27603 - CentroMedico III

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Environmental & Social Review Summary

Project Number

27603

Company Name

CONTROLADORA DE SERVICIOS MEDICOS S.A. DE C.V

Date ESRS Disclosed

Feb 19, 2009

Country

Mexico

Region

Latin America and the Caribbean

Last Updated Date

Nov 30, 2016

Environmental Category

B - Limited

Status

Completed

Previous Events

Approved : May 11, 2009
Signed : Jun 9, 2009
Invested : Nov 9, 2009

Sector

Hospitals and Clinics

Industry

Health, Education and Life Sciences

Department

Gbl Ind, Manufact, Agribus & Services

Project Description

The proposed project involves design and construction of two small 40-bed hospitals in the cities of Tepic, State of Nayarit, and Colima, State of Colima, in Mexico. The new hospitals will offer general primary, secondary and tertiary care and will add to the existing ambulatory surgical center capabilities and 86-bed hospital that the company operates in northern Guadalajara, as well as the 60-bed hospital under construction in southern Guadalajara. In addition to the new hospitals and in line with past projects, this new Project also includes the construction of medical offices that CMPDH will sell to third party doctors. CMPDH will lease approximately 40% of the office space.

Overview of IFC's Scope of Review

Review of this project consisted of analysis of documentation provided by the project sponsor and the data contained in a detailed questionnaire addressing environmental and social issues. IFC staff including environmental staff of a co-investor (IDB) conducted a visit to Centro Medico operations in Mexico to appraise environmental and social affairs management and plans for the new hospitals. In addition, IFC conducted a review of company performance. Supervision included review of compliance with the Environmental Action Plan developed for the previous investment to close observed gaps between IFC requirements and the company’s operations; and, field visits by IFC environmental staff.

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;
- PS5: Land Acquisition and Involuntary Resettlement.

The two, new hospitals will be constructed on plots of land in two cities in western Mexico. Site locations include Tepic, State of Nayarit, and Colima, State of Colima. The new, small projects have limited specific environmental and social impacts that can be avoided or mitigated by adhering to good international industry practices and transfer of CentroMexico’s previously developed programs for hospital operations to the new operations once construction is completed. IFC previously invested in hospitals constructed by the company and required the establishment of a management system for environmental and social affairs. Review of the proposed investment through the lens of the Performance Standards and the revised EHS guidelines, which were not in effect at the time of the original investment, shows that there are limited issues that will be addressed through adherence to the requirements of Mexico’s strong regulatory environmental for health care facilities, IFC’s performance standards, applicable EHS guidelines, and CentroMedico’s existing programs for health care waste, sanitary wastewater, and associated operations issues.

Environmental and Social Mitigation Measures

1. PS1- Social and Environmental Assessment and Management Systems – CentroMedico Puerta de Hierro (CMPDH) has implemented a systematic approach to management of internal affairs, environmental and occupational health and safety, and other hospital management considerations. CMPDH mitigates potential impacts from hospital operations through adherence to and the institutionalization of procedures based upon regulations promulgated by the ministries of Environment, Health and Civil Protection. Thus, for example environmental health and safety procedures are oriented to energy savings, minimization of water consumption, management of dangerous wastes in accordance with Mexican regulations, and ongoing monitoring programs. CMPDH’s existing hospital at Zapopan originally planned to establish and operate a formal quality management system that met the requirements of ISO 9001:2000 and certification was to be obtained as part of the previous investment. After consideration of the benefits of ISO versus more health care oriented certifications, its business model and other considerations, CMPDH decided to obtain Certificacion de Establecimientos de Atencion Medica (Health Care Institutions Certification) from the Mexican Ministry of Health as well to seek Joint Commission International (JCI) certification. The JCI assesses health care organizations to determine compliance with a strict a set of standards and requirements designed to improve quality of care. CMPDH’s Zapopan Hospital will receive its Health Care Institutions Certification in February 2009 and will obtain JCI certification in accordance with the attached environmental action plan (EAP). CMPDH will transfer and adapt the existing Mexican government-certified management system to the new hospitals at Colima and Tepic once construction is complete and each is in operation. Subsequently, both hospitals will obtain the Mexican Ministry of Health certification in accordance with the attached Environmental Action Plan (EAP).

CMPDH does not currently hold meetings with stakeholders to inform them of hospital operations and upcoming activities seek their input and provide them with a grievance mechanism to air complaints about hospital operations and other concerns. CMPDH will develop an active program for the two new hospitals and prior to the commencement of construction will institute an active and ongoing program to keep host communities informed and facilitate receipt and response to all community grievances.

2. PS2 – Labor and Working Conditions - CentroMedico’s Human Resources (HR) policy and procedures principally address acquisition and placement of new employees. Subcontracted employees are required to comply with CMPDH procedures and policies applied to permanent CMPDH employees. The human resource policy and existing procedures are incomplete in terms of labor transparency requirements, employee grievances, and participation in organized labor organizations and associated issues stipulated in this performance standard. CMPDH will revise its human resources policy to incorporate missing elements described in performance standard 2 in accordance with the attached Environmental Action Plan (EAP).

