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, IFC Performance Standards, and IFC environmental, health and safety 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 Environmental and Social Action Plan (ESAP).
- PS1: Social and Environmental Assessment and Management Systems
- Environmental and Social Assessment:
As a part of the licensing process for the expansion and new developments the sponsor had to fulfill certain environmental, health and safety requirements set by different responsible Ministries, but a formal environmental and social assessments has not been done. The sponsor has considerable in-house capacity and project management expertise to develop, construct and operate its educational facilities. Since its establishment in 2005, USTH hospital has been recognized for its high professionalism compared to most healthcare facilities in Yemen.
UST and USTH operate according to relevant regulation in Yemen. Regular inspections of USTH and UST operations are conducted by Ministry of Public Health and Population, Ministry of Higher Education, Ministry of Water and Environment and Ministry of Social Affairs and Labor.
USTH – The hospital comprises of two buildings; first one accommodates different service units, for example outpatient clinic, laboratory, administration, IT unit, laundry, kitchen, and restaurant, with second one reserved for hospital with currently 144 beds and outpatient clinics. The designs for the expansion of its current Hospital in Sana`a will be referenced by national and international health care standards such as JCI (international standards for hospitals), as in the future the sponsor hopes to obtain JCI certification. The guidelines and regulations that the sponsor will apply in the expansion and refurbishing of the existing hospital specify building and operational standards including but not limited to: sustainable materials in the construction process; design requirements for fire safety, disease prevention and isolation; segregation of medical and other wastes, energy-efficient plant and systems. Similar sound construction and operational standards will be applied in construction of the parking garages, especially in relation to Life and Fire Safety protection.
UST – UST has obtained a construction permits from the Ministry for Higher Education. As the campus will be open to the public, UST’s application for the construction permit is required to contain a security report (e.g., describing fire safety measures such as emergency exits, types of the structural elements and material to be used in the construction, etc.). Besides that the local construction company that is contracted for the work will apply sound environmental engineering and construction standards related to the selection of sustainable materials, energy efficiency systems, etc.
- Management Program and Organization:
USTH - The sponsor does not have formalized ESMS to manage their health care facility; rather the EHS issues are dealt with through separate processes that are in place. At the present Maintenance Department takes the responsibility of the environmental issues. EHS capacity has been strengthen just recently with hiring of a Medical Director of the hospital, who has been working as public health specialist/hospital director and in charge of health and safety issues for many years in a hospital in Aden, which was established by BP in 1954 as a hospital for oil workers and consequently in 1977 was handed over to the Government. Additional hiring of an EHS expert has been contemplated by the sponsor. Currently there is an officer in charge of health and environmental issues. In total there are three staff that directly deal with EHS issues out of which 2 for infection control one for security and safety.
USTH is currently preparing to introduce ISO 9001 standard into its operations and has developed internal expertise i.e. quality assurance officer and a team of internal auditors to assist in QMS certification process. Once developed the internal staff structure that manage quality issues in the Hospital can assist in developing similar capacity for EMS.
UST - Given the nature of UST facility and its limited EHS impact on environment there are no designated personnel that specifically cover for EHS issues. There are several departments that provide different services and the maintenance function.
- Training:
USTH has had a limited amount of training for its staff; a general Monthly Lecture about “environment and its threats” is conducted. Infectious control department conduct regular training for nurses and doctors, part of which was a specialized training for nurses in Jordan. In addition the Hospital is providing training to its staff on fire and life safety. Trainings and courses that are provided to UST staff are:
- Safety Training,
- Personnel Security,
- Training in safe handling of tools and equipments,
- Medical Equipment Maintenance,
- Fire Fighting,
- Typical Use for Pesticide,
- How to treat Customers.
- Community Engagement:
No complaints have been received from the local communities near its existing sites. Prior to the establishment of its facilities, the sponsor consults with local governments and local communities. Both UST and USTH will keep open communication channels and will consult regularly with the local authorities and communities. Each existing facility implements grievance mechanisms for receiving and addressing grievances raised by the local community.
