public disclosure authorizedmoenv.gov.jo/en/environmental_sectors/atmosphere... · 2019-05-08 ·...

$: Public Disclosure Authorizedmoenv.gov.jo/En/Environmental_Sectors/Atmosphere... · 2019-05-08 · 3.1 Commercial Refrigeration Manufacturing ... low permeability \chemical layer such$
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Hashemite Kingdom of Jordan

Ministry of Environment

National Ozone Unit

Ozone Depleting Substances HCFC Phase-Out Project (ODS3)

Additional Financing (AF)

Environmental Management Framework (EMF)

Final

May 22, 2017

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Abbreviations and Acronyms AC Air Conditioning AF Additional Financing CFC Chlorofluorocarbon CO Carbon Monoxide CP Country Program CP Cyclo-pentane DIN Deutsches Institut für Normung (German Institute for Standardization) ED50 Median Effective Dose EIA Environmental Impact Assessment EHS Environmental Health and Safety EMF Environmental Management Framework EMP Environmental Management Plan EPA Environmental Protection Agency ExCom Executive Committee FAA Fathei Abu Arja & Partners Industrial Co. FTOC Foams Technical Options Committee GAM Greater Amman Municipality GCC Gulf Cooperation Council GIIP Good International Industry Practice GWP Global Warming Potential HC Hydrocarbons HCFC Hydrochlorofluorocarbon HFC Hydrofluorocarbon HFO Hydrofluoroolefin HP High pressure HPMP HCFC Phase-out Management Plan IC50 Median Inhibitory Concentration ICC Incremental Capital Costs IEC International Electrotechnical Commission IOC Incremental Operational Costs ISO International Standards Organization ISR Implementation Status Report JFDA Jordan Food and Drug Administration JLVM Jordan Light Vehicle Manufacturing JMSS Jordan Manufacturing and Services Solutions KG Kilograms LD50 Median Lethal Dose LP Liquid propane MC Methylene Chloride MDI isocyanate MF Methyl Formate MIS Management Information Systems MLF Multilateral Fund for the Implementation of the Montreal Protocol MOE Ministry of Environment MOPIC Ministry of Planning and International Cooperation MP Montreal Protocol MT Metric Tons MW Molecular Weight

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NOU National Ozone Unit ODP Ozone Depleting Potential ODS Ozone Depleting Substances OEL Occupational Exposure Limit OECD Organization for Economic Cooperation and Development OH Hydroxyl value OHS Occupational Health and Safety OHSA Occupational Health and Safety Agency OP Operational Policy PDA Personal Digital Assistant PLC Programmable Logic Controller PMU Project Management Unit PU Polyurethane QIZ Qualifying Industrial Zones RTOC Refrigeration Technical Options Committee SAIP Secondary Air Injection Pump SGA Sub-Grant Agreement SMEs Small and Medium Enterprises SNAP Significant New Alternatives Policy TA Technical Assistance TEAP Technology and Economic Assessment Panel TLV Threshold Limit Value TRbF German Technical Regulations for Flammable Liquids (TRbF) UNEP United Nations Environment Programme UNIDO United Nations Industrial Development Organisation VOCs Volatile Organic Compound

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CONTENTS

Abbreviations and Acronyms ....................................................................................................................... ii

1. Executive Summary ........................................................................................................................... v

2. Introduction ........................................................................................................................................ 1

3. Baseline Project Locations and Physical Characteristics ................................................................... 2

3.1 Commercial Refrigeration Manufacturing .................................................................................... 3 3.2 Refrigerated Transport .................................................................................................................. 3 3.3 Domestic Refrigeration ................................................................................................................. 4 3.4 Foam Sector .................................................................................................................................. 4

3.4.1. Discontinuous Panels ..........................................................................................................................4 3.4.2 Continuous Panels ...............................................................................................................................4 3.4.3 Solar Water Heaters .............................................................................................................................4 3.4.4 Shutter Blinds ......................................................................................................................................5

4. Analysis of Alternative Technologies ................................................................................................ 5

5. Climate Change Impact Assessment ................................................................................................ 11

6. Applicable Jordanian Environmental Legislative Framework .............................................................. 12

6.1 Relevant International Legal Documents .................................................................................... 12 6.2 National Laws and Regulations ................................................................................................... 12 6.3 Applicable National Technical Guidelines/Standards ................................................................. 13

7. Applicable World Bank Safeguards Policies ................................................................................... 14

8. Institutional Arrangements ............................................................................................................... 15

9. EMP Requirements and Subproject Contracts ................................................................................. 18

10. EMP Monitoring and Reporting Specifics ....................................................................................... 29

11. Capacity Building/Training .............................................................................................................. 31

12. Consultations .................................................................................................................................... 33

13. Grievance Redress Mechanisms ...................................................................................................... 34

Annex 1: Governing Laws and Regulations Relating to Environmental Health and Safety ..................... 35

Annex 2: Risk Profile of Dosing, Mixing, and Processing PU ................................................................. 41

Chemical Hazard Review ....................................................................................................................... 41 Example: Foam Blowing Machine in Medium-Sized Factory .............................................................. 43 Fire and Explosion Risk Related to Foam Blowing with Hydrocarbons ................................................ 44

Annex 3: Sub-Project Generic EMP Template .......................................................................................... 47

Annex 4: Additional EMP Table for Cyclopentane Use ........................................................................... 52

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1. Executive Summary The Government of Jordan would like to address all remaining ydrochlorofluorocarbon (HCFC)-based foam manufacturing primarily through the Jordan Ozone Depleting Substances (ODS3) Additional Financing (Stage II). According to Jordan’s official 2015 data reporting of HCFC consumption, use of HCFC-141b in foam manufacturing amounted to 20.8 Ozone Depleting Potential (ODP) tons of bulk HCFC-141b use and 19.8 ODP tons of HCFC-141b in imported pre-blended polyol.

Elimination of all HCFC-141b consumed in Jordan in two sectors (foam and refrigeration) is in alignment with the Multilateral Fund (MLF) Executive Committee (ExCom) policy that HCFC-141b, which has a higher ODP than other HCFCs, is addressed as a priority, along with manufacturing. The removal of access to HCFC-141b in imported pre-blended polyol is expected to also remove any future pressure for an enterprise of the blending house to source bulk HCFC-141b.

The project will have a positive impact on the global environment by reducing the use of HCFCs, which are ozone-depleting substances and greenhouse gases with a global warming potential (GWP) ranging from several hundred to several thousand times that of CO2. While HCFCs have an impact on the global environment, they have no adverse local impact as these chemicals are stable and not considered toxic or otherwise dangerous for the environment. The project will include a series of investment activities with commercial refrigeration manufacturing, refrigerated transport, domestic refrigeration, and various foam sector entities. No closure, relocation, or expansion of enterprises is expected. All enterprises are located in industrial zones. Hydrocarbon, hydrofluoro-olefin (HFOs) and, possibly water/CO2 have been selected as blowing agents to replace HCFC-141b that is being used across the foam sector. Hydrocarbon has a GWP of less than 25. Hydrocarbon (cyclopentane) is classified as a Volatile Organic Compound (VOC), but its use results in very low levels of emissions of about 2-3% of the blowing agent. Therefore, there is no significant environmental impact from the chemical hydrocarbon itself. HFOs, also known as unsaturated hydrofluorocarbons (HFCs), are emerging blowing agents that have no ODP and GWPs under 5 and are considered by HFO producers nonflammable. The other chemicals involved in foam production are MDI (isocyanates), amine catalysts and fire retardants. The foam enterprises purchase pre-formulated polyol (blended with or without HCFC-141b) and polymeric MDI for their rigid foam production. The probability that a spill of polymeric MDI (a liquid at room temperature) contaminates the soil and water is very low, because the floor of the foam production areas consist of cement coated with an anti-leakage, low permeability\chemical layer such as epoxy. In the case that MDI leaks into the soil, it will react with the moisture/water, and the reaction would result in CO2 and insoluble polyurea compounds, which are not biodegradable but chemically inert. Fire retardant and amine catalysts (very limited amount) are mixed/pre-formulated in the polyol at the system houses (pre-blended polyol suppliers), from which the foam enterprises purchase pre-blended polyol and MDI, so the foam enterprises will not handle these toxic chemicals directly. Fire retardant and amine catalysts will remain in the final foam products and are not likely to be emitted to the environment during the foam production or later. Therefore, there are no anticipated legacy environmental contamination issues that are associated with the production at the foam enterprises. However, safety requirements associated with hydrocarbons (cylco-pentanes under the project) due to the flammability may still present operational challenges for smaller foam enterprises. Therefore, the Environmental Assessment (OP/BP 4.01) policy is triggered.

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Based on the above, it is not considered necessary to prepare an Environmental Impact Assessment (EIA); rather, an Environmental Management Plan (EMP) for enterprises’ use during the project implementation stage will address the safety concerns of hydrocarbon.

In addition to this overall EMF, the enterprises have also been requested to prepare their site-specific EMPs as an integrated part of their subproject proposals in order to participate in the Project and receive access to any funding. The enterprises’ managers and operational staff will be trained annually on environment and health/safety requirements during the foam conversion under the Project. Safety audits before the start-up of normal foam production using hydrocarbons will be carried out by technical consultants hired by the National Ozone Unit (NOU). World Bank supervision missions will also follow up on implementation of the EMP. Technical assistance (TA) is required under the proposed sector plan for the enterprises and the country to ensure efficient and effectual phase-out across the sectors and nation-wide. This will be made up of training workshops for the foam and refrigeration enterprises, training of government officers, organized industry consultations, study tours on HCFC alternatives, information management for monitoring of HCFC-using sector, and consultant services on alternative technologies. The Technical Assistance and Policy Component of this Jordan ODS3 AF project is allocated as $215,129. These funds will support the activities detailed above. Additionally, one of the staff in the project management unit (PMU) in the NOU will be dedicated to supporting conversions in the facilities, including environmental safety concerns and training associated with technology changes. The budget for the percentage level of effort dedicated to environmental safeguards support for this staff member is estimated at $10,000/year. The total budget of the ODS3 AF partially or fully dedicated to environmental safeguards is estimated at $215,129, which is approximately 10% of the total ODS3 AF budget.

Complaints Resolution Mechanisms relating to this project are located in the Ministry of Labor and the Ministry of Environment. Safeguards performance reporting will be made public as part of the Implementation Status Reporting (ISR) dissemination process, available on the www.worldbank.org website, on the Jordan country page, under the “projects” tab.

http://www.worldbank.org/

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2. Introduction Hydrochlorofluorocarbons (HCFCs) are substances used in several manufacturing sectors but primarily as refrigerants in refrigeration and air-conditioning (AC) equipment and as blowing agents for producing foam. HCFCs were introduced as transitional substances to chlorofluorocarbons (CFCs) given that they have a much lower ozone depleting potential (ODP). Nonetheless, as ozone-depleting substances (ODS), HCFCs are now also subject to control measures of the Montreal Protocol (MP) on Substances that Deplete the Ozone Layer (an international environmental treaty with universal ratification) following the complete elimination of CFCs. The Government of Jordan would like all remaining HCFC-based manufacturing to be addressed in HCFC Phase-Out Management Plan (HPMP) Stage II which, according to the 2015 Country Programme (CP) amounts to 20.8 ODP tons of bulk HCFC use and 19.8 ODP tons of HCFC-141b in imported pre-blended polyol.

Elimination of all HCFC-141b consumed in Jordan in two sectors (foam and refrigeration) is in alignment with the Multilateral Fund (MLF) Executive Committee (ExCom) policy that HCFC-141b, which has a higher ODP than other HCFCs, is addressed as a priority, along with manufacturing. The removal of access to HCFC-141b in imported pre-blended polyol is expected to also remove any future pressure for an enterprise of the blending house to source bulk HCFC-141b.

Consequently, addressing the allocated phase-out of controlled substances across Jordan’s economy, along with the required grant funding, technical assistance support and policy measures will permit Jordan to comfortably meet compliance requirements in 2020 (reduction of the HCFC baseline level by 35%), while advancing significantly the reductions towards the next MP target in 2025.

The foam sector is completely dependent on HCFC-141b in pre-blended polyol and thus the use of HCFC-141b extends well beyond what is considered as a controlled substance by the Montreal Protocol (the bulk amount) with official records indicating 350.1 metric tons (MT) in total. Jordan’s strategy for the second stage of its HCFC Phase-out Management Plan that addresses HCFC control targets in 2018 through 2022 proposes to tackle all uses of HCFC-141b,.

Consumption of HCFCs is predominantly by small and medium size enterprises (SMEs). There are only four enterprises with consumption of HCFCs over 20 MT. This small consumption on an enterprise level affects the type of alternative technology that can be introduced as well as funding levels. Consequently, the Stage II approach will entail a combination of individual investment subprojects and a separate implementation modality for SMEs, either simple subgrant agreements or a group project.

Because the majority of recipients are SMEs, a third party will most likely be required to ensure systematically that not only do enterprises have the capacity to effectively utilize the new technologies, but that they do so in a safe manner. Traditionally, system houses can play this role in training and sharing know-how as well as ensuring safe operation with the isocyanate (MDI) and ensuring that exposure to MDI vapour is minimized. World Bank environmental and social safeguard policies will ensure that this part of the delivery approach is included by the country and technical assistance support will allow this to be addressed in implementation.

