| Performance Standard | Description and Potential Impact | Mitigation |
|---|
| PS 4. Community Health, Safety and Security | Key risks include:
- Potential nuisances/impacts on affected communities and the public during construction (e.g. traffic, restricted access to land) and operation (e.g. traffic & patient parking).
- Disruption to continuity of primary care during the temporary closure of facilities (during demolition/construction). Patients may need to travel further to alternative / overstretched facilities during that period.
- Inadequate L&FS measures and structural integrity (including vulnerability to natural disasters) defined during the design and L&FS procedures and emergency preparedness and response during operation. Accessibility to disabled people.
- Levels of violence in Brazil are considered high and workplace violence is a recognized hazard at healthcare facilities. Armed robberies of hospitals have occurred . Inappropriate use of force by police is a risk in Brazil, (national and local authorities have encouraged police to kill suspects ).
- GBV risks for patients and communities. Discrimination and violence towards women are both common and severe in Brazil. | The E&S scoping study in Phase I will assess key risks and identify mitigations. IFC will recommend the PPP agreements to include obligations to follow PS4 and GIIP as in the WBG EHS General Guidelines and Guidelines for Healthcare Facilities.
These obligations will include, among others:
- Requiring new buildings to be designed, constructed and operated in full compliance with the local life safety code and structural code and an internationally accepted L&FS standard
- Requiring existing buildings to be rehabilitated or refurbished to undergo a risk based LFS review and implement actions to close any identified gaps
- Considering accessibility for disabled people in building design
- Providing suitable interim primary healthcare during temporary closures
- Assessing and managing risks posed by security arrangements and
- Requiring the concessionaires staff to adhere to a code of conduct in relation to GBV risk. |
| PS 3. Resource Efficiency and Pollution Prevention | Key risks are associated with pollution during construction and waste management during construction and operation. In particular, demolition / construction may lead to impacts related to increased noise, dust, generation of hazardous waste (e.g. asbestos during demolition of old facilities), increased use of resources and utilities. Potential past liabilities may be related to existing on-site infrastructure or activities performed on or adjacent to selected land plots.
If the capacity and efficiency of available municipal sewerage system and wastewater treatment facilities are inadequate then there could be a contamination risk if site-specific treatment systems are not designed and installed. Even if installed correctly, incorrect operation and maintenance could lead to a contamination risk. Improper disposal of medical waste, chemical waste or other hazardous materials is a significant risk during operations. Incorrect operation and maintenance of onsite incinerators or backup generators could lead to air pollution risks.
With respect to climate change, in addition to increased exposure to natural hazards, key aspects relate to efficient use of water and energy resources within the context of water scarcity / pollution, and risks related to extreme heat and droughts, (frequent in northeast Brazil). | The E&S scoping study in Phase I will assess key risks and propose mitigations in line with IFC PS3. This will include a review of potential liabilities at the selected site (soil contamination, asbestos risks) as well as challenges associated with wastewater treatment, waste disposal and potential sources of air emissions.
IFC will recommend the PPP contract will include specific obligations to follow PS3 and GIIP as in the WBG EHS General Guidelines and Guidelines for Healthcare Facilities. |
| PS 2. Labor and Working Conditions | There is risk of inadequate labor and working conditions during construction and O&M for subcontractors. The contextual risk screening indicated that, in general terms, the national legislation is aligned with IFC PS2. However, there are potential gaps with respect to a human resources policy, workers grievance mechanism, and OHS management of third-party contractors.
The key risks are expected during construction/renovation because of a potential influx of workers, potential hiring of unskilled workers in the project area, inadequate labor and working conditions, sexual harassment and gender based violence (GBV) in the workforce, as well as poor OHS practices among contractors and subcontractors.
Operational risks are mainly related to handling of biohazardous medical waste, managing equipment, sexual harassment, GBV, patient violence against healthcare workers, and communicable diseases, (including Covid-19).
