PS5: Land Acquisition and Involuntary Resettlement is not applicable as the project sites have been purchased on a willing buyer, willing seller basis and the sites have no encumbrances. PS6: Biodiversity Conservation and Sustainable Management of Living Resources does not apply because the project sites are located in urban centers with commercial buildings and residential housing with no significant biodiversity values. PS7: Indigenous Peoples and PS8: Cultural Heritage do not apply because the project will not cause any impacts on indigenous people and the presence of cultural artifacts is unlikely. 

    This is a Category B project according to IFC’s Environmental and Social Sustainability Policy. Based on information reviewed by IFC, this investment will have limited adverse environmental and social risks and impacts that are few in number and site-specific, with construction impacts mainly being short term and not significant. Operational impacts are expected to be generally site specific and can be avoided or mitigated by adhering to recognized performance standards, procedures, guidelines and design criteria as described in the following sections. Fulfillment of the action items included in the attached E&S Action Plan (ESAP), adherence to the national laws and regulations, internationally recognized standards, like the WBG EHS General Guidelines and EHS Guidelines for Healthcare facilities will facilitate the project implementation in a sustainable manner.

Key E&S risks and impacts associated with the project include; the implementation of environmental and social management systems, the hospital’s capacity to assess and manage E&S risks and issues associated with its operations and during construction; provision of fair and safe working conditions for its employees and contractors including Occupational Health and Safety (OHS) policies and practices; resource efficiency measures, healthcare waste and wastewater management in compliance with applicable WBG EHS Guidelines and the company’s stakeholder engagement activities.

   Environmental and Social Assessment and Management Systems:

NCHS holds environmental permits for all its facilities from the Environmental Protection Agency. For the new construction that will be undertaken at Ashiaman, Michel Camp, Tema and Afenyo, NCHS will commission a suitably qualified and experienced consultant to undertake Environmental and Social Impact Assessments (ESIAs) in accordance with good international practices and in line with the requirements of IFC Performance Standards (ESAP 1). The ESIA will cover labor and OHS issues during construction. The ESIA report along with the Construction Environmental Health and Safety Plan (CEHSP) will be submitted to IFC for review prior to commencement of construction.

To lead and institutionalize quality improvement in healthcare for its customers, NCHS adopted the SafeCare quality improvement methodology and standards https://www.safe-care.org/, accredited by the International Society for Quality in Healthcare (ISQua). The SafeCare standards are accredited clinical standards tailor-made for resource restricted settings. They create a common language and ensure quality is measured against international standards, while leaving room for more local adaptions. NCHS has undergone the rigors of quality assessments, training, management improvement, documentation and implementation of the SafeCare standards at all the facilities and have achieved Level 3 out of 5 in the SafeCare accreditation journey at each of the facilities as at March 2019. Level 3 certification is medium quality strength rating and implies that each of the facilities is accustomed to operating according to standardized procedures and has started to monitor implementation of the management system and standards. NCHS has indeed developed a Quality Management System (Quality Manual) that complies with the requirements of SafeCare standards. In accordance with ESAP 2, NCHS will revise the quality manual to integrate environment and occupational health and safety aspects and objectives in compliance with IFC PS 1 requirements.

Policy

NCHS has an Occupational Health and Safety (OHS) Policy that guides health, safety, environment and social performance of its operations. The Policy objectives cover all inherent risk areas and outlines management responsibilities for different risks. The Policy also covers temporary and contracted workers. Interviewed workers exhibited good understanding of the Policy. NCHS will continue with sensitization activities on the Policy to the recently recruited workers.

Identification of Risks and Impacts

The company has developed a corporate risk management procedure to guide the management of quality, environment and social (E&S) risks and impacts in the various facilities. The Risk Manager is responsible for overseeing its implementation. The hospital has also conducted risk assessments for each of the facilities, and developed risk registers whose implementation is overseen by the facility operations managers. The risk assessment is guided by the business objectives and priorities, identified risks are documented and addressed on site, while major risks are upscaled for management interventions, especially where additional resources are needed to address the risks. NCHS conducts regular facility audits and updates the risk registers after each audit, incorporating any new risks.

Management Programs

NCHS’s risk management program is implemented at each facility and includes; the development and implementation of risk registers, development and implementation of annual Quality Improvement Plans (QIPs), on-going on the job risk management training and monitoring. In addition, the company has developed and implements the following programs across all facilities; a fire and life safety program, occupational health and safety (OHS) program, healthcare waste management program, security risk management program, access control systems at patient care areas, handwashing and sanitizing program and an infection prevention and control program.