Complete HCFC-141b phase-out in both foam and refrigeration will require a national ban in manufacturing with HCFC-141b, similar to the one that was introduced for air-conditioning containing HCFCs at the end of 2016. These bans will be mirrored and timed with a ban of import of products containing HCFC-141b, including pre-blended polyol. The added difficulty of controlling imports of HCFC pre-blended polyol was recognized, particularly at this time where no supplier is able to provide feasible alternative pre-blended polyols. Ongoing

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monitoring of technological developments, outcomes of MLF-supported demonstration projects (such as the Bank demonstration on HFO technology for SMEs in the foam sector in Thailand which is expected to be completed by end 2017) and follow-up with regional and local polyol suppliers will be required from now until subproject preparation, technical appraisal and implementation start.

The October 2016 hydrofluorocarbon (HFC) amendment of the Montreal Protocol on Substances that Deplete the Ozone Layer is hoped to speed-up the commercialization of non-HFC options for Jordanian enterprises to access. In the time between Stage II approval and start of implementation of individual and group conversions, technical assistance (TA) will be used to confirm the status of availability and costs of alternatives in the sector with known suppliers, importers and industry stakeholders for the wider group of enterprises. Workshops will also be organized to inform manufacturers of Jordan’s commitments to eliminating HCFCs and state and cost of HFO and water-based technologies, as well as other low-GWP alternatives such as c-pentane. Study tours for implementation staff, enterprise representatives and when decided, the group project coordinator(s) will be organized to demonstrate the use of HFO technology. The overall Stage II HCFC phase-out approach will therefore be to concurrently pursue sector-wide phase-out of HCFC-141b used in manufacturing foam to maintain, and meet new national level phaseout targets according to the MP HCFC phase-out schedule. The intervention as a whole would have positive climate outcomes (a net reduction in CO2 eq. emissions). To ensure sustainable phase-out and a level-playing field for enterprises in respective sectors, policy and regulatory measures will need to be put in place accordingly. Technical assistance would also be provided to HCFC-consuming enterprises and associated government agencies, in addition to project management funds for a project management unit within the NOU which would manage the overall HPMP and implement the group projects and support the individual subprojects (technical and financial appraisal, preparing subprojects and sub-grant agreements (SGAs), etc.). Jordan’s Stage HPMP will include the management and oversight by UNIDO, which acts as a “Cooperating Agency” upon Jordan’s request, of the conversions at six enterprises in the sprayfoam subsector. In addition, given that the servicing sector is of greater significance than originally estimated, and hence in terms of Jordan’s ability to comply with MP obligations, 100 MT of HCFC-22 consumption phase-out from this sector is included in Jordan’s Stage II HPMP but under UNIDO implementation. .

3. Baseline Project Locations and Physical Characteristics

As part of project preparation, site visits where conducted to 30 of the 69 possible participating enterprises. Most of the manufacturers (foam product manufacturers, commercial refrigeration, refrigerated transport, domestic refrigeration) are located in industrial estates on the periphery of Amman. A few are located in Qualifying Industrial Zones (QIZs) outside of Amman, near Mafraq or Irbid. With regards to the foam sector companies, most of the large sandwich panel manufacturing are similarly in the industrial zones on the periphery of Amman. The small hand-mixed foam businesses are more diffusely distributed across the large towns in Jordan, including several in Aqaba as part of the Aqaba Special Economic Zone.

Most enterprises producing refrigeration equipment are Amman-based, medium-sized Jordanian-owned family businesses which market not only to Jordan, but also to Gulf Cooperating Council countries, such as Saudi Arabia and Kuwait. A few enterprises have branched out to sheet metal forming and cutting, in order to manufacture customized refrigeration equipment. Almost all enterprises’ foaming operations in commercial refrigeration, including sandwich panels, are hand-poured.

Most Amman-based enterprises are located either on the south or south-east side of Amman, with a few enterprises located on the north-east side of Amman on the road to Zarqa. This is a result of a May 1963 municipal decision

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to move all service workshops and light industry outside the inner city and allocate them on the southern outskirts of Amman. This decision was reinforced by zoning code in 1974. These originally industrial-zoned areas moved further out of Amman, again in the south and south-east, with a new industrial policy launched by Greater Amman Municipality (GAM) in 1987. The policy established principles for relocation existing industries as well as establishing new ones. Refrigeration industries are considered ‘light to medium’ manufacturing, and are mostly located outside formal QIZs. Instead, these enterprises are clustered in industrial neighborhoods with low-to-no residential populations, transportation and utility services built to support demands of industry, and public and private commuter transportation options for workers.

3.1 Commercial Refrigeration Manufacturing The demand for commercial refrigeration in Jordan continues to grow due to increases in population and climatic conditions. There is a wide spread use of hypermarkets, large/small supermarkets cold rooms, horizontal and vertical medium temperature and low temperature display cabinets, refrigerated cabinets for the convenience shops, butcher shops in the country. The use of commercial refrigeration equipment is directly linked to safety and health needs for food production, handling, storage and sales. Commercial refrigeration equipment must meet technical specifications and standards stipulated by the Jordan Food and Drug Administration (JFDA). The typical commercial refrigeration equipment manufactured in Jordan are:

• Standalone refrigeration equipment (plug-in units) which are typically low and medium temperature freezers, fresh food and frozen food display cabinets of various types;

• Condensing units typically installed in bakeries, butcher shops, convenient stores and small super markets including cold rooms, frozen food storage rooms;

• Centralized refrigeration systems for supermarkets and • Cold storage rooms for hotels, shops and for the food industry.

There is customized manufacturing of commercial refrigeration equipment for restaurants grocery shops meat shops etc. This is mainly catered by small manufacturers. HCFC-22 is used as refrigerant and 141b as foaming agent. All the commercial refrigeration equipment manufacturers use pre-blended polyols procured from the systems houses within the country or system suppliers. HCFC-141b consumption in the commercial refrigeration subsector is distributed across 23 enterprises: five with consumption that ranges from 2,400 to 8,800 kilograms (kgs) per year and the rest with consumption ranging from 200 to 1,400 kg per year.

3.2 Refrigerated Transport Jordan has several companies providing refrigerated transport as first reported in the Stage I HPMP however none actually manufacture these vehicles, with the exception of three companies that do manufacturer sandwich panels with HCFC-141b. All these companies are in the business of repair and servicing of refrigerated systems. It is estimated that more than 2000 refrigerated trucks are on the road in Jordan, however, more and more use HFCs as refrigerants. These enterprises also consume small amounts of HCFC-141b pre-blended polyol to produce sandwich panels, done by hand-pouring (with the exception of Abdin). Most of this pre-blended polyol is purchased by the sole local blending house in Jordan, Fathei Abu Arja & Partners Industrial Company (FAA). Total 2015 HCFC-141b (in pre-blended polyol) was estimated to be 37.1 MT (4.1 ODP MT).

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3.3 Domestic Refrigeration Jordan has several domestic refrigeration equipment manufacturing companies which use cyclopentane as a foam blowing agent and R-134a as a refrigerant. These companies were financed by MLF to replace CFC use. The exception is Abu Haltam Group for Investments Company, one of the beneficiaries of the Stage I HPMP, which continues to manufacturer refrigerators using HCFC-141b for the insulation part and HFC-134a for the refrigerant part. There is one relatively small enterprise, Abu Haltam for Investments and Home Appliances Co. that still uses HCFC-141b as a blowing agent for domestic refrigeration. It consumes close to 170 MT of polyurethane (PU) systems per annum.

3.4 Foam Sector

In the Jordanian foam sector all the HCFC-141b is used for the manufacture of PU rigid foam. The small amount of integral skin foam locally manufactured is blowing with CO2 (water). Bulk HCFC-141b consumption was 170 MT in 2015, whereas 180 MT of HCFC-141b was imported in pre-blended polyol (as per CP data). The sector is dominated by sandwich panel manufacturing and spray foam but also includes foaming for domestic refrigerators, commercial refrigeration (as mentioned above), solar water heaters, shutters and piping. Demand for foam paneling has boomed the last several years due to the refugee crisis in the region. More than the 350 MT of HCFC-141b consumption was accounted for through the survey and preparation work among these applications for 2015. 3.4.1. Discontinuous Panels The largest subsector of the foam market is discontinuous panels, dominated by seven local companies with individual HCFC consumption from 11,800 up to 35,000 kg. These seven companies account for 92% of the total HCFC-141b usage in this subsector. The most common substrates are pre-painted steel, aluminium and plywood, and the standard moulded foam density ranges between 38 and 42 kg/m3. In addition to these enterprises, another eight companies that manufacture discontinuous panels have been identified. Their HCFC consumption ranges from 600 to 2,500 kg/year. Four of them own liquid propane (LP) dispensers and the rest use hand-mix operations. 3.4.2 Continuous Panels There is one enterprise that produce continuous insulating panels eligible for MLF funding. This compnany consumes HCFC-141b, and started manufacturing discontinuous panels in 1992. In 2004, a two-component continuous machine with a linear speed of 6-7 m/min and equipped with a Secondary Air Injection Pump (SAIP) high-pressure (HP) dispenser, replaced the discontinuous line. The line produces B-2 and B-3 sandwich panels of 25 meter long and thicknesses from 40 to 150 mm. Substrates used for faces are pre-painted steel, aluminium and Kraft paper. The estimated consumption of HCFC-141b in 2015 was 23,800 kg.

3.4.3 Solar Water Heaters The manufacture of solar water heaters is a highly dispersed market with more than 19 small enterprises where consumption of HCFC-141b ranges from 400 to 1,800 kg and with only one medium-size factory that uses around

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6,000 kg/year. The foam is mostly applied by hand-mixing. Only one LP dispenser has been identified to be in use across the subsector.

3.4.4 Shutter Blinds The production of aluminum blind shutters for windows and entrances is popular in Jordan. There are three enterprises with an annual HCFC consumption ranging from 3,500 to 4,550 kg. The production lines consist of an aluminum sheet-forming unit followed by a low LP dispenser with a small polyol/isocyanate throughput (45 g/s). A typical width of the PU insulation layer between aluminum plates is 10 mm and the foam density ranges from 45 to 55 kg/cm3 to ensure an appropriate mechanical strength.

4. Analysis of Alternative Technologies

This section outlines the state of alternative technologies to HCFC-141b in the air-conditioning, refrigeration and foam sectors (see Annex 3 for detailed analysis using a risk profile approach). The following factors need to be considered in the selection of alternative technology:

Table 1. Factors to be Considered in Selecting Refrigerant Technology Factors Considerations

Technical Factors

• Thermo-physical characteristics • Functionality in end product • Proven and mature technology • Energy efficiency

Commercial factors

• Cost-effectiveness • Reliable availability

Health and safety factors

• Low risk for occupational health • Low risk for physical safety (flammability,

etc.) Environmental factors

• Zero ozone impact • Low direct and indirect climate impacts

The review and update of technical options for HCFC replacement is being carried out periodically and is being reported in United Nations Environment Programme (UNEP) Refrigeration Technical Options Committee (RTOC) reports and the summary updates annually in Technology and Economic Assessment Panel (TEAP) reports. The traditional replacements for this sector and sub-sectors cited are HFCs, blends of HFCs, hydrocarbons and ammonia. However, with the ongoing discussions on phase-down of HFCs under the Montreal Protocol, the focus has been shifted towards low-GWP alternatives. Flammable Options to replace HCFC-141b

Hydrocarbons. The main route for PU rigid foams is to use hydrocarbons (HC), principally pentanes (n-pentane, cyclopentane and cyclo/iso-pentane blends), and technologies have been well established to allow their safe use, with the only exception of spray applications. The major drawback with the hydrocarbon family is their flammability. This has a strong impact on both the capital costs for processing -to ensure that safety is properly engineered- and on product handling, which is particularly problematic for smaller enterprises. This is not the case of domestic refrigeration and large enterprises of commercial refrigeration and continuous panels. Specifically for

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this application the blowing agents of choice are cyclopentane and iso/cyclopentane blends. n-Pentane is very popular for continuous panels because of its cost/performance balance. Formulations for PU foams based on these hydrocarbons have been refined and their insulation performance, expressed by foam thermal conductivity, is similar to those for HCFC-based foams. The following table describes the properties of typical hydrocarbons:

Table 2. Hydrocarbons

Cyclopentane n-Pentane Iso-Pentane Iso-Butane n-Butane

Chemical Formula

(C5H10) CH3(CH2)3

CH3 CH3CH(CH3)CH

CH3 CH3CH(CH3)

CH3 CH3CH2CH2C

H3

Molecular Weight

70.1 72.1 72.1 58.1 58.1

Boiling Point (°C)

49 36.1 28 -11.7 -0.45

Gas Conductivity (mW/mK @ 10°C)

11.0 14.0 13.0 15.9 13.6^

Flammable Limits in Air (vol.%)

1.5-8.7 1.4-8.0 1.4-8.3 1.8-8.4 1.8-8.5

TLV* or OEL** (ppm) (USA) 600 610 1000 800 800

GWP (100 year time horizon)

<25 <25* <25* <25* <25*

FTOC 2010 assessment report. ^ Measured at 0°C. *Threshold Limit Value **Occupational Exposure Limit *** Precise figure varies according to local atmospheric conditions.

Methyl Formate (MF). This substance is promoted as blowing agent under the trade name of Ecomate by Foam Supplies, which has patented the application in several countries. 365 tones were consumed worldwide in 2009 and close to 1,600 in 2015 (the FTOC estimated the total use of blowing agent for rigid foam in 360,000 tones for 2005).

MF is finding increased use in the flexible moulded and integral skin foam applications. It has also been the technology of choice to replace HCFC-141b in some rigid foam applications, particularly in the less insulating demanding, despite there is missing information on some technical issues: the effect of its plasticising characteristics on the long term thermal and dimensional stability performance of the foams, the eventual poor adhesion to metal substrates in discontinuous sandwich panels, the increased capital cost related to the corrosiveness (formation of formic acid) and flammability issues, the safety risk associated to the spray foam application and the potential hydrolysis in the gas cell to formic acid, CO2 and CO. The pros and cons of MF technology are briefly described in the FTOC 2010 assessment report.

