SFG2842 V2 P152232 MINISTRY OF NATURAL RESOURCES AND ENVIRONMENT VIET NAM PROJECT MANAGEMENT UNIT HCFC Phase-out Project (Stage II) GENERIC ENVIRONMENTAL MANAGEMENT PLAN (For Refrigeration Manufacturing Sector) November, 2016 TABLE OF CONTENT 1. Objective and Structure of Generic Environmental Management Plan ................................................4 2. Project Description ........................................................................................................................4 3. HCFC Phase-out Activities for Refrigeration Sector ..........................................................................7 4. General Introduction of Alternative Technology ...............................................................................8 5. Legal and Regulatory Framework Requirements.............................................................................10 5.1 Relevant International legal documents ..............................................................................10 5.2 National laws and regulations ............................................................................................10 5.3 WB Policies and Other Guidelines .....................................................................................14 5.4 Stakeholder Consultation and Public Disclosure ..................................................................14 6. Overview of Environmental and Social Impacts and Mitigate Measures ...........................................15 6.1 Potential Environmental Impacts .......................................................................................15 6.2 Environmental and Social Impacts Mitigation Measures .......................................................18 6.3 Proposed Measures for Handling and Safety Operating of Explosive Gases ............................29 6.3.1 Building and Structure ......................................................................................................31 6.3.2 Safety Criteria for Construction of Storage Facility for refrigerants .......................................31 6.3.2 Plant Equipment, Machineries Hazard Identification and Risk Management ..........................33 6.3.3 Electrical System Inspection and Maintenance.....................................................................33 6.3.4 Mobile Plant Equipment Inspection and Maintenance (applied depending case to case) ...........34 6.3.5 Standard Operating Procedures and Safe Work Method Statement ........................................34 6.3.6 Accident Reporting and Investigation Procedure ..................................................................34 6.3.7 Permit To Work Procedures...............................................................................................35 6.3.8 Warehouse and Storage Facilities Management, Hazardous Material Handling and Storage ............................................................................................................................35 6.3.9 Transportation and Traffic Management .............................................................................36 6.3.10 Workplace Environmental Management .............................................................................37 6.3.11 Personal Protective Equipment ..........................................................................................37 6.3.12 Training and Certification Management ..............................................................................38 6.3.13 Emergency Response ........................................................................................................38 6.3.14 Waste Management ..........................................................................................................39 7. Estimated Budget for Mitigation Measures ....................................................................................39 7.1 Estimated cost for installation and change refrigerants ............................................................40 7.2 Estimated annual cost for environmental management during operation phase .......................40 8. Institutional Arrangement Organizations .......................................................................................41 9. Environmental and Safety Monitoring Requirements and Monitoring Plan .......................................43 Implementation Schedule and Reporting Procedures ......................................................................46 10. Training Plan .................................................................................................................................49 References ...........................................................................................................................................49 ANNEX 1 - Environmental Codes of Practice (ECOP) for Small Civil Works ...........................................51 ANNEX 2 - Template of Site Environmental Management Plan ...............................................................57 ANNEX 3 – Outline of Measures on precautions and chemical emergency response ..................................65 ANNEX 4 – Main refrigerants to be replaced the use of HCFC-22 ............................................................66 ANNEX 5 - Summary of Material Safety Datasheet for Gases used in Air Conditioning .............................68 ANNEX 6: Information on Refrigeration Manufacturers and their total investment ...................................75 ANNEX 7 - Area Classifications for the Design of Production Line Use Flammable Gas ..........................79 ANNEX 8 - Oxygen-Propane Brazing Safety Guideline ...........................................................................80 ANNEX 9 - Summary of Project Stakeholder Consultation of Generic Environmental Management Plan for the Refrigeration and Air Conditioning Sectors ..................................................................84 2 List of Abbreviations AC Air Conditioners ASME American Society of Mechanical Engineers CAS No Chemical Abstract System Number CFC Chlorofluorocarbons CO2 Carbon dioxide dB Decibel EC European Country EHS Environmental, Health and Safety EMP Environmental Management Plan Ex Explosive / explosion GHG Greenhouse Gases GHS Global Harmonized System GWP Global Warming Potential HCFC Hydro chlorofluorocarbons HPMP HCFC Phase-out Management Plan IEC International Electrical Code LEL Lower Explosive Limit MLF Multilateral Fund MOLISA Ministry of Labor, Invalids and Social Affairs MOIT The Ministry of Industry and Trade ` MONRE Ministry of Natural Resources and Environment MSDS Material Safety Data Sheet MT Metric Tons NEC National Electric Code NFPA National Fire Protection Association NOU The National Ozone Unit ODS Ozone-Depleting Substances OHS Occupational Health and Safety PLC Programmable Logic Controller PMU Project Management Unit SME Small and Medium-size Enterprises SOP Standard Operating Procedures 3 1. Objective and Structure of Generic Environmental Management Plan This Generic Environmental Management Plan (EMP) is prepared for the refrigeration manufacturing sectors as the guidelines for the owners of refrigeration sub-projects to prepare their specific EMP, which identifies the principles, approach, procedures and methods that could be used to control and minimize the environmental and social impacts of all construction and operational activities associated with the project. The sub-project owners can use the template site-EMP in Annex 2 and information in the Generic EMP to prepare their site EMP for each specific case. The Generic EMP is structured as follows: - An overview of the project description is provided in section 3. - HCFC Phase-out activities for air- conditioning in section 4. - General introduction of alternative technology in section 5. - Legal and regulatory framework requirements in section 6. - Overview of environmental and social impacts and mitigation measures in section 7. - Proposed measures for handling and Safety Operating of explosive gases in section 8. - Estimated Budget for Mitigation Measures in section 9. - Institutional Arrangement Organizations in section 10. - Environmental and Safety Monitoring Requirements and Monitoring Plan in section 11. - Training Plan in section 12. The Generic EMP also contents the 8 annexes of which: - Annex 1 is the Environmental Code of Practice (ECOP) for Small Civil Works to help enterprises manage small environmental impacts during construction if any. - The sub-project owners can use the Annex 2 – template site EMP to prepare the site- EMP and the Outline of Measures on precautions and chemical emergency response in Annex 3 to prepare their Chemical precautions and chemical emergency response reports; - Annex 4 and 5 provide the detailed information of the recommended low-GWP refrigerants which will replace HCFCs and their safety data sheet; - List of survey and potential refrigeration manufacturers and the estimated costs of conversion gases are presented in Annex 6. - The Annex 7 and Annex 8 provide the guidelines on Area Classifications for the Design of Production Line Use Flammable Gas and Oxygen-Propane Brazing Safety; and - The Annex 9 summaries the results of Stakeholder Consultation for Generic Environmental Management Plan of the refrigeration sector. 2. Project Description 1. The project development objective is to reduce HCFC consumption in order to assist Vietnam meet its HCFC phase-out obligations under the Montreal Protocol, and to reduce greenhouse gas emissions arising from the replacement of these HCFCs while promoting energy savings if any from the newer refrigeration and air-conditioning equipment. 2. Vietnam became one of the Bank’s first two partner countries to receive approval of Stage II HPMP funds at US$14.64 million by the MLF in May 2016. Vietnam is to reduce HCFC consumption by 35% of its baseline by 2020 in the three remaining manufacturing sectors, residential AC, refrigeration and foam, as well as in the servicing sector. It agreed to a total elimination of HCFCs in the AC sector and in imported pre-blended polyols by January 1, 2022. 4 The total phase-out of HCFC-22 and HCFC-141b in imported pre-blended polyol agreed to be achieved under the Stage II project would be 1,005.6 MT (55.31 ODP tons) and 684 MT (75.26 ODP tons)1 respectively. Japan will join the Bank as a “cooperating agency” to specifically provide technical assistance to the AC sector through its refrigeration and AC industry association (JRAIA). The Stage II project is a continuation of the ongoing Stage I project and the project duration is expected to be from 2017 to 2022. The project consists of three proposed components described below. Component 1: HCFC Consumption Reduction 3. AC manufacturing and servicing sector. The project will finance incremental capital costs (ICC) needed for converting to non-HCFC based AC production including procurement of new production equipment, performance testing of new AC models, and technician training for installation and servicing, and incremental operating cost (IOC) based on MLF financing guidelines at four enterprises (consuming a total 175 MT of HCFC-22 in 2014). After conversion at the four enterprises, no HCFC-22 will be used for AC production in the entire sector, i.e. 251 MT of HCFC-22 will be completely phased out. The approved funding is US$2.18 million. The lower GWP alternatives to HCFC-22 in the AC sector are HFC-32 with a GWP 675 or R-290 with a GWP of 5, however both are flammable which will require special safety precautions and investments. 4. Due to its classification as an A2L refrigerant, mildly flammable refrigerant, HFC-32 requires that certain measures be put into place before its wider use in Vietnam, including in manufacturing. TA will be needed specifically for effective adoption of this technology. Given its recent experience in this area including related to HFC-32 regulation, Japan has been approved under the MLF to provide TA as the Cooperating Agency while drawing practical expertise from Japanese AC manufacturers through JRAIA. TA activities are proposed at a total cost of $233,630: development of A2L policy measures, TA to the AC manufacturers, and TA for good practice in installation and operation. An additional 66.3 MT in HCFC-22 phase-out is expected from the AC servicing and Japan TA activities. 5. Refrigeration manufacturing sector. The project will finance conversion of priority industrial refrigeration systems where cost-effective and low GWP alternatives (e.g. ammonia, hydrocarbons, HFC-32, etc.) are available through ICC (for system, component and process redesign, new equipment, performance verification, and safety training) and IOC at about 34 enterprises which are eligible for MLF funding.2 Approved funding is US$3.64 million. A reduction of 303 MT will be achieved by project closing. The implementation of HCFC phase- out in the refrigeration sector will be phased, whereby 6-10 demonstration subprojects for applications including ice making units, stand-alone refrigeration units, cold storage rooms, and condensing units will be started at the beginning of the Stage II project. As soon as a body of experience has been accumulated, the knowledge will be used by experts to inform remaining companies. 6. Refrigeration servicing sector. The project will finance the following activities in the refrigeration servicing sector: training and certification in good servicing and maintenance practices, provision of servicing tools to selected vocational training centers to enable training in the handling of alternative flammable refrigerants and to selected servicing shops to inform the 1 Remaining HCFC-141b consumption that is eligible for MLF. 2 Companies established before September 2007, the ExCom’s cut -off date for determining total eligible funding. A total of 71 refrigeration manufacturing enterprises were identified during the 2015 survey. 5 sector on alternatives and prepare for Stage III, TA demonstration for 10 selected industrial refrigeration end users on HCFC leakage management. The approved funding is US$1.37 million for an HCFC-22 phase-out impact of 285.3 MT. 7. Foam sector. The project will finance ICC needed for foam production conversion to hydrocarbon, methyl formate or HFO (hydrofluoroolefin) alternatives at about 44 enterprises. After completion of conversion at these enterprises, it will be prohibited to use HCFC-141b contained in pre-blended polyol for foam production in the whole sector. About 2035 MT of HCFC-141b will be completely phased out. In order to allow SMEs (consuming less than 20MT of HCFC-141b) to convert to non-HCFC production in a cost-effective way, the project will also finance upgrading of two to four system houses to be competitively selected among existing foam producers or chemical suppliers that have established the basic system house infrastructure. These system houses would supply non-HCFC pre-blended polyol to SMEs. In addition, the project will finance conversion at an enterprise which used HCFC-22 of 100 MT in 2014 for XPS foam production. The approved funding for HCFC-141b phase-out and HCFC-22 phase-out in the foam sector is US$5.52 million and US$613,568 respectively. 8. Implementation in the foam sector will also be phased due to the limited funding approved in contrast to the large amount of HCFCs used. The largest consumer of pre-blended HCFC- 141b polyol systems in Vietnam is the insulated roofing panel manufacturing industry. This subsector is made up of primarily SMEs in real terms. Therefore, four demonstration projects including establishment of system houses for the roofing subsector will be initiated first at the beginning of the Stage II project. Component 2: Technical Assistance and Policy Actions 9. This component aims to support sector-wide technology and knowledge transfer, TA and exchange of best practices, as well as to create a policy and market environment that will enable and sustain sector transformation. TA activities focusing on the AC, refrigeration and foam manufacturing sectors will include training workshops on subproject preparation, approval and implementation procedures and requirements, international and national technical consultant services for subproject appraisal and technical support for the PMU and enterprises, development of technical standards of alternatives, training for government officials, training on the safe use of alternatives, study tours on HCFC alternatives, a joint study on integrating HCFC phase-out and EE improvement in the industrial refrigeration manufacturing and food process sectors, and others as needed.3 10. On policies, this component will cover the annual HCFC import quota issuance and the development and issuance of sector-specific policy and regulations by project completion, including a ban on local production and import of HCFC-22 based ACs, and a ban on import and use of pre-blended HCFC-141b polyol in foam production. Component 3: Project Management 11. The PMU currently implementing the Stage I HCFC Phase-out Project will most likely continue with financial, procurement, and safeguard management as well as monitoring and reporting responsibility. This component will finance the PMU staff including one project coordinator, two project officers, one procurement officer, one accountant and one 3 TA for the AC and refrigeration servicing sector is included in Component 1 as it results in HCFC phase-out impact. 6 administrative officer, project launch and completion workshops, financial audits, annual HCFC consumption verification, public awareness activities, and incremental operating cost (of the PMU). 3. HCFC Phase-out Activities for Refrigeration Sector Refrigeration manufacturing using HCFC-22 remains in Vietnam primarily because there are a number of end-users that purchase ice makers, cold stores, condensing units, contact freezers, etc. which are located in urban areas. Many industrial size operations, particularly those focused on the export market (such as the seafood processing industry) have shifted to ammonia systems. HCFC-22 use also remains in plants that have a combination of systems and have not had the capital to changeover to HCFC-free technologies. Industrial consolidation and a highly competitive market has served to slow demand for HCFC-22 in the sector in newly installed large distributive systems, but it is expected that there will be residual consumption for new manufacturing for some time. Servicing demand will continue to grow. With the likelihood that servicing demand is higher than has been estimated by the country (through MONRE’s annual analysis of import data and consultations with Customs and importers for data reporting) and that consumption for refrigeration manufacturing is also higher than what was captured by the survey but lower than MONRE’s estimate, it is likely that the 2014 consumption of HCFC-22 is as follows: Table 3-1: Stage II Estimated Distribution of HCFC-22 Consumption in 2014 Stage II 2014 CP Data Sector ODP tonnes Estimated ODP tonnes (MT) Allocation (MT) Manufacturing 1407.0 77.4 951.0 47.1 Foam 100.0 5.5 Air-conditioning 251.0 13.8 Refrigeration 700.0 27.8 Servicing 2109.7 116.0 2566.0 141.1 Total 3516.7 193.4 3517.0 137.4 *Data estimated from survey results of 71 refrigeration manufacturers. Based on an assessment of the use of HCFC-22 in the refrigeration sector in 2014, it is estimated that only 60% of the identified consumption (505 MT) could be phased out in the sector, i.e. 303 MT. As reported by TEAP, alternatives are in principle available for all refrigeration applications. The challenges are that some of the available alternatives come with high GWPs such as R404A and the R407, some are classified as A1 (highly flammable) refrigerants such as HC-290 and HC-1270 or as A2L (limited flammability) such as HFC-32, R448A and R449A, and the most prevalent, ammonia, is toxic. In addition, CO2 systems and new HFO-based alternatives are not yet commercially viable. A reduction of 303 MT will be achieved by a combination of funding to 34 companies and technical assistance (TA) to all companies in the sector. The assistance will be phased, whereby investment support (on design, prototypes and assembly line modifications) will be provided at the beginning of Stage II, and as soon as a body of experience has been accumulated, the knowledge will be used by experts to inform the remaining companies. The 7 TA activities will include information on design of refrigeration systems alternative, measures to safely handle flammable refrigerants in the workshop and on the sites where such refrigeration systems are installed. The lessons learned from the 34 companies will be the basis for the information to the industry in general. By addressing a portion of the HCFC consumed in the refrigeration manufacturing sector according to what is feasible given the challenges, Vietnam can slowly chip away at the HCFC consumption while monitoring technology developments and building confidence in the industry for conversion through technical assistance and outreach, when the time is right for complete HCFC-22 phase-out in refrigeration manufacturing in Stage III. In the meantime, it is proposed that MONRE, in partnership with MARD and MOIT which regulate refrigeration end-users set up a technical committee to determine what and when regulations can be introduced to eventually and comprehensively ban HCFC-22 use taking into account related requirements of energy efficiency and food security in this sector. A comparison of HCFC-22, HC-290, HFC-32 and NH3 physical properties are provided below. Table 3.2: Comparison of HCFC-22, HC-290, HFC-32 and NH3 Physical Properties Physical properties HCFC-22 HC-290 HFC-32 NH3 Flammable No A3 Yes, A2L Yes, A2L Flash point (C) NA -104 Not available 11 LEL-UEL NA 1.8%-8.4% 12.7%-33.4% 15%-28% GWP 1810 <25 650 0 Molecular weight 86.47 44.1 52.03 17 Heavy than air 1.6 times 3.82 times 0.76 Boiling point (C) -40.8 -42.1 -51.7 -33 Critical temperature (C) 96.2 96.7 78.45 132 Critical pressure Mpa 4.99 4.2 5.808 11.3 Specific heat of Liquid 0.31 2.75 2.35 (KJ/(Kg*C) Details see the Annex 4. 