While all Performance Standards are applicable to this investment, IFCs environmental and social due diligence indicates that the investment will have impacts which must be managed in a manner consistent with the following Performance Standards. If IFC's investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards.

PS 1 – Assessment and Management of Environmental and Social Risks and Impacts
PS 2 - Labor and working conditions
PS 3 - Resource Efficiency and Pollution Prevention
PS 4 – Community Health, Safety and Security

This is a category B project according to IFC’s Environmental and Social Sustainability Policy because the Project will generate limited and site-specific E&S impacts that can be avoided or mitigated by adhering to generally recognized performance standards, guidelines or design criteria. The Project is designed to manage and reduce social and environmental risks and impacts in Metropolitano owned operations in compliance with IFC Performance Standards, applicable national laws and regulations, WBG General and sector-specific Environmental, Health and Safety (EHS) Guidelines, including Health Care Facilities. The main risks and impacts associated with the project are addressed below as part of the Performance Standards analysis.

The key environmental, health and safety, human resources and social issues raised and reviewed during appraisal included the following: (a) Assessment of the management system to ensure environmental, health and safety, human resources and social performance; (b) Occupational health and safety and implementation of good hospital management practices and employee training programs to prevent nosocomial diseases; (c) Quality and sustainability of potable water supply; (d) Adequacy of disinfection and sterilization programs and facilities; (e) Effluent management; (f) Solid and infectious waste management and disposal; (g) Life and fire safety in the construction and operational phase of facilities.

The location of Metropolitano is in the city of Managua and as such, there is no conversion of natural and/or critical habitats leading to biodiversity loss. Hospital operations and expansion will take place within its own land and the project will not involve land acquisition. No presence of indigenous people or prior cultural asset history. Therefore, PS5, PS6, PS7, and PS8 are not applicable to this project.

IFC's appraisal considered the environmental and social management planning process and documentation for the project and gaps, if any, between these and IFCs requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and (if applicable) in an agreed Environmental and Social Action Plan (ESAP). Through the implementation of these measures, the project is expected to be designed and operated in accordance with Performance Standards objectives.

During appraisal, using the IFC ESMS tool, Metropolitano conducted a self-assessment of the institutionalization of the elements of its ESMS as defined in PS1. An independent assessment was also done by IFC based on the information available from the Hospital. The rating scale is from 0 to 5 for each element. Following this exercise, both assessments showed a similar trend, with an overall rating of 4.6, demonstrating a high level of maturity of the ESMS.



Policy

The EHS policy of Metropolitano was originally outlined an endorsed by senior management on August, 2008. The policy is communicated to all medical and administrative employees, including seasonal workers, through HOMETSA, the intranet site of Metropolitano. It is also communicated to contractors through inductions and brochures prior to beginning works. The brochures are also available to patients and neighbors. The policy has provisions for biannual reviews with participation of senior management. Updates, when available, are disseminated to all employees via HOMETSA and communiqués. The Hospital continually improves and monitors the environmental and social performance of its operations. The policy is consistent with IFC Performance Standards and describes Metropolitano’s comprehensive environmental and social approach and commitment that all its operations will be in compliance with all applicable laws and regulations of Nicaragua and its obligations under international law, such as guarantee good labor and working conditions in direct operations; alignment with good international practices for occupational health and safety (OHS); prevention of environmental contamination through use of technologies and best practices for waste management and emissions; avoidance of impacts to communities; and, ongoing monitoring process.



Identification of Risks and Impacts

Typical environmental and social risks arising from hospital direct operations and potential impacts to neighbors, are well understood, and are being addressed by Metropolitano. The Hospital has established comprehensive management procedures consistent with best international practice for health care facilities to conduct audits for risk assessment and proactively prevent, identify, prioritize, respond to, and periodically correct potential exposure to E&S risks, including associated labor risks, in the short and long term. The Hospital mitigates potential impacts from hospital operations through adherence to and the institutionalization of procedures based upon regulations promulgated by the Government of Nicaragua and the Joint Commission International (JCI) certification requirements. Environmental health and safety procedures, such as energy savings, minimization of water consumption, Kg infectious waste/occupied bed/day, etc., are in accordance with national and JCI requirements, and ongoing monitoring programs.