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It should be noticed that in the mentioned FTOC assessment report and the TEAP report issued in response to MP Decision XXV/5 it is stated that the plasticizing effect that this substance has on the polyurethane matrix with the subsequent dimensional stability problem (foam shrinkage) may be countered by increasing the foam density where this is a commercial option.

Methylal. Lambiotte, a Belgium chemical company, and others are promoting this blowing agent for PU applications. The industrial experience of its use as sole auxiliary blowing agent is very limited. However, in the last three years is finding increased use in integral skin foam and shoe soles applications. The implications on safety of its flammability characteristics plus foam properties need to be clarified and verified for its use in PU rigid foam. The pilot project conducted in Brazil under MLF support showed the need of larger foam densities (high solvent power) and higher foam thermal conductivities in comparison to HCFC-141b. Non-flammable Options to replace HCFC-141b

Saturated HFCs. HFC-245fa and HFC-365mfc (in blends with HFC-227ea) were developed at the end of last century to replace HCFC 141b in polyurethane rigid insulating foams. The requirement was to develop a non-flammable “liquid” blowing agent. These HFCs are being used and technology around them is being optimised. There is comparatively little use of HFC-134a in polyurethane insulating foams. In domestic and commercial refrigeration as well as in spray HFC-245fa has been the HFC of choice. It develops foams with thermal conductivity and other physical properties very similar to those based on HCFC-141b. Although an additional capital investment is not needed it results in significant higher operating costs mainly because of the higher price of the blowing agent. The major drawbacks of the HFCs are their high GWP and price. The table below illustrates the properties of HFCs currently in use:

Table 3. Saturated HFCs

HFC-134a HFC-245fa HFC-365mfc HFC-227ea

Chemical Formula CH2FCF3 CF3CH2 CHF2 CF3CH2 CF2 CH3

CF3CHFCF3

Molecular Weight 102 134 148 170 Boiling Point (°C) -26.2 15.3 40.2 -16.5 Gas Conductivity (mW/mK @ 10°C)

12.4 12.5* 10.6* 11.6

Flammable Limits in Air (vol.%) None None 3.8-13.3 None TLV or OEL (ppm) (USA) 1000 300 1000 1000 GWP (100 year time horizon)^ 1300 858 804 3350

FTOC [2011]. * Measured at 24-25°C. ^ IPCC [2013]

Because of their high GWP saturated HFCs are being regulated in the developed countries. In the United States, the Significant New Alternatives Policy (SNAP) program implemented by the Environmental Protection Agency (EPA) changed the status of several foam blowing agents. In Rule 20 in July 2015, the SNAP program change of status to unacceptable for the blowing agents HFC-134a, HFC-245fa and HFC-365mfc and other higher GWP HFCs for use in polyurethane, phenolic, and polystyrene foams between 2017 and 2021. In the European Union, high GWP fluorinated gases are being phased down, according to F Gas regulations. In 2015, all HFCs with GWP greater than 150 were banned for foam use in domestic appliances and by January 1st,

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2023, they will be phased out in all foam manufacturing (see the 2016 FTOC progress report).

Carbon Dioxide (Water). The technology based on CO2, derived from the isocyanate-water reaction, has been tried from time to time with limited success, particularly for commercial refrigeration (bottle displays) where insulation performance is not as critical as in other applications such as domestic refrigeration. The major drawbacks of fully blowing with water are: insulating performance as a result of the relatively high lambda value of CO2; foam dimensional stability at room temperature caused by the high permeability values of CO2 through the polyurethane matrix, which requires a significant increase in foam moulded density, up to 10%, compared to 141b/water based formulations; and reduced “adhesion” to the substrates where it is applied (metal, thermoplastics), a consequence of the high amount of poly-urea present in the polymer, which makes necessary a careful reformulation generally involving the use of long molecular weight and/or primary OH (hydroxyl value) rich polyols. However, the use of CO2 (water) as a co-blowing agent with HFCs and hydrocarbons is a popular route, almost universal, to improve flow and reduce cost (in the case of HFCs).

Recently some large system houses are promoting a so called “second generation” of water-blown systems, claiming a significant reduction of the foam density required to meet the dimensional stability specifications. A recent pilot trial in commercial refrigeration conducted by Proklima provided promising results compared to HCFC-141b.

In the Japanese spray market, the use of water blown foam along with patented super-critical CO2 technology has been introduced and reached some levels of market penetration, whilst significant, suggest that there may be limitations in some applications. This technology became the focus of a MLF supported pilot-project conducted in Colombia that showed the feasibility of its application in Article 5 parties. However, the high costs involved (technology fees, machinery retrofit and raw materials) constitute a serious obstacle for its introduction.

Unsaturated HFCs (HFOs). These compounds represent an emerging group of potential blowing agents that exhibit a number of the characteristics also displayed by saturated HFCs, but have considerably lower GWP (< 5). The prime reason for these lower values relates to the shorter lifetime of the molecules in the atmosphere caused by the presence of a double bond between adjacent carbon atoms. The fluoro-chemical companies (Arkema, Chemours and Honeywell) in association with the largest PU chemicals producers (BASF, BAYER, Dow, etc.) are doing intensive research on their performance characteristics with very promising results. Honeywell started up the first global scale production plant in 2014 and in the same year one of the world largest manufacturers of domestic refrigerators began to use one of these products in North America. Chemours announced a world scale facility to be ready in 2017 and Honeywell another in 2017.

Table 4. Unsaturated HFCs (HFOs)

Trade Name Formacel® 1100 SolsticeTM Liquid BA Forane® 1233zd

Common name 1336mzzm(Z) 1233zd(E) 1233zd(E)

Chemical Formula Cis- CF3-CH=CH-CF3

Trans- ClCH=CH-CF3 Trans- ClCH=CH-CF3

Molecular Weight 164 130.5 130.5

Boiling Point ( 0C ) 33 19 19

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Gas Conductivity (mW/mK @ 10ºC) 10.7 10.6 (25 ºC)* 9.0

Flammable Limits in Air (vol.%) None None None

TLV or OEL (ppm) (USA) 500a 300** Undisclosed

GWP (100 year time horizon)***

2 1 <7

Producer DuPont Honeywell Arkema

FTOC [2011]. (a) DuPont Allowable Exposure Limits (8-12 hr. TWA). *Provided by Honeywell ** Preliminary Honeywell OEL ***Indicated GWP values from the intended suppliers.

Table 5.Comparison of Characteristics of HFOs

Common Name

HFO-1234ze(E)

HFO-1336mzzm(Z)

(DuPont)

HFO-1233zd(E)

(Solvay and Arkema)

Characteristic Gaseous liquid Liquid Proof of performance 0 + + Flammability ++ +++ +++ Other Health & Safety + + + Global Warming +++ +++ +++ Other Environmental + + + Cost Effectiveness (C) ++ ++ ++ Cost Effectiveness (O) -- -- -- Process Versatility + + +

In summary, several new low GWP blowing agents have emerged and are being introduced in the market with different levels of success. The TEAP Task force reports in response to Decisions XXIII/9, XXIV/7 and XXV/V describe the pros and cons of each alternative. For small and medium enterprises (SMEs) the current transition out of HCFC-141b substantially differs from the CFC phase-out that took place in the last decade where the only non-flammable, low GWP option (782 vs. 4660 of CFC-11) was the HCFC-141b. Several options that meet these characteristics are presently available and could be the choice depending on foam application, market economics and processing conditions: hydrocarbons -pure and pre-blended-, unsaturated HFCs (HFOs), all water blown, methyl formate and methylal. Today the PU systems providers are forced to simultaneously offer different options depending on the specific needs of the several end users. For example, meanwhile hydrocarbons, CO2

(water) or HFOs can be the preferred selection for some rigid foam applications methyl formate or methylal can be the choice for integral skin.

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See Annex 2 for more details concerning the risk profile of dosing, mixing and processing PU, including further chemical hazard reviews, example of foam-blowing machine in a medium-sized factory, and fire and explosion risk related to foam blowing with hydrocarbons.

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5. Climate Change Impact Assessment

As per decision of the Parties to the Montreal Protocol (specifically, Decision XIX/6), potential climate impacts should be minimized and preference should be given to low carbon substitute technologies taking into account global warming potential and energy use, as well as for meeting other health, safety and economic considerations. In accordance with the guidance given by the Parties, hydrocarbon technology has been selected as a blowing agent instead of HCFC-141b for one enterprise, and the rest of the PU foam sector in Jordan has committed to transition to HFO-based pre-blended polyol. During implementation and depending on HFO costs, some may choose water/CO2 with of course no climate impact.

Table 6. Climate Benefits from HCFC-141b Phase-out in the PU Foam Sector

(including Refrigeration Subsectors)

Chemical GWP Foam Blowing Agent Used (MT)

Climate Impact (tCO2 per year)

HCFC-141b 725 333.9 242,093 C-Pentane used (Pioneer)

< 25 23.8 595

Net Climate Benefits 241,498

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6. Applicable Jordanian Environmental Legislative Framework Of the ten safeguard policies of the World Bank, only Environmental Assessment OP 4.01 is triggered for the proposed project. In addition, the implementation of the EMF must follow the World Bank Group EHS (Environment, Health and Safety) Guidelines to address safety requirements associated with the hydrocarbon technology.

6.1 Relevant International Legal Documents The Vienna Convention for the Protection of the Ozone Layer and its Montreal Protocol on Substances that Deplete the Ozone Layer, as well as the London (1990), Copenhagen (1992), Beijing (1997) and Montreal (1999) Amendments to the Protocol.

6.2 National Laws and Regulations The National laws and regulations listed below should be applied for the environmental management (including worker health and safety) of the conversion to cyclopentane, HFO or water/CO2 technology in the foam manufacturing enterprises. The related articles are shown in Annex 1.

Table 7: Relevant National Laws and Regulations

National Laws and Regulations Area Relevant Articles

Environment Protection law No. 52 for year 2006 Environmental management

• Article 6 paragraph ( A,B,C,D) a • Article 7 • paragraph ( C) b • Article 11 ( A “1”, “2”) • Article 19 Paragraph ( A), (B)d

Labor law and Amendment No. 8 for year 1996 Worker health and safety

• Chapters 9 Article 78: Paragraph (1,2,3) • Article 79 (A,B,C) • Article 82, Article 87, Article 88 • Article 90 ( A,B,C,D)

Regulation No. (43) of the Year 1998

The Regulation of Protection and Safety from Industrial Tools and Machines and Work Sites

(issued by virtue of the Provisions of Paragraph (C) of Article (85) of the Labor Law No. (8) of the Year 1996)

Worker health and safety

• Article 2, Article 3 paragraph B , Article 5, Article 6. Article 8, Article 9, Article 10.

Regulations No. (37) of 2005:

Environmental Impact Assessment Regulations

(issued by virtue of Sub-paragraphs 9 and 11 of Paragraph A of Article 23 of the Environmental Protection Law No. (1) of 2003)

EIA • Article 4 paragraph (A,B ) • Article 8 Paragraph ( A,B) • Article 12, Article 17 • Article 18, Article 22, Article 23. Article

25, Article 26, Article 29

Regulations No. (24) of 2005: Transport of hazardous chemicals

Article 6, 7,8

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National Laws and Regulations Area Relevant Articles

Management, Transportation and Handling of Harmful and Hazardous Substances Regulations

(Issued by virtue of Sub-paragraph 7 of Paragraph A of Article 23of the Environmental Protection Law No. (1) of 2003)

6.3 Applicable National Technical Guidelines/Standards

Jordan has issued an Instruction for the Monitoring and Control of Ozone Depleting Substances, issued pursuant to Article (8) paragraph (f) of the Environment Protection Law No. (12) for 1995. These instructions are now under processing in order to be updated according to Montreal Adjustment in 2007 for accelerating the phase out of HCFCs; specifically, Article (17) prohibits venting of ODS to the atmosphere. See Table 8 below.

