Understanding Bonsucro Standard Report of a workshop held at Trichy 25-26 July 2011
Participants of the workshop
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Opening Session
from Bonsucro (London), WWF, AgSri Consulting, EID Parry, Prakruthi and Solidaridad.
Mr. Rajesh Dubey of Solidaridad South and South East Asia and convener of this workshop gave a brief background of the efforts that Prakruthi and EID Parry have put in to promote the concept of better sugar initiative that would be sustainable environmentally and economically.
The opening remarks and context-setting was done by Dr. Gopinathan M.C., Senior Vice-President of EID Parry. The training was facilitated abd conducted by Mr. Peter Turner and and Mr. Pat Brentley of Bonsucro, London.
There were about 20 stakeholder-participants representing sugar mills in South and North India, trainers
BONSUCRO Purpose To transform the sugarcane industry.
Bonsucro Vision To be a leader in driving the marketdemand for certified sugarcane produced against sustainable standards.
Bonsucro Mission Bonsucro aims to improve the social, environmental, and economic sustainability of sugarcane by promoting the use of a global metric standard, with the aim of continuously improving sugarcane production and downstream processing in order to contribute to a more sustainable future. 3
Opeing Remarks and Context-setting Dr Gopinathan, one of the Directors of Bonsucro set the tone and tenor the two-day programme by walking the participants through the history, vision and mission of of Bonsucro.
Dr. Gopinathan said that, on the whole, there is a change in the mindset of social and corporate entrepreneurs. There is more concern for the environment and the impact that economic activities have on ecology and what it does to global warming contributing to climate change, globally. He went on to say that sugar is as precious as gold since early days of civilization, and along with salt, sugar is the one of the oldest trading commodities. He narrated a historical perspective of sugar from the colonial days when sugar beet was in great demand. The demand has now shifted to sugarcane, he added. Sugarcane crop is also famous for employing child labour and forced/bonded labour, from the early days when sugar became a colonial commercial trading product. Presently, the sugar, like other consumer products, is also being produced to meet the ‘aspiration of customers’. Hence, sugarcane production has become more responsible by addressing the three inter-locking sectoral issues of sustainability, namely, that of the the social, economic, and of the environment. Dr. Gopinathan went on to describe the merits and advantages of certification since sugar has moved into the sphere of the ‘aspiration of customers’ and part of the value chain.
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He said that three types of certification are possible: a. Self-certification by producers and service providers. b. Government standards or rules framed by government or commerce bodies. c. Third party certification by community-based organisations or NGOs, etc. It is against this background that a group of professionals involved in sugarcane industry came together in London in 2005 to initiate a certification process for sugarcane production by the name ‘Better Sugarcane Initiative (BSI) for better sugar business. Subsequently, a few months later some of the members came together to form a ‘working group’ for Bonsucro (initially known as BSI). The group developed initial standards and piloted the same in a few countries. At the Annual General Meeting of Bonsucro in Chennai in 2009 the standard was approved by incorporating learnings from pilot projects. In London, there were just two members for the BSI, but now it has grown to 40 members/organisations that back BSI standards in several countries. Bonsucro standard is different from other existing standards as it is a metric-based whereas others are process-based standards. This standard basically applies to the sugar-producing mills. A sugar mill in Brazil obtained first certification from Bonsucro and the
Code of Conduct The Bonsucro is committed to achieving a sugar cane industry that: Promotes responsible business practices free of corruption and bribery and in compliance with relevant national laws; Respects labour and employment practices (particularly ILO core labour conventions) and provides a safe and healthy working environment; Aims for continuous improvement in production and resource efficiency; Respects the environment and aims to reduce emissions to air and water (with particular reference to climate change and green house gas emissions); Recognises the importance of biodiversity and ecosystem services in the long term viability of operations. Bonsucro is open to all who support the production, procurement and use of sugar cane and products derived from sugar who meet Bonsucro’s core principles and commit to its code of conduct. 5
certified product was bought as niche product by Coca Cola Company. Dr. Gopinathan concluded his inaugural address by saying that by opting for Bonsucro certification, the producers would be able to asses where they stand in world market in sugarcane/sugar production, and they will also learn how they can improve production/performance to match global standards. It is a win-win situation for, at the end of the day, it saves the planet for the future, without sacrificing the interests of the farmers, producers and consumers.
