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Sub-sectoral Environmental and Social Guideline: Livestock and Perishable Foods Markets EBRD Sub Sector Environmental & Social Guideline 2016 Page 1 Livestock and Perishable Food Markets Introduction This guideline is designed to be used by EBRD Financial Intermediaries (FIs) to understand the nature of environmental and social (E&S) risks associated with existing operations in this sector and suggested actions for businesses to manage these E&S risks. It also provides guidance for FIs on potential due diligence questions to raise with management to understand how their business is managing these E&S risks. This guideline focuses on material E&S risks; it is not an exhaustive list. In managing E&S risks, all businesses should be compliant with relevant E&S laws and regulations. 1 Where applicable, this includes European Union legislation, which may also be taken as a benchmark for good practice. This guideline covers livestock markets and perishable wholesale food and flower markets (e.g. fruit, vegetables, flowers, meat, dairy products). Reference NACE codes: 46.2 Wholesale of agricultural raw materials and live animals 46.23 Wholesale of live animals 46.3 Wholesale of food, beverages and tobacco Material risks Below is an overview of the material risks present in the operation of livestock and perishable food markets. 1 This guideline outlines some relevant legislation but does not provide an exhaustive list of applicable laws and regulations.

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Page 1: SubSocial Guidel-sectoral Environmental and ine: Livestock and · 2020. 9. 9. · sewerage network or the water treatment plant (if any); Obtain any necessary permits to control discharge

Sub-sectoral Environmental and

Social Guideline: Livestock and

Perishable Foods Markets

EBRD Sub Sector Environmental & Social Guideline 2016 Page 1

Livestock and Perishable Food Markets

Introduction

This guideline is designed to be used by EBRD Financial Intermediaries (FIs) to understand

the nature of environmental and social (E&S) risks associated with existing operations in this

sector and suggested actions for businesses to manage these E&S risks. It also provides

guidance for FIs on potential due diligence questions to raise with management to understand

how their business is managing these E&S risks. This guideline focuses on material E&S

risks; it is not an exhaustive list. In managing E&S risks, all businesses should be compliant

with relevant E&S laws and regulations.1 Where applicable, this includes European Union

legislation, which may also be taken as a benchmark for good practice.

This guideline covers livestock markets and perishable wholesale food and flower markets

(e.g. fruit, vegetables, flowers, meat, dairy products).

Reference NACE codes:

46.2 Wholesale of agricultural raw materials and live animals

46.23 Wholesale of live animals

46.3 Wholesale of food, beverages and tobacco

Material risks

Below is an overview of the material risks present in the operation of livestock and perishable

food markets.

1 This guideline outlines some relevant legislation but does not provide an exhaustive list of applicable laws and regulations.

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Sub-sectoral Environmental and

Social Guideline: Livestock and

Perishable Foods Markets

EBRD Sub Sector Environmental & Social Guideline 2016 Page 2

Livestock and Perishable Food Markets

E&S Risk

Category

Environment

Health and

Safety

Labour

Community

Page

no.

Key E&S Risks2

AAffect the natural

environment

Affect the

health or safety

of employees

Affect

workplace

conditions

and the

treatment of

employees

Affect the health

and safety,

livelihoods, and

environment of the

community and

wider public

Water Use √ √ 5

Wastewater √ √ 5

Waste √ √ 6

Product Hygiene √ √ 7

Odour √ √ √ 7

Packaging √ 8

Refrigerants √ √ 8

Polychlorinated

Biphenyls

(PCBs)

√ √ 9

Asbestos √ √ 9

Slips, Trips and

Falls

√ √ 10

Collision Risk √ √ 10

2 Note: this table provides an indicative list of the EHS risks associated with the sub-sector; it is not meant to be an exhaustive list

and EHS risks will depend on the specific setting and scale of the operation or facility.

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Sub-sectoral Environmental and

Social Guideline: Livestock and

Perishable Foods Markets

EBRD Sub Sector Environmental & Social Guideline 2016 Page 3

Livestock and Perishable Food Markets

Sharp Edges and

Machinery

√ √ 10

Manual Handling √ √ 11

Hazardous

Materials

√ √ 11

Air Emissions √ √ √ 11

Fire √ √ √ 12

Animal Welfare √ √ √ 12

Biosecurity √ √ √ 13

Traffic

Management

√ √ √ 13

Community

Relations

√ 13

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Sub-sectoral Environmental and

Social Guideline: Livestock and

Perishable Foods Markets

EBRD Sub Sector Environmental & Social Guideline 2016 Page 4

Livestock and Perishable Food Markets

Contents

Section Page No.