National Technical Guidelines and Standards Area Relevant Articles

Instruction for the control, use, import and re-export of ozone Depleting Substances and all equipment and appliances that contain these substances, issued pursuant to Article (4) paragraph (D) of the Environment Protection Law No. (52) for 2006

(updated version under processing)

Protection of the Ozone layer

• Article 5, Article 6, Article 12, Article 14, Article 17, Article 20

Code for fire prevention (2003) by civil defense Fire prevention All

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7. Applicable World Bank Safeguards Policies

Of the 10 safeguards policies of the Bank, only Environmental Assessment Operational Policy (OP) 4.01 is triggered. In addition, the implementation of the EMP must follow the World Bank Group EHS (Environment, Health and Safety) Guidelines to address safety requirements associated with the hydrocarbon technology. The relevant content of World Bank OP 4.01 and EHS is described in Table 9 below:

World Bank

Safeguards

Abstracts/Descriptions

Environmental Assessment (OP 4.01)

EA is a process whose breadth, depth, and type of analysis depend on the nature, scale, and potential environmental impact of the proposed project. EA evaluates a project's potential environmental risks and impacts in its area of influence; examines project alternatives; identifies ways of improving project selection, siting, planning, design, and implementation by preventing, minimizing, mitigating, or compensating for adverse environmental impacts and enhancing positive impacts; and includes the process of mitigating and managing adverse environmental impacts throughout project implementation. The Bank favors preventive measures over mitigatory or compensatory measures, whenever feasible. The project will have a positive impact on the global environment by reducing the use of HCFCs, which are ozone-depleting substances and greenhouse gases with a global warming potential (GWP) ranging from several hundred to several thousand times that of CO2. While HCFCs have an impact on the global environment, they have no adverse local impact as these chemicals are stable and not considered toxic or otherwise dangerous for the environment. The project will include a series of investment activities with foam manufacturing in commercial refrigeration, refrigerated transport, domestic refrigeration, and various foam sector entities. No closure, relocation, or expansion of enterprises is expected. All enterprises are located in industrial zones. Hydrocarbon, HFOs and water blowing have been selected as blowing agents to replace HCFC-141b that is being used in the foam sector. Hydrocarbon has a Global Warming Potential of less than 25. Hydrocarbon (cyclopentane) is classified as a Volatile Organic Compound (VOC), but its use results in very low levels of emissions of about 2-3% of the blowing agent, which is minuscule compared, for example, to emissions from two-stroke motorcycle traffic in countries such as Vietnam. Therefore, there is no significant environmental impact from the chemical hydrocarbon itself. HFOs have GWPs under 5 and are considered by HFO producers to be nonflammable. The other chemicals involved in foam production are MDI, amine catalysts and fire retardants. The foam enterprises purchase pre-formulated polyol (blended with or without HCFC-141b) and polymeric MDI (isocyanates) for their rigid foam production. The probability that a spill of polymeric MDI- a liquid at room temperature- contaminates the soil and water is very low, because the floor of the foam production areas consists of cement coated with an anti-leakage, low permeability\chemical layer such as epoxy. In the case that MDI leaks into the soil, it will react with the moisture/water, and the reaction would result in CO2 and insoluble polyurea

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compounds, which are not biodegradable but chemically inert. Fire retardant and amine catalysts (very limited amount) are mixed/pre-formulated in the polyol at the system houses (pre-blended polyol suppliers), from which the foam enterprises purchase pre-blended polyol and MDI, so the foam enterprises will not handle these toxic chemicals directly. Fire retardant and amine catalysts will remain in the final foam products and are not likely to be emitted to the environment during the foam production or later. Therefore, there are no anticipated legacy environmental contamination issues that are associated with the production at the foam enterprises. However, safety requirements associated with hydrocarbons (cylco-pentanes under the project) due to the flammability may still present operational challenges for smaller foam enterprises. Therefore, the Environmental Assessment (OP/BP 4.01) policy is triggered. Based on the above, it is not considered necessary to prepare an Environmental Impact Assessment, but an Environmental Management Plan for enterprises’ use during the project implementation stage was determined to address the safety concerns of hydrocarbon. In addition to this overall EMF, the enterprises have also been requested to prepare their site-specific EMPs as an integrated part of their subproject proposals in order to participate in the Project and receive access to any funding. The enterprises’ managers and operational staff will be trained annually on environment and health/safety requirements during the foam conversion under the Project. Safety audits before the start-up of normal foam production using hydrocarbons will be carried out by technical consultants hired by the NOU. World Bank supervision missions will also follow up on implementation of the EMP.

World Bank Group Environmental,Health, & Safety (EHS) General Guidelines

The Environmental Health and Safety Guidelines (EHS) are technical reference. The EHS Guidelines are technical reference documents with general and industry-specific examples of Good International Industry Practice (GIIP), as defined in IFC's Performance Standard 3 on Pollution Prevention and Abatement. The EHS Guidelines contain the performance levels and measures that are normally acceptable to the World Bank Group and are generally considered to be achievable in new facilities at reasonable costs by existing technology. 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 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. In this EMF, relevant guidelines from the World Bank Group EHS guidelines are incorporated into mitigation measures.

8. Institutional Arrangements

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The total number of eligible enterprises at baseline (2015-16 data) is 69. Jordan ODS3 AF sets a target of 60 participating enterprises because: (i) the majority of these enterprises are small and may not be in business by the time implementation starts; (ii) they may be found ineligible per current Multilateral Fund (MLF) rules (date of establishment after September 2007); or (iii) they simply may not want to participate in the project. The target is set at 85% of the total identified enterprises. The enterprises established after September 2007 will not receive direct support, however, there will be technical support available in the form of training workshops and knowledge sharing.

After further consultation with the National Ozone Unit (NOU) in Ministry of Environment, it is clear what larger enterprises from the different subsectors will be invited to prepare and submit an individual enterprise subproject (a total of six). Therefore, six subproject EMPs will be prepared.

All other participating enterprises are significantly smaller and will be receiving funding for only Incremental Operating Costs (IOC) and Technical Assistance (TA), under a simplified subproject agreement approach. A two-payment approach is being considered – one small payment at letter agreement signing and the larger amount upon project completion/new production start-up and against receipts of raw material. However, the approach for SMEs, including disbursement modalities will be decided during implementation of the first group of larger companies. By 2018, the Bank MP portfolio will have gained more experience in SME project design and implementation in the foam sector, and there will be some developments from the technology demonstration in Thailand. At that time, a generic EMP to be attached to SME signed agreement will be created, and this EMF updated to reflect more details of the phased approach.

Each individual enterprise EMP shall allocate the responsibilities for the implementation of said mitigation measures as follows:

Foam manufacturing enterprises are responsible for the safe conversion from HCFC-141b to cyclo-pentane, to HFO pre-blended polyol or to water blown foam production.

In order to be eligible for MP financing, foam enterprises must:

Before conversion:

• Obtain approval from local authorities and fire protection authority as per local and national requirements; • Obtain safety specifications from fire protection measures from the suppliers;

• Obtain approval from relevant authorities for storage and use of hydrocarbons;

• Prepare an EMP for the implementation of the conversion project following the guidance in this EMF

including its annexes; • Prepare and file an environmental impact assessment following national regulations if required, e.g. for a

new and an expansion of the existing foam production facility; and • Prepare and file safety and health reports if and as required by national or local regulations, and report

accidents to the competent authorities.

Before starting production with alternatives:

• Request from chemical supplier the safety data sheets for each chemical used in the foam production process;

• Obtain full instructions and training on the safe handling of these chemicals and keep workers continuously trained on all safety and health aspects related to the use of chemicals and foam production;

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• Ensure that production managers enforce and workers follow the guidance in safety data sheets and comply with all other safety and environmental requirements when handling chemicals and in the foam production process;

• Make arrangements with an environment servicing company for the collection and disposal of polyurethane waste and empty chemical drums;

• Assign technical staff to monitor compliance with (i) all OHS measures and environment requirements and (ii) all safety requirements and fire protection rules when working with cyclo-pentane during and after the conversion process;

• Arrange for a safety audit and obtain a fire safety certificate from a competent fire protection authority when conversion is completed and before start of production with hydrocarbon; and

• Send copies of any environmental, safety and health plans and reports related to HCFC conversion to the NOU for information and oversight.

After start of production

• Take adequate measures to prevent leaking and spilling of chemicals during storage and manufacturing; • Respond to chemical contamination and accidents promptly by carrying out mitigation measures to

minimize environmental and health impacts of as appropriate for each chemical and step in the production process;

• Prepare safety protocols, procedures and checklists on preparedness for and mitigation of fire emergencies, explosions, accidents, and environmental contamination and keep these documents accessible and regularly updated;

• Conduct Testing of fire and other safety equipment and procedures regularly by following established checklists and procedures, ensure good operational conditions and promptly replace failing, used up, worn or expired devices and personal safety equipment and materials; and

• Prepare and file environmental, safety and health reports if and as required by national or local regulations, and report accidents to the competent authorities.

The NOU is responsible for proper management and oversight of the overall HCFC phase-out project including environmental and safety aspects of each HCFC conversion sub-project. In execution of this responsibility, under guidance from Ministry of Industry and Trade and the World Bank, the NOU/PMU will:

• Provide technical assistance to participating foam enterprises on alternatives to HCFC-based foam production including their environmental and health risks;

• Review and assess the adequacy of the HCFC conversion plan including the EMP of all participating companies;

• Include the approved EMP in the sub-grant agreement with each participating foam enterprise such that the responsibilities and commitments in the EMP become contractual obligations of the participating enterprises;

• Supervise the implementation of the HCFC conversion project and the company’s compliance with the agreed environmental and safety requirements and standards;

• If necessary, cooperate with competent national and local authorities to enforce environmental, health and safety compliance by participating companies; and

• Prepare reports on environmental, health and safety compliance of the overall HCFC phase-out project.

Equipment suppliers are responsible for safe design and installation of the foam production line, in particular when using cyclo-pentane. In execution of this responsibility, equipment suppliers will:

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• Assess the production facility and location and design the foam production line in a manner that will meet all environmental, health and safety concerns;

• Install, or assist with the installation of, the foam production line and related equipment to ensure save production conditions;

• Provide to the production company complete information manuals and operational instructions on the installed equipment and inform customers on any newly emerging safety concerns related to the installed equipment;

• Provide training on the safe operation of the supplied equipment, including environmental and health risks and mitigation measures; and

• Provide after-sales services and warranties in the case of accidents due to technical equipment failure.

9. EMP Requirements and Subproject Contracts

Foam production impacts the environment when (part of) the blowing agent and/or other chemicals used in the foaming process are emitted to the environment from storage containers, during the production process or in the use of the final product.

a) Ozone depletion: The phase-out of HCFC as a blowing agent by the project will contribute positively to the recovery of the ozone layer. HFOs and cyclo-pentane are ozone neutral.

b) Global climate change:. Switching to cyclo-pentane with a GWP of 25 results in 95% reduction of GHG emissions compared to HCFC141b. This percentage increases when switching to HFO pre-blended polyol.

c) Local air pollution: While HCFC and HFOs are chemically stable and do not affect local air quality, cyclo-pentane is a volatile organic compound (VOCs), which can contribute to ground-level smog pollution. But with emission of only 2-3% of the blowing agent, the environmental impact is insignificant.

d) Soil and water pollution: The other chemicals involved in foam production are MDI, amine catalysts and fire retardants. The probability that a spill of polymeric MDI (liquid at room temperature) contaminates the soil and water is very low, because the floor of the foam production areas consists of cement coated with an anti-leakage, low permeability chemical layer such as epoxy. If MDI leaks into the soil, it will react with the moisture or water, and the reaction would result in CO2 and insoluble polyurea compounds, which are not biodegradable and chemically inert. Fire retardant and amine catalysts (very limited amount) are mixed with polyol by system house suppliers. They remain in the final foam products and are not emitted to the environment during foam production or later.

Mitigation Measures - Environmental Management Plan

Due to their flammability, safety requirements associated with the use of hydrocarbons may present operational challenges for foam enterprises. Therefore, the World Bank’s Environmental Assessment (OP/BP 4.01) policy is triggered. The six larger companies need to prepare a site-specific Environmental Management Plan (EMP) for the conversion to address safety concerns. A template for the sub-project specific EMP is attached as Annex 3 and an additional table specific to cyclo-pentane use is attached as Annex 4.

Prospective project participants must submit the EMP as part of their subproject proposal. The PMU will assess conformance of the EMP with the EMF’s requirements and its acceptability to the Bank,

Before the EMP becomes a part of the sub-grant agreement. The EMP must introduce appropriate OHS measures as well as emergency preparedness and response measures for:

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• Prevention of direct contact with and inhalation of MDI vapors (which can cause irritation); • Spill prevention, control, and countermeasures; and • Fire protection and countermeasures.

In addition, the EMP must contain provisions for:

• Training of enterprises’ managers and operational staff on environment, health and safety requirements during the conversion process and in the handling of cyclo-pentane in the foam production process; and

• At least one safety inspection and audit before the start-up of normal foam production using cyclo-pentane.

See the following Tables 10 and 11 below, which have been prepared as master tables from which to prepare enterprise-specific EMPs.

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Table 10: EMP Master Summary of General Industrial Impacts and Key Mitigation Measures

Issues / Risks Mitigation Measures Risk of handling compressed gases Follow manufacturer’s safety data sheet of the compressed gases.

Oxy acetylene gas cylinders shall be handled in a chained manner. Air emissions For workers, workplace VOC measurements shall be conducted

For environment, ambient air quality measurements shall be conducted Provide adequate indoor ventilation for fugitive emissions. Collection of Volatile Organic Compounds (VOCs) through air extractors and remove VOCs with control devices such as condensers or activated carbon absorption.

