PS1 Environmental Assessment and Management
Environmental and Social Assessment:
There may be a national requirement for the University to complete an environmental and social impact assessment (ESIA) for their expansion plans depending on the scale and complexity of the development. The University will also be required to get various permits and licenses for the development/facilities from the Municipality, including environment, water and sewerage, and civil protection, among others. However at the moment, UAG has no formal (written) environmental and social assessment process in place to assess the impacts or risks of its operations.
Management Program:
Certain parts of the UAG group do have some level of formal [Environmental and Social] management system (ESMS), for example, the two Business Incubators, CIDI and CITSIA have national certification and the hospitals, Hospital Dr. Angel Leaño (HAL) and Hospital Ramon Garibay, have medical procedures and protocols in place. The hospitals do not explicitly follow the Joint Commission International Accreditation (JCIA) (which is a division of the American-based Joint Commission on Accreditation of Healthcare Organization (JCAHO), the largest accreditor of healthcare organization in the USA and internationally), but rather the new Mexican Health Care Regulations. The Hospital’s Administration is going through the new national regulations and will be working with the Commission to certify their health care facilities which will be aligned with JICA. The Security and Patrimonial Intelligence Department is in charge of Security, Life and Fire Safety (L&FS), Emergency Response and Training. This department is currently undertaking a risk assessment of all of the UAG facilities with regard to L&FS and is completing a plan to retrofit and upgrade equipment and other aspects of emergency planning (for fire, seismic or other events) where necessary. However, there is no corporate wide ESMS in place to manage and mitigate environmental and social issues. Such an approach is warranted, given the size, geographical spread and complexity of UAG’s education and health facilities.
Organisation:
For many years, UAG was a traditional founders approached business, with a small close knit management team made up of primarily founders and ex-alumni members. Recently UAG has begun to restructure and strengthen its management team. As part of this management team, a new Chief Operating Officer, a Chief Commercial Officer and Chief Administrative and Financial Officer were hired, and under their responsibilities, are Operation, Finances, Marketing, Treasury, Information and Health and Safety, which are directly related to the Management of EHS issues. These units are staffed with qualified personal that will be able to contribute to the design of the ESMS.
Training:
UAG’s Security and Patrimonial Intelligence Department is responsible for and implements the necessary training for Life and Fire Safety (L&FS). This includes training on equipment and drills for fires and seismic events, both for their own facilities, as well as in preparation to help during a national or even international natural disaster, in association with the UAG Medicine in the Community Program (Please see section on Community Engagement below), as they have done in the past.
Community Engagement:
UAG has very little interaction with the community on purely environmental and social issues. However, the nature of the services UAG offers, that of Health and Education, implicitly involves many segments of the community, such as employees, students, parents, and patients. Many of the faculties are directly involved with serving the community such as the Medicine in the Community Program associated with the Medical School and other faculties (Please see section on Community Engagement below), the Renewable Energy Center and the Incubators among others, provide a solid University-Society link.
Monitoring and Reporting:
UAG do monitor and report to relevant national and local authorities certain environmental indicators regarding water and waste water, social statistics such as labor and civil protection, but there is no concise method to manage these results and evaluate them over time.
Action:
UAG will appoint a suitably qualified person to lead the development, integration, implementation, and maintenance of an Environmental and Social Management System (ESMS). The system will be implemented in all UAG’s operations and will encompass environment, social, occupational health and safety, human resources, and corporate affairs management. The first step will be to identify and document the environmental and social impacts of all of UAG’s operations. The ESMS will require compliance with Mexican and local regulations, IFC Performance Standards and WBG EHS Guidelines as referenced above. The ESMS will include a formal system for monitoring, and reporting social and environmental issues to UAG’s senior management team and to the IFC in the form of an Annual Monitoring Report (AMR).
