April 17th, 2013

Overview of IFC’s scope of review

The review of this investment builds upon the appraisal and supervision of IFC’s previous investment in Samson Maritime Limited (“Samson” or the “Company”) conducted in 2008 for IFC project # 26817. Samson reports to IFC regarding the ongoing management of its environmental and social performance, which has been satisfactory. IFC’s appraisal mission in March 2013 confirmed that the company is meeting the requirements of the original investment agreement and continues to demonstrate that its activities comply with applicable Indian laws and regulations, and IFC requirements.Accordingly, the review consisted of appraising technical, environmental and social information submitted by Samson including a review of:Samson’s Safety Management System Manual; the Company’s Environment Management System; Manual; Human Resource Manual; Incident Monitoring Records; Safety Equipment (on board) inspection and testing logs including records also for mock drills, training, safety committee meetings, waste management; records of permits and certifications. The appraisal team interviewed Samson’s corporate operation, human resources (HR), health, safety and environment (HSE) managers and also vessel master.  Further, the appraisal included a visit to vessel Ocean Sapphire, which was under dry dock repairs in February 2013.

Project Description

Samson Maritime Limited is one of the established players in the business of providing offshore logistics support services to the Oil & Gas sector in India. The Samson Group has a fleet of 21 vessels which comprise Anchor Tugs, Supply Vessels, Harbor tugs, Ocean going Tugs, utility boats / vessels and barges which are deployed in: Offshore Logistics Support and Supply Services; Single Point Mooring (SPM) – Operations & Maintenance; Lighterage and Harbor Operations; and Diving & Salvage Services. IFC is considering providing Samson a loan for part financing the purchase of a new anchor handling tug supply vessel (“AHTS”), which will be deployed under contract , to support single point mooring (SPM) operations near ports or liquid petroleum product terminals along the coast of a India. The AHTSwill be Dynamic Positioning 2 (DP2) compliant, have a DWT (GT) of approximately 1850and is expected to be deployed by September/October 2013.

Identified Applicable Performance Standards

While all Performance Standards are applicable to this investment, IFC’s environmental and social due diligence indicates that the investment will have impacts which must be managed in a manner consistent with the following Performance Standards:

  • PS1 –Assessment and Management of Social and Environmental Risks and Impacts;
  • PS2 – Labor and Working Conditions; and
  • PS3 – Resource Efficiency and Pollution Prevention

There is no land acquisition and involuntary resettlement, and no impact on indigenous people or cultural property under the project, nor is it expected to impact natural habitats, forests, or protected or sensitive areas.

E&S Categorization Rationale

Similar to the categorization of the earlier investment, this is also a Category B project because a limited number of specific environmental and social impacts may result which can be avoided or mitigated by adhering to generally recognized performance standards, guidelines or design criteria.

Description of Key Environmental & Social Issues and Mitigation

The key social, environmental, health and safety risks and impacts associated with the project will include: Environmental, Health and Safety Management Systems; Labor working conditions, including occupational health and safety; Vessel safety and pollution control; and Oil spill prevention, containment and recovery. Accordingly, the Company has presented plans to address impacts of relevance to this AHTS’s operations and to ensure that the proposed Project will, upon implementation of the specific agreed measures, comply with applicable environmental, health and safety and social requirements, including: International Maritime Organization (IMO) standards under MARPOL, SOLAS andSTCW; Indian Merchant Shipping Rules and environmental, health and safety laws; and the IFC Performance Standards.  The information about how these potential impacts will be addressed by the Company is summarized in the paragraphs that follow.

PS1:  Assessment and Management of Environmental and Social Risks and Impacts

Samson has implemented a safety management system (SMS) based on International Management Code for Safe Operation of Ships and for Pollution Prevention (ISM Code). The management system supports Safety of Life at Sea (SOLAS), Marine Pollution Prevention (MARPOL) standards and applicable IMO conventions. While vessels of less than 500 GRT are not certified to ISM standards, the Company implements SMS based on ISM to these vessels as well. Further, the Company has implemented an environment management system based on ISO 14001 standards with IFC’s Performance Standards incorporated (the ISM code based SMSand ISO 14001 certified EMS together referred to as ESMS). Under the ESMS, a well defined organizational structure and processes are in place and qualified professionals have been appointed.  Samson has internal on-board safety committees for all its vessels, which meet every month. Further, there is a weekly corporate level HSE meeting.  Samson has processes for annual internal safety and environmental audits and periodic third party audits. The Company implements corrective actions based on audit findings. Samson has procedures to: monitor accidents and incident; undertake investigation and root cause analysis of incidents; implement corrective action; and transfer the lessons learned in each vessel to other vessels across the Company. The Company has procedures for monitoring, periodic reporting of safety and environmental information to Senior Management and for management review. Prior to commencement of operations of this AHTS, the Company will suitably adapt the existing ESMS and ensure adherence to this ESMS in vessel operations.