Water emissions Provide a documented receipt (manifest needed) from treatment plant department to assure the actual disposal Noise Ambient and occupational noise level measurements shall be conducted by certified party

Selecting equipment with lower sound power level Installing silencers for fans Installing acoustic enclosures for equipment Reduce working time to less than 8 hours according to the measured noise level Installing vibration isolation for mechanical equipment

Hazardous chemicals Follow Management, Transportation and Handling of Harmful and Hazardous Substances Regulation, no. 24, 2005 (see Table 6) Non-hazardous waste Evaluate waste production process and identification of potentially recyclable material, then recycle and/or reuse it

Non-hazardous waste should be stored in separate watertight storage area and then disposed of via approved collector(s) by MoEnv Maintain good housekeeping frequently

Hazardous waste Hazardous waste should be stored segregated from non-hazardous waste Store closed containers away from direct sunlight, wind and rain Provide adequate ventilation Conducting periodic inspections of storage areas and documenting the findings; Preparing and implementing spill response and emergency plans to address accidental releases; Provide secondary containment for all on-site hazardous waste and waste storage facilities; Equip facility with adequate fire fighting equipment Disposal of these waste shall be carried out thorough Ministry of Environment for approval to disposal into Sawaqa Hazardous Wastes Treatment Center Proper manifest should be acquired and maintained

Occupational health and safety Full commitment to wearing the personnel protective equipment against fugitive emission, hand injuries, slip hazard, manual handling Fire extinguishers are distributed in a well manner Emergency response and evacuation plan is in place at the workplace Health and safety senior supervisor and five officers assigned in the company Health and safety committee is formed The workers receive periodically fire prevention and first aid training New comers are receiving safety and environment orientation prior to starting job

http://teeic.anl.gov/glossary/glossary.cfm#161

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Issues / Risks Mitigation Measures Restriction signs for Smoking and food are distributed properly in the workplace. Electrical management/safety is good where cables are placed in the designated trenches area way of the walkways. Safe guards are installed on dangerous machinery. Under operating conditions, workers should wear personal protective equipment, e.g. gas masks, PE gloves and other personal protection equipment. Appropriate measures such as ventilation, fire prevention and cooling should be planned and installed to accommodate the use of different chemicals The workers should receive proper safety training and proved to be qualified through tests before assuming the position; when the use of hazardous chemicals is involved, a safety facilitator/officer with adequate knowledge of safety operations and of hazardous chemicals should be recruited No Smoking, No Food and No open Fire should be allowed on project site; Mark the caution signs both in Arabic and in English Ensure safety use of electrical appliance

Training of workers in environment, health and safety

Project training requirements and Jordanian labour law Certain Safety training aspects can be intensified and provided to workers; such as ergonomics, electrical safety, manual handling, hazardous substances handling, etc

Environmental risks Install spill containment area Spill containment plan and measures at the workplace is implemented Provide spill tool kit at workplace Provide emergency response plan

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Table 11: EMP Master Summary of Chemical Impacts, Key Mitigation Measures and Residual Impacts

Chemical Theoretical impact Potential impact in foam production

Key mitigation measures Residual impacts

MDI diphenylmethane- 4,4'-diisocyanate CAS No. 26447-40-5

ENVIRONMENT IMPACTS Acute Fish toxicity: diphenylmethane-diisocyanate, isomers and homologues LC0 > 1.000 mg/l Species: Danio rerio (zebra fish) Exposure duration: 96 h Method: OECD Test Guideline 203 Acute toxicity for daphnia: diphenylmethane-diisocyanate, isomers and homologues EC50 > 1.000 mg/l Species: Daphnia magna (Water flea) Exposure duration: 24 h Method: OECD Test Guideline 202 Acute bacterial toxicity: diphenylmethane-diisocyanate, isomers and homologues EC50 > 100 mg/l Tested on: activated sludge Duration of test: 3 h Method: OECD Test Guideline 209 Persistence and degradability Biodegradability: diphenylmethane-diisocyanate, isomers and homologues Biodegradation: 0 %, 28 d, i.e. not degradable Method: OECD Test Guideline 302 C OHS IMPACTS Skin contact – Skin contact may cause an allergic skin reaction. Animal studies have shown that skin contact with isocyanates may play a role in respiratory sensitization. Eye contact – MDI may cause moderate eye irritation and slight, temporary corneal injury.

ENVIRONMENT IMPACTS In the aquatic and terrestrial environment, MDI reacts with water, forming insoluble polyureas that are chemically and biologically inert. This reaction limits the movement of MDI in soil and water. OHS • Harmful by inhalation • Irritating to eyes, respiratory

system and skin • May cause sensitisation by

inhalation and skin contact

-Avoid any spills during the storage and production by means of constructing storage facilities, pipelines and polyurethane foaming machine according to strictest machine construction standards.

- Efficient and adequate extract ventilation

- Chemical goggles should be used when working with MDI and an eye wash fountain should be located in the immediate work area.

- Hazard communication and training programs to prepare workers to recognize and respond to workplace chemical hazards

None

23



Inhalation – At room temperature, MDI vapors are minimal due to low volatility. However, certain operations may generate vapor or mist concentrations sufficient to cause respiratory irritation and other adverse effects. Such operations include those in which the material is heated, sprayed or otherwise mechanically dispersed such as drumming, venting or pumping. Excessive exposure may cause irritation to upper respiratory tract (nose and throat) and lungs. MDI inhalation exposure may cause pulmonary edema (fluid in the lungs.) Effects may be delayed. Decreased lung function has been associated with overexposure to isocyanates. MDI inhalation may cause an allergic respiratory response. MDI concentrations below the exposure guidelines may cause allergic respiratory reactions in individuals already sensitized. Asthma-like symptoms may include coughing, difficult breathing and a feeling of tightness in the chest. Occasionally, breathing difficulties may be life threatening. Ingestion – MDI products have low acute oral toxicity. Small amounts swallowed incidentally as a result of normal handling operations are not likely to cause injury; however, swallowing larger amounts may cause injury. Good personal hygiene practices must be observed and hands washed before eating. Food should not be stored or consumed where MDI is used. Other – Lung tumours have been observed in laboratory animals exposed to respirable aerosol droplets of MDI/Polymeric MDI (6 mg/m3) for their lifetime. Tumors occurred concurrently with respiratory irritation and lung injury. Current exposure guidelines are expected to protect against these effects reported for MDI. MDI has been toxic to the fetus in laboratory animals at doses toxic to the mother. MDI did not cause birth defects in laboratory animals.

Polyol - Polyol component is a

ENVIRONMENT IMPACTS

ENVIRONMENT IMPACTS

- Avoid any spills during the storage and production by means of constructing storage

None

24



mixture of various polyols combined with polyamines and cross-linking agents

Ecotoxicity - Data for Component: Phenol, polymer with formaldehyde, propylene oxide and ethylene oxide: Material is harmful to aquatic organisms (LC50/EC50/IC50 between 10 and 100 mg/L in most sensitive species). OHS IMPACTS Skin Contact - Prolonged contact may cause slight skin irritation with local redness. Eye Contact - Many polyols cause only slight temporary irritation if they contact the eyes. Safety glasses are recommended for minimum eye protection when these polyols are handled or used. Amine-initiated and Mannich-based polyols can cause moderate to severe irritation and injury to the eyes. Therefore, chemical goggles are recommended for handling these materials, as stated on the MSDS and product label. Inhalation - Because of their low vapor pressure, polyols do not pose a significant inhalation hazard when handled at room temperature. Under most conditions of use, good general ventilation will be adequate and no respiratory protections are needed. If materials are heated, or if a fine mist is being generated, local ventilation and respiratory protection may be required. Ingestion - Polyols are low to very low in acute oral toxicity. Most LD50 values range from 2.0 grams to greater than 10 grams per kilogram of body weight for laboratory animals. A few have oral LD50 values between 1,000 and 2,000 mg/kg. Swallowing small amounts of these polyols is not likely to cause injury. Although swallowing large amounts of polyols may cause toxic effects, the possibility of such ingestion is unlikely with proper industrial handling and use.

• No bio-concentration is expected because of the relatively high molecular weight (MW greater than 1000).

• Based largely or completely on information for similar material(s). No bio-concentration is expected because of the relatively high water solubility.

OHS IMPACTS The principal hazard associated with polyol is a safety hazard—spilled material can be very slippery

facilities, pipelines and polyurethane foaming machine according to strictest machine construction standards.

- Use magnetic couplings always when possible to avoid polyol spill / leakages from the pumps

- Adequate ventilation


Cyclo-pentane Cas No. 287-92-3

ENVIRONMENTAL IMPACTS

ENVIRONMENTAL IMPACTS

- Avoid any spills during the storage and production by means of constructing storage facilities, pipelines and polyurethane foaming

None

25



Usage from 70 kg to 280 kg/day Normal release to the environment during production operation in 11 factories is from 2.5kg/day to 11 kg/day

• Harmful to aquatic organisms, may cause long-term adverse effects in the aquatic environment.

• Given its physical and chemical characteristics, the product shows very little mobility in the ground.

Eco-toxity – Cyclo-pentane is water insoluble and cannot move readily in soil and water; evaporation is rapid, reducing the likelihood of soil or water contamination Aquatic Toxicity EC50 (Crustacea, 48hr) 19.6mg/litre (artemia salina), 10.5mg/litre (daphnia magna) EC50 (Algae, 3hr) 124mg/litre (chlamydomonas species), 116mg/litre (chlorella vulgaris) Marine pollutant – not marine pollutant OHS IMPACTS Highly flammable Vapor/air mixtures are explosive Dizziness. Headache. Nausea. Unconsciousness. Weakness.

Bioaccumulation - cyclo-pentane is poorly absorbed but may bioaccumulate moderately Biodegradation – cyclo-pentane degrades slowly in the presence of oxygen Abiotic Degradation – cyclopentane reacts with atmospheric hydroxyl radicals; its estimated halflife in air is 66 hours OHS IMPACTS Explosion, if not handled correctly Lower explosive limit: 1.1 vol-% = 32 g/m3 Upper explosion limit: 8.7 vol-% = 267g/m3 (Evaporation rate at 20°C – 30°C > 2.4 kg/h per m2 surface) Vapor has higher density than air (accumulates on the lowest point of the workshop)

machine according to strictest machine construction standards.


- Avoid uncontrolled reactions and conditions resulting in fire or explosion. Recommended prevention practice include the following:

+ Use magnetic couplings always when possible to avoid spill / leakages from the pumps

+ Always use non-sparking bronze or aluminum hand tools. All electrical and mechanical equipment (including lighting, switchgear and forklift trucks) used with or around this product must be explosion-proof according to the zoning.

+ Always ground or electrically bond both the source container and the receiving container, and transfer pump before transferring contents.

+ Avoid splashing by ensuring that the product nozzle is below the surface in the receiving container.

+ For indoor storage, only store a minimum quantity in a cool (below 30 °C / 86 °F) environment, away from sources of ignition, heat and oxidizing agents.

+ Bulk storage should be outdoors, but under a roof to prevent exposure to the sun. Tanks must be vented, and the vents equipped with spark arrestors. Drums must be kept away from oxidizers and corrosives. Drums should have pressure/vacuum relief venting. Drums

26



should be bonded or grounded – contact with an appropriately conductive concrete floor may is supposed to be adequate. Drum storage area must be well ventilated – with floor level venting! Storage area should have raised sills to contain spills.

+ Storage area must be kept clean and free of rags, mops, and similar equipment.

+ Never use a cloth dampened with this product for wiping or cleaning surfaces! The friction of wiping is likely to generate a static charge which may ignite the cyclo-pentane.

+ Prohibition of all sources of ignition from areas near storage tanks. Never cut, drill, weld or grind on or near this container.

- Good extract ventilation is necessary for the OHS

- Avoid breathing product vapor. Use with adequate ventilation. If dealing with a spill, and ventilation is impossible or impractical, wear a suitable respirator with organic vapor cartridge. An air-supplied respirator may be necessary because cyclo-pentane is so volatile that it may displace oxygen, potentially asphyxiating an unprotected worker.

- Avoid contact with skin and wash work clothes frequently. An eye bath and safety shower must be available near the workplace.

- Prepare Emergency Preparedness and Response Plan to cope with fire risk which include the following:

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+ Training staff/workers on release prevention including drills to specific to fire explosion

+ Implementation of inspection programs to maintain the mechanical integrity and operability of pressure vessels, tanks, piping systems, relief and vent valve systems, containment infrastructure, emergency shutdown systems, controls and pumps, and associated process equipment

+Identification of locations of cyclo-pentane and associated activities on emergency plan site map

+ Description of response activities in case of fire explosion include:

o internal and external notification procedures

o specific responsibility of individual or groups

o facility evacuation routes

Methylene Chloride CAS No: 75-09-2

ENVIRONMENTAL IMPACTS Impact is very limited due its fast evaporation rate LC 50, 96 Hrs, FISH mg/l 224 EC 50, 48 Hrs, DAPHNIA, mg/l 480 IC 50, 72 Hrs, ALGAE, mg/l 662 Combustible under specific conditions. Gives off irritating or toxic fumes (or gases) in a fire. OHS IMPACT MC can affect the body if it is inhaled or if the liquid comes in contact with the eyes or skin. It can also affect the body if it is swallowed

ENVIRONMENTAL IMPACTS Bioaccumulation - The product has poor water-solubility. Biodegradation - The product is not expected to be biodegradable OHS IMPACT MC can affect the body if it is inhaled or if the liquid comes in contact with the eyes or skin. It can

- Avoid any spills. - New foaming machines to be purchased do not require use of Methylene Chloride for cleaning the foam mixing head. Thus the use of methylene chloride should be avoided and minimized so much as possible. - Small spills should be absorbed onto sand and taken to a safe area for atmospheric evaporation.

None

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Short-term Exposure: MC is an anesthetic. Inhaling the vapor may cause mental confusion, light-headedness, nausea, vomiting, and headache. Continued exposure may cause increased light-headedness, staggering, unconsciousness, and even death. High vapor concentrations may also cause irritation of the eyes and respiratory tract. Exposure to MC may make the symptoms of angina (chest pains) worse. Skin exposure to liquid MC may cause irritation. If liquid MC remains on the skin, it may cause skin burns. Splashes of the liquid into the eyes may cause irritation. Long-term (chronic) exposure: The best evidence that MC causes cancer is from laboratory studies in which rats, mice and hamsters inhaled MC 6 hours per day, 5 days per week for 2 years. MC exposure produced lung and liver tumors in mice and mammary tumors in rats. No carcinogenic effects of MC were found in hamsters. There are also some human epidemiological studies which show an association between occupational exposure to MC and increases in biliary (bile duct) cancer and a type of brain cancer. Other epidemiological studies have not observed a relationship between MC exposure and cancer. OSHA interprets these results to mean that there is suggestive (but not absolute) evidence that MC is a human carcinogen.

also affect the body if it is swallowed

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10. EMP Monitoring and Reporting Specifics

Enterprise Responsibilities: During conversion period of 2018-2022, enterprises should detail all activities of conversion in the Progress Report such as implementation timing, testing, trials and proto sample to be produced, and progress and results of mitigation and monitoring measures. Frequency and duration of mitigation measures and monitoring as well as remedial actions, if any, showing consequences in accordance with the phasing-out targets and schedule should be included. Similarly, a breakdown timetable consisting of detailed activities should be included in the report. The Environmental Report prepared by enterprises should be submitted annually to the NOU as part of the Subproject Implementation Progress Reporting activities. The Project Implementation Progress report is to be submitted semi-annually from NOU by January 31 and July 30 each year to the World Bank.

