This is an E&S category B project because, based on information reviewed by IFC, this investment will have limited adverse social and environmental impacts that are few, are generally site specific, largely reversible and readily addressed through mitigation measures, as outlined in the Environmental and Social Action Plan (ESAP) attached to this ESRS.

Specific key environment, social, health and safety issues reviewed during the appraisal included environmental and social (E&S) management capacity of the sponsors to undertake the project and operations in a manner consistent with IFC Performance Standards; working conditions for employees and contract workers during both construction and operation of the hospital; efficient use of energy, water and resources; plans for the management of liquid effluents and its discharge; and management of hazardous materials and hazardous health care wastes during the operations. A critical aspect is to ensure that Life and Fire Safety systems are constructed and operated according to relevant national and international standards.

The findings of the project appraisal indicate that there are no impacts related to PS5: Land Acquisition and Involuntary Resettlement given that the land is already owned by the Hospital on the same campus as presently occupied; PS6: Biodiversity conservation and Sustainable Management of Living Natural resources, PS7: Indigenous Peoples, and

PS8: Cultural Heritage do not apply because no adverse impacts to biodiversity or sustainable natural resource management have been identified, and no Indigenous People are known to have been in the area of the project. No sites of cultural heritage are expected at the location of the development.                                                   

Environmental and Social Assessment and Management Systems: The project is in its initial stages of planning, and as per local regulations (City of Buenos Aires- CABA), this development does not require a full Environmental Impact Assessment but the renovation of the environmental license and risk evaluation with a proposed Environmental Management Plan describing the key environmental impacts and mitigation measures proposed for the project. The company will develop a complete Environmental, Health and Safety mitigation plan (EHS MP) with measures and a monitoring strategy that will be agreed with CABA, including a periodic monitoring and reporting by an independent party (ESAP #1). The company will request the construction license once the project has detailed engineering plans.

Environmental and social impacts in the Hospital Aleman are managed per the established operational management system. The current management system has in place procedures and programs to address key issues such as patient safety, occupational health and safety, hazardous health care wastes, and efficient use of energy and water aspects of the operations. Also, presently, the hospital is within a formal process of accreditation by the Joint Commission International (JCI), in which measurable elements are managed and monitored for quality and safety in the following aspects: patients, employees, facilities and the processes. The hospital will continue utilizing the present framework within their social, environmental and Occupational Health and Safety (OHS) management systems to ensure adequate management of its impacts during the operation of the new portion of the hospital.

The Company has commissioned the design of the hospital to a recognized local architecture and engineering company specialized in the design of health care facilities with experience working with international architecture firms. The planned design aims to achieve international standards for patient safety, life and fire safety and environmental protection. The new hospital is being designed to be in compliance with the local ITAES (Instituto Técnico para la Acreditación de Establecimientos de Salud in Argentina) standards, Joint Commission International (JCI) and to adhere to Energy and Environmental Design programs (i.e.: EDGE of IFC), among other applicable standards.

Organizational Capacity and Competency: Hospital Aleman has appointed a construction manager who is responsible for the coordination of the development of the new tower for the hospital. Also, specialized firms for structural safety, life and fire safety, ventilation, sanitary systems, other are providing technical input in the planned design of the hospital. During construction the Company will assign a responsible supervisor to verify that environmental and OHS measures are addressed as described in the Environmental Management Plan and to ensure compliance with contract requirements.

For the operations of the new portion of the hospital, the current structure will be retained, the hospital has a management structure for E&S aspects, with an environmental coordinator, a human resources manager (responsible for occupational health), a security coordinator, a human resources manager and quality assurance manager who interact with other divisions to manage E&S issues in an integrated way.

The company will appoint personnel with sufficient knowledge, experience and skills to implement the specific measures to ensure compliance with local regulations and the requirements of IFC’s Performance Standards. The company will guarantee E&S competency of the employees by hiring qualified individuals and/or providing additional training to the employees.