CMPDH provides diverse training to ensure professional capacity and active occupational safety and health prevention and response programs. These programs are subject to the oversight of the Secretaría de Salud (Ministry of Health). Moreover, labor safety and disease prevention programs, which consist of the following elements, are well developed. When new employees have signed the labor contract, they must provide a current medical certificate including required laboratory test results. Employees assigned to critical areas including neonatal intensive care, pediatric and adult intensive care, operating theatres, dialysis, etc. as well as in nutrition and food services participate in epidemiological surveillance for specifically notifiable diseases. All employees receive Hepatitis B vaccination. In addition, all employees participate in accident prevention training, and all accidents are reported the appropriate regulatory agency. Infectious and contagious disease patients are isolated in accordance with internal and Ministry of Health requirements. CMPDH submits a weekly report to the Ministry of Health detailing new cases of specifically notifiable diseases (monitored in the epidemiological survey) and nosocomial disease. In addition, CMPDH provides specialized training and appropriate personal protective equipment (PPE) for employees handling infected clothing, linens and hazardous health care waste.

3. PS 3 Pollution Prevention and Abatement – CFE the Mexican electrical authority provides electric power from the national grid’s Comisión Federal de Electricidad (CFE) to a principal substation for distribution to dry transformers for each building. Engine-driven generators will provide standby electric power and these will be isolated adequately to prevent local noise impacts. To conserve energy, internal lighting will consist predominantly of fluorescent fixtures. CMPDH operating procedures address minimization and recycling of non hazardous waste such as wood, plastics, paper, and cardboard. Current plans include centralized control for lighting and equipment to avoid consumption of energy by unused equipment and lighting. The control system facilitates custom programming and facilitates data collection and trends in electric power consumption. Each host municipality will provide potable water and each hospital will provide further treatment consisting of filtration and softening to ensure the potability of water for hospital operations and critical applications. Both hospitals will discharge sanitary wastewater to public sewerage under permit that municipal government-owned treatment works will treat and disinfect.

Hospital staff segregates wastes from hospital operations into one of the following classifications: municipal solid waste, dangerous biological or infectious waste [biological, infectious waste (RPBI)] and hazardous waste. All wastes are collected for off site management. RPBI is collected in red bags by especially trained staff with appropriate PPE and then transported to temporary storage designed and built for such wastes. Red bag waste is stored in a low temperature chamber, which staff clean daily, and remains locked. CMPDH contracts RPBI collection and disposal to Sterimed SA CV a company licensed by the Ministry of Ecology and Environment for this service. Sterimed collects RPBI daily and provides CMPDH with a manifest for collected waste. Similarly, staff accumulates pathological wastes as well as sharps in yellow bags collected for disposal by Sterimed SA CV. Gen Industrial SA CV, certified by the Ministry of Environment for this service, collects and disposes of municipal solid waste and hazardous health care waste (segregated into specialized containers), and also provides manifests addressing collection and destruction.

4. PS4 – Community Health Safety and Security – CMPDH will engage the services of life and fire safety engineering professionals to review the design of both new hospitals to ensure compliance with IFC life and fire safety requirements addressed in the General EHS guideline. In addition, after completion of construction, the life and fire safety design professional will inspect each building to ensure that the responsible contractor constructed the facility in accordance with the design. As described above, CMPDH hospitals have well-developed waste management programs, employee training and internal disease prevention programs that aid in protection of host communities and patients.

CMPDH will develop and implement a traffic safety program for all vehicle operators associated with the hospital to reduce the frequency and severity of motor vehicle accidents.

5. PS5 Land Acquisition and Involuntary Resettlement - CMPDH is the current owner of the two properties in Tepic and Colima designated for construction of the two new hospitals. CMPDH acquired each property through a willing buyer-willing seller relationship. There were no economic or physical dislocations resulting from transfer of ownership of either property.

Stakeholder Engagement

The Ministry of Health, Ecology and Civil Protection regulate CMPDH and as part of this oversight carry out unannounced visits to operating hospitals. These inspectors inform CMPDH of all observed out of the ordinary situation exists and return within 30 days to ensure that the noted deficiency has been corrected. CMPDH does not currently hold meetings with stakeholders to inform them of hospital operations and upcoming activities or seek their input and provide them with a grievance mechanism to air complaints about hospital operations and other concerns. CMPDH will develop an active program for the two new hospitals and prior to the commencement of construction will institute an active and ongoing program to keep host communities informed and facilitate receipt and response to all community grievances.

In addition, CMPDH will utilize the content of this ESRS and the attached EAP without reference to IFC, translate this information into Spanish and make the documentation available to the public at strategic locations in the cities of Colima and Tepic as well in local newspapers.

CMPDH will promulgate information about the project as well as potential environmental impacts and mitigation measures contained in this environmental and social review summary and in the companion environmental action plan without reference to IFC. The document will be prepared in Spanish and made available to the public at strategic locations in the cities of Colima and Tepic. The availability of this information will be announced in local newspapers in the cities of Colima and Tepic. This information will be published on CMPDH’s website (www.cmpdh.com) and available at the following physical location: Centro Medico Puerta de Hierro, Blvd. Puerta de Hierro No. 5150, Plaza Corp. Zapopan, Guadalajara, Mexico.

CMPDH professionals to contact about the project include the following:

Alejandro Gil
Address: Centro Medico Puerta de Hierro, Blvd. Puerta de Hierro No. 5150,
Plaza Corp. Zapopan,
Guadalajara, Mexico

Tel: +(5233) 3848-4052
Fax: (5233) 3848-4058
Email: alejandro.gil@cmpdh.com
CMPDH Website address: http://www.cmpdh.com/

Client Documentation

File Name	Actions
Centro Medico III 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.
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