History June 2005 –First “better sugar: better business” meeting agrees key impacts at a conference in London 2007 -Steering Group advanced the initiative with appointment of a secretariat and TWG’s. 2008 development of measurable indicators and criteria 2008 AGM in Brazil Bonsucro is an Associate Member of ISEAL Bonsucro –Incorporated as a not-for-profit company in the UK 2009 AGM India –version 2 approved Certification model developed in parallel with business plan Bonsucro Standard Version 2010 approved Big Five package submitted for recognition of EU Renewable Energy Directive (Due May/June 2011) Auditor training commenced in February 2011 Certification to commence in June/July 2011
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Input Session 1 Mr. Pat Brenchley, agri-scientist, currently working with Solidaridad promoting the Bonsucro Standard, presented the overall plan for the two-day workshop, after which he talked about sustainability.
By way of defining ‘sustainability’, it was felt that the definition offered by the Brundtland Report in mid-1980s summed up best the thrust in the present context: “Sustainable development is development that meets the needs of the present without compromising the ability of future generations to meet their own needs.” He also briefly presented the UN Global Compact by saying that “From its inception, the Global Compact has operated on the premise that finding solutions to make markets more sustainable and inclusive can only be achieved if societal actors learn to work effectively together. The international economic order must also become more inclusive by giving billions of marginalized
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people access to global markets in a manner that guarantees equitable opportunities for development.” It is the world’s largest corporate citizenship and sustainability initiative. Since its official launch in July 2000, the initiative has grown to more than 8,000 participants, including over 5300 businesses in 130 countries, he added
Mr. Brenchley introduced the Solidaridad Pyramid of Change in which the consumers (labels) are at the top of the pyramid, the companies (particularly their CSR arms) in the middle, and sectors (round tables and industrial codes of conduct) are at the bottom. Here, the consumers make choices, companies take responsibility and sectors set conditions as a licence to operate.
All the ten principles of the Global Compact are applicable in the context of Bonsucro Standard, namely Human Rights (Principles 1 and 2), Labour (Principles 3 to 6), Environment (Principles 7 to 9) and Anticorruption (Principle 10).
Over the past few years, numerous initiatives have been developed to address the environmental and socio-economic impacts associated with the production of biofuels or of specific biofuel feedstocks, and specifically mentioned the Bio-Energy & Food Security Criteria & Indicators Project (BEFSCI), which is relevant to the current discourse.
Considerable time was also spent on introducing the Solidaridad Management Systems (SMS), in which the three important components are: 1. Internal Management Systems (IMS), often referred to as an Internal Control System; 2. Legal Register, and 3. A Manual of Better Management Practices. Mr. Brenchley explained that this Internal Management System is based on ISEAL’s Common Requirements for the Certification of Producer Groups, P035 - Public Version 1 - November, 2008, and said that therefore, there was no need to ‘re-invent the wheel’. 8
Input Session 2 Mr Pat Turner, in his session, shared more about the about the Vision, Mission and a brief history of Bonsucro, which was incorporated as not-for-profit organisation in the UK. In 2010, the pilot version of the Bonsucro Standard was approved.
Mr. Turner went on to elaborate how the Standard was developed (see box below) about its member organisations and the process adopted for developing the Standard. There are five core criteria in the Standard that need compulsory 100 per cent satisfaction while auditing. There is also a European Union-specific Bonsucro Standard as the conditions there are vastly different from other parts according to experience so far.
How the Standard was developed Technical working groups (TWGs) were created to identify indicators for which we can measure reduced impacts. TWGs draft performance standards that reduce key impacts to acceptable levels. TWG’s suggest research on impacts where there is disagreement or too little data. Identify BMPs that are put in guidance documents to help producers to reach performance levels. As an ISEAL Associate Member followed the Code of Best Practice for the development of the Standard. Built the dedicated ‘Production Standard’ website Conducted two X 60 days and one X 30 day public consultation via the website Consulted with members Conducted global Stakeholder Outreach Meetings 9
The certification protocol has three components: Audit Guidance, Production Standard, and Chain of Custody Document. A certificate is valid for three years, during which course there will be two surveillance audits. The units of certification are the mill and the cane supply area of mill.
