The key social and environmental issues associated with the Project include: adequacy of the social and environmental assessment of the construction and operations phases of the Project; implementation of social, environmental, health and safety management systems; assurance of fair, safe and healthy working conditions during construction and operations; efforts to minimize energy and water consumption; life and fire safety of the laboratories and clinics and management of wastes and emissions - especially the biomedical/hazardous waste disposal.
The Company has presented plans to address the E&S impacts and risks to ensure that the proposed Project will, upon implementation of the specific agreed measures, comply with the E&S requirements including the host country laws and regulations; and IFC’s Performance Standards. The information about how these potential impacts will be addressed by the Company is summarized in the paragraphs that follow.
PS1: Social and Environmental Assessment and Management System
Environmental Assessment and Management Systems:
National and Local regulatory requirements do not require SRL to conduct a formal environmental and social impact assessment study for its operations. However, as a part of permitting process for biomedical waste, fire safety and power back up installation & operation, the Company is required to assess and revise its designs/plans as required, so as to comply with the stipulated requirements– thereby mitigating key environmental and safety related impacts. Accordingly, SRL has standardized design and safety features, which are adopted while designing all new labs.
To ensure consistent service quality and safety standards across its network of diagnostic laboratories and centers, SRL has developed several detailed operational manuals and procedures, that conform to international best practice for the health sector. For instance, Sample Collection Manual documents SOPs for collection and handling of pathological samples. Similarly, Laboratory Safety Manual includes SOPs on tackling infectious spills, management of work related injuries, waste management, emergency response & contingency plan, bioterrorism response plan, X-ray safety policy, fire prevention and control, etc.
Several of the SRL labs have received various diagnostics industry accreditations including College of American Pathologists (CAP), ISO 9001:2008 and India’s National Accreditation Board for Testing and Calibration Laboratories (NABL). The NABL accreditation is benchmarked to ISO 15189:2007, which specifies requirements for quality and competence particular to medical laboratories. The Company undertakes annual internal audits of all its laboratories in accordance with the requirements of ISO 15189:2007. The Company has plans to gradually extend accreditation to all laboratories, though no timeframe has been defined for this yet.
The local regulatory requirements applicable to the Company operations vary across states. To keep track of compliance with permit conditions and regulatory requirements with respect to emissions and biomedical waste handling and disposal, the Company will maintain a legal commitment register for each lab and will develop a process for ongoing monitoring of compliance.
Organization:
At corporate level, Chief Quality Officer has the responsibility of environmental, occupational health and safety management systems and quality control. The Chief Quality Officer has a team of 12 professionals who support the implementation of SOPs across the organization. At individual facility level, Laboratory Heads and management representatives are responsible for these functions. At franchisee laboratories, the Company provides its own doctor, an information technology and finance professional. This allows the Company to monitor the implementation of SOPs and ensures quality control.
Training:
Training on SOPs, occupational health and safety, infection control, emergency management and response, and handling of liquid and solid waste is provided to all staff as part of induction training as well as through regular refresher training.
Monitoring:
Currently, the Company monitors wastewater quality at all laboratories which have their own effluent treatment plants (ETPS) in line with local regulatory requirements. Going forward, SRL will develop an SOP for environment monitoring covering all its reference and network laboratories in line with applicable regulatory and requirements and WBG’s EHS guidelines. This SOP shall define the key parameters (such as air emissions, effluent quality, biomedical waste quantity and fate) to be monitored and the frequency at which these will be monitored.
PS2: Labor and Working Conditions
As in November 2011, SRL has around 4,565 employees all over the country. Of these, 3870 are on company rolls, 314 are consultants and 381 retainers. The consultants work on contract basis, but enjoy all the benefits that are available to the Company employees.
Housekeeping and security services are outsourced. In addition, the Company has a call center employing 21 persons, which is managed by a group Company Religare Technologies Ltd. SRL, as principal employer, confirms compliance of its sub-contractors with the national regulatory requirements.
Human Resource Policy, Management:
SRL has implemented human resources (HR) policies and procedures which are in line with national regulations and IFC PS2 requirements and are documented in HR manual. The HR manual thus articulates terms of employment, SRL’s commitment to non-discrimination and equal opportunity, and includes an employee grievance mechanism. Freedom of Association exists, although there are currently no trade unions. SRL does not employ child or forced labor.
Grievance Mechanism:
SRL’s HR manual articulates the grievance handling procedure. The Company has established an Inquiry Committee comprising of senior management members for grievances redressal. The contact details including phone numbers and email addresses of all the committee members are included in the HR Policy which is available to all employees. Grievances related to salary revision, employment opportunities, promotions, transfers, sexual harassment, employment related, etc. can be raised verbally to HR department or using a dedicated email address for reporting grievances. The HR policy requires that all complaints are handled strictly confidentially.
Occupational Health and Safety:
The Company has developed SOPs to ensure safe and healthy working conditions for its employees. These include SOPs to handle radiation safety, infection control, fire safety and hazardous waste management, which are consistent with national regulatory requirements and international best practices. There are SOPs for spills of hazardous materials such as xylene and formaldehyde, though the risk is minimal as only small quantities are stored at facilities.
Certain individual laboratories of the Company are licensed to use Computed Tomography (CT) and Magnetic Resonance Imaging (MRI) machines. To obtain and retain licenses for these, these laboratories follow government regulations for equipment maintenance, monitoring and radiation protection.