4. General Introduction of Alternative Technology All refrigeration manufacturing companies deliver the refrigeration equipment on the site based on the client’s requirement. Pre-charged systems are assembled and tested in-house before delivery. At the location where they are installed, they are connected to the power. In fact, small cold store refrigeration units are in principle air-conditioners, but designed for much lower temperature and with similar installation as in the air conditioning sector. Larger refrigeration systems are assembled in-house and tested, then unassembled, transported and installed at the sites. Installation on site would require charging equipment, often from cylinders, and leak detectors. It is noted from the survey that used compressors have been exported from countries which are phasing out HCFC-22 to Vietnam. This is resulting in even cheaper HCFC-22-based refrigeration systems, but with unknown energy performance. There is no single refrigerant which can replace HCFC-22, making the phase-out of HCFCs in the refrigerant sector very challenging. HFC-32 is a single component refrigerant with zero ODP, GWP 675 (which is a third of that of HCFC-22) and is the main component of R-410A. Its 8 working pressure is higher than HCFC-22, with good heat transfer properties, volumetric refrigerating capacity and theoretical energy efficiency. HFC-32 refrigerant has at given saturated temperature approximately 60% higher pressure (for example at 55°C condensing temperature 33 bar (g) compared with 21bar (g) less for HCFC-22), which requires on high pressure side a 60% higher burst pressure of compressor shell, condenser, accumulator, filter-dryer and high pressure copper tubes to be reached by thicker walls; the pressure differential is similar. HFC-32, HC-290, NH3 compressors use synthetic POE, which is highly hygroscopic. It absorbs moisture quickly and once absorbed, the moisture cannot be removed through the system evacuation. Therefore, it is important to prevent moisture from getting into the POE oil in the first place. The cooling circuit elements, evaporator, condenser and tubes must by dried by dry Nitrogen before inserting them into the circuit. The main concern is the flammability of HC-290 and NH3. NH3 is toxic gas and therefore both HC-290 and NH3 is not suited to most small and medium sized industrial systems. The investment cost for NH3 system is high and need more space, therefore, this system is not suitable for the manufacturers which is not synchronously invested or large-scale extended. For the small and medium scale of NH3- refrigeration system, the investment cost is approximately twice times higher than those of HCFC-22. The 34 refrigeration companies (listed in Annex 6) established before 2007 will be targeted in phase 2. They can be divided into 2 groups based on their production situation: - 7 companies in group 1, which are companies manufacturing full range of industrial refrigeration equipment and systems, both standardized equipment and made to –order system. - 27 companies in group , which mainly focus on standardized equipment. Based on the information collected from the survey and enterprise visits, changes that are needed for phasing out HCFC-22 with low GWP alternatives are summarized below: Table 4-1: Changes need for use of low GWP alternative gases No. Item Required Modification 1 System redesign The overall system, components and process would need to be redesigned for adaptation with the new alternatives and technology This will include redesign and calculations, simulation, reengineering of the system components, such as compressors, expansion valves, heat exchangers, unit structure, electrical systems, and compilation of production process, drawings, documentation and complete bill of materials. As the alternatives in the future most likely will be classified as A2L and A2, special safety measures might be needed to be built into the system. 2 Sheet Metal Redesigning of the systems The sheet metal processing dies for unit Processing housing and other parts will need to be Changed and depend on the actual units. 3 Product Assembly Due to the redesigned system, positioning fixtures for assembly will need to be changed. The existing charging, evacuation and leak detection equipment will need to be changed so flammable refrigerants can be used. Building modification, ventilation and gas sensors might 9 be required. 4 Quality inspection, The existing test rig for HCFC-22 based products will need testing and finishing modifications due to the redesigned products. As flammable refrigerants are used, safety measures might be needed. 5 Production The exiting charging equipment, vacuum pumps and leak detectors equipment would be needed to enabling use of flammable refrigerants. 6 Prototype A pilot-level quantity of the selected models will need to be subjected manufacturing, to prototype production, trials and testing to establish the process and trials and testing fine-tune as needed and establish product performance through testing. The results would be fed back into the process and product design, to ensure smooth conversion. 7 Product certification Evaluation and certification of product performance will need to be obtained from external agencies. Might be needed for some standards units. 8 Process and safety Process and safety training will need to be provided to the training manufacturing, installation and maintenance personnel on alternative properties and handling, applications and safety precautions, process adjustments, installation and calibration of dies and on operating parameters, product operation and performance, installation, calibration and maintenance protocols and safety precautions 9 Technical assistance Technical assistance from national and international experts will be provided throughout the conversion process for various aspects of the conversion, such as component specifications and selection, technical and regulatory aspects, technical inputs for procurement, etc. 10 Storage of flammable National requirements regarding storage and use of flammable refrigerants refrigerants have to be implemented and approved by National safety authorities. (e.g. worker safety) 5. Legal and Regulatory Framework Requirements 5.1 Relevant International legal documents - The Vienna Convention for the protection of the Ozone Layer and it’s the Montreal Protocol on substances that deplete the Ozone Layer as well as the London (1990), Copenhagen (1992), Beijing (1997) and the Montreal (1999) Amendments to the Protocol. - The Agreement between Government of Vietnam and the Executive Committee of the Multilateral Fund for the implementation of the Montreal Protocol for the Reduction in Consumption of HCFCs. - The Trust Fund Grant Agreement between Vietnam Government and The International Bank for Reconstruction and Development (The World Bank) for the implementation of Vietnam National HCFC Phase-out Management Plan Stage I that was approved by the Executive Committee of the Multilateral Fund. 5.2 National laws and regulations National law and regulations listed below should be applied for the environmental management of the conversion to HCF-32, HC-290 and NH3 in the refrigeration manufacturing enterprises. 10 Table 5-1: Relevant National Laws and Regulations National Laws and Regulations Effective Date Remarks to enterprises Regulations on Environment and Safety Law on Environment Protection No 01/01/2015 Change on EIA 55/2014/QH13 dated 23 June 2014 Requirement Decree No. 18/2015/ND-CP dated 14 01/04/2015 Enterprises required to February 2015 by Government, providing prepare the EIA/EMP details regulations on environmental should follow new Decree. protection plan, strategic environmental assessment, environmental impacts assessment and environmental protection plan Decree No. 19/2015/ND-CP dated 14 01/04/2015 February 2015 by Government on implementation guidance for environmental law Circular No. 27/2015/TT-BTNMT dated 29 06/2015 Enterprises required to May, 2015 by MONRE on guidance of prepare the EIA/EMP implementation of Decree No.18. should follow new Circular Circular 36/2015/TT-BTNMT dated 30 June Public the hazardous waste 2015 on hazardous waste management owner registration book Decree No.38/2015/ND-CP on Management Management of hazardous of Waste and Discarded Materials waste National Technical Standard QCVN 07: 2009 on thresholds of hazardous waste Circular No 48/2011/TT- BTNMT dated 28 Refer on changes of waste February 2011 on the Environment management and EIA Management and Protection at industrial approval for enterprises Zones located in industrial zones Decree No. 179/2013/ND-CP on the Maximum fine of 01 billion Sanction of Administrative Violations in the VND for individuals and Domain of Environmental Protection 02 billion VND for organization Law on occupational safety and hygiene Regulate safety and No.84/2015/QH13 dated 25 June 2015 hygiene conditions applied for all enterprises and individual worker Regulations on chemicals Chemical law No. 06/2007/QH12 dated 21 01/07/2008 November, 2007 Decree No. 108/2008/ND-CP dated 07 05/11/2008 October, 2008 by Government on implementation of chemical law Decree No 26/2011/ NĐ-CP dated 8 April 01/06/2011 HFC-32 (75-10-5) 2011 on the modification of the Decree Appendix IV and is the chemical No.1050, 108/2008/ND-CP on the implementation of Appendix VII NH3(7664-41-7) is the the Law on Chemicals chemical No. 1117 11 National Laws and Regulations Effective Date Remarks to enterprises and HFC-290 (74-98-6) is the chemical No. 1040 in the list of chemicals which require the measures on precautions, chemical emergency response. Circular No.04/2012/BCT dated 13 30/03/2012 February 2012 on classification and labels of chemicals Circular No. 20/2013/TT-BCT dated 5 15/10/2013 According to Article 12, August, 2013 on the implement of Decree chapter 3, the enterprises No.26/2011 and regulation of plans and need to prepare the measures on precautions, chemical measures and submit to emergency response for industrial sectors Department of Industry and Trading for approval TCVN 5507:2002 – Hazardous chemical – Safety regulation in production, trade, utilization, storage and transport Regulations on fire prevention and protection Law on fire prevention and protection No. 04/10/2001 All articles, fire prevention 27/2001/QH10 dated 29 June 2001 and protection Decree No. 35/2003/ND-CP dated 04 March 2003 by Government on implementation of the Law 27/2001/QH10 on fire prevention and protection Law No.40/2013/QH13 dated 22 November, 01/07/2014 2014 on amended law of fire prevention and protection Decree No.79/2014/ND-CP by Government 31/07/2014 on implementation of amended laws Circular No 11/2014/TT- BCA of the 12/03/2014 Enterprises should Ministry of Police on Fire prevention and prepare the Fire protection dated 12 March, 2014 on detailed prevention and protection regulations in Decree No. 35/2003/ND-CP document following the dated 04 March 2003, Decree No. PC-10 template mentioned 46/2012/ND-CP dated 22 May 2012 in this circular. Circular No. 66/2014/TT- BCA of the Ministry of Police on Implementation of Decree No. 79/2014 TCVN 3890:2009 on fire prevention and fight equipment for house and structures – Equipment, installation, inspection and maintenance Law on Standards and Technical Applicable Regulations of Vietnam No. 68/2006/QH11 standards/national dated on June 29, 2006, ratified by 11th technical National Assembly of Vietnam Socialist regulations Republic 12 Applicable National Technical Guidelines/Standards QCVN 07:2009/BTNMT: National technical regulation on hazardous waste thresholds. National Technical Standard TCVN 5507: 2002 regarding Hazardous chemicals – Code of practice for safety in production, commerce, use, handling and transportation. Discharge, emission, and Waste management shall meet minimum requirement as stated on the QCVN 06:2009/BTNMT; QCVN 07:2009/BTNMT, QCVN 14:2006/BTNMT; QCVN 40:2011/BTNMT, QCVN 08-MT:2015/BTNMT requires that the licensed factories shall always comply with the established standard for discharging waste and emitting pollution. In general, refrigeration production processes do not generate waste water and emission of air contaminants directly except the factory that has pre-treatment process of the metal parts for powder coating. In the refrigeration factory that has waste water from metal cleaning pits, must ensure the quality of discharged effluent always within the limits. There are regulations on management of waste and discarded material (Decree No.38/2015/ND- CP) and hazardous waste management (Circular 36/2015/TT-BTNMT) on guidance for transportation, storage, handling and disposal of chemical and hazardous substance packages (TCVN07:2002). Law on Occupational Safety and Hygiene (2015)  Occupational Safety, Health Law 2015.  Ministerial Regulation of Occupation Safety, Health, biliteral circular No.14/1998/TTLT-BLDTBXH-BYT-TLDLDVN dated 31 October 1998 Section 2, Item 2.1 General, roles and responsibilities of appointed safety officers.  Ministerial Regulation of Occupation Safety, Health, biliteral circular No.14/1998/TTLT-BLDTBXH-BYT-TLDLDVN dated 31 October 1998 also promulgates the reporting employee accident, injury/illness and lost.  Ministerial Regulation of Occupation Safety, Health, biliteral circular No.14/1998/TTLT-BLDTBXH-BYT-TLDLDVN dated 31 October 1998 promulgates the preparation and implementation of occupational safety plan This law is empowered by the 13th National Assembly (No.84/2015/QH13) to make sure that industrial sector in Vietnam are built their factory building and utilities, install machineries and equipment, operate their production in a way that causes no harm to workers, community and environment. To achieve that general aim, the authority uses their power through the process of granting licenses to the enterprises. Electrical system inspection and maintenance Depending on technical requirements and installed equipment, enterprises have to compromise with QCVN 01:2008/BCT on electrical safety of MOIT. There are series of regulation on electrical safety which the enterprise should take into account such as: QCVN QTĐ 5:2009/BCT, QCVN QTĐ 6:2009/BCT, QCVN QTĐ 7:2009/BCT, QCVN QTĐ 2:2008/BCT. There is notification on occupational safety related on electrical equipment issued by Ministry of Labor, Invalids and Social Affairs in QCVN 12:2012/BLĐTBXH. Fire precautions and preventions 13 Law on fire prevention and protection No. 27/2001/QH10 and No.40/2013/QH13. National Technical Regulations QCVN 06:2010/BXD by Ministry of construction regarding fire safety prevention for buildings and structures. National Technical Standard TCVN 3890:2009 regarding Fire Prevention and Protection Equipment for buildings and structures – arrangement, check and maintenance. National Technical Standard TCVN 5760 regarding Fire Prevention and Protection System – General requirement on design, installation and utilization. National Technical Standard TCVN 5507: 2002 regarding Hazardous chemicals – Code of practice for safety in production, commerce, use, handling and transportation. National Technical Standard TCVN 2662: 1995 regarding Fire Prevention and Protection for Buildings and Structures – Design Requirements Emergency response Where required, LPG and HFC-32 are classified as hazardous substances, manifests or registers shall be established and shall comply with legislative requirements issued by the Department of Industry and Trading and Department of Natural Resources and Environmental. The plans or measures for chemical precautions and emergency response should be submitted to and approved by Department of Industry and Trading before commissioning as regulated by the Decree No.26 and Circular No.20/BCT. First aid requirements shall be assessed, and the first aid system shall be appropriate to the operational risks. 5.3 WB Policies and Other Guidelines Of the 10 safeguards policies of the Bank, Environmental Assessment OP 4.01 is triggered and probably OP 4.12 (in few specific case if the resettlement is needed). In addition, the World Bank Group Environment, Health and Safety Guidelines (EHS) on Gas distribution system and the ISO 817:2014 on Refrigerants – Designation and safety classification, are recommended to follow to address safety requirements associated with the hydrocarbon technology. 5.4 Stakeholder Consultation and Public Disclosure The Project Stakeholder Consultation of Environmental Management Plan (EMP) for the refrigeration sector under HCFC Phase out Project stage II was organized at 2 rounds such as: (i) be consulted by surveyed enterprises during the Bank due diligent; and (ii) the stakeholder meeting hold at meeting room of the World Bank on 17 November, 2016. The first consultancy, aimed at exploring the potential risks and challenges for converting the refrigerants, was addressed during the due diligent mission of the World Bank team from 6 to 10 November, 2015; 26 January, 2016, and from 12 August to 16 September, 2016. There 14 were 9 participants from relative agencies attending this consultation, including Phuong Nam, SAREE, REE, Midea, Metero, Darling, Ngo Long, 6M, VietTrust meeting. The main objective of the second stakeholder consultation meeting was to present the content and goal of the EMP for refrigeration manufacturers comprising of general risk assessment for refrigeration sector, local regulations applicable for the refrigeration enterprises, local regulations specific for HFC-32 and HC-290 refrigerant and proposed mitigation measures for the conversion from HCFC-22 to HFC-32 and HC-290 refrigerants. More details of the consultation and stakeholders recommendations are provided in Annex 9 . All the comments from stakeholders was included in the final generic EMPs, which was disclosed on the website and office of the Bank, PMU and enterprises from 18 November, 2016. Due diligence: A due diligence review of Environmental and Social Safeguard on occupational health and safety measures, fire and exposure risk will be conducted during the commission of subprojects and the early operation phase by the PMU. The Bank team will also selectively visit some subprojects to carry out safety and environmental review as well to ensure the full EMP implementation. 6. Overview of Environmental and Social Impacts and Mitigate Measures In general, many major air conditioning manufacturers have determined that HFC 32 is the optimum choice for use in their products due to its advantages such as following: - Zero Ozone Depletion - 1/3 GWP of HCFC-22 - Superior energy efficiency - High refrigeration capacity - Low pressure drop - Single component refrigerant easy to handle and recover - Low toxicity - Readily available (R32 is used in the manufacture of HCFC-22 which is a blend of 50% R32 & 50% R125) There have been a number of performance comparison made between HC-290 and HCFC-22 which indicates that HC-290 has 2-9% higher efficiency and lower recharge levels (approximately 0.10-0.15 kg/kW of cooling capacity), and miscibility with mineral oils (synthetic lubricants are not required), reduced compressor discharge temperature and improve heat transfer due to favorable thermo-physical properties. 6.1 Potential Environmental Impacts The main environmental and social impacts of the phase-out of CFC for refrigeration production due to change the refrigerants to HCF-32, HC-290 and NH3 are including: a) Social impacts: A Resettlement Policy Framework has been prepared to guide relocation and potential land issues if any during preparation of the subproject proposals (during the overall project implementation stage). Most enterprises have being operated and may not need relocation or land acquisition. In case of needed the Bank will review when and how the land was acquired or being acquired and the 15 enterprise relocation plan at the preparation stage of sub-projects. For each sub-project which require involuntary resettlement, if the land has been acquired before the grant agreement is signed, a due diligence review of the land acquisition process will be undertaken by the Bank team to confirm whether there is any legacy issues. b) Ozone depletion potential (ODP): The phase-out by the project of HCFC as blowing agent will contribute positively to the recovery of the ozone layer. HCFC-22 has ODP of 0.055 compared with zero value of HFC-32, HC-290 and NH3. In phase II, project is aimed to remove 55.3 tons of ODP, i.e. volume of HCFC-22 phase-out of 1,005 MT, of which 303 MT from refrigeration sector. c) Global climate change: HCFCs and HFCs are greenhouse gases with different global warming potentials (GWP). Due to a reduced formulation of CFC in refrigerants for refrigeration production, the impact on the global climate due to switching from HCFC to HFC and HC is by and large neutral; whereas switching to HFC-32 results in 76% reduction of GHG emissions. HFC-32 has only about one- third the GWP; HC-290 has about one-seventy of currently used HCFC-22; and NH3 has zero GWP. HFC is also improves the energy efficiency of equipment by 10% and could reduce the charging volume by 30% compared to HCFC-22. HFC-32 offers favorable GWP and lower charging volume. HFC-32 related CO2 emissions decrease by 76% thanks to the lower GWP and the charging volume reduction. c) Energy efficiency: The potential refrigerant effect of HFC-32 is 1.5 times that of HCFC-22. More specifically, pressure losses are lower with HFC-32 than HCFC-22 for the same capacity and the liquid density of HFC-32 is also 10% lower. Thus the piping diameter can be smaller. As a result, the charging volume can be 30% less than with HCFC-22. The cooling seasonal performance factor (CSPF) of HFC-32 is higher than conventional refrigerants. Its peak power consumption is also lower, helping to alleviate power shortages in large cities during periods of high demand. d) Occupational health and safety: All refrigerant gasses classified in ISO 817 can initiate some form of adverse health effect if the concentration is high enough, therefore it is technically incorrect to claim any classified refrigerant as “non-toxic”. However, compared to all other common refrigerants, HFC-32 requires the highest concentration level to cause any adverse health effect. International Standard ISO 817 defines 2 toxicity classes for refrigerants: Class A – Lower Chronic Toxicity and Class B – Higher Chronic Toxicity. R32 is categorized as Class A. Compared to all other Class A (Lower Toxicity) refrigerants such as R22, R410A, R134a, R290 (Propane) and R600a (Isobutane), R32 has the highest (safest) Acute Toxicity Exposure Limit (ATEL) of 220,000 ppm of the 99 refrigerants designated in Table 5 of ISO 8174. 4 http://www.arema.com.au/2012/wp-content/uploads/R32-Common-Questions-Sept-2014.pdf 16 It is noted that NH3 is toxic gas, classed as B2L, which is toxic and it is not suited for small and medium industries. e) Flammability and Safety: International Standard ISO 817:2014, segregates the flammability of refrigerants into 4 categories as follows: - no flame propagation (Class 1), lower flammability (Class 2L), flammable (Class 2) and higher flammability (Class 3). In general language these classifications are called Non Flammable, Mildly Flammable, Flammable and Highly Flammable. HFC-32 and NH3 fall into the “lower flammability” or Class 2L "mildly flammable" category. Under ISO 817, any refrigerant and air mixture that is capable of self-propagating a flame falls into one of the three flammable categories. Class 2L refrigerants present the lowest risk of the 3 flammable categories and are defined by having a burning velocity of less than 10 cm per second. The characteristic of this low burning velocity is that the flame front does not propagate readily in a horizontal direction. This is because the convection rise due to combustion creates a higher velocity than the burning velocity. This effectively means that a Class 2L refrigerant is not explosive if ignited because the flame only propagates in an upwards direction from the ignition point and not rapidly outwards in all directions. Table 6-1: ISO 817-2014 Safety Group Classification Flammability Low Toxicity A High Toxicity B Class 3 Higher flammability A3 Propane, Isobutene, Others B3 n/a Class 2 Lower Flammability A2 R-152a B2 R-40, R-611 R-32(675), R-1234yf(4), R- Class 2L Lower flammability A2L B2L Ammonia 1234ze (E)(6), Others R-410A(675), R-134a(1430), R- Class 1 No flame propagation A1 B1 R-123, R-245fa 407C(1770), Others A2L and B2L are lower flammability/mildly flammability refrigerants with a maximum burning velocity ≤ 10 cm/s (3.9 in./s). GWP value is indicated in parenthesis based on IPCC 4th AR. ISO 817 lists the burning velocity of R32 at 6.7 cm/s (0.24 km/h) and HC-290 is 39 cm/s in comparison the burning velocity of ammonia is 7.2 cm/s, and hydrogen is 317 cm/s (meanwhile R-22 is non-flame propagation). The burning velocity of a gas is the speed of the flame front relative to motionless gas. The actual flame speed can be several times higher due to the expansion of combusting gas in combination with the burning velocity. This is especially applicable to A2 and A3 refrigerants as their higher heat of combustion generates rapid expansion and turbulence to dramatically increase the flame speed. ISO 817 also requires a Class 2L refrigerant to have a heat of combustion of less than 19 MJ/kg. R32 has a heat of combustion of 9.5 MJ/kg; for ammonia it is 18.6 MJ/kg, for R-290 is 46.9 MJ/kg. Table 6.1 shows that HCFC-22 has been classified under Safety Group A1 based on the test result that indicates two characteristic; no flame propagation and lower toxicity. Meanwhile HFC-32 has been classified under Safety Group A2L because it is Lower flammability and Lower toxicity refrigerant with a maximum burning velocity of less than or equal 10 cm per 17 second. More detail information indicated safety data for refrigerants such as HCFC-22, HFC-32, HC-290 and NH3 can be found in Annex 5. f) Soil and water pollution: Other chemical involved in refrigeration production is the synthetic Polyol ester (POE) oil. POE oil is a family of synthetic lubricants. Unlike natural mineral oils, POE oil is completely wax-free and is the best choice of lubricants due to their better thermal stability, more miscible and highly biodegradable. POE oils are more hygroscopic than mineral oils, so exposing POE oils to air will result in their absorbing moisture more quickly than mineral oils. When POE oils are exposed to moisture and heat, they may react, forming acid that is harmful to the system. POE oils should also be stored properly in their original container because many plastics used to package oils are permeable to moisture. It is also important to keep compressors and systems closed, except when work is actually being done on the equipment, and to filter out undesirable contaminants. This can be achieved with proper installation and service techniques as well as the use of correct filters and driers. The proper technique should be applied to recover the POE to avoid the discharges could affect on surrounding environment cause water or soil pollution. g) Local air: the alter refrigerants are not toxicity therefore not harm to environment and health. However, the accumulative concentration at one site could result in falling into range of lower explosive limits to upper explosive limits and causing fire. When fire exists, it will damage and cause significant air pollution. h) Solid waste management: Improper disposal of contaminated containers could be a problem for waste management especially for gases tank and broken products. However, this is not issue because all enterprises have to sign the contract for collecting and treatment their waste properly. 