PS2: Labor and Working Conditions

Samson engages about 571 personnel in its operations including 100 shore based staff. Vessel based crew is typically on short term contracts. Conditions of employment as also wages and benefits are communicated to employees/contract workers/masters and crew in the appointment letter or contracts. The Company also has in place certified standing orders and ensures compliance to statutory requirements related to working hours, working age, wages, overtime hours, overtime wages, leaves, weekly off, misconduct and disciplinary procedures. The Company has in place a documented Human Resource (HR) Policy and Manual that includes procedures on: recruitment, induction and training; leaves and attendance; entitlement and benefits; health and safety; employee conduct and discipline; and separation. Samson has as part of the HR policies articulated and communicated to all personnel: an equal opportunities and non discrimination policy; and a grievance redress procedure.The HR Policies are available on the Company’s intranet and key policies are circulated to all employees. The Company will, for systemic improvements, upgrade its recording, documentation, monitoring and trend analysis procedures relating to employee grievances received and redressed.

Samson has an effective employee health and safety program, much of which is detailed in stringent written work procedures. Personal protective equipment is provided, as are instructions in its use.  Seafarers and shore staff undergo periodic medical examinations.  Samson crew complete basic safety training, and officers undertake advance courses in fire fighting, life saving and medical first aid. The Company’s vessels implement permit to work and lockout/tag out procedures.Fire detection, prevention and control equipment and procedures are typically in place in the vessels. Procedures are in place to check and test life saving and fire fighting appliances. Regular mock drills for fire, spill response, and medical evacuation are conducted on vessels. While Samson operates a large fleet of vessels, there have been no significant accidents in the past three years. Accidents/incidents/near misses events are documented and analyses of causes are conducted to prevent reoccurrence in the future. The Company’s existing human resource and labor working condition policies and procedures will be applicable to the employees/vessel personnel deployed in this AHTS as well. Further, Samson will ensure that the AHTS is designed, built and operated in accordance with the applicable international standards and requirements of its SMS.

PS3: Resource Efficiency and Pollution Prevention

 All of Samson’s ships have certificates issued by regulatory authorities appropriate to their tonnage indicating compliance with Indian and international safety and pollution prevention requirements.  Ships are regularly inspected, and all inspections are up to date.

The Company’s ESMS has detailed waste management procedures in accordance with appropriate MARPOL requirements. Waste, garbage and oily waste are segregated, stored appropriately, records are maintained, periodically brought ashore to be disposed at authorized port reception facilities in a manner consistent with Indian and MARPOL requirements.

Samson has implemented a Shipboard Oil Pollution Emergency Plan detailing oil/chemical spill contingency plans and procedures as part of the ISM code based SMS, which provides for shipboard and shore side response in the event of a spill resulting from Samson’s operations.  In addition, the Company has prepared Emergency Management Plan (EMP) that covers the procedures for responding to collision, grounding, fire, abandon ship, personnel overboard, personnel injury, illness, flooding, air diving, and oil spill or pollution events. The Company’s ships are suitably equipped with spill clean-up and fire fighting equipment consistent with the emergency response requirements. On-board equipment is periodically tested, and the Company’s crews are trained in emergency response by authorities. There have been no material spill incidents from Samson’s operations.

Further, Samson’s vessels participate in joint spill prevention and control drills carried out by stakeholders like coast guards, platform owners/clients.The Company will suitably define the AHTS’s/Project vessels role in the Client’s (SPM owners) and the relevant Port’s oil spillcontingency and disaster management plans (DMP), links its emergency procedures to the Client’s DMP, and actively participate in each of these respective emergency response activities and drills.

Client’s Community Engagement

Owing to the nature of Samson’s activities, no specific local communities are directly affected by risks or impacts from this project.  As a result, no formal information dissemination activities have been undertaken.  Notwithstanding, and as part of the ISO 14001 certified system , Samson will be establishing procedures for communication of the environmental aspects to external interested parties.  In addition, the Company will establish and maintain procedures for receiving, documenting and responding to concerns from any external interested parties relating to the project.

Local Access of Project Documentation

Further, the Company will disclose on its website (www.samsonmaritime.com), the measures it proposed to implement so as to conduct its operations in accordance with IFC’s Performance Standards.

Any queries and/or comments about the Project may be directed to :

Mr. Ashwin Samant, Samson Maritime Limited, 201/202, Raheja Xion, 2nd Floor, Dr. Babasaheb Ambedkar Road, Near DCP Office Zone III, Byculla (East) Mumbai – 400 027. INDIA.
Ph: +91 22 2377 9400,  +91 22 2377 9410   Fax: +91 22 2377 9499