The Standard The standard is intended to constitute an auditable document and not merely a reporting framework, according to ISO 65. All Indicator Notes have been amplified in the accompanying Bonsucro Standard Audit Guidance document. Accordingly, Members undertake to: PRINCIPLE 1. Obey the law. PRINCIPLE 2. Respect human rights and labour standards. PRINCIPLE 3. Manage input, production and processing efficiencies to enhance sustainability. PRINCIPLE 4. Actively manage biodiversity and ecosystem services. PRINCIPLE 5. Continuously improve key areas of the business . 10
The Production Standard The Bonsucro Standard is the first-ever global metric standard for sugar cane This metric Standard can precisely measure a company’s carbon footprint by monitoring global warming emissions Bonsucro provides a Greenhouse Gas Emissions Calculator Bonsucro will position a company at the fore front of global sustainability targets The Standard demonstrates through measurable impacts that a company is against child labour, supports human rights and is concerned with implementing environmentally sound practices
Input Session 3 This session comprised two sections: Introduction to the Bonsucro Production Standard by Mr. Peter Turner, and Understanding the Bonsucro Audit Manual by Mr. Pat Brenchley. The Bonsucro Standard format has the following components: a. Criteria; b. Indicators; c. Milling; d. Agriculture; e. Verifiers, and f. Notes – all based on the Principles and Criteria adopted by Bonsucro (see box). In the course of the discussion, several points that were not compatible with Indian context were pointed out by
Principles and Criteria Bonsucro Principles and Criteria (P&Cs) provide a framework within which practices can be demonstrated. The P&C address sugarcane production in the field and processing issues in the mill, including all sugarcane derived products, as they incorporate economic, financial, environmental and social dimensions and reflect good industry practices for the sugarcane sector. We believe that adoption of these P&C’s will generate business benefits and opportunities, as well as providing safe and secure employment and protection of the environment. To be effective the P&Cs need to be delivered in the context of long term economic and financial viability for individual companies and the sector as a whole, and through timely and transparent disclosure of information on company environmental and social performance to stakeholders. We further believe that the implementation of these P&Cs across the sugarcane industry is an important undertaking given the significance and growth of sugarcane and all its derived products. 11
the participants. (A detailed list of non-compatibles were recorded by Mr. Turner and Mr. Brenchley for further action and follow-up to make the Standard India-specific is found in the Annexure to this report.) Mr. Turner then shared the Bonsucro Audit Manual in detail followed by an introduction to Environmental Management Plan (EMP). Audits can be either internal or external. If internal, they can be done by two parties, called first and second parties. In the case of first party audit, it may be performed by a company or a department of its own systems, procedures and facilities. Such auditors may be from the company’s own ranks or from an external environment. It could
also be self-audit performed by an individual of his or her own systems, procedures and facilities. As for external audits, it could be performed either by a second party or a third party. Termed a supplier audit, the second party audits are performed by a company on their suppliers or sub-suppliers utilizing their own staff or external auditors. In the event of a third party audit it is conducted by external independent organisations such as registrars and regulatory authorities. These organisations provide certification or registration of conformity with requirements such as those of ISO9001 or ISO14001. Audits can be classified into different categories such as Quality management, system audits EMS audit, Systems audit, Documentation audits, Process audits, Surveillance
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audits, Follow-up audits, Pre-contract-award audits, Specification audits, Product audits, Project audits, GlobalGap, FSC, and SuSFarMS audit.
dard needs suitable modifications to to be applied to the Indian context because of the vast prevailing differences, even within the country from region to region.
Each of the audits was explained in detailed including the process to be adopted and the desired reporting format. While talking of the Environmental Management Plan, Mr. Brenchley gave a list of items when considering activities. This list included an exhortation to start the process at the earliest; to keep it simple at the start (think big, but start small); to be flexible as things change; to improve as one goes along; to learn from others; to seek support; and to make sure that success can be measured. The immprtance of assessing risk was also driven home. A clear distinction between environmental aspects and environmental impact was drawn, for determining the significant environmental aspects and associated impacts allows a facility to focus its time and resources on those issues with the greatest potential for environmental impact. It is also true that the significant environmental aspects that are identified will determine how other elements of the Standard are fulfilled. After discussions and clarifications from the floor, the group unanimously suggested that the Bonsucro Stan-
Certification Process Quick steps: Apply for and acquire Bonsucro membership Hire a Bonsucro recognisedCertification Body Complete the Self Assessment Undertake audit Upon successful completion of the audit, enter the amount of certified product into the Bonsucro Management System Claim & label Tools to help achieve certification: Producer self-assessment form GHG Calculator Online management system 13
Input Session 4 Mr. Pat Brenchley continued the session on ‘User’s Guide to Bonsucro Calculator’. Since the Standard is based on metrics, an exclusive calculator with some value has been developed and approved for the Bonsucro audit/auditors. He shared the principles on which the calculator was developed. Presenting the calculator in excel format, Mr. Brenchley explained it in detail. The participants found that most the values in the calculator were based on situations prevailing in other countries and hence not suitable for the Indian context. In this context the group discussed the ‘Command Area’ concept in Tamil Nadu and the
practices in other Indian states. It was found that most of the states do not have such a concept but have an open competitive market which forces some kind of challenge for the mills to go for Bonsucro certification. Once again touching the Environmental Management Plan, Mr. Brenchley explained the Best Management Practices (BMP) in detail. BMPs are based on knowledge derived from scientific studies. BMPs may require upgradation as new technology, legislation, thinking and methods are developed through research and should be seen as steps towards continual improvemnt. For growers they need to be practical, and for legislators, environmentalists and growers they need to be to acceptable. The adoption of BMPs must be underpinned by appropriate farm management planning (economic assessments, good budgeting, effective record keeping) andworkplace health and safety. Management of inputs and operations in sugarcane production should be aimed at sustainability. Sustainability should not mean reduced productivity and profits. Profitable cane production needs to be achieved in combination with the maintenance of the farm’s natural resources for future generations, and care for the wider environment with minimal offsite impacts.