6.2 Environmental and Social Impacts Mitigation Measures The 34 refrigeration manufacturers have existed and operated. Due diligence review found that there is not large scale of land requirement or social impacts. During project implementation phase, it they need to move in the industrial zone, the procedures for undertaking land due diligence review is presented as bellowed: a) PMU/MONRE submits to the Bank, a report containing general information on the actual status of the resettlement and compensation on the proposed project enterprises (within the selected IZ) as part of the package required for the subproject grant appraisal submission procedures. b) World Bank undertakes a due diligence (DD) of the resettlement and compensation in the selected area. The DD serves to confirm that involuntary resettlement and compensation in the proposed IZs is completed or substantially advanced. It will confirm that was undertaken following government norms and regulations and for general consistency with Bank policies and objectives. Additionally, it should confirm pending issues as per Grievances and Redress Mechanisms reports of the pertinent authorities, recommending actions to be followed. Preparation of Abbreviated RAPs. An abbreviated RAPs (A-RAP) if applicable will be prepared for subprojects (as part of the sub-project proposals) to handle the relocation and potential land issues. Possible social issues if any outside resettlement will be reviewed as an annex to the 18 generic EMP, as no significant social issues are expected. For the enterprises have to be relocated to industrial zone, the relocation progress and construction will be done before implementing the alter refrigerants. Therefore, there is almost no impacts during construction phase or the construction work requirements will be very minor (if need to redesign the manufacture). The mitigation measures in the construction phase for the non-relocated enterprises are likely minor. The Table 6-2 below summarizes the adverse impacts of chemicals used, key mitigation measures and residual impacts for the refrigeration production during the operation phase. 19 Table 6-2: Summary of Chemical Impacts and Key Mitigation Measures for Refrigeration production due to change the refrigerants Chemical Theoretical impact Potential impact in Key mitigation measures refrigeration production Difluoromet ENVIRONMENT IMPACTS ENVIRONMENT - Avoid all possible sources of ignition (spark or flame). Do not hane (HFC- This material is considered IMPACTS pressurize, cut, weld, braze, solder, drill, grind or expose containers to 32) hazardous by the OSHA Danger, extremely heat or sources of ignition. Do not allow gas to accumulate in low or CAS No. 75- Hazard Communication flammable gas. May confined areas. 10-5 Standard (29 CFR form explosive - Efficient and adequate extract ventilation. 1910.1200). mixtures with air. - Promptly isolate the scene by removing all persons from the vicinity of Contains gas under the incident if there is a fire. No action shall be taken involving any pressure; may explode personal risk or without suitable training. Contact supplier immediately if heated. May cause for specialist advice. Move containers from fire area if this can be done frostbite. May displace without risk. Use water spray to keep fire-exposed containers cool. If oxygen and cause rapid Ecotoxicity involved in fire, shut off flow immediately if it can be done without risk. suffocation. If this is impossible, withdraw from area and allow fire to burn. Fight LC50 Inhalation Gas for Rat fire from protected location or maximum possible distance. 3780 mg/m³ when exposed 1 Highly reactive or - Fire-fighters should wear appropriate protective equipment and self- hour; incompatible with the contained breathing apparatus (SCBA) with a full face-piece operated in following materials: LC50 Inhalation Vapour for Rat positive pressure mode. oxidizing materials and 1890 g/m³ when exposed 4 acids. More detailed measures in Fire precaution and fight plan report. hours; Bioaccumulative potential: Low; The product is stable. LogPow : 0.21 Under normal conditions of storage Chemical Theoretical impact Potential impact in Key mitigation measures refrigeration production and use, hazardous reactions will not occur. OHS IMPACTS OHS - First Aid measures: + Flush contaminated skin with plenty of water. Remove Skin contact – No known The direct contact of contaminated clothing and shoes. To avoid the risk of static significant effects or critical HFC-32 can be harmful discharges and gas ignition, soak contaminated clothing thoroughly hazards. to skin. with water before removing it. Get medical attention if symptoms occur. Wash clothing before reuse. Clean shoes thoroughly before reuse. Eye contact – No known significant effects or critical + Immediately flush eyes with plenty of water, occasionally lifting the hazards. upper and lower eyelids. Check for and remove any contact lenses. Continue to rinse for at least 10 minutes. Get medical attention if Inhalation – No known irritation occurs. significant effects or critical _+Remove victim to fresh air and keep at rest in a position hazards. comfortable for breathing. If not breathing, if breathing is irregular or Frostbite - Try to warm up the if respiratory arrest occurs, provide artificial respiration or oxygen by frozen tissues and seek medical trained personnel. If unconscious, place in recovery position and get attention. medical attention immediately. Maintain an open airway. Loosen tight clothing such as a collar, tie, belt or waistband. Ingestion – As this product is a - Hazard communication and training programs to prepare workers to gas, refer to the inhalation recognize, prevent and respond to workplace chemical hazards section. ACCIDENTS RELEASE Explosion if not Evacuate surrounding areas. Keep unnecessary and unprotected Chemical Theoretical impact Potential impact in Key mitigation measures refrigeration production Accidental releases pose a handled correctly personnel from entering. Shut off all ignition sources. No flares, serious fire or explosion smoking or flames in hazard area. Avoid breathing gas. Provide hazard. adequate ventilation. Wear appropriate respirator when ventilation is inadequate. Put on appropriate personal protective equipment. Ensure emergency procedures to deal with accidental gas releases are in place to avoid contamination of the environment. Inform the relevant authorities if the product has caused environmental pollution (sewers, waterways, soil or air). Implement the measures in Fire precaution and fire fighting plan. Immediately contact emergency personnel. Stop leak if without risk. Spill, leakage Use spark-proof tools and explosion-proof equipment. Spills, leakage - Avoid any spills during the storage and production by means of constructing storage facilities. Strictly implement the measures listed in the Chemical emergency precaution measures. Synthetic Non-hazardous mixture of When POE oils are - Proper installation and service techniques, as well as the use of the Polyol ester synthetic polyol ester exposed to moisture correct filter driers and moisture indicators to minimize water contact. oil (POE 32 and heat, they may - Use filter driers remove moisture circulating through the refrigeration & 68) HMIS Hazard Ratings: Fire react, forming acid that system and then hold that moisture to prevent it from contaminating the – 1, Health – 0, Reactivity is harmful to the system expansion device, evaporator, compressor, or oil. – 0, Specific – 0 and difficult to be recovered. - Personal Precautionary Measures: Avoid contact with eyes and skin. Wash thoroughly after handling. Do not breathe vapors or fumes.  Inhalation: Low hazard for OHS impacts Inhalation: If symptomatic, move to fresh air. Get medical attention if Chemical Theoretical impact Potential impact in Key mitigation measures refrigeration production usual industrial handling by Product is considered symptoms persist. Eyes: Immediately flush with plenty of water for at trained personnel. stable. Carbon least 15 minutes. Get medical attention. Skin: Remove contaminated  Eyes: Causes irritation. monoxide and clothing, wash affected skin with soap and water immediately. Get  Skin: Low hazard for unidentified organic medical attention if symptoms occur. Ingestion: Drink plenty of usual industrial handling by compounds may be water. Get immediate medical attention. trained personnel, see label formed during - Prevention of Fire and Explosion: Keep from contact with oxidizing warnings. combustion. materials, alkalis and acids. Store away from heat, sunlight and  Ingestion: Components are Acute toxicity data: not moisture of low oral toxicity. available - Leaks should be stopped. Absorb spill with vermiculite or other inert Explosion if not material, then place in a container for chemical waste. Large liquid handled correctly spills should be removed by using a vacuum truck, flush spill area with water spray. Prevent run-off from entering drains, sewers, or Large Spill streams, collect run-off. Solid spills should be scooped up and placed in approved containers for disposal. The spill area should then be flushed with water followed by liberal covering of sodium bicarbonate. Propane ENVIRONMENT IMPACTS ENVIRONMENT - Avoid all possible sources of ignition (spark or flame). Do not (HC-290) This material is considered IMPACTS pressurize, cut, weld, braze, solder, drill, grind or expose containers to CAS No. 74- hazardous by the OSHA Danger, extremely heat or sources of ignition. Do not allow gas to accumulate in low or 98-6 Hazard Communication flammable gas. May confined areas. Standard (29 CFR form explosive - Promptly isolate the scene by removing all persons from the vicinity of 1910.1200). mixtures with air. the incident if there is a fire. No action shall be taken involving any Contains gas under personal risk or without suitable training. Contact supplier immediately pressure; may explode Chemical Theoretical impact Potential impact in Key mitigation measures refrigeration production if heated. May cause for specialist advice. Move containers from fire area if this can be done frostbite. May displace without risk. Use water spray to keep fire-exposed containers cool. If oxygen and cause rapid involved in fire, shut off flow immediately if it can be done without risk. suffocation. If this is impossible, withdraw from area and allow fire to burn. Fight Ecotoxicity fire from protected location or maximum possible distance. - Fire-fighters should wear appropriate protective equipment and self- Not available contained breathing apparatus (SCBA) with a full face-piece operated in positive pressure mode. Strictly implement the measures listed in the Bioaccumulative potential: Low; Biodegradation: The Chemical emergency precaution measures. LogPow :1.09 product is stable and not biodegradable. Bioaccumulation: has poor water-solubility Under normal conditions of storage and use, hazardous reactions will not occur. OHS IMPACTS OHS - First Aid measures: + Flush contaminated skin with plenty of water. Remove Skin contact – No known No specific data. contaminated clothing and shoes. To avoid the risk of static significant effects or critical discharges and gas ignition, soak contaminated clothing thoroughly hazards. with water before removing it. Get medical attention if symptoms occur. Wash clothing before reuse. Clean shoes thoroughly before reuse. Chemical Theoretical impact Potential impact in Key mitigation measures refrigeration production Eye contact – No known + Immediately flush eyes with plenty of water, occasionally lifting the significant effects or critical upper and lower eyelids. Check for and remove any contact lenses. hazards. Continue to rinse for at least 10 minutes. Get medical attention if irritation occurs. Inhalation – No known +Remove victim to fresh air and keep at rest in a position comfortable significant effects or critical for breathing. If not breathing, if breathing is irregular or if hazards. respiratory arrest occurs, provide artificial respiration or oxygen by Frostbite - Try to warm up the trained personnel. If unconscious, place in recovery position and get frozen tissues and seek medical medical attention immediately. Maintain an open airway. Loosen attention. tight clothing such as a collar, tie, belt or waistband. Ingestion – As this product is a gas, refer to the inhalation - Hazard communication and training programs to prepare workers to section. recognize, prevent and respond to workplace chemical hazards ACCIDENTS RELEASE Explosion if not Evacuate surrounding areas. Keep unnecessary and unprotected Accidental releases pose a handled correctly personnel from entering. Shut off all ignition sources. No flares, serious fire or explosion smoking or flames in hazard area. Avoid breathing gas. Provide hazard. adequate ventilation. Wear appropriate respirator when ventilation is inadequate. Put on appropriate personal protective equipment. Ensure emergency procedures to deal with accidental gas releases are in place to avoid contamination of the environment. Inform the relevant authorities if the product has caused environmental pollution (sewers, Chemical Theoretical impact Potential impact in Key mitigation measures refrigeration production waterways, soil or air). Immediately contact emergency personnel. Stop leak if without risk. Use spark-proof tools and explosion-proof Spills, leakage equipment. Implement the measures in Fire precaution and fire fighting Spills, leakage plan. - Avoid any spills during the storage and production by means of constructing storage facilities. More detailed measures are listed in the Chemical emergency precaution measures. Amonia ENVIRONMENT IMPACTS ENVIRONMENT - Avoid all possible sources of ignition (spark or flame). Do not (NH3) This material is considered IMPACTS pressurize, cut, weld, braze, solder, drill, grind or expose containers to CAS No. acute toxic by GHS-US. Flammable gas, contain heat or sources of ignition. Do not allow gas to accumulate in low or 766664-41-7 gas under pressure; may confined areas. explode if heated; toxic- Promptly isolate the scene by removing all persons from the vicinity of if inhaled, causes severe the incident if there is a fire. No action shall be taken involving any skin burns and eye personal risk or without suitable training. Contact supplier immediately Ecotoxicity damage, very toxic to for specialist advice. Move containers from fire area if this can be done aquatic life; corrosive without risk. Use water spray to keep fire-exposed containers cool. If LC50 Inhalation Gas for Rat to the respiratory tract. involved in fire, shut off flow immediately if it can be done without risk. 7338 mg/m³ when exposed 1 If this is impossible, withdraw from area and allow fire to burn. Fight hour; No reactivity hazard, fire from protected location or maximum possible distance. LC50 Inhalation Vapour for Rat Stable under normal 3000 g/m³ when exposed 4 conditions. - Fire-fighters should wear appropriate protective equipment and self- hours; contained breathing apparatus (SCBA) with a full face-piece operated in Biodegradation: The LC50 fish 1: 0.44 mg/l positive pressure mode. More detailed measures in Fire precaution and substance is (Exposure time: 96 h - Species: fight plan report. biodegradable. Unlikely Chemical Theoretical impact Potential impact in Key mitigation measures refrigeration production Cyprinus carpio) to persist. - Hazard communication and training programs to prepare workers to EC50 Daphnia 1: 25.4 mg/l Not expected to recognize, prevent and respond to workplace chemical hazards (Exposure time: 48 h - Species: bioaccumulate due to Daphnia magna) the low log Kow (< 4). Because of its high volatility, Under normal the product is unlikely to cause conditions of storage ground or water pollution. and use, hazardous reactions will not occur. OHS IMPACTS OHS - First Aid measures: + Immediately flush affected areas with plenty of water for at least 15 Skin contact – Cause serve No specific data. minutes while removing contaminated clothing and shoes. Call a skin burns. Immediate (acute) physician. Wash clothing before reuse. Discard contaminated shoes. health hazard Delayed + Immediately flush eyes thoroughly with water for at least 15 (chronic) health hazard minutes. Hold the eyelids open and away from the eyeballs to ensure Sudden release of that all surfaces are flushed thoroughly. Contact an ophthalmologist Eye contact – Cause serve eye pressure hazard Fire immediately. Get immediate medical attention. damage. hazard + Remove victim to uncontaminated area wearing self- contained breathing apparatus. Keep victim warm and rested. Call a doctor. Apply artificial respiration if breathing stopped. Inhalation – No known - Hazard communication and training programs to prepare workers to significant effects or critical recognize, prevent and respond to workplace chemical hazards hazards. Chemical Theoretical impact Potential impact in Key mitigation measures refrigeration production Ingestion – As this product is a gas, refer to the inhalation section. ACCIDENTS RELEASE Evacuate surrounding areas. Keep unnecessary and unprotected Accidental releases pose a Take care not to personnel from entering. Shut off all ignition sources. No flares, serious fire or explosion extinguish flames. If smoking or flames in hazard area. Avoid breathing gas. Provide hazard. flames are accidentally adequate ventilation. Wear appropriate respirator when ventilation is extinguished, inadequate. Put on appropriate personal protective equipment. explosive re-ignition may occur. Allow fire Ensure emergency procedures to deal with accidental gas releases are in to burn out. place to avoid contamination of the environment. Inform the relevant authorities if the product has caused environmental pollution (sewers, waterways, soil or air). Implement the measures in Fire precaution and fire fighting plan. Immediately contact emergency personnel. Stop leak if without risk. Spills, leakage Use spark-proof tools and explosion-proof equipment. Spills, leakage - Avoid any spills during the storage and production by means of constructing storage facilities. Strictly implement the measures listed in the Chemical emergency precaution measures report. 6.3 Proposed Measures for Handling and Safety Operating of Explosive Gases The refrigerants are delivered in a cylinder as it is liquefied gas. The given information above indicates HFC-32, when it released from the container and enter to the atmosphere, it will be turned to gas phase instantly because of very low boi l i ng point at below -400C. When it mixes with the air around the area of leaking, the first lowest concentration that the air mixture can be ignited is 12.7%. NH3 is similar to HCF-32 and has the first lowest concentration that the air mixture can be ignited is 15%, and the flash point is 110C. On the other hand, HC-290, when it released from the container and enter to the atmosphere, it will be turned to gas phase instantly because of very low b oi l i ng point. When it mixes with the air around the area of leaking, the first lowest concentration that the air mixture can be ignited is 1.8%. The general condition of refrigerant charging procedure has very low likelihood of HFC- 32 and HC-290 to be released uncontrollable and reach the lower flammable limit. However, in the event that refrigerants may leak out due to failure of connections, hose ruptures, the possibility to have HFC and air mixture at the level of lower flammable limit is likely. Well designed, and maintained equipment used in charging process will minimize the likelihood of uncontrolled release of HFC-32. On the other hand, poor connection, under specification hoses, seal and connector and combination with incompetent and unskilled worker who perform the task may increase the likelihood of leakage of HFC-32, NH3 and HC-290. In this case, the risk of fire in the charging area is increased. The air-HFC32 or air-HC-290 mixtures can cause flash fire. Because of the HFC-32 is almost 4 times and HC-290 is 1.6 times heavier than air. When it leak, the gas can travel along the lower area such as sump pit, drainage and find the way to be ignited by the ignition sources away from the location where it leak. The fire will flash back into the source of leaking and burn vigorously. Ventilation in the area where HFC-32 or HC- 290 is stored, handled and used is critical. Auto-Ignition temperature of HFC-32 is 530oC, of NH3 is 680 oC and of HC-290 is 287oC. At this temperature, the naked flame from brazing torch used at the assembly 61 line nearby or a small arc from electrical sockets due to poor installation can simply ignite the flammable atmosphere. Therefore, the additional safeguards to put in place before HFC-32, HC-290 and NH3 is to be used including: 1. Redesign of work area to keep distance where alternative refrigerant is used and the area where ignition sources from the adjacent process. 2. Redesign of storage facility. The use of electric fans from the ceiling, ventilation exhaust fans on the wall are example of the term “General ventilation”. 3. Installation of the Ex-Proof (explosion-proof) electrical equipment in the storage area, production line around alternative refrigerant charging, vacuum and also the electrical used in performance test labs. 4. Ex-proof type of transfer pumps, vacuum pumps, charging machines, and piping are required. 