Understanding Bonsucro StandardReport of a workshop held at Trichy

25-26 July 2011

2

Participants of the workshop

Opening Session

Mr. Rajesh Dubey of Solidaridad South and South EastAsia and convener of this workshop gave a briefbackground of the efforts that Prakruthi and EID Parryhave put in to promote the concept of better sugarinitiative that would be sustainable environmentally andeconomically.

There were about 20 stakeholder-participantsrepresenting 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 forcertified sugarcane produced against sustainablestandards.

Bonsucro Mission

Bonsucro aims to improve the social, environmental,and economic sustainability of sugarcane bypromoting the use of a global metric standard, withthe aim of continuously improving sugarcaneproduction and downstream processing in orderto contribute to a more sustainable future.

from Bonsucro (London), WWF, AgSri Consulting, EIDParry, Prakruthi and Solidaridad.

The opening remarks and context-setting was done byDr. Gopinathan M.C., Senior Vice-President of EID Parry.The training was facilitated abd conducted by Mr. PeterTurner and and Mr. Pat Brentley of Bonsucro, London.

3

Dr Gopinathan, one of the Directors of Bonsucro set thetone and tenor the two-day programme by walking theparticipants through the history, vision and mission ofof Bonsucro.

Opeing Remarks andContext-setting

Dr. Gopinathan said that, on the whole, there is a changein the mindset of social and corporate entrepreneurs.There is more concern for the environment and theimpact that economic activities have on ecology andwhat it does to global warming contributing to climatechange, globally.

He went on to say that sugar is as precious as gold sinceearly days of civilization, and along with salt, sugar isthe one of the oldest trading commodities. He narrateda historical perspective of sugar from the colonial dayswhen sugar beet was in great demand. The demand hasnow shifted to sugarcane, he added.

Sugarcane crop is also famous for employing child labourand forced/bonded labour, from the early days whensugar became a colonial commercial trading product.Presently, the sugar, like other consumer products, isalso being produced to meet the ‘aspiration of customers’.Hence, sugarcane production has become moreresponsible by addressing the three inter-locking sectoralissues of sustainability, namely, that of the the social,economic, and of the environment.

Dr. Gopinathan went on to describe the merits andadvantages of certification since sugar has moved intothe sphere of the ‘aspiration of customers’ and part ofthe value chain.

4

He said that three types of certification are possible:

a. Self-certification by producers and service providers.

b. Government standards or rules framed bygovernment or commerce bodies.

c. Third party certification by community-basedorganisations or NGOs, etc.

It is against this background that a group of professionalsinvolved in sugarcane industry came together in Londonin 2005 to initiate a certification process for sugarcaneproduction by the name ‘Better Sugarcane Initiative (BSI)for better sugar business. Subsequently, a few monthslater some of the members came together to form a‘working group’ for Bonsucro (initially known as BSI).The group developed initial standards and piloted thesame in a few countries. At the Annual General Meetingof Bonsucro in Chennai in 2009 the standard wasapproved 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 thatback BSI standards in several countries.

Bonsucro standard is different from other existingstandards as it is a metric-based whereas others areprocess-based standards. This standard basically appliesto the sugar-producing mills. A sugar mill in Brazilobtained first certification from Bonsucro and the

Code of ConductThe Bonsucro is committed to achieving a sugarcane industry that:

Promotes responsible business practices free ofcorruption and bribery and in compliance withrelevant national laws;

Respects labour and employment practices(particularly ILO core labour conventions) andprovides a safe and healthy workingenvironment;

Aims for continuous improvement in productionand resource efficiency;

Respects the environment and aims to reduceemissions to air and water (with particularreference to climate change and green housegas emissions);

Recognises the importance of biodiversity andecosystem services in the long term viability ofoperations.

Bonsucro is open to all who support theproduction, procurement and use of sugar caneand products derived from sugar who meetBonsucro’s core principles and commit to its codeof conduct.

5

certified product was bought as niche product by CocaCola Company.

Dr. Gopinathan concluded his inaugural address by sayingthat by opting for Bonsucro certification, the producerswould be able to asses where they stand in world marketin sugarcane/sugar production, and they will also learnhow they can improve production/performance to matchglobal standards. It is a win-win situation for, at theend of the day, it saves the planet for the future, withoutsacrificing the interests of the farmers, producers andconsumers.

History

June 2005 –First “better sugar: better business”meeting agrees key impacts at a conference inLondon

2007 -Steering Group advanced the initiativewith appointment of a secretariat and TWG’s.

