recall is a

matter of removing all foods associated with specific lot

numbers. With a robust food safety program in place, a

company can protect itself from product adulteration,

contamination, and the impacts of food recalls.

Fish processing should therefore be performed according to

internationally recognized food safety standards consistent with

the principles and practice of HACCP6 and Codex Alimentaria.7

Recommended food safety principles include the following:

• Respect “clean” and “dirty” zoning. Design in accordance

with veterinary rules (e.g. surfaces are easy to clean and

desterilize knives);

• Improve the cooling chain;

• Facilitate tracing parts of processed product;

• Comply with veterinary regulation and precautions for

waste and by-products;

• Full institutionalization of HACCP prerequisites including:

o Sanitation

o Good Management Practices (GMPs)

o Implement integrated pest and vector management

programs and maximize pest and vector control

through mechanical means(e.g. traps), and use mesh

on doors and windows to reduce the need for

chemical pest and vector control

o Chemical control

o Allergen control

o Customer complaints mechanism

o Traceability and recall

6 ISO (2005). 7 FAO and WHO (1962–2005).

2.0 Performance Indicators and Monitoring

2.1 Environment

Emissions and Effluent Guidelines Tables 1 and 2 present emission and effluent guidelines for this

sector. Guideline values for process emissions and effluents in

this sector are indicative of good international industry practice

as reflected in relevant standards of countries with recognized

regulatory frameworks. These levels should be achieved,

without dilution, at least 95 percent of the time that the plant or

unit is operating, to be calculated as a proportion of annual

operating hours. Deviation from these levels in consideration of

specific, local project conditions should be justified in the

environmental assessment.

Effluent guidelines are applicable for direct discharges of treated

effluents to surface waters for general use. Site-specific

discharge levels may be established based on the availability

and requirements of publicly operated sewage collection and

treatment systems or, if discharged directly to surface waters,

on the receiving water use classification as described in the


Emissions guidelines are applicable to process emissions.

Combustion source emissions guidelines associated with

steam- and power-generation activities from sources with a

capacity equal to or lower than 50 MWth are addressed in the

General EHS Guidelines with larger power source emissions

addressed in the EHS Guidelines for Thermal Power.

Guidance on ambient considerations based on the total load of

emissions is provided in the General EHS Guidelines.


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Table 1. Effluent levels for fish processing

Pollutants Units Guideline Value

pH pH 6 – 9

BOD5 mg/l 50

COD mg/l 250

Total nitrogen mg/l 10

Total phosphorus mg/l 2

Oil and grease mg/l 10

Total suspended solids mg/l 50

Temperature increase °C <3b

Total coliform bacteria MPNa / 100 ml 400

Active Ingredients / Antibiotics

To be determined on a case specific basis

Notes: a MPN = Most Probable Number b At the edge of a scientifically established mixing zone which takes into account ambient water quality, receiving water use, potential receptors and assimilative capacity

Table 2. Air emission levels for fish processing.

Pollutants Unit Guideline Value

Ammonia mg/m3 1

Amines and amides mg/m3 5

Hydrogen sulfide, sulfides, and mercaptans

mg/m3 2

Resource Use Table 3 provides examples of energy and water consumption in-

dicators for various aspects of fish processing. Industry

benchmark values are provided for comparative purposes only

and individual projects should target continual improvement in

these areas.

Table 3. Energy and water consumption for common fish production processes

Output per unit of product Unit Energy consumption per ton of raw material

Processing of shrimps

Freezing (contact freezer)

Freezer (blast freezer)

Fillet production

Fish-meal production

MJ

MJ

MJ

MJ

MJ

350

328

350

18

2300

Outputs per unit of product Units

Water consumption per ton raw materialsa

Whitefish

Herring filleting

Mackerel filleting

m3/t

m3/t

m3/t

5–11

5–8

5–8

a UNEP: Cleaner Production: Fish Processing

http://www.agrifood-forum.net/publications/guide/f_chp0.pdf

Environmental Monitoring Environmental monitoring programs for this sector should be

implemented to address all activities that have been identified to

have potentially significant impacts on the environment during

normal operations and upset conditions. Environmental

monitoring activities should be based on direct or indirect

indicators of emissions, effluents, and resource use applicable

to the particular project.

Monitoring frequency should be sufficient to provide

representative data for the parameter being monitored.

Monitoring should be conducted by trained individuals following

monitoring and record-keeping procedures and using properly

calibrated and maintained equipment. Monitoring data should be

analyzed and reviewed at regular intervals and compared with

the operating standards so that any necessary corrective

actions can be taken. Additional guidance on applicable

sampling and analytical methods for emissions and effluents is

provided in the General EHS Guidelines.


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Occupational Health and Safety Guidelines Occupational health and safety performance should be

evaluated against internationally published exposure guidelines,

of which examples include the Threshold Limit Value (TLV®)

occupational exposure guidelines and Biological Exposure

Indices (BEIs®) published by American Conference of

Governmental Industrial Hygienists (ACGIH),8 the Pocket Guide

to Chemical Hazards published by the United States National

Institute for Occupational Health and Safety (NIOSH),9

Permissible Exposure Limits (PELs) published by the

Occupational Safety and Health Administration of the United

States (OSHA),10 Indicative Occupational Exposure Limit Values

published by European Union member states,11 or other similar

sources.

Accident and Fatality Rates Projects should try to reduce the number of accidents among

project workers (whether directly employed or subcontracted) to

a rate of zero, especially accidents that could result in lost work

time, different levels of disability, or even fatalities. Facility rates

may be benchmarked against the performance of facilities in this

sector in developed countries through consultation with

published sources (e.g. US Bureau of Labor Statistics and UK

Health and Safety Executive)12.

Occupational Health and Safety Monitoring The working environment should be monitored for occupational

hazards relevant to the specific project. Monitoring should be

8 Available at: http://www.acgih.org/TLV/ and http://www.acgih.org/store/ 9 Available at: http://www.cdc.gov/niosh/npg/ 10 Available at: http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9992 11 Available at: http://europe.osha.eu.int/good_practice/risks/ds/oel/ 12 Available at: http://www.bls.gov/iif/ and http://www.hse.gov.uk/statistics/index.htm

designed and implemented by accredited professionals13 as part

of an occupational health and safety monitoring program.

Facilities should also maintain a record of occupational

accidents and diseases and dangerous occurrences and

accidents. Additional guidance on occupational health and

safety monitoring programs is provided in the General EHS

Guidelines.

13 Accredited professionals may include certified industrial hygienists, registered occupational hygienists, or certified safety professionals or their equivalent.


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3.0 References BLS (US Bureau of Labor Statistics). 2004a. Industry Injury and Illness Data – 2004. Supplemental News Release Tables. Table SNR05: Incident rate and number of nonfatal occupational injuries by industry, 2004. Washington, DC: BLS. Available at http://www.bls.gov/iif/oshwc/osh/os/ostb1479.pdf

BLS (US Bureau of Labor Statistics). 2004b. Census of Fatal Occupational Injuries Charts, 1992–2004. Number and rate of fatal occupational injuries by private industry sector, 2004. (Table page 10). Washington, DC: BLS. Available at http://www.bls.gov/iif/oshwc/cfoi/cfch0003.pdf

DEFRA (Department for Environment, Food and Rural Affairs). Process Guidance Note 6/19 (05) Secretary of State’s Guidance for Fish-Meal and Fish-Oil Processes. Scotland: DEFRA.

EC (European Commission). 1996. Council Directive 96/61/EC of 24 September 1996 concerning integrated pollution prevention and control (IPPC). EC. Available at http://europa.eu.int/comm/environment/ippc/index.htm Consolidated: http://europa.eu.int/eur-lex/en/consleg/pdf/1996/en_1996L0061_do_001.pdf

EC (European Commission). 2005. Integrated Pollution Prevention and Control, Draft Reference Document on Best Available Techniques in the Food, Drink and Milk Industries. BREF finalized. Dated January 2006. p vii Typical FDM waste water quality after treatment – the emission levels given are indicators of the emission levels that would be achieved with those techniques normally considered to represent BAT.

EC (European Commission). 2006. Integrated Pollution Prevention and Control, Draft Reference Document on Best Available Techniques in the Food, Drink and Milk Industries. BREF finalized. Dated January 2006. EC. Available at http://eippcb.jrc.es/pages/FActivities.htm

FAO and WHO (Food and Agriculture Organization and World Health Organization).1962–2005. Codex Alimentaris is an important link of information on product origin tracking for food safety, input/output indicators for monitoring, including food/feed conversion efficiencies, etc. Maximum Residues Limits for Pesticides in Food. Geneva: FAO and WHO. Available at http://www.codexalimentarius.net/web/index_en.jsp

HSC (Health and Safety Commission). 2005a. United Kingdom. Statistics of Fatal Injuries 2004/05. Fatal injuries to workers in manufacturing (p.7). London: National Statistics. Available at http://www.hse.gov.uk/statistics/overall/fatl0405.pdf

HSC (Health and Safety Commission). 2005b. United Kingdom. Rates of Reported Fatal Injury to Workers, Non Fatal Injuries to Employees and LFS Rates of Reportable Injury to Workers in Manufacturing. London: National Statistics. Available at http://www.hse.gov.uk/statistics/industry/manufacturing-ld1.htm#notes

India EPA (Environmental Protection Agency). 1998. Liquid Effluent Standards – Category: 52.0 Slaughter House, Meat & Sea Food industry. EPA Notification S.O. 64(E), dt. January 18, 1998. Indian EPA. Available at http://www.cpcb.nic.in/standard52.htm

Irish EPA (Environmental Protection Agency). 1996. BATNEEC Guidance Note, Class 7.5, Fish-meal and Fish-oil (Draft 3). Ireland: Irish EPA. Available at http://www.epa.ie/Licensing/IPPCLicensing/BATNEECGuidanceNotes/FileUpload,561,en.DOC

ISO (International Standards Organization). 2005. ISO 20000: 2005: Food safety management systems: Requirements for any organization in the food chain. ISO. Available at http://www.iso.org/iso/en/CatalogueDetailPage.CatalogueDetail?CSNUMBER=35466&ICS1=67&ICS2=20&ICS3=

Nordic Council of Ministers. 1997. BAT Best Available Technology in the Fishing Industry, TemaNord 1997:579, Copenhagen: Nordic Council of Ministers.

Thailand MOSTE (Ministry of Science, Technology and Environment).1996. Industrial Effluent Standard. Notification by the Ministry of Science, Technology and Environment, No. 3, B.E.2539 (1996) issued under the Enhancement and Conservation of the National Environmental Quality Act B.E.2535 (1992). MOSTE. Available at http://www.pcd.go.th/info_serv/en_reg_std_water04.html#s1

World Bank Group. International Finance Corporation Environmental, Health and Safety Guidelines for Fish Processing. Washington, DC: World Bank Group. Available at http://www.ifc.org/ifcext/enviro.nsf/Content/EnvironmentalGuidelines


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Annex A: General Description of Industry Activities The activities that charaterize the fish processing sector depend

on the type of fish being processed and the desired final

products. Fish processing broadly consists of removing the

inedible part of the fish and preserving the edible parts. The

main fish processing stocks include cod, tuna, herring,

mackerel, anchovy, pilchard, salmon, pollack, hake, and

haddock. Products for human consumption range from whole

fish to fillets and specialty products, which may be sold frozen,

fresh (chilled) or preserved. Wild-caught marine fish processing

facilities are typically located at commercial fishing harbors,

while factories processing aquaculture products are often

located close to the fish farming operation. Fish processing

comprises the processing of the main product and associated

by-products. Processing activities for fish filleting and

preserving, the most common type of production type, are

presented in Figure A-1 and described below. Mollusk and

crustacean processing activities contain fewer stages and

concentrate on the washing, cooking, cooling, processing, and

packaging of the product.

Industry Activities

Material Reception and Preparation

Raw materials are typically received at the fish processing

facility from a commercial fishing vessel or fish farm. For some

fish species, gutting, cleaning, and head removal can take place

at sea on board fishing vessels to maintain optimal quality. This

is often the case for white fish with a low oil content, which are

then kept on ice or frozen until they arrive at the processing

facility. Fatty fish fillets may have an oil content of up to 30

percent and are usually not gutted until they arrive at the

processing facility. When fish are processed at sea, the offal is

typically discarded into the sea. Although this reduces the

amount of offal produced at land-based fish processing facilities,

if taken ashore, the offal could be turned into a potentially

valuable by-product.