The ESMS should be in place as the University completes its plans for expansion so social and environmental criteria (for example, Life and Fire Safety (L&FS), contractor Occupational Health and Safety (OHS) compliance, water use, efficiency and waste water discharge) can be assessed and managed moving forward. The expansion plans will consider, to the extent possible, the need to improve the existing approach to water and waste water treatment (WWT), by assessing water needs and integrating WWT Plants into facilities. The ESMS will also establish an employee training program covering environmental and social issues based on the responsibilities and impacts of the employee’s activities and it will include training for the employees responsible for the L&FS, community engagement and grievance mechanisms, particularly during construction.
PS2 Labor and Working Conditions
Human Resources Policy and Management:
UAG has a Human Resources (HR) Department with an HR Director and Managers at various levels throughout the organization. They have a basic formal HR policy which includes: recruiting, compensation, benefits and working conditions (such as leave, overtime, payroll), discipline and termination. The HR Department is evolving to be “more than just payroll” and the HR Policy should expand to include all the requirements as outlined in PS2.
UAG has a total of approximately 2,700 full time employees and 1,400 part time employees in their various educational and medical facilities. However at the main UAG campus 65% of their teaching staff are part time and 35% are full time. Employment could expect to increase over time during the expansion of their facilities, although the majority will be part time staff.
The turnover rates are generally very low for professional staff and slightly higher for cleaning and security staff, the average tenure of a worker is more than 12 years of employment. All employees are paid their various benefits as per Mexican laws through the Mexican Social Security Institute (IMSS) which provides to every employee medical, disability, pensions (based on the salary, 60 years of age (minimum age of retirement) and 30 years of working), and a housing loan scheme called INFONAVIT. Employees and their dependents can take advantage of scholarships that are offered at the various education facilities for graduate, post graduate or language studies. There are daycares and various other benefits such as glasses, mechanics, mobile phones, clothing discounts and the university will give loans to employees at a better rate than banks. Some services are contracted out, such as hospital and clinic cleaning, landscaping, waste collection and maintenance (physical plant) services.
Workers Organisations:
Many of UAG’s employees are white collar professionals such as administrators, professors, teachers, clerical staff and office workers. All employees below a certain level of management (Principals and Deans) are members of a union, which they join once they are hired. The unions are associated with the main national unions, known as the “Sindicato de Trabajadores Academicos y Adminstrativos de la Universidad Autonoma de Guadalajara.” These unions have negotiated certain benefits regarding working conditions with UAG and could have further collective bargaining agreements in the future. In addition there are several clubs similar to worker associations including one for women executives, secretaries and employees which generally organize social activities.
UAG does not have a formal documented grievance procedure to receive and log complaints from employees and systematically address them. There is an open door policy with managers to discuss issues and resolve conflicts. There is an email/suggestion box (both electronic and on campuses), where people can register a complaint anonymously and confidentially by posting a form. There has been an information campaign to inform staff of this system. There is a committee made up of various levels of staff which determines priorities or actions needed to solve issues as they arise.
Non-Discrimination and Equal Opportunity:
UAG has a code of conduct and an ethics code, which includes references to non discrimination and equal opportunities, in their General Regulations which students and Faculty of the university and other facilities are expected to follow.
Retrenchment:
The University educational system has no expectation of retrenchment, in fact it is more likely to be hiring due to the renovation and expansion plans.
Protecting the Workforce:
Mexican law has very specific provisions for under age workers. The basic minimum age for workers in Mexico is 18 years of age. There is no employment of any minors under the age of 16 without parental permission. Currently there are 7 young people employed between the ages of 16-18, and in all cases UAG has the permission of the parents for these young workers. They are either training as secretaries, classroom aids or support functions and are the sons/daughters of existing UAG employees. UAG has a Healthy Workers Program to promote compliance with ILO and National Labor Standards. Reports are prepared for the Ministry of Labor and Statistics on all statistics from all UAG’s facilities on injuries, an analysis of root cause and the implementation of prevention programs. From 2003-2006 UAG carried out a study to detect the various risks factors for each job description, carried out a diagnostic to anticipate changes needed in implementation, and then undertook corrective actions as needed.
