25324 - Hygeia Expansion

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Environmental & Social Review Summary

Project Number

25324

Company Name

HYGEIA NIGERIA LIMITED

Date ESRS Disclosed

Oct 20, 2006

Country

Nigeria

Region

Africa

Last Updated Date

Nov 30, 2016

Environmental Category

B - Limited

Status

Completed

Previous Events

Approved : Jan 25, 2007
Signed : Jan 30, 2007
Invested : Jul 26, 2007

Sector

Hospitals and Clinics

Industry

Health, Education and Life Sciences

Department

Gbl Ind, Manufact, Agribus & Services

Project Description

This project involves expansion of several operations of Hygeia Limited, which is a private sector provider of hospital and health maintenance organization (HMO) services in Nigeria. Through IFC’s African Enterprise Fund (AEF) in 1999, IFC previously invested in Hygeia. The key elements of the current proposed project include: upgrade, renovation and expansion of three Hygeia hospitals:

- Lagoon Apapa, Lagoon Victoria Island (VI), and Lagoon Ikeja;
- a doubling of the overall capacity of the Hygeia’s hospitals in Lagos from 50 to 100 beds;
- establishment of five regional offices and the expansion of information technology infrastructure in relation to its HMO business;
- refinancing of a 5 year loan with a local Nigerian bank used to purchase MRI, CT Scan, and other critical care equipment in 2004 and 2005; and
- funding of working capital to facilitate the company’s expansion program.

Overview of IFC's Scope of Review

Environmental and social review of the project included a physical visit to each of the three Hygeia health care facilities in Lagos, Nigeria, to evaluate the project sites and environs and to conduct interviews with key client staff. Proposed modifications and additions to Hygeia’s health care facilities are limited in scope and will affect existing structures exclusively. There is no planned land acquisition or expansion of properties required for this project with the exception of potential acquisition of one parcel that is currently leased.

Additionally, IFC reviewed supplemental information provided by the client including proposed environmental and social affairs management programs, community engagement, labor and community engagement.

IFC communicated with client and consultant staff responsible for environmental and social affairs including :

- Dr/Professor Ade Elebute, Chairman, Lagoon Hospitals
- Mrs. Fola Laoye, Group Managing Director, Lagoon Hospitals
- Dr. AF Oyewumi, Quality Manager, Lagoon Hospitals
- Dr. SA Osunkoya, Director of Clinical Services, Lagoon Hospitals
- Dr. O.O. Onakoya, Medical Director, Lagoon Hospitals
- Ms. Ejiro Ehimah, Group Manager, Human Resources
- Ms. Jumoke Ajure, Assistant General Manager, Group Operations, Lagoon Hospitals

E & S Project Categorization and Applicable Standard

- PS 1: Social and Environmental Assessment and Management Systems;
- PS 2: Labor and Working Conditions;
- PS 3: Pollution Prevention and Abatement;
- PS 4: Community Health, Safety and Security; and
- PS5: Land Acquisition and Involuntary Resettlement.

Hygeia’s Apapa facilities have been in operation since 1986 when the existing property for Lagoon Apapa Hospital was purchased. Former land use was residential housing in the Apapa Government Reserve Area (GRA), which was established for restricted residential housing during colonial times. The existing structure was converted into the Lagoon Apapa Hospital. The Ikeja facility is leased and was completed in 1999 on property situated in a long standing residential/industrial area. One vacant, derelict building was demolished by Hygeia to facilitate construction of the new, purpose built health care facility. The primary care facility Lagoon Victoria Island (VI) is a leased residential home that was converted into a primary care facility. This facility will be replaced with a purpose built health care facility.

This is a category B project according to IFC''s Procedure for Environmental and Social Review of Projects because a limited number of specific environmental and social impacts may result that can be avoided or mitigated by adhering to generally recognized performance standards, guidelines, or design criteria.

Because project expansion and associated impacts will emanate from changes in existing land use and structures, environmental impacts anticipated in this health care facilities expansion are limited and minor.

Mitigation measures required to obviate several potential environmental impacts have been identified and are incorporated into the attached Environmental Action Plan (EAP).

Environmental and Social Mitigation Measures

Key environmental and social issues are listed below. In addition, specific information defining how elucidated potential impacts will be addressed by the sponsor/project is described. Upon implementation of the featured mitigation measures described below and in the attached environmental action plan (EAP), the project will comply with environmental and social requirements, host country laws and regulations and the World Bank/IFC performance standards as well as applicable environmental, health and safety guidelines.