For the new facilities to be constructed and for the proposed rehabilitation of existing buildings, construction environmental, health and safety (CEHSP) plans as per ESAP 1 will be developed from ESIA studies to guide in the management of potential risks and impacts during construction. The construction EHS plans for each facility will be implemented as part of the NCHS management programs and reviewed as necessary to cover new risks.

Organizational Capacity and Competency

NCHS Director of Operations is responsible for overseeing the implementation of the Quality Management System (QMS), including coordinating quality audits and implementation of Quality Improvement Plans (QIPs). The hospital also has designated a Risk Manager in the Audit department to oversee the implementation of the Risk Management Procedures. Operation managers at each facility oversee risk management at their respective facilities. These officers understand the general EHS risk management aspects but need further competence enhancement on assessment of environmental and social risks and occupational safety and health. As per ESAP 3, NCHS will designate a quality, health, safety and environment (QHSE) manager to co-ordinate the day to day implementation of the quality, health, safety and environment management system with the respective facility operations managers and report to the Director of Operations. The designated officer will need training on EHS.

The Human Resource (HR) department develops and implements a training plan annually. The 2019 training plan was approved by management and is being implemented by the company. Staff are trained periodically on quality and risk management aspects relevant to their facilities as required by the SafeCare standards. Training topics include quality assurance, health and safety, infection prevention and control, healthcare waste management, fire safety, management of spillage among other on the job trainings and refresher courses. Staff training schedules and evidence of training is kept on personnel file.

Emergency Preparedness and Response

A description of the general emergency response procedures at corporate level are found in the corporate OHS policy and procedures documents. The company has also developed a corporate life and fire safety manual. At the facilities, emergency numbers are posted on notice boards and emergency equipment (alarms, signs) are in place. According to ESAP 4, site specific Emergency Response Procedures will be developed for each hospital considering all possible emergencies that may occur on site. The emergency procedures will include site-specific decision-making procedures, communication plan to staff and patients, evacuation procedures and provisions for care for inpatients (including back-up facilities, medication, transport etc.) to ensure safe continuity of care. NCHS will also review the locations and materials used for emergency signage at each facility, to ensure that signage locations are strategic and that they are clearly visible even in darkness. 

Monitoring and Review

NCHS conducts daily safety talks before work to raise any risk-related issues at each facility. In addition, the operations managers at each facility monitor, review and track the implementation of issues raised in the risk registers. Internal quarterly monitoring and annual audits of the QMS and agreed QIPs is done by the quality improvement teams at each facility. External monitoring is done by SafeCare assessors who monitor the implementation of the improvement plans using two approaches; monthly (remotely) via phone calls and updates on a WhatsApp page and quarterly via facility site visits to confirm the updates provided through remote monitoring also provide support to the staff in handling any challenges on implementation through facilitation. The internal and external monitoring reports are collated by the Director of Operations and discussed at the NCHS Board.

External communications and Grievance Mechanisms

NCHS has public suggestion boxes, complaints hotline numbers and grievance books at each of the facilities. These are primarily to receive comments and complaints from patients or visitors. The Medical Officers at each facility are charged with recording and addressing or escalating comments or grievances received in a log book and provide feedback to complainants. As part of the stakeholder engagement plan and as per ESAP 9, NCHS will revise the complaints management procedure to provide clear instructions on how to handle, document analyze and prepare a report on E&S complaints including maintenance of records received and the resolution of the complaint.  

    NCHS currently employs approximately 431 staff across its facilities. Of these, 292 are female and 139 male staff. The company has 47 staff in management, 10 female and 37 male staff. There are 15 part time clinical staff (mostly mid-wives) and 21 contracted staff outsourced from a cleaning company that provide services to the facilities.  With the new construction of clinical space, renovation and expansion of facilities, it is envisaged that the staff numbers will increase in the short term.

Human Resources Policies and Procedures

NCHS has developed a Human Resources (HR) policy and procedures manual. The HR manual has provisions on general conditions of service (working hours, performance appraisal, leave, duration of probation), non-discrimination and equal opportunity, recruitment, promotion (required competencies and qualifications for promotion), overtime/ locum policy, staff development and training, disciplinary, demotion, grievance procedures, termination and annual medical examination policy.

Working Conditions and Terms of Employment

All employees have formal written contracts provided upon recruitment and the terms of service are explained during staff orientation. The contracts describe the role or function of the employee, working conditions and terms of employment.