1. Process Description .............................................................................................................. 5

2. Key E&S Risks ..................................................................................................................... 5

3. Financial implications ....................................................................................................... 14

4. Suggested due diligence questions .................................................................................... 14

5. References and additional sources .................................................................................... 19

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Sub-sectoral Environmental and

Social Guideline: Livestock and

Perishable Foods Markets

EBRD Sub Sector Environmental & Social Guideline 2016 Page 5

Livestock and Perishable Food Markets

1. Process Description

This guideline covers livestock markets

and perishable wholesale food and flower

markets (e.g. fruit, vegetables, flowers,

meat, dairy products).

The wholesale marketing and distribution

of grain is covered by Warehouse Receipts

and Commodity Trading Guideline and the

Grain Mills Products Guideline. The

wholesale of processed foods is covered in

the Food Outlets Guidelines.

2. Key E&S Risks

Below are the material E&S risks

associated with this sector and key

measures to manage them. Where gaps

are found in the management of key E&S

risks, the E&S risk management measures

may form part of a corrective E&S action

plan agreed with your customer.

Water Use

Livestock and wholesale perishable food

markets use large quantities of fresh water

for maintaining clean and hygienic

conditions, i.e. watering and washing

livestock, cleaning and disinfecting

vehicles and floors.

How can a business manage this risk?

Minimise water consumption through

reuse/recycling of clean water;

Store non-contact/rain water for use where

possible;

Ensure that product washing and cleaning

operations are conducted in a controlled

environment with appropriate water quality

control measures.

Wastewater

The effluent (wastewater) produced at the

market may generate pollution problems

due to the high content of manure,

vegetable matter, other organic material

and any cleaning detergents.

Discharge of wastewater to surface drains

and surface waters affects water quality in

three ways:

The discharge of biodegradable organic

compounds may cause a reduction of

the amount of dissolved oxygen in

water, which in turn may lead to

reduced levels of activity or even death

of aquatic life;

Macro-nutrients, such as nitrates and

phosphates may cause eutrophication of

the receiving water bodies. Excessive

algae growth and subsequent dying off

and mineralisation of these algae, may

lead to the death of aquatic life through

oxygen depletion;

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Social Guideline: Livestock and

Perishable Foods Markets

EBRD Sub Sector Environmental & Social Guideline 2016 Page 6

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Effluent may also contain pathogenic

and non-pathogenic viruses, bacteria,

and parasite eggs;

The effluent may contain chemicals or

substances that are directly toxic to

aquatic life;

Stormwater can become contaminated

when it comes into contact with animal

holding pens, sludge stockpiles and

treated wastewater irrigation areas.

Some markets have on site wastewater

treatment plants which may utilise

mechanical and chemical means of

treatment. Others may store the effluent in

tanks awaiting collection for off-site

treatment.

How can a business manage this risk?

Treat effluent prior to discharge (e.g. by

screening to capture organic solids); discharge

of the effluent directly to water bodies is

discouraged due to the high organic content and

potential to pollute water courses;

Install traps and/or grids to prevent animal

products and other solid materials from entering

the wastewater drainage system;

Reduce water volumes used through the use of

high-pressure hoses and re-use and recirculation

of water and use of re-circulated chilled water

systems where practicable;

Minimise the discharge of animal wastes

including manure, to drains, surface waters, the

sewerage network or the water treatment plant

(if any);

Obtain any necessary permits to control

discharge of water from the facility to water

courses or sewerage networks.

Waste

Inadequate waste handling may spread

disease and cause offensive odours. Solid

wastes arising from livestock and food

markets include:

Manure, bedding material and feed

from transport and lairage which can be

composted;

Animal carcasses;

Spoilt animal feed;

Unsold food or food spoiled through

spillage, inadequate storage or poor

handling.

How can a business manage this risk?