Management Program

Metropolitano has implemented a systematic approach to management of intern
al affairs, environmental and occupational health and safety, and other hospital management considerations. After consideration of the benefits of more health care oriented certifications, its business model and other considerations, Metropolitano decided to seek Joint Commission International (JCI) certification. The JCI assesses health care organizations to determine compliance with a strict a set of standards and requirements designed to improve quality of care. Metropolitano recently updated its JCI certification till August 2016. Under JCI, Metropolitano monitors 323 standards to ensure the delivery of a safe and quality health care.



Organizational Capacity and Competency

A committee involving multiple hospital functions jointly conducts the identification of all environmental and social risks. Supervisors and staff representatives participate in the identification and mitigation of risks. The committee gives precedence to actions that avoid impacts. The procedures for risk assessment are periodically reviewed and improved based on monitoring reports and internal and external feedback. Members of the committee include: Director General of the hospital, Quality Assurance Department, Client relations manager, Human Resources Department (OHS), Maintenance Department (L&FS), Security Department.



The EHS functions and the E&S staff are currently housed under the Quality Assurance Department. As described in the ESAP, Metropolitano will provide IFC with a copy of the internal memorandum establishing a stand-alone Environmental and Social Management Unit and provide an annual operational budget. Metropolitano will submit evidence to IFC that an adequate budgeting, management endorsement, vision and mission statements and associated documentation are in place to institutionalize the functions of the standalone Environmental and Social Management Unit, reporting directly to Metropolitano’s most senior administrative manager.



Emergency Preparedness and Response

Employees are trained in emergency preparedness and involved in identification and handling of emergencies. Resources and line of responsibilities have been allocated to handle emergencies. The emergency program is in line with Metropolitano’s risk assessment and monitoring program that identifies areas where emergencies could happen and the potential impacts to all those concerned. Response procedures and equipment are in place for fire and other emergencies such as earthquakes. And, procedures ensure that activities are back to normal in the shortest time possible. The Hospital has developed life and fire safety (L&FS) considerations, off-site emergency communication channels and management with neighbors, and provisions for availability of appropriate L&FS equipment in all their premises. A fire brigade is in place. Fire suppression equipment is monitored on regular basis, and updated to recent technology to keep up with new potential risks. Implementation of the L&FS pla
n includes evaluation of emergency alarms, evacuation drills, fire drills with participation of senior management and Managua’s fire department as external auditor, documentation of needed corrective measures for reporting to senior management, and, a system procedure to ensure that corrective measures are implemented.



The Hospital has color codes for emergencies that determine emergency decisions. The color code is placed in the back of the ID cards of all employees. Color codes have been established for cardiac arrest, fire, security breach, failure of critical hospital equipment, missing children, arrival of an ambulance with patient in trauma, chemical spills, and need for an emergency evacuation. The emergency color code is part of the induction training at Metropolitano. An emergency hotline (5555) is in place and available to all staff to report emergencies following the Hospital color code. Trained staff and external experts are engaged for specific tasks, such as evaluation of emergency and response plans, training for specific issues such as maintenance and upgrading of fire equipment, new acquisitions, disaster management, etc.





Stakeholder Engagement

Metropolitano is located in an urban area and surrounded by residential neighborhoods. The Hospital has a “Gerencia de Atención al Cliente” (Client Relations Manager) with responsibility for overseeing all engagement with local authorities and external communications to neighbors, and manages exceptional issues that may arise from Metropolitano operations in close cooperation with the EHS staff. For all community issues and concerns, the Client Relations Manager reports directly to the Hospital’s Director General. The Hospital has conducted a stakeholder analysis, and has formal management procedures for engagement with its neighbors. An operating grievance mechanism is publicly available to facilitate receipt and response to community grievances about the Hospital operations. The Hospital has developed an active program prior to the commencement of construction and has established an active and ongoing program to keep neighbors informed.