Occupational Health and Safety:
Regarding occupational health and safety, the UAG hospital and medical schools have medical procedures which include various medical protocols concerning for example the handling of blood products, hazardous materials and waste disposal within the clinics and all staff/students are adequately trained on these protocols. All students and teachers working in labs are provided with appropriate PPE.
Actions:
The University will revise its current HR policy to confirm that it covers all matters to which PS2 refers, including issued related to non discrimination, equal opportunity, sexual harassment (which could be part of a Code of Ethics for example), freedom of association and collective bargaining, training and induction, performance evaluation, and professional development.
The University will prepare a policy summary which will be available for all employees at all UAG facilities. UAG will formally develop and implement an employee grievance mechanism and continue to communicate it to all employees. Also, the University will ensure that PS2 requirements for contractors, particularly regarding OHS (provision of PPE and safe working conditions during employment, renovation and construction of new facilities) and the minimum age of the contractor’s workforce, are included in all future contracts.
PS3 Pollution Prevention and Abatement
Pollution Prevention, Resource Conservation, Energy Efficiency:
UAG has had a Centre for Renewable Energy (RE) since 2007 and offers a MSc. in RE and promotes sustainable energy in the state and metropolitan area as well as outreach to the community on issues of concern such as water which is becoming increasingly scarce. In addition UAG are researching the effects of climate change, bio fuels and ecotourism and carrying out research projects in the local area on such themes. UAG is currently evaluating its main campus buildings and assessing how these can be adapted to be more resource efficient. Measures under evaluation include applying a coating on windows to reduce heating and cooling loads, water free urinals, low flush/dual flush toilets and automatic taps, etc.
Water and Waste Water:
At present almost all of the UAG facilities are connected to the municipal sewage collection and treatment systems and usually do not have effluent pre treatment. However, the clinical analysis laboratory of the Chemistry department and the Center for Research and Industrial Development (CIDI), both send water to special containers where the water is treated to reduce biological hazard or neutralize chemicals. In addition, the cafeteria waste water has grease traps to avoid edible oils going into the municipal sewage system.
The only exception to the use of the municipal sewage system occurs at the School of Medicine in Tesistan, where the development of the facility preceded the urban development for more than twenty years. The School of Medicine is located in one of the most topographic challenging zones surrounded by many cliffs and hills that made it impossible to connect with the municipal sewage system. Hence, the effluent is released to the cliffs according to the Mexican regulation of effluents released to surface grounds. Every year, UAG have the effluent analyzed by a third party (e.g., analytical lab) and their results are sent to the proper authorities. The results show a high level of oil and grease in the effluent so UAG will add grease traps to the cafeteria facilities at HAL, as well as other buildings as necessary to meet IFC requirements.
UAG is planning to build small waste water treatment plants for all major buildings (i.e., building population more than 100 people) in various facilities, in particular the UAG main campus, the Biological Sciences Institute (that hosts the first two years of the medical school), Santa Anita Campus (kindergarten to high school programs), and the clinic area in Tesistan (which has the last 2 years of the School of Medicine and the University Hospital, HAL), with the objective to achieve grey water standards that allow reuse of treated water for irrigation of gardens and sports fields. Planning for these new sewage systems has begun and will include a method to separate rainwater from potable water which will be used for irrigation.
State and county official now require new housing and commercial developments to include WWTPs and which UAG will be required to do on any new developments. County official have also required that all new construction needs to separate rain water from effluents so this water may be sent to shallow wells for more than 15 years to help restore the aquifers, which the city and UAG rely on for their water supply.
Solid and Hazardous Waste :
Solid waste is collected several times a week by a private company, Recolectora Industrial de Occidente, which separates all the wastes and sends the organic waste to the municipal landfills. The University is looking at how they might compost the vast amount of organic waste they collect (leaves, grass cuttings, cafeteria, etc) and use it in landscaping. The hospitals, clinics and medical school’s medical waste is collected and stored in red collection containers and collected in one central storage area on the hospital grounds or in the clinics in a secure site. The medical waste is collected weekly or more frequently by waste collection company (Sterimed Inc. is the UAG main provider and it offers an environmental affidavit of their collection process) and incinerated at its facility. CIDI labs are serviced by Manejo y Acopio de Residuos Peligrosos, which collects and disposes of chemical residues or expired substances, in steel drums with wood debris and disposed according to Mexican environmental regulations.