During unpacking, fish are subject to quality control (including

traceability documentation) and, at this stage, any by-catch and

offal can be diverted to the by-product line. Fresh raw fish is

washed and graded to separate any material that does not meet

standards for quality and uniformity. Frozen raw material has to

be thawed (e.g. under running water or with air at controlled

temperatures) before washing and grading. The prepared raw

material is then chilled for storage, re-iced, or, in the case of live

catch, held in holding tan

Product Processing

The product processing phase begins with skinning and cutting

to remove the edible parts of the fish and reduce the size to the

desired portions. Skinning can be done manually or

automatically. In automatic operations, white fish are skinned by

pulling the fillet over an automatic knife. Fatty fish, such as

herring, are skinned by pulling them over a freezing drum. The

fish are then transported to cutting tables where evisceration

takes place (e.g. the heads, tails, and inedible parts are

removed). The offal is collected and diverted to the by-product

line. At this stage, any valuable by-products(e.g. liver and roe),

are collected and then sent for separate handling. After

evisceration, the cleaned fish products are filleted at the cutting

tables and then washed.

Evisceration generates significant amounts of solid waste, most

of which ends up in the aqueous waste stream. Facilities

processing fatty, ungutted fish such as herring typically generate


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the highest levels of aqueous pollutants. However, dry collection

and transport of waste can be used to reduce water

consumption, increase the amount of saleable offal, and reduce

organic discharge in wastewater (e.g. a 60 to 70 percent

reduction can be achieved in the herring filleting industry).14

Product Finalization

In product finalization, the cut fish and shellfish product is

preserved through a variety of processes and may be consumed

in their primary form, either raw or cooked. They may also be

further processed to produce fish- or shellfish-based foods, such

as molded products (fish fingers) or prepared dishes.

Preservation methods typically used in fish processing include

chilling and freezing, canning, brining and salting, fermenting,

drying, and smoking, which may be used in various

combinations, such as fermentation with salting and drying.

Chilling and freezing decrease the fish temperature to levels

(approximately 0 °C or less than - 18°C, respectively) where

metabolic activities, catalyzed by autolytic or microbial enzymes,

are reduced or completely stopped. Canning preserves the

product by first heating it (usually under pressure) to a

temperature that destroys contaminating micro-organisms, and

then sealing it in air-tight jars or cans. The remaining

preservation techniques, described below, control microbial

growth by reducing the water content, adding anti-microbial

agents, and / or decreasing the pH of the product.

During brining and salting, a product is treated with common

and curing salts (nitrate and / or nitrite) to reduce the water

activity beyond the microbial tolerance limits, ensuring that the

life of the product is increased and also giving it flavor. Both salt

and nitrite are essential for curing to take place. Brining methods

include dry, immersion, and tumble / massage brining.

Fermentation processes allow the partial decomposition of the

14 Nordic Council of Ministers (1997).

fish, which lowers the pH and prevents putrefaction, while giving

the final product a strong, distinctive flavor.

Drying decreases the water activity level of the fish to minimize

microbial growth. Salted and fermented fish are often further

dried to increase shelf life, or fish might be dried without other

primary preservation steps. Drying processes can range from

solar drying to temperature- and humidity-controlled drying

rooms. Dried fish typically has a moisture content of between 38

and 48 percent, depending on the product. Smoking preserves

the product through exposure to smoke, which has a

bacteriostatic effect. There are two types of smoking, hot and

cold both of which add flavor.

By-products There are two main by-products from the main fish processing

process: fish meal and fish oil.

Fish Meal

Fish meal is produced through a cooking and dehydrating

process whereby fish oil is separated and water is removed from

the product. Fish meal production is a high energy consuming

process. Raw material enters the fish meal production line on a

feeder system and is then cooked. Cooking temperature and

duration depends on the cooker type, but typically the material is

cooked for approximately 20 minutes at 90oC. This activity

results in significant odor levels. The cooked material is pressed

in a screw-press or decanter centrifuge, and the press liquid is

diverted into a centrifuge where the fish oil is separated from the

stick water. The stick-water flow is then evaporated in a

multiple-stage evaporator and the remaining sludge is mixed

with the press cake. This combined material is then dried until it

has a water content of below 10 percent. After drying, the

material is ground to break up any lumps. The fish meal is then

sent to packaging and intermediate storage.


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Fish Oil

Fish oil production is typically an integrated part of fish meal

production, however, the production of cod liver oil and other

specialty products can be established as stand-alone production

units. The quality of the fish oil obtained depends largely on the

quality of the fish raw material and the equipment used. Today,

the extraction of fish oil is conducted exclusively by centrifugal

machinery, typically three-phase decanters and separators.

Annex B: Sustainable Fishing Principles and References to Existing Good Practice Materials

Code of Conduct for Responsible Fisheries Initiated by the United Nations Food and Agricultural

Organization (FAO), the Rome Declaration establishes a “Code

of Conduct for Responsible Fisheries.” The Code is available

online at

www.fao.org/figis/servlet/static?dom=org&xmlCCRF_prog.xml

and outlines the following recommendations:

• Base conservation and management decisions on the best

scientific evidence available, taking into account traditional

knowledge of the resources and their habitat;

• Develop further selective and environmentally safe fishing

gear to maintain biodiversity, minimize waste, catch of

nontarget species, and so on;

• Ensure fisheries interests are accommodated in the

multiple uses of the coastal zone and are integrated into

coastal area management;

• Protect and rehabilitate critical fisheries habitats;

• Ensure compliance with and enforcement of conservation

and management measures and establish effective

mechanisms to monitor and control activities of fishing

vessels and fishing support vessels;

• Exercise effective flag state control to ensure the proper

application of the Code;

• Cooperate through subregional, regional, and global

fisheries management organizations;

• Conduct fish trade in accordance with the principles, rights,

and obligations established in the World Trade

Organization Agreement; and

• Promote awareness of responsible fisheries through

education and training, as well as involve fishers and fish

farmers in the policy formulation and implementation

process.

Marine Stewardship Council (MSC) The MSC provides a set of Principles and Criteria for

Sustainable Fishing that are used as the standard in a third

party, independent, and voluntary certification program. These

principles are based on the Rome Declaration’s Code of

Conduct for Responsible Fisheries.


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Figure A.1: Fish Processing Activities

Unpacking

Thawing (in water)

Washing and grading

Skinning

Evisceration and removal of valuable by

products (liver, milt, etc)

Raw material reception from fishing

vessel or farm

Rejected fish

Rejected fish

Skin

Guts, head

Filleting

Washing

Process By-product

Conservation: chilling, freezing, salting,

drying

Quality control

External packing

Bones, off-cuts, rejects

By-product raw material Fish meal and fish oil processes

Dehydrating

Packing


Page 99 of 111

Annex XIII World Bank Group EHS Guidelines for Aquaculture

Environmental, Health, and Safety Guidelines AQUACULTURE

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Environmental, Health, and Safety Guidelines for Aquaculture

Introduction

The Environmental, Health, and Safety (EHS) Guidelines are

technical reference documents with general and industry-

specific examples of Good International Industry Practice

(GIIP) 1. When one or more members of the World Bank Group

are involved in a project, these EHS Guidelines are applied as

required by their respective policies and standards. These

industry sector EHS guidelines are designed to be used

together with the General EHS Guidelines document, which

provides guidance to users on common EHS issues potentially

applicable to all industry sectors. For complex projects, use of

multiple industry-sector guidelines may be necessary. A

complete list of industry-sector guidelines can be found at:

www.ifc.org/ifcext/enviro.nsf/Content/EnvironmentalGuidelines

The EHS Guidelines contain the performance levels and

measures that are generally considered to be achievable in new

facilities by existing technology at reasonable costs. Application

of the EHS Guidelines to existing facilities may involve the

establishment of site-specific targets, with an appropriate

timetable for achieving them.

The applicability of the EHS Guidelines should be tailored to

the hazards and risks established for each project on the basis

of the results of an environmental assessment in which site-

specific variables, such as host country context, assimilative

1 Defined as the exercise of professional skill, diligence, prudence and foresight that would be reasonably expected from skilled and experienced professionals engaged in the same type of undertaking under the same or similar circumstances globally. The circumstances that skilled and experienced professionals may find when evaluating the range of pollution prevention and control techniques available to a project may include, but are not limited to, varying levels of environmental degradation and environmental assimilative capacity as well as varying levels of financial and technical feasibility.

capacity of the environment, and other project factors, are

taken into account. The applicability of specific technical

recommendations should be based on the professional opinion

of qualified and experienced persons.

When host country regulations differ from the levels and

measures presented in the EHS Guidelines, projects are

expected to achieve whichever is more stringent. If less

stringent levels or measures than those provided in these EHS

Guidelines are appropriate, in view of specific project

circumstances, a full and detailed justification for any proposed

alternatives is needed as part of the site-specific environmental

assessment. This justification should demonstrate that the

choice for any alternate performance levels is protective of

human health and the environment.

Applicability

The EHS Guidelines for Aquaculture provide information

relevant to semi-intensive and intensive/super-intensive,

commercial aquaculture production of the main aquatic species,

including crustaceans, mollusks, seaweeds and finfish, located

in developing countries in temperate and tropical regions. Annex

A contains a full description of industry activities for this sector.

This document is organized according to the following sections:

Section 1.0 — Industry-Specific Impacts and Management Section 2.0 — Performance Indicators and Monitoring Section 3.0 — References Annex A — General Description of Industry Activities


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1.0 Industry-Specific Impacts and Management

The following section provides a summary of EHS issues

associated with aquaculture, along with recommendations for

their management. Recommendations for the management of

EHS issues common to most projects during the construction

and decommissioning phases are provided in the General EHS

Guidelines.

1.1 Environment

Environmental issues associated with the aquaculture sector

primarily include the following:

• Threats to biodiversity

• Contamination of aquatic systems

• Hazardous Materials

Threats to Biodiversity Threats to biodiversity are mainly associated with conversion of

natural habitats during construction; potential release of alien

species into the natural environment during operations; potential

loss of genetic resources due to collection of larvae, fry, or

juveniles for aquaculture production; potential release of

artificially propagated seed into the wild (e.g. there are more

farmed than wild Atlantic salmon in existence); sustainability of

fish meal and fish oil ingredients for fish and crustacean feeds;

and development of antibiotic resistance in pathogenic bacteria

that can then spread from farms to wild stock.

Conversion of Natural Habitats

The construction and operational phases of the project cycle of

an aquaculture facility may require conversion of the natural

environment including, for example, the removal of mangroves

for excavation of ponds, or alteration of the natural hydrology of

lagoons, bays, rivers, or wetlands.2 Operational phase issues

may also include alteration of aquatic habitats and substrates

(e.g. under sea cages or shellfish farms).

A range of management measures can be taken to prevent and

reduce the environmental impacts caused by the construction of

aquaculture facilities, as presented below. Further potential

impacts are related to changes to stream hydrology caused by

the construction of barriers to flow (e.g. dams may cause

disruption of wetland areas and changes in stream morphology,

potentially affecting migratory species, including birds, and

nursery areas for juvenile fish). Measures should include all of

the following:

• Survey the project area before land and water conversion

to aquaculture production is undertaken to identify,

categorize, and delineate natural and modified habitats and

ascertain their biodiversity importance at the national or

regional level;

• Ensure that the area to be converted to aquaculture use

does not represent a habitat that is unique or protected

(such as mangrove areas), or includes high biodiversity

value, such as known sites of critically endangered or

endangered species, or important wildlife breeding,

feeding, and staging areas;

• Be aware of the presence of critically endangered or

endangered species in the areas already used for

aquaculture production, and implement management

processes that take them into account;

• Design facilities so that as much as possible of the natural

vegetation habitat is left intact (e.g. through the use of

vegetated buffer zones and habitat corridors) and that

2 Hydrological changes may also contribute to changes in the natural geochemistry such as the release of pyrite from formerly submerged soils of cleared mangrove areas. When pyrite comes into contact with oxygen, it creates acid sulfate soil, which in turn has potentially serious impacts on the health of the aquaculture organisms for many years to come.


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conversion and degradation of the natural habitat is

minimized;

• Design and implement mitigation measures to achieve no

net loss of biodiversity where feasible, for instance through

post-operation restoration of habitats; offset of losses

through the creation of ecologically comparable area(s)

managed for biodiversity; and compensation to direct users

of biodiversity;

• Avoid the need to frequently abandon and replace

improperly designed and built aquaculture ponds:

o Assess soil properties prior to pond construction to

ensure that the bottom-sealing layer of the soil with

percolation rates/porosity low enough to satisfactorily

hold pond water. If there is not enough clay, then the

ponds may demonstrate high seepage rates and

require additional expenditure (e.g. pumping in water,

or relining with clay-rich or possibly bentonite-rich

topsoil from other sites) or eventual abandonment.