Maintain an inventory of waste volumes and

minimise generation where possible;

Store solid wastes in adequate containers,

segregated where possible to encourage

recycling. Dispose regularly of solid wastes to

avoid odour, litter, pest and rodent problems;

Employ waste segregation and reclamation

programmes;

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Social Guideline: Livestock and

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EBRD Sub Sector Environmental & Social Guideline 2016 Page 7

Livestock and Perishable Food Markets

Remove solid waste from transport equipment

and surface areas before rinsing and washing,

e.g. using scrapers, brooms and vacuum

cleaners;

Obtain any necessary permits for waste

disposal, and ensure that any wastes going off-

site go to licensed contractors;

Prohibit all fly-tipping of waste;

Dispose of unwanted animal remains in a

hygienic manner approved by local health

authorities;

Store spoilt animal feed so that it does not

become contaminated by domestic animals,

birds or rodents or encourage the growth of

moulds;

Wherever possible, use waste or spoiled food

for compost.

Product Hygiene

Contamination of the produce could result

in health impacts to the general public.

Several types of hygiene regulations will

apply to the markets. For example, EU

regulation 852/2004 on the hygiene of

foodstuffs seeks to ensure the hygiene of

foodstuffs at all stages of the production

process, from primary production up to

and including sale to the final consumer.

How can a business manage this risk?

Address hygiene standards in the treating,

handling and storage of animals and meat;

Carry out regular hygiene and animal health

checks at all stages of the process;

Design marketplace operations to

internationally-recognised food safety standards

consistent with the principles and practice of

Hazard Analysis Critical Control Points

(HACCP)3 and Codex Alimentarius

4;

Ensure that the requirements of EU regulation

852/2004 on the hygiene of foodstuffs are

complied with;

Consider implementing procedures and controls

to screen raw materials and products for

potential contamination from pesticides,

herbicides, radioactivity, heavy metals,

industrial pollutants.

Odour

Odour can be a serious problem for

livestock and perishable food markets if

effluent and waste streams are not

managed correctly, particularly when the

market is located near a residential area or

in a hot climate.

3 ISO 2005 4 FAO and WHO (1962–2009).

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Social Guideline: Livestock and

Perishable Foods Markets

EBRD Sub Sector Environmental & Social Guideline 2016 Page 8

Livestock and Perishable Food Markets

The main sources of atmospheric odour

are:

Overloading effluent treatment systems,

especially with organic materials, can

result in the emission of unpleasant

odours, including hydrogen sulphide;

Untreated effluent;

Other wastes such as unsold or spoilt

fruit and vegetables;

Animal carcasses.

How can a business manage this risk?

Maintain good housekeeping at all times in

retention areas. The adoption of good cleaning

and working practises as a routine will reduce

odour emissions;

Using measures to reduce the impact of odour

by cleaning pens and livestock yards on a timely

basis and emptying and cleaning fat traps

frequently;

Install ventilation within buildings;

Adopt appropriate odour management measures

to prevent odour nuisance to communities.

Packaging

Excessive packaging adds to costs and

waste levels and may be required to be

recycled or reused in certain markets. This

is particularly relevant for food export,

where food products must meet the

recycling standards in force in the export

market.

Companies operating with the European

Union (either as a manufacturer or as a

supplier into European Union countries)

will be subject to the European Union

Packaging and Packaging Waste Directive

(94/62/EC), which aims to reduce the

amount of packing that is being introduced

into waste streams.

How can a business manage this risk?

Companies operating in EU who fall under the

Packaging and Packaging Waste Directive may

implement a packaging waste management

system.

Refrigerants

Some perishable food markets may have

chilling facilities to preserve the products.

The refrigerants used may be ozone

depleting chemicals, such as

Chlorofluorocarbons (CFCs)

Hydrochlorofluorocarbons (HCFCs) the

production of which are being phased out

under the Montreal Protocol. Releases of

these types of refrigerant gases should be

avoided.

Ammonia is becoming a more commonly

used alternative refrigerant, which has no

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Perishable Foods Markets

EBRD Sub Sector Environmental & Social Guideline 2016 Page 9

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such restriction but does have health and

safety issues.

How can a business manage this risk?

