The company has presented plans to address the potential environmental and social impacts to ensure that the project will, upon implementation of the specific agreed mitigation measures, comply with policies and standards internal to KHI, applicable national laws and regulations, IFC’s Performance Standards on Social and Environmental Sustainability and IFC’s applicable Environmental, Health and Safety (EHS) Guidelines. The information about how these potential impacts will be addressed by the project is summarized in the paragraphs that follow, and in the ESAP which is disclosed with this document.
Social and Environmental Assessment and Management Systems
A Land Certificate was issued to KHI by the national Land Title Registry which confirms the lease agreement for the site. In terms of the Environmental Assessment Regulations, the development required an EIA. KHI commissioned a local environmental consultancy to undertake the EIA which was subsequently approved by the Environmental Protection Agency (EPA) with an Environmental Permit being issued for the project. KHI obtained a permit from the Accra Metropolitan Assembly (ACA) for demolition of the old Ambassador Hotel subsequent to which a building permit was issued by the ACA for the new hotel. All relevant departments within the ACA e.g., planning, engineering, traffic, fire protection, also signed off on the design drawings.
A joint venture between a local construction company and a company based in Italy i.e., Ghana & Italy 5Star Hotel Development (G&I) were commissioned by KHI to construct the hotel. G&I has a detailed organgram defining relevant roles and responsibilities within the joint venture. Aside from the technical aspects, there is a full-time Human Resources Manager and Safety Manager. KHI also has a dedicated Project Manager on-site who is supported by a Resident Engineer, amongst other personnel.
Dar-al-Handasah undertakes quality control on behalf of KHI using an ISO 9001 accredited quality management system as a basis for this. Dar-al-Handasah has experienced personnel e.g., architects, civil, structural and mechanical engineers, on-site who are responsible for quality assurance. These representatives engage with G&I’s quality assurance team during all phases of project implementation. In addition, KHI have engaged the Bureau Veritas, an international group that specializes in the inspection, analysis, audit, and certification of products and infrastructure relative to regulatory or voluntary standards. The Bureau Veritas undertake ongoing audits of the development to confirm construction is being completed in accordance with the standards specified.
Mövenpick has extensive experience in hotel management and has already appointed key personnel including a Human Resources Manager and Engineering Manager for the hotel. The company has standard operating policies and procedures that apply to all operations. Topics covered include human resources, operation of equipment and the management of life and fire safety, amongst others.
As per the Environmental Permit, an Annual Environmental Report is required for submission to the EPA. To date, G&I have submitted two environmental reports on behalf of KHI to the authorities. During the operational phase, this will be the responsibility of Mövenpick.
Labor and Working Conditions
While the number of construction workers on-site varies according to the construction stage, currently there are 500-1000 workers on site daily. All employment is in accordance with national legislation as contractually defined between KHI and G&I, and this similarly applies to sub-contractors. The minimum age for employment in Ghana is 18 years and G&I review personal records to ensure workers are above the legal age.
Once the hotel is operational, Mövenpick will be responsible for employment. At the time of opening the staff compliment will be 288, and this will increase to 311 by the end of 2011. It is estimated that 38% of staff will be women. Mövenpick has a Code of Conduct that applies to all employees which includes a non-discrimination policy and guidelines in respect of harassment and victimization at work. The company also has a generic Employee Handbook that is applicable to all operations and includes a grievance mechanism. This defines conditions of employment including leave benefits (vacation, sick and maternity leave), access to medical aid which is inclusive of an employee’s immediate family, and the company’s approach to training and development of employees. The Mövenpick Human Resources Manager for the hotel is currently on-site compiling a facility-specific human resources manual. In Ghana all employees are allowed to join unions and the Commercial and Industrial Union generally represents employees in the tourism industry. While Mövenpick’s human resources policies are generally compliant with this Performance Standard, as per the project ESAP, KHI are required to submit the hotel’s human resources manual to IFC to confirm compliance. In addition, KHI will include a condition in contracts with tenants renting office or retail space requiring compliance with national labor legislation; Ghana is a member of the International Labor Organization and has ratified 46 Conventions including those related to minimum wage, weekly rest, child labor and discrimination.
