Description of the key issues and mitigation measures are described in the paragraphs below. Furthermore, Medlife has agreed to implement an Environmental and Social Action Plan (ESAP) which is enclosed with this report.
PS1: Social and Environmental Assessment and Management Systems
Management Systems and Assessment: MedLife hospitals and hyperclinics operate under management systems established and certified in accordance with the international standards of ISO 9001:2008, ISO 14001:2005 and ISO 18001:2007. The medical laboratories are accredited to the international standard of ISO 17025:2005 which is specific about competence of calibration and testing laboratories and to the ISO 15189:2007 which describes medical laboratories norms. The accreditation will be extended to all new hospitals, clinics and laboratories. Medlife is also targeting the accreditation of its health care services under the standards set by Joint Commission International which is an assessment and certification body accredited by International Society for Quality in Health Care and recognized by World Health Organization (WHO). Medlife hospitals, clinics and laboratories are subject to regular inspections by the Ministry of Health of Romania to ensure on-going compliance with applicable local regulations.
Development stages of new hospitals and clinics, including planning and design, construction and start-up are subject to assessment and approval by regulatory authorities according to national regulations which refer to internationally agreed standards, particularly to EU regulations and norms. Construction safety, life and fire safety, water supply, wastewater discharge, handling and disposal of wastes, including medical, require permits and licenses. Medlife will provide IFC with the copies of the third party assessment documents and licenses for its facilities and relevant action plans to remain in compliance.
Medlife will conduct social and environmental due diligence to ensure compliance to the applicable IFC’s performance standards, for all new projects, acquisitions and changes. On-going operations will be regularly reviewed.
Medlife has achieved significant progress in various areas with regard to the Environmental and Social Action Plan agreed for the previous IFC investment. Hence, waste management practices have been further improved; heating-ventilation-air conditioning equipments have been upgraded, energy efficient systems have been installed, infection control teams and control mechanisms have been further enhanced. Due to certain organizational changes and hire of new staff, progress on certain action plan items is still going on and will be fulfilled in accordance with the enclosed ESAP.
Organization: Overall environmental, occupational health and safety management systems at Medlife rely on Management Systems Coordinator and detailed responsibilities are delegated at each hospital, clinic and laboratory. Key responsibilities are documented according to the ISO 9001:2000 standard. In accordance with the current operations and on-going expansion, Medlife will ensure that corporate management systems coordinator and delegates at the facilities are kept informed about the IFC’s Performance Standards which will be maintained incorporated into the management systems documentation. Medlife will assign delegates for the coordination and implementation of the management systems at the new hospitals as well.
Training: Training provisions for staff are organized and tracked by the Human Resources Department of Medlife. All staff receive induction training at hire and regular refresher trainings. Trainings include, but are not limited to: management systems, service excellence, occupational health and safety, risk assessment and control, infection control, emergency management and response, and environmental management.
Monitoring: Quality and EHS (Environment, Health and Safety) monitoring programs at hospitals, clinics and laboratories are set in line with the regulatory requirement as well as in accordance with ISO 9001, ISO 17025, ISO 14001 and OHSAS 18001 management system requirements. Medlife will submit to IFC an Annual Monitoring Report on Environmental and Social Performance prepared in accordance with the IFC’s Performance Standards and WBG’s EHS guidelines.
PS2: Labor and Working Conditions
Labor Relations: Medlife has an internal human resources procedure, in line with the local regulations, which describes the following: employee qualification, hiring and contract making processes, promotions and general working conditions. The minimum age of employment is 18. Cleaning and security services are outsourced at the clinics. Catering and laundry services are outsourced at the hospitals. The Company reported that there is no discrimination on the basis of personal beliefs or characteristics, Medlife does not employ child or forced labor, and does not anticipate any retrenchment in the near future as reported by the management; in fact, Medlife is currently in a growth phase. The management stated that it does not prohibit or discourage union membership; nevertheless, there is actually no union activity or collective agreement in the hospitals; employees work through individual contracts. Employees can address grievances directly to their hierarchy or to the Human Resources Department. There is a formal grievance procedure describing how to communicate and address the grievances. Medlife will regularly review and maintain its Human Resources policy and procedures for its own staff and contractors to ensure that all IFC Performance Standard 2 requirements are formalized within the policy and procedures.
Occupational Health and Safety: As mentioned previously, Medlife has established an occupational health and safety management system in its hospitals and clinics certified in line with the international standard of OHSAS 18001. Workplace risks are regularly assessed and mitigation measures implemented within an action plan. Medlife has recently installed an MRI (Magnetic Resonance Imaging) for enhanced means of examination in its Memorial Hospital in Grivita with adequate safety provisions, including a Faraday cage that prevents the escape of electromagnetic field. Biosafety is the key program in the laboratory operations. Infection control and emergency response committees conduct regular meetings, trainings and drills. All staff, including medical and non-medical, receives adequate training in accordance with the specific risks of their workplaces. No major accident occurred in any of the facilities for the last five years as reported by Medlife in its AMRs. Medlife reported that personnel are subject to the medical checks in accordance with the Romanian labor legislation both upon employment and periodically, depending on the characteristics of the activity carried out.
