CONFIDENTIAL
1
RSPO MAIN ASSESSMENT REPORT
FELDA KAHANG PALM OIL MILL COMPLEX CERTIFICATION UNIT
1 FELDA PALM INDUSTRIES SDN BHD, KAHANG PALM OIL MILL, 86007, KLUANG, JOHOR DARUL TAKZIM 2 FELDA KAHANG BARAT, PEJABAT FELDA KAHANG BARAT, 86009, KLUANG, JOHOR DARUL TAKZIM 3 FELDA KAHANG TIMUR, PEJABAT FELDA KAHANG TIMUR, 86000, KLUANG, JOHOR DARUL TAKZIM 4 FELDA ULU DENGAR, PEJABAT FELDA ULU DENGAR, 86000, KLUANG, JOHOR DARUL TAKZIM
SIRIM QAS INTERNATIONAL SDN. BHD. Building 4, SIRIM Complex, No. 1 ,Persiaran Dato’ Menteri, Section 2, P.O. Box 7035, 40911 Shah Alam, Selangor, Malaysia. Tel: 603 5544 6448 Fax: 603 5544 6763 Website : www.sirim-qas.com.my
SIRIM QAS INTERNATIONAL SDN. BHD. Building 4, SIRIM Complex, No. 1 ,Persiaran Dato’ Menteri, Section 2, P.O. Box 7035, File Reference 40911 Shah Alam, Selangor, Malaysia. EF03060002
RSPO ASSESSMENT REPORT
CLIENT: FELDA GLOBAL VENTURES PLANTATIONS (MALAYSIA) SDN. BHD.
ADDRESS : Tingkat 8, Balai FELDA, Jalan Gurney 1, 54000 Kuala Lumpur, Malaysia
PALM OIL MILL: FELDA PALM INDUSTRIES SDN. BHD. Kahang Palm Oil Mill
SUPPLY BASE: 1 FELDA Kahang Barat, Pejabat FELDA Kahang Barat, 86000, Kluang, Johor Darul Takzim 2 FELDA Kahang Timur, Pejabat FELDA Kahang Timur, 86000, Kluang, Johor Darul Takzim 3 FELDA Ulu Dengar, Pejabat FELDA Ulu Dengar, 86000, Kluang, Johor Darul Takzim
ADDRESS OF SITE: FELDA, Kahang Palm Oil Mill Complex Certification Unit Kilang Sawit Kahang 86000 Kluang, Johor Darul Takzim, Malaysia
ASSESSMENT DATE: STAGE 2 : 10TH, 11TH & 14TH DECEMBER 2012 DURATION : 15 AUDITOR DAYS
STANDARD: ROUNDTABLE ON SUSTAINABLE PALM OIL (RSPO) INCLUDING SMALLHOLDER MALAYSIA NATIONAL INTERPRETATION WORKING GROUP (MY-NIWG): NOV 2010 AND SUPPLY CHAIN CERTIFICATION SYSTEM REQUIREMENTS, NOV 2011
SCOPE OF CERTIFICATION ASSESSMENT: PRODUCTION OF CRUDE PALM OIL AND PALM KERNEL USING MASS BALANCE MODEL.
i TABLE OF CONTENT Page no
Abbreviation used iv
1.0 Introduction ...... 1 1.1 Description of the Certification Unit ...... 1 1.2 Description of FELDA and its Settlers Scheme ...... 1 1.3. Organisation structure in a scheme ...... 2 1.3.1 Settler’s Institution...... 4 1.3.2 Facilities provided in a scheme ...... 5 1.4 Workforce composition ...... 5 1.5 Time Bound Plan for Other Management Units and Justification...... 5 1.6 Location of Mill and Supply Base ...... 6 1.7 Description of the Supply Base...... 6 1.8 Other Management System Certification Held ...... 8 1.9 Organizational Information/Contact Person ...... 8 1.10 Approximate FFB Tonnages Offered for Certification ...... 8
2.0 Assessment Process...... 8 2.1 Assessment Methodology (Program, Site Visits) ...... 9 2.2 Date of Next Surveillance Visit ...... 9 2.3 Assessment Team ...... 9 2.4 Stakeholder Consultations ...... 12
3.0 Assessment Findings ...... 12
4.0 Comments from Stakeholder ...... 67
5.0 Assessment Recommendation ...... 67
6.0 Certified organization’s Acknowledgement of Internal Responsibility and Formal sign-off of assessment findings ...... 67
List of Tables
Table 1 Total and Composition of Workers in the Certification Unit as of December 2012 Table 2 Coordinates of Kahang CU (Mill and Estates) Table 3a Annual (Jan 1st 2012 – 31st December 2012) FFB Contribution by Each Scheme to
ii Kahang Palm Oil Mill Table 3b Annual Total CPO and PK Production (Jan 1st 2012 – 31st December 2012) by Kahang Palm Oil Mill Table 4 Year of Establishment of Estates and Area Planted with Oil Palm Table 5a Planting Cycle : FELDA Ulu Beltiong
Table 5b Planting Cycle : FELDA Bulit Tongkat Table 5c Planting Cycle : FELDA Ulu Penggeli Table 5d Planting Cycle : FELDA Air Hitam Table 5e Planting Cycle : FELDA Bukit Permai Table 5f Planting Cycle : FELDA Layang-Layang Table 5c Planting Cycle : FASSB Belitong Table 5h Layang2, FASSB Belitong, Inas Selatan (Div B – Bukit Tongkat) Table 6 Approximate CPO and PK tonnage Claim for Certification in 2013
List of Attachments
Attachment 1a Time Bound Plan Attachment 2a Location map for FELDA Kahang CU in neighbouring context Attachment 2b Location map for each schemes Attachment 2c Location map for Felda Kahang Barat Attachment 2d Location map for Felda Kahang Timur Attachment 2e Location map for Felda Ulu Dengar Attachment 3 Assessment programme Attachment 4 List and Comment from Stakeholders Attachment 5 Non-Conformity Report Attachment 6 List of Opportunity for Improvements
iii Abbreviations:
BOD Biochemical Oxygen Demand B.Sc. Bachelor of Science CHRA Chemical Health Risk Assessment CoC Consolidated Annual Charges COD Chemical Oxygen Demand CPO Crude Palm Oil CU Certification Unit DID Drainage and Irrigation Department, Malaysia DOE Department of Environment DOSH Department of Occupational Safety and Health EARA Environmental Auditors Registration Association EB Executive Board EFB Empty Fruit Bunch EMP Environmental Management Plan EPF Employees Provident Fund EQA Environmental Quality Act ERT Endangered, Rare and Threatened Species FIC FELDA Investment Cooperative FFB Fresh Fruit Bunch GAP Good Agricultural Practice GPS Global Positioning System GPW Gabungan Pembangunan Wanita (Women Development Association) GSA Group Settlement Act Ha Hectares HCV High Conservation Value HIRARC Hazard Identification, Risk Assessment and Risk Control IEMA Institute for Environmental Management and Assessment IPM Integrated Pest Management ISP Incorporated Society of Planters IRCA International Register of Certificated Auditors JCC Joint Consultative Committee JKKR Jawatankuasa Kemajuan Rancangan (Scheme Development Committee) M.E Master of Engineering MSDS Material Safety Data Sheet MNS Malaysian Nature Society MOA Memorandum of Alliance or Agreement MPOA Malaysian Palm Oil Association MPOB Malaysia Palm Oil Board MYNI Malaysia National Interpretation MYNI – WG Malaysia National Interpretation – Working Group NCR Non-Conformity Report NGO Non Governmental Organisation OER Oil Extraction Rate OFI Opportunity for Improvement OHD Occupational Health Doctor OSH Occupational Safety and Health OHSAS Occupational Health and Safety Assessment Series
iv PERKESO Social Security Organization PDRM Polis Di-Raja Malaysia Ph.D. Doctor of Philosophy POM Palm Oil Mill POME Palm Oil Mill Effluent PPE Personal Protective Equipment RSPO Roundtable on Sustainable Palm Oil SIA Social Impact Assessment SS Suspended Solid SOP Standard Operating Procedure USA United States of America USECHH Use and Standards of Exposure of Chemicals Hazardous to Health WTP Water Treatment Plant WWF World Wide Fund for Nature
v RSPO STAGE 2 ASSESSMENT REPORT
1.0 Introduction
1.1 Description of the Certification Unit
FELDA Global Ventures Plantations (Malaysia) Sdn Bhd – (hereinafter referred to as FGVPM) – principally an investment holding company was tasked by FELDA Global Ventures Holdings Berhad to oversee those FELDA-leased land and land belonging to settlers planted with oil palm obtain certification against the RSPO standard in accordance to the time bound plan set by FELDA.
This certification unit (CU) of FGVPM Kahang Palm Oil Mill Complex (FGVPM-KCU) was assessed for certification against the RSPO Principles and Criteria for Sustainable Palm Oil Production, including smallholder, Malaysia National Interpretation Working Group (RSPO MYNIWG: November 2010) and RSPO Supply Chain Certification System (SCCS) Requirements November 2011. The smallholder schemes were assessed against the national guidance for scheme smallholders.
This certification assessment covered FELDA Kahang Palm Oil Mill and its supply bases, that is, three smallholders’ schemes from land owned by settlers. It did not include the third party FFB suppliers.
The smallholder schemes began development in phases as far back as 1973. They are land owned by settlers in accordance with the Group Settlement Act (GSA) 1960, and, throughout Malaysia they are being administered by the Federal Land Authority, in short FELDA, a government of Malaysia owned agency.
One FELDA Manager manages one smallholder’s scheme. He is primarily tasked to oversee the socio-economic aspect and welfare of the settlers whereas on the field operational support he is assisted by FELDA Technoplant Sdn. Bhd (hereafter referred to as FTPSB) Manager. FTPSB is a subsidiary of FELDA Holdings Berhad (FHB) which is responsible for managing smallholder plantation areas (those who for inevitable reasons elected not to work on their farm) from replanting to production of FFB as well as the maintenance of these planted areas.
There is also another subsidiary company of FHB, FELDA Agriculture Services Sdn Bhd (FASSB) whose core business is research of palm oil seeds, producing and selling seedlings, rat baits and the provision of foliar and soil analysis, whom FGVPM-KCU can call upon to assist on a need basis.
1.2 Description of FELDA and its Settlers Scheme
FELDA is a government agency established under the Land Development Ordinance on 6th July 1956. Its objectives were:
to provide land for the landless. to uplift socio-economic status of rural communities; and to encourage the development of a progressive, productive and disciplined settlers community.
MSC/RSPO/DOC/06-02 Issue 1 Rev. 0 Page 1 of 102 In the following year FELDA initiated the first land development by planting rubber trees at Lurah Bilut, Pahang. In 1958, five similar schemes were opened. Subsequently, via Group Settlement Act 1960 FELDA developed more areas. To date, 853,313 hectares (as of March 2012) of land had been opened for cultivation, infrastructure, settlers’ housing and public facilities for 112,635 settlers. 811,140 hectares were allocated for agricultural area of which 722,946 hectares or 84.7 % had been planted with oil palm trees. The remaining areas were planted with rubber, sugar cane, timber, and fruit trees and plot for research and development. FELDA settlers’ settlement area (village) accounted for 42,173 hectares or 4.9 % of land developed.
Managed as an estate style (1700 – 2500 ha.), a typical settlers’ settlement range between 400- 600 settlers per scheme and each settler was given a house and a plot of land to farm.
At FGVPM-KCU each settler was assigned to a particular settlement, and was given 10 acres (4.0 ha.) of land to cultivate oil palms. All of them planted oil palm trees as their first crop and continue to do so with replanting.
As a scheme participant, all settlers were required to reside at the settlement itself, and were allotted an additional 0.25 acres (0.10 ha) each in a planned village, where their home - built by FELDA - is located. About 20 houses made up a block and each block chose its own representatives who voice their concerns to their Scheme Development Committee (JKKR) and FELDA Management. All basic infrastructures, such as piped water, electricity, schools, clinics, and places of worship were provided either by FELDA or through government agencies.
The costs of acquiring, developing and allocating the land were borne by loans made to FELDA settlers. These loans were to be repaid in monthly installments deducted from the settlers' income over a 15-year period.
Although settlers were supposed to focus on agricultural activities, they also were encourage by the government to participate in non-farm activities, such as entrepreneurship in SAWARI Program (food and craft industry) Agro-based industry, Business, Services and Related activities, etc, as side income to help alleviate their financial needs.
1.3. Organisation structure in a scheme
In a settlers’ scheme, as evident at FGVPM-KCU the management of the scheme was based on the structure as shown in Figure 1.
They comprised of two committees in a scheme, one representing FELDA, referred to as Management Committee and the other representing the settlers, known as Settler Committee.
The Scheme Manager besides being responsible to coordinate and manage all aspects in a scheme in an estate like manner was also responsible to the Regional General Manager (RGM), FELDA Segamat, Johor for community development, welfare and well being of its settlers, their dependant get adequate income, and ultimately FELDA fulfill their social, educational and economic obligations/needs.
MSC/RSPO/DOC/06-02 Issue 1 Rev. 0 Page 2 of 102
Figure 1: Organisation structure in a scheme
The settlers’ obligation was to farm their land in accordance to Good Agricultural Practices determined by the Scheme Manager. There are two types of settler’s in a scheme, that is, those who tend their farm on their own and those who farm-out their land (because of deceased parent (1st generation plot owner), old age and sickness) to FTPSB. The Scheme Manager together with his Field Supervisors will oversee that the settlers who tend to their own farm and those run by FTPSB conform to those practices in accordance to FELDA Plantation standard by making daily field visits. The duties of office staff were to monitor the implementation of all activities in a scheme and maintain certain records of implementation.
The binding contract between a settler and FELDA is an agreement tying both parties for a CoC (Consolidated Annual Charges).
MSC/RSPO/DOC/06-02 Issue 1 Rev. 0 Page 3 of 102 1.3.1 Settler’s Institution Leadership and involvement of settler’s in scheme management is shown in Figure 2 and are implemented through:
Block Management Scheme Development Committee (Jawatankuasa Kemajuan dan Keselamatan Rancangan - JKKR) JKKR Coalition Settler's Consultancy Committee (Jawatankuasa Perunding Peneroka - JKPP) Women Association Movement (Gerakan Perkumpulan Wanita – GPW)
All of these Settler's Bodies play major roles toward Settler's Institution development.
National Level
Regional Level
Scheme Level
Block Level Block Level Block Level
Figure 2 : Settler Participation in Management
JKKR Coalition is the supreme council for settlers at the Regional level aimed to unite ideas, efforts and energy towards improving production, farm development and formation of settler's family well being. Settler's top involvement and participation in the management and administration of the scheme is through Settler’s Consultancy Committee, (JKPP).
JKPP is a supreme council where committee members comprised of FELDA's top management, Heads of Male/Female Settlers and Youth leaders. JKPP becomes the relation and consultation body between Head of Settlers and FELDA's management. Other roles of JKPP are to study, check, consider and take resolutions of policies concerning settlers.
A land scheme, as mentioned above, normally would involve between 400 – 600 smallholders and the scheme is divided into blocks. .Each block typically consists of 20 settler families. They among themselves elect Block Leaders and each block is represented by 2 Block Leaders. The leaders co-ordinate activities within their group members and voice member’s concern during the Scheme level meeting..
Collectively, the settlers through their committee can raise issues of concerns to the Management Committee who via the mandate vested in them would resolve the issues amicably. If it cannot be resolved at the Scheme Level, it can be escalated to the Regional and National Level as described above under Settler’s Institution.
MSC/RSPO/DOC/06-02 Issue 1 Rev. 0 Page 4 of 102 There are also local stakeholders in a scheme. Local stakeholders are organizations / groups involved with the settler community / management such as Gerakan Perkumpulan Wanita (Women Movement) and Majlis Belia (Youth Council).
In the FELDA schemes assessed, besides the Scheme Manager there usually is between 8 -15 other staff comprising of Field Supervisors, office clerks and driver.
1.3.2 Facilities provided in a scheme
Through site visits, the assessors witnessed the presence of the following infrastructure in all schemes assessed. It included mosque, kindergarten, primary school, religious school, staff quarters, shops, cooperative garage and motor vehicle workshop, scheme/plantation administration office, fertilizer store and community hall.
1.4 Workforce composition
The total and composition of the workforce at the FGVPM-KCU assessed is as shown in Table 1.
Table 1: Total and Composition of Workers in the Certification Unit as of Dec 2012
Operating Unit Local Foreign Sub-Total Kahang POM 90 - 90
FELDA Kahang Barat 14 69 83
FELDA Kahang Timur 26 44 70
FELDA Ulu Dengar 3 27 30 Grand Total 133 140 273
Foreign workers account for about 51% of the CU’s total field/plantation workforce whereas at the mill the composition of workforce is 100% local.
1.5 Time Bound Plan for Other Management Units and Justification
Being a member of RSPO, FELDA is committed to full compliance with the RSPO's Principles and Criteria (P&C) in all its operations in Malaysia. As of to date, FELDA had attained RSPO certification in one Smallholder Group Certification Unit, and sixteen mill complexes in Pahang and Johor.
In year 2012, eight CU were being assessed.
It also had established a challenging and realistic time bound plan, as shown in Attachment 1, to certify all of its estates and mills by the year ending 2017. FELDA have been on schedule with the time bound plan for the certification of all the CUs. This FGVPM-KCU is among the latest one to be assessed for certification.
MSC/RSPO/DOC/06-02 Issue 1 Rev. 0 Page 5 of 102 1.6 Location of Mill and Supply Base
There are three (3) types of FFB supplier to FELDA Palm Industries Sdn. Bhd. (FPISB), Kahang Palm Oil Mill. It consists of the following:
1 FELDA settlers, whom choose to be independent. They carry out replanting and manage their estates by themselves and sell the FFB to FELDA mills. 2 FELDA schemes, which is made up of smallholder schemes with dependents (settlers) whom due to inevitable reason (death of breadwinner, age, etc) had opted to let FTPSB to manage on their behalf replanting and ongoing management of their plots. 3 Other estates: Commercial oil palm plantations belonging to independent outgrowers . The FGVPM-KCU covers one palm oil mill and three oil palm schemes, all in the state of Johor. The locations of the mill and schemes are shown in Table 2.
Table 2: Coordinates of Kahang CU (Mill and Estates)
Post Code, District, Mill / Scheme State *Latitude *Longitude FELDA Palm Industries, 86000 Kluang, Johor 2° 07' 49" N 103° 49' 30" E Kahang Palm Oil Mill, FELDA Kahang Barat 86000 Kluang, Johor 2° 02' 03" N 103° 25' 25" E
FELDA Kahang Timur 86000 Kluang, Johor 2° 05' 11" N 103˚ 29’ 29’’E
FELDA Ulu Dengar 86000 Kluang, Johor 2˚ 04’ 33’’N 103˚ 30’ 05’’ E
* Coordinate readings were taken at the respective scheme administrative office
The location map of the CU is shown as in Attachment 2.
1.7 Description of the Supply Base
All the above FELDA land schemes had been supplying FFBs to the Kahang POM. Apart from these estates, there were six outside crop suppliers, three of which had been regularly sending their FFB to the FELDA Kahang POM. These six FFB suppliers are FFB traders.
Data on FFB supply information as well as CPO and PK production is as per the table below.
Table 3a: Annual (Jan 1st 2012 – 31st December 2012) FFB Contribution by Each Scheme to Kahang Palm Oil Mill
FFB Production Land Scheme Tonnes Percentage FELDA Kahang Barat 29,500 13.35 FELDA Kahang Timur 33,100 14.98
FELDA Ulu Dengar 5,800 2.63
Outgrowers crop 152,520 69.04 Total 220,920 100.00
MSC/RSPO/DOC/06-02 Issue 1 Rev. 0 Page 6 of 102 Table 3b: Annual Total CPO and PK Production (Jan 1st 2012 – 31st December 2012) by Kahang Palm Oil Mill
OER, % CPO Production (MT) KER, % PK Production (MT) 19.59 12387.30 5.60 3484.13
FELDA follows a 25-year replanting cycle. Table 4 shows the details of the year of establishment of the estates, year started/switched to oil palm and their respective total land and area planted with oil palm, while Tables 5a to 5h show the percentage of planted area in each estate by year of planting and the planting cycle.
Table 4: Year of Establishment of Estates and Area Planted with Oil Palm
Year of Year started/ Total Area Planted Area Operating Unit Establishment switched to (ha) (ha)
oil palm Started with Oil FELDA Kahang Barat 1973 1945.79 1832.79 Palm FELDA Kahang 1974 Started with Oil 2388.46 1942.54 Timur Palm Started with Oil FELDA Ulu Dengar 1974 1653.91 1439.15 Palm Total 5988.16 5214.48
Table 5a: FELDA Kahang Barat
Plot Year of Planting Cycle Planted Area (ha) Percentage of Planting Planted Area 01 2003 2nd generation 902.64 49.3
02 2004 2nd generation 680.27 37.1
03 2008 2nd generation 97.09 5.3
04 2004 2nd generation 152.79 8.3 Total 1832.79 100.00
Table 5b: FELDA Kahang Timur
Plot Year of Planting Cycle Planted Area (ha) Percentage of Planting Planted Area 01 2003 2nd generation 928.00 47.8
02 2004 2nd generation 572.44 29.5
03 2011 2nd generation 214.2 11.0
04 2011 2nd generation 227.9 11.7 Total 1,942.54 100.00
MSC/RSPO/DOC/06-02 Issue 1 Rev. 0 Page 7 of 102 Table 5c: FELDA Ulu Dengar
Year of Planting Cycle Planted Area (ha) Percentage of Planting Planted Area Plot 01 2006 2nd generation 305.35 21.2
02 2009 2nd generation 396.29 27.5
03 2012 2nd generation 580.05 40.3
04 2012 2nd generation 157.46 10.9 Total 1439.15 100.00
1.8 Other Management System Certification Held
All the three FELDA land schemes assessed except for the FELDA Palm Industries Kahang Palm Oil Mill do not hold any form of third-party certification to any of the internationally recognized management systems. The mill is certified to ISO 9001:2008, ISO 14001:2004 and OHSAS 18001:2007 and had completed the annual surveillance audit. Its certificates are valid.
1.9 Organizational Information/Contact Person
Name :.Norazam Abdul Hameed Designation : Head, Plantations Sustainability & Quality Management Address : FGV Plantations Malaysia Sdn Bhd Tingkat 8, Balai FELDA, Jalan Gurney 1, 54000 Kuala Lumpur, Malaysia. Telephone : +03-2698 7772 Fax : +03-2691 1378 e-mail : [email protected]
1.10 Approximate FFB Tonnages Offered for Certification
The approximate tonnage of CPO and PK produced per year, as well as the tonnage claimed for certification, are as shown in Table 6 as follows:
Table 6: Approximate CPO and PK tonnage Claimed for Certification in 2013
Tonnage Claimed for Certification (MT) Certification Unit CPO PK FELDA Kahang Palm Oil Mill Complex 12387 3484 Certification Unit
2.0 Assessment Process
MSC/RSPO/DOC/06-02 Issue 1 Rev. 0 Page 8 of 102 2.1 Assessment Methodology (Program, Site Visits)
The assessment for certification was carried out in conformity with the procedures as laid down in SIRIM QAS Procedure Manual. During the assessment qualified SIRIM QAS assessors used the RSPO:MYNI November 2010 standard and RSPO Supply Chain Certification System (SCCS) Requirements November 2011.and recorded their findings.
There was no Stage 1 assessment conducted to determine the adequacy of the established documentation in addressing the requirements of the RSPO MYNI November 2010 standard and RSPO Supply Chain Certification System (SCCS) Requirements November 2011. The company instead relied on using the experience of main assessment from past CU RSPO assessments to ensure that this management unit conformed to the RSPO Principles & Criteria.
The RSPO Stage 2 assessment was conducted from 10th-11th December 2012. The main objective of the assessment was to verify the CU’s conformance to the requirements of certification standard, the RSPO MYNI (including smallholder November 2010) and RSPO Supply Chain Certification System (SCCS) Requirements November 2011. The planning for the Stage 2 assessment was guided according to the RSPO Certification Systems Document. After studying the document given to us, it was decided that the sampling formula of 0.8√y to determine the number of schemes to be audited would be used. Besides the Kahang Palm Oil Mill, a total of two FELDA smallholder schemes were assessed.
The assessment was conducted by visiting the fields, mill and settlers’ houses to verify implementation. Interviews were held with the CU’s management, settlers, employees, contractors and other relevant stakeholders. Related records and other documentation audit were conducted at all estates and mill visited.
Details of the actual assessment programme are given in Attachment 3.
2.2 Date of Next Surveillance Visit
The first surveillance audit will be conducted around twelve months from the date of issuance of the certificate.