Monitoring: During the project implementation, the NOU will work with local environmental authorities and its consultants to monitor the implementation of HCFC phase-out subprojects and to ensure that all the specified EMPs are implemented properly.

Reporting: The technical consultant will supervise and prepare an aggregate social and environmental safeguards monitoring reports for the NOU, MOE, and MOPIC. Such reports will include, at least twice annually, a detailed report on the implementation of this EMF.

The implementation schedule and reporting procedure are summarized as follows in Table 11:

(i) Institutional responsibilities for implementation and supervision of this EMF; (ii) Subproject contracting design and implementation specifics relating to EMP implementation; (iii) EMF monitoring and reporting specifics; and

(iv) the identified potential environmental and social impact and mitigation measures for each of the sites, as well as a monitoring plan during the conversion and operational phases of implementation.

Organization Responsibilities of Stakeholders for Implementation and Supervision of this EMF

Current Status of EMF implementation/remedial

actions required

Private sector enterprises

Bear all responsibility, but under monitoring and supervision of the NOU and the World Bank, for the conversion from HCFC-22 and HCFC-141b in AC and foam manufacturing. Technical assistance will be provided through the project. Request chemical suppliers to provide safety data sheets for replacement refrigerants and full guidance and training on safely handling these chemicals. Follow stringently the safety data sheets when handling these chemicals. Assign technical staff to monitor the compliance with the safety occupational health and environment requirements on using chemicals. Keep workers continuously trained, in cooperation with the NOU and chemical and equipment suppliers on safe AC and foam production; Take all necessary measures to prevent leakage during the manufacturing process. Carry out the mitigation measures described above for the chemical

NOU will regularly conduct monitoring and supervision visits and meetings

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substance and in case of chemical leakage. Contract local services for collection and disposal of the empty chemical drums in accordance with national regulations.

Prepare an EIA following the national regulations in the event that a plant is constructed or rehabilitated to implement the HCFC phase-out subproject.

Jordan NOU in the MOEnv

Sign the subproject grant agreement (SGA) with each participating enterprise. The SGA annex will list enterprise responsibilities and documents / plans it is obligated to adhere to in implementation of the EMP. Coordinate and supervise subproject implementation, including all environmental and safety requirements listed by hiring technical consultants as necessary. Ensure project implementation will achieve the HCFC-22 and/or HCFC-141b phase-out target and safety requirements for the use and disposal of chemicals in accordance with national regulations and World Bank safeguard policies and guidelines Cooperate with relevant Government and municipal agencies and departments to carry out enforcement of environmental and worker safety regulations. Prepare project progress and environmental and social monitoring reports

S

Equipment Suppliers

Provide safe and environmentally sound design and installation of the AC and/or foam production lines Provide adequate training and guidance on safe operation of the supplied equipment taking into account any environmental and health risks and mitigation measures Provide adequate after-sale service and warranty in the case of accident due to the technical faults.

Equipment suppliers are to provide either at country of origin or on the factory floor training, for operational procedures, safety and occupational risks

Gov’t. Enforcement Agencies

Joint inspection of the three factories by Ministry of Environment, Ministry of Labor, Civil Defense, Ministry of Health to detect any shortfalls from the regulatory requirements of those agencies will be repeated annually for the duration of the project, or more frequently if requested by MOE.

Pertinent GOJ agencies continue to do their enforcement and supervision roles through the application of the national laws and regulations

Stakeholder/

Organization Implementing

schedule Report on/to Time Frequency

NOU

2018-2022

Subproject Implementation Progress Reports of the conversion sub-project and submit to World Bank

Project Environment and Monitoring Report (with inputs from the enterprises), including environment monitoring requirements/indicators, including compliance with all environmental health and safety regulations

31 July and 31 January

Semi-annually

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Enterprises 2018-2022

Subproject Implementation Progress Report to NOU

- Environment and safety issues, especially accidents, fires, or lost time injuries, if any, to local authority and to NOU

- Notification to the chemicals and equipment suppliers and copy to the NOU on any issues during the conversion and after conversion

-EIA report for any enterprise building new factories

1 month after each quarter

When needed

When the fault takes place

One-time reporting and approved by local EPA before construction starts

Quarterly (year 1)

11. Capacity Building/Training TA is required under the proposed sector plan for the enterprises and the country to ensure efficient and effectual phase-out across the sectors and nation-wide. This will be made up of training workshops and sessions, organized industry consultations, and consultant services on alternative technologies.

a. Training workshops for the foam and refrigeration enterprises. Workshops will be organized to broadly inform foam and commercial refrigeration manufacturing enterprises of the objectives of the Stage II HPMP, Jordan’s MP obligations in terms of HCFC phase-out and eventual bans, and the state of technologies. Participants will be informed of the funding rules and modalities, submission of applications for grant funds, subproject review and approval by the NOU, and implementation, commissioning and reporting requirements. Potential beneficiaries of the HPMP, excluding spray foam and servicing, will be informed about World Bank and country requirements and procedures for procurement of goods and works, financial management, disbursement, and environmental and social safeguards.

b. International and national technical consultant services. International and national technical

consultants on foam and commercial refrigeration will be selected competitively to provide technical support and guidance to the NOU and enterprises. These consultants will provide up-to-date technical knowledge to the NOU and Ministry, so that they can credibly make the case for future bans in the sectors to other agencies and offices to gain their support and buy-in. Experts will also be there as resource persons on alternative technologies and operations, equipment technical specifications, and to address broader technical issues as requested during implementation.

c. Study tours on HCFC alternatives. Study tours will be organized as needed to allow NOU staff and national technical experts as well as enterprises to have access to emerging technologies developed and/or employed in other countries. All manufacturing sectors covered by Stage II involve conversion to HFO technology which is new and barely tested even in developed countries. Some of the larger beneficiaries which are particularly concerned about maintaining quality and competitiveness will be candidates for study tours or external technical workshops.

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d. Other TA activities. As is usually the case in comprehensive multi-year projects, other requirements and needs for TA may arise during implementation. Jordan will use the flexibility included in the Stage II agreement to adjust its plans for TA as is required.

The Technical Assistance and Policy Component of this Jordan ODS3 AF project is allocated as $215,129. These funds will fund the activities detailed above. Additionally, one of the staff in the Project Management Unit will be dedicated to supporting conversions in the facilities, including environmental safety concerns and training associated with technology changes. The budget for the percentage level of effort dedicated to environmental safeguards support for this staff member is estimated at $10,000/year. The total budget of the ODS3 AF partially or fully dedicated to environmental safeguards is estimated at $215,129, which is approximately 10% of the total ODS3 AF budget.

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12. Consultations

Consultations with Proposed Beneficiaries February 14th and 16th, 2017

Al- Mani Prefabricated Buildings Company: Raed Mohammed Ahmed Abu Laban Al-Qanadeel: Ahmed Mohamed Ahmed Al-Safa: Samir Abdul Razak Mohammed Saleh FAA: Ahmad Samara Jordan Light Vehicle Manufacturing: Mofid Jamil Abu Jamaa and Ghaith Tajeddin Hidayeh Joseph Workshop Metal Industries: Fadi Yousef Suleiman Abdel Kader Pioneer: Jamal Riaz Jamal Anabtawi Shams-Ram Enterprise: Hussein Ali Hussein Khalifa

Consultations with beneficiaries were held throughout the week of February 12th – 16th, according to the availability of the firm engineers and general managers. The World Bank staff and National Ozone Unit shared with the beneficiaries details of the ODS3 Additional Financing as follows:

• Jordan’s agreement with the Multilateral Fund (MLF) to phase-out HCFC 141b; • The timetable for phase-out as well as the timetable for project implementation; • Technological choices available to substitute for HCFC 141-b; • Details of sub-project technical and financial appraisal, including means of consumption

verification and other documentation needed to apply for sub-project funding, and review of a draft sub-project proposal;

• Legal covenants to be part of the sub-project agreement, including a review of a draft sub-project grant agreement, and a pay-out schedule;

• What incremental capital and operating costs (ICC and IOC, respectively) are eligible for funding, and what the likely financial envelope will be for each firm;

• Options for access to technical assistance and study tours; • Safety provisions for which compliance must be documented, through ISO certification and/or

physical on-site inspections. Feedback voiced by the beneficiaries included:

• Asking the exact amount of grant funds they will receive (this is to be determined); • Asking exactly when the money will be available to access; • Asking for technical feedback on the type of conversion they are considering adopting; • Feedback that the amount of money for HCFC conversion is not enough; • Feedback that HFOs are too expensive to convert to at present; • Request for more information on HFO suppliers and HFO-related technical assistance local to

Jordan. These follow-up questions were addressed to the best of the NOU’s abilities, and the questions which were not fully addressed will be integrated into the next stages of AF preparation.

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13. Grievance Redress Mechanisms

Grievance Redress Mechanisms relevant to the Jordan ODS3 AF project are of two types: those relating to workers’ conditions in ODS3 participating firms and those relating to environmental management of firm production.

Workers in ODS3 participating firms are able to access the Hotline/Complaints Department of the Ministry of Labor. The Hotline/Complaints Department is the official channel for receiving an array of complaints associated with workers being abused and mistreated as well as illegality of workers. In order to be responsive to non-Jordanian workers, the Department has translators who can register complaints; however they have no ability to provide legal advice on the issues raised. There are multiple informal and/or less structured channels through which complaints are sometimes transferred to the Hotline. These channels include walk-ins; letters, faxes, complaints made to the Minister and to other Ministries however not all complaints are registered, and therefore follow up and clarity on percentage of resolution is also unreliable.

Additionally, the Ministry of Labor Inspectorate Unit will carry out inspections relating to compliance with international and Jordanian labor standards, especially if there is a complaint relating to occupational health and safety of workers.

Lastly, whereas the Ministry of Labor is responsible for the “inside-factory complaints”, the Ministry of Environment is responsible for the “outside factory complaints”. The Ministry of Environment has a Directorate of Environmental Inspection, with an Environmental Inspection Section within. If the Ministry of Environment receives a complaint regarding environmental quality violations, the Environmental Inspection Section will conduct both a “surprise” and a “follow-up” inspections. According to Article 7 of the Jordan Environmental Protection Law, the inspectors issue warnings to violations, and cannot issue fines directly. Instead, repeat offenders can be sent to court and fined, usually for the cost of the remediation plus 25%.

The inspectors usually measure and monitor the following: (i) industrial wastewater; (ii) emissions/filters; and (iii) solid (including industrial, hazardous, and medical) waste. The Section has various tools which aid in the inspection process, including SOPs, code of inspector conduct, and reporting format.

As of yet, the Ministry of Environment does not yet have a proper handheld-computerized system in place to register inspection visits. The checklist now in use is on personal digital assistant (PDA) which is no longer effective in the field. The Ministry of Environment would like to upgrade to a tablet-based system. However, it appears that most inspection visits are being recorded manually and posted to a management information system once the inspector returns to the office. This system has files for each firm report and is not easily able to sort, aggregate or analyze data.

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Annex 1: Governing Laws and Regulations Relating to Environmental Health and Safety

Environmental Protection Law No. 52 of 2006

Article 6:

A- Materials prohibited from being entered into the Kingdom shall be set by instructions issued by the Council of Ministers upon the recommendation of the Minister.

B- Hazardous waste is not permitted to be entered into Jordan. This waste shall be defined by virtue of instructions issued by the Council of Ministers upon recommendation of the Minister.

C- In the event of the discovery of hazardous waste entered into the Kingdom or the entry of any environmental pollutant in an illegal manner, the Ministry, in coordination with the concerned authorities, shall return same to its origin at the expense of the party who entered it into the Kingdom and shall levy fines and recoup costs and losses suffered by the Kingdom.

D- Any person violating the provisions of this Article shall by fined an amount of not less than (20,000) Twenty Thousand Dinars or by imprisonment for a period of not less than 3 years and not exceeding fifteen years, or both.

Article 7:

A - For the purposes of this Law, the specialized officer named by the Minister in writing upon the recommendation of the Secretary General shall be granted police powers and he may enter any industrial, commercial, handicraft or agricultural shop or any establishment or corporation or any other entity whose activities may affect in any way the Element and components of the Environment to ensure its compliance and the compliance of its activities with the standard environmental conditions

B - The perpetrator of any of the violations provided in this Article, after the end of the period of notification and the failure to remove the violation shall be punished by imprisonment for a period of not less than thirty days and not exceeding 3 months or by a fine of not less than Three Hundred Dinars and not exceeding Five Thousand Dinars. In case of a repeat of the violation, the fine shall be doubled. If the violation is repeated a third time, the entity shall be shut down until the violation is removed.

Article 11:

A - It is forbidden to dump, dispose of, or collect any materials harmful to the Environment, whether such materials are solid, liquid, gaseous, radioactive or thermal, in the sources of water.

B - It is forbidden to store any of the materials listed in Paragraph 1 thereof in the proximity of water sources within the safe limits set by the Ministers by virtue of instructions issued for that purpose, including the protection of water basins, in coordination with the concerned parties.

Article 19:

A- The owners of factories or vehicles or workshops or any entity that conducts activities with a negative impact on the Environment and environmental pollutants must install equipment or take the necessary measures to prevent or reduce the emission of such pollutants there from, and to control such pollutants before emission from such factories or vehicles into the air to within the limits permitted based on the set standards.

