Environmental and Social Management Systems:
The company has a quality management system and related documentation in place which includes some environmental, health and safety (EHS) elements. While there are common principles across the group, specific policies and operational procedures are implemented at each country level, aligned with respective local context and regulatory requirements.
IDH is the only College for American Pathologists (CAP)-accredited diagnostics company in Egypt. Echo-Scan in Nigeria is currently ISO 9001-2007 (quality management) certified and planning to acquire ISO 14001 (environmental management) and OHSAS 18001 (OHS management) in the future.
In addition, there are country specific operational procedures to ensure compliance with local regulatory requirements. For instance, in Egypt, design of all the labs must fulfill requirement of the Ministry of Health in respect to space, electrical supplies, ventilation, water supply, equipment, decontamination equipment and infrastructure. The Mega lab in Egypt uses Honeywell operations system, which is an automated building management system that monitors temperatures, automated fire systems, efficiency of generators, all electric mechanical activity inside the lab, efficiency of air conditioning ventilation and units, and access control at entrances.
IDH’s operations in Jordan under “Biolab” brand are accredited by the Jordanian Ministry of Health, with two of its branches accredited with ISO 15189 (medical laboratories) and by Joint Commission International (JCI) and one branch received CAP accreditation in 2018. Echo-Scan in Nigeria has implemented ESMS since October 2017, that is generally aligned with PS1 requirements; and the company is gradually extending the corporate ESMS to all the facilities.
Going forward, the company will harmonize the current quality management systems and operational procedures across different countries to develop a fit-for-purpose corporate level ESMS, by implementing various actions as described in the following sections.
Policy:
As part of its quality assurance documentation, IDH has developed a safety manual that includes EHS policies and procedures for the Mega lab in Egypt. These include, specific standard operating procedures (SOPs) and forms related to lab operations (e.g. general precautions, biologic hazards, biological spills clean up, waste management, fire prevention and control, evacuation plan, etc.). In Nigeria, the E&S policy has been integrated into the ESMS. IDH has separate policies as part of its quality assurance and HR documentation. Building upon these policies, IDH will develop an overarching corporate E&S policy defining the objectives and principles that guide its operations to achieve sound E&S performance. The policy will also include a framework for the E&S assessment and management process, and commitment to comply with the applicable laws and regulations; and shall be consistent with the objectives of the Performance Standards (ESAP #1).
Identification of Risk and Impacts:
Risk and impacts are assessed as part of the quality assurance management system. In Egypt, E&S screening is carried out during the due diligence for acquiring other labs and/or companies. This screening includes checks on licensing from the Ministry of Health and any relevant environmental and safety related permits required by local legislation. The company also checks EHS related elements (e. g. ventilation, availability of establishing a hazard room, exhaust system) as required by local legislation / requirements. Going forward, IDH will update the current quality management systems to include a documented procedure to conduct E&S risk assessments and due diligence to assess the applicability of all the IFC’s PSs, to undertake the screening of future acquisitions and developments of new facilities or brands/companies in new markets (ESAP #2).
E&S Organization:
In Egypt, the E&S functions are carried out by several persons including the quality assurance manager, safety officer, HR manager, talent acquisition, and maintenance personnel. In line with IFC’S E&S requirements, Echo-Scan hired an EHS unit team lead, based at the regional office in Abuja, to oversees implementation and monitoring of EHS in all diagnostic centers. The lead is assisted by an EHS committee in each branch chaired by the head of radiology. In Jordan, there is at least one EHS officer in every branch responsible for all EHS tasks. The company’s E&S organization is considered to be appropriate to the nature and scale of the company’s operations. Similar fit-for-purpose E&S organization will be established in the assets that will be acquired or developed in the future.
Monitoring and Reporting:
The company in Egypt has established a monthly operations committee meeting where issues/EHS related incidents are discussed and presented to the management. The safety officer in Egypt ensures that all labs across Egypt are visited on a quarterly basis. There is a health and safety checklist that is used by the Ministry of Health (MoH) that is also used by IDH Egypt, covering fire alarm systems, fire extinguishers, compliance with waste disposal, and electricity consumption required to meet certain standards by the MoH. The Mega lab undergoes weekly audits by the safety officer, and the follow up actions are reported during the safety committee meetings.
Echo-Scan has a framework to monitor legal requirements and national compliance for all its branches. Recently, the company commissioned a consultant to assess key environment parameters around and within Echo lab facilities, provide the level of national and international compliance and outline corrective action plans where required. The parameters which were monitored included air quality, noise, potable water quality, and liquid and solid waste.
In Jordan, the quality control and safety coordinator in each lab is responsible for constant follow up with employees on any safety issues. In addition, he/she is responsible to highlight any new risk issues that may arise and communicate it to the quality assurance team. They report to the quality control head on a weekly basis during their meetings and report on any incidents, non-compliances, or EHS related issues at each of the labs. Currently, there is no formal reporting line on OHS issues to IDH headquarters in Egypt.
Emergency Preparedness and Response
The Egypt operations have an emergency preparedness and response plan (EPRP) that is specific to every type of lab, (A, B, and C). The EPRP mainly covers evacuation in case of fire hazard, hence it needs to be updated to incorporate all types of risks including earthquakes, riots, etc. The Nigeria operations are in the process of developing such an EPRP; as part of requirements under IFC’s existing investment. Jordan has a comprehensive EPRP covering all the operations.
COVID Response:
During the early months of COVID-19 pandemic, in order to retain people, the executive team members relinquished 40% of their own salaries to ensure all employees’ salaries were covered; therefore, none of the staff was financially affected. The company tried to increase cost savings by closing the HQ and having work from home modalities for those employees who could do so.
In response to the COVID-19 pandemic, IDH has taken several measures to ensure health and safety of its staff and customers by developing a Crisis Management Plan which includes: (i) temperature screening of employees and visitors; (ii) placement of hand sanitizers on each floor; (iii) hourly cleaning of doorknobs with water and recommended disinfectants from the Ministry of Health; (iv) closing the food cafeteria to minimize the risk of the infection; (v) communicated Crisis Management Documents to all IDH management team with weekly updates meeting; (vi) supporting pregnant women, mothers and employees with chronic diseases with leave priority; (vii) mandatory wearing of facial masks at all times; and (viii) enforcing social distancing throughout the facilities.