-Monitoring and Reporting:
USTH reports on its EHS performance to the Environment Department in the Ministry of Water and Environment and to the Safety Department of the Ministry of Public Health and Population.
UST – reports to the top management on different issues that are related to its overall EHS performance are submitted by different departments (cost of energy use, utilities, agriculture and green area, buildings and medical equipments maintenance, security issues)
The sponsor is committed to develop an Environmental and Social Management Plan/Procedures (ESMP) template for integrating environmental and health and safety issues into the design, construction and operation of its current and new healthcare facilities and educational facilities and provide a copy of the ESMP template to IFC. In addition, the sponsor will develop, operate and maintain health care waste management system (HWMS) adequate for the scale and type of activities and identified hazard. ESMP and HWMS will be Conditions of Disbursement as defined in ESAP.
- PS2: Labor and Working Conditions
USTH and UST have a comprehensive human resources (HR) policy and documented procedures for managing HR issues, ranging from recruitment and retention, working hours, maternity and paternity leave, training and staff development, performance assessments and organization climate and culture, workers grievance mechanism and disciplinary policy. The Company’s HR policies, management system, conditions of employment and working conditions are in compliance with national law and PS2. The HR policy provides options for flex time, compressed work hours or part time work. The Ministry of Social Affairs and Labor is the authority responsible for the safety and care of workers i.e. responsibility includes protection from chemical, physical and bio hazardous pollutants specific and commensurate with the working environment.
Yemeni Labor Law specifies a set of obligation that Ministry of Social Affairs and Labor, employer and employees need to follow to implement sound working and labor conditions. These include:
- old age, disability and death insurance,
- medical and work accidents insurance,
- work accidents and death compensations,
- medical care and compensations for disability.
A number of regular trainings are held i.e. on-job, in-house (patients care, problem solving training/managing stress, team work, how to treat customers). The company’s internal grievance mechanism encourages staff to raise issues through direct discussions with immediate supervisors or managers and by e-mail directly to management.
USTH - Current workforce of UST-H is 865 staff out of which female staff is 240. Minimum salary is 20,000 YR/month (approx 100 USD), and minimum employment age is 18 years of age. Working time per week is 48 hours. The salaries are high for local Yemeni standards and every year there is an average salary increase, based on a worker’s performance, which is assessed by a HR/Admin manager. Two years ago a law on social requirements has been enacted in Yemen requiring each employer and employee to contribute 15 % total from the annual gross salary (9% and 6% respectively) into the “employer’s social/pension package”. As a part of its HR policy USTH has in place:
- A Minimum Staff Age Policy,
- Complaints Mechanisms,
- Non-Discrimination Policy.
The work force is provided with appropriate PPE (personal protective equipment) and a number of training in OHS is conducted. Health and safety assessment of USTH operations was done recently by an insurance company and report is available for review. USTH is equipped with good ventilation system and ICU system. The hospital performs HCV, HBV, HIV test before any new employments. No court cases or labor unrests, strikes or other disputes have happened.
UST - Current workforce of UST is 864 out of which is 114 female. Minimum Salary is 21.410 YR/month and minimum age of employees is 18 years of age. There is a Non-Discrimination policy in UST to select the staff based on certain standards and employing conditions which are based on:
- the special requirement and conditions of each position,
- adequate skills,
- training,
- experience, and
- language.
A set of OHS trainings is provided to UST staff (safety training, personnel security, safe handling tools and equipments) and healthy working conditions and appropriate PPE for the workforce provided (sterilization means in laboratories, respirators, medical computer screens lighting, air conditioning). UST HR policy has mechanisms for raising complaints to the top management through Learning Management System (LMS), Complaints Box, and Labor Unions and through departments’ managements. UST has two workers Unions :
- Staff Union, and
- Teaching Staff Union.
UST/USTH will use commercially reasonable efforts to apply requirements of PS2 that relates for subcontractors. These requirements, specified in contracts between the sponsor and its sub/contractors, should address compliance with Labor and OHS Laws of Yemen and compliance with PS2. UST/USTH will monitor and report any accidents statistics during construction to IFC.