B- The owner of a factory who commits a violation referred to in Paragraph A hereof and does not remove such a violation within the period set by the Minister or whoever he delegates, shall be referred to the Court, who is entitled to issue a decision to shut down such factory and punish the perpetrator by imprisonment for a period of not less than one week and not exceeding thirty days, or by a fine of not less than One Hundred Dinars and not exceeding One Thousand Dinars, or both. He shall also be obligated to remove

36

the violation within the period set for that purpose, and he shall be fined an amount of not less than Fifty Dinars and not exceeding One Hundred Dinars for each day that he fails to remove the violation after the end of the period set for that purpose.

Labour Law and Its Amendments No. 8 of the Year 1996

Article 79:

After consulting the competent official authorities, the Minister shall determine in the instructions that he shall issue the following:

A. Precautions that should be taken or provided in all establishments or in any of them to protect the employees and establishments from the dangers of work and the occupational diseases.

B. The equipment that shall be provided in the establishments or any of them to protect the employees from the dangers of work and the occupational diseases.

C. The basis and standards that should be available in the industrial establishments to secure an environment free of pollution, noise, vibrations and all what may endanger the health of the employee in accordance with the approved international standards and determine the methods of check and test related to controlling these standards

Article 78:

A. The employer shall do the following:

1. Provide the required precautions to protect the employees from the dangers and diseases that may result from the work and the used equipment.

2. Provide personal protection equipment for the employees to protect them against the work dangers and occupational diseases such as clothes, glasses, gloves, shoes and others, in addition to guiding them how to use, keep them and keep their cleanliness.

3. Acquainting the employee before his/her employment with the dangers of his/her occupation and the protective means that shall be taken in accordance with the regulations and decisions issued in this regards

Article 82:

The employees working in any establishment shall abide by the provisions, instructions and decisions related to the precautions of protection, vocational health and safety, using and maintaining the equipment of vocational health and safety, and refraining from any act that may hinder the execution of such provisions, decisions and instructions and refraining from misusing the equipment of protection and vocational health and safety or destroying them at the risk of being subject to the disciplinary penalties stipulated in the bylaw of establishment.

Article 87:

A. If the employee was injured because of work an injury that led to his/her death or caused him/her a serious body injury that hindered his/her continuation in work, the employer shall transfer the injured to the hospital or any medical center and notify the competent security authorities of the accident and send a notification to the Ministry during a period not exceeding (48) hours from the occurrence of the accident, the employer shall bear the expenses of transferring the injured to the hospital or the medical center to treat him/her.

Article 88:

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The employer shall be responsible for paying the compensation stated in this law for the employee who has been infected with an occupational disease resulting from his/her work based on a report of the medical authority.

Article 90:

A. If the work injury has resulted in the death of the employee or his/her total disability, the employer shall compensate the employee with the wage of one thousand and two hundred working days provided that the compensation shall not exceed five thousand JDs and not less than two thousand JDs.

B. If the work injury has led to temporary disability of the employee, then he/she shall be entitled to a daily remuneration equaling (75%) of the rate of his/her daily wage as of the date in which the injury has taken place during the period of medication which shall be determined based on a report of the medical authority if his/her medication was outside the hospital, the remuneration shall be reduced to (65%) of that wage if the injured was treated at one of the approved medication centers.

C. If the work injury has resulted in permanent partial disability in accordance with the report of the medical authority, the employee shall be paid compensation at the rate of that disability to the compensation decided for the total disability by virtue of table No. (2) annexed to this law.

D. If the one work injury has resulted in more than one body injury, the injured employee shall be entitled to compensation for each injury in accordance with the basis stipulated in this law provided that the total of that amount payable shall not exceed the amount of the compensation payable in case of total disability.

Regulation No. (43) of the Year 1998 - The Regulation of Protection and Safety from Industrial Tools and Machines and Work Sites Issued by virtue of the Provisions of

Paragraph (C) of Article (85) of the Labour Law No. (80) Of the Year 1996

Article (2)

The employer or the director of the establishment should take the precautionary measures and procedures that guarantee protection and safety from the mechanical, electrical, chemical dangers of industrial tools and machines and work sites, pursuant to the provisions of this regulation and the instructions that were issued accordingly

Article (3)

B- During the setup of the barriers mentioned in paragraph (A) of this article, the following should be taken into consideration:

1. They should prevent the worker or any part of his/her body from reaching the danger area during work.

2. They should constrict and enclose the danger area.

3. They should not disturb the worker and hinder him/her from work.

4. They should be suitable for the work, machine and the tool, so that they will not cause a delay in production.

5. They should not hinder oiling, checking, adjusting or fixing the machine or the tool.

6. They should not have sharp corners, dangerous or rough edges or ends and they should not be a source of any kind of accidents.

7. They should prevent flying splinters from reaching the workers.

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Article (5):

The chemical dangers:

A- All necessary precautionary measures should be taken to protect workers from the hazards of being subjected to chemical materials that are used or that leak to the work environment, such as gases and dusts and from the liquids and acids that they may contain, so that they will not exceed the allowed limits in accordance with the table which is attached to this regulation.

B- Taking the appropriate procedures which prevent workers from being harmed or injured when gas, dust, wastes or any impurities are generated during work.

C- The work chambers inside the productive establishments should have good ventilation in accordance with the health requirements that are approved by the Directorate of Environmental and Vocational Health and Safety at the Ministry of Labour, in order to get rid of dusts, gases and other materials that are harmful to the health from where they are originated by using sucking machines or industrial ventilation system.

D- Providing all personal protective tools that fit the nature of working in chemical industries, including filtered masks, suitable shoes, head helmets, hand gloves, work clothes, leather coats and protective glasses.

E- Providing appropriate warehouses that are suitable to store raw and synthesized chemical materials separately, as well as providing all the requirements needed for the storage.

F- Preparing special places or buildings that are isolated from the work places for the industrial processes, machines or tools which could generate harmful vapors, dusts and gases when they are operated, on the condition that these places and buildings are supplied with the necessary protective means that guarantee the prevention of spreading these materials into the work environment.

G- Placing a sticker on each chemical material, specifying the material name, the chemical composition, the trade name, the way it is used and stored, the dangers, the procedures to be protected from and any other necessary information.

Article (6)

Every establishment should be obligated to do the following:

A- Providing instructional and warning plates around the used raw materials, synthesized materials, machines and different processes that indicate the dangers resulting from dealing with these materials and machines, on the condition that they will include the technical instructions that are necessary to prevent injuries and work accidents. These plates should be posted in visible places, as well as in the places of different operations.

B- Carrying out regular maintenance needed for tools, devices and machines by specialized technicians, in a way to secure the safety. The maintenance procedures should be documented in special records that are prepared for this purpose.

C- Preventing any person from removing or assembling any protective barrier or any part of a protective device, unless the tool or the machine failed to work, on the condition that each part should be put back to its original place before re-operating the tool or the machine.

D- Not to possess, sell, rent or transfer tools, machines and devices that have dangerous parts which do not have adequate protection.

Article (8)

When the employer or the in charge director employs a worker in a dangerous industry, the employer should explain to him/her the dangers that he/she might be subjected to as a result of his/her work. The employer or the director should also train the worker for a period not less than one month under his direct supervision or under the supervision of the responsible section director.

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Article (9)

The vocational health and safety inspectors at the Ministry of Labour have the right to examine the technical and scientific specifications of the raw chemical materials, compounds and aids that are used in industrial processes, in order to determine the safety levels of the materials which are dangerous and harmful to health that are allowed to exist at the work environment.

Article (10)

Based on a recommendation from the Directorate of Environmental and Vocational Health and Safety at the Ministry of Labour, the Minister of Labour may add, delete or modify any material from the permitted names or levels that are mentioned in the table attached to this regulation, on the condition that it will be published in the official gazette.

Regulation No. (37) of 2005 Environmental Impact Assessment Regulations- Issued by Virtue of Sub-paragraphs 9 and 11 of Paragraph A of Article 23 of the Environmental

Protection Law No. (1) of 2003

Article 4

A. No industrial, agricultural, commercial, housing or tourism project or any construction development project or any of the projects specified in Annexes 2 and 3 of these Regulations may commence operations with the services relevant thereto, until it obtains the Environmental Approval required for this purpose from the Ministry.

B. The Ministry, upon the recommendation of the Secretary General, may require the owner of the

project not from among those specified in Annexes 2 and 3 of these Regulations to conduct an environmental impact assessment study based on the nature or location of the project, or the nature of the impact that may result therefrom.

Article 8 A. The project owner shall submit an application to the Ministry to obtain the Environmental Approval

needed to establish his project, in accordance with the special form prepared for this purpose, and shall present with it all the necessary information and data, and attaching thereto the preliminary maps, designs and specifications referred to in Annex 1 of these Regulations.

B. The project shall be classified in any of the following categories by decision of the Secretary General on the basis of the recommendations of the competent party at the Ministry: 1. Category 1: includes the projects referred to in Annex 2 of these Regulations and which

require a comprehensive environmental impact assessment.

2. Category 2: includes the projects referred to in Annex 3 of these Regulations and which require a preliminary environmental impact assessment, based on which the need to conduct a comprehensive environmental impact assessment will be determined.

3. Category 3: includes the projects that require neither a preliminary nor a comprehensive

environmental impact assessment.

Article 12 When launching his project and during all the implementation and operation phases, the project owner shall abide by the contents of the Environmental Impact Assessment Document and any other conditions issued by the Ministry when granting its approval.

Article 17

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The Ministry shall regularly monitor the extent of the compliance of the project owner with all the conditions and requirements stipulated in the Environmental Approval during any of the activities of the project including its implementation, operation, and disassembling.

Article 18 The Ministry shall make available to the concerned entities and upon their request, the information and data related to the Environment provided by project owner during the phases of the environmental impact assessment study. In specific cases dictated by the public interest or the provider's own interest, the Ministry may consider some of the data or information provided as confidential.

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Annex 2: Risk Profile of Dosing, Mixing, and Processing PU

A blowing agent is a substance which is capable of producing a cellular structure via a foaming process in a variety of materials that undergo hardening or phase transition, such as polymers, plastics. They are typically applied when the blown material is in a liquid stage. The cellular structure in a matrix reduces density, increasing thermal and acoustic insulation, while increasing relative stiffness of the original polymer.

Blowing agents or related mechanisms to create holes in a matrix producing cellular materials, have been classified as follows: Physical blowing agents e.g. HCFCs, hydrocarbons (e.g. pentane, isopentane, cyclopentane). The bubble/foam-making process is reversible and endothermic, i.e. it needs heat (e.g. from a melt process or the chemical exothermic due to cross-linking), to volatile a liquid blowing agent. However, on cooling the blowing agent will condense, i.e. a reversible process.

Chemicals used in Foam blowing process

• Polyurethane • MDI • CFC • Cyclopentane ( for the substitution of HCFC)

Chemical Hazard Review

Polyol

Polyether Polyol CAS. NO. 25214-63-5

In case of fire emergency: Amber Form: liquid Odor: slight. Use cold water spray to cool fire-exposed containers to minimize the risk of rupture. May cause eye irritation. Firefighters should be equipped with self-contained breathing apparatus to protect against potentially toxic and irritating fumes. Use cold water spray to cool fire-exposed containers to minimize the risk of rupture. Cover spill with inert material (e. g., dry sand or earth) and collect for proper disposal. Use appropriate personal protective equipment during clean up. Evacuate and keep unnecessary people out of spill area. Polyol can be stored at room temperature 15-49 C0 .

It is not flammable since flash point is very high at 196 C0 . Therefore under normal room temperature in most parts of Jordan will not make it vaporize easily. Polyol is stable and not cause polymerization in a reaction with other chemicals. It is not toxic since LD50 is quite high. It does not cause prolonged effect to health. However, it is listed as Hazardous Material according to US OSHA HAZCOM Rating, and USEPA.

MDI Or known as : Polymeric MDI, Polyphenylmethane Polyisocyanate, Crude MDI

Active ingredients:

Diphenylmethane-4,4’-diisocyanate CAS NO.101-68-8 30-60% w/w

Polymethylene Polyphenyl Isocyanate CAS NO. 9016-87-9 30-60% w/w

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Prolonged or repeated exposure may cause skin irritation. May stain the skin. Skin contact may result in allergic skin reactions or respiratory sensitisation but is not expected to result in absorption of amounts sufficient to cause other adverse effects. The LD50 for skin absorption in rabbits is >9400 mg/kg. At room temperature, vapours are minimal due to low vapour pressure. However, certain operations may generate vapour or aerosol concentrations sufficient to cause irritation or other adverse effects. Such operations include those in which the material is heated, sprayed or otherwise mechanically dispersed such as drumming, venting or pumping. Excessive exposure may cause irritation of the eyes,upper respiratory tract and lungs. May cause respiratory sensitisation in susceptible individuals. MDI concentrations below the exposure standards may cause allergic respiratory reactions in individuals already sensitised. Symptoms may include coughing, difficult breathing and feeling of tightness in chest. Effects may be delayed. Impaired lung function (decreased ventilatory capacity) has been associated with overexposure to isocyanates. Systemic (other target organ) effects: Tissue injury in the upper respiratory tract and lungs has been observed in laboratory animals after repeated excessive exposures to MDI/Polymeric MDI aerosols. Cancer Information: Lung tumours have been observed in laboratory animals exposed to aerosol droplets of MDI/Polymeric MDI (6mg/m3) for their lifetime. Tumours occurred concurrently with respiratory irritation and lung injury. Current exposure standards are expected to protect against these effects. Teratology (birth defects): In laboratory animals, Polymeric MDI did not produce birth defects, other foetal effects occurred only at high doses, which were toxic to the mother. Other Health hazard Information: Industrial experience has shown no evidence of carcinogenicity of MDI in humans. An animal study indicates that MDI may induce hypersensitivity following dermal exposure. MDI will support combustion. Toxic fumes are released in fire situations.