High seepage rates can also pollute groundwater

required for other purposes in the vicinity with use for

drinking water a major concern.

o Assess the soil pH and the presence of pesticide and

pollutant residues (especially on land that was

previously used for intensive agriculture), as well as

the natural occurrence of pyrite, prior to construction

as the presence of anthropogenic or natural pollutants

may hinder the viability of the pond.

Conversion of Agricultural Land - Salinization If new land areas are not available for aquaculture, an

alternative is to convert former agricultural land. If the selected

production is based on brackish water, this may pose a risk of

salinization of surrounding agricultural land. The following

measures can be taken to avoid salinization of agricultural land:

• Ensure that the embankments around brackish water pond

systems are high enough to form a physical division

between agriculture and aquaculture;

• Ensure that the saline / brackish water discharges are

appropriately treated and disposed of (e.g. through use of

discharge canals) for the receiving waters;

• Ensure that appropriate discussions are held at the

community level to avoid conflicts of interest when

agricultural land is transferred to aquaculture production.

Introduction of Alien, Selectively Bred, or Genetically Engineered Species

Introductions can result in interactions with the wild, including

escapes from farms, or open systems (such as mussel rafts). As

such, introductions can disturb the existing ecological balance;

cause loss of species biodiversity; cause loss of genetic

diversity of the wild populations; reduce fitness of wild

population through breeding with genetically altered escapees;

and result in the transmission or spread of fish diseases. The

widespread seeding of an alien genotype is of considerable

concern both as regards species biodiversity and genetic

biodiversity.

Management measures to reduce the risks from introductions of

alien, selectively bred, or genetically modified species include

the following:

• Application of codes and guidelines (see Section 3.0);

• Farming of sterile fish;

• Preventing the escape of species from pond-based

aquaculture systems. Examples of common escape

prevention measures include:

o Installation and maintenance of screens with a mesh

that is small enough to prevent the entry and potential

escape of aquatic species in the drainage channels

connecting production ponds to sedimentation ponds,


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as well as those connecting sedimentation ponds to

the receiving water

o Installation of fish-proof strainer dams

o Installation and maintenance of gravel filtration on

pond discharge structures

o When necessary, consider chemical treatment of

water released from hatcheries(e.g. with chlorine at

acceptable concentrations for the receiving waters) to

destroy escaping larvae or juveniles

o Consider the hydrology of the region in the design of

the pond system and ensure that the pond

embankments are high enough to contain the pond

water and prevent escape of the species during

periods of heavy rainfall and potential flooding

o Establish a contingency plan if there is an escape of

the species being cultivated into the wild

• Preventing the escape of species from open water

aquaculture systems. Examples of common escape

prevention measures include:

o Regularly inspect the cage and pen netting for

holes(e.g. before crowding of the harvest and at

intervals during the operation)

o Design and construct cage and pen units, including

choice of nets, to deal with the worst weather and

environmental conditions likely to occur on the site

o Provide for containment during periods of storm

surges and excessively high tides

o For cage culture in open waters, use submersible

cages that can be submerged during storms below

damaging wave action

o Provide adequate marking of the fish farm system to

warn navigators of the potential obstruction and

reduce the risk of collision3

3 Shetland Aquaculture (2006).

o Establish a contingency plan for harvest of escapees

of the species being cultivated into the wild.

Impacts of Harvesting on Ecosystem Functions

The practice of capturing females, eggs, fry, juveniles, or even

fingerlings from the wild for the purpose of stocking aquaculture

systems may threaten ecosystem biodiversity. Fry and larvae

may be gathered from fresh or brackish water using very fine

meshed nets resulting in considerable by-catch, as well as the

removal of large number of larvae, fry, and juveniles from the

food chain.4 The recommended prevention of this type of

ecosystem pressure is the breeding of stock material in

captivity. However, for some species, careful harvesting of

hatchlings/ and or fry (less than 3 cm) that are still at a stage of

expected high mortality can result in relatively little impact on the

overall population as compared to collecting larger fingerlings

from a smaller population for grow-out.

Fish meal and fish oil

Fish meal and oil are derived from the capture and processing

of wild pelagic fish stocks (e.g. anchovy, pilchard, herring,

sardine, sand eel, sprat, and capelin). Although the production

of fish meal and oil is not covered by these Guidelines,

processed fishmeal and oil are the primary sources of protein

and dietary lipids in fish feed for farmed fish in aquaculture

operations. The aquaculture sector is an important consumer of

fish meal and fish oil, and there are concerns regarding the

sustainability of the pelagic fish stocks from which fish meal and

fish oil are derived. Aquaculture operations should consider

incorporating the use of alternatives to supplies of fish feed

produced from fish meal and fish oil. Alternatives for fish feed

ingredients may include use of plant material substitutes [e.g.

4 Some jurisdictions have outlawed the larvae and fry collection or export although the practice still represents a source of income for the poor in some developing countries.


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soya for bulk protein and single-cell protein (yeast for lysine and

other amino acids)] and biotechnology options (e.g. bio-

fermentation products).5

Source Water Quality

The quality of source water can also have a major effect on the

viability of an aquaculture operation whether it is water used for

hatchery and ponds systems or the water in which cages and

pens are established. The water itself can affect the health of

the organism as well as contribute to the accumulation of

substances or pathogens toxic to consumers. Quality guidelines

have been developed for aquaculture and vary depending upon

the organism cultured.6

Contamination of Aquatic Systems Aquaculture activities, particularly pond-based systems, may

affect aquatic systems due to construction and operation

activities, primarily the mobilization of soils and sediments

during construction and through the release of effluents during

operation. Fish cage culture can also be a major contributor to

marine pollution in areas of high density use.

Soil Erosion and Sedimentation

Earth excavation and moving activities conducted during

construction of some types of aquaculture projects may result in

soil erosion and the subsequent sedimentation of nearby water

bodies. Sedimentation of aquatic resources may contribute to

eutrophication and overall degradation of water quality.

Recommended management strategies include the following:

5 Further information is available from Use of Fishmeal and Fish Oil in Aquafeeds: Further Thoughts on the Fishmeal Trap, FAO (2001) Available at http://www.fao.org/docrep/005/y3781e/y3781e07.htm#bm07.3.3 and Assessment of the Sustainability of Industrial Fisheries Producing Fish Meal and Fish Oil, Royal Society for the Protection of Birds (2004) available at http://www.rspb.org.uk/Images/fishmeal_tcm5-58613.pdf 6 Zweig, R. D., J. D. Morton and M. M Stewart.1999. Source Water Quality for Aquaculture: A Guide for Assessment. The World Bank. 62 pp.

• Construct pond and canal levees with a 2:1 or 3:1 slope

(based on soil type) as this adds stability to the pond

banks, reduces erosion, and deters weeds. Avoid pond

construction in areas that have a slope of more than 2

percent, as this will require energy-intensive construction

and maintenance;

• Stabilize the embankments to prevent erosion;

• Reduce excavation and disturbance of acid sulfate soils

during construction;

• Carry out construction work during the ‘dry’ season to

reduce sediment runoff that may pollute adjacent waters;

• Install temporary silt fences during construction to slow

down and catch any suspended sediments. Silt fences can

be made of woven plastic or fabric, or hay bales.

Wastewater Discharges

Industrial Process Wastewater: The effluent released from

aquaculture systems typically contains a high organic and

nutrient load, suspended solids, and may also contain chemical

residues including feed supplements and antibiotics. The

possible impacts include contamination of groundwater and

surface water from release of effluents or communication to

receiving water from unconfined process and storage tanks

(such as ponds and lagoons). Impacts on aquatic systems

include creation of eutrophic zones within receiving waters,

increased fluctuation of dissolved oxygen levels, creation of

visible plumes, and accumulation of nutrients within the

receiving waters.7

The high nutrient load results from efforts to artificially boost

production levels by increasing the food supply for the cultured

species. This is done by increasing nutrient availability either

directly through supplemental feed or indirectly by fertilizing

7 Department of Primary Industries and the Queensland Finfish Aquaculture Industry (1999).


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ponds to increase primary productivity. Pond ecosystems have

a limited capacity to recycle organic matter and nutrients, and

increasing the stocking rate removes this capacity, resulting in

the build-up of organic matter, nitrogenous waste, and

phosphorus both in the water mass and on the bottom of the

pond or pen / cage.8 The suspended solids are derived from

particulate organic matter and erosion of pond floor, walls, and

discharge channels.

The chemical residues may include the remains of veterinary

drugs (e.g. antibiotics) that may have been applied to the

cultivated species, and toxic substances such as formalin and

malachite green, a cancer causing agent, that may have been

that are used to treat finfish for parasites and their eggs for

fungal growth. Malachite green is banned in most countries and

must not be used. Formalin should only be used under

controlled conditions (e.g. in dipping containers) and with proper

care – it should not be introduced directly into production

systems.9

A range of measures can be taken in pond systems and pen /

cage systems to (i) reduce the amount of contamination of the

effluent; (ii) prevent pond effluent from entering surrounding

water bodies; and (iii) treat the effluent before its release into the

receiving waters to reduce contaminant levels. Aquaculture

operations in large water bodies, however, are open to the

surrounding environment and do not have the second or third

options, therefore any contamination takes effect immediately.10

The following management measures can prevent the

contamination of effluent:

8 Center for Tropical and Subtropical Aquaculture (2001). 9 Because the use of these highly toxic substances is primarily an occupational health and safety issue, refer to the Occupational Health and Safety section for a more detailed review of their application and for practical guidance. 10 Aquaculture is also somewhat self-regulating in that if the water is highly eutrophic or laden with dissolved or particulate nutrients or BOD, this will adversely affect many cultured organism and thus would be counterproductive not to manage it to a high quality level. This would somewhat reduce impacts of effluents.

Feed:

• Ensure that pellet feed has a minimum amount of “fines” or

feed dust. Fines are not consumed and add to the nutrient

load in the water;

• Match the pellet size to the species’ life-cycle stage (e.g.

smaller pellets should be fed to fry or juvenile animals to

reduce the unconsumed fraction);

• Regularly monitor feed uptake to determine whether it is

being consumed and adjust feeding rates accordingly.

Feed may be wasted due to overfeeding or not feeding at

the right time of day;

• Where feasible, use floating or extruded feed pellets as

they allow for observation during feeding time;

• Store feed in cool, dry facilities and ideally for no longer

than 30 days to avoid reduction in vitamin contents. Moldy

feed should never be used as it may cause disease;

• Spread feed as evenly as possible throughout the culture

system, ensuring that as many animals as possible have

access to the feed. Some species are highly territorial, and

uneaten feed adds to the nutrient load;

• Feed several times a day, especially when animals are

young, allowing better access to food, better feed

conversion ratios and less waste;

• Halt feeding at a suitable interval before harvest to

eliminate the presence of food and / or fecal material in the

animal’s gut;

• During harvesting, contain and disinfect blood water and

effluent to reduce the risk of disease spread and to contain

effluent matter.

Other organic materials:

• Perform slaughter and processing in an area where the

effluent is contained;

• Prevent effluent leakage from harvest rafts and bins by

using harvest bins in good condition with sealed bin liners

and secure lids and bindings;


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• Equip off-loading bays with a waterproof apron and

surround with a bund to contain potential spills and prevent

contamination with effluent.11

Suspended solids:

• Avoid discharging waters from ponds while they are being

harvested with nets, as this will add to the suspended

solids in the effluent drainage;

• If feasible, use partial draining techniques to empty ponds

that have been harvested. The last 10–15 percent of pond

water contains the highest quantities of dissolved nutrients,

suspended solids, and organic matter. After harvest, hold

the remaining water in the pond for a number of days

before discharge, or transfer to a separate treatment

facility.

Fertilizers:

• Plan the rate and mode of application of fertilizers to

maximize utilization and prevent over-application, taking

into account predicted consumption rates;

• Increase the efficiency of application and dispersion

through such practices as dilution of liquid fertilizers or

solution of granulated fertilizers prior to application. Other

options include the use of powdered fertilizers or the

placement of powdered fertilizer bags in shallow water to

allow solution and dispersion;

• Consider the use of time-released fertilizer in which resin

coated granules release nutrients into the pond water, with

the rate of release corresponding to water temperature and

movement;

• Avoid the use of fertilizers containing ammonia or

ammonium in water with pH of 8 or above to avoid the

formation of toxic unionized ammonia (NH3);12

11 Shetland Aquaculture (2006). 12 WRAC (2000).

• Depending on the system (e.g., freshwater aquaculture),

grow organic fertilizer (e.g. natural grass) in the pond basin

after harvest;

• Initiate pond fertilization only in static ponds with no pond

water overflow that can impact downstream waters and

watersheds;

• Conduct pond fertilization to avoid or minimize

consequences of potential runoff due to floods or heavy

rain and avoid application to overflowing ponds.