Replacement of refrigerant gas or equipment

may be required to meet international standards;

Seal any leakages in the refrigeration system;

Change to non-CFC coolants and/or sealing of

leakages in the refrigeration system;

Implement a preventative inspection and

maintenance plan for the refrigeration

equipment, to reduce risk of accidental release

of gas;

Implement a plan for dealing with accidental

release of ammonia, with appropriate training of

personnel. The plan should include: evacuation

of affected area; ventilation of potentially

explosive atmosphere; removal of sources of

heat and ignition from the area; availability and

deployment of appropriate PPE for spill clean-

up; use of water spray to clean area of small

spills; and use of bunding and containment to

clean up larger spills.

Polychlorinated Biphenyls (PCBs)

PCBs are a group of substances which are

good electrical insulators. Typically,

PCBs may be present in hydraulic oils or

dielectric fluids in electrical switchgear

and transformers.

Though the presence of PCBs is not likely

to be a principal issue of concern in

livestock and food markets, it may be

present in equipment and be an

environmental and health and safety

hazard.

How can a business manage this risk?

Identify any electrical equipment (e.g.

transformers, large capacitors, heat transfer and

hydraulic systems) which were installed prior to

the 1990s. Seek advice on whether PCB fluids

are present, and if so, make a plan for their

replacement, taking proper care to dispose of

PCB-containing equipment according to the

requirements of Directive 96/59/EC.

Asbestos

Asbestos has been used on a large scale for

many years as a fire proofing and

insulation material and may be

encountered in a wide range of forms

including asbestos cement boards, as fire

retardant gaskets in pipework and as fire

retardant insulation around boilers and

furnaces.

How can a business manage this risk?

Particular attention should be paid to facilities

constructed prior to the 1990s.

Conduct/commission an asbestos survey (by

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qualified personnel);

If asbestos exists, establish if an asbestos

management plan is in place.

Slips, Trips and Falls

Slippery floors and wet surfaces present a

high risk of slips, trips and falls. Uneven

ground and poor housekeeping are also

common causes.

How can a business manage this risk?

Keep walking and working surfaces clean and

dry;

Maintain high standards of general

housekeeping within the market place and

supply/goods yards

Restrict access restriction to areas being cleaned

or where spillages have occurred;

Schedule floor cleaning for a time when work is

not in progress or has finished for the day and

floors have dried as much as possible.

Replace flooring in livestock markets with non-

slip stable surfaces.

Collision Risk

In a busy environment, it is common to

have injuries where people are struck by

moving or falling objects, such as animals,

crates, boxes and fork lift trucks, all of

which can lead to injury.

How can a business manage this risk?

Separate people from vehicle movement to

ensure the safety of workers, the community

and the public;

Equipment operators (e.g. fork lift trucks) to

operate machinery and equipment with due care

and attention to other workers ands the public;

Fit vehicles with rollover protective structures

and provide guarding of dangerous plant.

Sharp Edges and Machinery

Cuts and abrasions may occur to humans

and animals during handling.

How can a business manage this risk?

Keep all livestock areas free of sharp edges or

projections;

Issue workers with appropriate personal

protective equipment (PPE).

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Social Guideline: Livestock and

Perishable Foods Markets

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Manual Handling

Lifting, repetitive work and posture

injuries occur because of lifting and

carrying heavy or awkward shaped items

such as animal carcasses, live animals,

manure and other solid wastes. Repetitive

tasks can lead to musculoskeletal injuries.

How can a business manage this risk?

Install mechanical lifting aids where possible

and rotate work tasks to reduce repetitive

activities;

Train workers in appropriate lifting techniques.

Hazardous Materials

Bulk storage facilities will be used for

product storage, chemicals used for

cleansing and disinfection, and fuel oils for

energy production.

Effluent may also be stored in tanks

awaiting collection for treatment offsite.

The cleaning and disinfecting of sales,

storage and livestock areas and vehicles

uses materials that if inappropriately used

and stored could result in chemical contact

burns, inhalation of harmful/toxic fumes or

ingestion of harmful substances.

How can a business manage this risk?