2008 development of measurable indicators andcriteria

2008 AGM in Brazil

Bonsucro is an Associate Member of ISEAL

Bonsucro –Incorporated as a not-for-profit com-pany in the UK

2009 AGM India –version 2 approved

Certification model developed in parallel withbusiness plan

Bonsucro Standard Version 2010 approved

Big Five package submitted for recognition ofEU Renewable Energy Directive (Due May/June2011)

Auditor training commenced in February 2011

Certification to commence in June/July 2011

6

Input Session 1

Mr. Pat Brenchley, agri-scientist, currently working withSolidaridad promoting the Bonsucro Standard, presentedthe overall plan for the two-day workshop, after whichhe talked about sustainability.

By way of defining ‘sustainability’, it was felt that thedefinition offered by the Brundtland Report in mid-1980ssummed up best the thrust in the present context:“Sustainable development is development that meets theneeds of the present without compromising the abilityof future generations to meet their own needs.”

He also briefly presented the UN Global Compact bysaying that “From its inception, the Global Compact hasoperated on the premise that finding solutions to makemarkets more sustainable and inclusive can only beachieved if societal actors learn to work effectively to-gether. The international economic order must also be-come more inclusive by giving billions of marginalized

7

people access to global markets in a manner that guar-antees equitable opportunities for development.” It isthe world’s largest corporate citizenship andsustainability initiative. Since its official launch in July2000, the initiative has grown to more than 8,000 par-ticipants, including over 5300 businesses in 130 coun-tries, he added

All the ten principles of the Global Compact areapplicable in the context of Bonsucro Standard, namelyHuman Rights (Principles 1 and 2), Labour (Principles3 to 6), Environment (Principles 7 to 9) and Anti-corruption (Principle 10).

Considerable time was also spent on introducing theSolidaridad Management Systems (SMS), in which thethree important components are:

1. Internal Management Systems (IMS), often referredto as an Internal Control System;

2. Legal Register, and

3. A Manual of Better Management Practices.

Mr. Brenchley explained that this Internal ManagementSystem is based on ISEAL’s Common Requirements forthe Certification of Producer Groups, P035 - Public Ver-sion 1 - November, 2008, and said that therefore, therewas no need to ‘re-invent the wheel’.

Mr. Brenchley introduced the Solidaridad Pyramid ofChange in which the consumers (labels) are at the top ofthe pyramid, the companies (particularly their CSR arms)in the middle, and sectors (round tables and industrialcodes of conduct) are at the bottom. Here, the consumersmake choices, companies take responsibility and sectorsset conditions as a licence to operate.

Over the past few years, numerous initiatives have beendeveloped to address the environmental and socio-eco-nomic impacts associated with the production of biofuelsor of specific biofuel feedstocks, and specifically men-tioned the Bio-Energy & Food Security Criteria & Indica-tors Project (BEFSCI), which is relevant to the currentdiscourse.

8

How the Standard was developedTechnical working groups (TWGs) were created toidentify indicators for which we can measure reducedimpacts.TWGs draft performance standards that reduce keyimpacts to acceptable levels.TWG’s suggest research on impacts where there isdisagreement or too little data.Identify BMPs that are put in guidance documentsto help producers to reach performance levels.As an ISEAL Associate Member followed the Codeof Best Practice for the development of the Standard.Built the dedicated ‘Production Standard’ websiteConducted two X 60 days and one X 30 day publicconsultation via the websiteConsulted with members

Conducted global Stakeholder Outreach Meetings

Mr Pat Turner, in his session, shared more about theabout the Vision, Mission and a brief history of Bonsucro,which was incorporated as not-for-profit organisationin the UK. In 2010, the pilot version of the BonsucroStandard was approved.

Mr. Turner went on to elaborate how the Standard wasdeveloped (see box below) about its member organisationsand the process adopted for developing the Standard.

There are five core criteria in the Standard that needcompulsory 100 per cent satisfaction while auditing.There is also a European Union-specific BonsucroStandard as the conditions there are vastly different fromother parts according to experience so far.

Input Session 2

9

The StandardThe standard is intended to constitute an auditabledocument and not merely a reporting framework,according to ISO 65. All Indicator Notes have beenamplified in the accompanying Bonsucro StandardAudit Guidance document.

Accordingly, Members undertake to:

PRINCIPLE 1. Obey the law.

PRINCIPLE 2. Respect human rights and labourstandards.

PRINCIPLE 3. Manage input, production andprocessing efficiencies to enhance sustainability.

PRINCIPLE 4. Actively manage biodiversity andecosystem services.

PRINCIPLE 5. Continuously improve key areas ofthe business .

The certification protocol has three components: AuditGuidance, Production Standard, and Chain of CustodyDocument. A certificate is valid for three years, duringwhich course there will be two surveillance audits. Theunits of certification are the mill and the cane supplyarea of mill.