Chemicals:

• Design the pond depth to reduce the need for chemical

control of aquatic weeds and reduce thermal stratification;

• Do not use antifoulants to treat cages and pens. The

chemically active substances used in antifouling agents are

very poisonous and highly stable in an aquatic

environment. Clean nets manually or in a net washing

machine.

The following management measures can be taken in pond-

based systems to prevent pond effluent from entering

surrounding water bodies:

• In some fish systems, avoid automatic drainage of ponds at

the end of the production cycle as the same pond water

may be used to cultivate several crop rotations of certain

species (e.g. catfish);13

• Reuse water from harvested ponds by pumping it into

adjacent ponds to help complement their primary

productivity, provided that the level of BOD is controlled;

This process is called “bloom seeding,” and requires

careful timing of harvests;

• Consider the hydrology of the region in the design of the

pond system and ensure that the pond embankments are

13 Not applicable to shrimp farming which requires the drying out of pond bottoms between harvests.


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high enough to contain the pond water and prevent loss of

effluent during periods of increased rainfall and potential

flooding.

Process Wastewater Treatment: Techniques for treating

industrial process wastewater in this sector include grease

traps, skimmers or oil water separators for separation of

floatable solids; flow and load equalization; sedimentation for

suspended solids reduction using clarifiers or settling ponds;

biological treatment, typically aerobic treatment, for reduction of

soluble organic matter (BOD); biological nutrient removal for

reduction in nitrogen and phosphorus; chlorination of effluent

when disinfection is required; dewatering and disposal of

residuals; in some instances composting or land application of

wastewater treatment residuals of acceptable quality may be

possible. Additional engineering controls may be required (i) for

removal of residual feed supplements, chemicals, antibiotics,

etc. which may pass through the wastewater treatment system,

and (ii) to contain and neutralize nuisance odors. For sea water

applications, unit operations for wastewater treatment may have

to be suitably adapted to the relatively high salinity of the water.

Management of industrial wastewater and examples of

treatment approaches are discussed in the General EHS

Guidelines. Through use of these technologies and good

practice techniques for wastewater management, facilities

should meet the Guideline Values for wastewater discharge as

indicated in the relevant table of Section 2 of this industry sector

document.

Other Wastewater Streams & Water Consumption: Guidance on

the management of non-contaminated wastewater from utility

operations, non-contaminated stormwater, and sanitary sewage

is provided in the General EHS Guidelines. Contaminated

streams should be routed to the treatment system for industrial

process wastewater. Recommendations to reduce water

consumption, especially where it may be a limited natural

resource, are provided in the General EHS Guidelines.

Hazardous Materials The aquaculture sector may involve the handling and use of

hazardous materials (e.g. oil, fertilizers, and other chemicals).

Recommendations for the safe storage, handling, and use of

hazardous materials, including guidance on oil spills and

containment, is provided in the General EHS Guidelines.


As a general approach, health and safety management planning

should include the adoption of a systematic and structured

approach for prevention and control of physical, chemical,

biological, and radiological health and safety hazards described

in the General EHS Guidelines. Occupational health and safety

hazards related to the daily operations of the aquaculture sector

can be grouped into two categories:


• Exposure to chemicals

• Exposure to water borne disease

Physical hazards

A number of hazards are connected with the daily working

routines in aquaculture, including heavy lifts, electric shock, and

drowning.

Heavy Lifts

A number of activities involving heavy lifts are carried out during

daily operations (e.g. refilling automatic feeders in the ponds

and grading the fish). The following management measures can

be taken to reduce exposure of personnel to injuries as a result

of heavy lifts:

• Use mechanical and / or automated equipment to facilitate

lifts heavier than 25 kg;


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• Design workstations that can be adapted to individual

workers, especially if fish are processed post-harvest;

• Construct ponds that are rectangular in shape to facilitate

harvesting. If ponds are of sufficient size, and the

embankments are at least 2.5 meters wide, vehicles can be

used on the embankments to drag harvest seines.

Electric Shock

Electrical devices typically used in aquaculture include manifold

and cover water pumps, paddlewheels, and lighting installations.

The risk of electrical shock is therefore present during all

operations in which the workers are in contact with the water.

Measures to reduce the risk of electric shock include:

• Waterproof all electrical installations;

• Ensure that fuses are used and that there is an appropriate

connection to the ground;

• Ensure that all cables are intact, waterproof, and without

connection;

• Provide training in the correct handling of electric

equipment (e.g. pumps and) to avoid the risk of short

circuits;

• Employ lock out / tag out procedures.

Drowning

The risk of drowning is present in almost all aquaculture

operations and, especially, in cage aquaculture at sea.

Management measures to reduce the risk of drowning among

workers and site visitors include the following:

• Provide lifejackets and harnesses with safety clips

(karabiners) that lock on to lines or fixed points;

• Ensure that personnel are experienced swimmers;

• Train personnel in safety at sea, including procedures for

supervision of personnel;

• Require that personnel wear lifejackets at all times on

exposed sites and at sea;

• Where large vessels are used to transport personnel and

equipment to marine sites, ensure that the vessel can be

securely berthed on the pontoons, reducing the risk of

falling into the gap between the vessel and the pontoon.

Exposure to Chemicals

A variety of chemicals may be used in the operation of an

aquaculture facility to treat and / or control disease organisms or

to facilitate production (e.g. lime, diluted chlorine, or salt).

Fertilizers are also generally caustic materials and care should

be taken in their application. Recommended guidance for the

management of occupational chemical exposure is discussed in

the General EHS Guidelines.

Water-borne Disease Workers may be directly or indirectly exposed to water-borne

diseases due to frequent contact with water (ponds) and the

close proximity of living quarters to surface water bodies. The

potential for transmission of water-borne disease should be

addressed as part of the occupational health and safety

program including specific additional medical screening for the

labor force and implementation of preventive measures (e.g.

mosquito nets in living quarters). Additional guidance on the

prevention and control of communicable diseases is provided in

the General EHS Guidelines.

1.3 Community Health and Safety

Community health and safety hazards arising from aquaculture

operations include the following:

• Salinization of neighboring agricultural land;

• Effects on water resources;

• Food safety impacts and management


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Effects on Water Resources

Water resources used in aquaculture may include the sea,

estuaries, rivers, lakes, and groundwater. The extraction of

water from these resources may result in changes to the natural

water regime, potentially affecting fish stocks and commercial /

recreational activities (e.g. fisheries and recreational activities

downstream of the extraction point), or the availability and

quality of groundwater. Water management strategies should

target the maintenance of hydrologic conditions which provide

water quality and quantity consistent with community needs and

uses; and, in the case of coastal facilities, prevent salt water

intrusion from affecting drinking and agricultural water supplies.

Aquaculture operations may act as breeding grounds for

different insects, especially the mosquito and tsetse fly, thus

increasing the risk of insect-borne disease among communities

in the region. Operators should plan site design and operation to

prevent and control these potential impacts. Additional

information is provided in the Disease Prevention section of the


Food Safety Impacts and Management

Development of Resistance to Veterinary Drugs

The main veterinary drugs used in aquaculture are antibiotics,

which are employed to prevent and treat bacterial diseases.

Antibiotics are generally administered in feed, having either

been added during manufacture or surface-coated onto the

pellets by the manufacturer or the farmer. The development of

antibiotic resistance by pathogenic bacteria may arise when

bacteria acquire resistance to one or more of the antibiotics to

which they were formerly susceptible. That resistance eventually

makes the antibiotics ineffective in treating specific microbial

diseases in humans.14 In addition, when antibiotics are

unintentionally consumed as residues in food, the amount

ingested cannot be quantified or monitored and may cause

direct health concerns (e.g. aplastic anemia), posing a serious

risk to human health. This can also occur with integrated fish

farming systems where antibiotic residues, from livestock

manures used for fertilizer, can be introduced to fishpond

culture.

Recognition of the risks brought about by consumption of

veterinary drugs has led to the banning of certain antibiotics in

aquaculture production and the establishment of maximum

residue limits (MRLs)15 for those with known risks. Observance

of MRLs is required by law under some national jurisdictions

and is encouraged elsewhere.16 Use of resistant strains should

be encouraged and good farm practices to maintain healthy fish

stocks promoted.

The following actions can be taken to limit the use of antibiotics:

• Vaccination should be adopted where possible as a way of

limiting the use of antibiotics;

• Where appropriate, aquaculture facilities should fallow sites

on an annual basis as part of a strategy to manage

pathogens in pen production units. The minimum fallow

period should be four weeks at the end of each cycle;

• Facilities involved in aquaculture production should use a

veterinary service on a frequent basis to review and assess

the health of the stock and employees’ competence and

training. With the assistance of the veterinary service,

14 FAO (2002b). 15 Annex IV of Regulation 2377/90/EEC lists nine substances that may not be used in food-producing species because no safe level of residue can be determined: chloramphenicol, chloroform, chlorpromazine, colchicine, dapsone, dimetridazole, metronidazole, nitrofurans (including furazolidone), and ronidazole. 16 The Codex Alimentarius contains maximum residue limits (MRLs) for veterinary drug residues in all major food products, including salmon and giant prawn. A simple MRL database is provided by FAO/WHO at the following Web site: http://www.codexalimentarius.net/mrls/vetdrugs/jsp/vetd_q-e.jsp


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facilities should develop a Veterinary Health Plan to include

the following aspects:17

o Summary of major diseases present and potentially

present;

o Disease prevention strategies;

o Treatments to be administered for regularly

encountered conditions;

o Recommended vaccination protocols;

o Recommended parasite controls;

o Medication recommendations for feed or water.

If antibiotics are recommended, the following measures should

be considered:

• Apply approved over-the-counter antibiotics in strict

accordance with the manufacturer’s instructions to ensure

responsible use;

• Apply approved antibiotics that are purchased and utilized

by prescription under the guidance of a qualified

professional;

• Develop a contingency plan covering how antibiotics

should be applied following the identification of disease

outbreaks;

• Store antibiotics in their original packaging, in a dedicated

location that:

o Can be locked, is properly identified with signs, and

limits access to authorized persons

o Can contain spills and avoid uncontrolled release of

antibiotics into the surrounding environment

o Provides for storage of containers on pallets or other

platforms to facilitate the visual detection of leaks

• Avoid stockpiles of waste antibiotics by adopting a “first-in,

first-out” principle so that they do not exceed their

17 For more information, see EUREPGAP guidance on integrated aquaculture assurance at: http://www.eurepgap.org/fish/Languages/English/index_html

expiration date. Any expired antibiotics should be disposed

of in compliance with national regulations.

Physical Hazards Communities may be exposed to a number of physical hazards,

including drowning, associated with the presence of pond

systems or other project infrastructure in proximity or in between

community areas, requiring frequent crossing and physical

interaction. Community use should be taken into consideration

in the design of access routes, for example by providing wide

enough walking areas with fall protection along potentially

hazardous locations.

2.0 Performance Indicators and Monitoring

2.1 Environment

Table 1 presents effluent guidelines for this sector. Guideline

values for process emissions and effluents in this sector are

indicative of good international industry practice as reflected in

relevant standards of countries with recognized regulatory

frameworks. These guidelines are achievable under normal

operating conditions in appropriately designed and operated

facilities through the application of pollution prevention and

control techniques discussed in the preceding sections of this

document. These levels should be achieved, without dilution, at

least 95 percent of the time that the plant or unit is operating, to

be calculated as a proportion of annual operating hours.

Deviation from these levels in consideration of specific, local

project conditions should be justified in the environmental

assessment.

Emissions guidelines are applicable to process emissions.

Combustion source emissions guidelines associated with

steam- and power-generation activities from sources with a

capacity equal to or lower than 50 MWth are addressed in the


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General EHS Guidelines with larger power source emissions

addressed in the EHS Guidelines for Thermal Power.

Guidance on ambient considerations based on the total load of

emissions is provided in the General EHS Guidelines.