2.3 Assessment Team
Member of the Role/area of RSPO Qualifications Assessment Team requirements Collected over 400 days of auditing experience in OHSAS 18001 and MS 1722 OHSMS (72 days for palm oil milling & 8 days for oil palm plantation) and 60 days of RSPO. Lead Assessor / CIMAH Competent Person with Occupational Health Malaysian Department of Occupational Mahzan Munap and Safety, Safety and Health (DOSH) since 1997. Environment & Occupational Safety and Health Trainer related legal issues at INSTEP Petronas Successfully completed RSPO Lead Assessor Course – 2008. Successfully completed Lead Assessor Course for OHSAS 18001- 2000.
MSC/RSPO/DOC/06-02 Issue 1 Rev. 0 Page 9 of 102 Successfully completed IRCA accredited Lead Assessor training for ISO 9001- 2006 Successfully completed RABQSA accredited Lead Assessor training for ISO 14001- 2008 MBA, Ohio University. a. B.Sc. Petroleum Engineering, University of Missouri, USA.
Collected 70 auditor days in auditing Forest Management Certification (FMC – MC&I 2002 and MC&I Natural Forest) Collected 38 auditor days in auditing RSPO Overall Team Leader 11 years working experience related to Assessor / ecology KhairulNajwan forest management, inventory, and environmental Ahmad Jahari surveying, HCVF and logging operation. issues/ HCV / Successfully completed accredited Lead Forestry Assessor training for ISO 14001: 2004, ISO 9001:2008 and OHS 18001:2000 Successfully completed RSPO Lead Assessor Course – 2011. B. Sc of Forestry (Forest Management) 8 days experience as Technical Adviser to RSPO Audits. 14 days of auditing experience in RSPO. B. Sc. (Hons) Agriculture – University of Agricultural Sciences, Hebbal, Banglore, India (1969-1973) A Planter with Kumpulan Guthrie Berhad (1995-2002 – retired) Assessor / Good Inclusive of One year in Liberia and Agricultural Practices Selvasingam TK 2 years in Estate Department in (GAP) and Guthrie head quarters environmental issues Experience in Managing: Nursery : Rubber and Cocoa Immature Area : Cocoa Replant, Rubber Replant, Oil Palm Replant & Oil Palm New Clearing Mature Area: Cocoa, Rubber & Oil Palm.
b. Collected over 40 days of auditing experience in ISO 14001, 75 days of Assessor, CDM (Carbon Development Hafriazhar B Mohd environmental issues Mechanism), 5 days of RSPO and 1 day Mokhtar related to mill and of ENMS (Energy Management System). plantation c. Conduct bi‐weekly internal site audit, monthly environmental compliance report to client & participate in the
MSC/RSPO/DOC/06-02 Issue 1 Rev. 0 Page 10 of 102 environmental audit inspections by client & authority (Dec 2002 –Sep 2003) d. 4 ½ years working experience in Palm Oil mill beginning with Cadet Engineer and rising upto Senior Assistant Mill Manager. Successfully completed RABQSA/IRCA EMS Lead Assessor Course for ISO 14001 in 2011. Successfully attended SIRIM QAS in- house training on CDM and ENMS in 2011. e. Bachelor Degree Engineering (Chemical), University Teknologi Malaysia
Collected 45 auditor days in auditing Forest Management Certification (FMC – MC&I 2002) and 13 auditor days in auditing FSC P&C. Collected 45 audit days in auditing RSPO Peer reviewer for FSC Forest Management certification reports B.A. Hons (Social Anthropology / Sociology) M.A. (Social Anthropology) Ph.D. (Major: Cultural Anthropology; Minors: Southeast Asian Studies International Agriculture and Rural Development Assessor / workers& 1977- 1992 – Lecturer, Department of community issues Social Sciences, Faculty of Dr.ZahidEmby and related legal Educational Services, Universiti issues Pertanian Malaysia Head, August 1992 – 1994, Department of Social Development Studies, Universiti Pertanian Malaysia August 1, 1998 -2001. Reappointed as Head of the renamed Department of Social and Development Science for a three year term Head, Department of Music from October 2003 until his retirement on December 17, 2006 Spent some time as a visiting scholar at University of Hull, U.K. and Victoria University of Wellington, New Zealand. Freelance consultant on social issues
MSC/RSPO/DOC/06-02 Issue 1 Rev. 0 Page 11 of 102
2.4 Stakeholder Consultations
SIRIM QAS International Sdn Bhd (SIRIM QAS International) initiated the stakeholder consultation by announcing the invitation in the RSPO and SIRIM QAS International’s websites on 15th November 2011. In addition, SIRIM QAS International had also sent invitations through letters to the relevant stakeholders, including government agencies and Non-Governmental Organizations (NGOs) on 15th November 2011. This was followed-up by telephone calls.
Whenever necessary, meetings with the relevant stakeholders were arranged during the on- site assessment. Please see Principle 6.
The consultation with the government agencies had involved meetings and discussions with the relevant departments mainly to solicit information as well as verification on the CU’s compliance with the applicable laws and regulations related to its operations.
The consultations with the NGOs were held to seek their comments mainly on the CU’s compliance with those criteria related to the social and environmental issues.
The method of consultation with the settlers, contractors and FELDA staff were through random sampling from each group in each of the FFB supplying unit and oil mill (e.g. mill operators, harvesters, general workers and sprayers) visited. The consultations which were conducted at the CU’s office had included solicitation of comments on issues relevant to principles 1 to 6 of the RPSO MYNI.
The consultations by assessors with the local communities were held at two different venues, that is at FELDA office and the other was by visiting the settler’s home/village during the times that were convenient to them. The intention was to solicit their views on the impact of the FGVPM-KCU’s operations on their economics and socio-cultural lives.
Outcome from the stakeholders being consulted is as in Attachment 4.
3.0 Assessment Findings
The findings of the assessment were highlighted and discussed during the on-site assessment. A total of fourteen (14) nonconformity reports (NCR) were raised on the FGVPM-KCU against the requirements of the RSPO MYNI, November 2010 and one against RSPO Supply Chain Certification System (SCCS) Requirements November 2011. Nine were categorized as Major and five as Minor non-conformities. Details of the non- conformities raised and corrective actions taken by the CU are as in Attachment 5. Evidences of the actions taken had been submitted to the assessment team. In addition to the NCR, twelve observations or opportunities for improvement were identified for the CU to improve in meeting with the requirements of the RSPO MYNI (see Attachment 6).
The detailed findings of the assessment on the CU’s compliance with the requirements of the RPSO MYNI and RSPO Supply Chain Certification System (SCCS) are as follows:
PRINCIPLE 1: COMMITMENT TO TRANSPARENCY
Criterion 1.1 Oil palm growers and millers provide adequate information to other stakeholders on environmental, social and legal issues relevant to RSPO Criteria, in appropriate languages and forms to allow for effective participation in decision making MSC/RSPO/DOC/06-02 Issue 1 Rev. 0 Page 12 of 102
Indicators: 1.1.1 Records of requests and responses must be maintained. Major compliance
Specific National Guidance for Scheme Smallholders Scheme Smallholders Scheme managers should assist in ensuring compliance by their organized smallholders in providing adequate information. Scheme managers must ensure that participant are given copies of:
-chemical use (4.6) -to-date records of debts and repayments, charges and fees (6.10) s are made available the following documents:
- Health and safety plan (4.7). - Plans and impact assessments relating to environmental and social impacts (5.1, 6.1, 7.1, 7.3). - Pollution prevention plans (5.6). - Details of complaints and grievances (6.3). - Negotiation procedures (6.4). - Procedure for calculating prices, and for grading, FFB (6.10) - Continuous improvement plan (8.1) confidential
Findings:
There was available procedure of communication as evidenced in FELDA Palm Industries Sdn Bhd (FPISB) No. document: FPI/L2/QOHSE-6.0 entitlted Manual Prosedur, Komunikasi, Penglibatan dan Rungdingan (Communication, Participation and Consultation). It involved internal and external consultation.
Additionally, FELDA has a website, www.feldaglobal.com for promotion of its products. The website contained brief information about the company’s profile, vision and key objectives, corporate structure, business operations, investor relations, financial, sustainability and corporate social responsibility.
FELDA had dedicated substantial resources to ensuring that every aspect of its business emulates the eight principles as laid out under Principles and Criteria for Sustainable Palm Oil which was accepted as the most complete document defining sustainable palm oil production, and follow the requirements of Module E: CPO Mill Mass Balance of the RSPO Supply Chain Certification System.
With respect to RSPO, FELDA had provided adequate information on issues relevant to interested stakeholders including publishing on its website inviting all stakeholders to take part to make a positive contribution to the RSPO certification decision. FELDA had asked all stakeholders to raise any issues, both positive and negative, in written form (by mail, fax or e-mail) or by attending an open stakeholder meeting at the site. It also had written to all stakeholders informing them on the availability of documents for public review.
A management official at the operating unit level had been assigned to be in charge on communication and consultation with stakeholders.
During the assessment, it was observed that FGVPM-KCU had compiled a list of local stakeholders that may be relevant to its operation. Immediate neighbouring stakeholders identified include KUB Estate, Rengo Estate, Tradewind Estate and Sindora Estate, The letters to stakeholders and the records of request were examined in the scheme inspected.
MSC/RSPO/DOC/06-02 Issue 1 Rev. 0 Page 13 of 102 A briefing for and discussion with stakeholders was held on 13th July 2012 at Meeting Room FELDA Segamat Regional Office as evidenced by the signed list of attendance. From the above records, it was evident that the company had committed to be transparent in its dealings with internal and external stakeholders. Please see Attachment 3 for List and comments from stakeholders.
In addition to the above, it was also seen there were regular (almost monthly) communications with Wildlife Department by FELDA Kahang Barat. The latest record was on 8th December 2012 via e-aduan (complaint on-line) regarding the encroachment of elephant.
There was also communication with the Johor State Forest Department on 6th November 2012. The last communication was evident through the meeting minutes. The system is thus transparent and the record was well kept by the FELDA Manager (Mr Wahab).
There was also evidence that Scheme Managers had assisted in ensuring compliance to RSPO P&C by providing adequate information to their scheme smallholders (settlers). The participants were given copies of contract between FELDA and them, up-to-date records of debts and repayments, charges and fees. Others include demonstration training on the safe use of agro-chemical, information on integrated pest management, health and safety plans, social and environmental impact / aspect assessments and plans, pollution prevention programs, procedure for complaints and grievances and procedure for calculating prices, and for grading FFB.
Criterion 1.2 Management documents are publicly available, except where this is prevented by commercial confidentiality or where disclosure of information would result in negative environmental or social outcomes. This concerns management documents relating to environmental, social and legal issues that are relevant to compliance with RSPO Criteria. Documents that must be publicly available include, but are not necessarily limited to:-
1.2.1 Land titles / user rights (C 2.2) 1.2.2 Safety and health plan (C 4.7) 1.2.3 Plans and impact assessments relating to environmental and social impacts (C 5.1, 6.1, 7.1, 7.3) 1.2.4 Pollution prevention plans (C 5.6) 1.2.5 Details of complaints and grievances (C 6.3) 1.2.6 Negotiation procedures (C 6.4) 1.2.7 Continuous improvement plan (C 8.1)
Guidance: Examples of commercially confidential information include financial data such as costs and income, and details relating to customers and/or suppliers. Data that affects personal privacy should also be confidential.
Examples of information where disclosure could result in potential negative environmental or social outcomes include information on sites of rare species where disclosure could increase the risk of hunting or capture for trade, or sacred sites, which a community wishes to maintain as private.
Specific National Guidance for Scheme Smallholders Scheme Smallholders Scheme managers should ensure that appropriate systems are in place for their organized smallholders to comply with the above. This may include providing information that covers.
-use rights; (certificate)
gement Plans
Findings:
MSC/RSPO/DOC/06-02 Issue 1 Rev. 0 Page 14 of 102 FELDA Kahang CU Complex had made publicly available the related management document as required by this Criterion through a letter sent to stakeholders. At FELDA Ulu Dengar it had sent out the letter to stakeholders on 6th November 2012. Each scheme had maintained record of requests made by stakeholders and this record was presented during the assessment.
Each offices of Kahang CU visited had allocated office space dedicated as RSPO Documentation area to keep all documentation and records. There is a Document Controller in-charge of the document to ensure its distribution is current and retrieve obsolete document.
Photograph 1 and 2 (L - R) : Publicly available documents at FELDA Ulu Dengar and Kahang Barat
Photograph 3 and 4 (L - R): Land title file, records and manuals.
The filing of documents was orderly such that any required document for referral is readily accessible, for instance, as sighted in Photographs 1 to 4 at the FELDA Ulu Dengar and FELDA Kahang Barat:
In addition, all the policies of the company had been clearly displayed on notice boards (see Photograph 5 and 6).
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Photograph 5 (L) : FPISB Safety and Health policies in English and Bahasa Malaysia at Kahang POM and photograph 6 (R) FGVPM Safety and Health Policy at FELDA Kahang Barat office.
PRINCIPLE 2: COMPLIANCE WITH APPLICABLE LAWS AND REGULATIONS
Criterion 2.1 There is compliance with all applicable local, national and ratified international laws and regulations
Indicators: 2.1.1 Evidence of compliance with legal requirements. Major compliance
2.1.2 A documented system, which includes written information on legal requirements. Minor compliance
2.1.3 A mechanism for ensuring that they are implemented. Minor compliance
2.1.4 A system for tracking any changes in the law. Minor compliance
Guidance: 1. Lists down all applicable laws including international laws and conventions ratified by the Malaysian government. 2. Identify the person(s) responsible to monitor this compliance. 3. Display applicable licenses and permits. 4. Unit responsible to monitor these will also be responsible to track and update changes.
Specific National Guidance for Scheme Smallholders Scheme Smallholders Scheme managers should ensure that their organized smallholders are aware of and comply with relevant legal requirements.
These would require provision of information regarding relevant legal requirements to the participants or their appointed representatives.
Findings:
Each scheme of the FGVPM-KCU visited followed procedure for documenting, checking, assessing of legal compliance and tracking of changes with applicable laws. They include
MSC/RSPO/DOC/06-02 Issue 1 Rev. 0 Page 16 of 102 international laws and conventions ratified by the Malaysian Government that are relevant to its operations.
Scheme and Mill Manager had been identified responsible for communicating changes in laws and regulations whereas the unit responsible for tracking, monitoring and updating the changes of applicable laws and regulations was based at FELDA Headquarters, Kuala Lumpur. All changes had been cascaded down to the settler’s land schemes, plantation and mill management.
List of laws/regulations and their summaries related to RSPO were available in a legal register. The applicable laws identified and recorded in the legal register included Pesticides Act 1974 and Regulations, Environmental Quality Act and Regulations, 1974, Factories and Machinery Act and Regulations, 1967, Occupational Safety and Health Act 1994, Employment Act 1955. The acts and its regulations were evaluated for compliance annually.
The Mill Manager and Scheme Managers interviewed showed understanding on the applicable legal requirements. Likewise, staff and smallholders interviewed showed their awareness, the need of them to comply with relevant legal requirements and the consequence for non-compliance.
Generally, FGVPM-KCU were in compliance with all applicable local, national and ratified international laws and regulations, for example, all foreign workers have valid Visit Pass (Temporary Employment) issued by the Department of Immigration, Malaysia; Sijil Kebenaran Bertulis Alat Pembakaran Udara issued by Department of Environment (DOE), boilers are equipped with Continuous Emission Monitoring System (CEMS) linked to DOE Johor has been installed more than five years ago, license issued by DOE with its compliance schedule had been adhered to, machineries requiring Certificate of Fitness were up-to-date and Competent Persons were available at the mill except for lapses as highlighted in NCR MM1 The requirement for Fire Certificate for Kahang POM was not identified in the Legal Register and CHRA was not conducted for contractor workers at FELDA Ulu Dengar as required by the USECHH Regulations 2000. .The exemption letter from BOMBA on the requirement for Fire Certificate and the CHRA report that had been conducted by the contractors working n behalf of FTPSB at Ulu Dengar had been submitted to the assessor and were found acceptable. The status of this NCR MM1 is closed.
Criterion 2.2 The right to use the land can be demonstrated, and is not legitimately contested by local communities with demonstrable rights.
Indicators: 2.2.1 Evidence of legal ownership of the land including history of land tenure. Major compliance
2.2.2 Growers must show that they comply with the terms of the land title. [This indicator is to be read with Guidance 2] Major compliance
2.2.3 Evidence that boundary stones along the perimeter adjacent to state land and other reserves are being located and visibly maintained. Minor compliance
Specific Guidance: Growers should attempt to comply with the above indicator within 15 months from date of announcement of first audit. Refer to State Land Office for examples of other reserves.
2.2.4 Where there are, or have been, disputes, proof of resolution or progress towards resolution by conflict resolution processes acceptable to all parties are implemented. Cross ref. to 2.3.3, 6.4.1 and 6.4.2. Minor compliance
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Guidance: 1. For any conflict or dispute over the land, the extent of the disputed area should be mapped out in a participatory way. 2. Where there is a conflict to the condition of land use as per land title, growers must show evidence that necessary action has been taken to resolve the conflict with the relevant authorities. 3. Ensure a mechanism to solve the dispute (Refer to C 6.3 and C6.4) 4. Evidence must be demonstrated that the dispute has been resolved. 5. All operations shall cease on land planted beyond the legal boundary.
Specific National Guidance for Scheme Smallholders Scheme Smallholders Scheme Managers should ensure that:
The members are able to show legal ownership of their land or land use rights. Is such title are yet to be issued the scheme management should show evidence of legal legitimacy of land allocated.
The management should facilitate in processing / procuring land ownership for those participants.
Findings:
The right to use the land can be demonstrated and not disputed as the land developed by FELDA was authorized under Section 4 of the Land (Group Settlement Area, in short GSA) Act 1960. Scheme management had showed evidence of legal legitimacy of land allocated via plantation map and copies of land title that correspond to each other. (See photograph 6 and 7).
Photograph 6 and 7 (L-R): Copy of land title and map showing smallholders plot at FELDA Ulu Dengar
The legal ownership and terms and conditions of the land were verified at FELDA Ulu Dengar and FELDA Kahang Barat. Each smallholder is given 2 separate grants with attached terms and conditions, one for oil palm cultivation and the other for housing. There were a total of 299 smallholder’s grants at FELDA Ulu Dengar and 418 grants at FELDA Kahang Barat. Field tour confirmed that growers had complied with the terms of the land title as stated in the Kanun Tanah Negara, Borang 5EK, Jadual Empat Belas
The original land title ownership document is kept by FELDA head office and shall be handed over (transfer of ownership) to owner in accordance to the Land Agreement when all members of the group (“Peringkat”) had fully settled their loan. The samples of grants verified during the audit are as shown in Table 1 below.
It was observed that at FELDA Kahang Barat and FELDA Ulu Dengar the transfer of land title ownership for 24 and 87 smallholders respectively were being processed. When completed, all (100%) scheme participants at FELDA Kahang Barat would have obtained their land title while at Ulu Dengar it is 53%. The auditor had sighted the correspondence
MSC/RSPO/DOC/06-02 Issue 1 Rev. 0 Page 18 of 102 between the FELDA management and Meridian Survey Consultant. Based on the content of the correspondence, the issue at hand needed more time to resolve especially where it involved the full payment status of each land owner to FELDA.
The recent follow-up with Meridian Survey Consultant was on 11th October 2012. Thus, there is a need to keep track on the status of this issue from time to time during next surveillance audit.
Table 1: samples of grant taken during audit at FELDA Ulu Dengar and FELDA Kahang Barat
Estate Grant Lot Hectarage Status Date Owner No. registered FELDA Ulu Dengar 2610 43300 4.101 Agricultural 28.5.2007 – Damhuri Hj Peringkat 1 Oil Palm 27.5.2106 Tohamat FELDA Ulu Dengar 2549 8961 3.996 Agricultural 28.5.2007 – Abdul Manaf Peringkat 1 Oil Palm 27.5.2106 @ Wahi Abdul Kader FELDA Ulu Dengar 2594 25285 0.1138 Housing 28.5.2007 – Noriah @ Noi Peringkat 1 27.5.2106 binti Abdullah FELDA Kahang 1065 43225 1.7 Agricultural 29.7.2002- Samian bin Barat peringkat 1 Oil Palm 28.7.2101 Paijoh FELDA Kahang 1451 37109 3.961 Agricultural 31.7.2002- Darin bin Barat Peringkat 2 Oil Palm 30.7.2101 Dasimin FELDA Kahang 1450 13525 0.1356 Housing 31.7.2002- Darin bin Barat Peringkat 2 30.7.2101 Dasimin FELDA Kahang 1245 43160 4.038 Agricultural 29.7.2002- Samian bin Barat Peringkat 1 Oil Palm 28.7.2101 Denim FELDA Kahang 1244 13372 0.0831 Housing 29.7.2002- Samian bin Barat Peringkat 1 28.7.2101 Denim
Photograph 8: Boundary stone at FELDA Ulu Dengar adjacent to Koperasi Usaha Bersatu (KUB) Agrotech, Ladang Sg Yong
During the field assessment all boundary stones at FELDA Ulu Dengar and FELDA Kahang Barat belonging to smallholders and those adjacent to state land and forest reserves had been sighted visibly maintained. (See Photograph 8-10). The boundary map also had been maintained in PA Map # 71680 & 71864 dated on 26th June 2000.
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Photograph 9: Boundary stone at FELDA Ulu Dengar adjacent to Kluang Forest Reserve, Gunung Belumut Recreational Forest
Photograph 10: Boundary stone at FELDA Kahang Barat adjacent with Kluang Forest Reserve
There had been no conflict over the land occupied by the scheme settlers and therefore there was no land claim from local communities on the FELDA smallholdings assessed.
Criterion 2.3 Use of the land for oil palm does not diminish the legal rights, or customary rights, of other users, without their free, prior and informed consent.
Indicators: 2.3.1 Where lands are encumbered by customary rights, participatory mapping should be conducted to construct maps that show the extent of these rights. Major compliance
2.3.2 Map of appropriate scale showing extent of claims under dispute. Major compliance
2.3.3 Copies of negotiated agreements detailing process of consent (C2.2, 7.5 and 7.6). Minor compliance
Guidance: Where lands are encumbered by legal or customary rights, the grower must demonstrate that these rights are understood and are not being threatened or reduced. This criterion should be considered in conjunction with Criteria 6.4, 7.5 and 7.6.
Where customary rights areas are unclear these are best established through participatory mapping exercises involving affected and neighbouring communities.
This criterion allows for sales and negotiated agreements to compensate other users for lost benefits and/or
MSC/RSPO/DOC/06-02 Issue 1 Rev. 0 Page 20 of 102 relinquished rights. Negotiated agreements should be non-coercive and entered into voluntarily, carried out prior to new investments or operations and based on an open sharing of all relevant information in appropriate forms and languages, including assessments of impacts, proposed benefit sharing and legal arrangements.
Communities must be permitted to seek legal counsel if they so choose. Communities must be represented through institutions or representatives of their own choosing, operating transparently and in open communication with other community members.
Adequate time must be given for customary decision-making and iterative negotiations allowed for, where requested. Negotiated agreements should be binding on all parties and enforceable in the courts. Establishing certainty in land negotiations is of long-term benefit for all parties.
Specific National Guidance for Scheme Smallholders Scheme Smallholders Scheme managers can show that lands acquired for participants do not diminish legal or customary rights. Where other customary lands have been taken-over, there is documentary proof of transfer of rights (eg sale) or payment of agreed compensation.
Findings:
As mentioned earlier, through Land (General Settlement Area) Act 1960, the schemes’ smallholders and management had been given the legal right to all the land for cultivation through the title provided by the State Department of Lands and Surveys. The smallholdings were established long time ago (started in 1973) and they did not diminish the legal rights, or customary rights, of other users in the vicinity at the time of planting.
The assessor had sighted evidences of clear land ownership (cross refer to section 2.2) documents for the smallholders at the FELDA Kahang office complex. It was also noted from records examined, as well as through interviews with small holders, that there were no disputes on land rights in the CU.
PRINCIPLE 3: COMMITMENT TO LONG-TERM ECONOMIC AND FINANCIAL VIABILITY
Criterion 3.1 There is an implemented management plan that aims to achieve long-term economic and financial viability.
Indicators: 3.1.1 Annual budget with a minimum 2 years of projection Major compliance
Specific Guidance: Annual budget may include FFB yield/ha, OER, CPO yield/ha and cost of production that is not required to be publicly available.
3.1.2 Annual replanting programme projected for a minimum of 5 years with yearly review. Minor compliance
Guidance: Individual organization is to define its own management unit i.e. mill, estate or group as per definition on unit of certification explained in Item 4.2.3 and 4.2.4 in the RSPO Certification Systems document located at: http://www.rspo.org/RSPO_Certification_Systems.aspx
Specific National Guidance for Scheme Smallholders Scheme Smallholders Scheme Managers have a documented management plan (minimum 2 years) which is shared with them or their selected representatives.
MSC/RSPO/DOC/06-02 Issue 1 Rev. 0 Page 21 of 102 Findings:
The budget for financial year 2012 was available with projections for 2013 and 2014. at every estate and at Kahang POM. There was separate budget for Administration and Plantation. The budgets included capital and operating expenditures with attention given to crop projection, FFB yield trends, mill extraction rates, cost of production, and cost per tonne of FFB or CPO. The cost of production was reviewed and compared against expenditure each year with projections in place for future years. The monitoring is carried out via monthly progress report.