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To ensure long-term sustainability of the sugarcane farm, BMPs must achieve: legal compliance (social and environmental); productivity and profitability improvements (economic benefit); society’s expectations, by providing opportunities to address the needs of labour and the local community (social and environmental concerns). He also indicated a few considerations for Best Management Practices such as Leaf Test and burning of cane as practised in western countries which can claim high recovery rates. However, in Indi generally only green cane is procured. This input was followed by elaborate discussions to understand the Indian context better. Participants from EID Parry shared their field experience related to EMPs and in relation to Bonsucro Standard requirements. Before winding up for the day, the participants were briefed on the field trip planned for the next day and what to note down for further discussions. 15
Field Visits Briefing
Prior to concluding the session on Day 1, the participants were briefed by Mr. Turner and Mr. Brenchley on what to observe during the visits to the field. In short, they were: 1. Soil and Water Testing Analysis; 2. Productivity and Results; 3. A few questions related to the information that was discussed in the workshop, and 4. Social indicators at the field level.
Visit to Bio-Control Production Lab
The Kolarpatti lab was the first of its kind but, now, there are many such labs in different locations.
The first visit was to Kolarpatti Village where the BioControl Production Lab is operational. The lab is managed by a farmer’s family and supported (technically and financially) by EID Parry. EID Parry staff accompanied the team of 15 members to the lab and field. The entire process of production at the lab was explained to the visitors.
These labs (mostly run by farmers’ families) supply biopesticides to other farmers and also earn a decent monthly income. This was EID encourages farmers to become technically aware, to run the labs as entrepreneurs and also promotes bio-controlled farming of sugarcane. The labs were set up based on two basic principles adhered to by EID Parry, namely:
It was in 1995 that EID Parry started the in-house airconditioned laboratory, and operated it until 2004, when it transferred the technology to the farmers/community. 16
1. No chemical pesticides to be used, and 2. Pest management must be preventive and not curative.
The EID scientist also explained the ‘technology’ used for production of such bio-labs by farmers. The terms are quite technical, but with usage and experience, the farmers have adapted fast and have started using it effectively with constant guidance of EID Parry extension officers. In simple terms, the production of bio-pesticide takes place in the manner how one produces curd from the milk using yoghurt sample at home. In 45 days, 300 trays are inoculated. Farmers using this technology can get up to 23 cc, otherwise they get maximum of 10 cc only. This particular farmer family that runs this lab earns between `10,000 and 12,000 a month from this lab business. Mr. Balu Subramany is the father-farmer and the lab is operated by his two sons, elder son’s wife and their two children. The family is happy about this work and thankful to EID Parry for this technology transfer and marketing support through which they earn a decent livelihood. Their investment is their time, labour, and a piece of land measuring about 1200 sq.ft. adjacent to their home.
the moisture is maintained steadily as required by the sugarcane crop. This is particular field also uses cow dung and earth worms by mulching which spreads and grows faster. No burning or thrashing is done here. There are many advantages to drip irrigation and organic farming, namely: Controls weeds; Moisture is maintained throughout;
Visit to Sugarcane Farm-Drip Irrigation Site
Spreads/grows earthworms;
The next visit was to the nearby farm where drip irrigation was installed for sugarcane growing. Drip irrigation uses less water compared to other conventional watering and
No fertilizers or chemical are needed; Increases the organic content; Able to measures the organic carbon content; 17
Provides better soil aeration, and Yields better even during ratoon periods.
Visit to a Conventional Sugarcane Farm The next visit was to Kaliamangalam Village where sugarcane is grown in the traditional manner. This is also a joint family farming wherein almost all the family members are involved. The irrigation is based on artificial water canals (sub-canals of river Cauveri). The trashing is done manually once every five months. The farmerbrothers and sons explained the cultivation pattern and the technical aspects of growing. They also explained the role of EID Parry in the process of cultivation to procurement.