Effluent guidelines are applicable for direct discharges of treated

effluents to surface waters for general use. Site-specific

discharge levels may be established based on the availability

and conditions in use of publicly operated sewage collection and

treatment systems or, if discharged directly to surface waters,

on the receiving water use classification as described in the


Table 1. Effluent levels for aquaculture

Pollutants Units Guideline Value

pH pH 6 – 9

BOD5 mg/l 50

COD mg/l 250

Total nitrogen mg/l 10

Total phosphorus mg/l 2

Oil and grease mg/l 10

Total suspended solids mg/l 50

Temperature increase °C <3b

Total coliform bacteria MPNa / 100 ml 400

Active Ingredients / Antibiotics

To be determined on a case specific basis

Notes: a MPN = Most Probable Number b At the edge of a scientifically established mixing zone which takes into account ambient water quality, receiving water use, potential receptors and assimilative capacity

Environmental Monitoring Environmental monitoring programs for this sector should be

implemented to address all activities that have been identified to

have potentially significant impacts on the environment, during

normal operations and upset conditions. Environmental

monitoring activities should be based on direct or indirect

indicators of emissions, effluents, and resource use applicable

to the particular project. Monitoring frequency should be

sufficient to provide representative data for the parameter being

monitored. Monitoring should be conducted by trained

individuals following monitoring and record-keeping procedures

and using properly calibrated and maintained equipment.

Monitoring data should be analyzed and reviewed at regular

intervals and compared with the operating standards so that any

necessary corrective actions can be taken. Additional guidance

on applicable sampling and analytical methods for emissions

and effluents is provided in the General EHS Guidelines.


Occupational Health and Safety Guidelines Occupational health and safety performance should be

evaluated against internationally published exposure guidelines,

of which examples include the Threshold Limit Value (TLV®)

occupational exposure guidelines and Biological Exposure

Indices (BEIs®) published by American Conference of

Governmental Industrial Hygienists (ACGIH),18 the Pocket

Guide to Chemical Hazards published by the United States

National Institute for Occupational Health and Safety (NIOSH),19

Permissible Exposure Limits (PELs) published by the

Occupational Safety and Health Administration of the United

States (OSHA),20 Indicative Occupational Exposure Limit Values

published by European Union member states,21 or other similar

sources.

Accident and Fatality Rates

Projects should try to reduce the number of accidents among

project workers (whether directly employed or subcontracted) to

18 Available at: http://www.acgih.org/TLV/ and http://www.acgih.org/store/ 19 Available at: http://www.cdc.gov/niosh/npg/ 20 Available at: http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9992 21 Available at: http://europe.osha.eu.int/good_practice/risks/ds/oel/


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a rate of zero, especially accidents that could result in lost work

time, different levels of disability, or even fatalities. Facility rates

may be benchmarked against the performance of facilities in this

sector in developed countries through consultation with

published sources (e.g. US Bureau of Labor Statistics and UK

Health and Safety Executive)22.

Occupational Health and Safety Monitoring The working environment should be monitored for occupational

hazards relevant to the specific project. Monitoring should be

designed and implemented by accredited professionals as part

of an occupational health and safety monitoring program. 23

Facilities should also maintain a record of occupational

accidents, diseases, and dangerous occurrences and other

kinds of accident. Additional guidance on occupational health

and safety monitoring programs is provided in the General EHS

Guidelines.

22 Available at: http://www.bls.gov/iif/ and http://www.hse.gov.uk/statistics/index.htm 23 Accredited professionals may include certified industrial hygienists, registered occupational hygienists, or certified safety professionals or their equivalent.


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3.0 References and Additional Sources Center for Tropical and Subtropical Aquaculture. 2001. Best Management Practices for Hawaiian Aquaculture. Publication No. 148. Waimanalo, Hawaii. Available at http://govdocs.aquake.org/cgi/reprint/2003/526/5260130.pdf

Department of Primary Industries and the Queensland Finfish Aquaculture Industry. 1999. Industry Environmental Code of Best Practice for Freshwater Finfish Aquaculture. Prepared by Dallas J Donovan, Kuruma Australia Pty Ltd. Queensland: Department of Primary Industries. Available at http://www.abfa.info/PDFS/Codeed2.pdf

Division of Applied Biosciences, Faculty of Fisheries, Graduate School of Agriculture, Kyoto University. 2004. Nitrogen and Phosphorus Budget in Coastal and Marine Cage Aquaculture and Impacts of Effluent Loading on Ecosystems?: Review and Analysis Towards Model Development (Abstract). Kyoto: Division of Applied Biosciences. Available at http://www.ncbi.nlm.nih.gov/entrez/ query.fcgi?cmd=Retrieve&db=PubMed&list_uids=15664033&dopt=Abstract

Euro-Retailer Produce Working Group (EUREP). EUREGAP. Available at: http://www.eurepgap.org/Languages/English/index_html

Food and Agriculture Organization of the United Nations (FAO). 1991. A Strategy for Aquaculture Development in Latin America. Rome: FAO. Available at http://www.fao.org/documents/show_cdr.asp?url_file=/docrep/008/u1780e/U1780E05.htm

FAO. 1997. Technical Guidelines for Responsible Fisheries 5. Aquaculture Development. Rome: FAO. Available at ftp://ftp.fao.org/docrep/fao/003/ W4493e/W4493e00.pdf

FAO. 2001. Report of the Technical Consultation on Legal Frameworks and Economic Policy Instruments for Sustainable Commercial Aquaculture in Africa South of the Sahara. Arusha, United Republic of Tanzania, 4–7 December 2001. Rome: FAO. Available at http://www.fao.org/documents/show_cdr.asp? url_file=/DOCREP/005/Y3575B/Y3575B00.HTM

FAO. 2002a. FAO Fisheries Technical Paper 428. Farming Freshwater Prawns. A Manual for the Culture of the Giant River Prawn (Macrobrachium rosenbergii). Technical Guidelines for Responsible Fisheries 5. Rome: FAO. Available at http://www.fao.org/documents/ show_cdr.asp?url_file=/docrep/005/y4100e/y4100e00.htm

FAO. 2002b. The State of the World’s Fisheries and Aquaculture (SOFIA). Rome: FAO. Available at http://www.fao.org/documents/show_cdr.asp? url_file=/docrep/005/y7300e/y7300e06.htm

FAO. Code of Conduct for Responsible Fisheries. Rome: FAO. Available at http://www.fao.org/documents/ show_cdr.asp?url_file=/DOCREP/005/v9878e/v9878e00.htm

FAO and World Health Organization (WHO). 1962–2005. Codex Alimentarius. Geneva: FAO and WHO. Available at http://www.codexalimentarius.net/web/index_en.jsp

Federation of European Aquaculture Producers (FEAP). 2000. Code of Conduct for European Aquaculture. Brussels: FEAP. Available at http://www.feap.info/FileLibrary /6/FEAP%20Code%20of%20Conduct.pdf

Francis-Floyd, R. 1996. Use of Formalin to Control Fish Parasites. College of Veterinary Medicine, Florida Cooperative Extension Service, Institute of Food

and Agricultural Sciences, University of Florida. Gainesville, FL: College of Veterinary Medicine. Available at http://edis.ifas.ufl.edu/VM061

Green, Bartholomew W. 2000. Level of Adoption of Selected Good Management Practices on Penaeid Shrimp Farms in Honduras. 36849-5419. Department of Fisheries and Allied Aquacultures, Auburn University. Auburn: Auburn University. Available at http://www.ag.auburn.edu/fish/

United Kingdom (UK) Health and Safety Executive (HSE). 2005a. Fatal Injuries Report 2004/05. Fatal Injuries in Farming, Forestry and Horticulture. Part 3: Non-Fatal Injuries in the Agricultural Sector, 1994/95–2003/04, pp.42–46. London: HSE. Available at http://www.hse.gov.uk/agriculture/pdf/fatal0405.pdf

UK HSE. 2005b. United Kingdom, Fatal Injuries Report 2004/05. Fatal Injuries in Farming, Forestry and Horticulture. Part 2: Analysis of Reportable Fatal Injuries in the Agricultural Sector, 1994/95–2003/04. p 23. London: HSE. Available at http://www.hse.gov.uk/agriculture/pdf/fatal0405.pdf

National Committee for Research Ethics in Science and Technology (NENT). 1995. The Holmenkollen Guidelines for Sustainable Industrial Fish Farming. Oslo: NENT.

National Committee for Research Ethics in Science and Technology. 1998. The Holmenkollen Guidelines for Sustainable Aquaculture. (Supercede the Holmenkollen Guidelines for Sustainable Industrial Fish Farming). Oslo: NENT. Available at http://www.ntva.no/rapport/aqua/report.htm

Northern Central Regional Aquaculture Center (NCRAC). 1992. Pond Culture of Walleye Fingerlings. Fact Sheet Series # 102. March 1992. In cooperation with the US Department of Agriculture (USDA). East Lansing, MI: NCRAC. Available at http://aquanic.org/publicat/usda_rac/fact.htm

OSPAR Commission. 1992. Convention for the Protection of the Marine Environment of the North East Atlantic. OSPAR. Available at http://www.ospar.org/eng/html/welcome.html

Shetland Aquaculture. 2006. A Code of Good Practice for Scottish Finfish Aquaculture , January 2006. Lerwick: Shetland Aquaculture. Available at http://www.shetlandaquaculture.com/code-of-good-practice

Southern Regional Aquaculture Center (SRAC). 1998. Fertilization of Fish Fry Ponds. SRA Publication No. 469. In cooperation with the US Department of Agriculture (USDA). Stoneville, MS: SRAC. Available at http://aquanic.org/publicat/usda_rac/fact.htm

SRAC. 1999. Fertilization of Fish Ponds. SRA Publication No. 471. In cooperation with the US Department of Agriculture (USDA). Stoneville, MS: SRAC. Available at http://aquanic.org/publicat/usda_rac/fact.htm

United Nations Environment Programme (UNEP) . 2001. Stockholm Convention on Persistent Organic Pollutants. Stockholm: UNEP. Available at http://www.pops.int/documents/convtext/convtext_en.pdf

United Nations Educational, Scientific and Cultural Organization (UNESCO). 1971. Convention on Wetlands of International Importance especially as Waterfowl Habitat (as amended in 1982 and 1987). Paris: UNESCO. 1994. Available at http://portal.unesco.org/en/ev.php-URL_ID=15398&URL_DO=DO_TOPIC&URL_SECTION=201.html

US Environmental Protection Agency (EPA). 2001. Office of Water, Engineering and Analysis Division. Update and Overview of the Effluent Limitations


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Guidelines and Standards for the Aquaculture Industry. NCRAC Meeting. 16–18 February, 2001. Washington, DC: US EPA. Available at http://aquanic.org/jsa/ effluents/EPA%20presentation%20at%20NCRAC.htm

United States (US) Bureau of Labor Statistics (BLS). 2004a. Census of Fatal Occupational Injuries Charts, 1992–2004. Table (p.10): Number and rate of fatal occupational injuries by private industry sector, 2004.) Washington, DC: BLS. Available at http://www.bls.gov/iif/oshwc/cfoi/cfch0003.pdf

US BLS. 2004b. Industry Injury and Illness Data — 2004. Supplemental News Release Tables. Table SNR05: Incident rate and number of nonfatal occupational injuries by industry, 2004. Washington, DC: BLS. Available at http://www.bls.gov/iif/home.htm

US Department of Commerce, National Oceanic and Atmospheric Administration (NOAA). 2005. National Offshore Aquaculture Act of 2005. Washington, DC: NOAA. Available at http://www.nmfs.noaa.gov/mediacenter/aquaculture/docs/ 03_National%20Offshore%20Aquaculture%20Act%20FINAL.pdf

US Department of Commerce, NOAA National Marine Fisheries Service (NMFS). Code of Conduct for Responsible Aquaculture Development in the US Exclusive Economic Zone. Washington, DC: NMFS. Available at http://www.nmfs.noaa.gov/trade/AQ/AQCode.pdf

US Food and Drug Administration (FDA). 2001. Center for Food Safety & Applied Nutrition. Fish and Fisheries Products Hazards and Controls Guidance: Third Edition. Washington, DC: US FDA. Available at http://www.cfsan.fda.gov/~comm/haccp4.html

United States Joint Subcommittee on Aquaculture (JSA) Working Group on Quality Assurance in Aquaculture Production. 2001. Guide to Drug, Vaccine and Pesticides in Aquaculture. Washington, DC: JSA. Available at http://aquanic.org/jsa/wgqaap/ drugguide/aquaculture_drug_guide.pdf

World Bank, ISME, cenTER Aarhus. 2003. Draft Code of Conduct for the Sustainable Management of Mangrove Ecosystems. Prepared by Professor Donald J. Macintosh and Dr. Elizabeth C. Ashton. Washington, DC: World Bank. Available at http://www.mangroverestoration.com/MBC_Code_AAA_WB070803_TN.pdf

World Bank. 2005. The NEPAD Action Plan for the Development of African Fisheries and Aquaculture. Washington, DC: World Bank. Available at http://siteresources.worldbank.org/ INTARD/Resources/ACTION_PLAN_endorsed.pdf

International and regional codes FAO Code of Conduct for Responsible Fisheries: http://www.fao.org/documents/show_cdr.asp?url_file=/DOCREP/005/v9878e/v9878e00.htm

FAO Technical Guidelines for Responsible Fisheries

o Aquaculture Development, 1997 ftp://ftp.fao.org/docrep/fao/003/W4493e/W4493e00.pdf

o Aquaculture Development 1. Good Aquaculture Feed Practice, 2001 ftp://ftp.fao.org/docrep/fao/005/y1453e/y1453e00.pdf

o Integration of Fisheries into coastal area management, 1996 ftp://ftp.fao.org/docrep/fao/003/W3593e/W3593e00.pdf

o Precautionary approach to capture fisheries and species introductions, 1996http://www.fao.org/documents/show_cdr.asp?url_file=/DOCREP/003/W3592E/ W3592E00.HTM

o Responsible Fish Utilization, 1998 ftp://ftp.fao.org/docrep/fao/003/w9634e/w9634e00.pdf

o Guidelines on the collection of structural aquaculture statistics,1997

Species introductions and Biodiversity FAO Technical Paper, International Introductions of Inland Aquatic Species 1988 http://www.fao.org/docrep/x5628E/x5628e00.htm#Contents

Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES), 1973. http://www.cites.org/

Convention on Biological Diversity (CBD), 1992. http://www.biodiv.org/convention/articles.asp

ICES/EIFAC Code of Practice on the Introductions and Transfers of Marine Organisms, 2004 http://www.ices.dk/reports/general/2004/ICESCOP2004.pdf

EIFAC Code of Practice and Manual of Processes for Consideration of Introductions and Transfers of Marine and Freshwater Organisms, 1988.