Others included the provision of allocation for mill and estate operations and maintenance covering upkeep of Plant & Machineries, Housing, Buildings & Amenities, Office Equipment, Land & Infrastructure, Agriculture Equipment & Vehicle. Budget for continuous improvement projects had been addressed, for examples, training, occupational safety and health, environmental upkeep (reduced, reuse and recycle) and for welfare and social activities for settlers. All allocations provided are only utilized for the purpose it was allocated. This is monitored via program sheets and monthly progress report.
PRINCIPLE 4: USE OF APPROPRIATE BEST PRACTICES BY GROWERS AND MILLERS
Criterion 4.1 Operating procedures are appropriately documented and consistently implemented and monitored.
Indicators: 4.1.1 Documented Standard Operating Procedures (SOP) for estates and mills Major compliance
4.1.2 Records of monitoring and the actions taken are maintained and kept for a minimum of 12 months. Minor compliance
Specific National Guidance for Scheme Smallholders Scheme Smallholders Working practices should be consistent with documented procedures that are adopted. Such documents should be explained to the participants and made available for reference.
For smallholders, working practices will have to be consistent with documented procedures provided by customers or related government agencies and organizations.
Findings
It was evident at all FGVPM-KCU sites that the use of appropriate best practices are implemented based on the documented manuals and procedures accordingly. The implemented procedural documents as well as records were well kept appropriately in designated files.
Manuals and procedures referred to were those developed at the group level that include the standard operation procedures and sustainability procedures covering both estates and mill operations. It covered all plantation activities, from seedling to the transportation of FFB to the mill, and mill operations such as FFB receipt and grading, machineries and equipment start-up, process operations and monitoring, shutdown and maintenance activities.
At the sites assessed, they (FELDA Technoplant and FELDA Smallholder Scheme) used the following generic document:
MSC/RSPO/DOC/06-02 Issue 1 Rev. 0 Page 22 of 102 1. FELDA Operations Manual for Sustainable Oil Palm Plantations (Manual Operasi Ladang Sawit Lestari) updated on October 2007; 2. Sustainable Manual 1A (Manual Lestari 1A) dated March 2012; 3. Occupational Safety, Health and Environmental Manual and SOP (Manual Keselamatan, Kesihatan Pekerjaan dan Alam Sekitar dan Tataccara Kerja Selamat) updated on 2009; 4. Procedures on riparian buffer zone and Polisi Perlindungan Tanah Curam dan Rezab Sungai, in the document ML-1A /L2-PO3 (0) dated March 2012
On the other hand, the Kahang mill use its applicable generic document, such as: 1. Quality Procedure Manual; 2. EMS Operation Manual; 3. Laboratory Operation Manual; 4. Quality Occupational Safety, Health and Environmental Manual (Manual Kualiti, Kesihatan, Keselamatan Pekerjaan and Alam Sekitar); 5. SOP - Safety, Health and Environmental Management Manual (Manual Tatacara Kerja Selamat – Keselamatan, Kesihatan dan Alam Sekitar); and 6. Mill Operations Manual
In addition, specific SOP was sighted and implemented by the CU such as: Use of agrochemicals, spraying techniques including care of spraying at/near riparian zone Manual Pemantauan air per tan FFB process Rekod penggunaan air kilang dalam pemprosesan BTS Tatacara kerja selamat – seksyen 9 Peraturan Keselamatan Pengurusan dan Pengendalian Bahan Kimia Berbahaya
The manual and procedures were available to all levels of Executives in the plantations and mill.
Photograph 6, 7 and 8 (L-R) : Among manual used by scheme/plantation - FELDA Operations Manual for Sustainable Oil Palm Plantation, Sustainable Manual (Compliance to RSPO P&C) and Safety, Health and Environmental Manual
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Photograph 9, 10 and 11 (L-R) : Among manual used by Kahang POM – QMS Procedure Manual, EMS Operation Manual and Laboratory Operation Manual
Photograph 12, 13 and 14 (L-R) : FPISB Occupational Safety, Health and Environment Manual, SOP - Safety, Health and Environmental Management Manual and Mill Operations Manual
Irrespective of the land whether it belongs to settlers or those land managed by FTPSB the requirement to use the three established generic plantation manuals mentioned above had been applied by the Scheme Management. The Scheme Management had explained the need for the settlers to comply and the benefits to be gained in adopting the FELDA Good Agricultural Practices. This document had been made available for the participants to refer. Interview with settlers tending their own land revealed that they had occasionally consulted and were given helpful and relevant advice by their Scheme Management on Good Agricultural Practice.
Implementation of the manuals and SOP was verified. Through random interviews held with the staff, workers and self-tending farmers, the outcome revealed that they generally understood the requirements of these documents and their level of understanding on the contents of the manual and SOP was found acceptable. One of the many examples was in field interviews in which ripeness standard and chemicals usage had been properly MSC/RSPO/DOC/06-02 Issue 1 Rev. 0 Page 24 of 102 understood by the field workers. The checking on crop quality was done by the Quality Supervisor.
Herbicides spraying, slashing, FFB harvesting and frond arrangements were the field activities performed by these self-farming smallholders whereas manuring were at their choice, that is, either undertaken by themselves or through FTPSB. Each Block Leader (see above at Section 1.3.2. Human Capital at FELDA) gathered information from members on agrochemicals used and those FFB harvested. The information was then reported, recorded and kept at their respective FELDA scheme office.
At the smallholding schemes managed by FTPSB monthly progress monitoring for all activities were made available. Their records of monitoring for field related activities were captured in the ‘Programme Sheets’ for activities such as for manuring and spraying programmes,
Other records maintained include agrochemicals used (but not the parameters, cross reference Indicator 4.6.10 where NCR STK 02 had been issued), rat census/treatment, application for and issuance of personnel protective equipment (PPE) that were evident in the cost books, store requisition and issue sheets and related files.
At the mill, records of mill operations and maintenance including monitoring such as PPE issuance, Permit to Work issued, QOSHE Committee meeting, Chemical Health Risk Assessment (CHRA), Accident Investigation, Non-conformity, Corrective Action and Preventive Action, Health Surveillance, Audiometric test, DOSH Log book, Stack environmental air monitoring (based on the mill’s DOE license and compliance schedule), equipment history and others, were maintained as per QOSHE Manual, specifically to the requirement of element Control of records to ensure its implementation and practicality.
Generally, the monitoring reports and actions taken at estates and mill were well kept and maintained for a minimum of 12 months while others as per legal requirement, some up to thirty years.
Criterion 4.2 Practices maintain soil fertility at, or where possible improve soil fertility to, a level that ensures optimal and sustained yield.
MY-NIWG recommends that the indicators in criterion 4.2 and 4.3 are linked
4.2.1 Monitoring of fertilizer inputs through annual fertilizer recommendations. Minor compliance
4.2.2 Evidence of periodic tissue and soil sampling to monitor changes in nutrient status. Minor compliance
4.2.3 Monitor the area on which EFB, POME and zero-burn replanting is applied. Minor compliance
Guidance: Long-term fertility depends on maintaining the structure, organic matter content, nutrient status and microbiological health of the soil. Managers should ensure that best agricultural practice is followed. Nutrient efficiency must take account of the age of plantations and soil conditions.
Specific National Guidance for Scheme Smallholders Scheme Smallholders Scheme Managers are able to demonstrate that the participants have an understanding of the techniques required to maintain soil fertility and that they are being implemented.
Evidence of implementation can be in the form of:
1. Records of fertilizer application MSC/RSPO/DOC/06-02 Issue 1 Rev. 0 Page 25 of 102 2. Records of EFB or POME application (if practiced)
Findings:
The company practices the maintenance of long-term soil fertility by annual application of fertilizers based on periodic foliar and soil analysis, biomass retention (pruned fronds left to decompose in the fields) and EFB application. Soil map of each plantation was presented to the assessment team.
An annual agronomic foliar analysis undertaken by FASSB had been conducted in the plantation visited and the results formed the basis to ascertain soil fertility and recommendation for the application of fertilizer. All fertilizer regimes were relatively well planned; implemented and recorded. The assessor had sighted records on the movement of fertilizer and confirmed that they had been kept current. An interviews with smallholders also confirmed that they had applied fertilizer in their plot.
Empty fruit bunches (EFBs) was applied in Ulu Dengar in 2012. There was no application in Kahang Barat.
Criterion 4.3 Practices minimise and control erosion and degradation of soils.
Indicators: 4.3.1 Documented evidence of practices minimizing soil erosion and degradation (including maps). Minor compliance
Specific Guidance: Replanting on sloping land must be in compliance with MSGAP Part 2: OP (4.4.2.2)
For Sarawak, steep slopes are considered high risk erosion areas and cannot undergo replanting unless specified in the EIA report and approved by the Natural Resources and Environment Board (NREB).
For Sabah, slopes 25 degree and steeper are considered high risk erosion areas and cannot undergo replanting unless specified in the EIA report [Environment Protection (Prescribed Activities)(Environment Impact Assessment) Order 2005] and approved by the Environmental Protection Department (EPD).
Slope determination methodology (slope analysis) should be based on average slope using topographic maps or topographical surveys.
4.3.2 Avoid or minimize bare or exposed soil within estates. Minor compliance
Specific Guidance: Appropriate conservation practices should be adopted.
4.3.3 Presence of road maintenance programme. Minor compliance
4.3.4 Subsidence of peat soils should be minimised through an effective and documented water management programme. Minor compliance
Specific Guidance: Maintaining water table at a mean of 60 cm (within a range of 50-75cm) below ground surface through a network of weirs, sandbags, etc. in fields and watergates at the discharge points of main drains.
4.3.5 Best management practices should be in place for other fragile and problem soils (e.g. sandy, low organic matter and acid sulphate soils). Minor compliance
Guidance: Techniques that minimise soil erosion are well-known and should be adopted, wherever appropriate. These may MSC/RSPO/DOC/06-02 Issue 1 Rev. 0 Page 26 of 102 include practices such as:
1. Expediting establishment of ground cover upon completion of land preparation for new replant. 2. Maximizing palm biomass retention/ recycling. 3. Maintaining good non-competitive ground covers in mature areas. 4. Encouraging the establishment/regeneration of non-competitive vegetation to avoid bare ground. 5. Construction of conservation terraces for slopes >15o 6. Advocating proper frond heap stacking such as contour/L-shaped stacking. for straight line planting and stacking along the terrace edges for terrace planting. 7. Appropriate road design and regular maintenance. 8. Diversion of water runoff from the field roads into terraces or silt pits. 9. Construction of stop bunds to retain water within the terrace. 10. Maintaining and restoring riparian areas in order to minimize erosion of stream and river banks.
Specific National Guidance for Scheme Smallholders Scheme Smallholders Scheme managers should be able to demonstrate that their participants have an understanding of the techniques adopted to manage their soils and that they are being implemented.
Findings:
There was sparse documented evidence of practices minimizing soil erosion and degradation other than protection by natural vegetation. During the field visit it was observed that FGVPM-KCU had yet to improve consistency of application of these practices across all of its operating units. Estates slope classification maps showing steep slopes above 25 degrees were not made available to the assessment team. Terraces were seen constructed in sloping areas.
Photograph 15: Fronds incorrectly stacked on Photo 16: Eroded road a slope at FELDA Kahang Barat
In addition to the map, a Minor NCR STK01 was therefore issued against Indicator 4.3.1 for
a. Stacking of fronds along the slope and not against the slope, as stated in the Manual Operasi Ladang Sawit Lestari, in FELDA Kahang Barat (Photograph 15)
b. Many roads at FELDA Kahang Barat and Ulu Dengar were badly eroded and not maintained (Photograph 16) making maneuvering of vehicles difficult. The severity of soil erosion as shown in photograph 17 even had filled the trench below a cattle trap at 2012 replant area at Ulu Dengar Furthermore, road side drains and silt traps were lacking to address surface run off waters. Although lacking, road side drains leading to field and silt pit are still used to temporary contain washed out gravel soil. Ground cover crop are also established.
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Photograph 17: Bare grounds at FELDA Photo 18: Cattle trap filled with soil from Kahang Barat. erosion
The NCR STK01 is now closed as in-field training on stacking of fronds had been conducted. Photographic evidence of the training conducted together with attendance list were submitted as proof. Also, road maintenance programme had been submitted.
At Ulu Dengar most areas had thick ground cover and a contract to transport and a programme to plant Mucuna bracteata was sighted.. However, at Kahang Barat a small area of bare ground (Photograph 18) was sighted. Thus, an OFI was raised.
There was no peat soil and other fragile soil area seen in the FGVPM-KCU and this was confirmed by the Schemes involved. Therefore, Indicators 4.3.4 and 4.3.5 are not applicable.
Criterion 4.4 Practices maintain the quality and availability of surface and ground water.
Indicators: 4.4.1 Protection of water courses and wetlands, including maintaining and restoring appropriate riparian buffer zones at or before replanting along all natural waterways within the estate. Major compliance
Specific Guidance: Riparian buffer zones: Reference to be made to relevant national regulations or guidelines from state authorities e.g. Department of Irrigation and Drainage (DID), whichever is more stringent.
4.4.2 No construction of bunds/weirs/dams across the main rivers or waterways passing through an estate. Major compliance
4.4.3 Outgoing water into main natural waterways should be monitored at a frequency that reflects the estates and mills current activities which may have negative impacts (Cross reference to C 5.1 and 8.1). Major compliance
4.4.4 Monitoring rainfall data for proper water management. Minor compliance
4.4.5 Monitoring of water usage in mills (tonnage water use/tonne FFB processed). Minor compliance
Specific Guidance: Data trended where possible over 3 years to look into resource utilization
4.4.6 Water drainage into protected areas is avoided wherever possible. Appropriate mitigating measures will be implemented following consultation with relevant stakeholders. Minor compliance
4.4.7 Evidence of water management plans. Minor compliance MSC/RSPO/DOC/06-02 Issue 1 Rev. 0 Page 28 of 102
Specific National Guidance for Scheme Smallholders Scheme Smallholder Scheme Managers should provide appropriate training for their participants on the importance of maintaining the quality and availability of surface and ground water.
Findings:
In the field assessed the criterion on the practices to maintain the quality and availability of surface and ground waters were not satisfactorily met.
There were lapses In the protection of water courses and wetlands, including maintaining and restoring appropriate riparian buffer zones along all natural waterways within the FELDA Kahang CU Complex. On one hand, a 5m buffer zone boundary had been identified, demarcated and erected with signboard (see Photograph 19 below) much in accordance with HCV4 Management Plan, but, on the other hand, spraying activities or trace of it were seen along the buffer zone of Sg Belumut, FELDA Ulu Dengar (photograph 20) and Sg Janoh, FELDA Kahang Barat (Photograph 21). In addition the boundary markers for buffer zone at these rivers were not clearly demarcated. Therefore a Major NCR NAJ-1 had been raised.
The training records by FELDA Ulu Dengar and Kahang Barat such as HCV Awareness training attendance list (for training given on 15th January 2013 and 14th February 2013 respectively) slide presentation, picture of implementation, including signboard and boundary marker had been submitted to auditor. Other action plans include reminding workers not to conduct any activities in buffer zone including spraying and manuring. The monitoring also has been planned every 2 weeks to monitor the buffer zone. The documents submitted were considered adequate and therefore this NCR NAJ-1 is considered closed.
Photograph 19: Identified and maintained Photograph 20: The buffer zone sprayed with buffer zone herbicide along Sg Belumut
There was no construction of bunds/weirs/dams seen across the main rivers or waterways passing through the estates visited. Likewise, all streams and drainage sighted were without obstruction.
Water sampling for monitoring had been conducted on each inlet and outlet of river stream of Sg. Belumut and Sg. Janoh. The results of the water analysis showed the water quality was within the acceptable level index of class III category, Interim National Water Quality Standard 2006 (INWQS) of the DOE except for Sg. Belumut although there was a rise in oil & grease in the water downstream of the river which may be due to picnickers upstream as explained by the Scheme Manager.
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Photograph 21: (L and R) The buffer zone sprayed with herbicide along Sg Janoh. No signage prohibiting spraying of herbicide and demarcation of riparian zone erected.
Photograph 22: Water sampling point Photograph 23: Water sampling point upstream Sg Belumut at Ulu Dengar downstream Sg Janoh at Kahang Barat
Water supplied to settler’s housing by Syarikat Air Johor thus no test required.
The Kahang POM had identified the source of outgoing water from the mill, which led into natural waterways. The sources identified were run-offs and discharges from the effluent treatment plant (ETP) and monsoon drain from the mill. Mill effluent were treated by anaerobic digestion in ponds and bio-polishing tank and analyzed prior to discharge into watercourse to comply with EQA (Prescribed Premises) (Crude Palm Oil) Regulations 1977. Parameters such as pH, BOD, COD, Total Solids, Suspended Solid, Oil and Grease, Ammoniacal Nitrogen and Total Nitrogen were analysed. The monitoring of these discharges and the water quality of down streams was conducted weekly. Results of the analysis showed that Kahang POM had generally met the requirements as stated in the DOE Permit “Kebenaran Bertulis”.
Daily rainfall data were also recorded by the mill in a monthly report. Likewise, all estates had been monitoring the rainfall data and at FELDA Kahang Barat records were available from 2006.
All estates had been monitoring the rainfall data as well as their water consumption as required by RSPO criteria & indicator. Daily records of rainfall data for each scheme were made available for inspection. The data was used in the water management for each scheme. Rain water harvesting was not practiced at line sites, mill and estate complexes.
MSC/RSPO/DOC/06-02 Issue 1 Rev. 0 Page 30 of 102 The mill had been monitoring water consumption and been reporting monthly usage against the FFB processed. Their records include daily water usage monitoring at boiler and oil room. Current water usage stood at 0.9 kl/mt FFB processed. There was good practice of water management plan which include raw water treatment for operational and potable use by Kahang POM.
Criterion 4.5 Pests, diseases, weeds and invasive introduced species are effectively managed using appropriate Integrated Pest Management (IPM) techniques.
Indicators: 4.5.1 Documented IPM system. Minor compliance
4.5.2 Monitoring extent of IPM implementation for major pests. Minor compliance
Specific Guidance: Major pests include leaf eating caterpillars, rhinoceros beetle and rats.
4.5.3 Recording areas where pesticides have been used. Minor compliance
4.5.4 Monitoring of pesticide usage units per hectare or per ton crop e.g. total quantity of active ingredient (a.i.) used/ tonne of oil. Minor compliance
Guidance: Growers should apply recognised IPM techniques, incorporating cultural, biological, mechanical or physical methods to minimise use of chemicals. Native species should be used in biological control wherever possible.
Specific National Guidance for Scheme Smallholders Scheme Managers Scheme Managers should provide training for their organized smallholders in IPM techniques and provide appropriate assistance on agrochemical application.
Findings:
The assessed FELDA estates had implemented the Integrated Pest Management (IPM) in conformance to their Agriculture Manual & Standard Operating Procedure for Oil Palm. Among the recognized techniques applied were:
1. Biological method such as (a) growing beneficial plants, Tunera subulata, along road sides (b) establishing barn owl boxes (Photograph 24) to address rats infestation, and (c) use of Pheromone traps to address Rhinoceros Beetle attack up to about 10 months from felling.
2. Mechanical means like fixing wire mesh around the base of young palms to prevent damage by wild pigs (Photograph 25) and individual plastic fences to prevent cattle damage. Cattle traps in replants meant to prevent cattle from entering the replanting area were also sighted.
3. Chemical application, example, rat baiting and in replants where the use of Pheromone traps was discontinued, pesticide cypermethrin was instead used when its threshold level is above 5%. . There was no prophylactic application of pesticides made in the schemes.
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Photograph 24 : A barn owl box as Photograph 25 : Wire mesh around palm base seen in the filed Field staff and storekeepers had been keeping records on the location, quantity and type of pesticides that had been applied in their Cost Books. Through records sighting, the Scheme Managers had provided training for their smallholders and workers in IPM techniques and the appropriate agrochemical application. For example, rat baits campaign and agrochemicals handling and spraying demonstration training had been carried out.
Criterion 4.6 Agrochemicals are used in a way that does not endanger health or the environment. There is no prophylactic use of pesticides, except in specific situations identified in national Best Practice guidelines. Where agrochemicals are used that are categorised as World Health Organisation Type 1A or 1B, or are listed by the Stockholm or Rotterdam Conventions, growers are actively seeking to identify alternatives, and this is documented.
Indicators: 4.6.1 Written justification in Standard Operating Procedures (SOP) of all agrochemicals use. Major compliance
4.6.2 Pesticides selected for use are those officially registered under the Pesticides Act 1974 (Act 149) and the relevant provision (Section 53A); and in accordance with USECHH Regulations (2000). Major compliance
Specific Guidance: Reference shall also be made to CHRA (Chemical Health Risk Assessment)
4.6.3 Pesticides shall be stored in accordance to the Occupational Safety and Health Act 1994 (Act 514) and Regulations and Orders and Pesticides Act 1974 (Act 149) and Regulations. Major compliance
Specific guidance: Unless participating in established recycling programmes or with expressed permission from the authorities, triple rinsed containers shall be pierced to prevent misuse. Disposal or destruction of containers shall be in accordance with the Pesticide Act 1974 (Act 149) and Environmental Quality Act 1974 (Scheduled Wastes) Regulations 2005.
4.6.4 All information regarding the chemicals and its usage, hazards, trade and generic names must be available in language understood by workers or explained carefully to them by a plantation management official at operating unit level. Major compliance
4.6.5 Annual medical surveillance as per CHRA for plantation pesticide operators. Major compliance
4.6.6 No work with pesticides for confirmed pregnant and breast-feeding women. MSC/RSPO/DOC/06-02 Issue 1 Rev. 0 Page 32 of 102 Major compliance
4.6.7 Documentary evidence that use of chemicals categorised as World Health Organisation Type 1A or 1B, or listed by the Stockholm or Rotterdam Conventions and paraquat, is reduced and/or eliminated. Adoption of suitable economic alternative to paraquat as suggested by the EB pending outcome of the RSPO study on IWM. Minor compliance
4.6.8 Documented justification of any aerial application of agrochemicals. No aerial spraying unless approved by relevant authorities. Major compliance
4.6.9 Evidence of chemical residues in CPO testing, as requested and conducted by the buyers. Minor compliance
4.6.10 Records of pesticide use (including active ingredients used, area treated, amount applied per ha and number of applications) are maintained for either a minimum of 5 years or starting November 2007. Minor compliance
Specific National Guidance for Scheme and Independent Smallholders
Scheme Smallholders Scheme Managers should provide regular training to their organized smallholders on agrochemical use. The training should include but not necessary limited to
1. Type of chemicals allowed to be used and precautions attached to their use 2. Methods of application, safety usage and appropriate PPE to be used. 3. Storage of chemicals and safe disposal of the empty containers. 4. No chemical handling and spraying by pregnant woman 5. Chemicals should only be applied following the product label.
The scheme managers should maintain necessary records on agrochemicals provided to their participants and to monitor their use so as proper measures are adhered to minimize risk and impacts.
Under consideration for 4.6.7 Evidence of registered and permitted agrochemicals use as regulated by the Minister of Agriculture
Findings:
At FGVPM-KCU agrochemicals were used in a way that does not endanger the health of employees or the environment. There was no prophylactic use of the agrochemicals. All estates had provided written justifications for all agrochemicals it was using as found in the Agriculture Manual and SOP. Safety and health precautions as recommended in the respective chemical Material Safety Data Sheet (MSDS) had been referred to.
All agrochemicals used were based on the ‘need-to-do basis’ to enhance field operations. Pesticides selected for use and storage were complied with Pesticides Act 1974 (Act 149) and the relevant provision (Section 53A), Classification, Packaging and Labelling of Hazardous Chemical Regulation 1997 and USECHH Regulations 2000, of the Occupational Safety & Health Act 1994. Evidence of compliance was verified by the assessment team such as permit to store paraquat, PPE provided to the chemical handler, chemical monitoring records, medical surveillance records as well as training records.
Records of the purchase, storage and use of agrochemicals had been properly documented in the Stock Statement Return.
A concrete chemical store well ventilated with exhaust and inlet fans and with locked door had been constructed at Kahang Barat. All pesticides were neatly stored. Paraquat has been stored inside an additional locked store in the chemical store (Photograph 26). Only authorized personnel (storekeeper) was allowed to enter the chemical store and issue out the chemicals. Respective chemical MSDS (Photograph 27) was made available and kept in
MSC/RSPO/DOC/06-02 Issue 1 Rev. 0 Page 33 of 102 the store. The storekeeper and pesticides sprayers interviewed had shown understanding of the hazards involved and the required control measures.
Photograph 26: Additional locked store for Photograph 27: MSDS for paraquat in store paraquat in the locked chemical store
The Agricultural Manual had included all information regarding the chemicals and its storage, usage, hazards, trade and generic names in Malay and/or English language.