Cyclopentane

EC No (from EINECS): 206-016-6 CAS No: 287-92-3 Index-Nr. 601-030-00-2 Chemical formula C5H10 Classification acc. to Regulation (EC) No 1272/2008/EC (CLP/GHS) Flammable liquid: Flam. Liq. 2 – Highly flammable liquid and vapour. Aquatic Chronic 3 - Harmful to aquatic life with long lasting effects. Classification acc. to Directive 67/548/EEC & 1999/45/EC: F; R11 | R52-53 Highly flammable. Harmful to aquatic organisms. May cause long term adverse effects in the aquatic environment. Risk advice to man and the environment Contact with liquid may cause cold burns/frost bite H225 Highly flammable liquid and vapour H412 Harmful to aquatic life with long lasting effects P210 Keep away from heat/sparks/open flames/hot surfaces. - No smoking. P240 Ground / bond container and receiving equipment.

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P243 Take precautionary measures against static discharge. P273 Avoid release to the environment. P233 Keep container tightly closed. P241 Use explosion-proof electrical/ventilating/lighting/equipment. P242 Use only non-sparking tools. P280 Wear protective gloves/protective clothing/eye protection/face protection. P303/361/353 IF ON SKIN (or hair):Remove/Take off immediately all contaminated clothing. Rinse skin with water/shower. P370/378 In case of fire: Use only foam or powder P403/235 Store in a well-ventilated place. Keep cool. P501 Dispose of contents and container in accordance with local regulations. Personal precautions, protective equipment and emergency procedures: Consider the risk of potentially explosive atmospheres. Evacuate area. Ensure adequate air ventilation. Wear self-contained breathing apparatus when entering area unless atmosphere is proved to be safe. Eliminate ignition sources. Prevent from entering sewers, basements and workpits, or any place where its accumulation can be dangerous.

Example: Foam Blowing Machine in Medium-Sized Factory

Common equipment in foam blowing process at medium size factory are;

• Liquid transfer pumps for Polyol and MDI • Jacketed Tanks • Hydraulic units • Stirrer • Ancillary circuits • Temperature control system- water chiller, heat exchanger • High pressure pump with mechanical or magnetic coupling • Level sensor • Mixing head handling system • Mixing head • Programmable Logic Controller (PLC) user interface

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These components in each foam factory are different in term of quality of the design, installation and the way it used by the operator and the effectiveness of maintenance.

When Cyclopentane is to be used on the existing equipment, in the same production area where is surrounding by the other tasks where naked flame is used to trim the excessive plastic from molding process, or poor electrical cables are nearby, the risk of fire and explosion is considerably high.

Summary

• Engineering controls are required to eliminate health hazards and minimize the risk of fire and explosion from flammable atmosphere when cyclopentane is used.

• Education is required to ensure that workers know the new procedures, follow safety rules, use the right steps to do the job

• Enforcement by the government authority. The matter of fact is that the existing working condition at many foam factories are not even close to minimum regulatory requirements.

Fire and Explosion Risk Related to Foam Blowing with Hydrocarbons

It is possible a that vapor, and escape during the production, processing, transportation and storage of flammable materials in foam industries During many processes also flammable blowing agent can leak out due to mishandling, hose rupture, or leakage of equipment. Cyclopentane has the range of flammability between 1.1%-8.7%. In the situation where flammable mixture is formed, the only chance to prevent fire and explosion is to eliminate ignition sources. The area around dosing, mixing and foam injecting station shall be clear from naked flame, free from electric arc and spark from electrical appliances, static charge from poor grounding and bonding. One essential question is, on what legal requirement or international standard that the area classification is defined for the proposed flammable storage and handling area.

Figure 1 Component of Fire and explosion

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Certain characteristic properties of these materials are required for safety considerations. The flash point of a flammable liquid is the minimum temperature at which a liquid gives off vapour in sufficient concentration to form an ignitable mixture with air near the surface of the liquid (at normal air pressure). If the flash point of a flammable liquid is far above the maximum temperatures which arise, an explosive atmosphere may not be formed. The flash point of a mixture of various liquids may be lower than that of the individual components.

Cyclopentane comes in the form of liquid. When it leak it will instantly become vapor because of it’s low flashpoint at

-39 C0 at the room temperature of foam blowing area. Therefore, it is considered as Danger Class AI according to German Technical Regulations for Flammable Liquids (TRbF):

As mentioned above the flammability of cyclopentane and air mixture is between 1.1%-8.7%. The likelihood of having flammable mixture in foam production line under normal circumstances is unlikely. However, this is depending on how well the plant equipment is maintained. How proper is the work processes associated with cyclopentane handling, decanting, dosing, mixing, are performed. To reach the lower flammable limit at 1.1% is seem to be likely if the production line is not in comply with minimum standard practices where incident that lead to uncontrolled release of cyclopentane can occur.

For an explosive atmosphere to form, the flammable material must be present in a certain concentration. If the concentration is too low (lean mixture) or too high (rich mixture), no explosion occurs, rather there is just a slow combustion reaction or none at all. Most likely ignition sources that will ignite the flammable mixture in the area near foam blowing ;

• hot surfaces • electrical arcs and sparks • electrostatic discharge • atmospheric discharge (lightning) • mechanical friction or impact sparks • open flames

Primary explosion protection refers to all precautions which prevent a dangerous, explosive atmosphere from being created. This can be achieved by: • avoiding flammable substances (replacement technologies) • deactivation (addition of nitrogen, carbon dioxide etc.) • limitation of the concentration • natural or artificial ventilation The principle of integrated explosion protection requires explosion protection measures to be taken in a certain sequence. If the danger of explosions cannot be completely or only partly avoided by primary explosion protection measures, then measures must be taken which prevent the ignition of an explosive atmosphere. The hazardous locations are therefore divided into zones, according to the probability of an explosive atmosphere being created In the USA and other countries, hazardous locations are classified into Classes

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and Divisions. For areas classified in this way, requirements must be met concerning the apparatus which are approved to be used in these locations. In addition it is stipulated how to prove that these minimum requirements have been met. Hazardous locations are classified into zones to facilitate the selection of appropriate electrical apparatus as well as the design of suitable electrical installations. Information and specifications for the classification into zones are included in IEC 60 079-10 and in national standards It would be uneconomical and sometimes not even possible to design all explosion protected electrical apparatus in such way that it always meets the maximum safety requirements, regardless of the use in each case. For this reason, the equipment is classified into groups and temperature classes in accordance with the properties of the explosive atmosphere for which it is intended. First of all a differentiation is made between two groups of equipment: Group I: Electrical apparatus for mining. Group II: Electrical apparatus for all remaining potentially explosive atmospheres. The question of possible risks of explosion must be addressed at the early stages of planning a new facility. When classifying potentially explosive areas, the influence of natural or artificial ventilation must be considered in addition to the levels of flammable materials being released. Furthermore, the classification figures relating to explosion technology must be determined for the flammable materials being used Only then a decision can be reached on the division of potentially explosive areas into Zones and the selection of suitable apparatus. International Electrotechnical Commission (IEC) 60 079-14 (DIN 60 079-14) applies to the installation of electrical apparatus in potentially explosive areas Group II.

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Annex 3: Sub-Project Generic EMP Template

Name of company:

Address:

Contact person:

Tel:

E-mail:

Location: Mixed residential and commercial area

Located in building next to road.

Commercial zone Industrial zone

Number of employees

Brief description of the company and its production:

Occupational Health and Safety Coordinator Information: (name(s), titles(s), contact information, educational background, technical training, years of experience in profession as well as at this faciliy

Baseline information: Equipment Unit 1: Unit 2: Current HCFC consumption

2014 2015: 2016:

Approvals by relevant authorities Authorities Item Date HCFC Storage Max Amount Fire safety plan

Drawings and maps Map showing location of factory and surroundings See annex Floor plan production area See annex Plan showing location of HCFC storage area/tank See annex

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Health, Safety, and Environmental Assessment (see accompanying table below) Date conducted: Names and titles of those met with: Other information not included in the table below: Suggested follow-up date: Immediate remedies required: Conducted by:

Firm XXXX will have the following responsibilities during subproject implementation:

• Bear all responsibility, but under monitoring and supervision of the PMU and the World Bank, for the conversion from HCFC-XX to XXXX in AC and/or foam manufacturing. Technical assistance will be provided through the project;

• Request chemical suppliers to provide safety data sheets for the [new refrigerant] and full guidance and training on safely handling these chemicals;

• Follow stringently the safety data sheets when handling these chemicals; • Assign technical staff to monitor the compliance with the safety occupational health and

environment requirements on using chemicals; • Keep workers continuously trained, in cooperation with the NOU and chemical and equipment

suppliers on safe AC/foam production; • Take all necessary measures to prevent leakage of refrigerant during the manufacturing process; • Carry out the mitigation measures for the chemical substance and in case of chemical leakage. • Contract local services for collection and disposal of the empty chemical drums in accordance with

national regulations; • Prepare an EIA following the national regulations in the event that a plant is constructed or

rehabilitated to implement the HCFC phase-out subproject. • Dispose of/utilize baseline equipment; and • Monitor parameters as outlined in the table below.

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Potential Environmental and Social Impacts & Proposed Mitigation Measures as Part of Sub-Project EMP for Firm XXX

Potential Negative Impact Health, Safety and Environmental Assessment Mitigation Measures

Compliance Indicator Monitoring

1) Risk of handling compressed gases

2) Air emissions 3) Water emissions 4) Noise 5) Hazardous chemicals 6) Non-hazardous waste 7) Hazardous waste 8) Occupational health

and safety

9) Training of workers in environment, health and safety

10) Environmental risks

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Potential Parameters to be Monitored as part of Sub-Project EMP for Firm XXX

Parameters to be monitored

Impacts Location Method of Monitoring

Monitoring Frequency

Standard Applied

Monitoring Cost

Responsible Party

Party to Report to

AC or foam manufacturing equipment specifications and design (charging machine, leak detectors)

Production area

Verification of specs & design in implementation & procurement plans

Before procurement

TBD

Included in conversion costs financed by the project

Enterprise and Technical Consultant

NOU

A/C or foam production lines

Occupational health & safety

Production area

Inspection by safety officer

Daily Labour Law No. 8, 1996,

Enterprise, Supplier

NOU

Manufacturing (leakage of refrigerant)

Air emissions, water emissions, noise, soil

Production area

• Internal and external visual inspection.

• Indoor measurements regarding noise and VOC emissions

2 times/year Labour Law No. 8, 1996,

OSHA regulation

Enterprise Local authorities, NOU

Empty drums and waste

Hazardous chemicals &

Non-hazardous waste

Store and Production area

Joint inspection Quarterly • Solid Waste Management Law 2005

• Labor Law no. 8, 1996

• Regulations No. (24) of 2005:


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Parameters to be monitored

Impacts Location Method of Monitoring

Monitoring Frequency

Standard Applied

Monitoring Cost

Responsible Party

Party to Report to

Management, Transportation and Handling of Harmful and Hazardous Substances Regulation

Storage of New Refrigerant

Hazardous chemicals

Store Joint inspection Quarterly Regulations No. (24) of 2005: Management, Transportation and Handling of Harmful and Hazardous Substances Regulation


Implementation of Action Plans

Occupational health & safety, Training of workers in environment, health &safety, Environmental risks

Enterprise Joint inspection 2 times/year Jordanian Laws:

• Environmental Protection law No 52, 2006. • Labour Law No. 8, 1996 • Fire prevention Codes (Civil Defense directorate)

Operating costs of the regulatory authorities

Ministry of Environment, Ministry of Labor, Civil Defense, Health

NOU

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Annex 4: Additional EMP Table for Cyclopentane Use

Checklist for safety measure for conversion to Cyclopentane and delivered by tank truck and stored in storage tank

Components/area National requirements Safety measures Complied with/ Implemented

CP storage tank above or underground.

National requirement for storage of CP CP storage tank located outside the building, And Protected against direct exposure to sunlight

Minimum distance to boundary of the property, to the factory and other buildings.

Location of CP storage tank approved by relevant authority

Access road for delivery of CP Easy access and exits for trucks delivering CP Electrical code normally include requirements regarding electrical installation in areas where explosive gases can occur

Electrical installation in CP tank area in accordance with Indonesian Electrical Code

CP gas detectors installed Fence around the CP storage area Safety marking and signs

CP Pre-mixing unit As per the foam equipment supplier specifications

See supplier specifications regarding safety measures. (Safety measures are normally part of the pre-mixing unit package)

Foaming area and jigs

As per recommendation by MLF and Foam equipment supplier

HP foaming equipment designed for the use CP (ex-proof electrical installation and wiring).

Electrical installations in the area consistent with ex-area classification.

Grounding of foaming equipment and jigs. Ventilation system with design capacity (m3/h) as specified by equipment supplier installed.

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CP Gas Detection System installed. CP Gas detectors installed. Nitrogen system installed. Fire fighting equipment installed.

Awareness and training

Involve local fire authority General awareness Training of workers

Operational manual for workers involved in handling CP foaming

Supplier of foaming and safety equipment

Training of workers involved in foaming.

Use of spark free tools in areas with risk of CP.

Checking and maintenance of safety measures

Recommended practice by foam equipment supplier and suppliers of fire safety equipment and relevant safety authorities

Develop a daily, monthly quarterly and annual program for checking and reporting.

Emergency plan Prepared in cooperation with suppliers and local safety authorities

Develop an emergency plan by internal team and with advice from local fire safety authorities.