5. Ventilation system – general ventilation and local ventilation at the charging station. Because of HFC-32 and HC-290 is heavier than air, it tends to accumulate near the ground level. Well-ventilated area will eliminate the likelihood of HFC-32 or HC-290 in the air at lower flammable limit which can be ignited by the ignition sources. Generally, ventilation can be classified into two types; first is natural ventilation which is mainly benefit from building design and construction to have air movement naturally and no need additional mechanical devices, and second is artificial ventilation. This type requires mechanical devices such as exhaust fan, hood and ducts. General ventilation is simple way to induce air movement in the building. The term “Local exhaust ventilation (LEV)” is a ventilation system consisting of hood to capture air contaminants at the source of generation and move it through the duct. The exhaust fan creates suction at the face of the hood and makes the air contaminant to be ventilated away. 6. Gas detection and alarm system is recommended to be installed at:  HFC-32, NH3 or HC-290 storage area  Refrigerant charging area  Vacuum area  Finish good warehouse Flammable gas detectors can make a valuable contribution to the safety of these processes. They can be used to trigger alarms if a specified concentration of the gas or vapor is exceeded. This can provide an early warning of a problem and help to ensure people’s safety. However, a detector does not prevent leaks occurring or indicate what action should be taken. It is not a substitute for safe working practices and maintenance. Detectors can be fixed, portable or transportable. It is recommended to have ‘fixed’ detectors, permanently installed in a location mentioned above to provide continuous monitoring of HFC-32, NH3 and HC-290. The components 61 of a gas detection system include sensors, control unit and alarm. The position of the detection sensors for HFC-32, NH3 and HC-290 should be at the low level above ground surface due the fact that they are heavier than air and tend to accumulate there. The control unit or control panel of detection system should be located outside of the hazardous zone. The alarm should be installed at the locations mentioned above and at the location where general area can be alerted. It is also recommended that the alarm should be installed at security guard house. 7. Redesign or improvement on fire protection is required. Especially when large volume of container like 1 ton is to be stored, adequate fire water for cooling gas container to prevent Boiling Liquid Expanding Vapor Explosion (BLEVE). 8. Reviewing of fire emergency response plan shall be done to ensure that the local fire department is familiar with fire at the compressed gas cylinders. Fire water cooling system shall be redesigned to cover the alternative refrigerant storage area. 9. Training of the workers who handling HFC-32, NH3 and HC-290 to be aware of its physical properties, flammability, immediate health hazards and personal protective equipment to be used. The following proposed mitigation measures are made to the refrigeration enterprises participating in the HCFC Stage 2 project to take into consideration to implement in addition to their existing programs. Some of these mitigations are prescribed by Vietnamese laws and regulations, some of them are considered recognized best practices among the industrial sectors as recommended. 6.3.1 Building and Structure Safe access and egress shall be provided for personnel during normal and emergency conditions, including appropriate entry and exit from the building. Good housekeeping should be maintained in the area near the plastic injection to ensure no plastic is jammed inside the more and catch on fire. The designated walkway shall be kept clear. Management shall assess the security risks for all permanent and temporary places of work prior to use and after significant structural or layout changes have been made. Potential security controls include restricted access (e.g. by using fences, gates, locks or electronic card entry), the presence of security personnel, alarms, CCTV cameras, adequate lighting and signage. When practicable, buildings and structures shall be designed so that access to certain areas can be restricted to authorized personnel. It is recommended that the area where alternative refrigerants to be stored, LPG tanks, and the storage of Oxygen cylinders are sensitive and require security control. CCTV or regular patrol by security guard is suggested. The layout and condition of buildings and structures are designed and maintained to eliminate or effectively control ergonomic risks, manual handling risks, exposure to noise, exposure to atmospheric contaminants or hazardous substances, exposure to extreme temperatures, slips, trips and falls, spills and leaks, fire and explosion and falling objects. 61 Use adequate protection from fire and explosion as required by laws and regulations. Managers shall ensure that established housekeeping standards are communicated and maintained, including arrangements for: safely storing tools, equipment and materials when not in use ensuring that passageways, pathways, aisles, emergency exits and equipment are not obstructed maintaining the cleanliness of work areas and amenities identifying and removing any slip and trip hazards. 6.3.2 Safety Criteria for Construction of Storage Facility for refrigerants This guideline should be applied for the air conditioner manufacturing company who are seeking for instruction to make the storage facility for HFC-32 and other compressed gases, chemicals used in their facility safe. Table 6-3: Guidelines should be applied for the air conditioner manufacturing company for storage facility for HFC-32 and other compressed gases and chemicals. Structures TCVN 5507: 2002 and TCVN 2622:1995 Building wall, Wall/ compartment must be fire resistant material. Width and compartment and height of the fire wall has been defined by this guideline (Section 5 fire wall Safety Requirement, item 5.1.3) The refrigeration plant that plan to build new storage room for the alternative refrigerants must be aware that the new building which is located near the other building in 10 meter distance, the wall and compartment should be non-combustible materialpable of fire resistant for at least 120 minutes (in case that the storage facility is used for flammable materials – section 5.1.4). Storage area for compressed gases including HFC-32 shall be under the roof to prevent exposure directly to sun light. Floor To maintain good ventilation, solid wall is not recommended. Specific requirement for the floor of storage room for HFC-32 is conductive floor to prevent electro static charge. There should have no pits or drainage near the area where HFC-32 is stored Doors ways and The storage room must have at least 2 doors for entrance and exit. emergency exit The size of the door must meet design criteria. Emergency light, safety signs are required. Roof non-combustible material Ventilation system Required and must meet specified criteria. Electrical system Meet Engineering design criteria. HFC-32 and other refrigerants storage room requires meeting Explosion Proof type and electrostatic charge protection, grounding. Emergency lighting Required at least at doors and exit. Electrical Gases storage room requires to meet Explosion proof type appliances and electrostatic charge protection, grounding 61 Lightning Building near the storage room in the distance 30 meter must protection have lightning system. The design must meet Engineering design criteria. Detection and Detectors can be fixed, portable or transportable. It is recommended alarm system to have ‘fixed’ detectors, permanently installed in a location mentioned above to provide continuous monitoring of HFC-32. The components of a gas detection system include sensors, control unit and alarm. The position of the detection sensors for HFC-32 should be at the low level above ground surface due the fact that HFC-32 is heavier than air and tend to accumulate there. The control unit or control panel of detection system should be located outside of the hazardous zone. The alarm should be installed at the locations mentioned above and at the location where general area can be alerted. It is also recommended that the alarm should be installed at security guard house. Fire protection Fire extinguishers, portable or fixed system. system Fire water Must have adequate fire water based on the size of storage facility. LPG and HFC-32 storage tanks can explode in case of fire. Cooling storage tanks with sufficient of water is to prevent Boiling Liquid Expanding Vapor Explosion. 6.3.2 Plant Equipment, Machineries Hazard Identification and Risk Management Hazards review of process equipment for either new or existing facilities. Occupational, Health and Safety laws and Regulations set out specific safety requirements for all power-operated plant and equipment that every workplace shall enforce in order to meet their legal responsibility of providing a safe working environment. The following minimum mandatory requirements shall be implemented to ensure workplace compliance in relation to plant and equipment: The Site/Operations Manager or their delegate shall establish hazard identification and a risk assessment process for all existing plant and equipment in use at the workplace. An appropriate site based plant and equipment database shall be developed and maintained. A Plant and Equipment Risk Assessment shall be undertaken prior to purchasing any new plant and equipment, and during the design or modification of plant and equipment. In addition, the Plant and Equipment Design/Modification Hazard Identification shall be completed. Consultation shall occur with relevant employee representatives when conducting plant and equipment risk assessments. A maintenance program that includes inspections, maintenance and cleaning shall be established for plant. Safe Work Method Statement (SWMSs) and site Standard Operating Procedures (SOPs) shall be \developed for all medium-to high-risk tasks that are associated with the use, adjustment, cleaning, repair or maintenance of any plant and equipment. All plant and equipment shall be registered where required by legislation or the regulated governing body. All plant and equipment that poses a mechanical/electrical hydraulic pneumatic or kinetic hazard shall be appropriately guarded. All personnel using plant and equipment shall be equipped with suitable Personal Protective Equipment (PPE). All unsafe plant and equipment shall be identified 61 and quarantined or withdrawn from service. Appropriate induction and training, including high-risk training, shall be provided where required. 6.3.3 Electrical System Inspection and Maintenance Occupational, Health and Safety standards set out specific electrical safety requirements that every workplace shall enforce in order to meet their legal responsibility of providing a safe working environment in all Air conditioner production plant workplaces. The following minimum mandatory requirements shall be implemented to ensure workplace compliance in relation to electrical safety: All electrical work, equipment and materials shall fully comply with regulated Vietnam and recognized Industrial Standards, Local Regulations and this EMP. All electrical equipment and materials shall be fit for their intended purpose and the environment in which they are being applied. Electrical work shall only be undertaken by: Licensed Electricians. All electrical work must be supervised by a licensed Electrician with an Electrical Supervisors Qualification (A Qualified Electrical Supervisor can supervise themselves). Site/Operation Manager shall ensure that all electrical personnel are aware of the “No Live Electrical Work” rule. 6.3.4 Mobile Plant Equipment Inspection and Maintenance (applied depending case to case) To prevent accident during transporting refrigerant from one location to the other locations. All operators shall be assessed as competent and hold a current statutory license for the mobile plant that they operate where such a license is required. Employees shall complete a Mobile Plant and Vehicle Pre-Start Check prior to using mobile plant for each shift, and this shall be retained by the Front Line Supervisor. The selection, purchasing, leasing or hiring process for mobile plant shall include a thorough risk assessment to ensure that the vehicle is fit for its intended purpose. Standard Operating Procedures that cover all aspects of a mobile plant’s operational use and maintenance activities shall be developed. 6.3.5 Standard Operating Procedures and Safe Work Method Statement The purpose of this Standard Operating Procedure (SOP) is to develop and maintain safe systems of work for persons responsible for the use and handling of compressed oxygen, LPG gas, Refrigerant cylinders and pressure vessels associated with the air condition making process. Pressure equipment Regulated air receivers covered by (other than gas cylinders) shall be inspected, operated and maintained. 61 6.3.6 Accident Reporting and Investigation Procedure It is the obligation of management and designated personnel required by laws to have standard management system that cover reporting and investigation incident in the workplace. Any person involved in or close to any incident, shall notify the site/operations manager or supervisor. The site/operations manager or supervisor shall, as far as is reasonably practicable, make the area of any incident safe and prevent further escalation. Immediate first aid, medical and other assistance shall be provided to any injured person. The site/operations manager or their delegate shall ensure that all relevant persons are informed of the incident in accordance with the incident consequence rating. The scene of an incident, where appropriate, shall be secured for incident investigation purposes. All incidents shall be reported to management and communicated in accordance with their consequence rating. All incidents shall be recorded. All incidents shall be investigated by a team, which is formed in accordance with the incident consequence rating. The investigation team shall identify the corrective actions required to prevent a re- occurrence of the incident, using controls selected in descending order from the Hierarchy of Control. 6.3.7 Permit To Work Procedures The hazards, risks and controls associated with a particular task shall be identified, assessed and understood by those carrying out the work. Risk control measures shall be developed and implemented. For example, a group of maintenance and out-sourced contractor are about to remove a section of roller conveyor near the refrigerant charging area. The tasks they are going to perform generate ignition sources from cutting, grinding and welding. In this example situation; the interactions between maintenance work, construction work and plant operations shall be safely managed. All personnel either issuing or receiving a Permit to Work shall be authorized to fulfill that role. The critical roles are, to be someone who gives permission and to be someone who receives permission. These does not means to create new position or to hire additional man power. It is the working procedure that nobody should just bring the tools and start working then causing fire and explosion in the production area without any controls. 6.3.8 Warehouse and Storage Facilities Management, Hazardous Material Handling and Storage There are specific regulation related to the qualification of workers who involve in receiving, unloading, handling and storage of compressed gases used in air conditioner production factory that need to be complied. The following minimum mandatory 61 plant workplace requirements shall be implemented to ensure Air conditioner production compliance in relation to hazardous substances and dangerous goods: Adequate storage shall be provided for hazardous substances, which may include suitable containers, adequate segregations and separation and loss containment. Containers, tanks, pipes, plant and storage areas associated with hazardous substances and dangerous goods shall be clearly and appropriately labeled. The suppliers of refrigerants, LPG, N2 and Oxygen shall be carefully selected and ensure that the compressed gases purchased and used in air conditioner production always meet the safety standards specified by authority. A Hazardous Substance Risk Assessment shall be conducted to identify the hazards involved with the use of each hazardous substance or dangerous goods, and the likelihood of these hazards causing injury or harm. Material Safety Data Sheets (MSDSs) shall be obtained for all hazardous substances and made available to all employees in hard copy as a minimum. All employees shall be trained in using and handling Hazardous Substances. Personal Protective Equipment (PPE) appropriate and necessary for handling hazardous substances and dangerous goods shall be provided and maintained in good condition. Adequate first aid facilities appropriate to the hazards associated with hazardous substances shall be readily available. Warehouses should be designed and laid out to allow for the safe movement of goods, materials and people. The warehouse design and layout should consider: Storage areas and the appropriate width of aisles and gangways - slip, trip and fall hazards - pedestrian and vehicle traffic routes and turning circles - staircases and ramps - lighting - ventilation - blind spots - emergency escape routes - speed limits - Surface type, condition, camber and slope. Information about the warehouse design and layout should be included in the Traffic Management Plan 6.3.9 Transportation and Traffic Management Site/operations managers or their delegates shall identify and assess all hazards related to powered mobile plant and vehicles at the workplace and the risk of people, facilities, plant and equipment coming into contact with those hazards. Appropriate controls to eliminate or minimize all identified risks shall be implemented. 61 A Traffic Management Plan especially in the area where transportation of flammable gases, refrigerants are taken place, shall be developed to ensure that pedestrians are physically separated (as far as is reasonably practicable) from all vehicles and powered mobile plant traversing or operating in any shared work space. Management shall consult key stakeholders (such as powered mobile plant operators and other employees) when assessing and developing a Traffic Management Plan. Site/operations managers or their delegates shall provide information and instruction to employees, contractors, customers and site visitors on the requirements of the Traffic Management Plan (e.g. through signage, workplace inductions and toolbox talks). All drivers and operators shall hold a current license or certificate and are required to be deemed competent to operate the relevant mobile plant or vehicles. Workplace inductions shall incorporate key traffic management requirements. Contractors performing work for the plant shall be inducted into the work area or workplace in which they will be working. Visitors who are at the workplace for the sole purpose of delivering or picking up goods shall remain on marked roadways, walkways or in the immediate proximity of their vehicles at all times when entering mobile plant areas. Children are not permitted in operating areas of air condition production plants. Any children visiting workplaces are to be supervised at all times. Employees shall supervise and, where applicable, escort all visitors to mobile plant work areas if they have not been officially inducted to the workplace. Employees, contractors and visitors shall observe all posted or marked signs, including speed limits, traffic flow directions and mobile phone exclusion zones, at all times. Employees, contractors and visitors shall wear high-visibility upper-torso garments at all times in areas where mobile plant operates, and shall remain on marked walkways (as appropriate). An auditing and review process shall be implemented to ensure that the Traffic Management Plan is current and to review the effectiveness of controls. Management shall provide adequate technical and financial resources to implement and maintain agreed controls. 6.3.10 Workplace Environmental Management Every workplace shall enforce in order to meet their legal responsibility of providing a safe working environment. The following minimum mandatory requirements shall be implemented to ensure workplace compliance in relation to health surveillance: Prospective employees and relevant contractors shall participate in a pre-placement 61 medical assessment using the Pre- and Post-Placement Health Assessment. 6.3.11 Personal Protective Equipment The Site/Operation Manager or Front Line Supervisor shall ensure that a PPE risk assessment is completed for all Personal Protective Equipment requirements. Appropriate signage which indicates the identified hazard and the required PPE shall be displayed wherever PPE is required to be worn. All employees (including management), contractors, and visitors shall wear PPE when required to do so. If contractors fail to wear the appropriate PPE their contract shall be reviewed and may be cancelled without further payment. Employees shall be consulted in the PPE selection process. All employees shall receive comprehensive training in the use of PPE relevant to their duties. When professional assessment deems it necessary, PPE shall be individually made and fitted to ensure maximum effectiveness. All PPE shall be stored and maintained according to the manufacturer’s specifications. Employees are expected to actively assist management in maintaining PPE. PPE audits shall be conducted regularly to ensure that the equipment offers maximum protection, and daily pre-use visual checks by the user shall occur to ensure the equipment is fit for use. If for any reason an employee cannot be equipped with the appropriate PPE (e.g. the employee has a medical condition that prevents them from wearing the item), they will not be permitted to enter the hazardous area. 6.3.12 Training and Certification Management Refer to: Occupational Safety, Health law by Ministry of Labor, Invalids and Social Affairs and Circular 27/2013/TT-BLDTBXH by MOLISA dated 18 October 2013 regarding training and certification on occupational safety and health. To ensure the level of knowledge, skills and competencies of employees who involve in storage, handling, charging, evacuating, and leak testing refrigerants, flammable gases, non-flammable compressed, liquefied gases, and hazardous materials in the production process of air conditioner. Occupational, Health and Safety (OHS) training objectives and targets and performance indicators shall be identified, monitored and evaluated for effectiveness. Resources shall be provided to ensure the effective implementation of the OHS training program. OHS training shall be provided to ensure persons understand and are aware of their OHS responsibilities. OHS Training shall ensure individuals required to perform work or operate equipment hold appropriate current licenses or certificates of competency in accordance with OHS legislative requirements Managers or supervisors shall ensure all persons under their authority can demonstrate competency to perform the work or operate equipment and not be solely reliant on the person’s license or certificate 61 as proven competence. OHS skills and knowledge requirements relating to contractors and the supply of labor shall be documented and communicated to the supplier, before the purchasing/tendering process commences. Employees, other workers, visitors and contractors shall be inducted to the workplace. The level of induction will be relevant to the level of risk and supervision. A Training Needs Analysis shall be completed for each site or area. Training plans and programs shall be developed based on the skills of the persons and the outcomes of the training needs analysis. Differences in learning, language, literacy and numeracy skills of trainees shall be taken into account in training programs. OHS training shall include clearly stated learning outcomes and where relevant, include a competency or assessment activity related to the learning outcomes. 