The use of these agrochemicals had also made references to Chemical Health Risk Assessment (CHRA) USECHH Regulations (2000) of the OSHA 1994 Act. Personnel who handled and were exposed to these agrochemicals had been assessed of the risks created by the chemical to the health of the employee. At the estates assessed they had a schedule for medical surveillance of its pesticide operators (sprayers). The medical surveillance was conducted but report yet to be received.
The operators involved were all male workers. It was confirmed there were no women sprayers in the FELDA estates.
Except for Paraquat no other Class I & II chemicals had been used. Its use was controlled and selective. Indeed to demonstrate its commitment, FELDA had established a policy on the use of Paraquat which specifically state it to be used only in immature areas and if there was a requirement for use in mature areas (e.g. for rehabilitation or for use in wet months) then special request for approval had to be made to higher management. At FELDA Kahang Barat the use of Paraquat has reduced. Records showed that in 2010, 2011 and 2012, 820 litres, 710 litres and 610 litres were used respectively.
However, records of pesticide use (including active ingredients used, area treated, amount applied per ha and number of applications) as required under Indicator 4.6.10 were not maintained at both FELDA Kahang Barat and FELDA Ulu Dengar. Hence, a Minor NCR STK02 was issued. This NCR is now closed as the required figures, active Ingredient/ hectare had been correctly computed, complied and maintained.
Besides FELDA workers, smallholders too had been trained in the safe handling of agrochemicals. The training included the type of chemicals allowed to be used, precautions attached to their use, dosage rate, mixing, methods of application, appropriate PPE required, storage of chemicals, triple rinsing of used container and safe disposal of the empty containers. The training conducted was recorded.
It was observed that there was no aerial spraying being conducted in all the estates.and this was confirmed by the Scheme and Plantation Managers.
MSC/RSPO/DOC/06-02 Issue 1 Rev. 0 Page 34 of 102 There was no request by buyers of chemical residues testing in CPO and thus, this indicator 4.6.9 is not applicable.
Criterion 4.7 An occupational health and safety plan is documented, effectively communicated and implemented
Indicator 4.7.1 : Evidence of documented Occupational Safety Health (OSH) plan which is in compliance with OSH Act 1994 and Factory and Machinery Act 1967(Act139) Major compliance
The safety and health (OSH) plan shall cover the following:
a. A safety and health policy, which is communicated and implemented. b. All operations have been risk assessed and documented. c. An awareness and training programme which includes the following specifics for pesticides: i. To ensure all workers involved have been adequately trained in a safe working practices ( See also C4.8) ii. All precautions attached to products should be properly observed and applied to the workers. d. The appropriate personal protective equipment (PPE) are used for each risk assessed operation. i. Companies to provide the appropriate PPE at the place of work to cover all potentially hazardous operations such as pesticide application, land preparation, harvesting and if used, burning. e. The responsible person (s) should be identified. f. There are records of regular meetings between the responsible person(s) and workers where concerns of workers about health and safety are discussed. g. Accident and emergency procedures should exist and instructions should be clearly understood by all workers. h. Workers trained in First Aid should be present in both field and mill operations. i. First Aid equipment should be available at worksites.
Indicator 4.7.2 : Records should be kept of all accidents and periodically reviewed at quarterly intervals. Major compliance
Specific Guidance : Record of safety performance is monitored through Lost Time Accident (LTA) rate.
Indicator 4.7.3 : Workers should be covered by accident insurance. Major compliance
Specific National Guidance for Scheme Smallholders Scheme Smallholders Scheme and Group Managers should implement a health and safety plan for their organized smallholders that include agrochemical use and fire drills.
The management should keep records of all accident and review them periodically. If records are not easily available, the management has to show evidence of measures adopted to seek such records.
Findings:
The Kahang CU has adopted the FGVPM’s occupational safety and health policy.. Correspondingly, FPISB, FPSB and FTPSB had published its subsidiary OSH policy. See Photograph 28 for FPISB QOSHE Policy. All these policies were in line with the Group OSH policy. The policy had been communicated to all employees through briefings and it was also displayed on the schemes’ office notice boards.
A safety management plan for each operating unit of FGVPM-KCU had been established. The OSH management plan had addressed, among others, issues related to hazards and risks, compliance with regulations such as Occupational Safety and Health Policy, Occupational Safety and Health (Safety Committee) Regulation, Occupational Safety and Health (Use of Standard Exposure of Chemicals Hazardous to Health) Regulation, Occupational Safety and Health (Notification of Accident, Dangerous Occurrence,
MSC/RSPO/DOC/06-02 Issue 1 Rev. 0 Page 35 of 102 Occupational Poisoning and Occupational Disease) Regulation, response to Occupational Safety & Health and Environmental emergencies, treatment of illness/injury during the job,
Although CHRA as required under USECHH Regulations (2000) had been performed by the mill, a lapse was seen at FELDA Ulu Dengar where contractor workers handling chemicals had not undergone Chemical Health Risk Assessment. A Major NCR MM1 was raised. (Cross reference Indicator 2.1.1)
Photograph 28: (L-R) FPISB QOSHE Policy in English and Malay Language
The hazard identification, risk assessment and risk control (HIRARC) carried out covered the activities in both the estates and mill. They had been documented into a HIRARC Register. Among the activities identified in the plantation were FFB evacuation and transportation to mill, chemical mixing and spraying, chemical storage, harvesting and potential occurrence of fire. As for the mill, the identified activities had include laboratory work and taking of samples, boiler operations, FFB sterilization, kernel extraction, oil extraction and clarification, machine maintenance and working in confined space. .Appropriate risk control measures had been made available to control the risks identified.
Annual & baseline audiometric test report dated 16 June 2012 was conducted for seventy seven (77) mill workers. Preventive action taken where monthly walkabout inspection including checking for PPE used had been practiced at POM and executed by OSH Committee members. Training and refresher training on the use, care and maintenance of PPE including ear protection device had been carried out annually. PPE traing besides being given by trained FGV staff, it is also jointly held with PPE manufacture/supplier and occasionally with External Safety Training (e.g. NIOSH). Training evaluation was carried ou according to determine effectiveness of the training. PPE posters, as well as posters from NIOSH (Hearing Loss) were displayed. FMA (Noise Regulation) 1994 requirements and training slides handout were part of the PPE program used to enhance awareness.
The assessment team first, observation to whether workers had adhere to signage requirement then interview why they were required to wear them and the consequences of departure to specified procedures. No complaints were raised by those who are exposed to high noise level.
MSC/RSPO/DOC/06-02 Issue 1 Rev. 0 Page 36 of 102 Although OSH Plan and HIRADC register had been established, OFIs against them had been assigned as follows:
OSH yearly plan for estate can be further improved by conducting the legal compliance evaluation program and At all operating units including the mill confusion in filling hazard and risk column exist and revision to it is in order.
Evidence of implementation on the control measures was observed during the field and mill assessments. For example, at the mill, machines which have moving parts had been well guarded, SOP for laboratory (photograph 29) and critical equipment operations (e.g. boiler, sterilizer, etc) clearly summarized and displayed, Permit To Work enforced, and fire fighting facilities installed at strategic locations. In the estate, it was noted that eye wash and shower room were made available near chemical mixing area.
Employees of both mill and estates visited were provided with and were seen to be using the appropriate PPE. The FGVPM-KCU had made available free of charge appropriate and adequate PPE to its workers. The PPE that had been commonly given were safety boots, helmets, goggles, ear plugs, aprons, nitrile rubber and cotton gloves.
Sprayers and workers responsible for fertilizers application were observed to have worn suitable PPE and had adequate tools to perform their works. Fruit harvesters had been provided with hard hats. Records on PPE distribution to workers had been maintained and sighted.
Photograph 29: SOP for use of Photograph 30: FTPSBSB OSH Committee Organization laboratory Chart at FELDA Ulu Dengar
During mill assessment, it was observed that signages (to remind workers to wear appropriate PPE) were posted at appropriate places. Workers interviewed understood the reasons and importance why they were required to wear the PPE.
The awareness and training program specific to agrochemicals had been held for workers and smallholders. This related to safe chemical handling and spraying, use and maintenance of PPE, its MSDS in particular precautions attached to the pesticides and the need to observe requirements of CHRA, including undergoing health surveillance.
Persons-in-charge of health and safety were identified as evidenced in appointment letter of OSH Committee at the mill and at FTPSB for Kahang Barat and Ulu Dengar. Photograph 30
MSC/RSPO/DOC/06-02 Issue 1 Rev. 0 Page 37 of 102 shows the OSH organization chart at FTPSB Ulu Dengar. Ultimate responsibility for safety, health and environment rested with Mill Manager or Scheme Manager, the top most officer who had overall control and influence at site.
The assessment team had verified the minutes of meeting of the OSH committee which was held quarterly to discuss issues pertaining to workers’ safety and health at work place. It was chaired by their respective Mill or Scheme Manager and discussed issues pertaining to workers’ safety and health at workplace including accident cases, if any, and results of workplace inspections. Issues requiring immediate attention were further discussed at working level via Tool Box meetings.
An OFI had been issued with respect to
involvement of Safety & Health Committee at estates could be further improved by active participation in all OSH programs and activities, among them, Workplace Inspection, attendance at quarterly OSH meeting, etc. Some oxy-acetylene gas cylinders were not fitted with flash back arrestor. The content of the first aid box need to be updated as some items were found missing. The laboratory oven had yet to be located under the chemical fume hood..
Minutes had been kept of all meetings and had been distributed to OHS Committee members and attendees for follow-up as a result of the meeting stating the actions required, person responsible and expected timeline for completion.
Accident cases had been monitored and reported to the FGVPM-KCU respective Mill or Scheme Manager, who in turn, report to FGV PSQM Department at Head office, Kuala Lumpur and state DOSH office as required by the NADOPOOD Regulation. Annual accident summary cases had been captured in JKKP 8 form and submitted to DOSH headquarters, Putrajaya. Each site Safety Performance had been displayed as LTA on the notice board of their office. Accident records had been kept and reviewed quarterly at the OSH Committee meeting.
All workers were covered by Workman Compensation. The mill and schemes visited had their workers insured against accident; the local workers insured against SOCSO and the foreign workers via accident insurance through underwriter BH Insurance Sdn Bhd.
Emergency procedure existed and their instructions to response were clearly understood by the employees of the sites assessed. Emergency evacuation and fire response drill had been conducted at the palm oil mil and scheme’s office assessed. It had been carried out meeting the procedure requirement of at least once a year, as sighted in the records of Kahang POM and FELDA Kahang Barat. The post-mortem report following emergency response drill could be improved to detail out time of events against outcome. Thus an OFI had been raised.
Assembly point, emergency telephone contact numbers of essential FELDA personnel and Government Emergency Service Providers, emergency evacuation route and emergency response procedure were made available and published for everyone’s information.
It was observed that first aid box was provided to the field supervisor and also made available at several strategic locations at the office. The first aid boxes were inspected and their contents were found lacking and an OFI had been assigned to it as mentioned above. Interviews with First Aiders were found to be conversant with rendering first aid practices for minor injuries.
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Criteria 4.8 All staff, workers, smallholders and contractors are appropriately trained.
Indicator 4.8.1 : A training programme (appropriate to the scale of the organization) that includes regular assessment of training needs and documentation, including records of training for employees are kept. Major compliance
Guidance: Appropriate training should be given to all staff, workers and contractors by growers and millers to enable them to fulfill their jobs and responsibilities in accordance with documented procedures. All Estate Hospital Assistants (EHA) are trained on the chemicals used and related laws.
Specific National Guidance for Scheme Smallholders Scheme Smallholders The participants and registered workers on participants’ plots are provided adequate training and skills and this is documented. The trainings can be achieved through extension activities of growers, FFB dealers or mills that purchase fruit from them, or through collaboration with relevant government agencies.
Findings:
There are training programs in place to improve and increase staff skills when seen required by management. The training programs and records for FGVPM-KCU were inspected. The respective operating unit management visited had trained their staff, workers and smallholders and records of training were kept. The records included information on the title of the training, name and signature of the attendees, name of the trainer, time and venue.
Among of the training program conducted were:
1. Safety Awareness for staff and workers and first aid. 2. Pesticide application and pesticide mixing 3. Harvesting techniques 4. Basic Fire Fighting and Evacuation drill 5. RSPO Awareness to employees 6. Scheduled Waste handling for waste store operator, and 7. Bio-polishing plant operation for the Wastewater Treatment Plant Operator.
For field workers, in addition to formal class room training, occasionally safety procedures and standards were also told and reminded during muster in the morning. From the interviews with workers they were found to be aware of the procedures and standards.
The staff, smallholders and plantation workers such as the storekeepers, sprayers and fertilizer applicators interviewed had shown that they understood the hazards of the chemicals and the need to follow the safety procedures and the use of PPE. The trade and generic names of the chemicals were made known to the workers through the MSDS training
Contractors had also been briefed on safety and environment upon commencement of work.
The level of understanding on safety, health, environment and RSPO varies between estates and was better at the mill primarily due to the mill had been emulating internationally recognized management system standards: ISO 9001, ISO 14001 and OHSAS 18001 a long time.
For most of the mill operation, task-oriented trainings had been conducted periodically. Most of the referred training materials are the standard operation procedures itself. There was
MSC/RSPO/DOC/06-02 Issue 1 Rev. 0 Page 39 of 102 also safe operation procedures training conducted based on the potential risk at the work place itself.
Specialized training courses had also been conducted when the need arises and this include group or in house training. They are competent persons training related to operation of boiler, confine space, fire fighting and first aid.
Despite the training given above, a Major NCR MM2 had been assigned against Indicator 4.8.1, that is,
1. The mill personnel had not been trained on the RSPO Supply Chain Certification Standard.
2. The environmental emergency response drill, for example, major CPO spillage, collapse of ETP bund, etc. at FELDA Kahang POM had yet to be carried out;
3. Training on Environmental aspect and impact identification / assessment, Hazard Identification, Risk Assessment and Determining Control and Legal Awareness and Compliance not being fully implemented for operational staff and settlers at the estates.
4. Training for HCV monitoring especially for buffer zone was not done at FELDA Kahang.Barat and FELDA Ulu Dengar.
5. RSPO training was not given to contractors (Syarikat Zainal Maulani and Syarikat Bumi Permas).
In response to the issued NCR MM2, Kahang CU had conducted the following training: 1. RSPO SCCS on 26 February 2013 for related Mill personnel; 2. RSPO Awareness on 11/01/13; 3. EIA ,and HIRADC on 16/01/13; 4. HCV on 25/01/13; and 5. SIA on 01/02/13 for staff, smallholders, workers and contractor
Training program, signed attendance list and photographs of training sessions conducted had been submitted to assessor. They are acceptable and thus status of NCR is Closed.
PRINCIPLE 5: ENVIRONMENTAL RESPONSIBILITY AND CONSERVATION OF NATURAL RESOURCES AND BIODIVERSITY
Criterion 5.1 Aspects of plantation and mill management, including replanting, that have environmental impacts are identified, and plans to mitigate the negative impacts and promote the positive ones are made, implemented and monitored, to demonstrate continuous improvement.
Indicators 5.1.1 Documented aspects and impacts risk assessment that is periodically reviewed and updated. Major compliance
5.1.2 Environmental improvement plan to mitigate the negative impacts and promote the positive ones, is developed, implemented and monitored. Minor compliance
Specific National Guidance for Scheme Smallholders Scheme Smallholders Scheme Managers should undertake and document aspects and impacts risk assessment, developed with the participation of the representatives of organized smallholders that sets out appropriate management planning and MSC/RSPO/DOC/06-02 Issue 1 Rev. 0 Page 40 of 102 operational procedures for each impact identified. For significant impact time bound action plans and operational procedures should be drawn to mitigate the negative impacts. The impact assessment should cover:
Building and maintenance of roads to service smallholdings and provide access to mills Putting in drainage or irrigation systems. Replanting or expansion of smallholdings. Clearing of remaining natural vegetation and the need to avoid the use of fire (see 5.5)
Findings:
The FGVPM-KCU had conducted the environmental aspects and impacts risk assessment (photograph 31) for all activities related to estate and mill operation as well as other facilities such as the workshop, chemical and waste stores, laboratory, effluent and water treatment plants. Although the assessed records [RSPO – P5/C.5.1/5.1.1 and RSPO 2011 (Kriteria 5.1/5.3/5.6)] showed that it had been identified, evaluated and reviewed annually it could be improved and thus OFI 5.1.1 and 5.1.2 were raised respectively as below:
The coverage of assessment for new activity either permanent or temporary, for example, construction of building at FELDA Kahang Barat to be included and updated in the related documents accordingly.
The performance of environmental improvement plan to mitigate negative impacts implemented within all CUs (Kahang Mill) to be enhanced by frequently updating its environmental performance status monitoring in proper documentation format.
Photograph 31: Environmental Aspect and Photograph 32: Diesel Tank bunding-at Impact Files at Kahang POM Kahang POM
MSC/RSPO/DOC/06-02 Issue 1 Rev. 0 Page 41 of 102 Photograph 33: Segregation of recyclable Photograph 34: Bioflow polishing tanks at wastes at Ulu Dengar store Kahang POM.
The Kahang POM had established their environmental improvement plan to mitigate the significant aspects from the above risk assessment. Among the improvements were: boiler smoke emission, bunding of diesel storage tank (Photograph 32), emergency preparedness drill, segregation and disposal of recyclable wastes (Photograph 33), and installation of the bioflow polishing system in order to meet the discharged requirements as per DOE license. (Photograph 34). While evidence of implementation of environmental improvement plan (to mitigate the identified negative impacts) at the estates included the construction of chemical store, marked buffer zones (Photograph 35 and 36), containment tray for trapping leaks of liquid herbicides (Photograph 37), erection of no forest intrusion and no hunting sign (Photograph 38) and waste recycling activities (Photograph 39).
Photograph 35 (L-R): Marked riparian zone at FELDA Kahang Barat and ULU Dengar
Photograph 36: Signage showing prohibited Photograph 37: Containment tray for activities at river buffer zone stacking of 20-liter herbicides drums in Chemical Store-FELDA Ulu Dengar,
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Photograph 38 (L-R): No intrusion into forest Photograph 39: 3R bins- (Kahang Barat and no hunting of wildlife sign Estate Office)
Criterion 5.2 The status of rare, threatened or endangered species (ERTs) and high conservation value habitats, if any, that exists in the plantation or that could be affected by plantation or mill management, shall be identified and their conservation taken into account in management plans and operations.
Indicator 5.2.1 Identification and assessment of HCV habitats and protected areas within landholdings; and attempt assessments of HCV habitats and protected areas surrounding landholdings. Major compliance
5.2.2 Management plan for HCV habitats (including ERTs) and their conservation. Major compliance
5.2.3 Evidence of a commitment to discourage any illegal or inappropriate hunting fishing or collecting activities, and developing responsible measures to resolve human-wildlife conflicts. Minor compliance
Specific Guidance: Identify ERTs and establish their conservation status based on national and state conservation schedules; and should provide evidence of attempts to do likewise for immediate adjacent areas.
In the event that the conservation status of a species has not been assessed locally, the IUCN list should be used to determine and report conservation status. Management plans to include areas for improvement.
Where appropriate, the above activities to be conducted involving relevant stakeholders
Specific National Guidance for Scheme Smallholders
Smallholders Scheme Managers should compile information about the status of these aspects for their organized smallholders, as well as the associated mill and directly managed estate (if any). If ERTs or HCV habitats are present or potentially affected by the small holdings, appropriate measures should be employed to maintain or enhance them depending on the size of the scheme.
Findings:
The Sustainability Department, FGVPM had compiled information into a report entitled “HCV Assessment & Management Plan of FELDA Kahang Complex Certification Unit, FELDA Wilayah Segamat” dated 26th September 2012, about the status of High Conservation Value (HCV) within and adjacent to the FGVPM-KCU land schemes. The consultation process included stakeholder meeting, interview with local people, government and non-government agencies. The national interpretation and the HCVF toolkit has been used and implemented.
MSC/RSPO/DOC/06-02 Issue 1 Rev. 0 Page 43 of 102 The HCV assessment had identified the endangered, rare and threatened (ERTs) species at FELDA Kahang Timur, FELDA Kahang Barat and FELDA Ulu Dengar, including the management and action plan.
The Management Plan and Action Plan had been developed based on the assessment findings and consultations with related stakeholders. The action plan, represented in tabular format, contained general descriptions of HCV, action steps and monitoring activities on quarterly basis.
During the site review, FELDA Ulu Dengar and FELDA Kahang Barat had identified and maintained the significant HCV, e.g. HCV4 which is to control and maintain the river buffer zone, and protection on erosion control near Sg. Belumut and Sg. Janoh (tributaries to Sg Sembrong).
There was also presence of external HCV at both FELDA Ulu Dengar and FELDA Kahang Barat, that is, HCV2 - wildlife corridor as well as border with Kluang Forest Reserve.
Results of the assessment showed that there were evidence of freely roaming ERTs between plantations near border of Kluang Forest Reserve, for example, Pangolin (Manis javanica), Elephant (Elephas maximus) and Malayan Tiger (Panthera tigris). Pangolin, elephant and Malayan tiger were listed as Totally Protected in Wildlife Conservation Act 2010 and listed as Endangered species under IUCN Red List.
As part of the management plan, information on the HCV2 were shared with the Forestry Department, Johor and the Wildlife Department, Johor. The last communication with the Forestry Department was on 6th November 2012 as sighted in the meeting minutes. The record was well kept by the FELDA Ulu Dengar Manager. At FELDA Kahang Barat the communication with Wildlife Department was conducted almost every month. The latest record was on 8th December 2012 made via e-aduan (complaint on-line) regarding the encroachment of elephant.
Other management plan sighted included evidences that FELDA Kahang CU Complex’s is committed to the conservation of the wildlife habitat. Signages to prohibit illegal hunting of wildlife were clearly displayed within the plantations (Photographs 40 and 41 below).
Photograph 40 and 41 (L-R): Sign board was erected to discourage hunting at FELDA Ulu Dengar (left) and FELDA Kahang Barat (right)
Although FGVPM-KCU had identified the ERTs and High Conservation areas within and adjacent to their estates, some improvement was needed when significant HCV4 that is, Sg Belumut and Sg Janoh (tributaries to Sg Sembrong) were not highlighted in the map of the MSC/RSPO/DOC/06-02 Issue 1 Rev. 0 Page 44 of 102 assessment report. Therefore, OFI 5.2.1 had been raised. In general, the quality of the HCV assessment report needs improvement.
Criterion 5.3 Waste is reduced, recycled, re-used and disposed off in an environmentally and socially responsible manner.
Indicators 5.3.1 Documented identification of all waste products and sources of pollution. Major compliance
5.3.2 Having identified wastes and pollutants, an operational plan should be developed and implemented, to avoid or reduce pollution. Minor compliance
Specific Guidance : Schedule wastes to be disposed as per EQA 1974 (Scheduled Wastes) Regulations, 2005. Reference to be made to the national programme on recycling of used HDPE pesticide containers. Municipal waste disposal as per local authority or district council in accordance to the Ministry of Health guidelines (i.e. specifications on landfills, licensed contractors, etc) or Workers’ Minimum Standards of Housing and Amenities Act 1990 (Act 446).
Indicator 5.3.3 Evidence that crop residues / biomass are recycled (Cross ref. C4.2). Minor compliance
Specific Guidance: POME should be discharged in compliance with the Environmental Quality Act 1974 (Act 127) and Regulations.
For Sabah and Sarawak, POME should be discharged according to the respective state policies.
Specific National Guidance for Scheme Smallholders Scheme Smallholders Scheme managers should develop and implement an appropriate plan for the management and disposal of waste from smallholdings including the safe disposal of pesticide containers (e.g. National Programme on recycling of used HDPE pesticide containers). Scheme managers should encourage/ educate participants to use resources efficiently and apply reduce, reuse, recycle methods wherever feasible/possible.
Findings:
Generally, waste products had been identified and documented under Environmental Aspect / Impact Assessment prepared. Among the wastes identified were general waste, scheduled waste, scrap metal, crop residue/biomass - fibre, shell, EFB, decanter cake and POME from the mill. For the plantations, they include empty containers, empty fertilizer bags, used office’s stationeries and those from settlers’ housing include domestic wastes.
All waste generated were being disposed in an environmentally and socially responsible manner. Plans to avoid or reduce pollution were also in place. At the mill, it ranged from diesel tank bunding, dedicated concrete building scheduled waste store (Photograph 42), concreted workshops, oil traps, bio-polishing plant, disposal of EFB and decanter cake to the oil palm fields for mulching (Photograph 42) while crop residue/biomass i.e. fibre and shell were used as fuel in the boiler. Palm oil mill effluent (POME) was treated in the effluent treatment plant and finally discharged into the waterways. Other liquid spills had been identified and mitigated through the use of sand or oil trap.
General/domestic wastes were collected and disposed by burying them at internal designated landfill areas. Proper signage had been erected at the landfill site.
Other than general wastes, plastic containers/bags from manuring and spraying activities were also collected, washed and reused. Chemical containers that could no longer be reused were disposed in accordance with legal requirement.