KHI is ultimately responsible for occupational health and safety (OHS) on-site, however their contract with G&I requires the construction company to comply with national requirements and appoint personnel to manage this component. Equally, subcontractors’ agreements with G&I require compliance with national standards and G&I’s internal requirements. Safety is an agenda item at all project meetings and all activities required a method statement prior to being initiated. The method statements include safety procedures, particularly where high risk activities are to be undertaken e.g., hot work, or working at heights. All construction workers are provided with personal protective equipment with the observed level of use during the appraisal being high. All workers are also subject to induction training, along with weekly toolbox talks which cover varying topics. There is a Safety Manager and 14 full-time safety officers on-site who undertake daily inspections of all work areas. In addition, safety officers are assigned to high risk practices such as hot work for the duration of the task. Daily safety reports are compiled, which are then consolidated into weekly and monthly reports. In the event of an incident, the cause is reported upon and corrective actions defined. There is an on-site clinic with a full-time nurse and a doctor visits the site three times a week. All employees may visit the clinic for treatment regardless of whether it is a work related ailment on not. To date there have been no fatalities or disabling injuries.
While the typical OHS risks during the operational phase are low, the Mövenpick Employees Handbook includes a section on safety at work. Equally, the company’s Operational Standards Manual – Security and Safety, which applies to all operations, includes a checklist of activities that need to be assessed on a regular basis to manage OHS.
Pollution Prevention and Abatement
The EIA includes an Environmental Management Plan for the construction phase implementation of which forms part of G&I’s contractual agreement with KHI. Ablution facilities are connected to five conservancy tanks which are regularly emptied and the contents disposed of via the Accra sewerage treatment works. Solid waste is collected in dedicated receptacles and disposed of at the municipal waste disposal site. Stormwater is collected in drainage channels that traverse the site and discharge into the municipal stormwater system. Dust control, a concern raised by stakeholders during the EIA process, is undertaken by mobile water tankers. No major environmental incidents have been recorded to date and there have been no complaints from neighboring properties.
The hotel will use approximately 95,000 m3 of water per annum as supplied by the Ghanian Water Board. There is currently one borehole on-site with another to be installed both of which will be used for irrigation purposes. Although the water received from the ACA is treated, it will be subject to further treated via an on-site water treatment plant prior to use. This process includes initial filtration, chlorine treatment and finally water softening. Water used in the kitchens will undergo a further treatment stage by ultraviolet light. As per Mövenpick’s standard practice, the water will be regularly monitored for purposes of quality control. However, as defined in the ESAP, the potable water quality monitoring program will be in compliance with IFC’s requirements.
The hotel will use an estimated 21 million kWh per annum supplied from the national grid, 1460 tons of diesel for the generators and steam generation by the boilers and liquefied petroleum gas (LPG) for cooking and heating in the laundry. This, combined with the use of chillers, will generate 18,200 tons of CO2 per annum. To optimize energy efficiency at the hotel and enhance energy use, following six months of operations, an energy efficiency audit will be undertaken of the hotel. This audit will also review water usage to ensure efficient use and identify opportunities for reduction. To support the audit, the hotel will also install a metering system to define the energy consumption of the hotel, office and retail areas separately, along with energy intensive equipment such as the chillers. These requirements are identified in the project ESAP.
The hotel has three standby generators with a capacity of 1.6 MVA each which are supplied with diesel from three 30,000 gallon underground storage tanks located adjacent to the generators. The tanks were fabricated on-site, the welds subject to nondestructive testing, and then pressure tested prior to being installed. The hotel will implement a stock reconciliation program to monitor the stock of diesel relative to that delivered, along with annual pressure testing of the tanks, to assist in leak detection. Diesel will also be used on a continuous basis by the boilers to generate steam for the laundry and kitchens. The anticipated usage of the standby generators for electricity generation is estimated to be 2 hours per day.
Five aboveground LPG storage tanks are located in a reinforced enclosed area isolated from the hotel. Each tank has a capacity of 5 m3 and was fabricated in France in accordance with the Code for Construction of Unfired Pressure Vessels (CODAP) and the Pressure European Directive 97/23/CE. The area has a fire suppression system and is monitored by CCTV cameras.