The Production StandardThe Bonsucro Standard is the first-ever globalmetric standard for sugar cane

This metric Standard can precisely measure acompany’s carbon footprint by monitoring glo-bal warming emissions Bonsucro provides aGreenhouse Gas Emissions Calculator

Bonsucro will position a company at the forefront of global sustainability targets

The Standard demonstrates through measurableimpacts that a company is against child labour,supports human rights and is concerned withimplementing environmentally sound practices

10

Input Session 3

This session comprised two sections: Introduction to theBonsucro Production Standard by Mr. Peter Turner, andUnderstanding the Bonsucro Audit Manual by Mr. PatBrenchley.

The Bonsucro Standard format has the followingcomponents: a. Criteria; b. Indicators; c. Milling; d.Agriculture; e. Verifiers, and f. Notes – all based on thePrinciples and Criteria adopted by Bonsucro (see box).

In the course of the discussion, several points that werenot compatible with Indian context were pointed out by

Principles and CriteriaBonsucro Principles and Criteria (P&Cs) provide aframework within which practices can be demon-strated. The P&C address sugarcane production inthe field and processing issues in the mill, includ-ing all sugarcane derived products, as they incor-porate economic, financial, environmental and so-cial dimensions and reflect good industry practicesfor the sugarcane sector.

We believe that adoption of these P&C’s willgenerate business benefits and opportunities, aswell as providing safe and secure employment andprotection of the environment.

To be effective the P&Cs need to be delivered inthe context of long term economic and financialviability for individual companies and the sector asa whole, and through timely and transparent dis-closure of information on company environmentaland social performance to stakeholders.

We further believe that the implementation of theseP&Cs across the sugarcane industry is an importantundertaking given the significance and growth ofsugarcane and all its derived products.

11

the participants. (A detailed list of non-compatibles wererecorded by Mr. Turner and Mr. Brenchley for furtheraction and follow-up to make the Standard India-specificis found in the Annexure to this report.)

Mr. Turner then shared the Bonsucro Audit Manual indetail followed by an introduction to EnvironmentalManagement Plan (EMP).

Audits can be either internal or external. If internal, theycan be done by two parties, called first and second parties.In the case of first party audit, it may be performed by acompany or a department of its own systems, proceduresand facilities. Such auditors may be from the company’sown ranks or from an external environment. It could

also be self-audit performed by an individual of his orher own systems, procedures and facilities. As for externalaudits, it could be performed either by a second party ora third party. Termed a supplier audit, the second partyaudits are performed by a company on their suppliers orsub-suppliers utilizing their own staff or external auditors.In the event of a third party audit it is conducted byexternal independent organisations such as registrars andregulatory authorities. These organisations providecertification or registration of conformity withrequirements such as those of ISO9001 or ISO14001.

Audits can be classified into different categories such asQuality management, system audits EMS audit, Systemsaudit, Documentation audits, Process audits, Surveillance

12

audits, Follow-up audits, Pre-contract-award audits,Specification audits, Product audits, Project audits,GlobalGap, FSC, and SuSFarMS audit.

Each of the audits was explained in detailed includingthe process to be adopted and the desired reportingformat.

While talking of the Environmental Management Plan,Mr. Brenchley gave a list of items when consideringactivities. This list included an exhortation to start theprocess 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; toseek support; and to make sure that success can bemeasured. The immprtance of assessing risk was alsodriven home.

A clear distinction between environmental aspects andenvironmental impact was drawn, for determining thesignificant environmental aspects and associated impactsallows a facility to focus its time and resources on thoseissues with the greatest potential for environmental im-pact. It is also true that the significant environmentalaspects that are identified will determine how other ele-ments of the Standard are fulfilled.

After discussions and clarifications from the floor, thegroup unanimously suggested that the Bonsucro Stan-

Certification ProcessQuick steps:

Apply for and acquire Bonsucro membership

Hire a Bonsucro recognisedCertification Body

Complete the Self Assessment

Undertake audit

Upon successful completion of the audit, enterthe amount of certified product into theBonsucro Management System

Claim & label

Tools to help achieve certification:

Producer self-assessment form

GHG Calculator

Online management system

dard needs suitable modifications to to be applied tothe Indian context because of the vast prevailing differ-ences, even within the country from region to region.

13

Input Session 4

Mr. Pat Brenchley continued the session on ‘User’s Guideto Bonsucro Calculator’. Since the Standard is based onmetrics, an exclusive calculator with some value has beendeveloped and approved for the Bonsucro audit/auditors.He shared the principles on which the calculator wasdeveloped.