6.3.13 Emergency Response The site/operations manager or their delegate shall identify Potential emergency situations on, or in the vicinity of, the workplace and develop a Site Emergency Response Plan. Emergency procedures are documented and regularly reviewed. As the refrigerants are risk chemicals, a measure of precautions and chemical emergency response must be prepared and submitted to DoIT. The guidance of outline of this measure is proposed in Annex 3. Each workplace shall have an established communications system that allows effective communication. Each workplace shall establish immediately available internal and external emergency contact details. The site/operations manager or their delegate shall allocate overall responsibility for the control of emergency situations to specific individuals, and shall communicate this information to all employees by completing and displaying the Emergency Response Contacts. Competent personnel shall assess the suitability, location and accessibility of emergency equipment. Emergency and fire-protection equipment, exit signs and alarm systems shall be regularly inspected, tested and maintained. Where required, dangerous goods and hazardous substances manifests or registers shall be established and shall comply with legislative requirements. First aid requirements shall be assessed, and the first aid system shall be appropriate to the operational risks. Emergency exercises, drills and review of effectiveness shall be conducted and details documented at least once a year. 6.3.14 Waste Management In the production of air conditioner few types of solid waste are generated such as empty chemical drums, oil drums, waste paint sludge from paint booth, powder coating waste from dust collector, metal dust from metal workshop, etc. These61 shall be collected, contained, transferred, and disposed properly by contract with legal authorized agencies. Hazardous/special waste generator locations must be especially careful to comply with regulatory Requirements: Government authorities usually must be notified to obtain an identification number or License: A written waste management and/or contingency plan for emergencies may be required. Moreover, regulatory requirements include the followings: Waste storage; Labeling; Inspections; Manifesting (Duty of Care); Record-keeping; and Reporting. Documented training of employees handling or exposed to hazardous waste is also often required by Legislation. Note: all equipment that is removed and replaced with the HFC-32 shall be disassembled, and disposed by the approved waste disposers. 7. Estimated Budget for Mitigation Measures 7.1 Estimated cost for installation and change refrigerants The Tables below provide more details on conversion cost for the thirty-four enterprises. Table 7-1: Total Incremental capital cost for gas conversion of Refrigeration Enterprises Cost components Cost for Cost for enterprises enterprises in group in group 1a(US$) 2b(US$) 1 System, component and process redesign, prototype manufacturing 30,000 and testing, software for system design for different new 70,000 refrigerants 2 Sheet metal processing, changes of standard modules 20,000 10,000 3 Assembly line and area modifications, 35,000 30,000 -Charging area modifications to allow use of flammable refrigerants -Pressure testing equipment -Refrigerant charging equipment -Leak detectors -Vacuum pumps 4 Storage of flammable refrigerants, piping and transfer pumps 30,000 15,000 5 Prototype manufacturing, trials and testing 30,000 15,000 6 Quality specification and inspection, verification of performance 10,000 15,000 etc. 7 Process, operation, maintenance and safety training 25,000 10,000 8 Technical assistance and support 30,000 20,000 Sub-total 255,000 140,000 Contingency (10%) 25,500 14,000 Total ICC cost for Group 1 and Group 2 280,500 154,000 Source: FS, 2016. Not: a Group 1 includes companies manufacturing a full range of industrial refrigeration equipment (there are 7 companies); b Group 2 includes companies manufacturing a standardized refrigeration equipment 61 (there are 27 companies); The operation cost varied depending on capacity of each enterprises (see Annex 6). However the cost effectiveness is estimated as US$ 21.29 per kg of HCFC-22 which will be phased- out. Total incremental cost for refrigeration companies is about US$ 7,111,080 for eliminating 303 MT of HCFC-22. 7.2 Estimated annual cost for environmental management during operation phase During the operation phase, the enterprises should assign a technical staff to control the chemical spill and leakage, if any and the cost for this assignment should be monthly salary of average 6,000,000 VND for the whole operation cycle. For the waste collection, including empty chemical drums and foam wastes and hazardous wastes, the monthly cost should be 1,000,000 – 1,500,000 VND depending the location and contract with local environment servicing company and amount of waste. These costs will be borne by the beneficiary from their counterpart funding. Costs for maintain and calibrate (if need) the gas leak detector is needed. 8. Institutional Arrangement Organizations The following institutions are involved in the implementation of environment protection for the foam production conversion and refrigerants change: Enterprises that are eligible for funding under the Vietnam HPMP Stage I and II will conduct the conversion in accordance with sub-grant agreement to be signed between the Vietnam HPMP PMU and the beneficiary. The beneficiary will play the main role in implementing the environment management plan and in carrying out the mitigation measures during the conversion and after conversion operation. The enterprises have to prepare and submit documents on fire prevention and protection to Department of Police and report of measures or plans of chemical precaution and emergency responses to Department of Industry and Trading for approval. The enterprises have to have the license on fire prevent and protection before commission They also need to sign the contract with the assigned hazardous management companies for their industrial and hazardous waste treatments. The enterprise should prepare an Annual Environment Monitoring Report as requested by the Law and Regulations of the Country (twice a year) and submit to Department of Natural Resources and Environment. The Vietnam HPMP PMU, set up by MONRE and the Vietnam National Ozone Unit will manage and coordinate implementation of the HPMP and sub-projects in Stage I and Sateg II phase out plan. The PMU or its hired consultant will also monitor the subproject implementation and the beneficiary’s compliance with the occupational health and environment requirements. The PMU will report to the Bank all the progress reports, especially the environmental monitoring reports. The equipment suppliers who will be awarded the contract for providing equipment and service for the conversion will provide the refrigeration manufacturing equipment foam equipment and installation in the safe environment manners They also provide the technical trainings on safety operations of technology. 61 The local government including the Environment Protection Agency, Fire Protection Police and Industrial Zone Management Body, the Department of Industry and trading, Department of Industrial Safety Techniques and Environment (DISTE) and the Department of Chemicals (DC) of MOIT to be invited by the MONRE/PMU will participate in controlling the company’s compliance with the environment/fire protection regulations as per their functions defined by the Vietnam Laws. The correlation among these stakeholders is described by a chart as follows: The World Bank Ministry of Natural Resources and Environment HPMP PMU Under MONRE PMU-hired Consultants for Equipment suppliers and Project implementation, contractor monitoring and safety audit Enterprises (including Foam Producers, Air condition producers, refrigeration producers, Local Departments, enterprises, service, etc.) DIST, DC and fire Industrial Zone protection police, etc. Management Board Table 8-1: Responsibilities of Stakeholders for Implementation and Supervision of EMP Organization Responsibilities To bear all responsibilities, but under monitoring and supervision of the World Enterprises/ Bank and the PMU, for the conversion from HCFC-22 to HFC-32, HC-290, NH3 Producers for refrigerants. Technical assistance will be provided through the Project to these enterprises. To request the chemical supplier to provide safety data sheets for each chemical and full guidance and training on safety handling these chemicals To follow stringently the safety data sheets when handling these chemicals To assign technical staff to (i) monitor the compliance with the safety occupational health and environment requirements on using chemicals and (ii) monitor the compliance with safety requirements when working with HC-290, HFC-32, NH3 and fire protection rules during the conversion 61 process and after conversion operation. To have safety audit and fire safety certificate from the fire protection authority. To keep the workers continuously trained, in cooperation with PMU and chemical and equipment suppliers on the safe foam production; To take all necessary measures to prevent leakage of the foam chemicals during the manufacturing process. To carry out the mitigation measures described in the parts 3 above for each chemical and each case of chemical leakage. To have contract with local environment servicing company for collection and disposal of waste and empty chemical drums. To prepare the Site-specific mitigation measures for each sub-project as well, in addition to following the generic EMPs, as part of the subproject proposal during the project implementation stage To prepare an EIA following the national regulations in case that a new plant will be constructed to implement the HCFC phase-out subproject. To prepare and submit documents on fire prevention and protection to Department of Police To prepare and submit the measures on precautions and chemical emergency responses to submit to Department of Industry and Trading. To prepare Annual Environment Report and send it to the local government environment agencies as requested by the Laws and copy to the PMU for monitoring purposes. To fulfil with Environment Protection Commitment made by the Company as defined by the Government regulations. To sign the subproject grant agreement (GA) with each participating refrigeration The PMU of manufacturers. The sub-GA will list enterprise responsibilities and documents / Vietnam plans it is obligated to adhere to on implementation of the EMP. HPMP and To coordinate and supervise the subproject implementation, including all NOU environmental and safety requirements listed in Section 3 by hiring technical consultants as necessary To ensure the project implementation will achieve the HCFC phase-out target and safety requirements for the used chemicals and refrigerants in accordance with the National Law and regulations and the World Bank safeguard policies and guidelines To cooperate with Department of Industry Safety Techniques and Environment and the Department of Chemicals under MOIT and Local Environment Protection Agencies, Local Fire Protection Police, and the Industrial Management Body to carry out the enforcement measures for the environment protection for each foam producer involved in the conversion. To prepare the project progress and environmental monitoring reports To provide the environmentally safety design and installation of the production Equipment line of the air condition, refrigerator production using HFC 32. Suppliers To provide adequate training and guidance on safe operation of the supplied equipment, including the environmental and health risks and mitigation measures. To provide good after-sale service and warranty in the case of accident due to the technical faults. 61 Enforcement Local Environment Protection Agencies, Local Fire Protection Polices, Agencies: Department of Industry Safety Techniques and Environment, Department of Chemicals and Local IZ Management Body to be invited by the MONRE/MU to carry out the enforcement control and monitoring of the occupational health, environment and fire safety at each foam company. 9. Environmental and Safety Monitoring Requirements and Monitoring Plan The main environment and safety monitoring requirement for the HCFC phase out subproject is to assure negative impacts of the conversion on the occupational health and local environment could be reduced or prevented. The site environment management plan for the conversions to HFC-32 and HC-290 at air condition and refrigerator producers eligible for the Project funding should be in accordance with Decree 18/2015/NĐ-CP; Circular 27/2015/TT-BTNMT; the Circular No 40/2014/TT- BTNMT of the Ministry of Natural Resources and Environment on the Environment Management and Protection at industrial zones; and Circular of the Ministry of Police No 66/2014/TT-BCA on Fire Protection, and the Environment Protection Commitments of the company. The enterprises have to receive the licence on fire precautions and fighting before commissioning. The report of plans or measures on chemical precautions and emergency responses following the Circular of the Ministry of Industry and Trade No 20/2011/TT-BCT and the Government Degree 26/2011/ND-CP on the implementation of the Law on Chemicals. As practice, the surrounding environment at the Industrial Zones is monitored by the IZ management body and local environment agencies, and the Environment Monitoring Report is to be sent to the City/Provincial Department of Natural resources and Environment annually. In the case of large scale pollution or serious violation of the environment protection law and regulations, the environment police will conduct investigation and identify the responsibility of the personnel or organizational entities. The monitoring will be conducted during all phases of the conversion for refrigerants as HFC-32 at each enterprise by the enterprises, the PMU, local accredited agencies, and local authorities. It includes design and construction of the refrigeration workshop to meet safety requirement of new refrigerants usage, preparation of technical specifications of the equipment, installations and commissioning of procured equipment, trial, safety audit and production start up, and the collection and disposal waste and empty chemical drums during use of HFC-32, HC-290 or NH3 to replace HCFC-22. The Monitoring Plan is proposed as each of participating enterprise. The annual Environment Monitoring Report prepared by each enterprise and reported by the PMU to the Bank team should include the progress on all mitigation measures proposed in the Table 9-1 to address the environmental and safety impacts raised in Section 7. Table 9-1: Monitoring Plan During Conversion and Operation Phases Parameters Place/ Method of Time of Standard Monitoring Responsibi Report to to be location monitoring monitorin applied Cost lity monitored g Design of for Verification Before the Safety Included in Enterprises PMU and workshop production done by constructi requirements the 61 and PMU- the Bank sites technical on of the when conversion hired foam team (it consultant workshop working cost to be technical should be hired by the and with financed by consultant included PMU and accepted explosive the in the sub local by the gas enterprise project authorities if enterprises counterpart proposal) applicable funding Technical for Verifications Before Equipment Included in Enterprises PMU and specifications production done by procureme suppliers the to prepare; the Bank and sites PMU-hired nt of the standard conversion installation team appropriate consultant equipment cost to be will be (it should installation of and/or by s financed by included in be the enterprises the the included equipments enterprise equipment in the counterpart purchase sub-projec funding contract. t proposal) Parameters Place/ Method of Time of Standard Monitoring Responsibi Report to to be location monitoring monitorin applied Cost lity monitored g Preparation For Prepared by Before International Included in Enterprises local of Explosion production each production experience the to prepare authorities Protection sites enterprise start-up Law on fire conversion and PMU- , PMU Document and reviewed precaution cost to be hired and the (EPD) by PMU and financed by consultant Bank team consultant protections, the to review Decree No. enterprise Department .29/2014, counterpart of Police Circular No. funding will 6/2014. approve and issue the licence Preparation Enterprises Prepared by Before Decree Included in Enterprises local of site EMP each production No.18 and the to prepare authorities for cases of enterprise start-up Circular conversion and PMU- , PMU existing and reviewed No.27 cost to be hired and the factories by PMU financed by consultant Bank team consultant the to review enterprise counterpart funding For the new Enterprises EIA needs to Before the Local EIA Enterprises Local factories EIA be prepared constructi regulations preparation to hire authorities is required. by an on of new Decree will be part accredited for accredited factories No.18 and of the agencies/ approval agency hired Circular conversion individuals; of the EIA by enterprises No.27 cost and can PMU to be financed ensure that by enterprise the EIA is counterpart approved funding by relevant authorities Report of Enterprises Report needs Before Local Included in Enterprises DOIT measures on to be commissio regulations the prepare 61 chemical prepared by n Decree conversion precautions enterprise No.26 and cost to be and and reviewed Circular financed by emergency by No.20 the response DOIT enterprise counterpart funding Spills and Chemical Visually Continuou Chemical Enterprises Enterprise 6,000,000 leakage of storage sly suprplier’s and its manageme VND per chemicals (if and or as assigned nt body month for any) production described in staff and to one area Section 3 local technician/ above and authority staff to be Explosion in case of financed by Protection accident the Document Parameters Place/ Method of Time of Standard Monitoring Responsibi Report to to be locationmonitoring monitorin applied Cost lity monitored g ConcentratioStorage, Control panel Continuou Explosion enterprise Enterprises Enterprise n of gas mixing and and HC sly Protection counterpart and its manageme production sensors Document funding assigned nt body area staff Chemical Enterprises Neutralize As per Local 1,500,000 Enterprises IZ empty drums the remaining contract regulations VND per to have a Managem and wastes chemicals in weekly or month to be contract ent body the drums monthly financed by with or local and having the qualified authorities contractors enterprise waste and for collection counterpart company included of waste and funding and PMU in the empty drums will verify sub-projec the t proposal contract. Safety audit Enterprise Local Before International Eligible Enterprises local production authorities to foam experience expenditures to be authorities workshop review production and local to be prepared , PMU, documentatio start-up requirement financed by for the and the n and pay site the project safety Bank visits audit; PMU-hired consultant to review and local authorities to approve the safety measures Table 9-2: Recommended Environmental Monitoring Indicators Indicators Schedule Responsible party/person Accident statistics and Once a year Safety61 officer of enterprises reportingdisposal record Waste Once a year Safety officer of enterprises (from the production line) Waste disposal record (from Once Safety officer of enterprises conversion Maintenance process) of equipment Once a year Manager of assembly line in a good condition i.e. preventive maintenance and/or calibration audit Pre-commissioning After installation of equipment MỎNRE- PMU Post-commissioning audit After commissioning of MONRE- PMU equipment Implementation Schedule and Reporting Procedures The PMU would carry out supervision of the implementation of the conversion sub-project during the implementation period of 2017 – 2021 After receiving enterprises' Project Progress Report, all mentioned conversion activities would be reviewed by PMU and the details of conversion activities such as time of conversion, testing, trials, and the project Environmental Monitoring Report should be included in the Project Progress Report. All activities of enterprises' conversion would be reported to PMU and the World Bank. The report is to submit semi-annually to the World Bank by January 31 and July 30 each year and annually to MONRE. Table 9-3: Time Schedule for Implementation of the Environmental Management Plan Responsibl Monitoring/ Actions Schedule e Measurement Develop action plans against January 2017 party/perso Participating Approved action mitigation measures nEnterprises plan under sub-project Implement mitigation action plans, After signing of Participating Approved action re-layout, install new equipment. sub-grant Enterprises plan under sub-project agreement Re-arrange and construct storage After signing of Participating Approved action plan area for HFC-32 or HC-290 sub-grant enterprises under sub-project Agreement Install gas detectors and alarm at After installing Participating Approved action refrigerants charging, vacuum, leak new equipment Enterprises plan under sub-project testing, test labs, and warehouse. Install fire protection system at During and Participating Approved action storage area of HFC-32 and HC 290. after Enterprises plan under sub-project construction Provide training/ SOPs training After signing of sub-grant Participating Training records and coaching sub-grant agreement enterprises Agreement During conversion period of 2017 – 2020, enterprises should detail all activities of conversion in the Progress Report such as implementation timing, testing, trials and proto sample to be produced, and progress and results of mitigation and monitoring measures. Frequency and duration of mitigation measures and monitoring as well as remedial actions, if any, showing consequences in accordance with the phasing-out targets and schedule should be inclusive. A breakdown timetable consisting of detailed activities should be inclusive in the report. 61 Besides, the Annual Environmental and Safety Report prepared by enterprises should be submitted to provincial DONRE. The report of Plans/or Measures on chemical precautions and emergency response. A copy of both reports should be sent to PMU. The implementation schedule and reporting procedure will be the following: Table 9.4: Implementation Schedule and Reporting Procedure Implement Stakeholder/ ing Report on/to Time Frequency Organization schedule - The Project Implementation Progress 31 July and Semi- Reports of the conversion sub-project and 31 January annually PMU 2017 submit to MONRE/World Bank - The Project Environment Monitoring by the end of Report (with inputs from the enterprises), each quarter Quarterly including environment monitoring requirements/indicators listed in Table 6 and submit to the Bank - Annual Environment Monitoring By 31 Yearly Report required by the national and local December regulations prepared by the enterprise to each year Local Department of Natural Resources and Environment and copy to PMU. - Subproject Implementation Progress By 30 June Semi- Report to PMU and 31 annually December - Environment and safety issues, if any, to local authority and to PMU When needed - Notification to the chemicals and equipment suppliers and copy to the PMU When the Occasionally on any faults happened during the fault takes conversion and after conversion operation place Enterprises 2017 - Site-EMP report for existing enterprises or One-time EIA report for enterprises to build new reporting One time factories for implementation of subprojects before construction or installation starts and EIA should be approved by local EPA - Plans or Measures on chemical One time precautions and emergency response before One time commissionin g 61 and accepted by DOIT Supervision of sub-project implementation and environment requirements The Vietnam HPMP PMU will be responsible for supervision of the implementation of the conversion sub-projects. A PMU-hired monitoring technical consultant will undertake supervision and prepare quarterly Environmental Monitoring Reports. Environmental Compliance Framework Warranty of the equipment supplier and its responsibility in case of fire risk, accidents happening due to the fault of the system will be defined in the contract for equipment supply. Enterprises take full responsibility to implement the commitment seriously stated in the site- EMP, Explosion Protection Documents and Measures of Chemical Precautions and Emergency Responses. Any failure implementation or risks found, the enterprises have to report to and work with local authority to find the best solutions for production in the environmental friendly approach. 