- Social and Environmental Assessment and Management Systems:

Lagoon Hospitals has an ongoing consulting and strategic alliance arrangement with Apollo Hospitals of India through which Apollo is advising Lagoon on managed health care and certification of hospital operations to international standards. Lagoon’s ultimate target is certification by the Joint Commission International (JCI), which is the international branch of the Joint Commission on Accreditation of Healthcare Organizations (JCAHO). Joint Commission International helps to improve the quality of patient care in many nations. As part of this initiative Lagoon documented its procedures and processes in operations, orients and trains new staff using this documentation, and is engaging in a number of other employee orientation and training initiatives. This systematization of operations provides a management system for all aspects of Lagoon Health Care facilities. Supplemental, supporting aspects of the management program include offering quality certification classes to all Lagoon staff. Hygeia is encouraging all professional staff to obtain the title of Certified Professional in Health Care Quality, which is a US Board Examination. In further coordination with Apollo, Hygeia has formed a number of committees oriented to assessment and monitoring of specific health care activities to ensure that ongoing performance adheres to written documentation of company processes and procedures. The committees at present include Planning and Therapeutics, Medical Records review and Infection control.

Environmental review and permitting for expansion of the three lagoon operations falls under the aegis of the operations manager. To obtain permits for expansions, Hygeia submits an application to the Urban Planning Unit for an Alteration of Use Permit. Urban Planning then reviews drawings and determines if there are environmental impacts associated with the proposed expansion or alteration of facility use. When the review is complete and required modifications have been incorporated into the design the permit is issued. Permits must be visible throughout the construction period. A post construction inspection will be performed by Urban Planning to ensure that the structures were constructed in accordance with approved designs and the permits.

Through existing communication channels with the Apapa Government Reserve Area (GRA) Residents Association, Lagoon Hospital Apapa will explain the scope of expansion activity and present potential impacts and mitigation measures to the host community. Similarly, Lagoon will engage other GRAs and/or other community organizations to explain expansion at Ikeja and Victoria Island. These engagement measures will be conducted to ensure that each community understands potential expansion issues and mitigation measures and is afforded the opportunity to express perceived issues and concerns.

In compliance with the attached Environmental Action Plan (EAP) Lagoon Hospitals will continue to strengthen its management system and to expand the scope of written procedures to address supplemental operations activity including life and fire safety, hazardous materials management, occupational health and safety, and community engagement.

- Labor and Working Conditions:

Lagoon Hospitals’ employs a Group Manager for Human Resources. The client has developed a Staff Handbook to explain employment rights and non specific wages and benefits information. Precise wages and benefits information is detailed in each letter of employment. The Staff Handbook is made available to all employees and is updated periodically. Salary ranges are reviewed and updated annually based upon a survey conducted by the human resources manager. The Staff Handbook incorporates an employee grievance mechanism. As Lagoon routinely seeks and hires highly qualified professionals there are no labor organizations to coordinate with and there are no collective bargaining agreements. Employment is offered to individuals in accordance with the terms of employment in the Staff Manual and in position-specific appointment letters. Selection criteria for employment include appropriate job requirement credentials and successful interviews. Lagoon does not hire anyone under the age of 18, which is the minimum age for employment in Nigeria. There are no discriminatory practices in hiring; however state law requires that employees meeting job requirements pass a medical examination.

Hygeia’s Lagoon Hospitals are regulated and certified by the State Hospital Management Board. Each facility is subject to an annual review that constitutes a validation exercise to confirm continuing quality operations. Credentials for the physicians and nurses are checked by the Human Resources Manager. Positive results from the annual review and credential certification leads to award of a Certificate of Practice for the operation.

Although a number of labor and working conditions considerations are addressed through existing committees and activities aimed at improving quality, there is at present no formal occupational health and safety program. In accordance with the attached EAP, Lagoon will refine existing operations to ensure implementation of a program that complies with the IFC occupational health and safety guideline.

