25805 - Max Phase II

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Environmental & Social Review Summary

Project Number

25805

Company Name

MAX HEALTHCARE INSTITUTE LIMITED

Date ESRS Disclosed

Apr 9, 2007

Country

India

Region

South Asia

Last Updated Date

Oct 30, 2021

Environmental Category

B - Limited

Status

Completed

Previous Events

Approved : May 24, 2007
Signed : Jun 29, 2007
Invested : Jul 20, 2007

Sector

Hospitals and Clinics

Industry

Health, Education and Life Sciences

Department

Gbl Ind, Manufact, Agribus & Services

Project Description

The proposed project is an expansion of Max Healthcare Institute and its network of hospitals (Max Healthcare or the company), one of the fastest growing healthcare providers in India. The company currently operates five hospitals (575 beds) primarily in the North Capital Region (NCR), which includes New Delhi and its approximate surroundings. Based on the strong demand for privately provided healthcare in India and particularly in Delhi, the company has plans to expand its presence to about 1200 beds by 2013. IFC’s investment would assist Max Healthcare implement its expansion strategy over the next two to four years. The proposed project includes:

- a 268 bed addition to Patparganj hospital, bringing total bed size to 414;
- new 100 bed secondary/multi-specialty hospital in Dehradun, located 250km north of Delhi;
- new 84 bed tertiary expansion (focused on obstetrics, gynecology, and pediatrics) at Saket in South Delhi; and
- Max Hospital -Gurgaon (new 100 bed facility).

Overview of IFC's Scope of Review

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 which can be avoided or mitigated by adhering to generally recognized performance standards, guidelines or design criteria. The review of this project consisted of appraising technical, environmental and social information submitted by the project Sponsor including:

- review of Max Healthcare’s policies and Standard Operating Procedures related to environmental management and occupational hygiene, health and safety;
- assessment of supplemental information submitted by the company on key environmental and social assessment issues; and
- meetings with the project’s management team in March 2007 to discuss IFC’s PSs, guidelines and other requirements.

E & S Project Categorization and Applicable Standard

While all Performance Standards are applicable to this investment, IFC’s environmental and social due diligence indicates that the investment will have impacts which must be managed in a manner consistent with the following Performance Standards:

- PS1: Social and Environmental Assessment and Management Systems;
- PS2: Labor and Working Conditions;
- PS3: Pollution Prevention and Abatement;
- PS4: Community Health, Safety and Security; and
- PS5: Land Acquisition and Involuntary Resettlement.

The project appraisal also assessed the applicability of PS6: Biodiversity Conservation and Sustainable Natural Resource Management, PS7: Indigenous Peoples, and PS8: Cultural Heritage. In regard to PS6, the project sites are expected to be located in heavily modified urban/peri-urban neighborhoods and no impact on biodiversity is therefore expected. With respect to PS7 and PS8, no indigenous peoples or cultural heritage resources will be affected by development of the project.

The project involves several hospital developments in peri-urban areas of India, primarily in the NCR. The key social, environmental, health and safety impacts associated with the project will include:

- emissions to air and water;
- management of hazardous materials and wastes;
- labor and working conditions, employee occupational health and safety and community health and safety during construction and operation.

Given that the proposed project locations are all in heavily modified areas, adverse impacts on environmentally sensitive areas are not expected to occur. The nature of hospital operations is such that it will be possible to readily design and implement engineering and management measures to mitigate any adverse impacts that result from the project. The company has indicated that, to date, it has acquired project sites on a willing buyer-willing seller basis and that had either formal or informal residents or users of resources. Moreover, in light of the fact that mitigation measures can readily be designed, adverse impacts are not expected to be diverse or irreversible and will be limited to project site, and no physical or economic displacement of communities occurred, the project has been classified as a Category B.

Environmental and Social Mitigation Measures

The sponsor has presented plans to address these impacts to ensure that the proposed project will upon implementation of the specific agreed measures, comply with the environmental and social requirements - the host country laws and regulations and the World Bank/IFC social and environmental Performance Standards and environmental, health and safety (EHS) guidelines. The information about how these potential impacts will be addressed by the sponsor/project is summarized in the paragraphs that follow. Further information is provided in the attached documentation.