10. Training Plan The training for the enterprise technical staff and all workers of each Refrigeration company on the safe refirgeration production using HFC-32, NH3 and HC-290 will be conducted by the Vietnam HPMP PMU in cooperation with chemical and equipment suppliers and local fire polices and local EPAs. The training courses will be conducted regularly, particularly on preparation and commission stage of enterprises. Table 10-1: Training Plan Organizer Number of Participants Frequency Duration Content Budget Courses One at the The Montreal Protocol PMU in for each All technical 1-2 days USD beginning and HCFC phase out; cooperation enterprises staff and 25,000 of the Environment and fire with or group workers of project in risk during the chemical and enterprise enterprises early 2017 conversion and after equipment depending Before conversion operations suppliers and on scale production Environment and OHS local fire start up and risk mitigations polices/EPAs after measures conversion Safe handling of operation chemical and refrigerants. Chemical About twice and waste collection a year from and treatment 2018 to Emergency Responses 2020 in case of accidents Formulation of Explosion Protection Document 61 for each enterprise (guidance takes about one day per company – however can be done at one work shop) The training cost will be covered by the Project under the Project Component 2. It is estimated that the funding for these training activities will be 25,000 USD. References 1. ANSI Z49.1 2005 Safety in welding cutting and allied process 2. Asia Industrial Gases Association, SAFETY AUDIT GUIDELINES, AIGA 01405 3. Designation and Safety Classifications of Refrigerants, ANSI/ASHRAE Standard 34- 1997, ANSI/ASHRAE Standard 34-2010, ANSI/ASHRAE Standard 34-2007 4. Environmental, Health, and Safety (EHS) Guidelines GENERAL EHS GUIDELINES: INTRODUCTION, IFC World Bank 5. IPCC (Intergovernmental Panel on Climate Change). Special Report on Safeguarding the Ozone Layer and the Global Climate System: Issues Related to Hydro fluorocarbons and Per fluorocarbons, Special Report of the Intergovernmental Panel on Climate Change, Cambridge, England, 2005. 6. OP 4.01, Annex B - Content of an Environmental Assessment Report, OP 4.01 - Annex B January, 1999 revised May 2011 7. US EPA Ozone Layer Protection, Class II Ozone-depleting Substances 8. WMO (World Meteorological Organization), Scientific Assessment of Ozone Depletion: 2006, Global Ozone Research and Monitoring Project—Report No. 50, 572 pp., Geneva, Switzerland, 2007. 61 ANNEX 1 - Environmental Codes of Practice (ECOP) for Small Civil Works 1. Objectives The Environmental Codes of Practice (ECOP) is prepared to manage small environmental impacts during construction. The ECOPs will apply to manage small scale infrastructure investments subproject. ECOP will be a mandatory part of construction contract or bidding documents so that contractor complies with environmental covenants. PMU/VCIC and construction supervisors will be responsible for monitoring of compliance with ECOP and preparing the required reports. There are a number of national technical regulations related to environmental, health and safety that apply to construction activities below:  Water Quality: (QCVN 01:2009/BYT, QCVN 02:2009/BYT, QCVN 08:2008/BTNMT, QCVN 09:2008/BTNMT, QCVN 10:2008/BTNMT, TCVN 5502:2003; TCVN 6773:2000, TCVN 6774:2000, TCVN 7222:2002)  Wastewater (QCVN 14:2008/BTNMT; QCVN 40:2011/BTNMT)  Air Quality (QCVN 05:2013/BTNMT, QCVN 06:2008/BTNMT)  Soil Quality (QCVN 03:2008/BTNMT)  Solid Waste Management (TCVN 6696:2009, QCVN 07:2009)  Vibration and Noise (QCVN 27:2010/BTNMT, QCVN 26:2010/BTNMT)  Labor Health and Safety: Decision No.3733/2002/QĐ-BYT issued by Ministry of Healthcare dated on 10/10/2002 about the application of 21 Labor health and safety standards that concerned about microclimate, noise, vibration, Chemicals – Permitted level in the working environment. 2. Responsibilities The SME owner and Contractors are the key entities responsible for implementation of this ECOP. Key responsibilities of PMU/VCIC and the contractors are as follows: (a) PMU 61  PMU/VCIC is responsible for ensuring that the ECOP is effectively implemented. The PMU/VCIC will assign a qualified staff to be responsible for checking implementation compliance of Contractors, include the following: (a) monitoring the contractors’ compliance with the environmental plan, (b) taking remedial actions in the event of non-compliance and/or adverse impacts, (c) investigating complaints, evaluating and identifying corrective measures; (d) advising the Contractor on environment improvement, awareness, proactive pollution prevention measures; (e) monitoring the activities of Contractors on replying to complaints; (f) providing guidance and on-the-job training to field engineers on various aspects to avoid/mitigate potential negative impacts to local environment and communities during construction. (b) Contractor  Contractor is responsible for carrying out civil works and informs PMU, local authority and community about construction plan and risks associated with civil works. As such, contractor is responsible for implementing agreed measures to mitigate environmental risks associated with its civil works.  Contractor is required to obey other national relevant legal regulations and laws. Part 1 – Contractor’s Responsibilities This is an example and is not necessarily a full treatment of all requirements for a specific project. For example, there might be reason to have contractor deal with sexually transmitted diseases, medical and hazardous waste s (e.g., oil from vehicle or furnace repair and similar, oily rags). Issues/Risks Mitigation Measure 1) Dust  The Contractor implement dust control measures to ensure that the generation generation/ Air of dust is minimized and is not perceived as a nuisance by local residents, pollution maintain a safe working environment, such as: - water dusty roads and construction sites; - covering of material stockpiles; - Material loads covered and secured during transportation to prevent the scattering of soil, sand, materials, or dust; - Exposed soil and material stockpiles shall be protected against wind erosion. 2) Noise and  All vehicles must have appropriate “Certificate of conformity from inspection of vibration quality, technical safety and environmental protection” following Decision No. 35/2005/QD-BGTVT; to avoid exceeding noise emission from poorly maintained machines. 3) Water  Portable or constructed toilets must be provided on site for construction pollution workers. Wastewater from toilets as well as kitchens, showers, sinks, etc. shall be discharged into a conservancy tank for removal from the site or discharged into municipal sewerage systems; there should be no direct discharges to any water body.  Wastewater over permissible values set by relevant Vietnam technical standards/regulations must be collected in a conservancy tank and removed from site by licensed waste collectors. 61  At completion of construction works, water collection tanks and septic tanks shall be covered and effectively sealed off. 4) Drainage and  The Contractor shall follow the detailed drainage design included in the sedimentation construction plans, to ensure drainage system is always maintained cleared of mud and other obstructions.  Areas of the site not disturbed by construction activities shall be maintained in their existing conditions. 5) Solid waste  At all places of work, the Contractor shall provide litter bins, containers and refuse collection facilities.  Solid waste may be temporarily stored on site in a designated area approved by the Construction Supervision Consultant and relevant local authorities prior to collection and disposal.  Waste storage containers shall be covered, tip-proof, weatherproof and scavenger proof. Issues/Risks Mitigation Measure  No burning, on-site burying or dumping of solid waste shall occur.  Recyclable materials such as wooden plates for trench works, steel, scaffolding material, site holding, packaging material, etc. shall be collected and separated on-site from other waste sources for reuse, for use as fill, or for sale.  If not removed off site, solid waste or construction debris shall be disposed of only at sites identified and approved by the Construction Supervision Consultant and included in the solid waste plan. Under no circumstances shall the contractor dispose of any material in environmentally sensitive areas, such as in areas of natural habitat or in watercourses. 6) Chemical or  Used oil and grease shall be removed from site and sold to an approved used oil hazardous recycling company. wastes  Used oil, lubricants, cleaning materials, etc. from the maintenance of vehicles and machinery shall be collected in holding tanks and removed from site by a specialized oil recycling company for disposal at an approved hazardous waste site.  Unused or rejected tar or bituminous products shall be returned to the supplier’s production plant.  Store chemicals in safe manner, such as roofing, fenced and appropriate labeling. 7) Disruption of  Areas to be cleared should be minimized as much as possible. vegetative cover and ecological  The Contractor shall remove topsoil from all areas where topsoil will be resources impacted on by rehabilitation activities, including temporary activities such as storage and stockpiling, etc; the stripped topsoil shall be stockpiled in areas agreed with the Construction Supervision Consultant for later use in re- vegetation and shall be adequately protected.  The application of chemicals for vegetation clearing is not permitted.  Prohibit cutting of any tree unless explicitly authorized in the vegetation clearing plan.  When needed, erect temporary protective fencing to efficiently protect the preserved trees before commencement of any works within the site. 61  The Contractor shall ensure that no hunting, trapping shooting, poisoning of fauna takes place. 8) Traffic  Before construction, carry out consultations with local government and management community and with traffic police.  Significant increases in number of vehicle trips must be covered in a construction plan previously approved. Routing, especially of heavy vehicles, needs to take into account sensitive sites such as schools, hospitals, and markets.  Installation of lighting at night must be done if this is necessary to ensure safe traffic circulation.  Place signs around the construction areas to facilitate traffic movement, provide directions to various components of the works, and provide safety advice and warning.  Employing safe traffic control measures, including road/rivers/canal signs and flag persons to warn of dangerous conditions. Issues/Risks Mitigation Measure  Avoid material transportation for construction during rush hour.  Signpost shall be installed appropriately in both water-ways and roads where necessary. 9) Interruption  Provide information to affected households on working schedules as well as of utility services planned disruptions of water/power at least 2 days in advance.  Any damages to existing utility systems of cable shall be reported to authorities and repaired as soon as possible. 10) Restoration of affected areas  Cleared areas such as disposal areas, site facilities, workers’ camps, stockpiles areas, working platforms and any areas temporarily occupied during construction of the project works shall be restored using landscaping, adequate drainage and revegetation.  Trees shall be planted at exposed land and on slopes to prevent or reduce land collapse and keep stability of slopes.  Soil contaminated with chemicals or hazardous substances shall be removed and transported and buried in waste disposal areas. 11) Worker and  Training workers on occupational safety regulations and provide sufficient public Safety protective clothing for workers in accordance with applicable Vietnamese laws.  Install fences, barriers, dangerous warning/prohibition site around the construction area which showing potential danger to public people.  The contractor shall provide safety measures as installation of fences, barriers warning signs, lighting system against traffic accidents as well as other risk to people and sensitive areas.  If previous assessments indicate there could be unexploded ordnance (UXO), clearance must be done by qualified personnel and as per detailed plans approved by the Construction Engineer. 12)Solid waste  The Contractor shall develop a solid waste control procedure (storage, provision generated from of bins, site clean-up schedule, bin clean-out schedule, etc.) before construction rehabilitation and strictly comply with developed procedure during construction activities.  The Contractor shall provide litter bins, containers and waste collection facilities at all places of work. 61  The Contractor store solid waste temporarily on site in a designated place prior to off-site transportation and disposal through a licensed waste collector.  The Contractor shall dispose of waste at designated place identified and approved by local authority. Opened burn or bury of solid waste in hospital shall not be allowed. Under no circumstances shall the contractor dispose of any material in environmentally sensitive areas, such as watercourses  Recyclable materials such as wooden plates for trench works, steel, scaffolding material, site holding, packaging material, etc shall be segregated and collected on-site from other waste sources for reuse or recycle (sale).  The removal of asbestos-containing materials or other toxic substances shall be performed and disposed of by specially trained and certified workers. 13)  The contractor shall coordinate with local authorities (leaders of local Communication communes, leader of villages) for agreed schedules of construction activities at with local areas nearby sensitive places or at sensitive times (e.g., religious festival days). communities Issues/Risks Mitigation Measure  Copies in Vietnamese of these ECOPs and of other relevant environmental safeguard documents shall be made available to local communities and to workers at the site.  Disseminate project information to affected parties (for example local authority, enterprises and affected households, etc) through community meetings before construction commencement.  Provide a community relations contact from whom interested parties can receive information on site activities, project status and project implementation results.  Inform local residents about construction and work schedules, interruption of services, traffic detour routes and provisional bus routes, blasting and demolition, as appropriate.  Notification boards shall be erected at all construction sites providing information about the project, as well as contact information about the site managers, environmental staff, health and safety staff, telephone numbers and other contact information so that any affected people can have the channel to voice their concerns and suggestions. 14) Chance find  If the Contractor discovers archeological sites, historical sites, remains and procedures objects, including graveyards and/or individual graves during excavation or construction, the Contractor shall:  Stop the construction activities in the area of the chance find;  Delineate the discovered site or area;  Secure the site to prevent any damage or loss of removable objects. In cases of removable antiquities or sensitive remains, a night guard shall be arranged until the responsible local authorities or the Department of Culture and Information takes over;  Notify the Construction Supervision Consultant who in turn will notify responsible local or national authorities in charge of the Cultural Property of Viet Nam (within 24 hours or less);  Relevant local or national authorities would be in charge of protecting and preserving the site before deciding on subsequent appropriate procedures. This would require a preliminary evaluation of the findings 61to be performed. The significance and importance of the findings should be assessed according to the various criteria relevant to cultural heritage; those include the aesthetic, historic, scientific or research, social and economic values;  Decisions on how to handle the finding shall be taken by the responsible authorities. This could include changes in the layout (such as when finding an irremovable remain of cultural or archeological importance) conservation, preservation, restoration and salvage;  If the cultural sites and/or relics are of high value and site preservation is recommended by the professionals and required by the cultural relics authority, the Project’s Owner will need to make necessary design changes to accommodate the request and preserve the site;  Decisions concerning the management of the finding shall be communicated in writing by relevant authorities;  Construction works could resume only after permission is granted from the responsible local authorities concerning safeguard of the heritage. Part 2 – Contractor’s Workers Environmental Code of Conducts This is an example for typical project, but for a specific project, some other requirements might be relevant. For example, washing hands protocol, or agreeing to attend STDs (Sexually Transmitted Diseases) workshops. Do: Do not  Use the toilet facilities provided –  Remove or damage vegetation without direct report dirty or full facilities instruction.  Clear your work areas of litter and  Make any fires. building rubbish at the end of each  Poach, injure, trap, feed or harm any animals – this day – use the waste bins provided includes birds, frogs, snakes, etc. and ensure that litter will not blow away.  Enter any fenced off or marked area.  Report all fuel or oil spills  Drive recklessly or above speed limit immediately & stop the spill from  Allow waste, litter, oils or foreign materials into the continuing. stream  Smoke in designated areas only and  Litter or leave food lying around. dispose of cigarettes and matches carefully. (Littering is an offence.)  Cut trees for any reason outside the approved construction area  Confine work and storage of equipment to within the immediate  Buy any wild animals for food; work area.  Use unapproved toxic materials, including lead-based  Use all safety equipment and comply paints, asbestos, etc.; with all safety procedures.  Disturb anything with architectural or historical value  Prevent contamination or pollution of  Use of firearms (except authorized security guards) streams and water channels.  Use of alcohol by workers during work hours  Ensure a working fire extinguisher is immediately at hand if any “hot  Wash cars or machinery in streams or creek work” is undertaken e.g. welding,  Do any maintenance (change of oils and filters) of cars grinding, gas cutting etc. and equipment outside authorized areas  Report any injury of workers or  Dispose trash in unauthorized places animals. 61  Have caged wild animals (especially birds) in camps  Drive on designated routes only.  Work without safety equipment (including boots and  Prevent excessive dust and noise helmets)  Create nuisances and disturbances in or near communities  Use rivers and streams for washing clothes  Dispose indiscriminately rubbish or construction wastes or rubble  Spill potential pollutants, such as petroleum products  Collect firewood  Do explosive and chemical fishing  Use latrines outside the designated facilities; and  Burn wastes and/or cleared vegetation. ANNEX 2 - Template of Site Environmental Management Plan (The Subproject owners can use this template to prepare their Site EMP) VIETNAM HCFC PHASE OUT PROJECT STAGE 2 SUB-PROJECT PROPOSAL ----------------------------------- Implementing company: ………………………………. Name of company:…………………………… Coordinating agency: The PMU of Vietnam HCFC Phase out Project Stage II Ministry of Natural Resources and Environment 61 VIETNAM HCFC PHASE OUT PROJECT STAGE 2 SUBPROJECT PROPOSAL FOR …………………….. PROJECT COVER SHEET COUNTRY : VIET NAM PROJECT TITLE: SECTOR COVERED: HCFC-22 USE IN THE ENTERPRISE PROJECT IMPACT (2009) Before After Reduction Reduction in the use of Ozone Depleting substance (in ODP ton) Reduction in the use of green house gases (ton CO2 e) (impact of HFC- 245fa is not included) PROJECT DURATION PROJECT COST (for conversion of refrigerants) Incremental Capital Costs: Contingencies (10%): Incremental Operating Costs: Total Project Cost MLFs FUNDING Eligible funding from MLFs Total 61 Counterpart funding Cost effectiveness by Grant Funding BENEFICIARY ENTERPRISE: NATIONAL COORDINATING BODY: PROJECT SUMMARY HO CHI MINH CITY, DECEMBER 2017 Prepared by: ……………………………. (Sign and seal) Mr. …. Director ………. Date: ………. Reviewed by: the PMU of Vietnam HCFC Phase out project Director of the PMU: (Sign and seal) Date: January,.... 2017 Reviewed by the World Bank’s Task Team Date:……….. 2017 61 1. INTRODUCTION 2. PROJECT OBJECTIVE 3. EMP OBJECTIVE 4. ENTERPRISE BACKGROUND [Name of Company] [Address] [Tel]: [Fax]: [E-mail]: [Website]: [Name of Company] was established in [month, year], and subsequently, the production of refrigeration unit, commenced on [date, month, year], with a workforce of [quantity number] employees. Besides selling the products locally, [Name of Company] is also exporting worldwide under its own brand name and to countries like [name(s) of nations]. Types of Refrigeration: Other production related to HCFC phase out; Other production related to HCFC phase out; Foam Air conditioner Foam tole Foam door In order to fulfill the ever-growing local and world-wide demand for better quality and more efficient refrigerators, [Name of Company] had in the past, invested a certain sum in the purchase of advanced technology Production and Testing equipment’s, such as, [for example], and will continue to do so in the future. [Name of Company] was established in [month, year], located in [name of province] in Vietnam. It’s production of [name of product(s)], commenced on [ date, month, year] , with a workforce of [quantity number] employees 61 with [quantity number] Capital Registered, today, [Name of Company] employs a total staff of [ quantity number] with [ quantity number] of them as engineers and technicians, has successfully developed a complete range of refrigeration product, covering [ for example ]. Besides selling the products locally, [Name of Company] is also exporting worldwide under its own brand name to countries like [ name of country(ies)]. In order to build [Name of Company] according to standards that are universally acceptable, the company has from the outset, made it a policy to be continually in search of new technology and know-how. At the factory, state-of-the-art equipment, are extensively used to ensure precision and accuracy at every stage of production. Production is computer controlled at each stage, and quality controls are in place throughout the production process, beginning with the arrival of raw materials. Finished products are tested to ensure they conform to the desired standards before leaving the factory. Table 1 - Production of …………… and amount of HCFC-22 Conversed Year Procurement of raw materials Used raw materials Production (ton) (ton) of AC POE HCFC- HCFC-22 POE HCFC- Replaced (BTUs) 32/HC-290 32/HC-290 HCFC-22 2015 2016 2017 Table 2 – Existing production line condition: Observed impacts/risks and proposed changes during conversion of refrigerants No. Section [photo] Concerned Observed impacts/risks Proposed Changes Process/Location related to refrigerant conversion Sheet metal forming Metal parts and shaping production Metal pre-treatment and powder coating Plastic injection Spraying solvents Brazing and welding Assembly line Refrigerant charging Finish good, handing 61 Storage 5. PROJET DESCRIPTION 5.1 Technology of refrigerant conversion 5.2 Project costs Table 3: Project cost for conversion of refrigerants (US$) Cost components Amount (US$) 1 System, component and process redesign, prototype manufacturing and testing, software for system design for different new refrigerants 2 Sheet metal processing, changes of standard modules 3 Assembly line and area modifications, -Charging area modifications to allow use of flammable refrigerants -Pressure testing equipment -Refrigerant charging equipment -Leak detectors -Vacuum pumps 4 Storage of flammable refrigerants, piping and transfer pumps 5 Prototype manufacturing, trials and testing 6 Quality specification and inspection, verification of performance etc. 7 Process, operation, maintenance and safety training 8 Technical assistance and support Sub-total Contingency (10%) Total ICC cost Amount Installation, servicing and sales of low GWP refrigerators (US$) Installation kits for low GWP refrigerators. Training of in-house technicians and installers and service technicians from dealers Dealers: installer and service teams Brochures etc. Total Cost efficiency rate Amount Summary 61 (US$) ICC Charging line ICC HE ICC servicing Sub-total Contingency Total IOC TOTAL cost Cost Effectiveness 5.3 Project implementation schedule Table 4: Implementation Schedule No TASK 2016 2017 2018…. Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 1 Project proposal (technical and financial appraisal) 2 Sub-grant Agreement signing 3 Preparation of equipment procurement Selection of supplier 4 Equipment Contract Signing 5 Civil work and preparation for the installation of equipment 6 Transportation, equipment arrival 7 Installation of equipment and ventilation system and Plant Modifications 8 Operation and safety Training 9 Validation of production and Trials 10 Safety Certification/Audit 11 Production start-up 12 Disposal of baseline HCFC- base equipment 13 Submit the measures of precautions and chemical emergency response to local authorities 14 Project completion report preparation and submission 15 Monitoring 61 15 Training 6. LEGAL AND REGULATORY FRAMEWORK REQUIREMENTS (see section 6) 7. ENVIRONMENTAL AND SOCIAL IMPACTS AND MITIGATIONS (see section 7) Table 5. Summary of Chemical Impacts, Key Mitigation Measures and Residual Impacts Items Theoretical impact Potential impact Key mitigation Residual in refrigeration measures impacts production Land acquisition Project commission Construction Operation 8. MEASURES FOR HANDLING AND SAFETY OPERATING FOR NEW REFIRGERANTS 9. ENVIRONMENTAL AND SAFETY MONITORING 10. TRAINING 11. EMP DISLOSURE 61 ANNEX 3 – Outline of Measures on precautions and chemical emergency response (The Subproject owners can use this outline to prepare the measurements on precautions and chemical emergency response) MEASURES OF CHEMICAL PRECAUTIONS AND EMERGENCY RESPONSES CONTENTS PREAMBLE 1. Introduction 2. The necessity to establish Measures of Chemical Precautions and Emergency Responses 3. Legal bases of establishing Measures of Chemical Precautions and Emergency Responses Chapter 1 - INFORMATION RELATED TO PROJECT ACTIVITIES I.1 Investment Scale I.2 Chemical Transportation Procedures I.3 List of Chemicals I.3.1 List of chemicals that require Measures of Chemical Precautions and Emergency Responses I.3.2.2 Chemical Characteristics I.4. Technical Requirements for Packing, Storage, and Transport I.5. Other Attachments Chapter II RISK PREDICTION OF INCIDENTAL SITUATIONS AND PLANS FOR CHECKING AND MONITORING CHEMICAL INCIDENTS II.1. List of Risks and Predictions of Incidental Situations II.1.1 List of Risks II.1.2 Predictions of Risk of Chemical Incidents II.2. Checking and Monitoring Plans for Sources of Risks and Chemical Incidents II.2.1 Regular, Periodical and Unexpected Checking II.2.2 Check Records Storing II.3. Measures to reduce risks and potentials of incidental chemical situations Section III MEASURES IN RESPOND TO CHEMICAL INCIDENTS III.1. Human resource for chemical incident responses III.1.1. Establishing the Executive Board and Response team for Chemical Emergencies III.1.2. External Support team in Chemical emergencies III.1.3. Operating method, direct rescuing and resolving incident\ III.2. Equipment and Transportation uses in respond of emergencies III.3. Warning system, Internal Information System and External informant in Emergency situation 61 III.4. Cooperating plan with Internal and External Support team III.4.1. Cooperating plan in case of Emergencies Leakage and Spilling Fire III.4.2. Evacuation Plan III.4.3. Training and Regularly Drill Plan III.5. Detail instruction of technical measures for collecting and cleaning area polluted by Chemical emergency III.6. Other activities to respond to Chemical Emergency CONCLUSION 1. Company’s evaluation of Measures of Chemical precautions and Emergency Responses 2. Company’s Commitment 3. Other recommendations by Company Annexes ANNEX 4 – Main refrigerants to be replaced the use of HCFC-22 The tables below provide a comparison of various refrigerants and the main refrigeration application in which they are used. Data is taken from the Ozone Secretariat fact sheets (April 2015). Table 1: Alternatives to avoid use of R-404A (in new equipment and for retrofit of existing) Refrigerant GWP Flamm Comments Com Ind Trans ability5 Ref Ref port R-407A 2100 1 There has been significant use of these blends in Europe X X X as R-404A alternatives (for new systems and for retrofit). X X X R-407F 1800 1 Can have higher efficiency than R-404A systems. R-446A 480 2L Newly developed blends with properties similar to R- X X 410A. Being considered for condensing units. Newly developed blends with properties similar to R- X X R-447A 600 2L 410A. Being considered for condensing units R-448A 1400 1 Newly developed blends with properties similar to R- X X X 407A and R-407F, but lower GWP. Currently there is X X X R-449A 1400 1 very little commercial experience or availability. A new blend targeted at the transport sector; an R-404A X X R-452A 2100 1 alternative with low discharge temperature at high ambient. Newly developed blends with properties similar to HFC- X X R-450A 570 1 134a. May be suitable for new road vehicles and R-513A 600 1 containers that are currently designed to use HFC-134a. MT system only. Table A3-2: Alternatives for new refrigeration equipment and systems Transcritical R-744 is being developed for large road vehicles X X X and for intermodal containers. Use of R-744 requires major changes to the design of transport refrigeration systems and the R-744 (CO2) 1 1 development of many new components. Some systems have been trialled in 2014 and it can be expected that R-744 could be widely available for transport applications by 2020. A widely used refrigerant for large distributed systems and X large chillers. This refrigerant is an important option for many R-717 0 2L industrial applications. It is toxic and it has low flammability – (ammonia) appropriate safety precautions are required. This can make it difficult to use ammonia for small and medium sized systems. Used in large industrial systems (distributed and chillers), 61 X X especially in petrochemical plants that are processing high HC-290 5 3 flammability products. HCs have high flammability and HC-1270 2 appropriate safety precautions are required. HCs are not suited to most small and medium sized industrial systems. Not currently used, but being considered for stand-alone X HF)-1234yf <1 2L systems and MT condensing units. Being introduced for industrial chillers as an alternative to (X) X HFC-134a. Other HFOs are also under development, such as HCFO-1233zd and HFO-1336mzz which are suitable for low HFO-1234ze <1 2L pressure chillers (as an alternative to HCFC 123). Not currently used, but being considered for stand-alone systems and MT condensing units. R-446A 480 2L Newly developed blends with properties similar to R-410A. X X Being considered for small and medium sized systems. Newly developed blends with properties similar to R-410A. X X R-447A 600 2L Being considered for small and medium sized systems. 5 3 = high flammability; 2L = low flammability; 1 = non-flammable R450A 570 1 Newly developed blends with properties similar to HFC-134a X X R-513A 600 1 Being considered for small and medium sized MT systems. R451A 140 2L Newly developed blends with properties similar to HFC-134a X R-451B 150 2L Being considered for small and medium sized MT systems. Being considered for small and medium sized systems. Also X X HFC-32 704 2L being considered for condensing units. Source: Technical report of project, 2016. 61 ANNEX 5 - Summary of Material Safety Datasheet for Gases used in Air Conditioning SAFETY DATA SHEET 1 . HCFC-22 Chlorodifluoromethane - CAS NO. 75-45-6 Physical property: Colorless, volatile liquid with ethereal and faint sweetish odor. Non-flammable material. Overexposure may cause dizziness and loss of concentration. At higher levels, CNS depression and cardiac arrhythmia may result from exposure. Vapors displace air and can cause asphyxiation in confined spaces. At higher temperatures, (>250°C), decomposition products may include Hydrochloric Acid (HCI), Hydrofluoric Acid (HF) and carbonyl halides. Transportation: Figure A4-1: Color Code for Refrigerant container Health Hazards: SKIN: Irritation would result from a defatting action on tissue. Liquid contact could cause frostbite. EYES: Liquid contact can cause severe irritation and frostbite. Mist may irritate. INHALATION: R-22 is low in acute toxicity in animals. When oxygen levels in air are reduced to 12- 14% by displacement, symptoms of asphyxiation, loss of coordination, increased pulse rate and deeper respiration will occur. At high levels, cardiac arrhythmia may occur. INGESTION: Ingestion is unlikely because of the low boiling point of the material. Should it occur, discomfort in the gastrointestinal tract from rapid evaporation of the material and consequent evolution of gas would result. Some effects of inhalation and skin exposure would be expected. DELAYED EFFECTS: None Known 68 Flammability: FLASH POINT: Gas, not applicable per DOT regulations FLASH POINT METHOD: Not applicable AUTOIGNITION TEMPERATURE: Unknown UPPER FLAME LIMIT (volume % in air): None* LOWER FLAME LIMIT (volume % in air): None* *Based on ASHRAE Standard 34 with match ignition FLAME PROPAGATION RATE (solids): Not applicable OSHA FLAMMABILITY CLASS: Not applicable It is not flammable at ambient temperatures and atmospheric pressure. However, this material will become combustible when mixed with air under pressure and exposed to strong ignition sources. Contact with certain reactive metals may result in formation of explosive or exothermic reactions under specific conditions (e.g. very high temperatures and/or appropriate pressures). R-22 should not be mixed with air above atmospheric pressure for leak testing or any other purpose. Store in a cool, well-ventilated area of low fire risk and out of direct sunlight. Protect cylinder and its fittings from physical damage. Storage in subsurface locations should be avoided. Close valve tightly after use and when empty. US DOT PROPER SHIPPING NAME: Chlorodifluoromethane US DOT HAZARD CLASS: 2.2 – Non-Flammable Gas US DOT PACKING GROUP: Not applicable US DOT ID NUMBER: UN1018 2. HFC-32 Safety Data: Difluoromethane - CAS NO. 75-45-6 Methylene fluoride; Carbon fluoride hydride (CF2H2); Difluoromethane; Freon 32; Genetron 32; Methylene difluoride; CH2F2; R 32 Physical property: Gas. [Liquefied gas] WARNING!  EXTREMELY FLAMMABLE GAS.  MAY CAUSE FLASH FIRE.  MAY BE HARMFUL IF SWALLOWED.  CAN CAUSE TARGET ORGAN DAMAGE.  Keep away from heat, sparks and flame.  Use only with adequate ventilation. Wash thoroughly after handling. Keep container closed. Flammability of the product: Flammable Auto-ignition temperature: 530°C - Flammable limits: Lower =14% Upper = 31% Heavier than air 3.82 US DOT PROPER SHIPPING NAME: Difluoromethane US DOT HAZARD CLASS: 2.1 – Flammable Gas US DOT PACKING GROUP: Not applicable US DOT ID NUMBER: UN 3252 69 3. HC-290 Safety Data: Propane - CAS NO. 74-98-6 Propyl hydride; n-Propane; Dimethyl methane; Bottled gas; propane in gaseous state; propane liquefied, n-Propane; Dimethylmethane; Freon 290; Liquefied petroleum gas; Lpg; Propyl hydride; R 290; C3H8; UN 1075; UN 1978; A-108; Hydrocarbon propellant. Physical property: Gas. [Liquefied gas] WARNING!  DANGER  EXTREMELY FLAMMABLE GAS.  MAY CAUSE FROSTBITE.  MAY FORM EXPLOSIVE MITURES IN AIR  MAY DISPLACE OXYGEN AND CAUSE RAPID SUFFOCATION Flammability of the product: Flammable Auto-ignition temperature: 497°C - Flammable limits: Lower =1.8% Upper = 8.4% Heavier than air 1.6. US DOT PROPER SHIPPING NAME: Propane US DOT HAZARD CLASS: 1 – Flammable Gas Transportation: Always transport in closed containers that are upright and secure. Ensure that persons transporting the product know what to do in the event of an accident or spillage. Disposal: The generation of waste should be avoided or minimized wherever possible. Disposal of this product, solutions and any by-products should at all times comply with the requirements of environmental protection and waste disposal legislation and any regional local authority requirements. Dispose of surplus and non-recyclable products via a licensed waste disposal contractor. Waste should not be disposed of untreated to the sewer unless fully compliant with the requirements of all authorities with jurisdiction. Empty Airgas-owned pressure vessels should be returned to Airgas. Waste packaging should be recycled. Incineration or landfill should only be considered when recycling is not feasible. This material and its container must be disposed of in a safe way. Empty containers or liners may retain some product residues. Do not puncture or incinerate container. 4. Ammonia anhydrous (NH3) CAS No. 76664-41-7 Physical property: GHS04 GHS05 GHS06 GHS09 Signal word (GHS-US) : DANGER Hazard statements (GHS-US) : H221 - FLAMMABLE GAS H280 - CONTAINS GAS UNDER PRESSURE; MAY EXPLODE IF HEATED H331 - TOXIC IF INHALED 70 H314 - CAUSES SEVERE SKIN BURNS AND EYE DAMAGE H400 - VERY TOXIC TO AQUATIC LIFE CGA-HG22 - CORROSIVE TO THE RESPIRATORY TRACT Flammability of the product: Flammable Auto-ignition temperature: 580°C - Flammable limits: Lower =15% Upper = 28%. Toxicity: Ecology - general : VERY TOXIC TO AQUATIC LIFE. No ecological damage caused by this product. Ammonia, anhydrous (7664-41-7) LC50 fish 1 0.44 mg/l (Exposure time: 96 h - Species: Cyprinus carpio) EC50 Daphnia 1 25.4 mg/l (Exposure time: 48 h - Species: Daphnia magna) LC50 fish 2 0.26 - 4.6 mg/l (Exposure time: 96 h - Species: Lepomis macrochirus) Storage: Store in a cool, well-ventilated place. Store and use with adequate ventilation. Store only where temperature will not exceed 125°F (52°C). Firmly secure containers upright to keep them from falling or being knocked over. Install valve protection cap, if provided, firmly in place by hand. Store full and empty containers separately. Use a first-in, first-out inventory system to prevent storing full containers for long periods. Other precautions for handling, storage and use: When handling product under pressure, use piping and equipment adequately designed to withstand the pressures to be encountered. Never work on a pressurized system. Use a back flow preventive device in the piping. Gases can cause rapid suffocation because of oxygen deficiency; store and use with adequate ventilation. If a leak occurs, close the container valve and blow down the system Transportation: Always transport in closed containers that are upright and secure. Ensure that persons transporting the product know what to do in the event of an accident or spillage. Disposal: Prevent waste from contaminating the surrounding environment. Prevent soil and water pollution. Dispose of contents/container in accordance with local/national/international regulations. Contact supplier for any special requirements. Exposure Controls: Use a local exhaust system, if necessary, to prevent oxygen deficiency and to keep hazardous fumes and gases below all applicable limits in the worker's breathing zone. MECHANICAL ENGINEERING CONTROLS: Not recommended as a primary ventilation system to control worker's exposure. USE ONLY IN A CLOSED SYSTEM. An explosion-proof, corrosion- resistant, forced-draft fume hood is preferred. 71 Wear metatarsal shoes and work gloves for cylinder handling, and protective clothing where needed. Wear appropriate chemical gloves (e.g. neoprene, nitrile, etc.) during cylinder change out or wherever contact with product is possible. Select per OSHA 29 CFR 1910.132, 1910.136, and 1910.138. Wear safety glasses when handling cylinders; vapor-proof goggles and a face shield during cylinder change out or whenever contact with product is possible. Select eye protection in accordance with OSHA 29 CFR 1910.133. Wear metatarsal shoes and work gloves for cylinder handling, and protective clothing where needed. Wear appropriate chemical gloves (e.g. neoprene, nitrile, etc.) during cylinder change out or wherever contact with product is possible. Select per OSHA 29 CFR 1910.132, 1910.136, and 1910.138. When workplace conditions warrant respirator use, follow a respiratory protection program that meets OSHA 29 CFR 1910.134, ANSI Z88.2, or MSHA 30 CFR 72.710 (where applicable). Use an air-supplied or air-purifying cartridge if the action level is exceeded. Ensure that the respirator has the appropriate protection factor for the exposure level. If cartridge type respirators are used, the cartridge must be appropriate for the chemical exposure (e.g., an organic vapor cartridge). For emergencies or instances with unknown exposure levels, use a self-contained breathing apparatus (SCBA). Wear cold insulating gloves when transfilling or breaking transfer connections. Refer to local regulations for restriction of emissions to the atmosphere. Wear gas tight chemically protective clothing in combination with self contained breathing apparatus. Standard protective clothing and equipment (Self Contained Breathing Apparatus) for fire fighters. The Table 1 is showing ODP, GWP and lifetime depending on the type of fluid: Table 1: Comparison of ODP, GWP and life time of refrigerants Type of ODP 100 year GWP Life cycle refrigerant Halons 3 to 1300 to 80 000 20 to 70 years 11 101 3 800 45 years Prohibited CFC ODP>0 12 1 8 100 100 years 115 0,6 9 300 1 700 years Bromide of 0,6 1 300 0,7 year methyl 0,05 400 to 1 800 1 to 20 years Prohibited in 2005 HCFC 0 140 to 11 700 1 to 300 years HFC Authorized ODP=0 0 6 500 to 9 200 10 000 to 50 000 years PFC 0 23 900 3 200 years SF6 Ammonia 0 0 few days 72 Formula and proportion GWP Name of every constituent for (100 years) ODP mixtures CFC R11 CFCl3 400 1 R12 CF2Cl2 0 850 1 HCFC 0 R22 CF2HCl 1700 0,055 R408A R125/143a/22 (7/46/47) (2650) R401A R22/152a/124 (53/13/34) (970) HFC R32 CH2F2 580 0 R125 CF3CHF2 320 0 R134a CF3CH2F 1300 0 0 R143a CF3CH3 440 0 Mixtures HFC 0 R404A R125/143a/134a 326 0 R407C R32/125/134a (23/25/52) (44/52/4) 152 0 - R410A R32/125 (50/50) 173 5 - R422A R125/134a/600a 253 0 - R422D (85,1/11,5/3,4) R125/134a/600a 5 223 - R427A (65,1/31,5/3,4) R32/125/143a/134a 5 1830 - R507A R125/143a (50/50) (15/25/10/50) 330 - 0 Figure 2: Relationship between Burning Velocity and GWP BV is indicated in parentheses. Source: Japan Refrigeration and Refrigeration Industry Association (JRAIA). Risk Assessment of Mildly Flammable Refrigerants 2013 Progress Report, April 2014, The Japan Society of Refrigerating and Air Conditioning Engineers 73 Table 2: Behavior of Flames Classificati Class 3 Class 2 Class 2L on A3 A2 A2L B2L Substance Propane R-152a R-32 Ammonia Burning 39 cm/sec 23 cm/sec 6.7 cm/sec 7.2 cm/sec velocity Heat of 46 MJ/kg 16 MJ/kg 9 MJ/kg 19 MJ/kg combustion Combustion state 2L refrigerants do not horizontally propagate due to their slow BV. Additionally, heat of the combustion of R-32 is low and the range of any impact by its flame is limited. Related information is available at the AREMA (The Refrigeration and Refrigeration Equipment Manufacturers Association of Australia) homepage. 