CSAIL-EM-ESMS-MPF-004

Contractor Management Plan Frame work

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 Contractor Management Plan Frame work CSAIL-EM-ESMS-MPF-004

1. Purpose and Applicability

Throughout a project’s life cycle, and especially during construction, a variety of contractors
may undertake activities on a project site under contract to the project company or to a
prime contractor retained by the project company. Even when work is under the control of
a primary contractor and conducted by a series of subcontractors, however, the CSAIL
project company retains ultimate responsibility for the environmental and social
performance of all contractors. Thus, is it important that the project company manage and
oversee contractor environmental and social performance of all project work. This
framework is intended to guide the means by which CSAIL project companies will manage
and oversee the environmental and social performance of contractors and subcontractors.
For new projects, the project company will develop a Contractor Management Plan prior to
engaging contractors to perform work on the project. For existing projects, the project
company will develop a Plan on a schedule established at the time of project acquisition,
which will be as soon as practicable after CSAIL assumes responsibility for the project. If the
Plan is prepared by a contractor or third party, the project company is responsible for
reviewing and approving the Plan before it is implemented.

2. Applicable Standards
There are few or no legal standards that control contractor management itself. Thus,
applicable standards are the environmental and social requirements that project company
must ensure that contractors meet. These include the requirements of host-country
national law, CSAIL and project company environmental and social objectives and relevant
policies, plans, standards, specifications and guidelines, and good international industry
practice. The standards that apply in any particular case should be taken from the
Environmental and Social Impact Assessment or other assessment of potential impacts,
including due diligence reports.
Key applicable standards include:
• CTG Internal Management Protocols
- Manual of quality, environmental, occupational health and safety management
(QG/CTG 01.03—2012), Section 7.3.5 Purchasing Management; Section 7.5 Environment
Operation Management, Section 7.6 Occupational Health Safety Management
- CTG Management Regulation for Contract Management (For trial implementation)
(CTG-G2-HT-01-2012),
- CTG Management Regulation for Bidding and Purchasing (For trial implementation)
(CTG-G2-ZT-01-2012),
- CTG Management Regulation for Environmental Protection (For trial
implementation) (QG/CTG 06.01 —2011), Section4, Section5.
- CTG Monitoring Management Measures for Energy Conservation and Emission
Reduction (For trial implementation) (QG/CTG 06.04—2012)
- CTG Management measures for environmental protection of hydropower project
(QG/CTG 06.05 —2012)

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 Contractor Management Plan Frame work CSAIL-EM-ESMS-MPF-004

- CTG Assessment management measures for environmental protection (QG/CTG

06.06 —2012)
• Legal standards that may apply to project companies, and thus must be imposed
upon contractors, National, regional, and local legislation to control or protect;
- Water efficiency and conservation
- Water quality and water pollution
- Air quality
- Aquatic and terrestrial biodiversity protection
- Protected areas conservation
- Natural resource conservation and exploitation
- Traffic and road safety
- Occupational health and safety
- Labour standards and labour relations
- Waste management
- Hazardous materials management
- Emergency preparedness and response
- Cultural resources and heritage
- Land acquisition and condemnation
• International Conventions and Protocols ratified/signed by the host country, which
could include;
- Basel Convention on the Control of Trans boundary Movements of Hazardous
Wastes and Their Disposal
- Convention on Wetlands of International Importance, especially as Waterfowl
Habitat (Ramsar Convention)
- Convention on International Trade in Endangered Species of Wild Fauna and Flora
(CITES)
- United Nations Framework Convention on Climate Change (UNFCCC)
- Kyoto Protocol to the United Nations Framework Convention on Climate Change
(Kyoto Protocol)
- Montreal Protocol on Substances that Deplete the Ozone Layer (Montreal protocol)
- United Nations Convention to Combat Desertification (UNCCD)
- United Nations Convention on the Law of Sea (LOS)
- Stockholm Convention on Persistent Organic Pollutants (POPs)
- Convention Concerning the Protection of World Culture and Natural Heritage (World
heritage convention), 1972
- International Plant Protection Convention, 1951
• IFC Performance Standards on Social and Environmental Sustainability

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- Performance Standard 1: Social and Environmental Assessment and Management

Systems
- Performance Standard 2: Labour and Working Conditions
- Performance Standard 3: Pollution Prevention and Abatement
- Performance Standard 4: Community Health, Safety and Security
- Performance Standard 5: Land Acquisition and Involuntary Resettlement
- Performance Standard 6: Biodiversity Conservation and Sustainable Natural
Resource Management
- Performance Standard 7: Indigenous Peoples
- Performance Standard 8: Cultural Heritage
• IFC Environmental, Health, and Safety Guidelines
- General Guideline
- Wind Energy
- Electric Power Transmission and Distribution

