Labor and Working Conditions

- Human Resource Policy and Management

UEEV’s HR Policy and Procedure Manual, and Staff Manual, outline the company’s Vision, Mission and Core Values, as well as a variety of policies and conditions of employment in compliance with national law and PS2. Policies and conditions covered by the Manual include staff ethics, honesty and integrity, attendance, working hours, gifts from customers and suppliers, performance review, promotion, training, retirement, termination, holidays, leave and disciplinary procedures. All staff receive training on and sign for the receipt of the HR Policy and Procedure Manual and the Staff Manual as part of their orientation. Half yearly and yearly appraisals are conducted of staff to determine career advancement. The company’s internal grievance mechanism encourages staff to raise issues through direct discussions with immediate supervisors or managers and by e-mail directly to management. Senior management also applies an Open Door policy for issues that can’t be resolved with direct superiors. Managers have committed to ensure that issues are resolved.

- Worker’s Organizations

UEEV has paid its union fee to the local government but the local unions in each of their locations has yet to send a representative to work in the company.

- Non-discrimination and Equal Opportunity

The Staff Manual outlines the company’s human resource policy, commitment to non-discrimination and equal opportunity.

- Retrenchment

UEEV has a total of 107 staff with plans to expand to 1,203 by the year 2009. UEEV does not have plans for retrenchment as the company is expanding its operations.

- Protecting the Work Force

The company does not engage children or forced labour and it complies with local labour laws and related PS2 requirements to protect the workforce. All employees are over the age of 21 which is above the minimum required age of 18. The minimum wage ranges between 600 and 1300 RMB per month depending on staff position, experience and tenure. Workers also receive a meal allowance. Staff are not allowed to work more than 3 hours of overtime on a weekend and 8 hours on a weekend or public holiday.

- Occupational Health and Safety

A safety committee was formed at UEL Singapore HQ last year to enhance the management of safety issues and it plans to release a Health and Safety manual to cover all of UEEV’s operations and certify its operations to ISO 14001.

To protect workers’ health, the following Personal Protection Equipment (PPE) is provided: respiratory protection (N95 mask); protective clothing, goggles, shoes, helmets and foot and hand protection. All the PPE above is designed to prevent workers’ exposure to heat, dust and noise. Spill kits are provided for the proper collection of MW spillage on-site and in MW transportation vehicles. In the event that workers’ are suspected of having contact with potentially, hazardous, contagious or radioactive wastes procedures are in place for the proper isolation and treatment of workers at appropriate medical facilities and contacting relevant authorities. After each shift, workers take showers and change their clothes before leaving the working areas. Two medical check-ups are conducted per year for each worker and Hepatitis B vaccinations are provided to staff. The company is in the process of monitoring its workplace conditions and will implement corrective actions as needed. No accidents have been reported as part of UEEV’s operations.

Poluution Prevention and Abatement

- Pollution Prevention, Resource Conservation and Energy Efficiency

UEEV operates four MW treatment plants and plans to develop 28 more throughout China, utilizing three types of technologies to treat medical waste (MW). The main sources of pollution from their operations arise from releases of pollutants from vehicular exhaust during the transportation of MW to the facility, of accidental releases of MW during transportation, processing and disposal, and of pollutants as a result of MW processing.

Pollutant releases from vehicles - The company uses various vehicles to transport waste from producer sites to treatment plants. To minimize air emissions and maximize fuel consumption, the company has a vehicular maintenance program and a GPS tracking system that will monitor its drivers and route efficiency.

Accidental releases of medical waste - To prevent and minimize accidental releases of MW from transportation vehicles, the company operates vehicles with fully enclosed bodies and one, double-layered access door. Bed liners rise several inches up the side walls to act as a berm should a waste spill occur in the vehicle. Each vehicle is equipped fire extinguishers and spill kits. Drivers are trained how to respond to accidents and spills and are provided with a list of groups to be contacted in the event of a roadside spills. In addition, vehicles leaving UEEV’s facilities are required to pass through a disinfection system. All the containers used for the storage and collection of MW by sources of the waste (e.g. hospitals) and UEEV are a standard size. They are normally yellow and are puncture-proof plastic containers with locking lids. This design minimizes the release of waste should a container fall from a vehicle or be dropped during loading or temporary storage at the MW treatment facility.

Impacts arising from the processing facility - UEEV’s operates: one SIMONDS F-3D incinerator in Liaocheng; one autoclave treatment process in Jiamusi; and three dry chemical disinfection production lines, using PIWS-3000 equipment, in Anshan, Dandong and Fuxin, with plans to open four more in the near future in Jiaozuo, Xinxiang, Shaoyang and Chenzhou. In addition to the pollution prevention and mitigation measures described below for each MW processing technology, set back requirements from populated areas for all facilities have been established to minimize noise, odor and other potential impacts.

