Fundacion Cardiovascular de Colombia (FCV) has described how the proposed project will comply with Colombian environmental and social requirements as well as IFC’s Environmental and Social Performance Standards and World Bank Group (WBG) environmental, health and safety (EHS) guidelines, through expansion of existing management practices and implementation of agreed additional measures summarized in the attached Environmental and Social Action Plan (ESAP). The following paragraphs describe how these potential impacts are or will be addressed by FCV.
Social and Environmental Assessment and Management System
Environmental and Social Assessment: Fundación Cardiovascular de Colombia (FCV) have four contiguous parcels of land constituting in total approximately 16 hectares (ha), of which 1.3 ha will be used to build the Hospital Internacional de Colombia. The land is located in a formerly rural area which has been reclassified by the local authorities as an urban setting. The company has obtaining from the local authorities the “Plan Parcial,” this document authorizes the use of the land for commercial, residential and medical purposes and it is a requisite to obtain urbanism and construction licensees needed for the project.
No environmental impact study was required by local authorities; however the company is preparing an “environmental management plan” which will be submitted to IFC and will be implemented during the construction and operation of the project. Potentially significant impacts during construction and operation of the project will be identified in the environmental management plan and include but are not limited to removal of vegetation and soil, excavation with its consequent dust and noise generation, OHS and labor risks during construction and issues such as waste generation, effluent management and life and fire safety controls during operation. All required permits for construction and operation have been identified including (i) the authorization for sustainable forest use (aprovechamiento forestal) for the removal of the existing fruit trees, (ii) construction permit, (iii) urbanization permit and (iv) permit for direct discharges to a body of water among others; all of them will be submitted to IFC once available.
Environmental and Social Management System: FCV has a structured approach to its management of quality and environmental and occupational health and safety (OHS) practices in its existing hospitals. The Instituto del Corazon in Floridablanca has a quality assurance management system certified compliant with ISO 9001 and it is accredited by the Joint Commission International (JCI), a program that focuses on patient safety.
Similar practices will be adopted in the Hospital Internacional de Colombia, where the company will implement a systematic social, environmental and occupational health and Safety (OHS) management system to environmental, social and occupational health and safety issues in the new hospital. The Hospital Internacional de Colombia will implement a management system to ensure adequate management of its impacts during the operation of the new hospital. The company will later extend this approach to all its facilities.
Organizational Capacity: Environmental and social aspects of the existing operations are managed under the corporate development unit (Relaciones Industriales) with dedicated teams to Human Resources and Occupational Health and Safety. Environmental issues are managed by the hospitals’ operations team and an environmental committee which ensure proper management of sanitary/hospital waste and rational use of resources such as electricity and water among others. For the proposed project the company has hired the services of an external consulting firm to perform the preliminary studies and to guide the project team on environmental and social issues. FCV will appoint a corporate environmental and social (E&S) professional with managerial responsibilities for environmental and social issues throughout the company (existing and new hospitals).
Training: All FCV personnel undergoes an induction program and on the job training. The training program covers, among other things, management of hazardous waste, management of emergencies, biological risks and safety aspects of the assigned job.
Training of professionals is a core element of FCV’s vision; therefore, FCV founded the “Universidad Corporativa” in 2010. Its main objective is to promote talent within the organization and to form and attract new personnel. The Universidad Corporativa has agreements with international hospitals and universities to provide training to qualified employees; in addition, it offers practical training (developing the needed skills and abilities) to future professionals in diverse areas of medical care.
Monitoring and Reporting: FCV monitors various social and environmental indicators covering labor conditions, occupational health and safety performance, utilities use, and waste generation. The company reports on environmental performance through the green hospital initiative, which described in the pollution prevention section of this ESRS. A consolidated report was not available to IFC’s appraisal team, but the company is planning to organize the information according to the outline of the Global Reporting Initiative (GRI). The environmental management plan for the new project will define a set of environmental and social indicators the company will monitor and report to senior management. As part of its management system, FCV will implement a procedure for monitoring and periodic reporting to senior management environmental and social elements identified to have potentially significant impacts during construction and operation of the project.