Presenting the calculator in excel format, Mr. Brenchleyexplained it in detail. The participants found that mostthe values in the calculator were based on situationsprevailing in other countries and hence not suitable forthe Indian context. In this context the group discussedthe ‘Command Area’ concept in Tamil Nadu and the

practices in other Indian states. It was found that mostof the states do not have such a concept but have anopen competitive market which forces some kind of chal-lenge for the mills to go for Bonsucro certification.

Once again touching the Environmental ManagementPlan, Mr. Brenchley explained the Best ManagementPractices (BMP) in detail.

BMPs are based on knowledge derived from scientificstudies. BMPs may require upgradation as newtechnology, legislation, thinking and methods aredeveloped through research and should be seen as stepstowards continual improvemnt. For growers they needto be practical, and for legislators, environmentalists andgrowers they need to be to acceptable. The adoption ofBMPs must be underpinned by appropriate farmmanagement planning (economic assessments, goodbudgeting, effective record keeping) andworkplace healthand safety.

Management of inputs and operations in sugarcane pro-duction should be aimed at sustainability. Sustainabilityshould not mean reduced productivity and profits. Prof-itable cane production needs to be achieved in combi-nation with the maintenance of the farm’s natural re-sources for future generations, and care for the widerenvironment with minimal offsite impacts.

14

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 opportunitiesto address the needs of labour and the localcommunity (social and environmental concerns).

He also indicated a few considerations for BestManagement Practices such as Leaf Test and burning ofcane as practised in western countries which can claimhigh recovery rates. However, in Indi generally only greencane is procured.

This input was followed by elaborate discussions tounderstand the Indian context better. Participants fromEID Parry shared their fieldexperience related to EMPs andin relation to Bonsucro Standardrequirements.

Before winding up for the day,the participants were briefed onthe field trip planned for thenext day and what to note downfor further discussions.

15

Field VisitsBriefing

Prior to concluding the session on Day 1, the participantswere briefed by Mr. Turner and Mr. Brenchley on whatto observe during the visits to the field. In short, theywere:

1. Soil and Water Testing Analysis;

2. Productivity and Results;

3. A few questions related to the information thatwas discussed in the workshop, and

4. Social indicators at the field level.

Visit to Bio-Control Production Lab

The first visit was to Kolarpatti Village where the Bio-Control Production Lab is operational. The lab is managedby a farmer’s family and supported (technically andfinancially) by EID Parry. EID Parry staff accompaniedthe team of 15 members to the lab and field. The entireprocess of production at the lab was explained to thevisitors.

It was in 1995 that EID Parry started the in-house air-conditioned laboratory, and operated it until 2004, whenit transferred the technology to the farmers/community.

The Kolarpatti lab was the first of its kind but, now,there are many such labs in different locations.

These labs (mostly run by farmers’ families) supply bio-pesticides to other farmers and also earn a decentmonthly income. This was EID encourages farmers tobecome technically aware, to run the labs as entrepre-neurs and also promotes bio-controlled farming of sug-arcane. The labs were set up based on two basic prin-ciples adhered to by EID Parry, namely:

1. No chemical pesticides to be used, and

2. Pest management must be preventive and notcurative.

16

The EID scientist also explained the ‘technology’ usedfor production of such bio-labs by farmers. The termsare quite technical, but with usage and experience, thefarmers have adapted fast and have started using iteffectively with constant guidance of EID Parry extensionofficers. In simple terms, the production of bio-pesticidetakes place in the manner how one produces curd fromthe milk using yoghurt sample at home. In 45 days, 300trays are inoculated. Farmers using this technology canget up to 23 cc, otherwise they get maximum of 10 cconly.

This particular farmer family that runs this lab earnsbetween `10,000 and 12,000 a month from this labbusiness. Mr. Balu Subramany is the father-farmer andthe lab is operated by his two sons, elder son’s wife andtheir two children. The family is happy about this workand thankful to EID Parry for this technology transferand marketing support through which they earn a decentlivelihood. Their investment is their time, labour, and apiece of land measuring about 1200 sq.ft. adjacent totheir home.

Visit to Sugarcane Farm-Drip Irrigation Site

The next visit was to the nearby farm where drip irrigationwas installed for sugarcane growing. Drip irrigation usesless water compared to other conventional watering and

the moisture is maintained steadily as required by thesugarcane crop. This is particular field also uses cowdung and earth worms by mulching which spreads andgrows faster. No burning or thrashing is done here. Thereare many advantages to drip irrigation and organicfarming, namely:

Controls weeds;

Moisture is maintained throughout;

Spreads/grows earthworms;

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 wheresugarcane is grown in the traditional manner. This isalso a joint family farming wherein almost all the familymembers are involved. The irrigation is based on artificialwater canals (sub-canals of river Cauveri). The trashingis done manually once every five months. The farmer-brothers and sons explained the cultivation pattern andthe technical aspects of growing. They also explainedthe role of EID Parry in the process of cultivation toprocurement.