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Photograph 42: Scheduled Waste Photograph 43: Mulching of EFB inside settler’s Store-Kahang POM, estate at Kahang Barat
The records of all waste products and sources of pollution identified by FELDA Ulu Dengar could be further improved by consistently updating the information, daily or weekly waste generated, stored and recycled/disposed, especially for the empty chemical containers. This was raised as an OFI against Indicator 5.3.1.
Implementation of recycling program varied. The palm oil mill had started quite sometimes ago and was successful whereas the line sites had just embarked on it. Recycle bins, (as in Photograph 50) had been provided at mill, worker’s housing areas and offices for separation of solid waste - paper, glass and plastic. It was observed that recyclable wastes had been collected and stored at designated areas. The assessment team had visited the scrap metal and scheduled waste storage area. The scheduled waste store was well built, with appropriate containment, and controlled access. The wastes had been segregated, labelled, stored, inventoried and disposed in full compliance to EQA (Scheduled Wastes) Regulations 2005.
At the smallholder’s level, interviews showed that they had been reminded during the JKKR meeting of the need for proper disposal and recycle of waste including the safe disposal of pesticide containers. Their campaign to increase awareness for recycling was ongoing.
The operational plan developed by CU (Kahang Mill, Kahang Barat Estate and Ulu Dengar Estate) to avoid or reduce pollution can be further improved on its implementation by being holistic, that is, to include both work (mill /estate) and community (quarters/village) area. This was raised as OFI against Indicator 5.3.2.
The handling of damaged empty fertilizer bag that is not stored or recycled by CU (Ulu Dengar Estate) can be further improved by disposing through proper domestic waste management channel. This was raised as OFI during the audit.
Criterion 5.4 Efficiency of energy use and use of renewable energy is maximized.
Indicators 5.4.1 Monitoring of renewable energy use per tonne of CPO or palm product in the mill. Major compliance
5.4.2 Monitoring of direct fossil fuel use per tonne of CPO or kW per tonne palm product in the mill (or FFB MSC/RSPO/DOC/06-02 Issue 1 Rev. 0 Page 46 of 102 where the grower has no mill). Minor compliance
Guidance: To establish baseline values and observe trends within appropriate time-frame. Growers and millers should assess the energy use including fuel and electricity, and energy efficiency of their operations. The feasibility of collecting and using biogas, biodiesel and biofuels should be studied if possible.
Specific National Guidance for Scheme and Independent Smallholders Scheme Managers Mill managers should be encouraged to develop appropriate action plan for improving the efficiency of energy use in their schemes and land holdings.
Findings:
FELDA Kahang Palm Oil Mill had embarked on commitment to use renewable energy in the mill. Fibre and shell were being used as boiler fuel to generate steam for the process, as well as electricity for the mill complex and labour lines. The usage of fibre and nut shell had been monitored and records maintained.
Fossil fuel and biomass fuel usage per ton CPO from January to June 2012 were tabulated as follows:
Year FFB CPO Biomass Fossil fuel Biomass Fossil fuel 2012 processed, production, used (Fiber used consumed, usage mt mt & Shell), (Diesel), mt/mt CPO liter/mt mt liter CPO Jan 16,000.00 3,040.76 3,456.00 27,783.00 1.14 9.14 Feb 14,250.00 2,781.89 3,078.00 30,292.00 1.11 10.89 Mar 13,420.00 2499.23 2,898.72 42,916.00 1.16 17.17 Apr 14,180.00 2,576.80 3,062.88 40,945.00 1.19 15.89 May 15,420.00 2,968.28 3,232.82 25,839.00 1.09 8.71 Jun 18,230.00 3,675.94 3,639.69 20,096.00 0.99 5.47
The usage of renewable energy (fiber and nut shell) showed a slight decrease (improvement) over the first six month of the preceding year per tonne of CPO produced. Monthly consumption of fossil fuel per ton of CPO produced also had relatively improved for the months of May and June 2012.
At the estates, the monitoring of fossil fuel usage as per tonne of CPO on a monthly basis had also been carried out. Currently diesel usage stood at an average of 2.05 liter/mt FFB processed, mainly to run emergency generator. The high diesel consumption was mainly due to one of the boiler at FELDA Kahang Palm Oil Mill being overhauled since May 2012 and expected to be completed in December 2012. Thus, it was not able to supply electricity to estate and line sites.
Scheduled wastes had been discussed under Criterion 5.3 and they had been disposed as per EQA 1974 (Scheduled Wastes) Regulations, 2005.
General domestic wastes were collected and disposed by burying them at internal designated landfill areas. Proper signage had been erected at the landfill site.
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Criterion 5.5 Use of fire for waste disposal and for preparing land for replanting is avoided except in specific situations, as identified in the ASEAN Guidance or other regional best practice.
Indicators: 5.5.1 No evidence of open burning. Where controlled burning occurs, it is as prescribed by the Environmental Quality (Declared Activities) (Open Burning) Order 2003. Major compliance
5.5.2 Previous crop should be felled/mowed down, chipped/shredded, windrowed or pulverized/ ploughed and mulched. Minor compliance
Specific Guidance: A special dispensation from the relevant authorities should be sought in areas where the previous crop or stand is highly diseased and there is a significant risk of disease spread or continuation into the next crop.
5.5.3 No evidence of burning waste (including domestic waste). Minor compliance
Specific National Guidance for Scheme and Independent Smallholders Scheme Smallholders Scheme and Group Managers should carry out training and provide extension support to their participants to avoid using fire for land preparation or open burning is not used except in accordance with ASEAN guidelines or other regional best practice.
Findings:
It was verified during the assessment through site visits, interviews and records sighted that no open burning had been carried out in line with the FELDA Kahang CU’s policy on zero burning. Signage disallowing open burning had been sighted at line sites. It was also seen that the line site garbage collection contractors came to collect the domestic waste as they bins sighted were empty.
Although replanting at Ulu Dengar took place in 2012, there was no evidence of burning spotted. Remains of previous crop were seen felled/mowed down, chipped/shredded, and left to rot.
Criterion 5.6 Plans to reduce pollution and emissions, including greenhouse gases, are developed, implemented and monitored.
Indicators: 5.6.1 Documented plans to mitigate all polluting activities (Cross ref to C 5.1). Major compliance
5.6.2 Plans are reviewed annually. Minor compliance
Specific Guidance: Pollutants and emissions are identified and plans to reduce them are developed in conformance to national regulations and guidance.
5.6.3 Monitor and reduce peat subsidence rate through water table management. (Within ranges specified in C 4.3). Minor compliance
Specific National Guidance for Scheme and Independent Smallholders Scheme Managers Scheme Managers should include an assessment of all polluting activities by their participants and develop abatement plan.
MSC/RSPO/DOC/06-02 Issue 1 Rev. 0 Page 48 of 102 Findings:
The mill and estates had identified the sources of pollution and emissions from the Environmental Aspect/Impact assessment carried out under Indicator 5.1.1. Various and regular measurements of the emissions and pollutants had been taken and the data had been used to develop mitigating plans and strategies for improvement. The assessor had verified the plans and among the planned actions were those discussed under Indicator 5.2.3, for example, the construction of oil traps, bunded diesel storage tank, POME being treated in a series of ponds and the final discharge parameters regularly monitored. The action plans had also been reviewed during regular operations meetings.
At the Kahang POM, although the action plans to mitigate all polluting activities had been discussed at regular operations meeting and reviewed annually by the Kahang Mill Manager it could be further improved by specifying the actual program, especially, for the polluting activities that had been legally compound by DOE for non-compliance (black smoke emission exceeded the Ringelman Chart no. 2 limit) in its RSPO documentation. This was raised as OFI.
There was no peat soil area in the FGVPM-KCU. Therefore, Indicator 5.6.3 is not applicable.
MSC/RSPO/DOC/06-02 Issue 1 Rev. 0 Page 49 of 102 PRINCIPLE 6: RESPONSIBLE CONSIDERATION OF EMPLOYEES AND OF INDIVIDUALS AND COMMUNITIES AFFECTED BY GROWERS AND MILLS
The responsible consideration of employees and individuals and communities by growers and millers was not conducted at Kahang Oil Mill. Thus a Major NCR ZE07 had been raised against the whole of Principle 6 for Kahang Oil Mill.
Criterion 6.1 Aspects of plantation and mill management, including replanting, that have social impacts are identified in a participatory way, and plans to mitigate the negative impacts and promote the positive ones are made, implemented and monitored, to demonstrate continuous improvement.
Indicators: 6.1.1 A documented social impact assessment including records of meetings. Major compliance
Specific Guidance: Non-restrictive format incorporating elements spelt out in this criterion and raised through stakeholder consultation including local expertise.
6.1.2 Evidence that the assessment has been done with the participation of affected parties. Minor compliance
Specific Guidance: Participation in this context means that affected parties or their official representatives or freely chosen spokespersons are able to express their views during the identification of impacts, reviewing findings and plans for mitigation, and monitoring the success of implemented plans.
6.1.3 A timetable with responsibilities for mitigation and monitoring is reviewed and updated as necessary. Minor compliance
Guidance: Identification of social impacts may be carried out by the grower in consultation with other affected parties, including women and migrant workers as appropriate to the situation. The involvement of independent experts should be sought where this is considered necessary to ensure that all impacts (both positive and negative) are identified. Particular attention should be paid to the impacts of outgrower schemes (where the plantation includes such a scheme).
Plantation and mill management may have social impacts on factors such as:
1. Access and use rights. 2. Economic livelihoods (e.g. paid employment) and working conditions. 3. Subsistence activities. 4. Cultural and religious values. 5. Health and education facilities. 6. Other community values, resulting from changes such as improved transport /communication or arrival of substantial migrant labour force.
Specific National Guidance for Scheme and Independent Smallholders Scheme Smallholders Management aspects that can result in social impact should be identified with the consultation of their participants or representatives. If it warrants, a documented SIA should be conducted with the participation of the affected parties. A time bound mitigation plan with responsibilities should be drawn and implemented (with review and update if necessary).
Findings:
In reference to 6.1.1 and 6.1.3, however, in the case of the land schemes of FELDA Ulu Dengar and FELDA Kahang Barat, a documented SIA including records of meetings and a timetable with responsibilities for mitigation and monitoring of impacts were sighted.
MSC/RSPO/DOC/06-02 Issue 1 Rev. 0 Page 50 of 102 The SIA was conducted based on a questionnaire formulated by FELDA HQ. They covered impacts of plantation and oil mill activities on internal (scheme participants, workers/employees) and external (neighbouring) community infrastructures, livelihood, cultural/religious values and other community values.
In reference to 6.1.2, for the plantations there were records that the assessment was carried out with the participation, of affected parties which include the scheme participants, workers/employees, suppliers/contractors and neighbouring community members. The respondents were informed prior to the conduct of the survey in the form of notices sent out to them
However, a number of weaknesses were noticed, for example the percentage of respondents interviewed were not highlighted, views of external stakeholders were collected through a meeting not through the questionnaire, the analysis succeeded in demonstrating the positive and negative views of the respondents rather than the impacts on the community resulting from plantation and mill activities and the items in the questionnaire were not fully elaborated in the report. Thus an OFI had been raised against this criterion for the plantations.
Criterion 6.2 There are open and transparent methods for communication and consultation between growers and/or millers, local communities and other affected or interested parties.
Indicators: 6.2.1 Documented consultation and communication procedures. Major compliance
6.2.2 A nominated plantation management official at the operating unit responsible for these issues. Minor compliance
6.2.3 Maintenance of a list of stakeholders, records of all communication and records of actions taken in response to input from stakeholders. Minor compliance
Specific Guidance: Decisions that the growers or mills are planning to make should be made clear, so that local communities and other interested parties understand the purpose of the communication and/or consultation.
Communication and consultation mechanisms should be designed in collaboration with local communities and other affected or interested parties. These should consider the use of existing local mechanisms and languages. Consideration should be given to the existence/ formation of a multi-stakeholder forum.
Communications should take into account differential access to information of women as compared to men, village leaders as compared to day workers, new versus established community groups, and different ethnic groups.
Consideration should be given to involving third parties, such as disinterested community groups, NGOs, or government (or a combination of these), to facilitate smallholder schemes and communities, and others as appropriate, in these communications.
Specific National Guidance for Scheme and Independent Smallholders Scheme Smallholders Scheme Managers should provide the necessary mechanism and designate an officer for consultation and communication with participants/representatives and other stakeholders and this should be documented.
Findings:
There was a documented consultation and communication procedures produced by the CU entitled “Manual Prosedur Komunikasi, Penglibatan dan Rundingan” (Manual for Communication, Participation and Consultation Procedures). It was used in communications
MSC/RSPO/DOC/06-02 Issue 1 Rev. 0 Page 51 of 102 and consultations with its stakeholders namely the scheme participants, workers/employees, suppliers/contractors and neighbouring community members. Records of meetings and discussions with Scheme Development and Safety Committee (JKKR) involving the operating unit’s management and community leaders were available.
A management official at each operating unit level (except at Kahanag POM) had been nominated to be responsible on issues related to consultations and communication between growers and/or millers and internal (scheme participants, workers/employees) and external (neighbouring communities, suppliers/contractors) stakeholders.
In reference to 6.2.3, a list of internal and external stakeholders was sighted in each scheme and records of meetings with the stakeholders were available except for the Kahang POM. It consisted of scheme participants, workers/employees, suppliers and contractors. However, the external stakeholder list did not include a number of local communities and smallholders. Meetings involving the CU’s management and scheme participant leaders were held regularly. Participants’ involvement and participation were encouraged. All issues raised were given due attention and actions had been taken to resolve the issues raised.
There were documents, produced by the schemes to show the existence of documented consultations and communication, for example, Minit Mesyuarat Jawatankuasa Wanita (minutes of Gender Committee meetings) and Minit Mesyuarat JKKR (minutes of the Scheme Development and Safety Committee meetings).
Other forms of management communication with workers/staff and scheme participants include the following:
Assembly/Roll calls Suggestion boxes Internal circulars/memos Staff/worker representatives Notice boards Written complaints
Consultations were held with randomly selected workers/staff, scheme participants and suppliers/contractors of the schemes audited. These auditor-stakeholder interviews confirmed that communications and relationships between the scheme management and stakeholders were good.
A list of internal and external stakeholders had been maintained.. However, the external stakeholders list was not all inclusive such that a number of external local communities like immediate neighbours (Southern Malay Estate, Sime Darby Tun Dr Ismail Estate) and smallholders, alienated land (ex Safari areas) and TNB were missed out. Thus, an OFI had been raised against Indicator 6.2.3.
Criterion 6.3 There is a mutually agreed and documented system for dealing with complaints and grievances, which is implemented and accepted by all parties.
Indicators: 6.3.1 Documentation of the process by which a dispute was resolved and the outcome. Major compliance
Specific Guidance: Records are to be kept for 3 years.
6.3.2 The system resolves disputes in an effective, timely and appropriate manner. Minor compliance
6.3.3 The system is open to any affected parties. Minor compliance
MSC/RSPO/DOC/06-02 Issue 1 Rev. 0 Page 52 of 102 Guidance: Dispute resolution mechanisms should be established through open and consensual agreements with relevant affected parties.
Complaints may be dealt with by mechanisms such as Joint Consultative Committees (JCC) with gender representation. Grievances may be internal (employees) or external.
Specific National Guidance for Scheme and Independent Smallholders Scheme Smallholders Scheme and Group Managers should provide the necessary mechanism to deal with complaints and grievances by their participants and other stakeholders and the outcome is open to affected parties. The management should actively seek to resolve the complaint and grievances within a reasonable period.
Findings:
A manual entitled Rungutan, Keingkaran, Siasatan Insiden dan Tindakan Pembetulan (Complaints, Rule Breakings, Incident Investigations and Corrective Actions) which described procedures for handling complaints and grievances was sighted except not made available by the Kahang POM. Staff/workers, scheme participants and suppliers/contractors were aware and understood the procedures. This was confirmed through consultations with them.
Borang Aduan (Complaint Form), Kotak Cadangan (Suggestion Boxes) and Buku Aduan (Complaints Book) were available at the scheme offices for any interested party to register their complaints. The aggrieved party could fill in the Complaint Form or write a letter and deposit it in the Suggestion Box or submit the complaint verbally to anyone in the main office or to the official responsible for handling social issues or to the worker representatives or gender representatives or record the complaint in the Complaints Book..
Since the procedure and system has been put in place only recently there were hardly any complaints recorded through the channels stated above. However, the few complaints recorded were dealt with in a timely manner as the records in the Complaint Book demonstrated.
The system was open to everyone, external as well as internal (scheme participants, workers/employees) communities. There was no evidence indicating the system was limited to certain parties (e.g. workers/employees and scheme participants only).
Besides the above channels, indeed, the scheme participants have an additional channel to submit their complaints, that is, the JKKR meeting. The complaints and suggestions were minuted and actions taken reported in the following meeting).
Criterion 6.4 Any negotiations concerning compensation for loss of legal or customary rights are dealt with through a documented system that enables indigenous peoples, local communities and other stakeholders to express their views through their own representative institutions.
Indicators: 6.4.1 Establishment of a procedure for identifying legal and customary rights and a procedure for identifying people entitled to compensation. Major compliance
6.4.2 A procedure for calculating and distributing fair compensation (monetary or otherwise) is established and implemented. This takes into account gender differences in the power to claim rights, ownership and access to land; and long-established communities; differences in ethnic groups’ proof of legal versus communal ownership of land. Minor compliance
6.4.3 The process and outcome of any compensation claims is documented and made publicly available.
MSC/RSPO/DOC/06-02 Issue 1 Rev. 0 Page 53 of 102 Minor compliance
Specific Guidance: This criterion should be considered in conjunction with Criterion 2.3.
Specific National Guidance for Scheme and Independent Smallholders Scheme Smallholders Scheme and Group Managers should be able to show that they have acquired and/or allocated land for their organized smallholdings in compliance with this criterion. If any land acquisition requires fair compensation, it should be dealt with documented system that includes respective parties involved and settlement details, if such provision is not available judicially.
Findings:
A procedure for identifying legal and customary rights and a procedure for identifying people entitled to compensation and the accompanying procedure for calculating and distributing fair compensation (monetary or otherwise) had not been developed in all the schemes and mill audited. Hence, a Minor NCR ZE01, ZE02 and ZE03 had been raised against all three indicators (6.4.1, 6.4.2, 6.4.3) under this criterion.
Criterion 6.5 Pay and conditions for employees and for employees of contractors always meet at least legal or industry minimum standards and are sufficient to provide decent living wages.
Indicators: 6.5.1 Documentation of pay and conditions. Major compliance
6.5.2 Labour laws, union agreements or direct contracts of employment detailing payments and conditions of employment (e.g. working hours, deductions, overtime, sickness, holiday entitlement, maternity leave, reasons for dismissal, period of notice, etc) are available in the language understood by the workers or explained carefully to them by a plantation management official in the operating unit. Minor compliance
6.5.3 Growers and millers provide adequate housing, water supplies, medical, educational and welfare amenities in accordance with Workers’ Minimum Standard of Housing and Amenities Act 1990 (Act 446) or above, where no such public facilities are available or accessible (not applicable to smallholders). Minor compliance
Guidance: Where temporary or migrant workers are employed, a special labour policy should be established. This labour policy would state the non discriminatory practices; no contract substitution of original contract, post arrival orientation program to focus especially on language, safety, labour laws, cultural practices etc; decent living conditions to be provided. Migrant workers are legalised, and a separate employment agreement should be drawn up to meet immigration requirements for foreign workers, and international standards, if ratified.
Specific National Guidance for Scheme and Independent Smallholders Scheme Smallholders Where temporary or migrant workers are employed, a special labour policy should be established. This labour policy would state the non discriminatory practices; no contract substitution of original contract, post arrival orientation program to focus especially on language, safety, labour laws, cultural practices etc; decent living conditions to be provided. Migrant workers are legalised, and a separate employment agreement should be drawn up to meet immigration requirements for foreign workers, and international standards, if ratified.
The Managers should educate the participants on legal obligations in employing workers on their plot/land.
Findings:
A contract of employment detailing payments and conditions of employment for local workers employed at FELDA Kahang Barat and Ulu Dengar (but not at Kahang Oil Mill) were sighted. However, the workers interviewed informed the auditor that they signed a contract
MSC/RSPO/DOC/06-02 Issue 1 Rev. 0 Page 54 of 102 of employment with FELDA in their country of origin before coming over. The details of the contract were explained to them before the signing. Even so, as the contracts were not sighted during the audit two Major NCR, ZE04 and ZE05 had been raised against Indicators 6.5.1 and 6.5.2 respectively.
FELDA Kahang Barat and FELDA Ulu Dengar had obtained records of contract of employment for foreign workers and copies of this record had been made available to the auditor. Status of NCR ZE04 and ZE05 are considered closed.
Free housing, subsidized and adequate water and power supply and free garbage collection were provided by FELDA for its local and foreign employees. Domestic water supplied by Syarikat Air Johor. The supplies were sufficient in quantity and wholesome in quantity. The employees interviewed had no complaint. However, some foreign workers were noted being housed in cabins which did not meet the Malaysian Workers’ Minimum Standard of Housing and Amenities Act 1990 (Act 446). Thus a Minor NCR ZE08 had been raised against Indicator 6.5.3.
Scheme participants who worked their own lot/land used family labour only. No hired workers were used. This was confirmed through interviews with scheme managers and the participants.
Criterion 6.6 The employer respects the right of all personnel to form and join trade unions of their choice and to bargain collectively. Where the right to freedom of association and collective bargaining are restricted under law, the employer facilitates parallel means of independent and free association and bargaining for all such personnel.
Indicators: 6.6.1 Documented minutes of meetings with main trade unions or workers representatives. Major compliance 6.6.2 A published statement in local languages recognizing freedom of association. Minor compliance
Guidance: The right of employees and contractors to form associations and bargain collectively with their employer should be respected. Documented company policy recognizing freedom of association.
Labour laws and union agreements or in their absence, direct contracts of employment detailing payments and other conditions are available in the languages understood by the workers or explained carefully to them by a plantation management official in the operating unit.
Specific National Guidance for Scheme and Independent Smallholders Scheme Smallholders Scheme managers must respect the right of participants to form and represent themselves through their own representative associations and / or trades unions and accept them as parties to participatory processes, consultations, communications and negotiations in the management of the scheme.
Findings:
FELDA in general supported the freedom and rights of its employees to form and join associations to bargain collectively for their benefits. As required by Indicator 6.6.2 an officially published statement entitled “Polisi Kebebasan Menganggotai Kesatuan Sekerja / Khidmat Sukarela” (Freedom of Association Policy) in the Malay language recognizing freedom of association was made available and explained to all workers and the policy exhibited in public places. However, foreign workers out of their own choice were not members of any trade union.
MSC/RSPO/DOC/06-02 Issue 1 Rev. 0 Page 55 of 102 However, no record of meetings between estate/mill management and trade union or worker representatives were sighted at at FELDA Kahang Barat, Ulu Dengar and Kahang Oil Mill. Thus a Major NCR ZE06 had been raised against Indicator 6.6.1.
With regards to the establishment of associations among the scheme participants, a committee, the JKKR (mentioned earlier) had been established in every scheme to represent the interests of the participants. The JKKR met the management regularly and all their meetings were minuted.
Criterion 6.7 Children are not employed or exploited. Work by children is acceptable on family farms, under adult supervision, and when not interfering with education programmes. Children are not exposed to hazardous working conditions.
Indicator: 31 6.7.1 Documented evidence that minimum age requirement is met. Major compliance
Guidance: Growers and millers should clearly define the minimum working age, together with working hours. Only workers 16 years and older may be employed, with the stated exception of family farms. Smallholders should allow work by children only if permitted by national regulations.
The minimum age of workers should be not less than 16 years, or the minimum school leaving age, or the minimum age permitted under national regulations, where higher.
Specific National Guidance for Scheme and Independent Smallholders Scheme Smallholders Children should only be allowed work in schemes and individual land holdings if permitted by national regulations and not interfering with education programmes. Under such situation, children should only work under adult supervision.
Findings:
FELDA has a written policy statement entitled “Polisi Pekerja-Pekerja Kanak-Kanak” (Child Labour Policy) prohibiting employment of children below 18 years old. The statement was sighted in the RSPO’s file on Principle 6 (except at Kahang POM) as well seen displayed on office notice boards. The policy was implemented as there was no record of persons under the age of eighteen, the minimum working age under Malaysian Labor Laws (Act A1238) hired by the CU. This was verified through an examination of the employment cards and copies of passports of foreign workers and confirmed also by interviewing randomly selected workers.
In the case of participants who used family labour to work their lot/land, child labour was not used. This was confirmed through interviews with the participants as well as the Scheme Manager.
Criterion 6.8 Any form of discrimination based on race, caste, national origin, religion, disability, gender, sexual orientation, union membership, political affiliation, or age, is prohibited.