Provide Personal Protective Equipment (PPE)

for chemical storage and handling;

Train personnel in the correct selection,

maintenance and use of PPE. Inspect PPE

regularly and main or replace as necessary;

Maintain storage areas to ensure that they are

organised, secure, clean and dry. Storage

facilities should be properly designed with

appropriate signage and ventilation, and should

be properly secured to prevent unauthorised

parties from gaining access, i.e. locked and

accessible only to trained and approved

personnel. They should be inspected on a

regular basis to ensure that leaks and spillages

do not occur;

Provide storage facilities with secondary

containment, e.g. concrete walls/bunds, or

recessed drainage gullies connected to effluent

treatment areas, to prevent spills reaching the

wider environment;

Conduct regular inspections/integrity testing of

tanks;

Install alarms to detect leakages.

Air Emissions

Dust may arise from storage, animal and

product handling; aerosols typically arise

from the use of compressed air and high-

pressure water for cleaning.

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Social Guideline: Livestock and

Perishable Foods Markets

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Workers may inhale or ingest the dust and

aerosols exposing them to biological and

microbial agents. When combined with

high levels of humidity they may give rise

to skin irritation or allergic reactions.

How can a business manage this risk?

Provide personal protective equipment (PPE)

that is fit for the task to prevent dust

exposure/risk and maintain hygiene standards.

Provide respiratory protective equipment (RPE)

for dusty operations as a last resort after other

abatement options are considered;

Train personnel in the correct selection,

maintenance and use of PPE;

Maintain high levels of housekeeping within the

market and storage/handling areas.

Fire

Fire in a marketplace can be disastrous.

Common causes of fire can include faulty

electrical appliances, overloading of

electrical circuitry, careless disposal of

cigarette ends, and spontaneous

combustion of dirty waste/packaging/rags,

especially if contaminated with oil or by

oil spillages in enclosed space.

How can a business manage this risk?

Introduce accident, fire and explosion

precautions and emergency procedures;

Maintain working areas, implement dust control

systems and limit the amount of dust build up in

the air.

Animal Welfare

The welfare of animals at markets may be

a matter of public concern and is

controlled under legislation. Humane

transport and care of animals is a

significant issue and is regulated under EU

Council Directive 93/119/EEC. Improper

treatment of animals may result in fines

and may impact on sales and markets.

How can a business manage this risk?

Provide separate storage and disposal

arrangements for animals that are sick or dead

on arrival;

Provide animals with adequate accommodation,

water, feed and bedding for the period they are

on site;

Implement traceability systems that facilitate

product/animal tracing after sale. In some

countries, this may be mandatory;

Provide adequate veterinary inspection,

including examination of medical certificates

for the animals. This may be mandatory in

some countries;

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Perishable Foods Markets

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Provide cleansing and disinfection for all

personnel and vehicles entering livestock areas;

Develop a programme to improve animal

welfare; improve animal enclosures where

appropriate

Biosecurity

There is a risk of disease being spread by

poor bio security controls.

Products may become contaminated

through poor storage conditions e.g. raised

moisture levels promoting insect, mould

and bacterial growth.

How can a business manage this risk?

Provide adequate cleansing and disinfection

facilities for all persons and vehicles entering

the site;

Treat sick or injured animals appropriately or

place them in an isolation pen. Animals not fit

for further transport may have to be humanely

destroyed;

Store carcasses awaiting collection

appropriately stored to prevent putrefaction.

Traffic Management

On market days, there will be a large

number of vehicles, including heavy goods

vehicles transporting animals and/or goods

to and from the site. This may result in:

Congestion and disturbance to

neighbouring businesses and residents,

which may result in complaints or in the

extreme legal action;

A road traffic accident which involves

the general public.

How can a business manage this risk?

Install wheel wash facilities at market exit

points;

Develop and implement a Traffic Management

Plan.

Community Relations

Having good relationships with

neighbouring communities reduces the risk

of local opposition to the market activities.

How can a business manage this risk?

Assess opportunities for the involvement of the

local community in direct employment or in the

provision of goods and services;

Engage with the local community and other

interested and/or affected stakeholders, on a

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regular basis, to maintain good social relations;

In areas of high population density or high

community interest, it is recommended that a

Stakeholder Engagement Plan (SEP) be

prepared and implemented by the company

3. Financial Implications

Outlined below are key financial

implications of ineffective management of

E&S risks related to livestock and

perishable food markets.