Visit to Namadhu Parry Mayyam

Namadhu (Our) Parry Mayyam (Centre) is located inChinnaponaiyur village of Pettavathalai block of TrichyDistrict. This is basically promoted by EID Parry andoperated by a group of farmers (like a steering group).The Centre is essentially a service provider to the farmersin its vicinity at very nominal rates/fees.

Its members) also own most of the required farmingequipments (semi- and fully-mechanized equipmentssuch as trashing machine, harvesting machine, etc. Mostof these machineries were purchased on loans from thebank and these loans are facilitated / assured by EIDParry on their behalf. The responsibility of loan re-

18

payment also lies with EID Parry. For this, an arrangementis done in such a way that when farmers hire the servicesof these equipments, a debit note is raised on their name,which is deducted by EID Parry at the time of sugarcaneprocurement (command area of EID) from those farmersand the amount is paid to the bank directly by EID Parryand the remaining amount is given to the members ofNamadhu Parry Mayyam for sharing among themselvesas profits. In this way, the loan payment and profit-sharing are managed by EID Parry.

Apart from these, the Centre also serves as a knowledgeor information (agri-related) hub for farmers. The Centreis facilitated by agriculture-based technical extensionofficers of EID Parry.

19

Feedback and Reflection Session

Following the visit, the feedback reflection session wasfacilitated by Mr. Pat Brenchley. Learnings andobservations, especially in terms of implementingBonsucro Standard were shared by the participants. Somethe major challenges expressed were:

1. There might be process monitoring issues ifcertification is implemented in the farms visitedbecause of the small-scale land holdings and theliteracy levels of the farmers.

2. Governance and institutionalization issues mightcome up as everywhere EID Parry kind of set-up or

model may not be possible (either not existing ornot feasible to build such set-up).

3. The Tamil Nadu example of the command areasystem is very different from what exists in otherstates, so feedback based on TN/EID experiencealone may not be a good example for the Standardwhile it is finalised for India.

4. Some the information for metric calculator fromthe farmers may not be feasible the same has notbeen recorded for a long time.

20

be taken into consideration in the audit format asa specific input in the Indian context.

During the discussions, Parry shared that it paysRs. 250 per ton for buying the trash from thesugarcane farmers. Indian sugarcane farmers andsugar producers also strongly believe that it is notgood to burn the trash in the farm lands as it haspotential to impact the next batch of sugarcanecrop negatively.

Several field experiences were shared by EID Parryteam and other sugar factory representatives inorder to understand the situation better. Thefacilitators too patiently listened to the feedbackfrom the group and noted down wherever it neededincorporation in the standard (see Annexure).

Concluding Session

The concluding session was facilitated by Mr. Turnerand he shared the Principles of the Standard in detail.Each principle was discussed threadbare in relation tothe Indian sugarcane context.

This was followed by a discussion on the way forwardand the following points have been noted:

In Tamil Nadu, farm labourers are paid a minimumof Rs.125 per day as wages and for each ton ofsugarcane harvested, the wages is Rs.500 (morethan two persons might be involved in harvestinga ton).

The group insisted that Bonsucro auditors need tobe more empathetic and understand the processholistically and positively, rather just mechanicallyfollowing the metric process and calling it a ‘non-conformity’ even though the process might beefficient for the farmers.

The group strongly recommended a process-basedcertification for sugarcane. Since most of theprinciples/indicators are based on agriculturalpractices, expecting documentation from farmersfor certification requirements may not be viable.

The role/impact of agri-support animals should also21

Future Activities of Bonsucro

Creation of the Global Producer InnovationNetwork:

Support producers seeking Bonsucro certification

Exchange Better Management Practice inform-ation to achieve Bonsucro Certification

Promote and foster innovation that will improveglobal performance of cane industry’s social,economic and environmental performance

Create new solutions to existing problems andembed new benchmarks in the BonsucroProduction Standard

Increase membership by 25% in 2011 andcontinue 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 addressingglobally significant issues

Other feedback from participants were:

1. An operational manual for auditors andimplementers would be ideal.

2. Reference points for each indicator (preferablycontextualized to Indian Scenario) is desired.

3. Add intend to each principle for better under-standing of auditor, company and farmers.

4. One or two similar training sessions are needed forrefining the Standard prior to finalization.

5. Like Bonsucro EU, possibilities of adopting aBonsucro India Standard must be explored.

Following the feedback session, Mr. Rajesh Dubeythanked the organisations/participants of the workshopfor their active participation and contribution. He alsorequested for ongoing support of the organisations untilthe Standard is finalised and implemented in India.