Indicators: 6.8.1 A publicly available equal opportunities policy. Major compliance
6.8.2 Evidence that employees and groups including migrant workers have not been discriminated against. Minor compliance
Guidance: The grievance procedures detailed in 6.3 apply. Positive discrimination to provide employment and benefits to specific communities is acceptable as part of negotiated agreements.
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Specific National Guidance for Scheme and Independent Smallholders Scheme Smallholders Scheme managers must ensure that women, indigenous peoples and minorities participate in negotiating processes. Positive discrimination to provide employment and benefits to specific communities is acceptable as part of negotiated agreements. All stakeholders should participate in the negotiating processes.
Findings:
There was clear evidence of conformance to this criterion. There was a publicly available equal opportunities policy entitled “Polisi Kesetaraan Peluang” (Equal Opportunity Policy), except at Kahang POM, in the Malay language, established, written and signed by the FELDA Managing Director. It was sighted in the RSPO file on Principle 6 and displayed at all offices visited. The policy stated clearly the equal rights assigned to all employees irrespective of race, caste, nationality, religion, gender, union membership, political affiliation and disability. It was also explained to foreign workers and found understood by them.
There was no evidence of discrimination. All employees (local or migrant, male or female) were hired based on their qualification not their socio-cultural background or political leanings. They were covered by the same pay and conditions of employment associated with the jobs they were hired for. This was confirmed by local and foreign employees interviewed during the assessment.
Poor and the landless Malaysians, regardless of their socio-cultural, religious or political affiliation, were eligible to join the scheme, and as scheme participants they were allowed to participate in negotiations related to their interests.
Criterion 6.9 A policy to prevent sexual harassment and all other forms of violence against women and to protect their reproductive rights is developed and applied.
Indicator: 6.9.1 A policy on sexual harassment and violence and records of implementation. Major compliance
6.9.2 A specific grievance mechanism is established. Major compliance
Guidance: There should be a clear policy developed in consultation with employees, contractors and other relevant stakeholders, which should be publicly available. The policy is applicable within the boundaries of the plantation/mills or while on duty outside the premises. Progress in implementing the policy should be regularly monitored and the results of monitoring activities should be recorded.
A committee specifically to address concerns of women may be required to comply with the criterion. This committee will consider matters such as; training on women’s rights, counselling for women affected by violence and child care facilities to be provided by the growers and millers. The activities of the committee should be documented.
Specific National Guidance for Scheme and Independent Smallholders
Scheme Smallholders For Scheme Managers, there should be a clear policy made publicly.
Findings:
There was a well displayed and clear policy on sexual harassment and violence entitled “Polisi Gangguan Seksual” (Sexual Harassment Policy). The policy in Bahasa Malaysia, was made available and explained to all female employees. The sexual harassment and violence policy had been implemented. MSC/RSPO/DOC/06-02 Issue 1 Rev. 0 Page 57 of 102 A specific grievance mechanism to handle issues related to sexual harassment and violence had been established except at Kahang POM. The grievances were dealt with through formal channels such as JKKR, Women Scheme Participant Movement or GPW and Gerakan Belia (Youth Movement). A Jawatankuasa Wanita (Gender Committee) whose responsibility among others was to look into gender issues (especially matters related to sexual harassment) had also been established. The existence of this policy and its implementation through the establishment of the sexual harassment grievance mechanism and the Gender Committee was confirmed by information gathered during consultations held with the female employees as well as members of the Gender Committee. The female employees interviewed during the assessment also understood the meaning of sexual harassment and the appropriate complaint procedure.
The scheme participants were also aware of this policy and the associated grievance mechanism. This was confirmed through interviews of randomly selected participants.
Criterion 6.10 Growers and mills deal fairly and transparently with smallholders and other local businesses.
Indicators: 6.10.1 Pricing mechanisms for FFB and inputs/services shall be documented. Major compliance
6.10.2 Current and past prices paid for FFB shall be publicly available. Minor compliance
6.10.3 Evidence that all parties understand the contractual agreements they enter into, and that contracts are fair, legal and transparent. Minor compliance
6.10.4 Agreed payments shall be made in a timely manner. Minor compliance
Guidance: Transactions with smallholders should consider issues such as the role of middlemen, transport and storage of FFB, quality and grading.
Smallholders must have access to the grievance procedure under Criterion 6.3, if they consider that they are not receiving a fair price for FFB, whether or not middlemen are involved.
The need for a fair and transparent pricing mechanism is particularly important for outgrowers, who are contractually obliged to sell all FFB to a particular mill. If mills require smallholders to change practices to meet the RSPO criteria, consideration must be given to the costs of such changes, and the possibility of advance payments for FFB could be considered.
Specific National Guidance for Scheme and Independent Smallholders Scheme Smallholders Scheme Managers are responsible for fair and transparent deal with participants and other local business. This will include:
mill or plantation).
fair, legal and transparent and all costs, fees and levies are explained and agreed in advance. manner.
manner. te lead in time.
MSC/RSPO/DOC/06-02 Issue 1 Rev. 0 Page 58 of 102 Findings:
Relevant files related to 6.10.1, 6.10.2, 6.10.3, 6.10.4 were sighted at the schemes but not at the Kahang POM. Even though consultations with contractors and suppliers pertaining to 6.10.3 and 6.10.4 stated that they understood the contractual agreements they entered into, and that the contracts were fair, legal and transparent, NCR’s are still raised against 6.10.3 and 6.10.4 (covered by the NCR raised against Principle 6 for Kahang Oil Mill).
Consultations with contractors and suppliers as well as scheme participants pertaining to 6.10.3 and 6.10.4 at the schemes audited showed that they understood the contractual agreements they entered into, and that contracts were fair, legal and transparent and that all payments were made in a timely manner.
Criterion 6.11 Growers and millers contribute to local sustainable development wherever appropriate.
Indicator: 6.11.1 Demonstrable contributions to local development that are based on the results of consultation with local communities. Minor compliance
Guidance: Contributions to local development should be based on the results of consultation with local communities. See also Criterion 6.2. Such consultation should be based on the principles of transparency, openness and participation and should encourage communities to identify their own priorities and needs, including the different needs of men and women.
Where candidates for employment are of equal merit, preference should always be given to members of local communities in accordance to national policy. Positive discrimination should not be recognized as conflicting with Criterion 6.8.
Specific National Guidance for Scheme and Independent Smallholders Scheme Smallholders Scheme Managers are encouraged to contribute to local development based on consultation with local communities.
Findings:
The Kahang CU, except at Kahang POM, had initiated consultations with the scheme participants through regular meetings that the management had with JKKR. Based on these consultations various activities to improve the participants’ economic and social conditions were carried out. This could be seen in the social management plan developed by each scheme and in other related documents. The emphasis was on education, health, religion and the family
The CU had also initiated consultations with settler communities as well as neighboring external communities. This was evident from the records being kept on social impact assessments. Information obtained was used to work out a social management plan, which, when implemented had contributed to local social development.
MSC/RSPO/DOC/06-02 Issue 1 Rev. 0 Page 59 of 102 PRINCIPLE 7: RESPONSIBLE DEVELOPMENT OF NEW PLANTINGS
Criterion 7.1 A comprehensive and participatory independent social and environmental impact assessment is undertaken prior to establishing new plantings or operations, or expanding existing ones, and the results incorporated into planning, management and operations.
Indicators: 7.1.1 An independent and participatory social and environmental impact assessment (SEIA) to be conducted and documented (Cross ref. to C 7.2, 7.3, 7.4, 7.5, 7.6). Major compliance
Specific Guidance:
SEIAs to include previous land use / history and involve independent consultation as per national and state regulations, via participatory methodology which includes external stakeholders.
For Sabah, slopes 25 degrees and above are considered high risk erosion areas and cannot undergo replanting unless specified in the EIA report [Environment Impact Assessment (Order 2005)] and approved by the Environmental Protection Department (EPD).
For Sarawak, steep slopes are considered high risk erosion areas and cannot undergo replanting unless specified in the EIA report [Natural Resources and Environment (Prescribed Activities) Order 1994] and approved by the Natural Resources and Environment Board (NREB).
7.1.2 The results of the SEIA to be incorporated into an appropriate management plan and operational procedures developed, implemented, monitored and reviewed. Minor compliance
7.1.3 Where the development includes smallholder schemes of above 500ha in total, the impacts and implications of how it is managed should be documented and a plan to manage the impacts produced. Minor compliance
Guidance: The terms of reference should be defined and impact assessment should be carried out by accredited independent experts, in order to ensure an objective process. Both should not be done by the same body. See also C 5.1 and C 6.1.
This indicator is not applicable to development of smallholder schemes below 500ha.
For Sabah, new planting or replanting of area 500ha or more requires EIA. For areas below 500ha but above 100ha, proposal for mitigation measures (PMM) is required. For Sarawak, only new planting of area 500ha and above requires EIA. Onus is on the company to report back to the DOE on the mitigation efforts being put in place arising out of the EIA.
Assessment of above and below ground carbon storage is important but beyond the scope of an EIA. Note: This aspect will be considered by an RSPO Greenhouse Gas Working Group.
Specific National Guidance for Scheme and Independent Smallholders
Scheme Smallholders This criterion applies to scheme smallholders of land holdings of above 500ha. The terms of reference should be defined by Federal/state authority and impact assessment should be carried out by accredited independent experts, in order to ensure an objective process.
For Sabah, new planting or replanting of area 500ha or more requires EIA. For areas below 500ha but above 100ha, proposal for mitigation measures (PMM) is required.
SEIAs to include previous land use / history and involve independent consultation as per national and state regulations, via participatory methodology which includes external stakeholders.
For Sabah, slopes 25 degrees and above are considered high risk erosion areas and cannot undergo replanting unless specified in the EIA report [Environment Impact Assessment (Order 2005)] and approved by the Environmental Protection Department (EPD).
MSC/RSPO/DOC/06-02 Issue 1 Rev. 0 Page 60 of 102 For Sarawak, steep slopes are considered high risk erosion areas and cannot undergo replanting unless specified in the EIA report [Natural Resources and Environment (Prescribed Activities) Order 1994] and approved by the Natural Resources and Environment Board (NREB).
Independent Smallholders
and land users and ensure that proposed new plantings take into consideration relevant RSPO P&C. a should conduct impact analysis if required by national legislation.
the analysis of impacts.
Findings:
The assessment team has verified that Principle 7 is not applicable to FGVPM-KCU.
Criterion 7.2 Soil surveys and topographic information are used for site planning in the establishment of new plantings, and the results are incorporated into plans and operations.
Indicators: 7.2.1 Soil suitability maps or soil surveys adequate to establish the long-term suitability of land for oil palm cultivation should be available. Major compliance
7.2.2 Topographic information adequate to guide the planning of drainage and irrigation systems, roads and other infrastructure should be available. Minor compliance
Guidance: These activities may be linked to the SEIA (C7.1) but need not be done by independent experts.
Soil surveys should be adequate to establish the long-term suitability of land for oil palm cultivation. Soil suitability maps or soil surveys should be appropriate to the scale of operation and should include information on soil types, topography, soil depth, moisture availability, stoniness, fertility and long-term soil sustainability. Soils unsuitable for planting or those requiring special treatment should be identified.
This information should be used to plan planting programmes, etc. Measures should be planned to minimise erosion through appropriate use of heavy machinery, terracing on slopes, appropriate road construction, rapid establishment of cover, protection of riverbanks, etc.
Specific National Guidance for Scheme and Independent Smallholders
Scheme Smallholders For scheme managers, the soil surveys should be adequate to establish the long-term suitability of land for oil palm cultivation. Soil suitability maps or soil surveys should be appropriate to the scale of operation.
Information on soils may be collected and provided by scheme management or the mill that purchases the scheme’s FFB.
Soils unsuitable for planting or those requiring special treatment should be identified.
Scheme managers must ensure that they apply the same procedures required for mills and new estates to all schemes. These activities may be linked to the SEIA (7.1) but need not be done by independent experts.
Independent Smallholders Where groups plan to expand their aggregate holdings by more than 500 ha. in any one year, group managers must ensure that these requirements are applied to all group members planning to expand their holdings or acquire new ones. National interpretations should include detail on peat depth.
Where groups plan to expand their aggregate holdings by less than 500 ha. in any one year only a simplified soil survey is required (see 71.)
MSC/RSPO/DOC/06-02 Issue 1 Rev. 0 Page 61 of 102 Findings:
The assessment team had verified that Principle 7 was not applicable to FGVPM-KCU.
Criterion 7.3 New plantings since November 2005, have not replaced primary forest or any area required to maintain or enhance one or more High Conservation Values.
Indicators: 7.3.1 A HCV assessment, including stakeholder consultation, is conducted prior to any conversion. Major compliance
Guidance: HCV assessments to be documented and included as part of the SEIA (C7.1). Reference should be made to EIA to indicate the extent of the HCV areas as determined by relevant experts, with priority given to the locals.
This criterion applies to forests and other vegetation types. This applies irrespective of any changes in land ownership or farm management that have taken place after this date. High Conservation Values (HCVs) may be identified in restricted areas of a landholding, and in such cases new plantings can be planned to allow the HCVs to be maintained or enhanced.
Specific Guidance to the above indicator are listed below:
1. New plantings within Nov 05 and Nov 07 must be in compliance with existing regulatory requirements that relate to social and environmental impacts assessment i.e. SEIA (ref.C7.1) and also comply with the legalized land spatial planning. 2. Where it can be proven that the land did not contain HCV after Nov 2005, the land can enter the RSPO certification programme. 3. Where the HCV status of the land is unknown and/or disputed, the land will be excluded from the RSPO certification programme, until an acceptable solution for HCV compensation has been developed. 4. Companies owning such land can enter other estates in the programme.
This arrangement is valid only for land development between Nov 05 and Nov 07 which was the RSPO P&C initial pilot implementation period.
7.3.2 No conversion of Environmentally Sensitive Areas (ESAs) to oil palm as per Peninsular Malaysia’s National Physical Plan (NPP) and Sabah Forest Management Unit under the Sabah Forest Management License Agreement. Major compliance
Specific Guidance: ESA rankings and management criteria as per the NPP are listed in Appendix 3.
7.3.3 No new plantings on floodplains (reference to be made to State DID). Major compliance
7.3.4 Dates of land preparation and commencement are recorded. Minor compliance
Specific National Guidance for Scheme and Independent Smallholders
Scheme Smallholders Scheme Managers must ensure that this criterion is applied to scheme smallholdings.
Independent Smallholders Group managers must ensure that this criterion is applied to group smallholdings.
This criterion also applies to independent smallholders who later seek to become members of smallholder groups seeking certification.
Findings:
The assessment team had verified that Principle 7 was not applicable to FGVPM-KCU.
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Criterion 7.4 Extensive planting (to be determined by SEIA) on steep terrain, and/or on marginal and fragile soils, is avoided.
Indicators: 7.4.1 All new plantings should not be cultivated on land more than 300m above sea level and on land more than 25 degrees slope unless specified by local legislation (Ref: MSGAP Part 2: OP 4.4.1.3 & 4.4.1.4) Major compliance
7.4.2 Where planting on fragile and marginal soils is proposed, plans shall be developed and implemented to protect them without incurring adverse impacts (e.g. hydrological) or significantly increased risks (e.g. fire risk) in areas outside the plantation. Minor compliance
Guidance: This activity should be subjected to a comprehensive EIA as required by C 7.1.
Marginal and fragile soils, including excessive gradients and peat soils, should be identified prior to conversion to plantation.
Specific National Guidance for Scheme and Independent Smallholders
Scheme Smallholders Scheme Managers should avoid establishing new plantings on steep terrain and/or on marginal and fragile soils. If it’s the only source of livelihood, it should be developed with the use of appropriate conservation measures. Furthermore, its planting must be fully justified and should not to push people into poverty, and must be done in accordance with the indicators.
Independent Smallholders Where groups plan to expand their aggregate holdings by more than 500 ha. in any one year, group managers must ensure that no new lands are acquired by existing group members on steep terrain and/or on marginal and fragile soils.
Findings:
The assessment team had verified that Principle 7 was not applicable to FGVPM-KCU.
Criterion 7.5 No new plantings are established on local peoples’ land without their free, prior and informed consent, dealt with through a documented system that enables indigenous peoples, local communities and other stakeholders to express their views through their own representative institutions.
Indicator: 7.5.1 This activity should be integrated with SEIA required by C 7.1 Major compliance
Guidance: Where new plantings are considered to be acceptable, management plans and operations should maintain sacred sites. Agreements with local communities should be made without coercion or other undue influence (see guidance for C 2.3)
Relevant stakeholders include those affected by or concerned with the new plantings. Refer also to C 2.2, 2.3, 6.2, 6.4 and 7.6 for indicators of compliance.
Specific National Guidance for Scheme and Independent Smallholders
Scheme Smallholders Scheme Managers can show that lands acquired for their organized smallholders do not diminish legal or customary rights. Where others’ customary or legally owned lands have been taken-over, there is documentary proof of transfer of rights (e.g. sale) and of payment or provision of agreed compensation.
To verify that, the Scheme managers must provide:-
MSC/RSPO/DOC/06-02 Issue 1 Rev. 0 Page 63 of 102 sed customary rights (criteria 2.3, 7.5 and 7.6)
Independent Smallholders Group Managers engages with indigenous people and local communities prior to the development of new oil palm plantings, and where the lands are encumbered by local or customary rights, these must be negotiated to reach settlement agreed by both parties. All negotiated agreement must be well documented for a long-term benefit for all parties.
Findings:
The assessment team had verified that Principle 7 was not applicable to FGVPM-KCU
Criterion 7.6 Local people are compensated for any agreed land acquisitions and relinquishment of rights, subject to their free, prior and informed consent and negotiated agreement.
Indicators: 7.6.1 Documented identification and assessment of legal and customary rights. Major compliance
Specific Guidance: Auditors to be aware of land acquisition in relation to native customary land.
7.6.2 Establishment of a system for identifying people entitled to compensation. Major compliance
7.6.3 This activity should be integrated with the SEIA required by C 7.1. Major compliance
7.6.4 Establishment of a system for calculating and distributing fair compensation (monetary or otherwise). Major compliance
7.6.5 The process and outcome of any compensation claims should be documented and made publicly available. Major compliance
7.6.6 Communities that have lost access and rights to land for plantation expansion are given opportunities to benefit from plantation development. Minor compliance
Guidance:
Refer also to C 2.2, 2.3 and 6.4 and associated guidance. This requirement includes indigenous peoples.
Specific National Guidance for Scheme and Independent Smallholders
Scheme Smallholders For Scheme and Group Managers, evidence may be in the form of letter of agreement from indigenous people and local communities, which is acknowledged or approved by the head of indigenous people/ village head or in accordance with local regulations. The area of relinquished rights should be mapped.
Independent Smallholders For Independent smallholders and smallgrowers, evidence may be in the form of letter of agreement from indigenous people and local communities, which is acknowledged or approved by the head of indigenous people/village head or in accordance with local regulations. See C7.5 above.
Findings:
The assessment team had verified that Principle 7 was not applicable to FGVPM-KCU.
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Criterion 7.7 Use of fire in the preparation of new plantings is avoided other than in specific cases as identified in the ASEAN Guidance or other regional best practice.
Indicators: 7.7.1 No evidence of clearing by burning. This activity should be integrated with the SEIA required by C 7.1 Major compliance
7.7.2 Evidence of approval for controlled burning, as per Environmental Quality (Declared Activities) (Open Burning) Order 2003. Major compliance
Specific National Guidance for Scheme and Independent Smallholders
Scheme Smallholders Scheme Managers should ensure that no open burning is being used to establish new plantings. Fire should be used only where an assessment has demonstrated that it is the most effective and least environmentally damaging option for minimising the risk of severe pest and disease outbreaks during the preparation of new plantings, and with evidence that fire-use is carefully controlled. Where such use of fire may be acceptable for example through reference to ‘Guidelines for the implementation of the ASEAN policy on zero burning’, or comparable guidelines in other locations.
Independent Smallholders Group managers must ensure that no fire is used to establish new plantings.
Fire should be used only where an assessment has demonstrated that it is the most effective and least environmentally damaging option for minimising the risk of severe pest and disease outbreaks during the preparation of new plantings, and with evidence that fire-use is carefully controlled
National interpretation should identify any specific situations where such use of fire may be acceptable, for example through reference to ‘Guidelines for the implementation of the ASEAN policy on zero burning’, or comparable guidelines in other locations
Findings:
The assessment team had verified that Principle 7 was not applicable to FGVPM-KCU.
PRINCIPLE 8: COMMITMENT TO CONTINUOUS IMPROVEMENT IN KEY AREAS OF ACTIVITY
Criterion 8.1 Growers and millers regularly monitor and review their activities and develop and implement action plans that allow demonstrable continuous improvement in key operations.
MY NIWG commits to demonstrate progressive improvement to the following but not limited to:
8.1.1 Minimise use of certain pesticides (C4.6) Major compliance
8.1.2 Environmental impacts (C5.1) Major compliance
8.1.3 Maximizing recycling and minimizing waste or by-products generation. Major compliance
Specific Guidance: To work towards zero-waste (C5.3)
8.1.4 Pollution prevention plans (C5.6) Major compliance
8.1.5 Social impacts (C6.1) MSC/RSPO/DOC/06-02 Issue 1 Rev. 0 Page 65 of 102 Major compliance
8.1.6 A mechanism to capture the performance and expenditure in social and environmental aspects. Minor compliance
Guidance: Specific minimum performance thresholds for key indicators should be established. (See also C 4.2, 4.3, 4.4, and 4.5).
Growers should have a system to improve practices in line with new information and techniques and a mechanism for disseminating this information throughout the workforce.
For smallholders, there should be systematic guidance and training for continuous improvement.
Specific National Guidance for Scheme and Independent Smallholders Scheme Smallholders Scheme Managers should develop an action plan for continual improvement in a participatory manner with their organized smallholder representatives, based on consideration of the main social and environmental impacts and opportunities for improvement.
Independent Smallholders Group managers must develop an action plan for continual improvement, developed in a participatory manner with group smallholders, based on a consideration of the main social and environmental impacts and opportunities of the smallholdings, and should include a range of indicators covered by these principles and criteria.
Findings: Generally, FGVPM-KCU had established a system to regularly monitor and review their key activities at the estates, and then initiate action plans for continuous improvement.
Evidences sighted include the commitment to minimize the use of certain pesticides like Paraquat and by implementing IPM. Paraquat use was controlled and selective. In Kahang Barat the use of Paraquat had reduced, 820 litres in 2010, 710 litres in 2011 and 610 litres in 2012. Other improvement plans include efforts to assess the social impacts and actions have been taken to minimize adverse impacts as well as to increase the awareness of workers on 3R’s initiatives (i.e. reduce, reuse, recycle) as part of their work and living culture.
The mill and estates also has plans to reduce environmental impacts as well as maximizing recycling and minimizing waste or by-products generation, as described under Criterion 5.1 and 5.3. The mills have documented environmental objectives which are reviewed annually. Achievement of objectives is monitored by respective personnel and reviewed during monthly meetings.
At the individual land scheme level, records maintained includes expenditure for social and environmental aspects, such as., allocations for JKKR and GPW allowances, donation fund for smallholders children, and Hari Raya incentives.
MSC/RSPO/DOC/06-02 Issue 1 Rev. 0 Page 66 of 102 RSPO Supply Chain Supply Standard 25 November 2011
5. General Chain of Custody System Requirements for the Supply Chain
5.2. Documented procedures 5.2.1. The facility shall have written procedures and/or work instructions to ensure the implementation of all the elements specified. This shall include at minimum the following:
- Complete and up to date procedures covering the implementation of all the elements in these requirements. - Complete and up to date records and reports that demonstrate compliance with these requirements. - The name of the person having overall responsibility for and authority over the implementation of these requirements and compliance with all applicable requirements. This person shall be able to demonstrate awareness of the facility’s procedures for the implementation of this standard.
Findings:
At the time of assessment, the Kahang Palm Oil Mill had not established the required documented procedures and/or work instructions to ensure implementation of all the elements specified for Module E – CPO Mill: Mass Balance. No such procedures and/or work instructions exist. Thus, a Major NCR MM3 was raised.
The SOP for RSPO SCCS Document No. FGVPM-RSPO SCCS, Issue No. 1, dated 1 December 2012 had been developed and submitted to the Assessor. It had been sighted and found acceptable and thus this NCR MM3 is considered closed. by FELDA Kahang POM management.
4.0 Comments from Stakeholder
Stakeholder consultations were conducted as part of the Stage 2 assessment. The summary of the comments from stakeholders is given in Attachment 5.
5.0 Assessment Recommendation
Based on the evidence gathered during the on-site visits it can be concluded that FELDA Kahang Certification Unit has conformed to the requirements of the RSPO Principles and Criteria for Sustainable Palm Oil Production, including smallholder, Malaysia National Interpretation Working Group (MYNIWG) November 2010.
Therefore, the assessment team recommends FELDA Kahang Certification Unit to be certified against RSPO Principles and Criteria for Sustainable Palm Oil Production, including smallholder, Malaysia National Interpretation Working Group (MYNIWG) November 2010.