If contaminated products were

permitted to enter the animal and

human food chain, the financial

implications on a viable business would

be significant. Financial impacts may

arise form compensation claims, loss of

reputation, loss of contracts and export

markets. Significant upgrades in

hygiene standards may be required at

the production facility in order to

reduce the risk of contamination during

processing and to satisfy national and

international food hygiene standards;

Specific national or international

legislation and customer requirements,

e.g. animal welfare, bio security,

packaging and waste disposal may

require modification to facilities and

processes or require additional capital

investment;

Where large quantities of energy are

used then this can result in high

operating costs to the business;

Income may be generated through sale

of organic waste such as spoilt fruit and

vegetables for use as animal feed;

Injures may lead to increased payroll

costs to replace skilled workers and lost

production time;

Fines, penalties and third party claims may be

incurred for non-compliance with environment,

health and safety regulations.

4. Suggested Due Diligence

Questions

When assessing E&S risks, it is important

to engage the customer on how these risks

are managed.

Perform a complete tour of the market and

hardstanding/storage areas, accompanied

by someone knowledgeable about the

various activities. Make sure that all high-

risk areas are visited, including waste

storage areas, packaging areas, animal

storage pens, waste product storage and

disposal areas, plant and vehicle

maintenance areas etc.

Confirm organisational responsibilities and

systems for environment, health, safety

and social matters and that these systems

cover both employees employed directly

and sub-contractors.

During the initial site visit, the issues will

vary according to the size of operation and

the level of environment, health and safety

management already introduced. While

visiting the site it is important to discuss

and review the following:

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Social Guideline: Livestock and

Perishable Foods Markets

EBRD Sub Sector Environmental & Social Guideline 2016 Page 15

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General Housekeeping

What is the standard of “housekeeping”

on site? Do areas look clean and tidy?

Look for evidence that the walking and

working surfaces are kept clean and

dry;

Check signage around the site:

o Does it convey the health and safety

risks?

o Are fire exits clearly marked?

o Are there separate routes for

pedestrians and vehicles painted on

floor?

Environment, Health and Safety

Has the company undertaken a

systematic, documented review of

operations against national legal

requirements relevant to Environmental,

Health, Safety and Social performance

and the extent of compliance with that

legislation?

Confirm organisational responsibilities

and systems for environment, health

and safety;

Discuss the procedures and controls

around screening of raw materials and

products for potential contamination

from pesticides, herbicides,

radioactivity, heavy metals, industrial

pollutants;

Observe food hygiene standards at the

facility and the results of previous food

hygiene inspections; Are food

traceability systems used?

Does the organisation have insurance in

place to cover the recall of

contaminated products? Have there

been any recent product recall

incidents?

Check the condition and efficiency of

any wastewater treatment plant and

location of discharge points for

wastewater from the market. Note the

colour and appearance of adjacent

watercourses;

Note whether the wastewater treatment

plant discharges to a local watercourse

or the municipal wastewater treatment

works. Higher environmental risks will

be associated with facilities discharging

to water courses;

Is there a system of animal/food

traceability?

Check the condition of storage facilities

for chemicals;

Check the age and condition of

equipment, look for signs of wear and

tear, degradation, leaks and breaks;

Check the condition of storage facilities

for chemicals;

Note whether Health and Safety risks

have been systematically assessed and

addressed;

Have efforts been made to reduce

hazards through application of the

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hierarchy of controls i.e. eliminate,

substitute, engineer, administer then

issue personal protective equipment

PPE as a last resort (e.g. install noise

reduction equipment before resorting to

issuing hearing protection);

If PPE is required, check that it is being

supplied by the employer, is used

effectively and maintained/checked

regularly;

Is fire-fighting and first aid equipment

available?

Find out whether there have been any

fatalities/significant environmental

health and safety incidents in the past 3

years;

Disposal of Waste

Check that waste storage areas are clean

of debris and that are skips covered to

prevent waste escaping, for example,

check that waste containers have lids or

are stored in an area with a roof;

Check that waste storage and disposal

(storage equipment) is in a good

condition;

Check that waste disposal takes place

on a regular basis;

Animal Welfare

Check animal housing conditions,

observe livestock yards to see if animals

are moved calmly into facility and that

workers have escape routes, check staff

are trained in humane handling

methods;

Have there been any recent (within the

last three years) incidents on site such

as fatalities, fires/explosions, spills?

