PS1: Social and Environmental Assessment and Management System
The project was four months into construction at the time of appraisal; completion is expected by May 2012 with operations due to commence in September 2012. Application had been made earlier to Escobedo (the municipality in which the project lies) for a Licence to Construct; the Licence was awarded in November 2011.
A Manifesto de Impacto Ambiental Modalidad General was prepared in November 2010 for the Binaria Project (which includes the hospital in which IFC is investing). The EIA was developed by a licensed professional and contains a description of the project, ambient environment, laws and regulations that the project will be subject to, environmental impacts, and mitigation measures related to impacts. Impacts were assessed for site preparation, construction and operation and maintenance of the project and are deemed to be appropriate to the types of issues associated with hospital construction and operation of this kind as is required by PS 1.
A professional architecture firm has been contracted to design the hospital with additional input provided from a specialist hospital design firm. Ginequito and Ambar Capital (the two partners in the venture) use a third party company to audit the design companies. In addition, the State of Nuevo Leon also conducts inspections of the site; no problems have been identified to date in such audits.
Management Program, Organization and Training
The EIA includes proposed management/mitigation actions to manage E&S impacts. Some, pertaining to construction for example, were observed being enacted during the site visit. These included dust control, covering of trucks carrying excavated earth and enforcing speed limits for haulage trucks. Storage and ultimately removal of wastes (hazardous and non-hazardous) is conducted by licensed contractor. Both Ambar and Ginequito have weekly meetings to review construction operations. The managing architect is responsible for compliance with contract requirements; an onsite team of approximately 20 people have specific responsibilities for elements of the management plan.
With regards to operation of the new medical facility, the quality management system (QMS) in existence at the downtown location will be duplicated to ensure appropriate management. E&S issues are integrated into the existing operations (including the QMS) by the head of Operations. Under this position is a Safety Supervisor who is responsible for fire and emergency preparedness (fire drills are conducted twice a year) and the overall physical safety of patients. A Maintenance Coordinator (hazardous materials management) and a General Services Coordinator (covering laundry, cleaners) provide necessary management and direction with regards to these issues. There is also a head of Personnel Administration; reporting to them is the Training and Development Coordinator and a Coordinator of Recruitment and Selection.
Training of personnel at the downtown hospital is provided according to their duties. For example, an internal fire brigade (as part of the Civic Protection Committee) receives training from the local fire department. Competency of employees is provided for by hiring qualified individuals or providing additional training to new hires and to those already employed. New employees receive a training plan; an annual training plan (continual training plan) is used to ensure ongoing training needs are met, i.e. according to job duty and responsibility and to reinforce prior training and experience. In addition, records of incidents are used to identify additional opportunities and need for training. Training records are maintained and were reviewed during appraisal. Examples of such training include avoidance of puncture wounds from handling sharps, isolation of (dangerous or contaminated) areas, etc.
Monitoring and Reporting
The existing hospital tracks water and energy use and waste generation. Management responsible for specific operational areas uses these data to drive performance, reductions as appropriate. In addition, there is a program in place (Sistema de Mejora de Empleados) to encourage employees to identify opportunities for efficiencies in their jobs, including that related to energy use. For example, boiler operations were fine tuned to save 30% equivalent energy consumption based upon a suggestion received from an employee who works in that area. H&S monitoring occurs and, as noted above, is used to identify on-going training needs.
Weekly management meetings are held which include E&S initiatives as part of the agenda. The hospital does not report detailed information to the local authority on waste generation other than that required to establish them as a large generator for the purposes of assessing waste collection fees (a generation of 13 tons monthly is defined as a large waste generator).
H&S statistics are reported monthly by the H&S committee to senior management. Senior management (Director General and Heads of Departments) uses this information to provide input into future training delivery in order to address identified issues.
The identification and assessment of the above risks and impacts, and new risks and impacts as they may occur, will be required at the new hospital and clinic. Management of the same will be achieved through the establishment of systems and the provision of suitably competent personnel and adequate budgets, the manner and likes of which are evident in the Ginequito facility.
PS2: Labor and Working Conditions
Human Resources Policy and Management
The existing hospital has many policies regarding human resources management. For example, policies exist on iinternal regulation of labor, collective bargaining, vacation, and recruitment, and selection of staff. Policies are based upon national/federal law.
Currently 400 people are employed at the downtown hospital (for 63 beds); 70% of employees are women. Similar levels of employment are expected at the new hospital/medical clinics due to there being a similar number of beds.
Working conditions are documented in the Internal Regulation of Labor; this is reviewed at the time of hiring and the new employee signs that they have seen and understand the contents. Induction training is provided to new employees. Contents include the history, mission and vision of the hospital; emergency plans; the contents of the Internal Regulation of Labor; rights of the employee (includes the extra food bonus, education program (completion of elementary or high school education) and the availability of a crèche); a review of the quality system; review of restricted access areas (non-employee elevators, hazardous materials storage, pathology waste areas, etc.). All this information is contained in a booklet that is provided to attendees.