MSC/RSPO/DOC/06-02 Issue 1 Rev. 0 Page 67 of 102
MSC/RSPO/DOC/06-02 Issue 1 Rev. 0 Page 68 of 102 Attachment 1
Time Bound Plan for Certification Units
No Mill complexes to be certified in the respective years
2009 2010 2011 2012 2013 2014 2015 2016 2017
1 K.Gelanggi Jengka 21 Adela Palong Timor Baiduri Ayu M. Puspita Selancar 2A Chalok Sampadi
2 L. Utara 6 Jengka 3 Lok Heng Triang Embara Budi N. Permata Selancar 2B J. Barat Aring A Kembara 3 Jengka 8 Semencu Belitong Tersang Pasoh J. Baru Aring B Sakti 4 L. Utara 4 Waha Bukit Besar L. Kemudi Besout Serting Kertih Ciku
5 Jengka 18 B. Kepayang Kahang Bukit Sagu Sg Tengi Serting Hilir F. Harapan Kechau A
6 Padang Piol Bukit Mendi Kulai Lepar Hilir Trolak Kerau H.Badai Kechau B
7 Segamat GC Kemasul Nitar Neram Keratong 2 Mempaga J.Bistari Kemahang
8 Tementi Penggeli Pancing Keratong 3 Maokil Kalabakan Cini 2
9 Keratong 9 Selendang Umas Cini 3
10 Tenggaroh
11 T.Timor
Total 2 7 8 8 8 9 11 9 9 Complexes
To date, FELDA has been on schedule with the time bound plan for the certification of all the CUs. SIRIM QAS International Sdn. Bhd. (SIRIM QAS International) is now involved with the certification of FELDA Kahang CU. MSC/RSPO/DOC/06-02 Issue 1 Rev. 0 Page 69 of 102 Attachment 2a
Kahang Complex Certification Unit
MSC/RSPO/DOC/06-02 Issue 1 Rev. 0 Page 70 of 102 Attachment 2b
Location Map for FELDA Kahang Certification Unit in Johor, Malaysia
FELDA Kahang Complex Certification Unit
1.Kahang Barat 2 Kahang Timur 3 Ulu Dengar
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Attachment 2c
FELDA Kahang Barat
MSC/RSPO/DOC/06-02 Issue 1 Rev. 0 Page 72 of 102 Attachment 2d
FELDA Kahang Timur
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Attachment 3
FELDA Ulu Dengar
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Attachment 3
RSPO MAIN ASSESSMENT PLAN
1. Objectives The objectives of the assessment are as follows: (i) To determine FELDA Global Ventures Plantations (Malaysia) Sdn.Bhd. – Kahang Palm Oil Mill Complex and Ulu Belitong Palm Oil Mill Complex conformance against the RSPO Principles & Criteria Malaysian National Interpretation (MY-NI). (ii) To make appropriate recommendations based on the assessment findings.
2. Date of assessment : 10 - 11 December 2012 (Kahang Palm Oil Mill Complex ) : 12 - 14 December 2012 (Belitong Palm Oil Mill Complex )
3. Site of assessment : FELDA Global Ventures Plantations (Malaysia) Sdn.Bhd. Kahang Palm Oil Mill Complex . Kahang Palm Oil Mill . FELDA Kahang Barat . FELDA Kahang Timur . FELDA Ulu Dengar
Belitong Palm Oil Mill Complex . Ulu Belitong Palm Oil Mill . FELDA Plantation Sdn. Bhd. Inas Selatan (Division B – Bukit Tongkah) . FELDA Bukit Tongkah . FELDA Ulu Belitong . FELDA Ulu Penggeli . FELDA Layang-Layang . FELDA Ayer Hitam . FELDA Bukit Permai 4. Reference Standard a. RSPO P&C MY-NI b. RSPO Supply Chain Certification Standard (25 November 2011) c. Company’s audit criteria including Company’s Manual/Procedures
5. Assessment Team a. Lead Assessor : Mahzan Munap b. Assessors : Dr Zahid Emby Khairul Najwan Selvasingam a/l Kandiah Hafriazhar There is any objection to the proposed audit team, the organization is required to inform the Lead Auditor/RSPO Section Manager.
5. Audit Witness : Nil
6. Audit Method Site audits including observation of practices, interviews with interested parties (employees, nearby population, etc.), documentation evaluation and evaluation of records.
7. Confidentiality Requirements SIRIM QAS International shall not disclose any information concerning the company regarding all matters arising or coming to its attention with the conduct of the programme, which is of confidential in nature other than information, which is in the public domain.
In the event that there be any legal requirements for disclosing any information concerning the organization, SIRIM QAS International shall inform the organization of the information to be disclosed.
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Attachment 3
8. Working Language : English and Bahasa Malaysia
9. Reporting a) Language : English b) Format : Verbal and written c) Expected date of issue : Thirty days after the date of assessment d) Distribution list : client file
10. Facilities Required
a. Room for discussion b. Relevant document and record c. Personnel protective equipment if required d. Photocopy facilities e. A guide for each assessor
11. Assessment Programme Details : As follows
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COMBINED ASSESSMENT PROGRAMME – KAHANG PALM OIL MILL COMPLEX AND ULU BELITONG PALM OIL MILL COMPLEX
Date: 10 December 2012 (Monday)
Time Activities / areas to be visited Auditee
8.00 am – Opening Meeting, - Combined opening meeting - Ulu Belitong Palm Oil Mill Complex and Kahang Palm Oil Mill Complex at Dewan JKKR Ulu 8.30 am Dengar. Audit team introduction and briefing on assessment objective, scope, methodology, criteria and programmes by SIRIM QAS Audit Team Leader
8.30 am – Briefing on the organization background and implementation of RSPO at Ulu Belitong Palm Oil Mill Complex and at FELDA Kahang Palm Oil Management 9.20 am Mill Complex Certification Unit by the respective FELDA Management Representative, e.g. representative Significant changes on organization activities, machinery, supply bases capacity, etc. Issue raised from interested party or stakeholder Areas of HCV interest and replanting program No. of settlers and area that are Koperasi/FTP managed vs. Self-farming
9.20 am – Travel to FELDA Ulu Dengar, FELDA Kahang Barat and FELDA Kahang Palm Oil Mill. Overview of current activities at FELDA Ulu Dengar, Plantation / 1.00 pm FELDA Kahang Barat and FELDA Kahang Palm Oil Mill by the respective Site Manager. Mill Manager Mahzan Selvasingam Hafriazhar KhairulNajwan Dr Zahid
Site visit and Site visit and Site visit and Site visit and Site visit and assessme Guide for each assessment at FELDA assessment at FELDA assessment at FELDA assessment at FELDA nt at FELDA Kahang Assessor Ulu Dengar. Kahang Barat. Kahang Palm Oil Mill. Ulu Dengar. Barat.
Coverage of assessment : Coverage of assessment : Coverage of assessment : Coverage of assessment : Coverage of assessment : P1, P2 (C2.1), P3, P4 P2 (C2.2.2), P3, P4 (C4.1 P1(C1.2), P2, (C2.1), P3, P2, (C2.1, I2.2.3), P3, P4 P1(C1.2) P2(C2.1 - C2.3), (C4.1, C4.7, C4.8), P8 - C4.6, C4.8), P5 (C5.1), P4 (C4.1, C4.8), P5(C5.1, (C4.1, C4.3, C4.4, C4.8), P3, P6 (C6.1 C6.11), P7(C7.2, C7.4, C7.7), P8 C5.3 – C5.5), P6(C6.11), C5.2, P7(C7.2 – C7.4), P7(C7.1, C7.4, C7.5, View documentation and P7(C7.1, C7.7), P8 P8 C7.6), P8 records relating to OSH View documentation and Management System records relating to Estate View documentation and View documentation and View documentation and management records relating to EIA records relating to estates records relating to local Witness activities & and management plan boundary, HCV and community and assessment at site i.e. Nursery (if any) management plan indigenous peoples
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(weeding/ spraying/ Good Agricultural Facilities at workplace Conservation area issues such as EIA, SIA harvesting/ other Practice (laboratory, water management and management plans maintenance Witness activities & treatment plant, Area of more than 25o Complaints and activities) assessment at site clinic, ETP, boiler, Inspection of protected grievances Facilities at workplace (weeding/ harvesting/ chimney, gensets, sites with HCV Land title user rights (water treatment plant, other maintenance chemical store, etc) attributes Negotiations and clinic, gensets, activities) Recycling activities Plantation Boundary dispute resolution chemical store, IPM implementation, Commitment to and land use by Consultation with fertilizer store, etc) training and sage use transparency neighbour relevant government Chemical store – of agrochemicals. Laws and regulations Forested area agencies, if applicable settler and EFB mulching Training Riparian Zone Commitment to to Technoplant / fertilizer Riparian Zone Continuous Water bodies long-term economic Workshop River system Improvement Plan Source of water and financial viability Commitment to including POME supply transparency. transparency discharge Other areas identified River system including Laws and regulations Laws and regulations Plantation on during the assessment. POME discharge Interviews with Emergency hilly/swampy area Plantation on selected staff/workers preparedness and Waste management hilly/swampy area such as sprayers, response. at field and line site Interview with general workers, Training Chemical store - stakeholders and chemical mixing etc, Interview OSH settler and relevant government Administration staff, Committee, chemical Technoplant / fertilizer agencies, if applicable GPW, JKKrR, Belia, handlers, workers and Workshop Commitment to Koperasi FELDA dependents (related to Training transparency Kahang, Pekebun Safety and Health, Laws and regulations Kecil & interested Environment, Social Training parties and welfare) Equal Opportunity, Sexual harassment and violence at workplace. Facilities at workplace (surau, rest area, canteen, etc) Local sustainable development 1.00 – LUNCH BREAK and SHOLAT All 2.00pm 2.00 – 5.30 Commitment to long- Commitment to Continue with unfinished Continue with unfinished Facilities provided at Guide for each
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Attachment 3 pm term economic and transparency elements. elements living quarters (i.e. Assessor financial viability Laws and regulations surau, community Continuous Commitment to long- Site visit FELDA Other area identified center, provision shop Improvement Plan term economic and Kahang Barat during the assessment &etc) financial viability Visit and discussion Site visit and Continuous Coverage of assessment : with Pengurus assessment FASSB Improvement Plan P1(C1.2), P2, (C2.1), P3, Rancangan, Pengurus Belitong P4 (C4.1, C4.8), P5(C5.1, Komuniti and C5.3 – C5.5), P6(C6.11), Community Leaders Coverage of assessment : P7(C7.1, C7.7), P8 (CSR, community P1, P2 (C2.1), P3, P4 affairs), workers and (C4.1, C4.7, C4.8), P8 View documentation and dependents at line records relating to EIA site, surrounding local, View documentation and and management plan indigenous people records relating to OSH issues on EIA, SIA Management System Waste management and management at estate, line site and plan. Good Agricultural dump site. Practice Recycling activities Witness activities & EFB mulching, POME assessment at site i.e. application (weeding/ spraying/ Facilities at workplace harvesting/ Replanting (water sampling point, other maintenance water treatment plant, activities) gensets, chemical / Waste Management fertilizer store, etc) Training Laws and regulations IPM implementation, Commitment to long- training and sage use term economic and of agrochemicals financial viability Commitments to Training transparency Continuous , Continuous improvement improvement Other areas identified during the assessment
Date: 11 December 2012 (Tuesday)
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Time Activities / areas to be visited Auditee
7.30 a.m. Travel to FELDA Ulu Dengar, FELDA Kahang Barat and FELDA Kahang Palm Oil Mill. Overview of current activities at FELDA Ulu Dengar, Plantation / – 9.00 FELDA Kahang Barat and FELDA Kahang Palm Oil Mill by the respective Site Manager. Mill a.m. Manager Mahzan Selvasingam Hafriazhar KhairulNajwan Dr. Zahid 9.00 a.m – Site visit and Site visit and Site visit and Site visit and Site visit and Guide(s) for 1.00 p.m assessment at FELDA assessment at FELDA assessment at FASSB assessment at FELDA assessment at FELDA each Kahang Palm Oil Mill Ulu Dengar Belitong Kahang Barat Ulu Dengar assessor
Coverage of assessment : Coverage of assessment : Coverage of assessment : Coverage of assessment : Coverage of assessment : P1, P2 (C2.1), P3, P4 P2 (C2.2.2), P3, P4 (C4.1 P1(C1.2), P2, (C2.1), P3, P2, (C2.1, I2.2.3), P3, P4 P1(C1.2) P2(C2.1 - C2.3), (C4.1, C4.7, C4.8), P8, - C4.6, C4.8), P5 (C5.1), P4 (C4.1, C4.8), P5(C5.1, (C4.1, C4.3, C4.4, C4.8), P3, P6 (C6.1 C6.11), Modular Requirements – P7(C7.2, C7.4, C7.7), P8 C5.3 – C5.5), P6(C6.11), C5.2, P7(C7.2 – C7.4), P8 P7(C7.1, C7.4, C7.5, Module E- CPO Mill – P7(C7.1, C7.7), P8 C7.6), P8 Mass Balance View documentation and View documentation and records relating to Estate View documentation and records relating to estates View documentation and View documentation and management records relating to EIA boundary, HCV and records relating to local records relating to OSH and management plan management plan community and Management System indigenous peoples Good Agricultural Conservation area issues such as EIA, SIA Practice Aspects/impacts of Commitment to management and management plans Witness activities & plantation transparency Area of more than 25o assessment at site Site visit and Commitment to long- Inspection of protected Interviews with (weeding/ harvesting/ assess water sampling term economic and sites with HCV selected staff/workers other maintenance point, water treatment financial viability attributes & interested parties activities) plant, chemical / Safety & Health Visit and discussion .EFB mulching fertilizer store Plantation Boundary practices – witness and land use by with Pengurus Riparian Zone Laws and activities at site neighbour Rancangan, Pengurus River system regulations Hazard Identification Forested area Komuniti, Community including POME Waste Management at and Risk Management Leaders (CSR, discharge estate, line site and Riparian Zone Laws and regulations community affairs), Plantation on dump site Water bodies Chemical dependents at line hilly/swampy area Recycling Source of water management site, surrounding local Waste management activities supply Interview with workers community issues on at field and line site Pollution Plantation on such as Chemical EIA, SIA and Chemical store - mitigating plans hilly/swampy area handler, safety management plan. settler and Commitment to Interview with committee and Facilities at workplace Technoplant / fertilizer long-term economic stakeholders and
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contractors. Workshop and financial viability relevant government (surau, rest area, Training Training agencies, if applicable canteen, etc) Other area identified IPM implementation, Continuous Commitment to Facilities provided at during the assessment training and sage use improvement transparency living quarters (i.e. surau, community of agrochemicals Laws and regulations Training center, Tadika, Replanting Other area identified provision shop & etc) during the assessment Continuous Commitment to long- Consultation with Improvement Plan term economic and relevant government Site visit and financial viability agencies, if applicable assessment at FELDA Continuous Commitment to to Ulu Dengar Improvement Plan long-term economic and financial viability Coverage of assessment : Other area identified transparency, and P1(C1.2), P2, (C2.1), P3, during the assessment Laws and regulations P4 (C4.1, C4.8), P5(C5.1, C5.3 – C5.5), P6(C6.11), P7(C7.1, C7.7), P8 Other area identified during the assessment View documentation and records relating to EIA and management plan
Aspects/impacts of plantation Site visit and assess water sampling point, water treatment plant, fertilizer store
1.00 – LUNCH BREAK and SHOLAT All 2.00pm 2.00 pm – Training Continue with unfinished Laws and regulations Continue with unfinished Site visit and 5.30 pm Emergency elements Waste Management at elements assessment at FELDA Guide(s) for Kahang Palm Oil Mill each preparedness and estate, line site and response dump site assessor Site visit and Other area identified Local sustainable Recycling activities Coverage of assessment : assessment at FASSB during the assessment development Belitong Pollution mitigating P1(C1.2) P2(C2.1 - C2.3),
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Continuous plans P3, P6 (C6.1 C6.11), improvement Coverage of assessment : Commitment to long- P7(C7.1, C7.4, C7.5, term economic and C7.6), P8 RSPO SCCS P2 (C2.2.2), P3, P4 (C4.1 - C4.6, C4.8), P5 (C5.1), financial viability P7(C7.2, C7.4, C7.7), P8 RFB Mulching, POME View documentation and application records relating to local View documentation and Training community and records relating to Continuous indigenous peoples Nursery and R&D improvement issues such as EIA, SIA and management plans management
Other area identified Interviews with Good Agricultural during the assessment Practice selected staff/workers, Witness activities & FFB Suppliers, assessment at site contractors, gender (weeding/ spraying/ representatives & harvesting/ interested parties Replanting/ other Laws and regulation maintenance Workers issues activities) Facilities at workplace Waste management (rest area, etc) .Training Line site Continuous IPM implementation, improvement training and sage use
of agrochemicals Commitment to long- Other area identified term economic and during the assessment financial viability Continuous Improvement Plan
Other area identified during the assessment
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Date: 12 December 2012 (Wednesday)
Time Activities / areas to be visited Auditee
7.30 am – Travel to FELDA Plantation Inas Selatan (Div B – Bukit Tongkat), FELDA Bukit Tongkat and FELDA Palm Oil Mill Ulu Belitong. Plantation / 8.30 am Overview of current activities at respective site visited by Plantation / Mill Manager. Mill Manager
Mahzan Selvasingam Hafriazhar Khairul Najwan Dr Zahid
8,45 am – Site visit and Site visit and Site visit and Site visit and Site visit and Guide for 1.00 pm assessment at FELDA assessment at assessment at FELDA assessment at FELDA assessment at, each Plantation Inas FELDA Plantation Inas Ulu Belitong Palm Oil Bukit Tongkat FELDA Plantation Inas Assessor Selatan (Div B – Bukit Selatan (Div B – Bukit Mill Selatan (Div B – Bukit Tongkat) Tongkat) Coverage of Tongkat) Coverage of assessment: Coverage of Coverage of assessment: P2 (C2.1, I2.2.3), P3, Coverage of assessment: assessment: P1(C1.2), P2 (C2.1), P4 (C4.1, C4.3, C4.4, assessment: P1(C1.2), P1, P2,(C2.1), P3, P4 P2 (C2.2.2), P3, P4 P3, P4 (C4.1, C4.8), C4.8), C5.2, P7 (C7.2 - P2(C2.1- C2.3), P3, P6 (C4.1, C4.7, C4.8), P8 (C4.1 -C4.6, C4.8), P5 P5(C5.1,C5.3-C5.6), C7.4), P8 (C6.1 – C6.11), P7 (C5.1), ,P7 (C7.2, C7.4, P6(C6.11), P7(C7.1, (C7.1, C7.4, C7.5, View documentation C7.7), P8 C7.7), P8 View documentation C7.6), P8 and records relating to and records relating to OSH Management View documentation View documentation estates boundary, HCV View documentation System and records relating to and records relating to and management plan and records relating to Estate management EIA and management local community issues Witness activities & plan Conservation such as EIA, SIA and assessment at site Nursery (if any) Facilities at area management management plans i.e. (weeding/ Good Agricultural workplace Area of more spraying/ Practice (laboratory, water than 25o Complaints and harvesting/ other Witness activities & treatment plant, ETP, Inspection of grievances maintenance assessment at site boiler, chimney, protected sites with Land titles user activities) (weeding/ gensets, chemical HCV attributes rights Facilities at harvesting/ other store, etc) Plantation Boundary Consultation with workplace (water maintenance Recycling activities and land use by relevant government treatment plant, activities) Commitment to neighbour agencies, if clinic, gensets, IPM implementation, transparency Forested area applicable chemical store, training and safe Laws and regulations Riparian Zone Laws and
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fertilizer store, etc) use of agro- Training Water bodies regulations Chemical store – chemicals. Continuous Source of water Interviews with settler and EFB mulching Improvement Plan supply Administration staff Technoplant / Riparian Zone River system workers (sprayers, fertilizer River system Other area identified including POME harvesters, general Workshop including POME during the assessment discharge workers, etc,), GPW, Commitment to discharge Plantation on Settlers, JKKR, transparency Plantation on hilly/swampy area Belia, Koperasi Laws and hilly/swampy area Interview with FELDA Layang- regulations Waste management stakeholders and Layang, Pekebun Emergency at field and line site relevant government Kecil & interested preparedness and Chemical store – agencies, if parties response, settler and applicable Equal Opportunity, Training Technoplant / Commitment to Sexual harassment Interview OSH fertilizer transparency and violence at Committee such as Workshop Laws and workplace chemical handlers, Training regulations implementation. workers and Training Facilities at dependents (related Continue with workplace (surau, to Safety and unfinished elements rest area, canteen, Health, etc) Environment, Social Local sustainable and welfare) development Commitment to Visit and discussion long-term economic Pengurus and financial viability Rancangan, Continuous Pengurus Komuniti Improvement Plan and Community Leaders (CSR, community affairs), workers and dependents at line site, surrounding local, community issues on EIA, SIA and management plan.
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1.00 – LUNCH BREAK and SHOLAT All 2.00pm 2.00 – 5.30 Site visit and Commitment to Continue with Site visit and Site visit and Guide for pm assessment FELDA transparency unfinished elements. assessment at FELDA assessment at, each Layang-Layang Laws and Plantation Inas (Div B FELDA Layang- Assessor regulations Site visti FELDA - Bukit Tongkat) Layang Coverage of Commitment to Bukit Tongkat assessment: long-term economic Coverage of Coverage of P1, P2,(C2.1), P3, P4 and financial viability Coverage of assessment: assessment: P1(C1.2), (C4.1, C4.7, C4.8), P8 Continuous assessment: P2 (C2.1, I2.2.3), P3, P2(C2.1- C2.3), P3, P6 Improvement Plan P1(C1.2), P2 (C2.1), P4 (C4.1, C4.3, C4.4, (C6.1 – C6.11), P7 View documentation P3, P4 (C4.1, C4.8), C4.8), C5.2, P7 (C7.2 - (C7.1, C7.4, C7.5,
and records relating to P5(C5.1,C5.3-C5.6), C7.4), P8 C7.6), P8 OSH Management P6(C6.11), P7(C7.1, C7.7), P8 View documentation View documentation Witness activities & and records relating to and records relating to assessment at site View documentation estates boundary, HCV local community issues (weeding / spraying and records relating to and management plan such as EIA, SIA and / harvesting/ EIA and management management plans Replanting / other plan Conservation maintenance Waste Management area management Complaints and activities) at estate, line site and Area of more grievances Facilities at dump site than 25o Land titles user workplace (water Recycling activities Inspection of rights treatment plant, EFB mulching, protected sites with Consultation with clinic, gensets, POME application HCV attributes relevant government chemical store, Facilities at Plantation Boundary agencies, if fertilizer store, etc) workplace (water and land use by applicable Chemical store – sampling point, water neighbour Laws and settler and treatment plant, Forested area regulations Technoplant / gensets, chemical / Riparian Zone Interviews with fertilizer fertilizer store, etc.) Water bodies Administration staff Workshop Laws and Source of water workers (sprayers, Commitment to regulations supply harvesters, general transparency Commitment to long- River system workers, etc,), GPW, Laws and term economic and including POME Settlers, JKKR, regulations financial viability discharge Belia, Koperasi Emergency Training Plantation on FELDA Layang-
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preparedness and Continuous hilly/swampy area Layang, Pekebun response, improvement Interview with Kecil & interested Training stakeholders and parties Interview OSH relevant government Equal Opportunity, Committee such as agencies, if Sexual harassment chemical handlers, applicable and violence at workers and Commitment to workplace dependents (related transparency implementation. to Safety and Laws and Facilities at Health, regulations workplace Environment, Social Training Local sustainable and welfare) Continue with development Commitment to unfinished elements Visit and discussion long-term economic Pengurus and financial viability Rancangan, Continuous Pengurus Komuniti Improvement Plan and Community Leaders (CSR, community affairs), workers and dependents at line site, surrounding local community issues on EIA, SIA and management plan.