Are there insurances in place to cover

such incidents?

Is the facility subject to any audits by

customers? What was the outcome of

these audits?

Labour Management

Check that labour standards, contracting

and remuneration are in line with

national law and are consistent with the

average for the sector;

Check that hours worked, including

overtime, are recorded and staff should

receive written details of hours worked

and payment received;

Ask particularly about the working

hours, pay and conditions regarding

casual labour, and check what health

and safety provisions (e.g. PPE) are

provided for them; are these comparable

with employees?

Has the company received inspections

from the local labour, H&S or

environmental inspectorate in the

previous three years? Have these

resulted in any penalties, fines, major

recommendations or corrective action

plans? What is the status of these?

Has the company undertaken a

systematic, documented review of

operations against national legal

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requirements relevant to Environmental,

Health, Safety and Social performance

and the extent of compliance with that

legislation?

Does the organisation have a grievance

mechanism which allows employees to

raise workplace concerns?

Is a grievance mechanism in place to

allow the community to raise concerns

regarding market operations? Note any

history of public complaints relating to

the facilities operation;

Are employees free to form, or join, a

worker’s organisation of their

choosing?

Inspections, Permitting and Regulations

Note/enquire about communications

from/with the relevant local regulators

regarding non compliance/fines and/or

warning letters;

Note any fines/fees against the site;

Check the conditions and duration of

validity for all permits;

Have the premises been inspected

recently (within the past 2 years) by the

regulatory authorities for health, safety

and the environment?

Check waste discharges and water

abstraction permits;

Check whether the facility is next to any

industries which may pollute ground

water used in the process;

Is the facility subject to any audits by

customers? What was the outcome of

these audits?

Investment

Does the business plan have budgeted

line items for environment, health and

safety improvements? Are there any

high value improvements noted in the

business plan for Environmental, Health

and Safety issues in the coming

months/years?

Management Plans

Review the operational procedures and

management plans available to control

risks. As a minimum, any business should

be required to have the following in place:

Environmental, Health & Safety

management systems which include

operational procedures that are

communicated, implemented and

regularly reviewed (i.e. “live” systems

that are used in practice, not just kept as

an office manual);

Monitoring (and where necessary,

testing) programmes (water, air, noise,

etc.);

Improvement objectives, targets and

project plans;

Training programmes for personnel;

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Regular inspections, checks and audits

against records to demonstrate

achievement of the required level of

performance against legal requirements

and improvement action;

Emergency plans for environment,

health and safety incidents and site

security;

Demonstrable involvement of senior

management in environment, health &

safety management and leadership.

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5. References and additional sources

European Bank for Reconstruction and Development (EBRD). Environmental and Social

Policy May 2008. http://www.ebrd.com/downloads/research/policies/2008policy.pdf

International Finance Corporation, 2007. Environmental, Health and Safety Guidelines,

Annual Crop Production.

http://www.ifc.org/wps/wcm/connect/077b7f004885533bae2cfe6a6515bb18/Final+-

+Annual+Crop+Production.pdf?MOD=AJPERES

European Commission Regulation No 543/2011 on laying down detailed rules for the

application of Council Regulation EC No 1234/2007 in respect of the fruit and vegetables and

processed fruit and vegetables sectors http://eur-

lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2011:157:0001:0163:EN:PDF

European Commission, 2006. Integrated Pollution Prevention and Control, Reference

Document on the Best Available Techniques in the Food, Drink and Milk Industries.

http://eippcb.jrc.ec.europa.eu/reference/BREF/fdm_bref_0806.pdf

European Commission, 2008. Agriculture and Rural Development, Agriculture and

Environment.

European Commission, Food Safety, from the Farm to the Fork.

United Kingdom (UK) Government Department for Environment, Food and Rural Affairs

(Defra), 2006. Code of practice for using plant protection products.

International Labour Organization (ILO). Programme on Safety and Health at Work and the

Environment (Safe Work).

ISO22000:2005: Food Safety Management System – Requirements for any organisation in

the food chain.

ISO14001:2004: Environmental Management Systems – Requirements with Guidance for use