The SIMONDS F-3D incinerator at the Liaocheng uses state-of-the-art technology that adopts the necessary air pollution control equipment [scrubber system, quenching unit, HCl scrubbing unit that includes HCl scrubbing, bag house, charcoal adsorption unit and equipment] to minimise air emissions. The plant also operates an induced draft fan system and properly management of fly ash and bottom ash. Based on the technology selected and known information about the incineration process, operating temperatures in excess of 800oC will be achieved in the primary and secondary chambers of the incinerator, as required for the combustion of MW and pollutants such as dioxins and furans. While air emissions are therefore expected to comply with local and WB/IFC requirements, this will be confirmed through ongoing monitoring and corrective actions will be adopted if required. Fly ash will be concreted into solid blocks in a purpose-built, immobilized room. Bottom ash will also be stored in a separate immobilized room. Both bottom ash and concreted fly ash will be transported to landfill for disposal in a special transportation truck equipped with a canvas cover.

Autoclave technology is a steam treatment process that does not generate substantive pollutant emissions to treat MW. Bags of medical waste and other containers will be loaded into carts that will be rolled into a pressure vessel/treatment chamber. Once the door to the vessel is closed, a pre-vacuum cycle removes air that may be trapped inside of bags and containers as air can insulate the waste from steam. Steam is then introduced at approximately a temperature of 135-137oC and a pressure of 30 psi. When steam contacts the waste, it condenses onto the waste surface. This contact of steam is extremely effective at inactivating organisms. Autoclaves have been used for over 100 years in healthcare to sterilize surgical instruments. At the end of the treatment cycle (which lasts 77 minutes), a vacuum is pulled again to quickly reduce the temperature of the waste in the treatment chamber. The emissions, that comprise water (as a liquid [condensate] and vapour), will be treated on-site to remove any microorganisms. The water vapour drawn off the autoclave during the end stage evacuation cycle and the prevacuum air will go through a HEPA filter to minimize any bioaerosol release. As the end product could be hazardous if hazardous waste is introduced by the producer, UEEV has adopted procedures to track MW from each collection source and implement corrective actions on-site and with the producers.

The dry chemical process utilizes 54 tons per year of Cold-Ster® chemical powder in UEEV’s PIWS-3000 WM treatment systems. Cold-Ster® is a propriety chemical, comprised of calcium oxide (CaO) and fly ash, which is now manufactured in China. The main active ingredient is CaO or lime. Testing has been conducted to confirm that this chemical process meets the efficacy requirements of the Chinese Center for Disease Control and Prevention (CDC) for treating MW. The company has adopted industry best practice to reduce dust arising from chemical handling in the operations area by enclosing and venting the air from the grinding system to the exterior. This is a significant measure that minimizes worker exposure.

The end product of the chemical process is extremely alkaline (pH>11) and it is stored in a separate area away from the main treatment plant. As a pH level in excess of 12.5 would make the waste hazardous, pH levels in the residual will be continuously monitored. If the waste exceeds 12.5, UEEV will implement the following procedures to manage the waste stream: residues will be stored in a storage tank for at least 2.5hr, pH value will be measured on daily basis and if pH >12.5, the residues will be re-loaded into PIWS machine for re-treatment. The hopper design of the equipment contains the waste and minimizes worker exposure. The final waste residual is transported in specially designed, covered vehicles to local sanitary landfills. Air emission and effluent data from the Anshan facility, operating the dry chemical treatment process, comply with local and WB/IFC limits.

The Company has adopted the following measures to reduce energy and water consumption at its facilities and consumption data is tracked on a monthly basis: water from truck and tub washing will be treated and recycled prior to its discharge in the municipal treatment system; the incineration plant uses a heat exchanger to heat the plant and has a pyrolysis-gasification unit which allows for lower diesel, power, and water consumption as compared to rotary incinerator and grate furnace; all building material and electronic devices are selected based on their energy efficiency performance; the use of reusable containers/tubs for MW minimizes the need to purchase and dispose of single use containers; and the selection of the MW tubs parallels the selection of the vehicles so that they are “cubed out” to maximize the utilization of space in the cargo body.

- Waste and Hazardous Materials

Residual waste and sludge from the dry chemical and autoclave technologies, as well as fly ash from the incinerator, will be disposed of at authorized hazardous waste treatment facilities. Bottom ash from the incinerator and other wastes will be disposed of in sanitary landfills which are also owned and operated by the local government. Prior to disposal, wastes are temporarily stored in cold storerooms constructed according to national specifications for the storage of MW and residual wastes. The storage areas are equipped to store the treated waste, and fly ash is stored in separate, designated areas. All wastes are transported in specially-sealed vehicles.

- Emergency Preparedness and Response

UEEV has identified the following as the main risks arising from their operations: traffic accidents during the medical waste collection; fire; electric shock; impacts from operating during serious epidemics; and managing radioactive materials wrongly received for waste disposal processing. As described below, UEEV has an emergency preparedness and response plan, in compliance with national laws, to respond to these potential emergency situations. The company is also enhancing existing procedures and plans to finalize its overall system in 2008 for certification to ISO 14001.