Action:
The client has agreed to continue to address their waste minimization, water efficiency, waste water treatment and energy efficiency strategies going forward and will comply with new regulations introduced by Mexican authorities and with WBG Guidelines on waste water treatment and water use. For energy efficiency and resource use, this might include benchmarking similar buildings against each other, and looking at trends. As part of the ESMS, energy, water and waste management plans will be developed and implemented to manage resource use to maximize efficiency and conservation, and minimize waste.
PS4 Community Health and Safety
Emergency Preparedness and Response:
The Physical Plant Manager is responsible for Life and Fire Safety (L&FS) and works closely with Security Department to implement changes to their systems and procedures. UAG has a procedural manual for Emergency Response and Planning referred to as the “Red Note Book”. In addition, UAG is part of a Safe Colleges Program. Each campus has its own L&FS Plan. This is to meet the requirements of National Law, that all offices and public buildings are required to have a site specific Civil Protection Plan (CCP). These plans are specific to each municipality but are based on the federal legislation of the National Labor Secretariat and Social Protection. Facilities can be inspected periodically by the Civil Protection Unit of the local Government and once inspected the facility receives accreditation. These plans include the responsibilities for the prevention of emergencies, training for first aid, seismic events and firefighting (e.g. the use of fire extinguishers) and the presence of evacuation brigades. The CCP must include evacuation drills, marked meeting points, locations of fire extinguishers, evacuation routes and emergency exits. Compliance with the program requires annual training of the brigades (i.e., formed by facility employees) in first aid and fire extinguisher operation. UAG has hired a fire safety professional who has prepared a risk analysis of the existing buildings and working on updating all of the Civil Protections Plans. This is a process which is on-going throughout the campus. There is a training program which focuses on fire protection, search and rescue, first aid and evacuation. Currently there are 267 people trained for the Fire Brigades on the main campus.
Grievance Mechanisms:
UAG does have some corporate social responsibility initiatives as well as the Medicine in the Community Program discussed in the section below, but it does not at this time have a community grievance mechanism to deal with for example construction impacts on local neighbourhoods that might arise in the future.
Security:
UAG have a Security Department which consists of various security teams of guards (unarmed) that move throughout the campus and other facilities, 24/7. There is also a Canine Squad. All guards are trained in human rights and the legal framework as it relates to their work.
Action:
UAG will commission a suitably qualified professional to prepare Life and Fire Safety (LFS) Master Plans, for all new buildings or buildings subject to major renovations or expansions. These plans shall identify how the buildings shall be designed and constructed or modified in such a manner that life and fire safety standards meet all applicable local and national Mexican requirements and an internationally recognized life safety code. Further detail on the content of the LFS Master Plans is available in the WBG EHS General Guidelines.
In addition, a suitably qualified and experienced professional acceptable to IFC will prepare a Life and Fire Safety (L&FS) Audit, based on a recognized international fire safety standard (in addition to Mexican regulations), of an agreed upon sample of the most at risk existing facilities (such as any multi storey buildings (more than 3 storey), hotels and football stadium). Once the Audit is completed a Corrective Action Plan (CAP) will be prepared and agreed with IFC and implemented to a specific timetable as agreed. Prior to disbursement, the three most at risk properties will be Audited and the CAPs reviewed and agreed with IFC. Additional properties identified will be Audited and the CAPs reviewed and agreed with IFC within a year of disbursement.
The ESMS procedure will include conducting fire drills, training and the quality control of fire fighting equipment which will be reported to IFC annually in the Annual Monitoring Report.
The University will develop a community grievance mechanism where applicable and integrate it into their ESMS.