European Inland Fisheries Advisory http://cdserver2.ru.ac.za/cd/011120_1/Aqua/SSA/codes.htm

Health management and best practice CODEX Alimentarius. http://www.codexalimentarius.net/web/standard_list.do?lang=en

International Aquatic Animal Health Code, 2005. http://www.oie.int/eng/normes/fcode/a_summry.htm

FAO/NACA Asia Regional Technical Guidelines on Health Management for the Responsible Movement of Live Aquatic Animals and the Beijing Consensus and Implementation Strategy, 2000. http://www.fao.org/documents/show_cdr.asp?url_file=/DOCREP/005/X8485E/x8485e02.htm

FAO/NACA Manual of Procedures for the Implementation of the Asia Regional Technical Guidelines on Health Management for the Responsible Movement of Live Aquatic Animals. 2001. http://www.fao.org/documents/show_cdr.asp?url_file=/DOCREP/005/Y1238E/Y1238E00.HTM

FAO/NACA Asia Diagnostic Guide to Aquatic Animal Diseases, 2001 http://www.fao.org/documents/show_cdr.asp?url_file=/DOCREP/005/Y1679E/Y1679E00.HTM

Better-practice approaches for culture-based fisheries development in Asia http://www.aciar.gov.au/web.nsf/att/ACIA-6M98FT/$file/CBF_manual.pdf

Holmenkollen Guidelines for Sustainable Aquaculture, 1998. http://www.ntva.no/rapport/aqua.htm


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Development of HARP Guidelines. Harmonised Quantification and Reporting Procedures for Nutrients. SFT Report 1759/2000. TA-1759/2000. ISBN 82-7655-401-6. http://www.sft.no/publikasjoner/vann/1759/ta1759.pdf

Shrimp culture Bangkok FAO Technical Consultation on policies for sustainable shrimp culture, Bangkok, Thailand, 8-11 December 1997. http://www.fao.org/documents/show_cdr.asp?url_file=/DOCREP/006/x0570t/x0570t00.HTM

Report of the Ad-hoc Expert Meeting on Indicators and Criteria of Sustainable Shrimp Culture, Rome, Italy. 28-30 April 1998. http://www.fao.org/documents/show_cdr.asp?url_file=/DOCREP/006/x0570t/x0570t00.HTM

Code of Practice for Sustainable Use of Mangrove Ecosystems for Aquaculture in Southeast Asia, 2005 http://www.ices.dk/reports/general/2004/ICESCOP2004.pdf

The International Principles for Responsible Shrimp Farming, http://www.enaca.org/modules/mydownloads/singlefile.php?cid=19&lid=755

Codes of Practice for Responsible Shrimp Farming. http://www.gaalliance.org/code.html#CODES

Codes of Practice and Conduct for Marine Shrimp Aquaculture, 2002. http://www.fw.vt.edu/fisheries/Aquaculture_Center/Power_Point_Presentations/FIW%204514/Lecture%209.1%20-%20aquaculture%20and%20environment/shrimpCOP.pdf

National codes and best practices Canada: National Code on Introductions and Transfers of Aquatic Animals, 2003. Department of Fisheries and Oceans, Government of Canada. http://www.dfo-mpo.gc.ca/science/aquaculture/code/Code2003_e.pdf

Chile: Code of Good Environmental Practices (CGEP) for well-managed salmonoids farms, 2003. http://library.enaca.org/certification/publications/Code_2003_ENGLISH.pdf

India: Guidelines for Sustainable Development and Management of Brackish Water Aquaculture, 1995. http://www.mpeda.com/

Japan: Basic Guidelines to Ensure Sustainable Aquaculture Production, 1999.

Philippines: Fisheries Code, 1998. http://www.da.gov.ph/FishCode/ra8550a.html

Scotland: Code of practice to avoid and minimise the impact of Infectious Salmon Anaemia (ISA), 2002. http://www.marlab.ac.uk/FRS.Web/Uploads/Documents/ISACodeofPractice.pdf

Sri Lanka: Best Aquaculture Practices (BAP) for Shrimp Framing Industry in Sri Lanka http://www.naqda.gov.lk/pages/BestAquaculturePracticeMethods.htm

Thailand: Thailand Code of Conduct for Shrimp Farming (in Thai) http://www.thaiqualityshrimp.com/coc/home.asp

USA: Code of Conduct for Responsible Aquaculture Development in the U.S. Exclusive Economic Zone. http://www.nmfs.noaa.gov/trade/AQ/AQCode.pdf

Guidance Relative to Development of Responsible Aquaculture Activities in Atlantic Coast States, 2002. http://www.asmfc.org/publications/specialReports/aquacultureGuidanceDocument.pdf

USDA Aquaculture BMP Index, 2004. http://efotg.nrcs.usda.gov/references/public/AL/INDEX.pdf

Guidelines for Ecological Risk Assessment. of Marine Fish Aquaculture. NOAA Technical Memorandum NMFS-NWFSC-71. http://www.nwfsc.noaa.gov/assets/25/6450_01302006_155445_NashFAOFinalTM71.pdf.

Guidelines for Environmental Management of Aquaculture in Vietnam http://imagebank.worldbank.org/servlet/WDS_IBank_Servlet?pcont=details&menuPK=64154159&searchMenuPK=64258162&theSitePK=501889&eid=000310607_20061101130138&siteName=IMAGEBANK

Industry / Organization codes Australian Aquaculture Code of Conduct. http://www.pir.sa.gov.au/byteserve/aquaculture/farm_practice/code_of_conduct.pdf

Environmental Code of Practice for Australian Prawn Farmers, 2001. http://www.apfa.com.au/prawnfarmers.cfm?inc=environment

A Code of Conduct for European Aquaculture. http://www.feap.info/FileLibrary/6/CodeFinalD.PDF

NZ Mussel Industry Environmental Codes of Practice, 2002. Mussel Industry Council Ltd., Blenheim

Judicious Antimicrobial Use in US Aquaculture: Principles and Practices, 2003. http://www.nationalaquaculture.org/pdf/Judicious%20Antimicrobial%20Use.pdf

Draft Protocol for Sustainable Shrimp Production, in preparation. http://www.ntva.no/rapport/aqua.htm

BCSFA Code of Practice, 2005. http://www.salmonfarmers.org/pdfs/codeofpractice1.pdf


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Annex A: General Description of Industry Activities The aquaculture sector is very diverse, in terms of products and

production methods, as detailed in Table A-1.

Extensive systems24 use low stocking densities and no

supplemental feeding. Extensive systems may use man-made

ponds or, more often, existing natural structures (e.g. lakes or

lagoons) that are typically large (>2 ha). Semi-intensive

systems25 (approximately 2 to 20 tons/ha/yr) use higher stocking

densities, supplemental feeding, and additional management

(such as water changes) and typically utilize man-made ponds,

pens, or cages. Some semi-intensive systems, especially

polycultures, utilize natural lakes (e.g. filter feeders and

omnivorous fish can be cultured in cages in shrimp or prawn

ponds).26

Intensive systems27 use maximum stocking densities and are

dependent on a mixture of natural and formulated feeds. Semi-

intensive and intensive systems typically use small pond

compartments of up to 1 ha for ease of management. Site

selection for the aquaculture facility is often the most important

issue related to environmental health and safety. Criteria for site

selection include water supply and quality; soil quality;

protection from natural hazards; and accessibility to inputs,

24 Production system characterized by (i) a low degree of control (e.g. of environment, nutrition, predators, competitors, disease agents); (ii) low initial costs, low-level technology, and low production efficiency (yielding no more than 500 kg/ha/yr); (iii) high dependence on local climate and water quality; use of natural water bodies (e.g. lagoons, bays, embayments) and of natural often unspecified food organisms.] 25 System of culture characterized by a production of 0.5-5 tons/ha/yr, possibly supplementary feeding with low-grade feeds, stocking with wild-caught or hatchery-reared fry, regular use of organic or inorganic fertilizers, rain or tidal water supply and/or some water exchange, simple monitoring of water quality, and normally in traditional or improved ponds; also some cage systems e.g. with zooplankton feeding for fry. 26 Center for Tropical and Subtropical Aquaculture (2001). Other polyculture systems are practiced in Asia, primarily carp in association with duckeries and piggeries and the growth of crops on pond embankments. 27 Systems of culture characterized by a production of 2 to 20 tons/ha/yr, which are dependent largely on natural food, which is augmented by fertilization or complemented by use of supplementary feed, stocking with hatchery-reared fry, regular use of fertilizers, some water exchange or aeration, often pumped or gravity supplied water, and normally in improved ponds, some enclosures, or simple cage systems.

including markets and labor.28 An aquaculture facility requires a

steady supply of water in adequate quantities throughout the

year. Water supply should be pollution-free and have a stable

and suitable pH, adequate dissolved oxygen, and low turbidity.

Some producers may treat the intake water to remove unwanted

substances, for example, using a filter to remove potential

predators. In addition, aquaculture farms should not be located

close to each other, as this could increase the risk of disease

transfer and may have a detrimental effect on the water quality

of the intake water.

Table A-1. Diversity of Aquaculture Production Methodologies

Resource System Installations

Stillwater Ponds and lakes

Flow-through Ponds, raceways, tanks (land-based)

Cages (lake and sea based) Large offshore units (sea

based)

Water

(fresh, brackish, or

marine)

Re-use or recirculation Tanks and land-based ponds

Extensive (No feed)

Ponds (land-based) Substrate - shellfish (sea-

based) Substrate - seaweeds (sea-

based)

Semi-intensive systems (Supplemental feeding

and/or fertilizer)

Ponds (land-based) Raceways (land-based) Nutrition

Intensive systems (Feed)

Ponds (land-based) Cages (lake and sea based)

Raceways (land and sea-based)

Silos and tanks (land-based )

Monoculture Animals (ponds and tanks, cages/pens in lakes or sea)

Plants (ponds and tanks, cages/pens in lakes or sea) Species

Polyculture Animals (fish species)

28 Food and Agriculture Organization of the United Nations (FAO), 1989, ADCP/REP/89/43, Aquaculture Systems and Practices: A Selected Review. http://www.fao.org/docrep/T8598E/t8598e00.HTM.


APRIL 30, 2007 18

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WORLD BANK GROUP

The site should have soils adequate for the intended structures

(e.g. clay-loam or sandy-clay soil for ponds, and firm bottom

mud for pens) to allow the structure to be driven deep into

substrate for better support. Aquaculture facilities should be

protected from high wind, waves, and tides; excessive storm

water runoff; predators; and other natural hazards. Moderate

tides, however, may help to ensure adequate water exchange

through ponds, pens, and cages.

Figure A-1 presents the typical production cycle for an

aquaculture facility. The production period varies from species

to species and from region to region, depending on the market

requirements for size and on the growth rates for the species,

which is dependent on temperature, feed quality, and feed

allocation. Most operations have a grow-out period of 4 to 18

months.