Community Grievance Mechanism

Metropolitano has contacted neighboring homes and a nearby school to provide all information concerning the ongoing construction, increased traffic of lorries, and the safe routes for pedestrians that have been implemented by the Hospital. As indicated under PS1, concerns from the communities are being addressed formally. The Hospital has a Community Grievance Mechanism, that has been made public to the neighbors and the community nearby. The grievance mechanism indicates how individuals may register grievances publicly or anonymously with Metropolitano. The procedure indicates that any event with communities, if at all, is recorded and reported to IFC in the AMR.



Monitoring and Review

Metropolitano has established comprehensive management system procedures for internal monitoring and reporting to high
er management staff E&S impacts of its hospital operations, including neighbors. The procedures involve the EHS Department, and monitoring activities take place with participation of medical staff and employees. The monitoring and review and its frequency is defined in its JCI-based management system procedures, and activities are in line with the standard risk assessment process. The process involves physical inspections and formal documentation. The monitoring results are used to check the effectiveness of the environmental and social action plans, and to improve the management system procedures. The content of these reports include performance indicators such as accident and lost time due to accidents, groundwater water abstraction, energy use and savings, water quality, wastewater quality, Waste generation and management of both hazardous (Kg infectious waste / occupied bed/day) and non-hazardous waste, and social responsibility. Annual reports are provided to Marena (Environmental Agency of Nicaragua) and to IFC through the AMR.

Human Resources (HR) Policy

Metropolitano has adopted a Human Resources Policy that has a number of management procedures available for administrative and human resources affairs that ensure full respect of the Nicaraguan regulatory labor requirements and related international law. The policy and implemented procedures are in line with all PS2 requirements. The HR policy covers all relevant issues in relation to protecting worker’s rights and to providing improved working conditions, as well as good practice in HR management (non-discrimination, no child labor, no forced labor, freedom of association, grievance mechanism, and matters of OHS) in a manual made available to employees. The policy outlines rights and responsibilities of the employees and those of Metropolitano. The Hospital is an equal opportunity employer. No identity documents of workers are ever deposited with the Hospital during employment for any reason. The policy is effectively communicated to all employees, including managers and supervisors during their induction at the time of recruitment. HR policy updates are provided via appropriate means or disclosed in notice boards, posters on the Hospital premises and via HOMETSA. If a major change in the HR policy is compulsory by a government legal directive or otherwise, a meeting is organized for the update and assessment of employee understanding of the new amendment. Metropolitano has a system procedure to regularly check that contractors are aware of the HR policy and adhere to it.



Non- Discrimination and Equal Opportunity

The HR policy prohibits discrimination in employment based on gender, race, age, ethnic and religious association, or nationality. The Hospital has stringiest provisions to prevent and address any type of harassment or mistreatment.



Child Labor

Child labor risks mentioned by the USDOL report for Nicaragua, have not been identified during appraisal of Metropolitano. Nicaragua has laws and regulations that prohibits and penalizes the use of child labor. Following applicable government regulations, Metropolitano’s HR policy has a clear mandate and monitoring procedures to observe ILO Conventions 138 on Minimum Age and 182 on Worst Forms of Child Labor in its direct operations and contractors.



Working Conditions and Terms of Employment

Metropolitano has 542 employees (61% female; 39% male) as of October 2013. Written contracts provided to permanent staff set up terms of employment consistent with national labor laws and PS2 requirements, including hours of work, wages and benefits, leave for illness, maternity, vacation or holiday, etc.



Worker’s Organizations

Although no workers organization is operating in Metropolitano, following Nicaragua’s law, and the Hospital HR policy, freedom to join a union of the employee’s choice is guaranteed by the Hospital.



Retrenchment

No retrenchment is anticipated, moreover, Metropolitano estimates that over 18% increase in number of direct employees is
expected as result of the expansion of its operations.





