|
BSI Standard, Public Comments - Phase 2
|
|
The comments on the BSI Standard received during the public consultation phase 2 from 12th November 2009 to 12th January 2010 (midnight UK time) are shown below.
|
|
|
General Comments
|
|
| |
Comments |
|
This standard should be expanded to include certification of biodiesel from sugarcane.
|
|
Principle 1. Obey the Law
|
1.1 Criterion – To comply with relevant applicable laws.
|
| |
Comments |
|
Should also recognize the UN Declaration of Human Rights
|
|
|
Principle 2. Respect Human Rights and Labour Standards
2.1 Criterion - To Comply with ILO labour conventions governing child labour, forced labour, discrimination and freedom of association and the right to collective bargaining.
|
|
Comments |
|
|
|
All ILO conventions listed in Appendix should be listed in the notes and indicators to ensure compliance with the core ILO conventions.
Additionally, production of sugarcane in non-signatory should still meet the conventions in order to meet certification - this should be made clear.
|
| |
This should also address education in addition to health, safety and morals for large farms in addition to small farms. E.g. all children living on the farm have access to quality primary school educaton.
|
| |
Should also be verified through record keeping of payroll records and employment applications.
|
| |
Recommend changing "should" to "shall" to ensure compliance. Fine line between prescription and guidance here.
|
|
|
2.2 Criterion - To respect and protect human rights and labour standards for employees and workers including migrant, seasonal and other contract labour.
|
|
Comments |
|
|
|
Management system should be demonstrable by the producers to ensurecompliance beyond the one or two day audits. Question here is: are workers
getting their social benefits? Are workers actually getting paid? Are workers free to leave? Audit must find a way to demonstrate this. This should go into the guidance document or notes.
|
|
2.3 Criterion - To provide a safe and healthy working environment in work place operations.
|
|
Comments |
|
|
|
This means 15 accidents are permissable per year amongst 480 workers. This is good. However, the producer should have an ability to prevent fake injuries - some type of system to prove accidents occur. Additionally, guidance document or local industry should consider how can the producer change systems to prevent accidents? Need to also find a way to avoid under-reporting.
|
|
Auditor should visibly review actual equipment to ensure quality and quantity for workers depending on the task for which the equipment is intended. Key is to review gear on site.
|
| |
Is 5 years regular updating for a worker? This needs clarification. Should consider health and safety for employees and workers, so that the notes always say "employess and workers." All employees and workers should receive health and safety training before every new job and once a year.
|
| |
Records should be kept to ensure potability of water. Samples should be taken once a year and sent to reputable, independent lab to ensure compliance with this. Visual check does not ensure quality as many harmful organisms are not visible to the naked eye.
|
| |
The mill and farms should be able to spell out clearly the requirements per person or per task based on international norms. What is the contents list required for first aid kits? Audits should check stocking list against what actually is present. Additional checklists in the mill area should include whether anti-venom available nearby from the mill or local hospital and if it is accessible?
|
2.4 Criterion - To provide employees and workers (including migrant, seasonal and other contract labour) with at least the national minimum living wage.
|
|
Comments |
|
|
|
Clarify the indicator so that it is greater than or equal to the national minimum wage. However, in an area where workers are well-documented to be malnourished, there should be a documented and proven attempt by the farm or milling operation to ensure that the minimum wage meets the needs for human needs. SAI for SA8000 has a simple formula that can accomodate this issue in a positive direction.
|
2.5 Criterion - To provide clear, equitable and comprehensive contracts.
|
|
Comments |
|
|
|
National working card is different than a contract. Both should be required in countries where they both exist.
|
Principle 3. Manage input, production and processing efficiencies to enhance sustainability
3.1 Criterion - To monitor production and process efficiency; to measure the impacts of production and processing so that improvements are made over time.
|
|
Comments |
|
|
|
This criteria should also be stated that in addition to monitoring, there must be compliance in order to meet the standards. It should not be "with a view to minimising" it should be "a plan to reduce to specific targets." The standard should also be clearly demarcated as a minimum performance level.
|
|
Need to define "supplementary," but should account for effective rainfall and irrigation use efficiency. In water stressed areas, mills should create a water management plan for their suppliers to aid in irrigation efficiencies and timings to secure environmental flows as well as future production and livelihoods.
|
| |
This should be clarified to ensure that it is in addition to the accident frequency above, or is it not?
|
| |
Should increase to 90% to improve logistics and ensure that sucrose recovery improves along with all other resource use efficiencies. 75% is a waste of 25% of all salaries and wages in the mill operating period.
|
3.2 Criterion - To monitor climate change impacts.
|
|
Comments |
|
|
|
This criteria should also be stated that in addition to monitoring, there must be compliance in order to meet the standards. It should not be "with a view to minimising" it should be a plan to reduce to specific targets" or "lead to substantial reductions." The standard should be clearly demarcated as a minimum performance level.
|
|
Is this low enough to begin to eliminate burning and reduce N2O/CH4 emissions? The indicator should be at a level that will begin to phase out burning, and the math should have the math to back it up. Though eliminating burning is prescriptive, it is a management practice directly attributable to greenhouse gases, particulate emissions, and other noxious gases that have direct, negative impacts on human health and the environment.
|
| |
The European RES-D states a default value of 24 g CO2eq/MJ for Ethanol from sugarcane. This value already includes 9 g CO2eq/MJ from transport to Europe. How do the 29 g accumulate over the value chain? Are calculation spreadsheets available? The threshold should be in line with RES-D for future compatibilty of the standards.