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Visit to Namadhu Parry Mayyam Namadhu (Our) Parry Mayyam (Centre) is located in Chinnaponaiyur village of Pettavathalai block of Trichy District. This is basically promoted by EID Parry and operated by a group of farmers (like a steering group). The Centre is essentially a service provider to the farmers in its vicinity at very nominal rates/fees. Its members) also own most of the required farming equipments (semi- and fully-mechanized equipments such as trashing machine, harvesting machine, etc. Most of these machineries were purchased on loans from the bank and these loans are facilitated / assured by EID Parry on their behalf. The responsibility of loan re-
payment also lies with EID Parry. For this, an arrangement is done in such a way that when farmers hire the services of these equipments, a debit note is raised on their name, which is deducted by EID Parry at the time of sugarcane procurement (command area of EID) from those farmers and the amount is paid to the bank directly by EID Parry and the remaining amount is given to the members of Namadhu Parry Mayyam for sharing among themselves as profits. In this way, the loan payment and profitsharing are managed by EID Parry. Apart from these, the Centre also serves as a knowledge or information (agri-related) hub for farmers. The Centre is facilitated by agriculture-based technical extension officers of EID Parry. 19
Feedback and Reflection Session Following the visit, the feedback reflection session was facilitated by Mr. Pat Brenchley. Learnings and observations, especially in terms of implementing Bonsucro Standard were shared by the participants. Some the major challenges expressed were: 1. There might be process monitoring issues if certification is implemented in the farms visited because of the small-scale land holdings and the literacy levels of the farmers. 2. Governance and institutionalization issues might come up as everywhere EID Parry kind of set-up or
model may not be possible (either not existing or not feasible to build such set-up). 3. The Tamil Nadu example of the command area system is very different from what exists in other states, so feedback based on TN/EID experience alone may not be a good example for the Standard while it is finalised for India. 4. Some the information for metric calculator from the farmers may not be feasible the same has not been recorded for a long time.
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Concluding Session
be taken into consideration in the audit format as a specific input in the Indian context.
The concluding session was facilitated by Mr. Turner and he shared the Principles of the Standard in detail. Each principle was discussed threadbare in relation to the Indian sugarcane context.
During the discussions, Parry shared that it pays Rs. 250 per ton for buying the trash from the sugarcane farmers. Indian sugarcane farmers and sugar producers also strongly believe that it is not good to burn the trash in the farm lands as it has potential to impact the next batch of sugarcane crop negatively.
This was followed by a discussion on the way forward and the following points have been noted: In Tamil Nadu, farm labourers are paid a minimum of Rs.125 per day as wages and for each ton of sugarcane harvested, the wages is Rs.500 (more than two persons might be involved in harvesting a ton). The group insisted that Bonsucro auditors need to be more empathetic and understand the process holistically and positively, rather just mechanically following the metric process and calling it a ‘nonconformity’ even though the process might be efficient for the farmers.
Several field experiences were shared by EID Parry team and other sugar factory representatives in order to understand the situation better. The facilitators too patiently listened to the feedback from the group and noted down wherever it needed incorporation in the standard (see Annexure).
The group strongly recommended a process-based certification for sugarcane. Since most of the principles/indicators are based on agricultural practices, expecting documentation from farmers for certification requirements may not be viable. The role/impact of agri-support animals should also 21
Other feedback from participants were: 1. An operational manual for auditors and implementers would be ideal. 2. Reference points for each indicator (preferably contextualized to Indian Scenario) is desired. 3. Add intend to each principle for better understanding of auditor, company and farmers. 4. One or two similar training sessions are needed for refining the Standard prior to finalization. 5. Like Bonsucro EU, possibilities of adopting a Bonsucro India Standard must be explored. Following the feedback session, Mr. Rajesh Dubey thanked the organisations/participants of the workshop for their active participation and contribution. He also requested for ongoing support of the organisations until the Standard is finalised and implemented in India.
Future Activities of Bonsucro Creation of the Global Producer Innovation Network: Support producers seeking Bonsucro certification Exchange Better Management Practice information to achieve Bonsucro Certification Promote and foster innovation that will improve global performance of cane industry’s social, economic and environmental performance Create new solutions to existing problems and embed new benchmarks in the Bonsucro Production Standard Increase membership by 25% in 2011 and continue at that pace year in, year out. Certify at least 20% of sugarcane by 2015 Help lead the cane industry Establish a leadership position in addressing globally significant issues
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Annexure 1: Bonsucro Principles and Criteria and Discussions on them
join trade unions and/or to bargain collectively in accordance with the law.
Principle 1: Obey the law
Age and descriptions for child labour definition need to take into account the UNCRC categories (as well as that of the ILO). Although there is a table in the guidance document, one is not not sure if this includes UNCRC definition?