74 ANNEX 6: Information on Refrigeration Manufacturers and their total investment Table 1: List of known refrigeration manufactures ID # Name 1 Nam Phu Thai JSC 2 Tuan Minh Industrial Refrigeration JSC 3 An Khang Refrigeration JSC 4 Rong Viet Refrigeration Technique JSC 5 Sao Phuong Nam Co., Ltd 6 Techbico Corporation 7 Phan Bach Refrigeration Technology Co., Ltd 8 TST Refrigeration Electrical JSC 9 Tan Long Refrigeration Electrical Mechanical Co., Ltd 10 Seatech Equipment JSC 11 Quang Minh JSC 12 Tri Phat Techique & Trading JSC 13 Quang Thang Refrigeration & Engineering Co., Ltd 14 Mai Duong Co., Ltd 15 Hoan Hao Refrigeration Trading and Service Co., Ltd 16 Viet Nhat Refrigeration and Civil Engineering Co., Ltd 17 Van Loi Refrigeration Technology Co., Ltd 18 Heat Refrigeration Technology JSC 19 Vietnam IBF Technology JSC 20 TST Refrigeration and Thermal Insulation Co., Ltd 21 Phu Hung Refrigeration and Engineering Co., Ltd 22 Bach Khoa Refrigeration Technology Co., Ltd 23 Tan Phuong Tay Refrigeration Engineering Co., Ltd 24 Vietnam Freight Mark Co., Ltd 25 Truong Thinh Refrigeneration servicing Co., Ltd 26 Vietnam Gea Refrigeration Co., Ltd 27 Tho Sai Gon Technique Trading and Servicing Co., Ltd 28 Dai Phu Thinh Refrigeration JSC 29 Viet Duc Production - Trading Service Co., Ltd 30 Danh Binh Trading and manufacturing Co., Ltd 31 Thuan Tien Eletric machinery and Building Co., Ltd 32 BKTECH Service and Trading Co., Ltd 33 Hoang Hai Technical service and Trading Co., Ltd 34 Hoang Hai Technical service and Trading Co., Ltd 35 Mien Tay Refrigeration Co., Ltd 36 Le Quoc Refrigeration & Engineering Co., Ltd 37 Tuan Ngoc Anh Refrigeration Engineering Service and Trading One Member Co., Ltd 38 Asia Refrigeration Industry Co., Ltd 75 39 Thai Ngoc Tuan Co., Ltd 40 Hung Tri JSC 41 VIET Engineering Co., Ltd 42 Hiep Phat Technology JSC 43 Tan & Ky Refrigeration Engineering Co., Ltd 44 KUEN LING Vietnam Machinery Refrigerating Co., Ltd 45 S.K.T Service and Trading Co., Ltd 46 SEA Refrigeration Electrical Engineering Company 47 Tan Phat Refrigeration Co., Ltd 48 Xuan Anh Trading and Manufacturing One Member Co., Ltd 49 Nam Thinh Mechical Electrical Refrigeration Corp 50 Thien Tam Refrigeration Engineering Co., Ltd 51 Dien An Co., Ltd 52 Phuc Hai Refrigeration Co., Ltd 53 Services Technology Number One Vietnam Co., Ltd 54 TAN PHUC HUNG JSC 55 Vietnam VP Technical Service JSC 56 VIETFIX JSC. 57 Le Sinh Refrigeration Technology Co., Ltd 58 Thien Hai Technical Service and Trading Co., Ltd 59 Lam Son Refrigeration Engineering JSC 60 Vietan General Trading JSC 61 Thien Phuc Refrigeration Engineering Co., Ltd 62 Hai Dang Construction and Commercial Refrigeration Electrical Engineering Co., Ltd 63 Hiep Anh Nhat Co., Ltd 64 Kinh Thanh Food Technology Joint Stock Company 65 Thanh My Refrigeration Co., Ltd 66 RE COM Refrigeration Technic Co., Ltd 67 VST Refrigeration Equipment and Insulation Co., Ltd 68 Sai Gon Refrigeration Engineering Co., Ltd (SAREE) 69 PER8 Refrigeration Technic Co., Ltd 70 Hung Vuong Refrigeration and Engineering Co., Ltd 71 Southeree Co., Ltd Table 2: Total conversion cost for Group 1 (7 companies) HCFC-22 HCFC-22 consumption Proposed Proposed Total consumption ID# Company Name for ICC IOC Cost for service manufacturing (US$) (US$) (US$) (MT) (MT) TST Refrigeration and 20 18 14 280,500 68,400 348,900 Thermal Insulation Co., Ltd Tan Phuong Tay 23 Refrigeration Engineering 15 20 280,500 57,000 337,500 Co., Ltd 76 40 Hung Tri JSC 30 0 280,500 114,000 394,500 51 Dien An Co, ltd. 15 0 280,500 57,000 337,500 Hai Dang Construction and Commercial Refrigeration 62 12 13 280,500 45,600 326,100 Electrical Engineering Co., Ltd SaiGon Refrigeration 68 Engineering Co., Ltd 16 6 280,500 60,800 341,300 (SAREE) 71 Southeree Co., Ltd 10 0.42 280,500 38,000 318,500 Total 116 53.42 1,963,500 440,800 2,404,300 Table 3: Total conversion cost for group 2 (27 companies) HCFC- HCFC consumption Proposed Propose Total consumption ID # Company for ICC d IOC Cost for service manufacturing (US$) (US$) (US$) (MT) (MT) Tuan Minh Industrial 2 6 0 154,000 19,000 173,000 Refrigeration JSC 6 Techbico Corporation 6 16 154,000 26,600 180,600 Tan Long Refrigeration 9 Electrical Mechanical Co., 6 9 154,000 19,000 173,000 Ltd 10 Seatech Equipment JSC 7 0 154,000 38,000 192,000 Quang Thang Refrigeration 13 5 17.34 154,000 26,600 180,600 & Engineering Co., Ltd 14 Mai Duong Co., Ltd 10 0 154,000 38,000 192,000 Hoan Hao Refrigeration 15 Trading and Service Co., 7 15 154,000 26,600 180,600 Ltd Viet Nhat Refrigeration 16 and Civil Engineering Co., 5 15.36 154,000 19,000 173,000 Ltd Phu Hung Refrigeration 21 6 14 154,000 22,800 176,800 and Engineering Co., Ltd Truong Thinh 25 Refrigeneration servicing 10 0 154,000 38,000 192,000 Co., Ltd Dai Phu Thinh 28 8 12 154,000 30,400 184,400 Refrigeration JSC Danh Binh Trading and 30 5 0 154,000 19,000 173,000 manufacturing Co., Ltd BKTECH Service and 32 12 0 154,000 45,600 199,600 Trading Co., Ltd Mien Tay Refrigeration 35 10 3 154,000 38,000 192,000 Co., Ltd 77 Le Quoc Refrigeration & 36 10 0 154,000 38,000 192,000 Engineering Co., Ltd Asia Refrigeration Industry 38 8 0 154,000 30,400 184,400 Co., Ltd Tan & Ky Refrigeration 43 6 0.31 154,000 22,800 176,800 Engineering Co., Ltd SEA 46 Refrigeration Electrical En 6 4 154,000 22,800 176,800 gineering Company Nam Thinh Mechical 49 Electrical Refrigeration 10 0 154,000 38,000 192,000 Corp Thien Tam Refrigeration 50 5 8 154,000 19,000 173,000 Engineering Co., Ltd Phuc Hai Refrigeration 52 4 11 154,000 15,200 169,200 Co., Ltd Le Sinh Refrigeration 57 5 2 154,000 19,000 173,000 Technology Co., Ltd Lam Son Refrigeration 59 7 0 154,000 26,600 180,600 Engineering JSC Thanh My Refrigeration 65 5 18.2 154,000 19,000 173,000 Co., Ltd RE COM Refrigeration 66 10 8.36 154,000 38,000 192,000 Technic Co., Ltd VST Refrigeration 67 Equipment and Insulation 7 3 154,000 26,600 180,600 Co., Ltd Hung Vuong Refrigeration 70 10 8 154,000 38,000 192,000 and Engineering Co., Ltd 196 164.57 4,158,000 760,000 4,918,000 78 ANNEX 7-Area Classifications for the Design of Production Line Use Flammable Gas Objective: In a situation in which there may be an explosive (flammable) atmosphere, the following steps should be taken: a) Eliminate the likelihood of an explosive gas atmosphere occurring around the source of ignition, or b) Eliminate the source of ignition. Where this is not possible, protective measures, process equipment, systems and procedures should be selected and prepared so the likelihood of the coincidence of a) and b) is so small as to be acceptable. Vietnamese Legal implication: According to Hazardous Substances registration, it is compulsory for the authority to prepare the standards for controlling;  Ingredients  Characteristics  Purity  Container and package inspection and testing requirement  Labeling  Manufacturing  Importing  Exporting  Transportation  Storage  Container disposal requirement According to Hazardous Substances, HCFCs and HFCs are classified as hazardous substance for which production, import, export or having in possession must have a license. To obtain a license, full compliance to relevant regulatory requirements is mandatory. DoIT Notification on Storage of Chemical and Hazardous Substances establishes a complete set of directives that can be used as a reference when air conditioner manufacturer are planning for new storage area of HFC-32 or making improvement of the existing storage facility. In summary the Chemical and Hazardous Material Storage Manual covers;  Specific criteria for fire wall  Type and characteristic of the floor  Means of egress and emergency exits  Type and characteristic of roofing material  Ventilation requirement  Electrical, emergency light, and electrical appliances requirement  Lightning protection  Detection and alarm systems  Fire protection Ministerial order on Fire prevention and control is applicable to all air conditioner manufacturers. Since most of the air conditioner plants are registered under the type 70, or 71 which are classified by this regulation as “medium fire risk factory”. Fire detection system, fire alarm, and fire suppression system requirements are specified. 79 ANNEX 8 - Oxygen-Propane Brazing Safety Guideline Oxy/fuel gas brazing is a common process in air conditioner manufacturing plant. Oxygen- Propane blow torch are used in copper tube- welding, heating, straightening. Small air conditioner plants use many Oxygen cylinders and Propane Gas cylinder in their operation. Large plant set propane and oxygen gas station outside the factory building. Gases supplied through manifold and piping system. Liquid Gas Flux connected to the gas manifold and fed into the welding/brazing tools. Oxy-Fuel welding is also being used in maintenance activity. Many people are injured each year by the incorrect or careless use of oxy/fuel gas equipment. Some people die. This guideline describes the hazards associated with portable or fixed oxy/fuel gas equipment and the precautions for avoiding injury and damage to property in air conditioner manufacturing process. Legal obligation: Employers are legally required to assess the risks in the workplace and take all reasonably practicable precautions to ensure the safety of workers and members of the public. Before using oxy/fuel gas equipment, a careful assessment of the risks should be carried out. This is particularly important if work is being carried out in unfamiliar surroundings. Permit To Work System: It recommended that the companies operate a written permit system for hot work. The permit details the work to be carried out, how and when it is to be done, and the precautions to be taken. A written permit system is likely to result in a higher standard of care and supervision. Oxy/fuel gas equipment should not be used unless it has been authorized by a suitably experienced manager or supervisor who has knowledge of the site, the work to be carried out, the risks involved and the precautions to be taken. Training and Certification: No one should use oxy/fuel gas equipment unless they have received adequate training in:  the safe use of the equipment;  the precautions to be taken;  the use of fire extinguishers;  the means of escape, raising the fire alarm and calling the fire brigade. Oxy-Fuel Gas Welding Equipment: All oxy/fuel gas processes operate in the same way. A fuel gas such as propane or acetylene is mixed with oxygen in a blowpipe (often called a 'torch') to produce a flame that is hot enough for the purpose. The main components of oxy/fuel gas equipment are:  cylinders of oxygen and fuel gas (propane or acetylene);  a means to shut off or isolate the gas supply, usually the cylinder valves;  a pressure regulator fitted to the outlet valve of the  gas cylinder, used to reduce and control gas pressure;  a flashback arrester to protect cylinders from flashbacks and backfires;  flexible hoses to convey the gases from the cylinders to the blowpipe;  non-return valves to prevent oxygen reverse flow into the fuel line and fuel flow into the oxygen line; 80  a blowpipe or other burner device where the fuel gas is mixed with oxygen and ignited. ry Oxygen Bottom LPG Rear Entry Twin Oxygen/ LPG Blowpipe +Mixer Entry Regulator Regulator Hose Cutting Attachment Nozzle Welding Tip Cutting Hazards and Risk: The main hazards are from fire and explosion. These are caused by:  careless handling of a lighted blowpipe resulting in burns to the user or others;  using the blowpipe too close to combustible material;  cutting up or repairing tanks or drums which contain or may have contained flammable materials;  gas leaking from hoses, valves and other equipment;  misuse of oxygen;  backfires and flashbacks. Most of the air conditioner manufacturing plant participating are not well manage the welding/brazing kits that being used in the production line. Oxygen gas cylinder should be secured to prevent falling down. Gas hoses are in poor condition. The flame from an oxy/fuel gas blowpipe is a very powerful source of ignition. Many fires have been caused by the careless use of oxy/fuel blowpipes. The flame will quickly ignite any combustible material it comes into contact with: wood, paper, cardboard, textiles, rubber, plastics. Many processes also generate sparks and hot spatter which can ignite these materials. In the assembly line of air conditioner process where the process of adhesive spraying is done near to the area where welding/brazing is taking place is considered high 81 risk. The production lay-out should be modified. The following precautions will help to prevent fire: o move the work piece to a safe location for carrying out the hot work process; o remove any combustible materials (such as flammable liquids, wood, paper, textiles, packaging or plastics) from within about 10 meters of the work; o ventilate spaces where vapors could accumulate, such as pits or trenches; o protect any combustible materials that cannot be moved, from close contact with flame, heat, sparks or hot slag. Use suitable guards or covers such as metal sheeting, mineral fiber o boards or fire retardant blankets; o Check that there are no combustible materials hidden behind walls or partitions which could be ignited, particularly if prolonged welding or cutting is planned. Some wall panels contain flammable insulation materials; use guards or covers to prevent hot particles passing through openings in floors and walls (doorways, windows, etc.); maintain a continuous fire watch during the period of the work, and for at least an hour afterwards; Keep fire extinguishers nearby. There is a risk of fire and explosion if oxy/fuel gas equipment is allowed to leak. Acetylene, Propane and other fuel gases are highly flammable, and form explosive mixtures with air and oxygen. Even small leaks can have serious consequences, particularly if they are leaking into a poorly ventilated room or confined space where the gases can accumulate. A leak of flammable gas could cause a flash fire or explosion. Gas leaks are often the result of damaged or poorly maintained gas control equipment, hoses, blowpipes and valves, poor connections and not closing valves properly after use. The following precautions will help to prevent leaks: o keep hoses clear of sharp edges and abrasive surfaces or where vehicles can run over them; o do not allow hot metal or spatter to fall on hoses; o handle cylinders carefully. Keep them in an upright position and fasten them to prevent them from falling or being knocked over. For example, chain them in a wheeled trolley or against a o wall; o always turn the gas supply off at the cylinder when the job is finished; o maintain all equipment and keep in good condition; o regularly check all connections and equipment for faults and leaks. Oxygen leaks also increase the fire risk. In particular, if clothing is contaminated with oxygen, it will catch fire easily and burn very fiercely resulting in severe injury. Even fire retardant clothing will burn if contaminated with oxygen. Also oxygen can cause explosions if used with incompatible materials. In particular, oxygen reacts explosively with oil and grease. Always take the following precautions:  never allow oil or grease to come into contact with oxygen valves or cylinder fittings;  never use oxygen with equipment not designed for it. In particular, check that the regulator is safe for oxygen and for the cylinder pressure. Back Fire and Flash back hazards: A backfire is when the flame burns back into the blowpipe often with a sharp bang. This may 82 happen when the blowpipe is held too close to the work piece, or if the nozzle is blocked or partly blocked. The flame may go out or it may re-ignite at the nozzle. Sometimes the flame burns back into the blowpipe, and burning continues at the mixing point. Backfires do not usually cause serious injury or damage but they indicate a fault in the equipment. Flashbacks are commonly caused by a reverse flow of oxygen into the fuel gas hose (or fuel into the oxygen hose), producing an explosive mixture in the hose. The flame can then burn back through the blowpipe, into the hose and may even reach the pressure regulator and the cylinder. The consequences of a flashback are potentially very serious. They can result in damage or destruction of equipment, and could even cause the cylinder to explode. This could end in serious injury to personnel and severe damage to property. To protect a cylinder, you should fit flashback arresters onto the regulator, on both the fuel and oxygen supply. Arresters may be fitted on the blowpipe but these do not give protection from a fire starting in the hose. For long lengths of hose, the arresters should be fitted on both the blowpipe and the regulator. 83 ANNEX 9 - Summary of Project Stakeholder Consultation of Generic Environmental Management Plan for the Refrigeration and Air Conditioning Sectors 1. Introduction The Project Stakeholder Consultation of Generic Environmental Management Plan (Generic EMP) for the Air- conditioning (AC) and Refrigeration Sectors under HCFC Phase out Project was organized at the meeting room of World Bank,etc. The main objective of this consultation m ee t i n g was to present the content and goal of generic EMP for Air- conditioning and refrigerant manufacturers and proposed mitigation measures for the conversion from HCFC-22 to other alternative gases such as HFC-32, NH3 or HC-290. The meeting is the second change for stakeholder consultant. 2. Background and Objectives The HCFC Phase out Management Plan (HPMP) Stage II was continued from the Stage I by M ONR E with assistance from the World Bank with the main objective to assist Vietnam to comply with the Montreal Protocol HCFC phase out obligations. The Executive Committee of the Multilateral Fund has already approved in principle the grant fund to Vietnam through the World Bank to implement activities proposed under HPMP Stage II during 2017-2020. In air-conditioning sector, HPMP Stage II will provide financial and technical assistance to 5 AC manufacturers with major Vietnamese-ownership to convert to HFC-32 or HC-290. In refrigeration sector, HPMP Stage II will provide financial and technical assistance to 34 refrigeration manufacturers among of 71 known ones. Given that 5 AC manufacturing and 34 refrigerant enterprises have been already identified and already confirmed their participation in the HPMP Stage II. The Executive Committee of the Multilateral Fund has already approved grant funds to these companies to convert to HFC-32 technology. A site- EMP must be prepared for individual enterprise following the generic EMP and be submitted as part of the sub-project proposal. Therefore, this stakeholder consultation would be a good forum to disseminate outcomes of generic EMP preparation as well as to receive valuable feedbacks from the stakeholders to improve and finalize the EMP, then later, each enterprise could complete and implement their own site- EMP. The first consultant is aimed to explore the potential risks and challenges for conversing the refrigerants during the due diligent of the World Bank team conducted from 6 to 10 November, 2015 and on 26 January, 2016. There were 11 participants from relative agencies attending this consultation, including Phuong Nam, SAREE, REE, Midea, Metero, Dien An, Darling, Ngo Long, 6M, Viet Trust, and Phu Vuong. 3. Presentation on Generic Environmental Management Plan for the Air- conditioning or Refrigeration Sectors 3.1 The consultants presented scope and content of generic EMP and provided an overview of related law and regulations for which the AC and refri geration enterprises need to comply for the conversion gas HFC-32 or NH3 and HC-290 technology, which are more flammable, therefore, all enterprises must follow and comply the following regulations such as: 84 o Occupational Safety and Health law 2015; o National Technical Regulations QCVN 06:2010/BXD by Ministry of construction regarding fire safety prevention for buildings and structures. o National Technical Standard TCVN 3890:2009 regarding Fire Prevention and Protection Equipment for buildings and structures – arrangement, check and maintenance. o National Technical Standard TCVN 5760 regarding Fire Prevention and Protection System – General requirement on design, installation and utilization. o National Technical Standard TCVN 2662: 1995 regarding Fire Prevention and Protection for Buildings and Structures – Design Requirements o TCVN 2622:1995 regarding fire prevention and protection for buildings and structures – Design requirement o TCVN 9385:2012 regarding protection of structures against lightning. o TCVN 5507: 2002 regarding “Hazardous chemicals - Code of practice for safety in production, commerce, use, handing and transportation” o Circular No. 20/2013/TT-BCT dated 5 August, 2013 on the implement of Decree No.26/2011 and regulation of plans and measures on precautions, chemical emergency response for industrial sectors. o Circular No 11/2014/TT- BCA of the Ministry of Police on Fire prevention and protection dated 12 March, 2014 on detailed regulations in Decree No. 35/2003/ND-CP dated 04 March 2003, Decree No. 46/2012/ND-CP dated 22 May 2012. o QCVN 07:2009/BTNMT: National technical regulation on hazardous waste thresholds. o Discharge, emission, and Waste management shall meet minimum requirement as stated on the QCVN 06:2009/BTNMT; QCVN 07:2009/BTNMT, QCVN 14:2006/BTNMT; QCVN 40:2011/BTNMT. 3.2 The consultant also raised the responsibility of enterprises related on environment. The discussion was opened with all stakeholders and find out that all participating enterprises were able to fulfill their legal environmental protection responsibility. o For the storage area of HFC-32 or HC-290, there is need for installation of gas detector to alert the enterprise as well as exhaust fan to dilute HFC-32 or HC-290 concentration from the ground (as they are heavier than air, the exhaust fan should installed at the low ground level); o The charging line needs to have at least exhaust fan, but the gas detector may be needed depending on the condition of the enterprise; o Refrigerant cylinder should not be put in the same place with oxygen tank. Liquefied oxygen cylinder and LPG cylinder should be 6 meter away from HFC- 32/NH3/HC-290 cylinder or must have fire wall. Crane and sling need to be check regularly; o HFC-32 is a liquefied gas and less flammable when compare with LPG. However, safety transport HFC-32 cylinder is essential. HFC-32 cylinder should be put on the 85 pallet and use fork lift to lift the pallet not directly life HFC-32 cylinder; o HFC-32 is heavier than air and will sink down. Leaked HFC-32 can penetrate to drainage system and reach smoker outside the working area. This will cause back fire to the leaked storage tank or assembly line; o Enterprise should be aware of back fire and flash back when dealing with oxygen tank. A diabetic compression and flask back arrester is important. No flashback arrester will cause back fire or flash back and lead to hire hazard; o The enterprise shall ensure that no free standing compressed gas cylinder will be allowed and avoid boiling liquid expanding vapor explosion (BLEVE). o Zoning classification of the working area was explained to the stakeholders. o The consultant emphasized the project proponents to ensure the continuity of the implementation of those mitigation measures. o NH3 is toxic and flammable gas which needs more investment and concerns on safety and fire precaution and fire fighting. 3.3 The consultant presented main potential adverse impacts due to refrigerant changes. The consultant proposed m itigation measures and good practices whi ch were introduced in the generic EMP. The major areas to be associated with alternative gases are (i) charging line, (ii) storage area of alternative gases and (iii) the storage area of finished products. 3.4 The requirements of monitoring, training and reporting was also presented. 4. Comments Received from Air-conditioning or Refrigeration Enterprises The enterprises expressed that they have experience in using LPG and thus have no objection with the proposed mitigation measures for HFC-32, NH3 and HC-290. With these mitigation measures, the enterprises can design the plant layout to suit the use of HFC-32, NH3 or HC-290. Participants expressed the following recommendations/suggestions to improve the EMP: o One enterprise raised a concern on high cost of installation of gas detector when compared to the approved funding by the Executive Committee. The approved funding may not be sufficient for the enterprise to install the device. The World Bank should consider the approval of reallocation of approved funding from other component i.e. incremental operating cost to cover the deficit of the budget; o The poor practice during transportation of finished products to the end user’s site should be improved. HCFC-22 is not flammable gas and the poor practice does not affect the safety of the transportation (but may affect the condition of the product). Awareness should be educated to the workers of the retailers and wholesalers. Moreover, the use of warning label at the box of the products would help to increase awareness of the workers; o For storage of finished product, the need for gas detector depends on the practice of the enterprises (i.e. the enterprise has checked leak test during the assembly process or not). The enterprise may consider installing sprinkle at the storage warehouse of finished product but not gas detector; o The Government or the Bank should enforce the enterprises collect and treat the old gas (HCFC-22) when doing maintenance or replacing them with new gas in service sectors to avoid discharge them to environment. 86 5. List of Stakeholders and meeting persons Mr. Dinh Hoang Chuong – tel: 003820352 Phuong Nam Company Mr. Huynh Nhat Vu – tel: 0909026262 Sai gon Electric Appliances Co., Ltd. SAREE Mr. Khoa, Administration Manager Ms. Trang, Executing manager – tel 0913909395 Metero Company Mr. Dinh Van Hien General Director Dien An Co., Ltd Mr. Nguyen Chi Toan – tel0908080123, Vice Director Mr. Doan Van Huong, Factory Manager R.E.E Electric Appliances J.S. Company Mr. Duong Van Thao, A/C factory manager Mr. Dam Hai Binh, factory manager Ms. Nguyen Thi Hoa, Admin. Officer Midea Consumer Electric (VN) Co. Ltd. Mr. Ngo Nguyen Ngoc Sang Deputy Director Phu Vuong Corp. Mr. Nguyen The Long, Vice Director 090620227 Darling Electronic –Refrigeration Co. Ltd. Mr, Ngo Tu Diep, General Director – 0903888999 Mr. Ngo Tu Quarng, Vice Director – 0902004949 Ngo Long Co. Ltd. Mr. Canh 6 M Co., Ltd. Mr. Nguyen Van Hung – factory Manager Mr. Tran Van Son – Chairman of Financial Committee Viet Trust Co., Ltd. 6. List of Stakeholders attend the 2nd consultation meeting Tran Ngoc Tuan Vice Director of Hoa Phat Com. Ltd. 87 TranThi Minh Chinh, Pham Nhat Quang My Viet Com. Ltd. Vu Manh Cuong Director of LLMC Dinh Van Hien SYTM HMC Com. Ltd. Pham Phan Anh Thu, Vu Thi Thu Thuy Nagakawa VN Tran Van Cuong Hoang Minh Quan, Le Cam Van HPMPI- PMU Photo of survey - Some snap-shots of products and activities in project enterprises Air conditioner product of Nam Air conditioner product of Air conditioner product of Phuong Co.Ltd SAREE Co.Ltd REETECH Co.Ltd Production line of AC Gas Compressor Gas recharging 88 Products Make 1 unit Packaging 89