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Date: 13 December 2012 (Thursday)
Time Activities / areas to be visited Auditee
8.00 a.m. – Travel to FELDA Bukit Tongkat, FELDA Layang-Layang and FELDA Ulu Belitong Palm Oil Mill Overview of current activities at Plantation / 9.00 a.m. respective site visited by Plantation / Mill Manager. Mill Manager
Mahzan Selvasingam Hafriazhar Khairul Najwan Dr. Zahid 9.00 a.m – FELDA Ulu Belitong Site visit and Site visit and Site visit and Site visit and 1.00 p.m Palm Oil Mull assessment at FELDA assessment at assessment at FELDA assessment at Bukit Tongkat FELDA Plantation Inas Layang-Layang FELDA Bukit Tongkat Guide(s) for Coverage of Selatan (Div B – Bukit each assessment: Coverage of Tongkat) Coverage of Coverage of assessor P1, P2,(C2.1), P3, P4 assessment: assessment: assessment: P1(C1.2), (C4.1, C4.7, C4.8), P8, P2 (C2.2.2), P3, P4 Coverage of P2 (C2.1, I2.2.3), P3, P4 P2(C2.1- C2.3), P3, P6 Modular Requirements (C4.1 -C4.6, C4.8), P5 assessment: (C4.1, C4.3, C4.4, (C6.1 – C6.11), P7 - Module E _ CPO Mill (C5.1), ,P7 (C7.2, C7.4, P1(C1.2), P2 (C2.1), P3, C4.8), C5.2, P7 (C7.2 - (C7.1, C7.4, C7.5, – Mass Balance C7.7), P8 P4 (C4.1, C4.8), C7.4), P8 C7.6), P8 P5(C5.1,C5.3-C5.6), View documentation View documentation P6(C6.11), P7(C7.1, View documentation and View documentation and records relating to and records relating to C7.7), P8 records relating to and records relating to OSH Management Estate management estates boundary, HCV local community and View documentation and and management plan indigenous peoples Commitments to Good Agricultural records relating to EIA issues such as EIA, SIA transparency Practice and management plan Conservation area and management plans Commitment to long- Witness activities & management o term economic and assessment at site Facilities at Area of more than 25 Interviews with financial viability (weeding/ spraying/ workplace (water Inspection of selected Safety & Health harvesting/ other treatment plant, protected sites with staff/workers such as practice – witness maintenance clinic, gensets, HCV attributes sprayers, general activities at site activities) chemical store, Plantation Boundary workers, chemical Hazard identification EFB mulching fertilizer store, etc) and land use by mixing etc, Administration staff, and Risk Riparian Zone Recycling activities neighbour Union members & Management River system Waste Management Forested area interested parties Laws and regulations including POME at estate, line site Riparian Zone Visit and discussion Chemical discharge and dump site Water bodies with management management Plantation on Commitment to Source of water Interview with workers (CSR, community
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such as chemical hilly/swampy area transparency supply affairs), workers and handler, safety Waste management Laws and River system dependents at line committee and at field and line site regulations including POME site, surrounding contractors Chemical Training discharge local community Training store/fertilizer Continuous Plantation on issues on EIA, SIA Emergency Estate Workshop Improvement Plan hilly/swampy area and management plan. preparedness and Commitment to Interview with response, transparency stakeholders and Facilities at Local sustainable Laws and relevant government workplace (surau, development regulations agencies, if rest area, canteen, Continuous Commitment to applicable etc) improvement long-term economic Laws and Facilities provided at RSPO SCC and financial regulations living quarters (i.e. viability Training surau, community Continuous center, provision Improvement Plan shop &etc) Consultation with
relevant government agencies, if applicable Commitment to to long-term economic and financial viability transparency, and Laws and regulations
1.00 – LUNCH BREAK and SHOLAT All 2.00pm 2.00 pm – Site visit and Site visit and Continue assessment Site visit and 5.30 pm assessment at FELDA assessment at assessment Ulu Guide(s) for Other area identified Layang-Layang FELDA Layang- Belitong Palm Oil Mill each during the assessment Layang assessor
Coverage of Coverage of Continue assessment assessment: Coverage of assessment: P1(C1.2), P2 (C2.2.2), P3, P4 assessment: P2(C2.1- C2.3), P3, P6 (C4.1 -C4.6, C4.8), P5 P1(C1.2), P2 (C2.1), (C6.1 – C6.11), P7 (C5.1), ,P7 (C7.2, C7.4, P3, P4 (C4.1, C4.8), (C7.1, C7.4, C7.5,
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C7.7), P8 P5(C5.1,C5.3-C5.6), C7.6), P8 P6(C6.11), P7(C7.1, Good Agricultural C7.7), P8 View documentation Practice and records relating to Witness activities & View documentation local community issues assessment at site and records relating to such as EIA, SIA and (weeding/ spraying/ EIA and management management plans harvesting/ other plan maintenance Interviews with activities) Facilities at selected staff/workers, EFB mulching workplace (water FFB suppliers, Riparian Zone treatment plant, contractors, gender River system clinic, gensets, representatives & including POME chemical store, interested parties discharge fertilizer store, etc) Laws and regulations Plantation on Recycling activities Workers Issues hilly/swampy area Waste Management Facilities at workplace Waste management at estate, line site (rest area, etc) at field and line site and dump site Line site Chemical Commitment to Continuous store/fertilizer transparency improvement Estate Workshop Laws and regulations Commitment to Other area identified Training transparency during the assessment Laws and Continuous
regulations Improvement Plan Commitment to long-term economic and financial viability Continuous Improvement Plan
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Date : 14 December 2012 (Friday)
Time Activities / areas to be visited Auditee
8.00 a.m. – Travel to Dewan JKKR Ulu Belitong 8.30 a.m. Representative of FELDA Certification Unit – Ulu Belitong Palm Oil Mill Complex and FELDA Kahang Palm Oil Mill Complex Certification Unit Mahzan Selvasingam Hafriazhar KhairulNajwan Dr Zahid 8.30 a.m. – Continue with Continue with Continue with Continue with Continue with 12.00 p.m. unfinished elements unfinished elements unfinished elements unfinished elements unfinished elements
Verification on outstanding issues for,FELDA Certification Unit – Ulu Belitong Palm Oil Mill Complex and FELDA Kahang Palm All Auditore Oil Mill Complex Certification Unit
Assessor to inform auditee on the required document / records
12.00 p.m. – LUNCH BREAK and SHOLAT All 2.30 p.m 2.30 p.m. – 3.30 p.m. Continue Audit Team discussion and preparation of assessment findings. All Auditors
3.30 p.m. – Discussion and acceptance on assessment findings FELDA Ulu Belitong Palm Oil Mill Complex and FELDA Kahang Palm Oil Auditors, Mill 4.30 p.m. Mill Complex Certification Unit and Plantation Managers 4.30 pm – Closing meeting - presentation of FELDA Certification Unit – Ulu Belitong Palm Oil Mill Complex and FELDA Kahang Palm Oil 5.00 pm All Mill Complex Certification Unit
5.00 pm End of assessment All
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LIST AND COMMENTS FROM STAKEHOLDER
List of Stakeholders Comment highlighted* Verification A : Government Agencies/Service Provider District and Land Office, District of Kluang No issue None The Department of Labor, Johor Bahru No issue None The Forestry Department, District of Kluang No comment None The Police Headquarters, District of Kluang No issue None Malaysian Palm Oil Board, Research Station, No issue None Kluang Malaysian Palm Oil Board, Kluang Branch No issue None Malaysian Palm Oil Board, Bandar Tenggara No issue None GiatMara, Sembrong No issue None GiatMara, District of Kluang No comment None The Public Works Department, District of Kluang No issue None The Department of Wildlife and National Park, Conservation of buffer zone, slope and water catchment District of Kluang areas to be protected. Verify during the audit Use of pesticide in the estate operation Financial allocation for conservation activities The Fire and Rescue Station, District of Kluang No comment None The Office of Municipal Council, District of Kluang No comment None The Education Office, District of Kluang No issue None The Department of Agricultural, District of Kluang No comment None The Department of Community Development, Specific plan on Wildlife Management and Biodiversity On-going Johor Conservation be developed The Department of Social Welfare, District of No issue None
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Kluang The Department of Youth and Sports, District of No issue None Kluang The Office of Islamic Religion, District of Kluang No issue None The (Rubber Industry Smallholders Development No issue None Authority) RISDA Office, District of Kluang The Religious Education Department, District of No issue None Kluang The Office of Veterinary Services, District of No issue None Kluang TNB Distribution Sdn Bhd, District of Kluang No issue None Department of Environment (DOE), District of No issue None Kluang The Malayan Railway Berhad, District of Kluang No issue None The Department of Aboriginal Affairs, District of No issue None Kluang The Department of Occupational, Safety and Incompliance with Occupational Safety and Health Act 1994 Verify during the Health, Johor Bahru and Factory and Machineries Act 1967 conduct of audit The Immigration Office, Kluang. No issue None The Royal Customs Office, Kluang No comment None The Meteorological Department Office, District of No issue None Kluang The Federal Agricultural and Marketing Authority No issue None (FAMA) Office, District of Kluang The Water Supply Department, District of Kluang No issue None Employees Provident Fund, Kluang No issue None The District Office, District of Kulaijaya Where can one get information on RSPO? Answer was at
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FELDA website The Land Office, District of Kulaijaya No issue None The Biotechnology and Biodiversity Corporation, No issue None Johor The Department of Tourism, Johor No issue None SIRIM Berhad, South Region, Johor No issue None The Royal Malaysian 33rd Artillery Regiment, Kem No issue None Mahakota, Kluang FELCRA Berhad, Wilayah Sedenak No issue None B. External Stakeholders Ladang Sungai Yong No issue None Sime Darby Plantations, Ladang Cenas No issue None Renggo Malay Estate Sdn Bhd No issue None Permodalan Pelangi Sdn Bhd., Ladang Pelangi No issue None Ladang Sindora, Kluang No issue None SAJ Holdings Sdn Bhd No issue None C. Internal Stakeholders Manager, FELDA Layang-Layang, Kluang No issue None Manager FELDA Kahang Barat, Kluang No issue None Manager, FELDA Ulu Dengar, Kluang No issue None Manager FELDA Bukit Batu, Kluang No issue None Manager, FELDA Bukit Tongkat, Kluang No issue None Manager, FELDA Ayer Hitam, Kluang No issue None Manager, FELDA Ulu Penggeli, Kluang No issue None
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Manager, FELDA Ulu Belitong, Kluang No issue None Manager, FELDA Nitar 1, Mersing No issue None Manager FELDA Nitar 2, Mersing No issue None Manager, FELDA Nitar Timur, Mersing No issue None Manager FELDA Segamat Region No issue None Agronomist, FELDA Agriculture Services Sdn Bhd No issue None Manager, FELDA Technoplant Sdn Bhd, Segamat No issue None Region Manager, FELDA Technoplant Sdn Bhd, Kahang No issue None Barat Manager, FELDA Technoplant Sdn Bhd, Ulu No issue None Dengar Mill Manager, FELDA Palm Industries Sdn Bhd., No issue None Belitong Palm Oil Mil Mill Manager, FELDA Palm Industries Sdn Bhd., No issue None Kahang Palm Oil Mill D : Local Communities Ibrahim Bin Ali No issue None Hj Mohd Anuar Bin Zakaria No issue None Akob Bin Sedek No issue None Shahrin Bin Omar No issue None Mujahid B Abdul Wahab No issue None Hj Abdul Karim Bin Abu Bakar No issue None Roszila Bt Mat Salleh No issue None E : Other interested parties
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FELDA Plantations Inas Selatan, Division B – No issue None workers representatives FELDA Plantations Inas Selatan, Division B – No issue None sprayer FELDA Plantations Inas Selatan, Division B – No issue None chemical store operator FELDA Plantations Inas Selatan, Division B – FFB No issue None harvesters FELDA Plantations Inas Selatan, Division B – No issue None safety & health committee member FELDA Bukit Tongkat – workers representatives No issue None FELDA Bukit Tongkate – female representatives No issue None FELDA Bukit Tongkat – chemical handler No issue None FELDA Bukit Tongkat – office staff representatives Which of the two Government Department, Forestry of None required. District Land Office is responsible for Forest and forest Answer given was boundary forest under forest department while forest boundary is the jurisdiction of District Land Office. FELDA Belitong POM – safety & health committee No issue None member FELDA Belitong POM – production operator No issue None FELDA Belitong POM – female representative No issue None FFB suppliers No issue None
* No issues means that no response received to the letters sent. Upon and following up, there was still no response * No comment means that no response received during attendance of stakeholders’ consultation meeting or no response received to the letters sent. Upon following up, the stakeholder informed that they did not have any comment.
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Attachment 6
DETAIL OF NON CONFORMITY AND CORRECTIVE ACTIONS TAKEN
P & C, Classification Detail Non conformance Corrective Action Taken Verification by Assessor Indicators Major / Minor Major 1. The Fire Certificate (Fire Services Act 1. Mill did not include in the register The exemption letter requiring a Fire Indicator 2.1.1 1988) had not been identified in the legal because exemption had been given. To Certificate issued by BOMAB had (MM01) register and the mill does not have a Fire obtain the exemption letter given by been sighted and found acceptable. Certificate. BOMBA. 2. CHRA report as required under USECHH 2. Plantation Management unaware that The contractors (Bumi Permas and Regulations 2000 for contactor sprayers Contractor is part of their extended Zainal Maulani) CHRA Report had (working on behalf of FTP at Ulu Dengar) employee as per OSHA 1994. To inform been submitted and found adequate. was not available as it had not been Bumi Permas and Zainal Maulani the conducted. requirement of CHRA Report under Status of NCR: Closed. USECHH Regulations 2000 and to get them abide by this requirement by getting them engage a CHRA Assessor. Subsequently a warning letter was issued to them for disregarding the requirement.
Indicator I 4.3.1 Minor Road Maintenance – Many Roads in both Poor planning and limited budget. Road Road Maintenance program, (STK01) Kahang Barat and in Ulu Dengar were badly maintenance to be carried out in 2013. photographs of road maintenance eroded making it very difficult for vehicles to Frond stacking training to be carried in Jan and signed list of participants maneuver . A cattle trap in the 2012 replant in & Feb 2013. attending training conducted Ulu Dengar was filled with soil due to erosion. received. Stacking on Fronds – It was observed pruned fronds were stacked along the slope and not Status of NCR: Closed. against the slope, as stated Manual Operasi Ladang Sawit Lestari , in Kahang Barat.
Indicator 4.4.1 Major Protection of water courses and wetlands, Information and training for spraying and The training records such as training (NAJ-1) including maintaining and restoring appropriate maintain buffer zone had not been identified. attendance, slide presentation, riparian buffer zones along all natural Training awareness on HCV and action plan picture of implementation, including waterways within the estate was not on buffer zone has been conducted on 14th signboard and boundary mark has maintained. February 2013 to all related workers, staff been given to auditor. The and contractors at FELDA Kahang Barat. implementation need to be verified During the site review at FELDA Ulu Dengar during the next audit. and FELDA Kahang Barat it was found the FELDA Ulu Dengar also has taken same buffer zone along Sg Belumut and Sg Janoh action by conducting awareness training on Status of NCR: Closed. respectively was not maintained; 15th January 2013. The workers have been • spraying activities/ trace has been found reminded to not conduct any activities in
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along the buffer zone buffer zone including spraying and • boundary mark for buffer zone was not manuring. The monitoring also has been clearly demarcated along the riverside planned every 2 weeks to monitor the buffer zone.
Indicator 4.6.10 Minor The usage of pesticides used has been The required figures have been complied The calculation of Active Ingredient/ (STK02) recorded and monitored in Field Cost Books. and maintained. Hectare has been correctly Total amounts/quantity of pesticides used was computed. available in both Kahang Barat and Ulu Dengar. Records of usage, including active Status of NCR: Closed. ingredients used, area treated, amount applied per ha and number of applications were not maintained.
Indicator 4.8.1 Major No training programme that includes regular Training needs identification had not been Training program, signed attendance (MM02) assessment of training needs and implemented extensively and those training list and photographs had been documentation, including records of training for courses held were prioritized. submitted to assessor. They are the following had been conducted: The following training had been conducted acceptable and thus status of NCR is 1. RSPO SCCS on 26 February 2013 for Closed. 1. RSPO Supply Chain Certification related Mil personnel. Standard at Kahang POM. (SCCS 2. RSPO Awareness on 11/01/13, EIA Criterion 5.7) ,and HIRADC on 16/01/13, HCV on 25/01/13 and SIA on 01/02/13 for staff, 2. Environmental emergency response drill smallholders, workers and contractor. such as major CPO spillage, collapse of ETP bund, etc at Kahang POM.
3. (a) Environmental aspect and impact identification / assessment, (b) Hazard Identification, Risk Assessment and Determining Control, and (c) Legal Awareness and Compliance for operational staff and settlers at the estates.
4. HCV monitoring course (for Kahang Barat and Ulu Dengar).
5. RSPO Awareness for contractors (Sykt Zainal Maulani and Sykt Bumi Permas).
SCCS 2011 Major The Kahang POM had not established the Procedure developed by head office was not Sighted the SOP sent and found Criterion 5.2 required written procedures and/or work disseminated to POM in time before the acceptable meeting the requirements Module E instructions for Module E – CPO Mill: Mass RSPO audit. The SOP for RSPO SCCS of SCCS of 5.2.1 of Module E – CPO
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(M03) Balance Document No. FGVPM-RSPO SCCS, Issue Mill. – No. 1, dated 1 December 2012 had been developed and approved by management. Status of NCR: Closed.
A procedure for identifying legal and The said procedure (Perundingan Hak The procedure and the file created Indicator 6.4.1 Major customary rights had not been developed. Perundangan dan Hak Adat) had been had been submitted to the auditor (ZE01) developed. There was no issue with all and found acceptable. Status of NCR stakeholders to date. (ZE01) Closed.
A procedure for calculating and distributing There was no issue with all stakeholders to The procedure had been submitted to Indicator 6.4.2 Minor compensation had not been developed. date and therefore the need was not there. the auditor and found acceptable. (ZE02) The said procedure had been developed. Status of NCR (ZE02) Closed.
The process and outcome of any There was no issue with all stakeholders to Copies of the content of the file had Indicator 6.4.3 Minor compensation claims had not been date and therefore the need was not there. been submitted to the auditor and (ZE03) documented and made publicly available. A file for keeping records of the process and found acceptable. Status of NCR outcome of any compensation claims had (ZE03) Closed. been created.
Contract of employment for local workers are Kahang Barat and Ulu Dengar had obtained The FGV Booklet and detail pay slip Indicator 6.5.1 Major available at FELDA Kahang Barat and Ulu records of contract of employment for showing remunerations and (ZE04) Dengar but no records of contract of foreign workers. FGV Booklet on Terms and deductions submitted were found employment for foreign workers are sighted. Conditions of Service, Code of Ethics and acceptable. Conduct had been issued to all employees Copies of this record had been made available to the auditor and found acceptable. Status of NCR (ZE04) Closed.
Contract of employment for local workers are Kahang Barat and UluDengar had obtained Copies of this record had been made Indicator 6.5.2 Minor available at FELDA Kahang Barat and Ulu records of contract of employment for available to the auditor and found (ZE05) Dengar but no records of contract of foreign workers. acceptable. Status of NCR (ZE05): employment for foreign workers are sighted. FGV Booklet on Terms and Conditions of Closed. Service, Code of Ethics and Conduct had been issued to all employees.
Foreign workers were housed in cabins. This Letter sent to the Labour Department No letter received from the Labour Indicator 6.5.3 Minor was not in accordance with the Workers’ requesting approval for use of the cabins as Department allowing use of the (ZE08) Minimum Standard of Housing and Amenities temporary housing for the foreign workers. cabins for temporary housing. . Act 1990 (Act 446) Supporting documents and Simultaneously Ulu Dengar and Kahang photographs showing hostel under Barat Management progress to build the construction submitted to Assessor worker’s hostel. Photographs showing hostel were found acceptable. construction in progress are attached. NCR (ZE08) status is Closed.
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No records of minutes of meetings with trade Kahang Barat and Ulu Dengar had taken Minutes of meeting had been sighted Indicator 6.6.1 Major unions or workers at FELDA Kahang Barat action to obtain the Minutes of JCC by the assessor and found (ZE06) and Ulu Dengar. meetings. acceptable. . Status of NCR (ZE06) is Closed
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DETAILS OF NCR RAISED DURING STAGE 2 ASSESMENT AT FELDA KAHANG POM
P & C Specification Detail of Non-Conformities Corrective Actions Verification by Assessor Indicator Major/Minor C 6.4 The said procedures (Perundingan Hak Copies of the procedures developed and the file Procedures for identifying legal and Perundangan dan Hak Adat) had been created were submitted to the auditors who customary rights and for calculating and developed and a file for recording found them to be acceptable. Hence the NCRs distributing fair compensation were not claims and actions taken had been (ZE01, ZE02 and ZE03) raised against C6.4 is available. Neither was the process and created. There was no such issues with closed. outcome of compensation claims all stakeholders to date. documented.
I 6.5.1 AND 6.5.2 FGV Booklet on Terms and Conditions The FGV Booklet and detail pay slip showing Document of pay and conditions and contract of Service, Code of Ethics and Conduct remunerations and deductions submitted were of employment were not available. had been issued to all employees. found acceptable. Status of NCRs (ZE04 and ZE05) for both indicators are closed.
I 6.5.3 Evidence provided to show adequate Documented evidences were submitted to the No records of adequate housing for workers. housing for workers. Letter seeking auditors were found acceptable. Hence, the approval for temporary use of cabin NCR (ZE08) is closed. while waiting completion of hostel construction had been sent to the Labour Department as well as photographs showing hostel construction in progress are attached.
I 6.6.1 Records of dates of meetings were The evidences submitted were viewed and Minutes of meeting between KKS Kahang produced as well as minutes of found acceptable. management and union/workers meeting. Hence, the NCR (ZE06) is closed. representative not available.
I 6.6.2 Statement in local languages The said statement was submitted to the Statement in local languages recognizing recognizing freedom of association was auditors and found to be sufficient. Hence, the freedom of association not available. made available. Proof of NCR (ZE07) is closed. implementation recognizing freedom of association are between (a) mill workers and management, and (b) land settlers as members of the JKKK.
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Indicator Detail of OFI 4.3.2 Avoid or minimize bare or exposed soil within estates In Ulu Dengar thick under growth was also seen in most blocks. In Kahang Barat bare grounds, as a result of blanket spraying, were sighted.
4.5.1 Documented IPM system. Only very few beneficial plants were sighted in both Kahang Barat and Ulu Dengar. A few barn owl boxes were also sighted. Wire mesh guards to prevent damage by Wild Boars and Porcupines were sighed in the replants and individual young palms were fenced using plastic netting to be protected from cattle damage. Cattle traps have been installed in the replants to prevent cattle entry and damage. However, proper programmes to continuously plant beneficial plants and to increase the number of Barn Owl boxes as per SOP could be documented and implemented to further improve IMP implementation.
4.7.1b All operations have been risk assessed and documented Although HIRADC register had been established, confusion in filling hazard and risk column exist and revision to it is in order.
OSH yearly plan for estate can be further improved by conducting the legal compliance evaluation program
The post-mortem report following emergency response drill could be improved to detail out time of events against outcome.
Involvement of Safety & Health Committee at estates could be further improved by active participation in all OSH programs and activities, among them, Workplace Inspection, attendance at quarterly OSH meeting, etc.
While some Oxy-acetylene gas cylinders are fitted with flashback arrestors their balance were not.
The First aid box content to be updated as some items were found missing.
The Laboratory Oven to be located under the fume hood.
5.1.1 Documented aspects and impacts risk assessment that is periodically reviewed and updated The assessment of aspects and impacts risk assessment can be further improved by including any new activity either permanent or temporary such as building construction activity under CU (Kahang Barat Estate) administration need to be assess its environmental aspects and impacts and updated its documents accordingly
5.1.2 Environmental improvement plan to mitigate the negative impacts and promote the positive ones, is developed, implemented and monitored The performance of environmental improvement plan to mitigate negative impacts implemented within all CUs (Kahang Mill) can be further improved by frequently updating its environmental performance status monitoring in proper documentations format.
5.2.1 Identification and assessment of HCV habitats and protected areas within landholding; and attempt assessment of HCV habitats and protected areas surrounding landholdings The High Conservation Value Assessment Report has been conducted for Kompleks Felda Kahang. Sg Belumut and Sg Janoh (tributaries to Sg Sembrong) was identified as significant HCVs areas and the action plans was prepared. However these river was not highlighted in the map of assessment report.
5.3.1 Documented identification of all waste products and sources of pollution. The records of all waste products and sources of pollution identified by CUs (Ulu Dengar Estate) can be further improved by consistently updating the
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information of daily or weekly waste generated stored and recycled/disposed especially for the empty chemical containers
5.3.2 Having identified wastes and pollutants, an operational plan should be developed and implemented, to avoid or reduce pollution. The operational plan developed by CUs (Kahang Mill, Kahang Barat Estate and Ulu Dengar Estate) to avoid or reduce pollution can be further improved its implementation by including both work (mill /estate) and community (quarters/village) area The handling of damaged empty sterilizer bag that is not stored or recycled by CU (Ulu Dengar Estate) can be further improved by disposing through proper domestic waste management channel
5.6.1 Documented plans to mitigate all polluting activities. The plans to mitigate all polluting activities by CU (Kahang Mill) can be further improved by specifying the actual program especially for polluting activities being legally compound by the authority for non-compliance (black smoke emission exceeded the Ringelman Chart no. 2 limit) in its RSPO documentations and file
6.1.1 A documented social impact assessment including records of meetings. There is a SIA for Kahang Complex. However there are certain items in the survey questionnaire which are not discussed in the report. It is suggested that the report be modified to suit the items in the questionnaire.
Maintenance of a list of stakeholders, records of all communication\ and records pof actions taken in response to input from stakeholders. 6.2.3 There is a list of stakeholders, internal and external. However it is suggested that the list of external stakeholders be updated to include immediate neighbours who were missed out in the present list.
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