The company provides medical coverage for employees and registered dependents, payment of allowances (travel, housing) and education sponsorship for staff. The working hours are based on the national legislation, which is a maximum of 40 hours a week in shifts. All employees are entitled to annual leave. Female employees are entitled to annual leave plus 12 weeks paid maternity leave and all staff are entitled to sick leave according to national law. NCHS is in the process of revising the HR manual to include detailed leave policies, sexual harassment policy and update the disciplinary and termination procedures in alignment with national legislation and IFC Performance Standard 2 requirements (ESAP 5).

Workers Organizations

NCHS recognizes and respects workers’ freedom of association and right to collective bargaining. The company staff, including third-party workers, have formed a welfare association to address their workplace issues. The association has elected their representatives. The hospital management informally acknowledges the welfare association and addresses issues raised from the welfare meetings. The workers, though informally allowed by the hospital management, have not joined the national unions. According to ESAP 5, the revised HR manual shall include explicit language recognizing workers’ rights to freedom of association and collective bargaining. 

Non-discrimination and equal opportunity

NCHS is an equal opportunity employer and the company does not discriminate on the basis of sex, ethnic background or religious and social affiliation. In accordance with ESAP 6, the company is updating the HR manual and procedures to include measures to prevent and address harassment, intimidation to employees, especially women.

Grievance Mechanism

NCHS has developed a workers’ grievance procedure that outlines the grievance management process for individual and group grievances, including feedback timelines. Staff interviewed during the appraisal were aware of the grievance process, including the approval to raise any issues on the WhatsApp communication platform. In accordance with ESAP 5, the company will revise and enhance the grievance procedure to allow staff usage of the hotline numbers and suggestion boxes for raising any anonymous grievances. The application of the grievance mechanism will be extended to contract or third-party workers at all NCHS facilities.

Protecting the workforce

The minimum age for employment in Ghana is 18 years. Ghana Labour Law prohibits employment of child labor (young persons between 18 and 21in hazardous work environments) or forced labor. The company’s employment screening requirements for potential employees include verification of birth certificates and national identity cards, which are only issued to persons 18 and over.

Occupational Health and Safety

NCHS has conducted risk assessments at each facility and designated teams to address risk management measures. Various clinical safety procedures have been developed to protect the workers and visitors from injury, illness or impacts associated with exposure to hazards encountered in the workplaces. Periodic SafeCare quality and risk management training is provided to workers. OHS incidents are recorded and reviewed by the hospital management. As already indicated, NCHS has an OHS policy and program covering a broad range of risks, mitigation measures and guidelines proposed to protect the healthcare workers at the facilities and provide a safe work environment. Some of the aspects covered by the program include routine medical surveillance of staff that are at high risk of exposure, prevention of communicable diseases, infection prevention and control, use of personal protective equipment, containment of spillages, decontamination of procedures, procedures for post exposure prophylaxis, prevention of alcohol and drug abuse and management of contractors at the healthcare facilities.

During construction of the new facilities and remodeling of the existing clinics, the company requires contractors to follow the national regulations related to environment, occupational safety, and fire safety as well as the company’s EHS policy and procedures. These will be elaborated in the CEHSP as per ESAP 1.

Workers engaged by third parties

The contracted workers, especially the cleaners, are integrated into the NCHS workforce without any discrimination. NCHS has formal contracts with their parent companies. The hospital will review the contracts to include E&S requirements as conditions to engaging third parties and conduct regular due diligence on their management operations to eliminate possible reputation or legal challenges as part of ESAP 5.  

   Resource efficiency

NCHS is committed to design the new hospital buildings to achieve international standards and adhere to IFC’s Excellence in Design for Greater Efficiencies (EDGE) program to ensure optimal use of energy, water and materials in the project.

Energy consumption: The company relies on electricity from the national grid, supplied by the Electricity Company of Ghana. Each facility has a stand-by diesel generator for use, with their capacities varying between 20-60kVA. None has reached 500 hrs a year. The hospital is installing QlikView dashboard, a software that will be used to track consumption of utilities against costs and gain factual data for strengthening energy conservation measures. At present, some energy conservation measures exist, especially related to managing timeframes for use of computers, TV sets, lights and AC equipment. In addition, NCHS has plans to install solar panels at some of the facilities to reduce on energy costs.

Water consumption: Water is supplied by the Ghana Water Company, a government utility. Each facility has water storage tanks to cater for any emergencies. Water is metered, and soon will be upgraded into the QlikView dashboard. Staff members has received trainings on water conservation, and visitors are provided with hand washing areas with prescribed volumes of water in improvised tapped drums.