Emergency Preparedness and Response: Hospital Aleman has in place emergency response plans including mechanisms to inform affected communities. The emergency plan includes a safety training program for all employees and in particular for the internal emergency brigade. The emergency plan will be modified to adapt conditions to the new development, with the identification of potential hazards and the response to emergency situations (ESAP #2).

Monitoring and Review: The Company will implement the monitoring measures defined in the Environmental Management Plan. Before construction starts, the Company will present to IFC a detailed E/S implementation and monitoring plan during construction, and will report on it during the construction stage. the Hospital will ensure monitoring plans and targets are aligned with the applicable sections of the WBG EH&S Guidelines for Health Care Facilities and the EH&S General Guidelines.

Monitoring of E&S elements during operations will be aligned with the E&S Management System to be implemented. Hospital Aleman will continue monitoring fire safety, including periodic internal audits; water and energy use; waste generation; OHS; and liquid effluents, among other indicators; and follow up on the corrective and preventive actions as they are implemented.

Human Resources Policies, Procedures and Terms of Employment: The Hospital has detailed procedures regarding human resources management. Based on these procedures, the company will develop a formal corporate Human Resources Policy aligned with Argentinian laws and the requirements of IFC’s Performance Standard 2 regarding labor and working conditions (ESAP #3). The company’s procedures include the Internal Rules and Regulations documents (Programas, Procedimientos, Reglamento Interno de Trabajo) and the company’s Code of Ethics. In addition, labor contracts define the working conditions and elements such as rights of the employees, working hours, compensation scheme, non-discrimination requirements, and minimum age of employment among others are described in the procedures. All employees receive copy of the employment contract and additional details are provided in the induction training that is mandatory to all employees. apply similar policies and procedures in compliance with local regulation.  The Hospital fixes the salaries according to the collective bargaining agreements and provides remuneration surveys with market wages to sustain their own competitively. There is a vital and mobile minimum wage that is considered by trade associations and business chambers when negotiating new salary scales

The current workforce at Hospital Aleman is near 1,830 direct employees, 63% are female workers (55% in supervisory category positions). Additional 310 workers are third party employees working at the premises. The project is expected to create jobs during construction and near 350 new direct jobs during the operation of the first phase of the new hospital tower (Juncal Building).

Workers Organizations:  part of the workforce of Hospital Aleman does belong to workers organizations or unions: ATSA “Asociación de Trabajadores de la Sanidad Argentina”, and AMAP “Asociación de Médicos de la Actividad Privada”. Additionally, the management team of hospital confirmed that they would not prevent employees to organize or participate in any workers’ organizations.

Non-Discrimination and Equal Opportunity: The Code of Ethics has explicit reference to principles of non-discrimination based on sex, skin color, nationality, political affiliation, etc. which are highly valued by the Company.

Grievance Mechanism: The Hospital has well defined communication mechanisms and has channels for employees’ grievances. The company uses HR as vehicle for grievances, direct access to supervisors and directors is available to all employees; in addition, there is a committee for working relations that documents and resolves grievances on behalf of the employees. The company promotes an open-door policy, through which employees can bring all kinds of concerns to the Personnel Management or other dependencies of the Hospital, there are provisions in the Code of Ethics to report controversial or conflictive situations. secure and confidential way (reserved identity) through an external telephone line.

Protecting the Workforce and Workers Engaged by Third Parties: Policies regarding age of employment and compensation are based upon national law. All employees should be at least 18 years to be employed; salaries paid are above minimal salary. No child labor or forced labor is used by the Company; these practices are not suspected in the supply chain. The company contracts with reputable companies the outsourced services to ensure compliance with Argentinian laws and regulations. The Hospital 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 and Safety: HA has in place a detailed and comprehensive Occupational Health and Safety (OHS) program consistent with the requirements of the Argentinian legislation and best practices for health care facilities such as ITAES program and the proposed JCI accreditation that will be followed by the company. The OHS program is aligned with quality programs and patient safety requirements, the program covers among others biological hazard safety (e.g. nosocomial infections, needle stick injuries), practices for handling hazardous drugs (e.g. chemotherapeutic drugs), radiation protection, ergonomic practices, preventive medicine, workplace monitoring and medical examination of employees. The new portion of the hospital, as part of the E&S Management System, is expected to follow the current OHS management system to manage all the identified risks.