Labor and working conditions
Currently FCV has1406 employees nationwide, of those 768 are employed in the Instituto del Corazon in Floridablanca. The FCV has reduced significantly the number of employees contracted through third party companies and most of its workforce is currently hired directly by FCV. Services such as housekeeping, laundry and security are outsourced. The project is expected to create almost 400 of jobs during construction and around 1500 new jobs during the operation of the new hospital. This hospital will not replace the existing hospital in Floridablanca.
Human Resources Policy and Management: FCV has a well defined Human Resources Policy articulated through the internal employment rules and the ethics code; the documents are consistent with the Colombian Labor Code and IFC’s Performance Standard 2. In addition the company has well defined procedures for hiring, induction process, disciplinary mechanisms, training, access to benefits and career development. FCV has an internal grievance mechanism which is managed by the human resources department.
Working relationship, conditions, and terms of employment: Working conditions are communicated to all employees through the working contracts, employment rules and regulations (reglamento interno de trabajo), the ethics code, policy manual and internal procedures. Elements covered include probation period; working hours (including overtime and flexible work schedules); employee labor rights and benefits; salary; social security contribution; occupational safety and health; disciplinary policies; and internal grievance mechanism and conflict resolution. The company has explicit statements regarding equal opportunity and non-discrimination for commercial transactions and these are also applied for employees. The company may recruit employees below the age of 18 years, but never younger than 17 years old; in which case FCV follows Colombian legislation regarding hours of work, duties (usually training contracts) and obtaining parental consent.
Workers Organizations: FCV employees do not belong to workers organizations or unions, and there has been no such request among the employees. The management team of FCV confirmed that they would not prevent employees to organize or participate in workers’ organizations.
Current Human Resources policies and procedures will be implemented in operations of the new project. FCV will implement mechanisms to ensure that contractors performing construction activities for the project are in compliance with local legislation and IFC requirements regarding Performance Standard 2, in particular regarding working conditions and terms of employment and compliance with Occupational Health and Safety obligations according to local law.
Occupational Health & Safety (OHS): FCV has developed an OHS program consistent with the requirements of the Colombian legislation and best practices for health care facilities. There is a Joint Committee on Occupational Health (COPASO - Comité Paritario de Salud Ocupacional) which considers employees’ views and needs by identifying and correcting potential OHS hazards and guiding the direction of the OHS program. The OHS program covers among others biological hazard safety, practices for handling hazardous drugs, radiation protection, preventive medicine, ergonomics, workplace monitoring and medical examination of employees. The program is well documented, considering for example international practices (aligned with JCI accreditation program) and its effective implementation was observed during the appraisal visit. There is an extensive employee training program in place. Accident statistics are collected and analyzed, including incidents not causing lost work time. The new hospital will implement and operate under an occupational health and safety management system to manage all the identified risks, including but not limited to radiation safety, biological hazard safety, chemical safety and ergonomics and musculoskeletal disorders.
FCV will implement mechanisms to ensure that contractors performing construction activities for the project maintain health and safety plans, train and provide their employees necessary safety protection, follow OHS procedures and overall comply with their OHS obligations according to local law.
During the design, installation, acceptance testing, and operations of all the radiology and oncology facilities FCV will ensure the guidance and verification of a qualified expert and the local authorities (Ingeominas and Secretaria de Salud) clearance. FCV will retain a radiation protection scientific/technical expert, satisfactory to IFC, to supervise the construction of the radiology facilities and to carry out post construction inspections to verify that the facilities were constructed as designed. The protective measures installed should focus on keeping occupational doses and public doses As Low As Reasonably Achievable (ALARA) which aims at radiation safety and avoidance of all unnecessary exposure. Existing radiology facilities managed by FCV has the approval of the local authorities and the company has in place a full monitoring program for ionizing radiation.