Grievance mechanism

Human resources procedures include an employee grievance mechanism that allows for workers to express their concerns and also to provide suggestions for improvement with line management staff or directly to the Human Resources supervisors. The Grievance mechanism can receive individual or collective concerns and allows for anonymous grievances. The procedure indicates that any grievance should be solved in a maximum of 7 working days.



Occupational Health and Safety (OHS)

Metropolitano has a centralized OHS department with professionals that have reporting lines and responsibilities in the EHS Committee. The Hospital conducts workplace/job hazard analysis which is used to prioritize mitigation actions; subsequently, employee training focuses on the demands and hazards associated with specific workplace and understanding of the hazard analysis, as well as orientation to employee responsibilities with regard to wearing PPE and reporting accidents and near misses. Appropriate PPE is provided as needed. Relevant occupational health and safety principles are effectively documented in the comprehensive OHS manual and ensure appropriate level of protection to all employees. The OHS procedures are based on prevention. Employees are trained on-the-job regularly, and training records are kept for all workers. Feedback from workers is used to modify the OHS training content. Metropolitano facilities are smoke-free environment inside its fence, and this regulation applies to internal premises, patio, and garden areas.



At present, reported accidents are investigated and summarized in compliance with a detailed flowchart that includes an analysis of the cause, cost and required mitigation measures for situations or conditions leading to the accident with a specific timeline for remediation. The Hospital records accident investigations, estimate and report to management costs of lost time accidents, and can demonstrate accomplishment of measures to avoid recurrence.



Responsibility for management and oversight of the new tower construction (including the health and safety of contractor employees and their compliance with labor regulations) lies with a professional Quality Assurance Construction Manager hired by Metropolitano. IFC interviewed the QA Construction Manager, and toured the construction site to review measures that had been put in place to provide for a safe working environment. Overall the measures were commensurate with the risks and impacts to be found on such a site, i.e., personnel protective equipment such as protective eyewear, steel toe boots, etc., were being worn by workers, all safety measures were in place to avoid accidents (Zero accidents to the day of the visit). The contractor maintains logs of operations and reports that are provided to the QA Construction Manager and to the senior management of Metropolitano.



Training

Metropolitano provid
es diverse training to ensure professional capacity and active occupational safety and health prevention and response programs. Moreover, labor safety and disease prevention programs are well developed. Employees assigned to critical areas including neonatal intensive care, pediatric and adult intensive care, operating theatres, dialysis, etc., as well as in nutrition and food services participate in epidemiological surveillance for specifically notifiable diseases. In addition, all employees participate in accident prevention training, and all accidents are reported the appropriate regulatory agency. Infectious and contagious disease patients are isolated in accordance with internal and Ministry of Health requirements. Metropolitano submits a weekly report to the Ministry of Health detailing new cases of specifically notifiable diseases and nosocomial disease. In addition, the Hospital provides specialized training and appropriate personal protective equipment (PPE) for employees handling infected clothing, linens, and infectious health care waste.



Besides quality health care training, capacity building at Metropolitano includes EHS issues and protection of workers involved in hazardous work environments. Contractors are provided with a briefing lecture and provided with leaflets that inform of key EHS regulations that must be respected during work at Metropolitano premises. Feedback from trainees, worker’s representatives, and internal consultations are used to improve training. An assessment is carried out at regular intervals to define if training has changed behavior or processes.

Resource Efficiency

Sustainable development is a priority for Metropolitano and the Hospital pays attention to resource efficiency, through continuous improvement of their processes, selection of equipment, and energy savings. Metropolitano has developed an energy saving plan (Plan PREMDA – set of facility improvement measures) to be implemented for remodeling the existing buildings to reduce their energy consumption and improve their performance, and a priority setting exercise is underway for budget allocation. The plan includes replacing fluorescent tubes with LED energy saving light bulbs, solar panels for water heating, insulation of cooling system pipes, separate electrical circuits into individual networks, and implement clean practices to reduce energy. Green building design concepts (such as low volume plumbing fixtures, larger windows for day lighting and optimal view, low energy consuming LED lighting, etc) have been included in the new tower as an effort to improve the energy efficiency, and lighting considerations are an important element of the green design.