22

Annexure 1: Bonsucro Principles and Criteriaand Discussions on them

Principle 1: Obey the law

Criterion 1.1 To comply with relevant applicable laws.

Indicator: Relevant national laws and internationalconventions complied with.

Legal issues not clear in India – there is nodocumentation of adherence and no documentationsummarized and available for growers to access. Also,various states of the country have enacted their ownlegislations on various issues.

Criterion 1.2 To demonstrate clear title to land inaccordance with national practice and law.

Indicator: The right to use the land can be demonstratedand is not legitimately contested by local communitieswith demonstrable rights.

Principle 2: Respect Human Rights and LabourStandards

Criterion 2.1 To comply with ILO Labour conventionsgoverning child labour, forced labour, discrimination andfreedom of association and the right to collectivebargaining.

Indicator: Minimum age of workers.

Indicator: Absence of forced or compulsory labour.

Indicator: Absence of discrimination.

Indicator: Respect the right of all personnel to form and

join trade unions and/or to bargain collectively inaccordance with the law.

Age and descriptions for child labour definition need totake into account the UNCRC categories (as well as thatof the ILO). Although there is a table in the guidancedocument, one is not not sure if this includes UNCRCdefinition?

It is not envisaged that farmers will be able to gatherproof of ‘no child labour’. EID Parry’s experience is thatthe issue of family and extended family working vis-a-vis records of labour hours, conditions, etc. will need tobe considered in depth to establish an understanding ofthe situation.

It was suggested that a committee of experts should gothrough the social documentation requirementscarefully with the contractors, cutters, farmers and themill.

Criterion 2.2 To apply Bonsucro human rights and labourstandards to suppliers and contractors.

Indicator: Percentage of contractors and major supplierswho have demonstrated compliance with human rightsand labour standards.

Criterion 2.3 To provide a safe and healthy workingenvironment in work place operations.

Indicator: Lost time accident frequency.

Indicator: Assessment of the main health and safetyrisks and measures implemented for mitigation of risk.

23

Indicator: Appropriate personal protective equipmentsupplied to and used by all workers.

Indicator: Training for health and safety.

Indicator: Availability of sufficient safe drinking waterto each worker present in the field and/or mill.

Indicator: Access to first aid and provision foremergency response.

Health and safety may be a problem as Primary HealthCentres are not functional in all places.

PPE generally not being used, even basic footwear, butapparently moving towards use.

Criterion 2.4 To provide employees and workers (includingmigrant, seasonal and other contract labour) with at leastthe national minimum wage.

Indicator: Ratio of lowest entry level wage includingbenefits to minimum wage and benefits required bylaw.

There is no “national minimum wage.”

Work on farms often done by relatives who are notpaid. This is a traditional issue and should receiverecognition.

Although there is no minimum ‘national’ wage there arestate legislations that define minimum minimum.

Verifying pay to labour likely to be very difficult.

Criterion 2.5: To provide clear, equitable andcomprehensive contracts.

Indicator: Existence of a contract or equivalentdocument.

Principle 3. Manage input, production and processingefficiencies to enhance sustainability.

Criterion 3.1 To monitor production and processefficiency; to measure impacts of production andprocessing so that improvements are made over time.

Indicator: Total raw materials used per kg product.

Indicator: Sugarcane yield.

Indicator: Working hours lost as percent of total hours.

Indicator: Mill overall time efficiency.

Indicator: Factory Performance Index.

Indicator: Industrial efficiency.

Sugarcane yield needs an alternative method ofcalculating, as growers often send their cane to two oreven three different processors (jiggery or competingmills) from the same field. Plant crops and ratoons yielddifferently. Could consider “soil systems” or “ecozones.”

Issue of farmers diverting part of their yield to a morelucrative market without declaring this to the miller(thus showing lower than expected yields).

Criterion 3.2 To monitor global warming emissions with aview to minimizing climate change impacts.

Indicator: Global warming burden per unit mass product.

Are composts and organic manures included in the GHGcalculation? No, but filtercake is.

24

Are different soil types taken into account in the GHGcalculation? No.

Terminology for vinasse, e.g. slops should be included.

Principle 4. Actively manage biodiversity and ecosystemservices.

Criterion 4.1 To assess impacts of sugarcane enterprises onbiodiversity and ecosystem services.

Indicator: Aquatic oxygen demand per unit massproduct.

Indicator: Percent of areas defined internationally ornationally as legally protected or classified as HighConservation Value areas (interpreted nationally andofficially as described in Appendix 1) planted tosugarcane after the cutoff date of 1 January 2008.