Criterion 1.1 To comply with relevant applicable laws. Indicator: Relevant national laws and international conventions complied with.
Legal issues not clear in India – there is no documentation of adherence and no documentation summarized and available for growers to access. Also, various states of the country have enacted their own legislations on various issues. Criterion 1.2 To demonstrate clear title to land in accordance with national practice and law. Indicator: The right to use the land can be demonstrated and is not legitimately contested by local communities with demonstrable rights. Principle 2: Respect Human Rights and Labour Standards Criterion 2.1 To comply with ILO Labour conventions governing child labour, forced labour, discrimination and freedom of association and the right to collective bargaining.
It is not envisaged that farmers will be able to gather proof of ‘no child labour’. EID Parry’s experience is that the issue of family and extended family working vis-avis records of labour hours, conditions, etc. will need to be considered in depth to establish an understanding of the situation. It was suggested that a committee of experts should go through the social documentation requirements carefully with the contractors, cutters, farmers and the mill. Criterion 2.2 To apply Bonsucro human rights and labour standards to suppliers and contractors. Indicator: Percentage of contractors and major suppliers who have demonstrated compliance with human rights and labour standards.
Indicator: Minimum age of workers.
Criterion 2.3 To provide a safe and healthy working environment in work place operations.
Indicator: Absence of forced or compulsory labour.
Indicator: Lost time accident frequency.
Indicator: Absence of discrimination.
Indicator: Assessment of the main health and safety risks and measures implemented for mitigation of risk.
Indicator: Respect the right of all personnel to form and
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Indicator: Appropriate personal protective equipment supplied to and used by all workers. Indicator: Training for health and safety. Indicator: Availability of sufficient safe drinking water to each worker present in the field and/or mill. Indicator: Access to first aid and provision for emergency response.
Principle 3. Manage input, production and processing efficiencies to enhance sustainability. Criterion 3.1 To monitor production and process efficiency; to measure impacts of production and processing so that improvements are made over time.
Health and safety may be a problem as Primary Health Centres are not functional in all places.
Indicator: Total raw materials used per kg product.
PPE generally not being used, even basic footwear, but apparently moving towards use.
Indicator: Working hours lost as percent of total hours.
Criterion 2.4 To provide employees and workers (including migrant, seasonal and other contract labour) with at least the national minimum wage.
Indicator: Sugarcane yield. Indicator: Mill overall time efficiency. Indicator: Factory Performance Index. Indicator: Industrial efficiency.
There is no “national minimum wage.”
Sugarcane yield needs an alternative method of calculating, as growers often send their cane to two or even three different processors (jiggery or competing mills) from the same field. Plant crops and ratoons yield differently. Could consider “soil systems” or “ecozones.”
Work on farms often done by relatives who are not paid. This is a traditional issue and should receive recognition.
Issue of farmers diverting part of their yield to a more lucrative market without declaring this to the miller (thus showing lower than expected yields).
Indicator: Ratio of lowest entry level wage including benefits to minimum wage and benefits required by law.
Although there is no minimum ‘national’ wage there are state legislations that define minimum minimum.
Criterion 3.2 To monitor global warming emissions with a view to minimizing climate change impacts.
Verifying pay to labour likely to be very difficult.
Indicator: Global warming burden per unit mass product.
Criterion 2.5: To provide clear, equitable and comprehensive contracts. 24
Indicator: Existence of a contract or equivalent document.
Are composts and organic manures included in the GHG calculation? No, but filtercake is.
Are different soil types taken into account in the GHG calculation? No.
Indicator: Herbicides and pesticides applied per hectare per year.
Terminology for vinasse, e.g. slops should be included. Principle 4. Actively manage biodiversity and ecosystem services.
Will auditors use field observation rather than documentation of field performance regarding environmental issues?
Criterion 4.1 To assess impacts of sugarcane enterprises on biodiversity and ecosystem services.
Discussion around metrics and country-specific standards.
Indicator: Aquatic oxygen demand per unit mass product.
Soil sample - a matrix required here for different regions and including soil health indicators.
Indicator: Percent of areas defined internationally or nationally as legally protected or classified as High Conservation Value areas (interpreted nationally and officially as described in Appendix 1) planted to sugarcane after the cutoff date of 1 January 2008.
Biocontrol system of parasitoid breeding by farmer entrepreneurs and supported by EID Parry provides a good example of P&D control plan for EMP indicator.
Indicator: Existence and implementation of an environmental management plan (EMP) taking into account endangered species, habitats and ecosystems as well as reference to ecosystem services and alien invader plant and animal control. Coverage of issues required in Appendix 4.