GHG

Energy used by the Hospital comes from the national grid, and during 2013 the Hospital consumed 3,048,949 KWh and 9699 liters of diesel (used in generators and planed tests of emergency fire pumps). GHG emissions during 2013 operations have been estimated at around 1771 tons CO2-equivalent, most of which is derived from electricity use for illumination purposes.



Water

Water use by Metropolitano does not affect use of the resource by neighboring communities. Water is supplied by different sources: a) through the municipal system of the National Water and Sewerage Company (ENACAL: by its Spanish Acronym), and b) by two wells. The Hospital has licenses to abstract groundwater from the two wells, each of approximately 200m depth. Water abstracted from the wells is treated to ensure potable water for hospital normal and critical operations, and water quality for Hospital use is monitored on regular basis as part of the risk assessment, JCI quality assurance procedures, and following national and WBG General EHS Guidelines. Metropolitano has contracted an ISO 17025 certified laboratory “Centro de Investigacion de Recursos Acuaticos” (CIRA) for water quality monitoring (reverse osmosis, potable water, drinking water, and wastewater).



Daily water consumption requirements are 175 M3, and this figure will increase following operations at the new tower facility. The Hospital holds a water reserve of 189M3 (50,000 US gallons) for any event of fire. In addition, a water reserve of 189M3 is in place for the Hospital use. If any emergency where water supply becomes unavailable, the present reserve will be exceeded by the daily needs of the Hospital under the expansion scenario. As set forth in the ESAP, Metropolitano will provide IFC with satisfactory documentary evidence, that additional emergency potable water reserve (additional 100,000 gallons; 378M3), has been constru
cted and is available.



Waste Management

Metropolitano manages solid waste in line with best practices (reuse, recycling, treatment, disposal, and monitoring) to reduce environmental impact. Records of solid waste by categories are kept, as well as receipts of final disposal from government authorized waste management and recycling contractors. Workers handling waste are trained on proper waste handling, and the appropriate use of PPE. Operating procedures address minimization and recycling of non-hazardous waste such as paper, and cardboard.



Metropolitano maintains a health care waste management system and staff segregates wastes from hospital operations into one of the following classifications: municipal solid waste, dangerous biological or infectious waste, and hazardous waste. All waste is identified and segregated at the point of generation, and collected for off site management. Municipal wastes are managed and collected by regular waste removal services. Following the management system procedure, infectious waste (9% of the total waste) is collected in red bags by especially trained staff with appropriate PPE and then transported to temporary storage designed and built for such wastes. Red bag waste is stored in a low temperature chamber, and remains locked. Metropolitano contracts infectious waste collection and disposal to Eco Tratamientos, S.A. (ECOTRASA), a company licensed by the Ministry of Health (MINSA). In this instance ECOTRASA maintains records, including waste manifests, in keeping with national regulatory requirements. All infectious waste is treated by ECOTRASA in an off-site incineration facility, to ensure that this waste is never sent to a municipal land fill. Similarly, staff accumulates pathological wastes as well as sharps collected for disposal by ECOTRASA. Collection of infectious waste takes place twice per week and provides Metropolitano with manifests addressing collection and destruction. Metropolitano E&S staff monitors the final disposal system through unanticipated supervisory visits to ECOTRASA facilities. Metropolitano has implemented an infectious waste reduction plan, involving interdepartmental staff, to decrease amounts of infectious waste generated. The final goal is to reduce the increasing annual financial cost of treatment and disposal, presently standing at US$ 2.30/Kg.



The hospital discharges sanitary wastewater to the public sewerage under permit that municipal government-owned treatment works will treat and disinfect, and there is no specific requirement for pre-treatment in Nicaragua. Waste segregation measures minimize entry of solid waste into the wastewaster stream. For wastewater management, the Hospital has contracted a service provider “Plomeria Picado”, that cleans off solid waste in the wastewater streams three times per annum.