Pollution Prevention and Abatement
Resource Conservation and Energy Efficiency: FCV participates in the local initiative “Hospital Verde” (green hospital), which is a continual improvement initiative based on internal programs for management of resources (water, energy, materials), wastes and chemical products. FCV monitors and controls the current use of utilities in the existing operations. The company has demonstrated a consistent reduction of the use of water and electricity throughout the years. Current level of water usage is 0.15 m3/bed/day and for electricity is 35kWh/bed, significant lower than industry benchmarks (e.g. USAID Eco III-project report: Energy Efficiency in Hospitals Best Practice Guide). The new hospital is being designed with a series of measures to increase the efficiency in the use of water and energy, including installation of high efficiency chillers running in parallel for the HVAC (Heating, Ventilation, and Air Conditioning) system; use of variable-speed sanitary and chilled water pumps, variable speed fans in the HVAC system; use of timers and electronic thermostats to control temperature in unoccupied spaces, use of energy saving light fixtures and motion sensors in common use areas; re-use of gray waters from non contaminated areas of the hospital; and installation of flow regulators and flush management devices for sanitary facilities. The Company will continue to monitor and benchmark annual consumption and costs of energy and water used. Water and electricity will be provided by the municipality and FCV will maintain backup systems.
Liquid effluent management: FCV will manage three effluents streams: (i) gray waters: to be treated and re-used for irrigation purposes; (ii) effluents from sanitary services and basic operations: which will be treated using aerobic and biological treatment with nutrient reduction; and (iii) water with elevated biological or potentially toxic load: to be disposed through external incineration or specialized companies, fully authorized by the local government and audited by FCV. The treated water will be discharged to the Mensuli creek, as authorized by local authorities given that currently the area where the project will be developed is not connected to public sewage. FCV has contracted the design for the wastewater treatment plant (WWTP) to comply with local and IFC requirements for the discharge. FCV will submit to IFC the design for the WWTP and once in operation it will provide confirmation of compliance with local and IFC requirements.
Air emissions: Electric power for the hospital will be provided primarily by the grid; however FCV is planning supplement grid power by a gas-fired co-generation system, of approximately 6 MVA capacity. FCV will review and consider local and IFC requirements for air emissions during the selection of the technology to be used. In addition FCV will have emergency power generation systems (diesel operated) to supply critical hospital equipment and areas. The diesel –fired generators are not expected to operate more than 100 hours/year. FCV is planning to perform annual monitoring of the emissions and will provide reports to IFC.
Solid Waste Management: FCV current practices include internal segregation of the different types of wastes. All biological, infectious and hazardous health care waste is collected and stored temporarily for daily pickup, treatment and disposal by an approved and licensed service company. FCV performs periodic audits and supervision visits to the service company to follow up on proper handling and disposal of the materials. Non hazardous waste is separated into recyclable and non-recyclable streams. The recyclable portion is collected, stored and provided to local recycling companies. The non-recyclable waste is disposed via municipal waste collection services. Management of hazardous and non-hazardous wastes in the new project will follow the procedures defined in the solid waste management program (Plan de Gestion Integral de Residuos – PGIR). Materials from the radiology department, including radiation dosimeter badges of the employees and materials used for radiology test are disposed through authorized vendors once the radiation levels are below 5 μSv/h. During construction the company will follow and enforce the procedures defined in the environmental management plan to be developed by FCV.
Hazardous Materials: The hazardous materials consist of small volumes of laboratory reagents, chemicals, preservers, solvents and cleaners. Hazardous materials are handled in accordance with acceptable practices. Radioactive material used in the radiology labs are controlled through internal procedures and only approved personnel (who has been trained) access and manipulate the materials. HVAC system in the new facility will use refrigerants R134a and R410a both are zero ozone depletion potential (ODP) refrigerants.
Greenhouse Gas Emissions: Greenhouse emissions of the operations are associated with electricity consumption, the use of fuel for co-generation, potential refrigerant losses from the HVAC system, and modest use of one ambulance. The annual greenhouse gas emissions during the operational stage of the project have been estimated at around 5,600 tons of CO2 equivalent.