- PS3: Pollution Prevention And Abatement
- Pollution Prevention, Resource Conservation and Energy Efficiency:
IFC guidelines for energy, water, and liquid and solid waste will be applied during both the construction and operational phases of the project. During the construction phase, IFC guidelines should be reflected in contracts between USTH/UST and contractors.
USTH - For the existing hospital located in Sana`a electricity is provided from the grid. On the site there are three back-up diesel generators of 1000 kVA each. Electricity is available for all hospital areas 24 hours daily and uninterrupted in high risk area as operating theatre, recovery room and outpatient clinics. Energy-efficient systems and equipment will be incorporated into the design of the expansion work. USTH has its own water well and drinking water purifier. The daily water use of the hospital is 170 m3. USTH is planning to reduce water and energy use through a set of measures that yet need to be developed. Wastewater is discharged off into the city sewer for final treatment in a central city waste water treatment plant. USTH is planning to put in place a waste water treatment plant for pre treatment before discharge off to a city sewage system. After the implementation of the pretreatment facility wastewater discharges should be compliant with local and IFC requirements.
UST – Given the nature of UST operation there is limited impact in regard to emissions and effluents. Potable water is supplied from USTH after being treated. Electric power is supplied via city grid. Approx 100 m3 of waste water is discarded off into the city sewer for final treatment. Household solid waste is being collected regularly and disposed by city utility on the central disposal site outside Sana’a city.
- Solid Waste and Hazardous Materials:
USTH - The management of hazardous health care wastes is conducted by USTH’s infectious control team. Housekeeping staff wear appropriate protective equipment and follow USTH infection control policy when managing the hazardous waste. Hazardous wastes are collected in special yellow bags or hard plastic containers (sharps, needles) and disposed off in a locked temporary storage area outside USTH buildings in an area with limited access. Other clinical wastes are collected in black bags and disposed in the same disposal storage area. Storage location is fenced and placed next to the future multi store parking garage. However during the site walkthrough we have noticed that the main doors to the storage area was open for unauthorized access and that both yellow and black bags are mixed together in several open containers. Inside the storage area a special closed container for hazardous waste (yellow bags) had no safety lock on, inside there was some waste; ventilation and lighting were not functioning as cable for electric power supply was cut off. This storage area needs to be upgraded to meet IFC guidelines. All wastes are removed regularly from the storage area by the city Utility as per request of the city Council, whose job is to decide on the most appropriate method of collection, transportation and disposal. The contractor is responsible for the offsite incineration of all clinical and hazardous waste. No incineration is conducted on-site. USTH has developed a plan for Disposal of Hazardous Materials. The Plan is available in Arabic and will be translated in English.
UST - Limited amount of household and hazardous material and waste are generated in different facilities of UST (Labs, Pharmacies, Dentistry Clinics, etc.) and this is managed according to the local regulations. Similar as for USTH a city Council through its contractor/utility is in charge of managing the waste.
- Emergency Preparedness and Response:
USTH – has a system and procedures in place to specifically address life and fire safety issues. Mandatory fire safety training is provided for all hospital employees twice a year but drills are not carried out regularly in accordance with the plan. Trainings cover general basic fire fighting procedure i.e how to evacuate disabled patients. USTH has duty engineers and safety manager available on-site 24 hours per day who are in charge of monitoring fire safety equipment. There are two buildings at USTH, the hospital is equipped with life and fire safety system, which is in compliance with all local fire safety laws and regulations (with automatic system to resist fire, alarm, and 160 fire extinguishers, but no sprinklers) and second building where the outpatient clinics, lab and other service departments are located does not have adequate life and fire safety system. L&F Safety provisions will be incorporated into the design for new expansion and garage building. USTH has Evacuation policy and Emergency treatment plan in Arabic and it will be translated in English. There are disease prevention measures in place, ranging from proper sanitation, use of PPE and equipment sterilization to the regular testing of air cultures, and the provision of negative pressure rooms for ICU patients, as well as facilities and systems to manage infectious diseases.