A joint workers-employer health and safety committee is in place. It meets bimonthly and part of its tasks is to identify potential risks, address workers concerns regarding OHS and ensure proper implementation of the OHS program. The Hospital has a comprehensive training program and accidents are investigated and corrective actions implemented.

Existing radiology facilities have the approval of the local authorities and a full monitoring program for ionizing radiation is in place, and during the design, installation, acceptance testing, and operations of all the radiology and oncology facilities in the future facilities, the company will ensure the guidance and verification of qualified experts and the clearance of the local authorities.  The construction administration manager working for Hospital Aleman 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.

Resource Efficiency: HA has implemented internal programs for management of water and energy and will continue with such programs in the future for the complete campus. HA monitors and controls the current use of water and electricity, current level of water usage is 0.45 m3/bed/day and for electricity is 10 kWh/bed, well below industry benchmarks (e.g. USAID Eco III-project report: Energy Efficiency in Hospitals Best Practice Guide). The new hospital tower will integrate energy and greater efficiency in the design and selection of equipment. The design is in early stages but selection of HVAC (Heating, Ventilation, and Air Conditioning) system; lighting and sanitary facilities will consider energy and water efficient criteria; also, all patient rooms will have natural light and there will be natural ventilation used in some areas of the building. 

HA will consider the applicable sections of the WBG Health Care Facilities EH&S Guidelines and EDGE (green Building) principles in the selection of equipment to be used in the new hospital. Water will be sourced from the municipality and monitored by the hospital for quality of all parameters.

Liquid effluent management: liquid effluents are mostly of sanitary type; there is an onsite segregation process for potentially contaminated materials which are disposed of via hazardous waste.   Effluents at the hospital are discharged to the municipal sewage in compliance with local regulation, periodic effluent monitoring is performed and the results show compliance with local requirements. The new tower will have a similar arrangement with no need for WWTP; local oil/ water separator and under-sink collecting tanks will be used for kitchen, traumatology (capture of cast residues), chemical laboratories and odontology, as required. No hazardous or infectious waste are discharged into the sewage system.

Greenhouse Gas Emissions: Greenhouse gas (GHG) emissions resulting from operation of the future Hospital tower will be estimated based upon actual resource consumption. The new building will have similar space dedicated to clinical offerings, the GHG emissions during the operational stage have been estimated as 712 tons CO2 equivalent per year for the complete hospital. Actual records will be used to review amounts of tons CO2 equivalent per year that will be emitted from the complete hospital once the new phase is operational.

Wastes: Functional procedures to manage wastes are implemented in the existing hospital. Wastes are segregated at the point of generation by risk, including segregation of organic, recyclable, biological, infectious and hazardous health care waste. Procedures for handling materials are defined in the hospital solid waste management program.

Wastes are stored temporarily for periodical pickup by specialized and licensed service companies. The provided facilities for storage and management of health care waste are in compliance with GIIP, including refrigeration and encapsulation (jellification) of organic liquid wastes. HA commissions periodic audits and visits to the service company to follow up on the handling and disposal of the materials. Management of hazardous and non-hazardous wastes for the new hospital tower will follow the procedures defined in the solid waste management program. HA uses reputable enterprises licensed by the relevant local authorities to handle the wastes and will obtain chain of custody documentation to the final destination.

Hazardous Materials: Hazardous chemicals in the hospital are limited to small volumes of laboratory reagents, chemicals, solvents, chemotherapeutic drugs, medicinal gases and anaesthetics. Hazardous chemicals are handled in accordance with acceptable practices; only trained personal handles the materials, precautions are taken when using and handling the materials, required protection equipment, such as ventilation hoods and personal protective equipment is provided. Material Safety Data Sheets are available. Radioactive material used in the radiology labs are controlled through internal procedures and only approved personnel access and manipulate the materials. Similar practices for management of hazardous materials will be implemented in the proposed project with detailed recording of quantities and final disposal (location, methodology) by final certified companies.                    