Complaints are managed through a system (Registro de Seguimiento a las Quejas de los Usuarios) as part of the quality management system. The register was made available as part of the appraisal and several comments, and follow up actions, reviewed. The head of Personnel Administration is responsible for managing the system. In addition, meetings that discuss work related topics include the message that if a complaint arises that cannot be resolved by the employee’s immediate supervisor, and then the Director General will make himself available to address the complaint.
Workers Organizations
There is a current and ongoing agreement between the hospital and the Asociacion Profesional de Trabajadores (‘Ignacio Allende’) Registro Legal 7/75, recognized by the Federal Government. The hospital pays the dues for the association.
Non-Discrimination, Equal Opportunity and Retrenchment and Protecting the Workforce
The Reglamento Interior de Trabajo includes coverage of this issue. The Principio de Igualdad states that non-discrimination in hiring is the practice; discrimination based on sex, skin color, nationality, political affiliation, etc. is not allowed. Retrenchment is not applicable as the new hospital will provide employment for approximately 300 individuals.
With respect to protecting the workforce, prospective employees are checked to determine their age (using voter identity cards or birth certificates for those under 18). The Reglamento Interior de Trabajo states that no one under 16 can be employed. Mexican Federal Labor Law (Nueva Ley Federal Del Trabajo, Title II, Chapter I, Art. 23) prohibits persons under the age of 16 from working. Considerations regarding labor in the supply chain (including contractors) are provided for through contract requirements to comply with applicable labor law. Forced labor is prohibited under Mexican Labor Law.
Occupational Health and Safety
The company maintains detailed and comprehensive internal procedures as part of its quality management system that includes issues related to OH&S. These are also in agreement with national norms and requirements and describe procedures for the protection of health of workers (for example, with regards to nonsocomial infections). A hierarchical approach to risk is used to identify areas with greater risks to employees (e.g. those working with radiation, clinical laboratories, and those working with food). Monitoring of such employees is conducted (e.g. those working with radioactive substances are provided with dosimeters and exposure is recorded and reports made to authorities to show compliance with legal limits). A program of general vaccination for all personnel that has contact with patients is implemented. This includes employees in the following areas: nurses, cleaning, maintenance, security, etc. 80% of employees participates in this program. A Heath and Safety Committee convened and maintained by the Department of Administration is comprised of employees and management representative of departments where higher risks are to be found. The committee meets quarterly and conducts walkthrough audits of the facility. Suggestions and other inputs are also received by the committee and reviewed as part of their mandate.
All accidents and incidents that occur are recorded and investigated; follow up actions are required. Such actions are audited to ensure equipment and/or behavior is fixed/improved. Training and re-training needs are identified as part of this exercise.
With regards to the construction of the proposed project, the client contract requires contractors comply with OH&S regulatory requirements. Evidence of good practice, such as use of appropriate personnel protective equipment, fall prevention measures for those working at height, etc. were observed during the visit to the construction site.
The identification, assessment and management of human resource issues, including OH&S, commensurate to the risks and impacts to be found at the new hospital and managed to the same standards observed at the downtown hospital will be required.
PS3: Pollution Prevention and Abatement
Compliance can be demonstrated with the WBG Health Care Facilities EH&S Guidelines. For example, design and operational considerations in the existing hospital include the separation of wastes according to hazard (achieved by using different colored containers and utilizing different routes that the wastes must follow before being picked up by a contractor and properly disposed.) Waste manifests are maintained and show use of licensed contractors to properly dispose of wastes in approved disposal facilities. The HVAC system is designed to provide specific, and isolated, flows to specific areas in the hospital (i.e., flows in operating theatres is exchanged every 2 hours). Waste minimization is practiced to the extent possible while providing appropriate care for patients; specific waste collected by the waste contractor is recycled as appropriate and where facilities exist. Source reduction has been applied; for example, the facility is mercury free. Employee suggestions in the past have targeted excess packaging in supplies (e.g., milk cartons); and reuse of certain materials, e.g. cotton clothes that (after disinfection) can be used for other purposes. The purchase and use of an ‘on-demand’ auto-clave to replace the continually running auto-clave was undertaken; this saved approximately 3% of the entire electrical consumption of the hospital. The air conditioning system was recently upgraded; the hospital installed a new electrical cable system, changed 16 compressors and their configuration which resulted in greater reliability, greater efficiency, and elimination of refrigerant loss during maintenance, and ultimately substantial cost savings. Small boilers in the existing hospital are powered by either gas or electricity.
Similar, if not identical operations, equipment and practices as those described above (e.g. connection to the municipal WWTP, use of electricity to heat water to required temperatures) will be put in place at the new hospital. With further regards to the new project, use of ‘bio-concrete’ that provides for infiltration of storm water, thereby preventing excessive runoff, will be made. Other specifics as currently proposed include: a water-cooled 600 ton cooling system using HFC 134a; T8’s for lighting will be the norm; motion detectors/sensors will be used in areas not experiencing heavy foot traffic and solar powered hot water heaters will heat water to 40oC which will then be further heated to 70 oC using boilers powered by either electricity or natural gas (supplied via pipeline). These energy saving techniques are currently used in the downtown hospital.