All technicians working in X-ray and radiation laboratories are provided with Personal Monitoring Badges (dosimeters) which are submitted to the regulatory authority every quarter. Those conducting tests for highly infectious diseases such as tuberculosis undergo annual health checks which include chest x-rays and are provided with all necessary personal protective equipment including N95 masks, gloves, goggles, coats and covered cloth shoes.
Needles are kept in puncture resistant containers to avoid injuries and infection to those handling them, and are later disposed of through licensed biomedical waste handling agency. Furthermore, recapping of needles is not permitted as per the SOP. With respect to other sharps such as broken glass and blades, there are specific SOPs on their handling and storage. In addition, all staff members receive immunizations.
All injuries and incidents are recorded and reported to management.
PS3: Pollution Prevention and Abatement
All laboratories and facilities of the Company receive municipal water supply and electricity from the national grid. Backup generators are available at most of the facilities. The Company has confirmed that it has in place all necessary regulatory permits and authorizations for all its laboratories and facilities.
In its effort to conserve resources, as per its corporate policy Company uses recycled paper for printing the diagnostic reports and has also started following the system of e-reporting to minimize the usage of paper.
Solid / Biomedical Waste Management:
The Company has implemented SOPs for segregation, storage and disposal of solid, hazardous and biomedical waste in line with national requirements and international best practices. Accordingly, at each site waste is segregated by category and securely stored before sending to licensed contractors for disposal. The needles are placed in 1% hypochlorite solution for chemical treatment prior to disposal through the biomedical waste management agency. While this practice is consistent with CAP and NABL requirements, in some labs it is inconsistent with the local permit requirements. The Company will upgrade its SOPs to ensure compliance with the national and local regulatory requirements and international best practices.
For disposal of biomedical waste, all laboratories have agreements with local authorized biomedical waste management agencies. At reference and network laboratory level, waste is collected on a daily basis and at collection centers, it is collected 2-3 times a week by the authorized biomedical waste management agency for ultimate disposal as per the permit conditions and local regulations.
No large quantities of hazardous chemicals are stored on site. The material used for diagnostics arrives in pre-packed units that are used directly on the specimen and are disposed of locally through local waste collectors. The laboratories do not produce any mercury waste and radioactive waste is very limited and disposed off according to national regulatory requirements.
Solid waste primarily comprises of packaging materials, empty containers and office waste. These are disposed of through local recyclers in accordance with environmental permit conditions.
Management of Wastewater:
Wastewater from SRL facilities is infectious in nature as it contains pathological samples such as stool, urine, blood, and chemical reagents.
Three reference laboratories (which are larger facilities) have their own effluent treatment plants (ETPs). The treated wastewater is either used for gardening or discharged into the municipal sewerage system, after due testing and analysis as per local regulatory requirement. The sludge is disposed of through licensed biomedical waste management agency.
In laboratories without ETPs (which are typically small-scale operations such as network labs or collection centers), the laboratory wastewater is collected and stored in containers with hypochlorite and later disposed of through the biomedical waste management agency as allowed by the environmental permit.
Air Emissions:
Main source of air emissions and noise is diesel generators used as power back-up in all laboratories. DG sets are equipped with acoustic enclosures as per the local regulatory requirements.
PS 4 – Community Health, Safety and Security
Life and Fire Safety:
All laboratories are co-located in leased premises within existing buildings and have fire safety provisions in line with local regulatory requirements. SRL has developed an SOP on the fire safety requirements for all its facilities.
For the SRL facilities visited during the appraisal, adequate fire safety provisions – commensurate with potential fire risks for such facilities - were found to be in place. This included for instance: clearly marked emergency exits, smoke detectors, fire alarms and extinguishers which are checked on a monthly basis. Where appropriate, the laboratories have obtained a No Objection Certificate (NOC) from the local fire department.
Fire safety drills are conducted at least once a year across all the facilities and all fire hydrants and extinguishers are checked monthly. Going forward SRL will conduct fire drills at least thrice a year for its larger facilities.
In order to confirm that life and fire safety provisions are adequate across its facilities and are in compliance with WBG’s EHS Guidelines, the Company will commission an independent review of life and fire safety provisions of its larger labs such as reference and network labs by a qualified external expert. A representative sample of all facilities (comprising 2 Reference Laboratories including the largest one in Mumbai, 5 Network laboratories including at least one franchisee and 5 Collection centers) shall form part of this review and results shall then be consistently applied across the board.
For new facilities, SRL will commission a fire safety professional to develop standard fire and life safety specifications, responsive to all national requirements and an internationally recognized fire and life safety code, as required by the life and fire safety section of the WBG EHS General Guidelines. This standard specification should form part of the SOP on life and fire safety. In addition, local conditions impacting fire safety will be evaluated for each proposed new facility , and on the basis of the SOP and this review, a qualified fire safety professional shall prepare a professional opinion that the proposed design meets the fire safety requirements described above. Furthermore, following construction the fire safety professional shall confirm that building construction was responsive to the SOP and any additional local requirements, and that the building as constructed meets the WBG life and fire safety requirements.
Emergency Preparedness and Response:
The Company has in place SOPs for a number of possible disaster situations such as earthquake, chemical, biological, or radioactive material spills. The SOPs require that surrounding buildings be notified in case of an emergency.