The company’s MW transportation vehicles comply with regulatory requirements; the container of the vehicle is leak-proof with a double rear door and MW tubs are fixed by chains inside the truck container. These measures minimize MW leakage in the event of a traffic accident. Each transportation truck is equipped with a spill kit that contains personal protection equipment (uniforms and gloves), special tubs and tools, and disinfection materials and tools. All drivers are trained to minimize accidental spills or releases of MW and each truck is equipped with an Emergency Response Contract List that includes numbers for the MW treatment plant’s General Manager and the head of city’s Environmental Protection Bureau and Health Bureau.

The company’s workshop areas are designed and constructed according to national regulations on fire fighting and electrical shock. These areas area equipped with portable fire extinguishers and staff are specially assigned and trained to respond to incidents of fire, electrical shock and other emergencies. A standard emergency response system is setup in each plant according to national standards with senior staff assigned as the designated responsible persons to manage incidents. Fire extinguishing equipment is appropriately maintained and inspected regularly, fire dills are conducted at least once a year and fire safety briefings and regular trainings are conducted. Arrangements are also in place to engage assistance from the public fire brigade and the Health and Environmental Protection Bureaux if needed; and each plant has fire insurance coverage.

In the event that workers’ are suspected of having contact with potentially, hazardous, contagious or radioactive wastes, procedures are in place to stop operations, isolate people from the material, contact local authorities to collect and transport the material to the hazardous waste treatment centre for further treatment, and to provide the proper treatment of workers at appropriate medical facilities.

- Green House Gas (GHG) Emissions

While UEEV’s operations are not expected to generate GHGs in excess of 100,000 tons of CO2 annually, emissions data from the one incinerator (once it is operational) will need to be assessed to determine actual quantities of GHG emissions generated. The other treatment processes, dry chemical or autoclave, do not generate GHGs.

- Pesticide Use and Management

The company does not use or manage pesticides.

Community Health, Safety and Security:

- Community Health and Safety

Feasibility and environmental impact assessment studies were conducted by the Provincial Academy of Environmental Science for approval by local and provincial authorities, and the State Environmental Protection Agency (SEPA) as required. During each of the EIA processes for each proposed site, UEEV held two evaluation meetings with experts from relevant fields to identify and assess environmental and social risks associated with the project location, technology application, engineering and local communities. Measures have also been adopted to minimize impacts during the transportation of MW to and from UEEV’s facilities, as described under PS3.

In addition to the pollution prevention and mitigation measures described above under PS3, set back requirements from populated areas are established to minimize impacts from all the facilities on local communities. 300 meters is required for facilities using non-burn technologies and 800 meters for an incineration plant. UEEV conducts ongoing monitoring of its operations to minimize impacts and comply with relevant requirements. Each facility’s management team also maintains ongoing communications with local governments to information and respond to concerns.

- Emergency Preparedness and Response

An emergency preparedness and response plan covers potential incidents associated with UEEV’s operations. A monitoring and reporting system is in place to engage local government as needed in the event of an emergency and arrangements are in place to engage assistance from the public fire brigade and the Health and Environmental Protection Bureaux if needed. More information is provided under PS3.

- Security Personnel Requirements

Professionally managed and trained security personnel are hired to guard UEEV’s facilities 24 hours a day, 7 days a week. Contracts include requirements to meet national laws and to provide appropriate training. Guards implement a visitor registration system, separate traffic for MW vehicles and other visitor or staff traffic and ensure that the vehicles pass through the disinfection system before leaving the plant.

- Land Acquisition and Involuntary Resettlement

Land acquired by UEEV for its existing facilities was either previously used as an existing landfill, was wasteland or land for which local farmers held the land use rights. No local residents, settlers or indigenous peoples were living on land acquired by UEEV and none were living inside the allowable area for developing MW treatment facilities.

The company negotiated its land acquisition proposals with the local government and the local government in turn negotiates its acquisition with local villagers directly. The company paid a land compensation fee for each site to the local governments, according to city’s compensation regulations and as stipulated by the local government, and witnessed the payment of the compensation fee to affected farmers. The land required for each treatment facility averages around 7.5mu (5,000 square meters). For each site, the land belonged to the government and is some cases a maximum of up to 5 farmers had land use rights. Copies of the compensation agreements and receipts were provided to IFC. Compensation payments have been made for land acquired for the Anshan, Dandong, Fuxin, Jiaozuo and Liaocheng facilities. Additional arrangements are underway for Xinxiang, Shaoyang, Chenzhou and Jiamusi according to the project land acquisition payment schedule.

Corrective Action Plan

Establish a grievance mechanism for receiving and addressing grievances raised by the local community for each of UEEV’s facilities by mid 2007.

Review emissions data from the incinerator operations to assess emissions characteristics and flue gas, bottom ash and residual fly ash to determine if it is hazardous. Identify and implement corrective actions as needed to ensure compliance with local and/or WB/IFC requirements by mid-2007.

For each facility using the chemical treatment process, adopt procedures for using a DOP test to assess the HEPA filter after each change out to ensure it is properly installed, and for the temporary storage of the large bags containing the dry chemical on solid plastic pallets to avoid contact with water by mid-2007.