3. Approach and Activities

It is essential that applicable requirements relevant to each contractor’s responsibilities be
part of the contract. It is preferable that requirements be considered as an integral part of
the tendering and contract award process. Wherever possible, therefore, requirements
relevant to the activities being procured, including mitigation measures required by the ESIA
or other assessment document, should be part of requests for tenders/proposals.
Tenderers/bidders in turn should be required to describe their approach, in as much detail
as possible, to meeting environmental and social requirements (including subcontractor
management and oversight) in their tenders/proposals, and that should have been
evaluated as part of the selection process.
Where contractor selection allows this approach, the Plan can be focused on ensuring the
contractor meets the commitments made in proposals/tenders. Where contractor selection
falls short of this ideal, the project company must ensure the prospective contractor
understands their environmental and social obligation has the capacity to meet those
obligations.
In developing and implementing the Plan, the project company will need to work with the
contractor(s) to:
• Understand the project company understands the prime contractor’s subcontracting
program, including the roles and responsibilities of all subcontractors in ensuring
environmental and social requirements are implemented and standards are met.
• Ensure the contractor understands its environmental and social obligations and the
obligations of all subcontractors, and that appropriate environmental and social
requirements are included in subcontracts.
• Agree on responsibilities for development and implementation of management
plans that are or will become part of the overall ESMMP.

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 Contractor Management Plan Frame work CSAIL-EM-ESMS-MPF-004

• Define and set requirements for the contractor’s, and all subcontractors’,
organization and staffing plan for meeting environmental and social obligations. For the
prime contractor and major subcontractors, the project company will need to review and
approve the qualifications and performance of those who are responsible for environmental
and social performance. The prime contractor will need to do the same for subcontractors
with significant environmental or social responsibilities.
• Define the resources that must be allocated on an ongoing basis to achieve effective
implementation of environmental and social requirements, including development of
various management plans that will become part of the ESMMP.
• Define the monitoring and reporting obligations of the contractor, and the reporting
obligations of subcontractors.

4. Monitoring, Recordkeeping and Reporting

The Plan must call for the project company to routinely monitor the performance of the
contractors with respect to ESMMP requirements, and to monitor prime contractors’
management and oversight of their subcontractors. Monitoring is to be accomplished by
inspecting records and reports, and by conducting routine and unannounced visits to project
sites to observe contractor performance.
The Plan will include specific requirements for monitoring each contractor, including;
• Procedures for Monitoring
- The key activities which could have a significant environmental impact, in order to
evaluate compliance with applicable standards and contract requirements, and the
contractors’ own monitoring program.
- Prime contractors’ implementation of their sub-contractor monitoring program,
which will have been agreed upon or immediately following contract award.
• Qualifications of person(s) who will review reports and conduct inspections.
• The minimum frequency of planned and unannounced monitoring and timeframes
for follow up monitoring in case of unsatisfactory results.
• Actions to be taken in case of unsatisfactory performance, whether environmental
and social performance or performance of the monitoring program.
• Records that must be kept and the person(s) responsible for keeping the records.
• Reports that will be prepared, to whom the reports are to be submitted for review,
and the length of time records will be kept.

5. Implementation
The Plan must identify and describe the roles and responsibilities of individual positions
within the project company. It should also identify the major position(s) within contractor
companies (prime contractors only), which will be subject to project company review and
approval.

6. Training
The Plan must identify training requirements for staff and managers of the project company,
including who will be responsible for conducting the training and who must be trained in

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what skills. Training will focus on the assigned responsibilities of the trainees, and will
encompass cover technical and administrative skills needed to perform assigned
responsibilities. For purposes of this Plan, primary responsibilities are related to contract
management, reviewing reports, and conducting inspections. In addition, staffs who are
normally involved in contract management rather than environmental and social
performance may require some familiarization with the meaning of environmental and
social requirements that are placed in contracts.

7. Relationship to other Plans

Every other sub-plan of the Environmental and Social Management and Monitoring Plan is
related to the Contractor Management Plan since the requirements of any of these other
plans that are delegated to contractors will be subject to monitoring by the project
company.

8. Revision
The Plan will be reviewed at least annually and will be revised if necessary to update
contractor management procedures and requirements. In addition, it will be updated at the
time any new contractor becomes responsible for any aspect of project activities.

Disclaimer: “This document is uncontrolled once printed”

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