Life Fire and Safety

In the new tower construction, Metropolitano will implement a Master Plan for Life and Fire Safety (L&FS), identifying major fire risks, applicable codes, standards and regulations, fire drills, and mitigation measures. As set forth in the ESAP, in the new tower construction, Metropolitano will implement a Master Plan for Life and Fire Safety (L&FS), identifying major fire risks, applicable codes, standards and regulations, fire drills, and mitigation measures. It will also address potential seismic risks. The Life and fire safety design shall be responsive to all the elements described in the WBG General EHS Guideline, the Nicaragua safety code, and to one international safety code (such as the NFPA system). Metropolitano will provide certification on the seismic (structural) design of the building; the sprinkler and fire alarm design drawings; information on HAZMATs, medical gases and any other system or storage that could represent a hazard for the building; and L&FS narrative/rational analysis. Metropolitano will engage a third party and qualified Life and Fire Safety Engineer acceptable to IFC, to review the Master Plan (engineering design).



Metropolitano will also conduct post construction inspections by a qualified Life and Fire Safety Engineer acceptable to IFC, to verify and provide certification that the L&FS system was constructed in accordance with the design and tested in accordance with international code. Metropolitano will also provide a certification on the seismic (structural) safety of the building.



Cafeteria Service Operations

The field appraisal indicated a need for housekeeping improvement in the kitchen area and as set forth in the ESAP, Metropolitano will present and implement a plan for food safety and hygiene monitoring management system at the cafeteria, for IFC approval, that will include: a) periodic health assessment for all cooks and support personnel working in the kitchen, b) use of quality protective garments for hands, head, and mouth, c) adequate storage and handling of raw ingredients, d) a monitoring plan for food safety and hygiene, and e) documentary evidence of continuous training in food safety.



Emergency Preparedness and Response

Metropolitano references in their JCI-based management system procedures the need for emergency preparedness and response, and the procedures developed and implemented to manage staff and patients in any event. The need for the new facilities to adopt similar practices, to include suitable equipment, exit signs and other related considerations in the event of a fire or earthquake being Nicaragua in a seismic area, and to conduct drills to ensure staff are familiar with what to do in the event an emergency situation occurs, is all addressed in the building design and in the risk assessment procedures. Neighbors interviewed indicated being well informed and continuously updated by Metropolitano. Further, indicated that Metropolitano had a
rapid response system when they approached the Hospital for information, or to discuss a concern.



Security Personnel

The security personnel at Metropolitano are not armed, it is outsourced, and a code of conduct for security forces has been implemented. No incidents with employees or neighbors have been reported. Procedural directions include how security forces are managed in accordance with IFC PS4 requirements (as described in paragraph 12 and 13). And, all security personnel has a background check on file that shows they have no record of human rights abuse, and provisions were found on how to respond to threats guided by the principle of proportionality.

Metropolitano intends to continue to maintain strong relationships with its immediate neighbors and the people of Nicaragua. Metropolitano provides services free-of-charge to burn children. The Hospital’s complex includes the only Burn Patients Unit for children in the country, administered by the Burn Children Association (“APROQUEN”) and operates free-of-charge with contributions from various business groups and individuals.

Hospital Metropolitano:
1- Ing. Gilberto Guzman
Director General Metropolitano
Km 9.8 Carretera a Masaya
Tel. (505) 22556900
Managua

2- Engineers MS Agnes Saborio, and MS Maria Jose Almanza.
Calidad, Medio Ambiente y Responsabilidad Social - Metropolitano
Hospital Metropolitano
Km 9.8 Carretera a Masaya
Tel. (505) 22556900
Managua

