Environmental and Social Management System (ESMS)
The healthcare facilities to
be acquired by HHI currently run three management systems concurrently; the
quality management system; the environmental management system and the occupational
health and safety management system. The systems have been developed consistent
with the current scope of outpatient healthcare services. The management
systems include the following manuals, policies and procedures; i)
Environmental Management Systems Manual; ii) Occupational Health and Safety
Manual; iii) Quality Assurance Manual iv) Combined Standard Operating
Procedures; v) Fire Policy; vi) Infection Control Guidelines; vii) an ESMS
plan; and viii) a Human Resources Policy and Procedures Manual.
The management systems in
place do not provide guidance
on management of E&S risks and impacts for the existing hospital in the
group, the proposed development of inpatient facilities and future healthcare
facility acquisitions . According to ESAP 1 , HHI shall
develop and implement an environmental and social management system at
corporate level to cover: i) E&S due diligence for acquisitions; ii)
management plans for effluents iii) Identification of impacts for greenfield
projects and iv) EHS management plans and procedures for the new hospital,
inpatient facilities healthcare facilities and outpatient healthcare
facilities. This ESMS must be endorsed by senior management and communicated to all levels within its organization and subsidiaries.
Identification of Risks and
Impacts
HHI plans to undertake a site specific
Environmental and Social Impact Assessment (ESIA) study for the proposed
greenfield hospital in Nairobi as part of the country permitting process. Thus,
as stipulated in ESAP 2 , HHI will
appoint a suitably
qualified and experienced consultant to undertake an ESIA in
accordance with good international practices and in line with the requirements
of IFC Performance Standards. The ESIA will cover labor and OHS issues during
construction. The ESIA report along with the Construction Environmental Health
and Safety Plan (CEHSP) and will be submitted to IFC for review prior to
commencement of construction.
HHI
have in place a procedure to perform legal due diligence and to identify the
regulatory environmental requirements for expansion projects, such as the need
for an EIA. HHI will consider the extent of the development, including
expansion of current footprint to identify the need for further identification
of risks and impacts.
For
operations of the targeted healthcare facilities, the four existing manuals on
quality, environment, occupational health and safety and fire safety address
risk assessment. The quality management system has a more elaborate process of
identification of risks and impacts in all clinical and laboratory processes
which are captured in various reports such as the total quality management
report, clinical audit reports, incident reports, fire risk assessments,
patient satisfaction surveys, complaints and grievances reports and feedback
from mystery shopper client visits. The corrective actions drawn from these
reports are included in the annual quality improvement plans and disseminated
throughout the facilities.
Management Programs
The healthcare facilities to
be acquired by HHI have a management system that identifies annual quality
improvement plans from their quality management system gap analysis reports,
environmental safety and quality improvement plans. The annual quality
improvement plan contains objectives and programs that provide a framework for
a systematic, integrated and organization-wide approach to monitor, assess and
improve patient care, health and safety, waste management and organizational
performance at the healthcare facilities.
The healthcare facilities OHS
Manual, has listed the following as the management programs to be carried out:
active involvement and commitment of managers, identification and control of
hazards, investigation and reporting of all accidents and dangerous incidents,
participation and consultation with, employees on safety matters, provision of
first aid and emergency procedures and provision of information, training and
supervision as necessary for safety. The fire safety manual addresses fire
safety risks and assessments. HHI will adopt and expand on the management
programs, include management programs for the new hospital in line with the
requirements, targets and programs set out in the corporate ESMS.
Organizational Capacity and
Competency
HHI have no
full-time E&S manager appointed at a corporate level with the experience
required to assess and manage the E&S risks and impacts of its operations. HHI shall hire a
qualified Quality, Environmental, Health and Safety (QEHS) manager who will
have the responsibility of enhancing and implementing at the corporate level
the ESMS and ensure that the new hospital and acquired healthcare facilities
develop and implement their site specific ESMS in line with corporate ESMS
requirements, conduct monitoring of E&S performance and report to HHI
management team on E&S performance and challenges ( ESAP 3 ).
Emergency Preparedness and Response
The
healthcare facilities to be acquired by HHI have an elaborate Fire safety
policy and procedures that elaborate actions to be taken in the event of fire,
evacuation procedures, roles and responsibilities of the various staff and fire
marshals, fire detection and prevention. In the annual quality improvement
plan, all facilities are required to undertake fire drills twice a year. The
company is in the process of consolidating data related to fire safety and fire
risk assessments of all the facilities to be acquired to ensure that the
facilities post fire safety signage and instructions for use of fire equipment,
conduct drills, maintain documented evacuation plans, conduct fire safety
training for fire marshals in each facility and conduct annual external fire
safety audits of each facility. As part of ESAP 1, HHI will develop and
implement a corporate emergency preparedness and response plan in line with IFC
PS1 requirements which will be adopted by the new hospital and the healthcare
facilities.
Monitoring and Review
The
targeted healthcare facilities carry out internal quality assurance audits
against Standard Operating Procedures (SOPs) and legislative requirements twice
a year. Results of these audits are assessed by the Quality Assurance
department and reported to the facilities country General Manager, who is
ultimately responsible for correcting any performance issues. There is an
annual Quality Improvement Plan developed to address any corrective actions. In
2016/2017 financial year, for example, the quality improvement plan addressed
the following EHS objectives; improvements in incident reporting; elimination
of the number of incidents with the root cause related to ineffective
escalation process; improvement in waste management systems to meet best
practice standards; ensuring best practice in hand hygiene and infection
control at all healthcare facilities; fire safety, energy savings, water
usage and conservation; reduction of losses at the pharmacies and laboratory
and improvement in internal and external communication. HHI will adopt and
expand the monitoring, reporting and review procedures to cover all its
inpatient and outpatient operations.