Preparation and Stocking

Freshwater Ponds

Ponds are most commonly constructed by excavating soils and

using the spoils from excavation for the embankments. Soils

that are suitable for earthen pond construction have the

following characteristics: adequate clay content (clay slows

down or may even eliminate seepage), low organic content,

proper soil texture, and preferably alkaline pH. When producing

at high densities, or during the early stages of fry or juveniles,

ponds can be sealed with a plastic sheet or concrete, or

production can take place in sealed raceways or tanks to

facilitate cleaning.

Pens and Cages

Pen and cage systems involves the rearing of fish within fixed or

floating net enclosures supported by rigid frameworks and set in

sheltered, shallow portions of lakes, bays, rivers, estuaries, or

the seacoast. Pens and cages are largely similar. Pens are

anchored to the lake or sea bottom, which serves as the floor of

the pen, while cages are suspended in the water, and can be

either fixed or floating. Cages can typically be located in more

exposed situations and in deeper water than pens. Fry may be

grown to fingerling size in special nursery compartments and

then released to pens or cages for grow-out, or fingerlings for

stocking may be purchased from land-based facilities. In some

cases, the stocking material may be wild caught.

Open Water Culture

Seaweed and mollusks are typically farmed in open marine

waters. Structures (e.g. rafts, racks, or stakes) that provide a

growth surface for the intended species are placed in suitable

areas. Often the species to be grown settle by themselves on

the structures, and the producer will only remove unwanted

species and occasionally thin the stock. The aquaculture of

other species, notably oysters, requires more active

management and the spat or other juvenile stages are added to

the structures for on-growing.

Start-Feeding

The early stages of fish and crustaceans production often

demand a special feeding regimen, and the use of artificial

feeds for these early stages can be problematic. During the

initial feeding phase, organic and / or inorganic fertilizers (e.g.

nitrogen and phosphorus) are often added to create an algal

bloom. The algal bloom boosts primary productivity levels in the

pond by generating a food source for microorganisms such as

zooplankton, which are eaten by the fry or larvae of the

organisms being cultivated. The algal bloom also prevents the

establishment of aquatic plants. Veterinary drugs may be added

at this stage to reduce the risk of disease or in response to

actual outbreaks. A broad spectrum antibiotic is the most

frequently used medication.


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On-growing After start-feeding, a transition toward on-growing takes place.

The quality of the feed used can vary widely, depending on the

species grown and / or the level of sophistication of the farm

setup. A simple solution involves the use of minced fish meat

prepared at the farm site and offered daily throughout the grow-

out period. Intensive operations may exclusively use high-

quality, pelletized, formulated feed throughout the production

period.

During feeding, the biomass will increase, resulting in increased

oxygen consumption, and pond aerators (e.g. paddlewheels and

diffusers) are often used to aerate the water. During the on-

growing period, the stock are monitored regularly for disease

and willingness to eat, allowing the pond manager to intervene

(e.g. applying antibiotics and changing the pond water) if

unsuitable conditions develop.

Harvesting and Cleaning Once the stock has reached the desired size, they are

harvested and marketed. Some species are sold live, and others

are slaughtered before sale. In the latter situation, special

facilities for slaughtering may be installed at the farm (e.g. to

control the “blood water” resulting from harvest of the

organisms). The slaughtered product is then iced and may be

sent out for further processing off-site at a specialized fish

processing plant, or sold fresh to local markets.29

After harvesting, the aquaculture effluent may be conveyed into

a sedimentation basin before being discharged to the receiving

water. After the pond has been emptied, the pond bottom is

cleaned to remove the sediment of uneaten feed and feces. For

intensive and semi-intensive systems, ponds are usually

allowed to dry completely and are treated (e.g. with lime or

pesticides) to control diseases, competing organisms, and 29 Refer to the EHS Guidelines for Fish Processing for practical guidance on EHS issues in this sector.

predators before the next production cycle begins. In the case of

cages and pens, fouling on the nets may be removed in a

mechanical cleaning process, which is often followed by bathing

the nets in chemicals to reduce settling on the nets in the grow-

out period.

Stocking with fry or juveniles

Start-feeding of fry or juveniles

On-growing phase

Harvest and cleaning of

ponds, cages, or pens

Preparation of ponds

Figure A.1: Typical Production Cycle for an Aquaculture Facility


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Annex XIV Grievance Mechanism

COMPLAINTS PROCESS for the Pacific Regional Oceanscape Program (PROP) Project (aka Grievance Redress Mechanism (GRM))

1. Principles of the Complaints Process

• The Complaints process is for people seeking satisfactory resolution of their complaints on the environmental and social performance of the PROP project at the Ministry of Fisheries and Marine Resources Development in Kiribati.

• This Process is consistent with the Project’s Environmental and Social Management Framework (ESMF) Grievance Redress Mechanism (Section XIV).

• The mechanism will ensure the following: o the basic rights and interests of every person affected by poor environmental

performance or social management of the project are protected; and o their concerns arising from the poor performance of the project during the phases of

design, construction and operation activities are effectively and timely addressed.

2. How to get in touch: Anyone can make a complaint or grievance, ask for information on the project or get in touch for any reason. Complaints can be anonymous. The various ways to get in touch are:

1) By Phone: (686) 63010292 at PROP Project Office 2) By email: [email protected] with copy to [email protected] 3) By mail: Post Office Box 64, Bairiki, Tarawa, Kiribati, Central Pacific 4) In person: PROP Office, Lagoon Side, Bairiki, Tarawa, Kiribati. Give to Mr. Kuureta Toakai or put

in complaints/suggestion box at MFMRD Office above the Post Office in Bairiki. 5) Website: www.mfmrd.gov.ki

This information, and a brief summary of the process for answering queries and managing grievances, will be published on the MFMRD website, Kiribati Government information website on the MFMRD public bulletin board, and in consultation discussions particularly when involving the people of Kiribati and other Stakeholders.

3. Roles and responsibilities: The following are persons involved in the complaints process and their supporting roles and responsibilities.

1) Focal Point for managing the Kiribati PROP Complaints Process: Mr. Beero Tioti, Project Manager for the PROP Project.

http://www.mfmrd.gov.ki/


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2) Person who will manage the database and record keeping: Mr Kuureta Toakai at the PROP Office of at MFMRD.

3) Person who will answer simple queries and manage simple complaints: Mr. Beero Tioti, Project Manager for PROP Project.

4) Person who will manage difficult complaints or grievances: Mr. Teeta Erikate, Senior Assistant Secretary of MFMRD.

5) Person who will prepare report for World Bank reporting: Mr Beero Tioti. 6) Grievance Committee will be formed on an ad hoc basis for complex or significant grievance

management. This will be made up of appropriate senior officials (Senior Assistant Secretary level or above) from the following:

a. Ministry of Finance and Economic Development (MFED) with support from a Safeguards Specialist

b. Deputy Secretary, The Ministry of Fisheries and Marine Resources Development c. Ministry of Health and Medical Services d. Ministry of Environment, Lands and Agriculture Development.

4. The complaints process: 1) All complaints or grievances are entered into an assigned database that tracks progress of each

complaint/grievance. Complaints records (letter, email, record of conversation) are stored together, electronically or in hard copy. Each record has a unique number reflecting year and sequence of received complaint (i.e. 2018-01, 2018-02 etc.).

2) Each complaint/grievance is assigned a specific person responsible for close out. 3) Each complaint or grievance will have a plan for addressing and closing out:

a. Contractor or Fisheries officer or similar project person can address issues on site as required.

b. If it relates to Contractor activities, Project should ensure the Contractor remedies any damage, pays compensation for damage or loss, etc.

c. Use of community leaders and customary methods of conflict resolution is encouraged if necessary and appropriate when an issue emerges.

d. If an issue/complaint cannot be resolved on site, it is elevated to the Project Manager for resolution (with support from the Safeguards Specialist). If the Project Manager and Safeguards Specialist cannot resolve the issue, it is referred to the ad hoc Grievance Committee.

e. If a resolution cannot be found through the Grievance Committee, the next course of action is the courts of Kiribati or an independent mediator.

4) All simple complaints and grievances must aim to be closed out within 1 month. Complex complaints should aim to be closed out within 3 months or deferred to the Grievance Committee.

5) All complainants have the right to use the courts of Kiribati at any time to seek resolution. 6) The Project Manager will make adjustments to consultations, the GRM, community

engagement, project implementation and other aspects as necessary to avoid future complaints and grievances.


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5. Reporting and Evaluation 1) Complaints shall be reported in the regular project reporting to the World Bank. It should

contain: a. Total number of complaints / grievances received b. Total number resolved. c. Total number under investigation / not yet resolved. d. Total number not yet resolved and also exceeds the recommended close out time of 1

month or 3 months. e. Short paragraph on any significant grievances currently not yet resolved and any risks to

project implementation. 2) If there are more than 30 complaints / grievances recorded, the Project Manager may decide to

investigate any patterns or repetition of issues that need addressing. The Project Manager may decide to get an independent consultant to review and provide advice.

__________END__________


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Annex XV Physical and Cultural Chance Find Procedure Cultural property include monuments, structures, works of art, or sites of significance points of view, and are defined as sites and structures having archaeological, historical, architectural, or religious significance, and natural sites with cultural values. This includes cemeteries, graveyards and graves.

The list of negative subproject attributes which would make a subproject ineligible for support includes any activity that would adversely impact cultural property. In the event that during reconstruction or construction sites of cultural value are found, the following procedures for identification, protection from theft, and treatment of discovered artifacts should be followed and included in standard bidding documents.

Chance find procedures will be used as follows:

(a) Stop the earthworks, construction or land clearing activities in the area of the chance find; (b) Delineate the discovered site or area; (c) Secure the site to prevent any damage or loss of removable objects. In cases of removable

antiquities or sensitive remains, a night guard shall be present until the responsible local authorities and the relevant Ministry take over;

(d) Notify the supervisory Engineer who in turn will notify the responsible local authorities and the relevant immediately;

(e) Responsible local authorities and the relevant Ministry would be in charge of protecting and preserving the site before deciding on subsequent appropriate procedures;

(f) Decisions on how to handle the finding shall be taken by the responsible authorities and the relevant Ministry;

(g) Implementation for the authority decision concerning the management of the finding shall be communicated in writing by the relevant Ministry; and

(h) Construction work could resume only after permission is given from the responsible local authorities and the relevant Ministry concerning safeguard of the heritage.

These procedures must be referred to as standard provisions in construction contracts. During project supervision, the Site Engineer shall monitor the above regulations relating to the treatment of any chance find encountered are observed.

Relevant findings will be recorded in World Bank Supervision Reports and Implementation Completion Reports will assess the overall effectiveness of the project’s cultural property mitigation, management, and activities.


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Annex XVI Pre-Appraisal Stakeholder Consultation Reports

Third Project Preparation Mission Consultations - February 2019

The Safeguards team met with stakeholders during the Joint Project Safeguards Field Scoping and Programmatic Preparation Advance Planning Mission to Kiribati (Tarawa and Kiritimati) in February 2019. A summary of findings is below:

15 February 2019 – Meeting with MELAD (ECD and Lands Departments), in South Tarawa

The mission met with MELAD (ECD and Lands) in Tarawa, Kiribati to provide a brief introduction to the PROP project and to identify any synergies or overlaps with the Division’s work program. The Safeguards team provided an overview of the proposed project components and activities and discussed the changes to the proposed activities since the original PCN was circulated. The four KFSU central services unit safeguards positions were also outlined.

ECD confirmed that they will share information on their licensing requirements with the Safeguards team. If facilities under the project may trigger permitting requirements, ECD would like to be informed early. Any land required on the outer islands (e.g. jetties) will be obtained via lease agreements. The land for the MCS building’s and Fisheries Offices in Tarawa will be located Government land. On Kiritimati, all the land is Government Land.

Pollution Monitoring Activity

ECD have just started a program that is monitoring mercury levels in fish. It will initially be a scoping study to assess the status of the mercury coming into the country. They have also recently signed up to a regional program, Minamata Regional Assessment, that UNEP is funding to investigate fish toxicology. The focus is on mercury levels in fish. The study has just started and will continue to the end of 2019.

ECD expressed concern that the pollution studies proposed under the original PCN fell under ECD’s jurisdiction, that fisheries don’t have the resources or equipment to undertake the studies, and that there would be overlap with what ECD are already doing. The Safeguards team explained that the pollution studies originally proposed have been changed into fish health and food safety studies (e.g. ciguatera and e. coli) which are under MRMRD’s remit and that the original PCN will be updated.