- Pollution Prevention and Abatement:

Potable water for all three Lagoon operations is provided by the local utility, Lagos State Water Corporation. Because water service is intermittent all three Lagoon hospitals are required to be prepared for water outages. When the water service is operating it flows to a primary cistern and is filtered and disinfected prior to being pumped to supplemental storage tanks situated on the roofs or at higher levels. Water samples are collected by Willy Jameson Ltd., a private water services contractor, and then analyzed for physical, chemical and microbiological parameters. When test results indicate a water supply problem the facilities take immediate action to resolve the issue. When water pressure is lost in water supply mains external contaminants can flow into non pressurized mains. In accordance with the EAP, Lagoon will ensure that supplemental disinfection capability is available for raw water storage and deployed during water supply outages to ensure adequate disinfection of raw water supplies.

Lagoon Hospitals’ sanitary wastewater is collected in concrete storage tanks for removal by a private contractor. Collected sanitary sewage is transported to Nigerian Cleaning Service, a Lagos State government sanitary sewage treatment center on Victoria Island. Storm water and air conditioning condensate and are evacuated through storm water drains servicing surface areas and the streets.

Aside from segregation of sharps (e.g. glass, needles, syringes, etc.) there is no formal segregation of health care wastes principally because there are no specialized services to manage segregated wastes. However, there is a great deal of awareness of AIDS transmission; thus preventive measures and attention to disposal is emphasized. Solid waste is collected in a segregated area in covered bins on the Apapa properties. A private contractor collects accumulated solid waste from the facilities and transports it to solid waste facilities owned and operated by Lagos State Waste Management. Lagoon is working with Lagos State Health Commission and others to rectify the existing situation in which there are no available specialty contractors or facilities for managing sharps or other health care waste aside from the disposal site where the state reportedly burns solid waste.

Electric power is supplied to the three facilities by the Power Holding Company of Nigeria PLC (PHCN). Power outages are common in Lagos thus local generation capacity is required. Generators use diesel fuel stored at Apapa. Drums of diesel are filled from the principal storage tank at Apapa and transported to the other operations for use. The annual generation of CO2 for all three facilities through national grid and local generation consumption is less than 2000 tons CO2/year, which is well under the IFC threshold of 100,000 tons/year. Nevertheless, the cost of energy and maintenance of electric power generators and UPS devices as well as the actual consumption from diagnostic equipment (MRIs, CTs, xRay, and others) is high. The company will benefit from energy consumption and use audit indicating benefits to be derived from specific ameliorative expenditures.

Lagoon Apapa recently completed installation of a centralized oxygen supply that provides oxygen to patient rooms, surgery and other locations. The central store of oxygen bottles provides chains for bottles but use is intermittent. Similarly full and empty cylinders awaiting use or collection are standing without restraint. As part of occupational health and safety system formalization described above, improved management of oxygen and other hazardous materials will be highlighted in specific procedures and in employee training.

- Community Health Safety and Security:

As part facility expansion designs, Lagoon will conduct a review of life and fire safety for the three proposed expansions in accordance with the attached EAP. Emergency response planning developed as part of formalized occupational health and safety activities described above will coordinate essential activities with host communities to ensure adequate communication of potential emergencies and appropriate response activity. Lagoon hospitals employ a combination of subcontractor security services and direct hire employees to provide entry and exit and traffic control, personnel entrance, and internal security for building and contents. None of the security guards are armed; all internal and outsourced security services are advised to call the police in the event of any type of incident.

- Land Acquisition and Involuntary Resettlement:

Lagoon Hospitals is negotiating the purchase of currently leased parcels utilized for Ikeja and Victoria Island operations. Purchase of these properties in the offing will be between a willing buyer and a willing seller. There will be no physical or economic displacement associated with these transactions. The land use will remain the same.

Stakeholder Engagement

Lagoon Hospitals will build upon its existing health outreach programs and commitment to work with local communities in which it operates and implement a thorough community engagement program to inform Apapa, Ikeja and Victoria Island communities of Lagoon Hospitals current expansion plans, anticipated impacts and mitigation measures. Through existing and enhanced communication channels Lagoon Hospitals will explain the scope of expansion activity and present potential impacts and mitigation measures to the host community. These community engagement measures will be conducted to ensure that each community understands potential expansion issues and mitigation measures and is afforded the opportunity to express perceived issues and concerns.