Environment: Possible to demonstrate environmentally satisfactory practices in field but difficult to provide documentary proof. Preference for a process-orientated standard due to regional differences. No reference to animal manure in the standard
Indicator: Use of co-products does not affect traditional uses (e.g. fodder, natural fertilizer, local fuel) or the soil nutrient balance or soil organic matter.
Individual indicators which are difficult - 4.1.5; 4.1.6; 4.1.7 Final record of actual fertilizer or agrochemicals applied is a problem but often this can be obtained through recommendations from Parry and subsequent records of purchases from Parry.
Indicator: Fertilizer applied according to soil or leaf analysis.
Individual indicators which are difficult - 4.1.5; 4.1.6 The use of organic and animal manures
Indicator: Nitrogen and phosphorus fertilizer (calculated as phosphate equivalent) applied per hectare per year.
Criterion 4.2 To implement measures to mitigate adverse impacts where identified. 25
Indicator: Documented plan and implementation of mitigation measures Principle 5. Continuously improve key areas of the business Criterion 5.1 To train employees and other workers in all areas of their work and develop their general skills Indicator: Training expense of worker as percentage of payroll expense. Criterion 5.2 To continuously improve the status of soil and water resources Indicator: Net water consumed per unit mass of product Indicator: Percent ground cover of tops or leaves after harvest Indicator: Soil surface mechanically tilled per year (% of area under cane). Indicator: Percent fields with samples showing analyses within acceptable limits for pH.
Not sensible because this varies tremendously. Tillage percentage will not be achievable in areas around Trichy because growers usually do not have more than three ratoons (i.e. 4 crops), which means they will be cultivating 25 per cent minimum. Re: Irrigation: This should be expanded to be more comprehensive, and if direct measurement cannot be done, then a method determined to estimate water use. 26
Water application measurements: There is a claim that these could be reasonably measured or closely estimated for well extraction, and canal extraction. (Subsequent discussion indicated perhaps this is not so simple. Currently no farmers make these sorts of measurements.) Cultivation indicator: Purpose being prevention of soil erosion – is not appropriate for Tamil Nadu – all lands are flat and erosion does not occur under current practices which require soil disturbance. Low number of ratoons means that the benchmark value is too low. Individual indicators which are difficult - 5.2 (Water measurements). Criterion 5.3 To continuously improve the quality of sugarcane and products from the mill. Indicator: Theoretical recoverable sugar content of cane. Indicator: Fermentable total sugars content of cane, expressed as invert (TSAI).
Calculator issues - 5.3 Theoretical recoverable sugar >10 appears to be difficult for some areas in India. Criterion 5.4 To promote energy efficiency. Indicator: Total net primary energy usage per kg product. Indicator: Energy used in cane transport per tonne of cane transported.
Indicator: Primary energy use per tonne of sugarcane.
Calculator issues - 5.4 Energy efficiency of electrical power used for farms may be difficult to obtain. Calculator issues - 5.4 Diesel use in agriculture – estimate only possible. Criterion 5.5 To reduce emissions and effluents. To promote recycling of waste streams where practical. Indicator: Atmospheric acidification burden per unit mass of product. Indicator: Non-hazardous solid residues per tonne of cane. Criterion 5.6 To foster effective and focused research, development and extension expertise. Indicator: Research and extension costs as a % of sales.
Individual indicators which are difficult – 5.6 need better reason for use of this standard. Criterion 5.7 For greenfield expansion or new sugarcane projects, to ensure transparent, consultative and participatory processes that address cumulative and induced effects via an environmental and social impact assessment Indicator: Compliance with a recognized ESIA (Environmental and Social Impact Assessment).
Criterion 5.8 To ensure active engagement and transparent, consultative and participatory processes with all relevant stakeholders. Indicator: Existence of a recognized grievance and dispute resolution mechanism for all stakeholders. Indicator: Percentage of meetings of stakeholder engagement where agreement has been reached by consensus driven process
Individual indicators which are difficult - 5.8 Deemed a problem. Criterion 5.9 To promote economic sustainability Indicator: Value added / tonne of cane Principle 6: Additional mandatory requirement for biofuels under the EU Renewable Energy Directive (RED). Criterion 6.1 To monitor global warming emissions with a view to minimizing climate change impacts. Indicator: Global warming burden per unit of energy. Criterion 6.2 To protect land with high biodiversity value, land with high carbon stock and peatlands. Indicator: Percentage of land with high biodiversity value, high carbon stock or peatlands planted to sugarcane after the cutoff date of 1 January 2008.