UST developed Fire and Safety plans. Regular trainings, informative courses and public awareness campaigns as to how to use fire fighting tools in emergency situations are held regularly. However no fire drills were performed during the last several. The buildings are equipped with fire protection system and each building has several emergency exists.
- Greenhouse Gas Emissions:
USTH and UST operations do not generate GHGs in excess of 100,000 tons of CO2 annually.
USTH and UST has committed to bring its hospital and educational facilities that are part of the Project in to the compliance with local regulatory requirements and IFC guidelines for air quality, wastewater discharges, hazardous waste, ambient noise and workplace conditions. As there is no modern central incinerator facility for treating healthcare hazardous waste in Sana`a, the sponsor is considering the construction of the on-site incinerator for infectious waste in its Sana`a hospital and on site pre-treatment plant for its health care waste water.
- PS4: Community Health, Safety And Security
- Community Health and Safety:
Given the fact that USTH and UST are located within the University complex/campus there is a limited interaction with neighboring communities, business etc. USTH provides regular trainings to some governmental medical schools; during the month of Ramadan certain medical services are provided for free. UST is known for its charitable work and support to institutions that take care of orphans.
USTH and UST will evaluate health and safety (including L&F Safety and occupational health and safety) risks and impacts that could affect the local community during the design, construction, operation and decommissioning stages of the project, and will establish measures to prevent or mitigate such risks and impacts commensurate with the identified risks and impacts. These measures will be included in the sponsor’s integrated Environmental and Social Management Plan/Procedures to be developed.
Several outstanding issues that IFC has observed during the appraisal visit will be adequately addressed by the management of USTH/UST as the management has expressed commitment to bring them into the compliance with the best international practice and IFC EHS requirements for health care and educational facilities. USTH has one of the biggest referral laboratories for testing on HIV, Hepatitis, Tuberculosis, Typhoid, in Yemen and special care need to be devoted to infectious control and safety of patients, staff and visitors.
New garages that will be constructed adjacent to the hospital thus solving current issue with the lack of parking space and an increased traffic flow in and from the hospital. Contractors for design and construction of the expansion of the existing hospital, including multi store garage, and new UST expansions i.e Sana’a campus and new campus in Taiz, will apply sound principles of environmental engineering and safety engineering during the sitting and construction phase, and these principles will be stipulated between the contractors and the sponsor in their contracts, to prevent and/or avoid any reputation or other risk for the sponsor associated with potential adverse environmental and social performance of the contractors activities.
- Security Personnel:
USTH and UST have their own 75 trained security personnel which are part of the Maintenance and Services Administration. Personnel, most of which retired or ex policeman, are required by local regulation to undergo regular trainings. Security staff guards entrances to the hospitals and educational facilities to ensure the safety of visitors, patients and students.
Specific to the Hospital in Sana`a, guards are instructed to request from all visitors which wear a traditional knife “gambia” to deposit it to a safety locker while visiting the hospital. So far, as reported by the management of hospital, there were very few incidents with those visitors who did not want initially to leave their knife at the reception area.
The sponsor will draft Life and Fire Safety Master Plan, in compliance with IFC Life and Fire Safety Guideline, including an Audit of the existing hospital and educational facilities, and Corrective Action Plan (CAP) if necessary.
Structural elements will be designed and constructed by qualified and experienced professionals and certified and approved by competent authorities or professional to IFC, similar to the L&FS requirements. This will be COD as defined in ESAP.
- PS5: Land Acquisition And Involuntary Resettlement
All expansions in Sana`a and new construction in Taiz do not include issues related to PS5, as the land either already belongs to USTH and UST or has been purchased through willing buyer/seller agreement. No persons have been displaced either physically or economically by the current facilities. No resettlement has been needed so far in USTH/UST operations. The sponsor will establish grievance mechanisms for receiving and addressing grievances raised by the local community. For any other potential development that may be part of the project in the future the sponsor is committed to follow local laws and IFC PS5, and to update IFC on the land acquisition process once future development sites are confirmed, and provide records of consultations undertaken and compensation provided to demonstrate compliance with PS5.
