Cotecna Inspection S.A., Niamey Liaison Office

Cotecna Inspection S.A. of Switzerland (COINS) seeks a MIGA guarantee for its investment in the COINS S.A. Niamey Liaison Office Inspection (Cotecna Niger).  The project consists of a five-year build-operate-transfer contract to supply, install, maintain, and operate three mobile container scanners at different locations (Niamey Route, Niamey Rive Droite, and Maradi); to provide pre-shipment inspection and document verification at origin; to verify compliance of imported goods with applicable standards based on service contracts; and to deliver training and logistical assistance to the Government of Niger (GoN) for the modernization of national customs.

This build-operate-transfer contract includes some pre-shipment inspection and document verification at the point of origin which will be carried out by Cotecna’s international network, and cargo scanning at the ports of entry.  The import verification process will use Cotecna’s Computerized Risk Management System (CRMS) which analyzes data on trade transactions in order to assign the correct level of intervention to identify which import transactions will be subject to pre-shipment inspection or scanning at destination on a risk assessment basis. 

B.  Environmental and Social Categorization

This project is Category B under MIGA's Policy on Social and Environmental Sustainability.  The key issue is safe operation of the equipment (occupational health and safety).  Land needed by the project will be provided by the customs administration within the Ports of Niamey Route, Niamey Rive Droite, and Maradi.  The scanners will be installed in a controlled access customs area which is restricted from the public.  There are no significant social and environmental adverse impacts directly resulting from this investment.

While all Performance Standards are applicable to this investment, the current information indicates that PS 1 (Social and Environmental Assessment and Management Systems) and PS 2 (Labor and Working Conditions) apply directly to this project.  The Security Personnel aspects of PS4 are also applicable as Cotecna Niger will engage private security guards to secure its offices and scanner sites. The World Bank Group General Environmental, Health and Safety Guidelines are applicable to the project (PS 3 Pollution Prevention and Abatement). 

PS 5 (Land Acquisition and Involuntary Resettlement), PS 6 (Biodiversity Conservation and Sustainable Natural Resource Management), PS 7 (Indigenous Peoples), and PS 8 (Cultural Heritage) are not applicable for the project as the scanners and small offices will be installed within the boundary of the seaport.

The documents reviewed by MIGA include:

• Environmental and Social Document:  Human Resources, Health & Safety, Training & Audit, prepared by Cotecna Inspection S.A. Niamey Liaison Office (Niamey, Niger), September 2012 [environmental and social management plan]
• Health and Safety Plans and Procedures prepared by Cotecna (e.g., Fire Protection Procedure - Procedure Incendie, 2007; Instruction for Radioactive Material Detection, 2010; Radioprotection Safety – Sécurité et Radioprotection, 2012)
• Information on Niger Collective Labour Agreements
• 2011 Annual Activity Report:  Cotecna
• Definitive Application for a MIGA Guarantee.

MIGA’s review of this project also included correspondence comprising of environmental and social information submitted by the project sponsor.

Social and Environmental Assessment and Management Systems

The project does not need to develop impact assessments; however, appropriate mitigation and monitoring measures are required.  Cotecna Niger has developed an environment and social management plan, and health and safety plans and procedures.  These plans and procedures address the potential environmental, health, and safety risks associated with the project and include information regarding ongoing training and monitoring. 

Labor and Working Conditions

Niger has ratified eight fundamental International Labour Organization (ILO) conventions, including conventions on forced labour, freedom of association, right to organize and collective bargaining, equal remuneration, discrimination, minimum age, and child labour, and also enforces the Niger Labour Code (Niger – Code du Travail – Ordonnance 096-039 du 29 juin 1996).

The project employs approximately 150 workers at the three port sites.  The project enterprise applies an equal opportunity and non-discriminatory work environment, and currently approximately 20% of the workforce is female.  Annual salaries are above the national average.  Cotecna Niger currently does have an HR Procedures document issued in January 2011 by the then Liaison Office general Manager and Internal HR Regulations dated 26 June 2012 cosigned by the Niger Labor inspector. Besides, it does follow the collective inter-professional labor Convention that was co-issued by the Government and the employers which is applicable to all companies active in the country. The agreement outlines the terms of employment and work conditions (e.g., working hours, overtime pay, minimum work age, and protection of women’s health, and annual leave (paid). Cotecna Niger has formalized its human resource commitments into a procedures manual consistent with PS 2.

The key health issue associated with scanner technology is radiological safety.  The project design incorporates all required safety training and auditing procedures.  Cotecna warrants that its Radiological Safety System - consisting of a wired-logic controller and associated safety sensors - autonomously guarantees safety in and around the scanners, so that the installations are completely safe for its operators, drivers, and those working in the vicinity. 

The project requires training of local staff in the handling and operation of the equipment. Cotecna and Customs Agents working near the scanner are equipped with dosimeters to measure personal exposure to radiation.  Dosimeters are analyzed and replaced every three months.  The radiometers in the scanning equipment are calibrated yearly.  A joint employer-employee occupational health and safety committee has been established to monitor health and safety conditions of the project. 

A fire safety procedure has been established for the project, emergency numbers are posted at the project, and fire extinguishers are available onsite.  Training for fire safety is part of Cotecna Niger’s training program.

Regular and frequent audits of all sites to verify compliance with all procedures, including safety procedures will be undertaken.  A specific clause in the contract will require the investor to ensure that worker safety is part of an ongoing internal auditing program as per the Occupational Health and Safety guidelines, PS2 and PS4.  Audit reports on occupational health and safety will be made available to MIGA.

Community Health, Safety & Security—Security Personnel

In cooperation with public security services, Cotecna will engage private, unarmed security guards to secure its offices and scanner sites.  Cotecna’s private security will be managed in accordance with PS4 as well as local laws and professional standards.  Cotecna will employ sufficient marshalling staff to safely and efficiently manage traffic movements in the pre-scanning and scanning areas, and in the truck parks.  Fencing will be used as a security/safety measure at the site.

Given that the project involves small physical installations within secure customs areas at seaports, environmental permitting and community consultation/engagement are not required for this project.

There are no attachments for this ESRS document.