Indicator: High Conservation Value areas (interpreted nationally as described in Appendix 1) used as % of total land affected by a new project or an expansion 27
Annexure 2: Summary of Discussions as recorded by the Training Team Dr Gopinathan in the introduction emphasised that no premium should be expected but that possibilities could arise due to various market and climate changes.
Makes good sense to aspire to sustainable production and to certification in case of future opportunities. Points arising in general discussion and during presentations Need for tools to educate all growers (all will need to comply since a random sample could be selected for audit). Suggestion that due to the apparent lack of a market in India (domestic market taking up the full production) Bonsucro should create a demand by consumers to require certified sugar – Bonsucro would need to advertise the benefits of certification and convey this to potential sugar buyers. (or explain the status of certified companies and the advantages they have). Compliance levels may be too high for some indicators. Need to relax the standard or take account of regional differences. (tc/ts) More than one request for a very user friendly form of the calculator, better explanation of indicators and more complete guidance for producer including intention/purpose of the indicator. 28
Following field visit Farmers keep virtually no records themselves and most information would have to be sourced through the miller support mechanism. Social issues are challenging and a structure is needed to enable collection of data and encouragement to adhere to standards. Garden, Wet land and Dryland agricultural models – need for clear definition of terms in the Bonsucro standard. Demonstration of operations would be preferred to having to comply with a specific value for a metric – (ISO approach preferred by EID Parry) An example is the comprehensive biocontrol programme, pre trashing, parasitoid release programme etc. Overall comments from participants at end of two day training: Standard needs operational guidelines plus explanation of units. Differences between regions needs to be taken account of- suggestion of a Manual of operations by company to explain their practices and their system of addressing the principles and criteria. Reference material is currently too broad to allow a good understanding of the needs. A column to express the intention of each indicator could be added to the standard document. (“Objective” paragraph as in Audit
Guidance might be suitable?)
1. Introduction to standard
Need to contextualize each indicator and state the benefits from complying with each indicator.
2. Survey data
SUMMARY 1. Some of the participants were new to Bonsucro and needed education on the whole standard. 2. This also meant that aspects of the standard were questioned rather than just questioning the detail of implementing the standard. 3. Need more comprehensive supporting documentation or detail regarding intention of indicators and explanation of calculations. 4. Farmers do not have records in terms of social environmental or even economic aspects. 5. Health and safety and use of PPE at farmer and contract cutter team and contractor (farm mechanical operations) level needs attention as this will not comply with the standards as they are currently. 6. EID Parry does have a comprehensive information management system which could be used to generate a large amount of the required information. 7. An implementation guide (on line) would be useful. EID Parry Gap analysis exercise. Programme to discuss the standard with EID Parry and identify difficulties with standard values, or complying with the standard.
3. Discussion on calculator 4. Internal Management System (Cane Management System) EID Parry programme on training of 400, 300, then a further 300 farmers in three years was explained – survey farmers, train them with a view to them training other farmers (training of trainers concept). Social indicators As far as farmers, cutter teams and contractors are concerned social indicators and safety and health indicators will be very difficult to comply with due to no record-keeping and no contracts. (However EID Parry has systems, e.g., medical insurance cover for all workers , which can go some of the way to satisfying the needs.) Environmental indicators View expressed that metrics in general are difficult to comply with and regional differences need to be taken into account or preferably a process approach taken. The company (EID Parry) would prefer to have the opportunity to develop their own document [similar to QMS Manual] stating their reasons for desiring certification, background to the company culture, their approach, and suggesting their own target levels for the metrics or explaining their practices which aim to achieve 29
the same objective. These could be included in the Environmental Management Plan.
4. Request for an even more friendly Calculator and option for online use.
Cane Management System
5. Consider increasing the value of the Environmental Management Plan – at present this counts as a single indicator. It could be elevated to a criterion and have 10 indicators. This could replace some indicators which have been suggested for situational differences. E.g. 4.1.5; 4.1.6; 4.1.7 Nitrogen, N and P, herbicide use and 5.2 % ground cover , % area soil disturbance.
Provides an exceptional record of most operations on farms and has documentary evidence and this could be sourced from this system on behalf of the farmers. The only aspect lacking is the social/labour details. FOR BONSUCRO CONSIDERATION A. For training programmes 1. Consider developing a standard suite of training materials. 2. If possible obtain a list of participants and backgrounds before hand. B. Possible needs identified in the training 1. Consider responding to repeated requests for establishment of Country or situation specific values (see alternative point 5 below) 2. Strong sentiment that organizations should be allowed to develop their own manual of practices or target values based on the Bonsucro Principles and criteria and that this be used for certification of the organization i.e. set own targets as for ISO type standards. 3. Request for a comprehensive guidance document for auditees. 30
More pictures from the field visit
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