Infrastructure and Equipment Design and Safety: HA will comply with Argentinian structural/seismic and fire protection codes for the design of the new hospital and improve existing fire safety conditions in the hospital. The requirements of life and fire safety will be aligned with local legislation and the requirements of the Joint Commission International (JCI), the company is planning to use NFPA (US-National Fire Protection Association) codes as reference. In order to confirm compliance with IFC requirements, HA will engage the professional services of a qualified Life and Fire Safety Engineer acceptable to IFC to prepare a Master Plan (engineering design) and, upon physical completion of the building, to verify that the systems were installed as designed and in line with good installation practices. Life and fire safety design and operation shall comply with the Life and Fire Safety requirements of the WBG General EHS Guideline, and be responsive to one internationally recognized life safety code, and the Argentinian fire regulations (CABA fire code). The complete building fire safety conditions were improved recently by recommendations made by the fire authorities of CABA, however, additional smoke detection coverage and notification (alarm) appliances will be provided by HA in all areas of the hospital by the time the new tower is commissioned (ESAP #4).

The new hospital will be designed to provide universal accessibility measures and to facilitate the mobilization of patients, including ramps and elevators for access.

The radiology area will be planned considering the requirements of the local authorities and good international industry practices (GIIP). The company will engage a professional to verify compliance with radiation protection measures.

Community Exposure to Disease: HA has a strong program relating to patience safety, aligned with the requirements of the local ITAES and the Joint Commission International (JCI), which includes control of nosocomial infections. HA has in place comprehensive 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 future portion of the hospital will be designed and operated under JCI criteria to manage nosocomial infections.

Potable water for the existing operation is provided by the municipality; HA monitors periodically the potable water to confirm physical and microbiological parameters. HA performs periodic maintenance to the storage tanks.    

Security Personnel: HA employs unarmed security guards managed via a third party, for access control and emergency response purposes at the new hospital. The company utilizes additional security service hired from the police department of CABA with one armed agent per day.                 

The Hospital is located in an urban area, however the link with the community is conducted through public and private channels such as personalized attention and / or public and open complaints and suggestions system. The current Hospital Aleman grievance mechanism is inclined towards customer satisfaction and patient safety management.

The project for the new portion of the hospital is in its early stages and there have not been formal consultations with the community, only with local authorities. The site of the project is an area inside the existing hospital perimeter, in an area with main roads and residential buildings. Negative impacts on local community are not expected from this project. However, within the environmental plan for construction and as dictated by local legislation for the operations, the company will develop a Stakeholder Engagement Plan “SEP” (ESAP # 5), which will include identification of stakeholders; develop communication channels and a grievance mechanism and publicize its availability. The plan shall include the elements described under PS1 such as, identification of environmental and social impacts and effective community engagement to identify the communities potentially impacted by the project and to address community concerns during construction and operation phases.  This plan will be in place before commencement of the main construction phase. 

External Communications and Grievance Mechanisms: The Hospital has stablished and maintained a procedure for external communications during operations. During construction, the contract manager will develop a mechanism to receive and register external communications from the public in order to assess the issues raised and to provide responses; as needed the company will adjust the E&S management programs to address the community concerns.                                                   

The company has implemented programs for community benefit with free scientific and cultural activities and various donations, like collaboration agreements with the Ministry of Health, training programs and scholarship agreement for nursing students with the Government of the City of Buenos Aires.

Hugo García Artal

Director de Administración y Finanzas

Tel.: +5411 4827-7000 interno 2871    

Av. Pueyrredón 1640. Ciudad de Buenos Aires. Argentina  

Webpage: https://www.hospitalaleman.org.ar/