Wastes and hazardous materials
Procedures to manage hazardous materials (HM) are developed and implemented in the existing medical facility, as noted above. For example, all HM are listed, precautions to be taken when using, handling the material, the required protection equipment to be utilized to protect the H&S of the employee and what to do in the case of a spill are detailed. The register of such substances, and associated information, is drawn from the material’s Material Safety Data Sheet.
Wastes are separated (such as bio-medical, hazardous, solid) in the existing hospital and are collected by a contractor who transports them to a municipal owned and operated waste treatment facility. This facility incinerates or recycles wastes according to the waste stream. Wastes for incineration are used to generate power. As noted above, manifests are maintained by the existing hospital operation to show appropriate practices are followed. Wastewater is discharged to the municipal WWTP. Effluents are analyzed annually according to regulatory requirements; results reviewed during appraisal demonstrated compliance with the legal limits in place in Monterrey. Medical wastes from the new medical facility, which may be more complex and/or toxic than those generated from the existing hospital due to the wider range of clinical services to be provided at the new installation (e.g. chemotherapy), will be segregated and/or treated and disposed of in accordance with the stricter of either the requirements within the WBG EH&S Guidelines for Health Care Facilities or municipal-based regulations (Norms by CENAPRED and OMS) including any pretreatment and related medical waste management programs that are in place.
Emergency Preparedness and Response
As noted elsewhere, the current operation includes assessment and has put in place a variety of plans and procedures to address emergency situations. Issues are identified during audits, are reviewed by the various employee and management committees and are integrated into the quality management system. Recognition of issues, for example, is made manifest by every employee having a Codigos de Seguridad which is a color coded risk identification system on which training is provided. Risks such as bomb threats, fire, child abduction, etc. are included in this system.
Greenhouse Gas Emissions
Estimates of the CO2 equivalent emissions resulting from operation of the new hospital are based upon actual resource consumption at the Ginequito facility (which consumed a total of 2,486,160 KWh/year, equivalent to 1,086 tons CO2 equivalent/year and an estimated total of 115,220 m3 of natural gas/year providing energy of approximating 4.216TJ responsible for 238 tons CO2 equivalent per year.) Given the new hospital will have less beds but more space dedicated to clinical offerings the emissions total of 1,324 tons CO2 equivalent per year is expected to be similar. Actual records will be used to review amounts of tons CO2 equivalent per year that will be emitted from the new hospital once it is operational.
Pesticide Use and Management
Mechanical traps are used against rodents in the grounds around the existing hospital; chemicals used in pest control (against ants, spiders, fleas, etc) are applied by a licensed third party service provider. Appropriate licenses were reviewed during the appraisal. Products used are allowed under regulations promulgated by the federal health department. Only products that are biodegradable are used.
The identification, assessment and targeting of pollution prevention opportunities and energy efficiency measures commensurate to the E&S risks and impacts to be found at the new hospital, then managed to the same standards observed at the downtown hospital, will be required.
PS4: Community Health, Safety and Security
The existing building has L&FS elements as would be expected in a hospital: smoke detection, signs, emergency lights, hose reels, trained fire fighting teams on each floor, and egress ramps to the adjacent parking structure to allow for the evacuation of bed-ridden patients, etc. The hospital is currently working with an independent licensed certification entity (ASES) to demonstrate compliance with civil protection requirements, a local government requirement that was recently promulgated. The same third party is engaged on other matters of L&FS, such as certification of fire extinguishers.
Life and Fire Safety, as it pertains to the new medical facility, is detailed in an L&FS master plan. This document contains plans and details such as layout and evacuation routes, equipment needs (smoke detection, control panels, enunciators, CCTV, etc.), the use of flame retardant materials, and provides for the overall design and installation of L&FS systems. The design and installation of L&FS systems is being handled by a third party. The company will certify that the L&FS plan is responsive to an international standard, such as the US NFPA.
Potable water for the existing operation comes from municipal sources. This is then subject to UV, carbon filtration and chlorination prior to use. Checks are made to ensure appropriate levels of residual chlorine remain in the supply according to Mexican Standards NOM-230-SSA1-2002, NOM-045-SSA2-2005 and NOM-127-SSA1-1994. Additional water supply is provided from bottled sources. Bi-annual checks on the water system for legionella are conducted in accordance with Mexican Norm NOM-127-SSA1-1994; monthly checks for fungus and molds are conducted.
The identification, assessment and management of community health, safety and security issues, including L&FS, commensurate to the risks and impacts to be found at the new hospital and managed to the same standards observed at the downtown hospital will be required. The establishment of such systems and the provision of personnel and budgets to do so are addressed in the accompanying E&S action plan.