Broad Community Support is not applicable for this project

S.no	Description	Anticipated Completion Date	Status
1	1.0 Establish Stand-alone Environmental and Social Management Unit and provide annual operational budget. Submit evidence to IFC that an adequate budgeting, management endorsement, vision and mission statements and associated documentation are in place to institutionalize the functions of a standalone Environmental and Social Management Unit, reporting directly to Metropolitano’s most senior administrative manager.	05/15/2014	Completed
2	1.0 Establish Stand-alone Environmental and Social Management Unit and provide annual operational budget. Submit evidence to IFC that an adequate budgeting, management endorsement, vision and mission statements and associated documentation are in place to institutionalize the functions of a standalone Environmental and Social Management Unit, reporting directly to Metropolitano’s most senior administrative manager.	05/15/2014	Completed
3	2.0 Provide IFC with satisfactory documentary evidence, that additional emergency potable water reserve (additional 100,000 gallons), has been constructed and is available.	12/31/2015	Completed
4	2.0 Provide IFC with satisfactory documentary evidence, that additional emergency potable water reserve (additional 100,000 gallons), has been constructed and is available.	12/31/2015	Completed
5	3.0 Certification of Life and Fire Safety Systems Construction: a) Implement a Master Plan for Life and Fire Safety (L&FS), identifying major fire risks, applicable codes, standards and regulations, fire drills, and mitigation measures. As set forth in the ESAP, in the new tower construction, Metropolitano will implement a Master Plan for Life and Fire Safety (L&FS), identifying major fire risks, applicable codes, standards and regulations, fire drills, and mitigation measures. It will also address potential seismic risks. The Life and fire safety design shall be responsive to all the elements described in the WBG General EHS Guideline, the Nicaragua safety code, and to one international safety code (such as the NFPA system). Metropolitano will provide certification on the seismic (structural) design of the building; the sprinkler and fire alarm design drawings; information on HAZMATs, medical gases and any other system or storage that could represent a hazard for the building; and L&FS narrative/rational analysis. b) Engage a third party and qualified Life and Fire Safety Engineer acceptable to IFC, to review the Master Plan (engineering design). c) Conduct post construction inspections by a qualified Life and Fire Safety Engineer acceptable to IFC, to verify and provide certification that the L&FS system was constructed in accordance with the design and tested in accordance with international code. Metropolitano will also provide a certification on the seismic (structural) safety of the building.	07/31/2014	Completed
6	3.0 Certification of Life and Fire Safety Systems Construction: a) Implement a Master Plan for Life and Fire Safety (L&FS), identifying major fire risks, applicable codes, standards and regulations, fire drills, and mitigation measures. As set forth in the ESAP, in the new tower construction, Metropolitano will implement a Master Plan for Life and Fire Safety (L&FS), identifying major fire risks, applicable codes, standards and regulations, fire drills, and mitigation measures. It will also address potential seismic risks. The Life and fire safety design shall be responsive to all the elements described in the WBG General EHS Guideline, the Nicaragua safety code, and to one international safety code (such as the NFPA system). Metropolitano will provide certification on the seismic (structural) design of the building; the sprinkler and fire alarm design drawings; information on HAZMATs, medical gases and any other system or storage that could represent a hazard for the building; and L&FS narrative/rational analysis. b) Engage a third party and qualified Life and Fire Safety Engineer acceptable to IFC, to review the Master Plan (engineering design). c) Conduct post construction inspections by a qualified Life and Fire Safety Engineer acceptable to IFC, to verify and provide certification that the L&FS system was constructed in accordance with the design and tested in accordance with international code. Metropolitano will also provide a certification on the seismic (structural) safety of the building.	07/31/2014	Completed
7	4.0 Present and implement a plan for food safety and hygiene monitoring management system at the cafeteria, for IFC approval, that will include: a) periodic health assessment for all cooks and support personnel working in the kitchen, b) use of quality protective garments for hands, head, and mouth, c) adequate storage and handling of raw ingredients, d) a monitoring plan for food safety and hygiene, and e) documentary evidence of continuous training in food safety	05/15/2014	Completed
8	4.0 Present and implement a plan for food safety and hygiene monitoring management system at the cafeteria, for IFC approval, that will include: a) periodic health assessment for all cooks and support personnel working in the kitchen, b) use of quality protective garments for hands, head, and mouth, c) adequate storage and handling of raw ingredients, d) a monitoring plan for food safety and hygiene, and e) documentary evidence of continuous training in food safety	05/15/2014	Completed