Some of the existing workforce, particularly non-medical workers such as janitors, at the centers to be demolished and rebuilt or those to be refurbished, depending on their type of contract and protection under the law/collective bargain agreements, may be deployed elsewhere or may be dismissed if not rehired by the concessionaire (e.g., through transferring provisions in the contract) once works are complete (i.e. possible retrenchment). In addition, workers whose employment contracts are transferred from a public to a private type of contract may be exposed to a reduction in compensation, benefits or other such disadvantages. | The E&S scoping study in Phase I will assess key labor risks, including whether there is a risk of retrenchment, and propose mitigations in line with IFC PS2.
IFC will recommend the PPP contract to include specific obligations to follow IFC PS2 in addition to national legislation.
These will include, among others, provisions to avoid forced and child labor, to promote gender equality and nondiscrimination, to ensure OHS practices and require that these are followed by all contractors and subcontractors, to conduct independent monitoring and audit of workers conditions, and to establish a workers grievance mechanism. It will also be recommended that the concessionaires staff adhere to a code of conduct in relation to GBV risk and sexual harassment.
For projects involving brownfield facilities, the client should be recommended to engage with the workers to explain the PPP and the implications on job security and to identify alternatives to retrenchment. In case retrenchment cannot be avoided, a retrenchment plan will need to be developed.
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| PS 1. Assessment and Management of Environmental and Social Risks and Impacts | E&S risks are considered to be limited and manageable through the application of a management system and standard operating procedures and impacts could be readily addressed through mitigations.
The specific locations for the Pilot Project sites are yet to be selected by the Client, hence currently there is no accurate information on possible site specific E&S risks that can be avoided / minimized through site selection, (i.e., by considering E&S criteria when selecting sites). Potential sitting related issues include:
- proximity to structures that may expose staff/patients to H&S risks (e.g. transmission lines or noise and emissions from industrial facilities)
- proximity to areas prone to natural hazards (such as flood, landslides)
- availability and quality of water
- historical contamination
- accessibility for disabled people
- proximity to public transportation links
- safety of pedestrian access
- parking space availability and
- ease of patient drop-off / pickup.
Applicability of PS5 is unlikely since it is currently assumed that plots to be selected will already be under client possession. However, PS5 applicability cannot be excluded as there might be users (formal/informal) or the plots might have been recently acquired. PS6, PS7 and PS8 are also not likely to be applicable. The Pilot Projects are expected to be located in urban settings where IPs and important biodiversity are unlikely to be present. However, applicability should be confirmed on a case-by-case basis.
If not engaged upfront, there could be community concerns and grievances due to construction related impacts, concerns around temporary or permanent closures of existing healthcare facilities, fears that local services will be reduced, and misconceptions that public health services are being privatized.
At the program level, there is a need to develop standardized documentation within the PPP agreement in order to include all relevant E&S aspects. | During Phase I, IFC will provide E&S criteria for the selected sites for E&S red flags. An E&S Scoping Study will also be commissioned to understand the land plots and infrastructure that will be made available to the private party, including any liabilities, and identify key risks for construction and operation, including a gap analysis of Brazilian's regulations against IFC Performance Standards. The study will include collecting information on current land use, ownership, historical contamination, any limitations or restrictions for particular activities or operations, and potential for physical / economic displacement. The scoping will also include preliminary stakeholder mapping and analysis. IFC will also evaluate Clients capacity on E&S matters and stakeholder engagement and provide recommendations on how to supplement it.
A Stakeholder engagement plan as per IFC PS1 requirements should be developed and implemented to manage early engagement with affected communities (who use the existing healthcare facilities or will be affected by construction), as well as existing staff and contractors. Communication plans should seek to manage any misconceptions that public health services are being privatized.
The E&S Scoping Study will verify the current assumption that PS5, PS6, PS7 and PS8 are not applicable. Specific advice will be provided if any are confirmed to be applicable, (in particular with respect to resettlement).
IFC will recommend the PPP contract to include specific obligations of parties in terms of E&S risk management during construction, operation and maintenance (O&M).
IFC will recommend standardized documentation within the PPP agreement at the program level to include IFC PS, WBG EHS General Guidelines and Guidelines for Healthcare Facilities, plus placeholders to cover specific risks that may or may not materialize depending on the site/type of facilities. |