Medlife will ensure that control of occupational health and safety control programs are enhanced at the construction and renovation works. Medlife will set up and maintain relevant occupational health and safety manuals and thoroughly include in all contractor agreements the rules on occupational health and safety and other working conditions, in accordance with the IFC PS2 requirements, will ensure that trainings are provided to the construction/renovation employees and will establish regular inspection mechanisms to ensure that rules are effectively implemented.
PS3: Pollution Prevention and Abatement
Hazardous Materials and Waste Management: Laboratory chemicals, cleaning and disinfection materials and other hazardous substances used in the hospitals and clinics are supplied from reliable, certified sources. Environmentally safe materials are selected, wherever possible. Extremely toxic formaldehyde is not used in any hospital or clinic for disinfection purposes. New cooling systems at hospitals and clinics include HFC refrigerants such as R-407a and R-410a without ozone depleting potential. Medlife will continue these efforts and will maintain a hazardous materials inventory at the workplaces.
Infectious waste, wastewater from radiology units and other hazardous wastes from laboratories are segregated at sources, collected in labeled containers, appropriately stored on-site, then transported and disposed of by licensed contractors. Medical waste is handled by authorized agencies and incinerated at government approved facilities. Medlife has plans to establish an on-site medical waste treatment system based on decontamination of infectious waste using microwave action, which will be operated by a licensed contractor company. The system is developed in Austria and is designed to disinfect various kinds of infectious waste, including fatty (ointments, pastes etc.) and albuminous substances (blood, pus, serum, etc.) in containers, used dialyzer, tubing, syringes, needles, blood bags, plastic disposals, catheters, metallic parts, etc. On the other hand, as this system cannot treat cytotoxic, radioactive waste, hazardous chemicals, body parts and large metal items, Medlife will continue to use a combination of different treatment and disposal means in accordance with the type of the wastes generated.
Medlife will further develop hazardous materials and waste minimization programs. For instance, it will be limiting the consumption of x-ray chemicals by moving imaging diagnostics into digital solutions in the future. There are no other sources of radioactive wastes or effluents as Medlife does not actually provide nuclear therapy. In case future operations include such treatments, Medlife will make appropriate handling and disposal of relevant wastes and effluents.
Other Wastes and Effluents Management: Domestic wastewater is discharged to the municipal sewer system without any specific requirement for pre-treatment. There is only a decantation tank and wastewater discharged to the city sewerage is regularly monitored by certified agencies and reports submitted to the regulatory authorities. Non-hazardous waste is collected and disposed of by the municipality. Medlife has developed its waste management program towards waste minimization, collecting recyclable wastes separately, wherever feasible.
Resource Conservation and Energy Efficiency: Water is supplied from the municipal networks and electricity from the city grids. Natural gas run boilers are the main sources for ambient heating and vapor generation. The hospitals are equipped with diesel run back-up generators. Medlife has installations to optimize water consumption and has introduced energy conservation programs. New pediatric and orthopedic hospitals are being equipped with VRF (Variable Refrigerant Flow) systems which are known to be highly energy efficient. Medlife will continue to develop water and energy conservation programs and annually report to IFC about relevant initiatives and performance
PS4: Community Health, Safety and Security
Community Health and Safety: Hospitals, clinics and laboratories of Medlife are equipped with the latest generation medical and laboratory equipment. Strong mechanisms for maintenance of medical and analytical equipment are in place. Utilities and safety equipment also are subject to regular maintenance programs and these will be further developed. Infection control techniques are established and tracked by two medical doctors specialized in this area.
As reported by Medlife, life and fire safety design and installations are being provided in line with the national standards and regulations which are being adapted to the EU norms and regulations. Fire sprinklers, detection and alarm systems, other fire fighting and emergency provisions are present in the Medlife Memorial hospital. New hospitals under development in Bucharest are being equipped with fire safety design and installations in line with the latest local regulations. Provision of adequate emergency exits and ventilation systems will be completed in the new medical laboratory in Bucharest. Other facilities are designed to have adequate provisions on life and fire safety. Construction is either undertaken by Medlife or partly outsourced to experienced construction companies. Medlife management reported that project designs and constructions take into account seismic risks. Bucharest is in high seismic zone. Medlife management reported that acquired buildings for conversion into health care facilities are consolidated to address seismic risks. All construction works are supervised by a certificated engineer commissioned by Medlife.
Medlife will provide IFC with third party verification documents on life and fire safety, earthquake safety and infection control for each clinic and hospital which is operational and under construction and relevant measures to remain in compliance with national and internationally agreed standards. Further detailed review of the existing facilities as well as of expansion projects will be performed by qualified experts as defined in the action plan agreed with IFC.
Water for consumption is supplied from municipal network and treated further at on-site facilities through a combination of reverse osmosis, ion exchangers, chemical and UV-disinfection systems. Strict procedures are established on water quality monitoring with regard to ISO 9000 management systems and infection control mechanisms. There is no cafeteria within the hospital and clinics premises, catering services are outsourced to an approved contractor which is regularly inspected as reported by the Medlife management.
Security: Unarmed and trained security personnel are employed through private contractors, in accordance with the IFC PS4 requirements.