Community health, safety and security
Community Health, Safety and Security: FCV has considered compliance with Colombian seismic codes and fire protection codes for the design of the new hospital. Seismic codes considered are the Colombian resolution 4445 from 1996, which addresses seismic requirements for hospitals and the Colombian seismic code (Reglamento Colombiano de Construcción Sismo Resistente NSR 10) which was updated in 2010. The requirements of life and fire safety are aligned with local legislation and the requirements of the Joint Commission International (JCI). In order to confirm compliance with IFC requirements, FCV will engage professional services of a qualified Life and Fire Safety Engineer acceptable to IFC to prepare a Master Plan (engineering design) and post construction inspections to verify that the system was installed as designed. Life and fire safety design and operation shall be responsive to one internationally recognized life safety code, and the Colombian life safety code. The design shall comply with the Life and fire Safety requirements of the WBG General EHS Guideline. FCV will also review compliance with the local and an internationally-recognized life and safety codes and implement corrective measures for the existing hospitals.
The new hospital is being designed to provide universal access and to facilitate the mobilization of patients.
The Hospital Internacional de Colombia will have a large area for radiology. The company has considered the requirements of the local authorities (Ingeominas and Secretaria de Salud) for the design of the facilities. The company will engage a professional to verify compliance with radiation protection measures as described under the OHS section of this document.
Current practices are aligned with the requirements of the Joint Commission International (JCI) relating patience safety, which includes control of nosocomial infections. This is done through proper engineering and administrative controls such as proper ventilation systems, architectural segregation, decontamination practices, and controls on water, food and waste, among other preventive and corrective measures. The new hospital is being design and will be operated under JCI criteria to manage nocosomial infections.
Emergency Preparedness and Response: The company has in place emergency response plans that include a comprehensive training program for all employees and in particular for the brigade. The emergency plan has considered the identification of potential hazards and the response to emergency situations. The Hospital Internacional de Colombia will implement an emergency response plan and it will include mechanisms to inform affected communities.
Potable Water: Potable water will be provided by the municipality, FCV has determined that the quality is acceptable for general hospital use. FCV will apply the same monitoring program that is applying to the current operations. The planned monitoring plan included continues monitoring for residual chlorine, daily monitoring for biological (E-coli) contamination and at least weekly assessment for other pathogens. FCV will confirm the quality of the potable water, before starting operations, ensuring compliance with WHO standards, in case of non compliance; FCV will install the required treatment facility. FCV will implement a potable water monitoring program for the Hospital Internacional de Colombia.
Security Personnel: FCV contracts an external company that provides security, it includes armed security guards, which is common practice in Colombia. These guards are subject to a rigorous selection and training procedures. FCV only contracts well recognized companies with all the required licenses. In the new development FCV will ensure that the companies contracted to provide security, both during construction and operation, maintain an appropriate conduct towards workers and local community. The grievance mechanism to external parties might be available to the community in case they need to express concerns about the security arrangements.
Cultural heritage and excavation procedures: The area of the project is not expected to have cultural heritage on site; however, the whole province of Santander, where the project is located, is known to have some sites with archeological value. The company has commissioned an external consultant to evaluate any potential finding. In addition, FCV will prepare and implement a Chance Finds procedure. The procedure will be implemented in full compliance with local and IFC’s requirements, the relevant contractors (e.g. those in charge of soil movement) will be instructed on the procedure.
During the land preparation, the company is expected to remove some 350,000 m3 of earth and clear existing vegetation which is mainly grass and fruit trees, in addition to some identified valuable trees; which will be retained or migrated; following instructions from the local environmental agency. The company is preparing and will implement specific environmental plans - as part of the environmental management plan - to manage the vegetation and the removed soil (Remoción de Cobertura Vegetal, Manejo y Disposición de Materiales de Excavación). The preliminary soil studies predicted that the use of explosives will likely not be needed; however, the company is planning to develop a program that involves communications with neighbors in case the use of explosives is required.