|
Principle 4. Actively manage biodiversity and ecosystem services
4.1 Criterion - To assess direct and indirect impacts of sugarcane enterprises on biodiversity and ecosystems services.
|
|
Comments |
|
|
|
In General: This Criterion is very week and not in compliance with EU RED. There should be a very clear GHG reduction target e.g 35 % by 2023 and 50 % by 2016
|
|
Criteria text should move from just assessing to also comply with and implement management systems to achieve level of performance within the indicators.
|
| |
Should also prohibit direct return of mill effluent into a river, stream, or lake. There should be an adequate wetland or man-made filter system to avoid impacts on freshwater and marine habitats. Who does the routine measurement? This needs clarification and subsequently undertaken by a certified and independent laboratory.
|
| |
Good. In guidance document, there should be recommendations on how to conduct an HCV assessment. Additionally, the Brazilian eco-zoning maps should be recognized as equivilent, given that the legislation prevents conversion of all natural habitats. Should also include remediation technique agreed upon by the management committee in order to certify sugarcane that has cleared HCVA post 1 January 2008- this would have to require significant protection of biodiversity and restoration.
|
| |
The indicator could not be used on the farm level, what is the influence of a farmer on the national precentage of protected areas. Principle 4 is vey weak and won't help to stop conversion.
|
| |
This is a mixture between results of HCV and legal requirements, how can a famer influence the existence and implementation of EMP. In general there is not cut-off date in the standard
|
| |
How is this supposed to be controlled and monitored/measured? Consider combining with probes taken for next criteria. "Jeopardize" should be defined.
|
| |
How does 5 kg AI stack up against average uses? Recommend setting it at a national level of best performance due to variable production issues and pest outbreaks. Should clarify that not only Stockholm Convention POPs, but also WHO Class 1A, 1b, and 2 should also be banned. Eventually link compliance to herbicides and pesticides banned in Europe.
|
4.2 Criterion - To consult relevant stakeholders and implement appropriate mitigation where adverse impacts are identified.
|
|
Comments |
|
|
|
Should also include long-term monitoring to ensure that desirable outcomes are being met in relation to downstream impact.
|
Principle 5. Commit to continuous improvement in key areas of their businessPrinciple
5.1 Criterion - To train employees and other workers in all areas of their work and develop their general skills.
|
|
Comments |
|
|
|
Please clarify as to how this will be calculated. Will workers be paid for undertaking the trainings?
|
5.2 Criterion - To continuously improve the status of soil and water resources.
|
|
Comments |
|
|
|
Should account for effective rainfall, not just irrigation, so that ecosystems are not hampered to eliminate or reduce hydrologic or environmental flows.
|
| |
Should be higher, at least 30 or 40% to maintain ground cover as well as eliminate the potential for secondary burning.
|
| |
Fine, as long as the un-measured fields are in fallow, but fields planted to cane should all be measured.
|
5.3 Criterion - To continuously improve the quality of sugarcane and products from the sugar mill.
|
|
Comments |
|
|
|
This should be raised to 11% or at least set a national bar of performance, whereby the top quarter percentile national recovery is the de facto standard with 10% being the global floor.
|
|
5.4 Criterion - To promote energy efficiency.
|
|
Comments |
|
|
|
Requires clear calculator spreadsheet for farmers to use in order to ensure consistency of their reporting.
|
|
5.5 Criterion - To reduce emissions and effluents. To promote recycling of waste streams where practical.
|
|
Comments |
|
|
|
Requires clear calculator spreadsheet for farmers to use in order to ensure consistency of their reporting.
|
5.6 Criterion - To foster effective and focused research, development and extension expertise.
|
|
Comments |
|
|
|
Is this for farmgate cane price or sugar end use sale? Needs to be clarified. Also, mandating research in a country that has no infrastructure for research puts farms in an unfair position. Need to specify from a cost accounting standpoint what is included in a cost of sales due to variations between accounting methods.
|
|
5.7 Criterion - For expansion or new sugarcane projects to ensure transparent, consultative and participatory processes that addresses cumulative and induced effects via an environmental and social impact assessment.
|
|
Comments |
|
|
|
Needs to ensure no deleterious impacts on freshwater resources for downstream users, while also taking into account best available climate change science in order to prove future feasibility. Also, if there is displacement of foodcrops, there must be a mitigation. Should be accompanied by a standard ESIA to ensure global consistency. Recommend utilizing an existing one, or developing ESI such as that used by the RSB or ISCC.
|
5.8 Criterion - To ensure active engagement and transparent, consultative and participatory processes with relevant stakeholders, as well as with local communities and to provide clear grievance mechanisms.
|
|
Comments |
|
|
|
90% seems unrealistic in highly contentious issues. Recommend refining to "provide evidence of good faith effort that conflicts are trying to be resolved, as well as that the meetings are had." Not everything can be solved.
|
5.9 Criterion - To promote economic sustainability.
|
|
Comments |
|
|
|
Needs refining. Mandating profitability is tough. What should be done is that the standard encourages profitability and that over a series of years the mill and farms are profitable. A specific level of value add is unreasonable. An economic indicator is good but this needs to be better formed to account for economic fluctuations like price of sugar, ethanol, oil, and currencies. A management system to monitor financial results is what is needed to ensure long term economic sustainability with accompanying performance against the budget.
|
|
Appendix 1. Definitions
|
|
Comments |
|
|
|
Definition of "significantly affected" should include all habitats, not just endangered habitats.
|
|
|
|
|