Indicator: Existence and implementation of anenvironmental management plan (EMP) taking intoaccount endangered species, habitats and ecosystems aswell as reference to ecosystem services and alien invaderplant and animal control. Coverage of issues required inAppendix 4.

Indicator: Use of co-products does not affect traditionaluses (e.g. fodder, natural fertilizer, local fuel) or the soilnutrient balance or soil organic matter.

Indicator: Fertilizer applied according to soil or leafanalysis.

Indicator: Nitrogen and phosphorus fertilizer (calculatedas phosphate equivalent) applied per hectare per year.

Indicator: Herbicides and pesticides applied per hectareper year.

Will auditors use field observation rather thandocumentation of field performance regardingenvironmental issues?

Discussion around metrics and country-specificstandards.

Soil sample - a matrix required here for differentregions and including soil health indicators.

Biocontrol system of parasitoid breeding by farmerentrepreneurs and supported by EID Parry provides agood example of P&D control plan for EMP indicator.

Environment: Possible to demonstrate environmentallysatisfactory practices in field but difficult to providedocumentary proof.

Preference for a process-orientated standard due toregional differences.

No reference to animal manure in the standard

Individual indicators which are difficult - 4.1.5; 4.1.6;4.1.7 Final record of actual fertilizer or agrochemicalsapplied is a problem but often this can be obtainedthrough recommendations from Parry and subsequentrecords of purchases from Parry.

Individual indicators which are difficult - 4.1.5; 4.1.6The use of organic and animal manures

Criterion 4.2 To implement measures to mitigate adverseimpacts where identified.

25

Indicator: Documented plan and implementation ofmitigation measures

Principle 5. Continuously improve key areas of thebusiness

Criterion 5.1 To train employees and other workers in allareas of their work and develop their general skills

Indicator: Training expense of worker as percentage ofpayroll expense.

Criterion 5.2 To continuously improve the status of soiland water resources

Indicator: Net water consumed per unit mass ofproduct

Indicator: Percent ground cover of tops or leaves afterharvest

Indicator: Soil surface mechanically tilled per year (% ofarea under cane).

Indicator: Percent fields with samples showing analyseswithin acceptable limits for pH.

Not sensible because this varies tremendously. Tillagepercentage will not be achievable in areas around Trichybecause growers usually do not have more than threeratoons (i.e. 4 crops), which means they will becultivating 25 per cent minimum.

Re: Irrigation: This should be expanded to be morecomprehensive, and if direct measurement cannot bedone, then a method determined to estimate water use.

Water application measurements: There is a claim thatthese could be reasonably measured or closelyestimated for well extraction, and canal extraction.(Subsequent discussion indicated perhaps this is not sosimple. Currently no farmers make these sorts ofmeasurements.)

Cultivation indicator: Purpose being prevention of soilerosion – is not appropriate for Tamil Nadu – all landsare flat and erosion does not occur under currentpractices which require soil disturbance. Low number ofratoons means that the benchmark value is too low.

Individual indicators which are difficult - 5.2 (Watermeasurements).

Criterion 5.3 To continuously improve the quality ofsugarcane and products from the mill.

Indicator: Theoretical recoverable sugar content ofcane.

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 kgproduct.

Indicator: Energy used in cane transport per tonne ofcane transported.

26

Indicator: Primary energy use per tonne of sugarcane.

Calculator issues - 5.4 Energy efficiency of electricalpower 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. Topromote recycling of waste streams where practical.

Indicator: Atmospheric acidification burden per unitmass of product.

Indicator: Non-hazardous solid residues per tonne ofcane.

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 needbetter reason for use of this standard.

Criterion 5.7 For greenfield expansion or new sugarcaneprojects, to ensure transparent, consultative andparticipatory processes that address cumulative andinduced effects via an environmental and social impactassessment

Indicator: Compliance with a recognized ESIA(Environmental and Social Impact Assessment).

Indicator: High Conservation Value areas (interpretednationally as described in Appendix 1) used as % oftotal land affected by a new project or an expansion

Criterion 5.8 To ensure active engagement andtransparent, consultative and participatory processes withall relevant stakeholders.

Indicator: Existence of a recognized grievance anddispute resolution mechanism for all stakeholders.

Indicator: Percentage of meetings of stakeholderengagement where agreement has been reached byconsensus driven process

Individual indicators which are difficult - 5.8 Deemed aproblem.

Criterion 5.9 To promote economic sustainability

Indicator: Value added / tonne of cane

Principle 6: Additional mandatory requirement forbiofuels under the EU Renewable Energy Directive(RED).

Criterion 6.1 To monitor global warming emissions with aview 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 biodiversityvalue, high carbon stock or peatlands planted tosugarcane after the cutoff date of 1 January 2008.