- PS1: Social and Environmental Assessment and Management Systems:

The company has established detailed environmental and occupational health and safety practices and Standard Operating Procedures (SOP) that conform to international best practice for the hospital sector. These systems have been covered under ISO 9001:2000 and the National Accreditation Board for Hospitals. Environmental, social and health and safety issues are managed by the Heads of hospitals, who report directly to Max Healthcare’s senior management group, to ensure that continuous improvement and instances of non-compliance are addressed immediately. The company also has established a detailed and comprehensive training program structure and schedule for new and existing staff. As part of its ESHS management systems, the company will attempt to formalize its process for community engagement, consultation and feedback. The company has received all relevant GoI clearances for existing and under-construction facilities, including plot Allotment Letters, Possession Letters and Sanction of Building Plans, as applicable. Requisite post-construction clearances include:

- consents under the Water (Prevention & Control of Pollution) Act, 1974;
- Air (Prevention & Control of Pollution) Act, 1981;
- Environment Protection Rules, 1986;
- Environmental Impact Assessment Notification, 1994;
- Bio-Medical Waste (Management and Handling) Rules, 1998; and
- Hazardous Waste (Management and Handling) Amendment Rules, 2003.

The company will provide IFC with copies of all clearance documents for future developments received in the previous 12 months with submission of the Annual Environmental and Social Monitoring Report (AMR) submitted to IFC.

- PS2: Labor and Working Conditions:

The company has in place a Human Resources policy and procedures that are consistent both with all relevant Government of India (GoI) statutes and regulations, as well as international best practice for the sector. Max Healthcare has reviewed PS 2 and confirmed that its policies and procedures conform fully with all PS2 requirements and to the four key ILO conventions. Employee OHS procedures and safeguards are detailed in a series of standard operating procedures (SOPs) that have been developed by the company for all aspects of its healthcare services including radiology, pathology, ambulance operations, pharmacy operations and emergency medicine. Radiology staff, for example, are regularly monitored for radiation exposure and x-ray equipment is inspected and certified by the Bhaba Atomic Research Center annually. Through employee training programs, the company ensures that all health care facility staff understand and manage the specific occupational hazards to which they are exposed. The company utilizes either Materials Safety Data Sheets or International Chemical Safety Cards to familiarize employees with the hazards and personal protective equipment required for specific tasks and chemical compounds that they use, or to which they are exposed, in their work (e.g. disinfectants, fumigants). In addition, the company monitors in-house occupational safety and health statistics to ensure that training programs are continuously updated to reflect the needs of each facility’s staff and patients.

The company has provided details on the life and fire safety (LFS) design, management and monitoring systems it incorporates in all of its facilities, which have been reviewed by IFC. All of Max Healthcare’s facilities include:

- a fire ring and mains with connectable hoses and dedicated water supply;
- central alarm, smoke detectors and sprinkler systems; and
- adequate and appropriately signed means of egress.

In addition to the LFS systems and equipment that will be installed, the company has training programs for all staff that cover fire prevention and response, and designates trained fire responders throughout the organization. These teams are responsible for training, demonstrating, and monitoring the implementation of the LFLS programs. The company will submit an L&FS Master Plan to IFC that identifies major fire risks, applicable codes, standards and regulations, and mitigation measures. The L&FS Master Plan will be prepared by a suitably qualified professional acceptable to IFC who will certify that the design meets the requirements of IFC’s Life and Fire Safety guidelines. On the basis of the Master Plan and its findings and recommendations, IFC will determine whether additional conditions to the attached Environmental and Social Action Plan (ESAP) are needed, and agree with the company on a mutually acceptable time frame for implementing these conditions. The qualified professional who prepares the L&FS Master Plan also will undertake a review at the time of L&FS systems testing and commissioning and certify that construction of these systems has been carried out in accordance with the accepted design. Findings and recommendations of this review may be incorporated into the ESAP, as needed, along with a mutually acceptable time frame for implementation.

Environmental, health and safety during construction is managed by Max Healthcare. The company’s contracts with all construction firms contain specific environmental, health and safety (EHS) provisions, compliance with which is overseen by Max Healthcare personnel who are on site at all times during construction. Site safety meetings are held weekly and attendance by safety officers of all contractors is mandatory. The status of general safety conditions and use of PPE by all workers is reviewed at this meeting, and laborers not wearing adequate PPE are not allowed to work at site. All contractors are required to have a housekeeping team which is responsible for cleanliness of the site areas at which they are currently engaged. Non-compliance with EHS provisions is grounds for termination of any of construction contract.