The hotel will generate approximately 76,000 m3 of sewerage per annum primarily from the ablution facilities, laundry and cleaning activities The kitchens are fitted with grease traps, there is lint trap on the discharge line from the laundry and an oil water separator on the discharge point from the building housing the generators. All sewerage will be disposed of via the Accra sewerage works which are operated by the ACA Metro Sewerage Unit. Correspondence from the Unit confirms that the sewerage works has more than sufficient capacity to accommodate the hotel. In addition, while there are various ongoing mechanical repairs to the works, the facility complies with Ghana’s national waste water standards.
Chemicals used at the pool include aluminum sulphate, chlorine gas stored in cylinders and chlorine and soda ash in granular form. These chemicals will be stored in a negatively pressurized room adjacent to the pool’s filtration plant.
Concrete from the original hotel was crushed and reused as a base layer for the external paved areas. Power consumption at the hotel will be controlled by a Building Management System. Measures implemented to manage and limit energy requirements include double glazing of windows and double external walls to improve insulation, keypads in guest rooms that turn off lighting and non-essential electrical items, low voltage lighting internally and high pressure sodium lighting for external areas. In addition, all toilets are dual flush systems and the flush systems for urinals in public areas are activated via infrared so as to minimize water usage.
Maintenance of the hotel gardens will require the use of pesticides on occasion and the hotel will also be fumigated according to a predefined schedule. As defined in the ESAP, KHI are required to compile and implement a pesticide management plan at the hotel that is consistent with IFC’s General EHS Guidelines.
Community Health, Safety and Security
Access to the site is via Independence Avenue which forms the south-eastern boundary of the hotel and has been widened some 50 m from hotel’s ingress point to accommodate incoming traffic and thus limit congestion. A bus / taxi rank is located approximately 50 m to the south of the hotel’s exit point, however this is offset from the road so as to avoid congestion and limit potential safety risks. Delivery vehicles will access the hotel via Liberia Link Road which forms the hotel’s western boundary.
Various building codes have been used in design and construction of the hotel depending on the nature of the activity. For example, the ASTM codes have been used in the structural design, the British Standards applied to the geotechnical design, and the Uniform Building Code used to define the hotel’s structural integrity in the event of seismic events. The National Fire Protection Association (NFPA) standards have been applied to the life, fire and safety design and management. Key design parameters include the installation of a water sprinkler system throughout the hotel, smoke detectors in all rooms, fire proof doors on all hotel guest rooms with a two hour safety rating, illuminated directional signage indicating exit routes, fire extinguishers on the hoods over the cooking areas and an automated fire detection and prevention system. The national Fire Protection Service also approved the life, fire and safety designs and the hotel will be regularly audited by the Service. Annual renewal of the hotel’s Fire Inspection Certificate is required as a condition of operation.
The Bureau Veritas undertake regular audits to confirm application of the relevant design criteria and building codes during construction. Once construction of the hotel is complete and prior to the public opening, KHI will commission an independent life, fire and safety specialist to undertake an audit to confirm that the hotel has been designed and constructed in accordance with the NFPA’s requirements. In addition, this will also include a review of the site specific emergency response plan to ensure it is responsive to the hotel’s life, fire and safety management system.
Access ramps are located at the hotel’s primary entry points for disabled persons and ablution facilities for disabled people are situated adjacent to the restaurant and bar, meetings rooms and the ball room. In addition, similar facilities are also available for employees.
To prevent the potential for the legionella bacteria developing in the hotel’s hot water system, the water will be stored at a minimum temperature of 600C. The pool water will be treated via a sand filter the throughput of which will equate to the total volume of the pool every six hours. In addition, the pool water will be treated via an automated chlorine testing and dosing system to maintain a constant amount of chlorine in the water. The hotel will however implement a monitoring program to confirm the legionella bacteria is not occurring in the hot water system and to verify the pool water and that to be used in the spa in of an acceptable quality. Food hygiene will be managed via implementation of an accredited Hazard Analysis and Critical Point (HACCP) food safety program. The requirement for the water quality monitoring and HACCP programs are defined as requirements in the ESAP.
Security during the construction phase was initially outsourced to a private security firm who used unarmed guards. However, as result of ongoing theft, security is currently being provided by the Military Police who are trained in the use of armed force and follow specific protocols in its application. To date there have no incidences of armed force being used. During the operational phase, security will once again be subcontracted to a private security who will use unarmed guards.