27

Annexure 2: Summary of Discussions asrecorded by the Training Team

Dr Gopinathan in the introduction emphasised that nopremium should be expected but that possibilities couldarise due to various market and climate changes.

Makes good sense to aspire to sustainable productionand to certification in case of future opportunities.

Points arising in general discussion and duringpresentations

Need for tools to educate all growers (all will need tocomply since a random sample could be selected foraudit).

Suggestion that due to the apparent lack of a market inIndia (domestic market taking up the full production)Bonsucro should create a demand by consumers torequire certified sugar – Bonsucro would need toadvertise the benefits of certification and convey this topotential sugar buyers. (or explain the status of certifiedcompanies and the advantages they have).

Compliance levels may be too high for some indicators.Need to relax the standard or take account of regionaldifferences. (tc/ts)

More than one request for a very user friendly form ofthe calculator, better explanation of indicators andmore complete guidance for producer includingintention/purpose of the indicator.

Following field visit

Farmers keep virtually no records themselves and mostinformation would have to be sourced through themiller support mechanism.

Social issues are challenging and a structure is neededto enable collection of data and encouragement toadhere to standards.

Garden, Wet land and Dryland agricultural models –need for clear definition of terms in the Bonsucrostandard.

Demonstration of operations would be preferred tohaving to comply with a specific value for a metric –(ISO approach preferred by EID Parry) An example is thecomprehensive biocontrol programme, pre trashing,parasitoid release programme etc.

Overall comments from participants at end of two daytraining:

Standard needs operational guidelines plus explanationof units.

Differences between regions needs to be taken accountof- suggestion of a Manual of operations by companyto explain their practices and their system of addressingthe principles and criteria.

Reference material is currently too broad to allow agood understanding of the needs. A column to expressthe intention of each indicator could be added to thestandard document. (“Objective” paragraph as in Audit

28

Guidance might be suitable?)

Need to contextualize each indicator and state thebenefits from complying with each indicator.

SUMMARY

1. Some of the participants were new to Bonsucro andneeded education on the whole standard.

2. This also meant that aspects of the standard werequestioned rather than just questioning the detail ofimplementing the standard.

3. Need more comprehensive supporting documentationor detail regarding intention of indicators andexplanation of calculations.

4. Farmers do not have records in terms of socialenvironmental or even economic aspects.

5. Health and safety and use of PPE at farmer andcontract cutter team and contractor (farm mechanicaloperations) level needs attention as this will not complywith the standards as they are currently.

6. EID Parry does have a comprehensive informationmanagement system which could be used to generate alarge 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 andidentify difficulties with standard values, or complyingwith the standard.

1. Introduction to standard

2. Survey data

3. Discussion on calculator

4. Internal Management System (Cane ManagementSystem)

EID Parry programme on training of 400, 300, then afurther 300 farmers in three years was explained – surveyfarmers, train them with a view to them training otherfarmers (training of trainers concept).

Social indicators

As far as farmers, cutter teams and contractors areconcerned social indicators and safety and healthindicators will be very difficult to comply with due to norecord-keeping and no contracts. (However EID Parry hassystems, 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 tocomply with and regional differences need to be takeninto account or preferably a process approach taken.

The company (EID Parry) would prefer to have theopportunity to develop their own document [similar toQMS Manual] stating their reasons for desiringcertification, background to the company culture, theirapproach, and suggesting their own target levels for themetrics or explaining their practices which aim to achieve

29

the same objective. These could be included in theEnvironmental Management Plan.

Cane Management System

Provides an exceptional record of most operations onfarms and has documentary evidence and this could besourced from this system on behalf of the farmers. Theonly aspect lacking is the social/labour details.

FOR BONSUCRO CONSIDERATION

A. For training programmes

1. Consider developing a standard suite of trainingmaterials.

2. If possible obtain a list of participants and backgroundsbefore hand.

B. Possible needs identified in the training

1. Consider responding to repeated requests forestablishment of Country or situation specific values(see alternative point 5 below)

2. Strong sentiment that organizations should be allowedto develop their own manual of practices or targetvalues based on the Bonsucro Principles and criteriaand that this be used for certification of theorganization i.e. set own targets as for ISO typestandards.

3. Request for a comprehensive guidance document forauditees.

4. Request for an even more friendly Calculator andoption for online use.

5. Consider increasing the value of the EnvironmentalManagement Plan – at present this counts as a singleindicator. It could be elevated to a criterion and have10 indicators. This could replace some indicators whichhave been suggested for situational differences. E.g.4.1.5; 4.1.6; 4.1.7 Nitrogen, N and P, herbicide use and5.2 % ground cover , % area soil disturbance.

30

31

More pictures from the field visit

32