Project planning documents and Alteration of Use Permits from the Urban Planning Department will be made available publicly once issued for the three facilities. Lagoon Hospitals representatives that may be contacted for information and to advise where project documents can be viewed publicly include the following:

- Mrs. Fola Laoye, Group Managing Director
Lagoon Hospitals
E-mail: customerservice@lagoonhospitals.org

- Ms. Jumoke Ajure, Assistant General Manager
Group Operations, Lagoon Hospitals
E-mail: customerservice@lagoonhospitals.org

Client Documentation

File Name	Actions
Lagoon Hospitals EAP.pdf

**Information on IFC's Policy and Performance Standards on Environmental and Social Sustainability can be found at www.ifc.org/sustainability

IFC supports its clients in addressing environmental and social issues arising from their business activities by requiring its real sector clients to set up and administer appropriate grievance mechanisms and/or procedures to address complaints from Affected Communities in relation to environmental and social issues arising from IFC's clients' business activities. Since 2012, IFC's Financial Intermediary clients applying the Performance Standards are required to develop External Communications Mechanisms to receive and review inquiries or complaints from any interested party regarding the E&S risks and impacts of their operations.

For IFC projects that are active or under consideration, individual(s), or their authorized representative(s), who allege they have been or will be adversely affected by E&S risks or impacts arising from IFC's clients' business activities, may submit a complaint to IFC directly for consideration. When receiving an E&S complaint, IFC engages with complainants and works with its clients to find solutions to E&S concerns as quickly and efficiently as possible.

Complaints can be submitted to IFC online at www.ifc.org/escomplaints or by email to EScomplaints@ifc.org.

IFC complaint response is separate from and complementary to IFC’s clients’ project level grievance mechanisms and IFC’s Independent Accountability Mechanism (CAO). Lodging a complaint directly with IFC does not, at any time, restrict access to CAO.

Affected communities have unrestricted access to the Compliance Advisor Ombudsman (CAO), the independent accountability mechanism for IFC and MIGA. CAO facilitates the resolution of complaints related to IFC and MIGA projects and sub-projects, undertakes reviews of IFC’s and MIGA’s environmental and social compliance, fosters public accountability for their commitments, and enhances the environmental and social performance of IFC and MIGA.

Independent of IFC and MIGA management and reporting directly to the IFC and MIGA Boards of Executive Directors, CAO helps resolve issues raised about the environmental and social impacts of projects through a neutral, collaborative, problem-solving approach via its Dispute Resolution function. It also reviews IFC’s and MIGA’s compliance with environmental and social policies, assesses related harm, and recommends remedial actions through its Compliance function. Additionally, CAO provides advice to IFC, MIGA, and their Boards to enhance environmental and social sustainability performance and minimize the risk of harm.

Complaints may relate to environmental and social harm regarding any aspect of the planning, implementation, or impact of a project or sub-project, and can be made by any individual, group, community, entity, or other party affected or likely to be affected by the environmental or social impacts of an IFC- or MIGA-financed business activity.

Complaints can be submitted by any of the following methods:

Online form: available at https://www.cao-ombudsman.org/
Mail/Hand Delivery to: 2121 Pennsylvania Avenue, NW, Washington, DC 20433, USA
Voice mail: +1 202 458 1973
Email: cao@worldbankgroup.org
SMS, WhatsApp, Telegram, and Signal: +1 202 650 2627

CAO receives and addresses complaints in accordance with the CAO Policy, which can be accessed at: https://www.cao-ombudsman.org/policies-guidelines.

This Environmental and Social Review Summary (ESRS) is prepared by IFC to disclose its findings and recommendations related to environmental and social considerations regarding potential investments. Its purpose is to enhance the transparency of IFC's activities. For any project documentation or data included or attached herein, whether prepared by the project sponsor or otherwise, authorization has been given for public release by the project sponsor. IFC considers that this ESRS is of adequate quality for release to the public, but has not necessarily independently verified all of the project information therein.
It is distributed in advance of IFC Board of Directors' consideration and may be periodically updated thereafter. Board dates are estimates only and this document should not be construed as presuming the outcome of the Board Directors’ decision. The following ESRS is disclosed in accordance with IFC's Access to Information Policy (AIP).

The map is for illustrative purposes and does not imply the expression of any opinion on the part of the World Bank, concerning the legal status of any country or territory or concerning the delimitation of frontiers or boundaries. Country borders or names do not necessarily reflect the World Bank Group's official position. In some cases, available project location information is limited to the country of the project's activities. Locations are approximate.

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