Greenhouse gas emission

The current greenhouse gas (GHG) emissions mainly related to electricity, generator and ambulance use, are deemed to be relatively insignificant. GHG emissions from the NCHS operations are less than 25,000tCO2eq/annum. NCHS will, however, harness solar power to provide alternative clean energy to supplement grid electricity and reduce possible reliance on the generators during outages.

Pollution prevention

The main pollution sources include generator use, healthcare wastes and wastewater. Generators are only used occasionally, so no significant air emissions are expected. NCHS manages healthcare wastes and waste wastes as described below to prevent/minimize possible land or water pollution.

Solid wastes

The company has developed and implements a healthcare waste management policy, plan and procedure across all facilities. Colour coded bins for the different waste types were observed during appraisal and staff were trained and are aware of the waste segregation procedures and protocols. The waste management plan maps out the sources of waste generation, segregation into waste types, containerization into colour coded waste bins, secure storage, transportation, treatment and storage. The company has contracted a licensed and accredited waste management company to collect, transport, treat and dispose of the waste. Expired drugs are shipped back to Ghana Health Service Department for safe destruction.

Wastewater

The main sources of wastewater at the facilities are sanitary wastewater (black water), minimal laundry wastewater (laundry is sub-contracted to an off-site commercial laundry facility), laboratory waste and runoff. Facilities segregate contaminated streams and disinfect them to ensure there is no biological contamination. At most of the facilities, all these streams of waste water are directed to closed prefabricated separation chambers, where the liquid part flows off and is redirected out into the municipal sewers, while the sludge is retained and exhausted after some time. In a few facilities, the wastewater is directed into septic tanks, and exhausted periodically. NCHS will ensure that the waste water treatment plants (WWTP) for the new buildings are designed to meet the WBG/IFC’s EHS Guidelines or the local regulations, whichever is more stringent (ESAP 6).

Hazardous Materials Management

The main hazardous materials handled at NCHS include soiled linen, sharps and other used clinical materials, wastewater and expired drugs. As indicated above, these materials and wastes are generally well handled at site. 

Pesticide use and management

NCHS has a set of Procedures that cover pest management alongside general cleaning activities.  

  Infrastructure and equipment design and safety

The new hospital buildings will be designed and constructed by competent professionals. The proposed new hospital buildings and renovation of existing buildings will comply with Ghanaian building requirements, fire department regulations and other related legal requirements. Since the new hospital buildings, particularly Ashaiman and Tema will be accessible to the public, they will be designed, constructed and operated in accordance with the requirements of the L&FS section of the WBG General EHS Guidelines which includes compliance with internationally accepted life and fire safety (L&FS) codes (such as NFPA 101). NCHS will engage an expert in international L&FS standards to prepare (ESAP 7) a L&FS Master Plan for the project, and upon physical completion of the building, to verify that the systems were installed as designed in accordance to the L&FS section of the WBG General EHS Guidelines. Under (ESAP 8) the L&FS professional will provide the certification, affirming that the L&FS systems were installed as designed and are properly tested.  If the certification is not issued, then a corrective Action Plan with proposed completion dates and expected metrics shall be submitted to IFC. The standard specifications will include operational and maintenance guidance, such as the preparing of schedules for mandatory regular maintenance and testing of life and fire safety systems and regular fire drills.

Security personnel

Most of the hospital facilities are in populated residential and mixed-use areas. Crowd management is therefore a likely security risk. NCHS employs unarmed security guards to manage access control and emergency response. The company has developed a corporate access control policy from their security risk management process and established guidelines for access control. The security guards are well trained on crowd management and customer care. NCHS will enhance the access control policies by developing a written procedure for reporting safety and security issues as per ESAP 2.  

    NCHS regularly engages with the regulatory agencies and occasionally with the communities though CSR activities. The CEO and his management team also engage different stakeholders on ad hoc bases. The company will develop a corporate Stakeholder Engagement Plan to formalize all stakeholder engagement activities, as required in ESAP 9.

Stakeholder engagement will also be conducted during the ESIA process for the new buildings, with communities neighboring the facilities, local government authorities and relevant non-government entities. 

 Contact Person: Dr Wisdom Amegbletor

Company Name: New Crystal Health Services Limited,

Address:  P.O. Box 540 Ashiaman, Accra, Ghana.

Email: wisamegbet@gmail.com

Phone: +233 544 347 237 / +233 501 264 598