- PS3: Pollution Prevention and Abatement:

All existing and proposed Max Healthcare facilities receive water from the municipal water supply system and/or permitted groundwater resources. Medcentre facilities maintain on-site storage facilities to ensure adequate water supply for operations. Water quality is regularly monitored both in-house and by independent laboratories. Potable water is derived from on-site reverse osmosis (RO) plants or from licensed bottled water suppliers. All facilities are equipped with sewage and /or wastewater treatment plant as required. Treated effluent is disposed to the municipal system in compliance with guidelines of the relevant State Pollution Control Board, which are consistent with World Bank Group (WBG) guidelines. The primary care outpatient facilities do not require water treatment plants; potable water is supplied by licensed bottled water suppliers. Hospital facilities maintain on-site storage facilities to ensure adequate water supply for operations.

All Max Healthcare facilities follow the company’s standard operating procedures (SOPs) for the disposal of general, pathological and chemical waste. These SOPs conform to WBG guidelines and Indian regulations. At each facility, waste is segregated by category and stored temporarily on site as per internationally accepted procedures. General (non-infectious/non-hazardous) solid waste is collected and disposed per municipal regulations. The company has contracted with two companies - Synergy Waste Management Company and Sambranky (located in Ghaziabad) - for the removal and disposal of all biomedical waste. Both contractors are authorized/licensed by the New Delhi Pollution Control Committee to collect, store, treat and dispose of bio-medical waste per national regulations (The Gazette of India notification No. / D.L. – 33004/98).

The company maintains a comprehensive infection control program, detailed in its Infection Control Policy and Procedures Manual that is periodically reviewed by an Infection Control Committee (ICC) made up of the members of various medical departments and including nursing, housekeeping, operating room and laboratories at its Medcentres. The role of the ICC is to serve as both a monitor and a resource in maintaining control standards for nosocomial infection in order to minimize risk to both staff and patients. The company also provides in-house training for all newly employed healthcare providers and housekeeping staff aimed at preventing infections as well as annual refresher training for existing staff. This training includes modules in the company’s standard operating procedures for bio-medical waste management as outlined above. All facilities follow a regular schedule of disinfection – with a dedicated staff for laboratory and operating theatre – that is undertaken in accordance with occupational safety and health objectives described below and monitored on a weekly basis. The ICC review the results the results of these monitoring reports and initiates corrective actions as needed.

- PS4: Community Health, Safety and Security:

As part of its ESHS management system, Max Healthcare prepares emergency preparedness and response plans (EPRPs) for all of its facilities, including policies and procedures to prevent community exposure to disease, pathogens and other bio hazards during normal and emergency scenarios. EPRPs are based on risk assessment and analysis. Hospitals are designed with separate entry and exit for service and delivery vehicles, so that the main entry roads are utilized only by staff, patients and visitors. Max Healthcare engages a private company to provide security services to the hospital and associated facilities. Contract provisions will include guidelines on how security personnel shall interact with any communities surrounding the facility. The Max Healthcare management team has reviewed PS4 and indicated that the facility will comply with its requirements in full. The company has designated a “May I help you” desk within each of the hospitals. Staff at these desks will be responsible for receiving and responding to questions, concerns or complaints raised by nearby communities or other stakeholders, and each hospital will maintain a register of such inquiries. Contact details (phone number and email address) at the hospital entrance.

- PS5: Land Acquisition and Involuntary Resettlement:

All of the land for Max Healthcare’s existing and under-construction hospitals has been acquired either on a willing buyer-willing seller basis or through concession under NCR planning programs designating areas for health care developments. The company has confirmed that none of its land acquisition and facility developments to date have entailed involuntary resettlement, and that it has always sought to acquire land that will not displace local residents or encroachers, either physically or economically. To formalize this policy, Max has reviewed the requirements of PS5 and will adopt a land acquisition ‘screening’ procedure in order to formally assess and document that no involuntary resettlement has occurred as a result of its expansion program. The company is in full compliance with all applicable national and local laws on land acquisition and has confirmed that all requisite permits, consents and approvals have been obtained.

Stakeholder Engagement

The company has a commitment to corporate social responsibility and service provision to the communities in which it operates. In the past Max Healthcare has undertaken various medical programs in consultation with Resident Welfare Associations that include eye camps, health awareness programs and supporting health care clinics for lower income groups.

Environmental Documents will be made available at the following location:

Max House
3rd Floor, 1, Dr. Jha Marg, Okhla Phase III
New Delhi, 110-020
Telephone: +91 011 269 33618
Fax: +91 011 269 33620

Client Documentation

File Name	Actions
Max Healthcare _25805 Final_ESAP.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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Environmental & Social Review Summary

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Environmental and Social Mitigation Measures

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