Transshipment Facilities

The Secretary of MRMRD met with ECD team last year to discuss transshipment facilities in Tarawa, including landfilling requirements. ECD expressed some concern regarding the potential landfilling requirements and pollution from foreign fishing vessels who may dump waste into the water. The Safeguards team explained that this proposed project will not finance transshipment construction as the scale of the facility is too large and too expensive. Only scoping studies or feasibility studies for transshipment could be included. Therefore, no landfilling or additional pollution from vessels is anticipated as part of the PROP project. However, pollution from vessels and waste management should be considered in relevant TA sub-projects

19 February 2019 - Lands Division in Kiritimati

The mission discussed the structure of the land lease and land use management plan on Kiritimati. It is understood that, Kiritimati has land leases for 25 years (this may change to change to 50 years) which


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are renewable after the end of the lease terms. The process to obtain a land lease on Kiritimati are as follows:

1. The entity (individual/or company) writes to the government of Kiribati (GoK) to seek approval for a land lease (commercial or residential) application.

2. Permission is given by the local board (Kiritimati) to approve the building permit (commercial or residential).

3. Once the board approves, the government makes the decision.

*For large companies, the lease application is sent directly to the government.

The lease rate differs whether is for a commercial or a residential application. According to the lands division, plots of land have been mapped (map to be provided to the mission) but have been restricted to set dimensions of, for example: 23m x 44m squared. If entities wish to apply for a bigger area, the application will need to cover a large plot, for example applying for 2 of the 23x44m square area.

The government will, however, allow 1-year probation on the land lease and determine whether to terminate or continue the lease on the land, this applies for both commercial or residential lease permits. For residential leases, applications can only be made by one person per household, it is also a requirement that couples be married when they apply for a residential lease.

On Kiritimati, the land is owned by the government, this enables all decisions to be made directly by the government. The mission observed that applications made by the government for land use on Kiritimati is simpler, given the land is used for government purpose (i.e.: government facilities, schools).

In turn, consultations are not always required in London as the land is commercial and government owned.

21 February 2019 - Consultation with fishing guides

The mission met with the fishing guides at the Ministry of Line and Phoenix conference room. Many of the men (quite a large disparity between men and women fishing guides) who attended had different levels of experience in the fishing guide industry – it ranged from 2 to 20 years. The mission noticed that the fishing guides were attached to known hotels on Kiritimati, these include: The Captain Cook Hotel, Ikari House, Villages Resort, Sunset Motel.

Discussions centered on gaining information from the fishing guides on the pattern of fishing activities and learning about what tourists would be willing to pay, for a good experience. It was understood that the interest stems from experienced fishermen who travel to Kiritimati on a regular basis and know what to expect when they arrive on the island. The majority are mainly interested in fishing, bone and Grand Trevally (GT) fish. The mission raised a potential question of overpopulated fishing grounds, however the fishing guides believed that the lagoon is big enough to cater for everyone, but have noticed that nowadays a lot of the fishing has to be done further out into the lagoon to catch the best bone fish/GT.

Key dates for fishermen to arrive on Kiritimati are: winter (Dec/Jan/Feb) for the US market and Summer (July/August) for the Australian market. To date, the main attractions is fishing, very few fishermen bring their spouse unless they are into fishing as well. A Fishing Guide Association was in place but has been defunct for some time. The mission discussed the Fisheries Act with the fishing guides and understood


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that while the Act is in place, there is no mandate in place to enforce fines and regulate the catch. There is a weak law

First Aid

The fishing guides often take the fishermen out into the lagoon on long trips, where exposure to sun and sea have the potential for health risks. The mission discussed first aid with the fishing guides and noticed that there is little first aid training provided and many are not trained. Establishments such as Ikari House provide their own training to the boat operator and the fishing guides, but only basic first aid training.

All boats are equipped with life jackets and radios, however maintenance and ensuring that the boats have updated equipment may be an area where the mission can support to reduce the risk of incidents at sea.

25 February 2019 – Kiritimati Council, Kiritimati

Their priorities for economic development of the island include the fisheries and tourism sectors (aligned with MLPID), as well as the agriculture sector (e.g. coconut palm plantation rehabilitation, vegetables and root crops). A new strategic plan for the Council is due in 2019.

Education: lots of primary schools, one state junior secondary school in London, two church senior secondary schools in London only. The Ministry of Education is introducing pre-school education and Kiribati Institute of Technology will establish a branch that will teach 3 units (English, business, accounting).

All other tertiary education requires students to go to Tarawa or Fiji. Youth unemployment is an issue. There is a need for technicians, including mechanics and trades.

With respect to services, the following are available on Kiritimati:

- One landfill outside every village - ECD permits required for borrow pits - Water supply through individual wells and rain water tanks. The Council also pumps water from

designated water reserves to town. - Power: one power station services London, Takwea and Banana, one power station services

Poland

Supplies come in from Fiji every two to three months (Fiji – Tarawa – Christmas), there are also four domestic supply vessels per year. Since 2018, there are also supply vessels coming in from Honolulu.

27 February 2019 – Kiribati Port Authority, Kiritimati

The Kiritimati port in London only deals with container cargo ships. The wharf facilities are outdated and KPA are planning a second wharf to service fisheries. KPA is currently in talks with MFMRD and KFL but is not able to finance the new wharf. They are looking for funding.

KPA is a state-owned enterprise but operates as a commercial entity. Although KPA managed to break even, there are no funds for major projects. The large BDL container ships comes to port every three months, several smaller container ships call every two months. Although the business is not viable, it is critical to the local economy. Their oceanside location makes berthing very tricky due to large swells,


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their preferred location for the new wharf would be at the current fishing harbor (where CPPL is located).

With regards to the ongoing transshipment operations in the lagoon, they mentioned the following:

- KPA collects berthing fees from incoming carriers and assign berthing locations - There are no re-fueling operations in the lagoon, tankers come alongside in open sea only - The carriers and fishing vessels only discharge fish matter, which attracts tuna and is welcomed

by local fishermen - The port does not offer waste reception facilities, and the KPA is not aware of ongoing practices

of sewage discharge, although carrier vessels usually stay for over a month - With respect to the EU proposed location at Poland, KPA thinks it is a good location, but haulage

costs to London will be substantial and will increase prices of goods

27 February 2019 – Tourism Authority, Kiritimati

The Tourism Authority’s priorities are to build capacity among operators to develop products and costings. The Authority also assists with putting together visitor information. They don’t deal with walk-in tourists as the majority of tourists come in on package tours.

Packages currently available include:

- Surfing package (one group of surfers now at Little Flower Resort) - Sport fishing package - Bird watching (small number) - Swimming with dolphins and manta rays (Lagoon View Resort) - Cultural package / school visits / nuclear testing grounds and memorial

The Authority is working with the Ministry of Commerce on developing crafts on the island.

Until a few years ago, there were up to 10 large cruise ships calling to Christmas Island per year, now their routes have changed and only one or two cruise liners call annually.

The Authority is currently undertaking a training needs assessment among staff employed in tourism and will be looking for funding.


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Pre-Appraisal Consultations – November - December 2019

Betio ESMF Workshop, Kiribati

The ESMF consultation was held at the Betio Town Council (BTC) boardroom on the 21st of November 2019. Key stakeholders that came for the consultation were the Vice Mayor for BTC, BTC Assistant Clerk, BTC Project Officer and the key government ministries and representatives from fishing co-operatives.

The workshop was conducted by the PROP Project Manager, Beero Tioti, assisted by Senior Assistant Secretary, Teeta Erikate and Ms Titeem Auatabu (Media Officer).

Welcome and Introductions

The consultation was opened by Ms Auatabu with welcome remarks and all attendees introduced themselves. All attendees were given the ESMF flyer and the PowerPoint presentation was delivered in English and was translated into Kiribati.

Beero presented and overview of the PROP Project, the component including its duration. Beero then presented the ESMF and the GRM. The presentation was given in English but translated (sub-titled) in Kiribati. At end of the presentation, the meeting was opened for questions and comments.

Discussion and Stakeholder Feedback

The discussions were conducted in Kiribati. Key points of the discussion included:

1. Lagoon Demarcation: The Assistant Clerk from the BTC enquired to know if there are plans in the project to demarcate the 3 zones (BTC, TUC and North Tarawa Council) in the Tarawa lagoon. The BTC rep added that fishermen especially from TUC have been fishing in the BTC area without any license and sometimes use destructive fishing methods (e.g. using gill net with splash-method fishing). Beero responded that this can be looked into and that MCS program under the PROP Program can assist with the MCS activities in the Tarawa lagoon.

2. Land. PROP PM indicated that there are plans in the project to build a laboratory for seafood verification purposes and also a MCS facility in Betio. He further elaborated that there will further public consultation before the actual facility is constructed to ensure that are no issues/risks associated with the buildings with regards to land ownership, health or safety issues and or any other related issues.

3. Assistance to local fishermen: A rep from the Fishing Co-op was interested to know if the PROP project could assist with the provision of a boat that could act as a “mother-ship” that would assist in providing ice, processing their catch and loading onto their boat catches from the fishermen at sea. He added that most of their fishing boats are small therefore have low storage capacity. In most cases, they will have to return to shore if they have too many fish and also when they run low on ice. SAS Teeta responded by saying that this is probably a request that MFMRD will look into.

Conclusion

Ms Auatabu closed the workshop with a word of thanks to the participants for their attendance. She thanked the BTC Assistant Mayor for hosting this workshop and for their support.


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List of Participants

Name Organization & Community Teurakai Ukenio Assistant Mayor BTC Tenea Atere Assistant Clerk Taakea Fetulele Island Project Officer Simon Odhiambo Min of Commerce Ierevita Buuti Min of Commerce Donna Tekanene Min of Commerce Ruuta Tiira Min of Commerce Katherine Maruia CA/KSVA (MFMRD) Ioane Titaake Min of Information Communication & Transport Unikaai Teeabo Chairman, Betio Fishermen Cooperative Biritaake Motinang Secretary, Betio Fishermen Cooperative Iekerua Karoba Member, Betio Fishermen Cooperative Tiaon Mata Vice Chairman, Betio Fishermen Cooperative


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Kiritimati ESMF Workshop, Kiribati

The ESMF consultation was held at the Village, Tabakea, in Kiritimati on the 17th of December 2019. Key stakeholders that came for the consultation were the Mayor for Kiritimati, Mayors for Fanning and Washington Island. A rep from the Unimnwane (the Elders) of Kiritimati also came, and the key government ministries (MLPID), MELAD, Tourism also came with representatives from Pettish Operators Association.

The workshop was conducted by the PROP Project Manager, Beero Tioti and assisted by Ms Titeem Auatabu (Media Officer) and Karianako James.

Welcome and Introductions

The consultation was opened by the Deputy Secretary, Ms Teue Baikarawa with welcome remarks and all attendees introduced themselves. All attendees were given the ESMF flyer and the PowerPoint presentation was delivered in English and was translated into Kiribati.

Beero presented and overview of the PROP Project, especially with regards to the Blue Economy and the projects to be implemented in Kiritimati. Beero then presented the ESMF and the GRM. The presentation were given in English but translated (sub-titled) in Kiribati. At end of the presentation, the meeting was opened for questions and comments.

Discussion and Stakeholder Feedback

The discussions was conducted in Kiribati. Key points of the discussion included:

1. The Mayor from Kiritimati was pleased to hear of the PROP Project and how it will contribute towards Kiritimati Island development especially in fisheries and tourism. However, he is concerned that CPP will be taken over by KFL. He requested if the PROP project could assist in building a new facility so that local fishermen won't have to suffer when it comes to marketing their catch. Beero explained that given the budget constraints and the need to prioritise the 3 buildings to be constructed under PROP, he emphasized that PROP can only accommodate (fund) for a small office building for now.

2. Land. Beero indicated that there are plans in the project to build an office for seafood verification purposes, an MCS facility and a CPPL Office in Kiritimati. He further elaborated that there will further public consultation before the actual facilities are constructed to ensure that are no issues/risks associated with the buildings with regards to land ownership, health or safety issues and or any other related issues.

3. Sourcing PROP Funds - a rep from the Tourism Office is interested in securing funds from PROP and was advised that there will be funds to look into the development of the Kiritimati Blue Economy so there is likely chance of getting funds through PROP.

4. Assistance to local fishermen: A rep from the Unimane requested if funding through PROP could also focus at the grassroots to assist with local needs including fishing gear, including the construction of small canoes and FADs (Fish Aggregating Devices). He also requested if PROP could sponsor participants of local guides international fly-fishing competition such as the one held recently in Tasmania.


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Conclusion

The Deputy Secretary closed the workshop with a word of thanks to the participants for their attendance. She thanked the Kiritimati Island Council Mayor for their support of the workshop. She also acknowledge the attendance of all other Mayors including the Unimane, the Fisheries Assistants from Fanning and Washington Island and representatives from the Pet Fish and the private sector.

List of Participants