Project land measuring 190,575 square feet (35 kanals) is owned by AHL and construction is underway with three of four basement levels completed wherein the teaching hospital and medical college have already commenced operations. The construction work will be limited within the existing premises and no new land will be required. The land for the project was acquired on a willing buyer willing seller basis through open market transaction, and site is located within urbanized/metropolitan area, in modified habitat The project will therefore not result in E&S impacts that must be managed according to PS5: Land Acquisition and Involuntary Resettlement; PS6: Biodiversity and Natural Resource Management, PS7: Indigenous Peoples and PS 8: Cultural Heritage. 

 This is a Category B project according to IFC’s Policy on Environmental and Social Sustainability as the E&S impacts are mostly site specific and localized and can be avoided or mitigated by adhering to generally recognized performance standards, guidelines or design criteria and adequately managed through the implementation of an expansion work specific Environmental and Social Management Plan.

Key environmental and social risks and issues identified include: i) the company’s capacity and systems to manage social, environmental, health and safety impacts during construction and operations, (ii) provision of fair and safe working conditions to its employees and contractors, including management of occupational health and safety, infection control and COVID-19 response measures iii) life and fire safety (LFS) management, iv) resource efficiency and (v) management of emissions and wastes including biomedical and hazardous waste.     

 Identification of Risks and Impacts:

As per the local regulatory requirement, the company commissioned an Initial Environmental Examination (IEE) study of the project which was approved by the local regulatory authority (EPA). The E&S assessments included a site specific qualitative and quantitative analysis. A process of stakeholders’ consultation was also carried out in due course of environmental assessment, wherein local residents, influential landowners of the area, representatives of union council, business and other vendors in the neighborhood were consulted. Overall consultation outcome was positive, with people looking forward to improvement in the quality of healthcare services in the city.

E&S Policy and Management System:

AHL’s EHS and Social management system (ESMS) includes an EHS Manual and several standard operating procedures (SOPs) specific to E&S, safety and security related matters. AHL also has a policy to extend the applicability of health and safety requirements to its patients, suppliers and contractors.

AHL’s ESMS is not certified for any international standards. Busines operations for NWGH are certified for ISO 9001 standards and has a system for internal audits. IFC is currently helping AHL to obtain Joint Commission International (JCI) accreditation for NWGH and NWSM (Academic Accreditation), through a separate advisory engagement.

Construction contractor for the project has prepared a project specific HSE policy.

Being part of overall Environmental and Social Management System, AHL will develop an overarching E&S policy (as described in ESAP #1) at the corporate level and ensure its applicability on all of its existing and upcoming facilities/projects (including NWTH) and will develop an operational phase EHS&S Manual specific to the NWTH project (as described in ESAP #2) .

HSE Team and Organization:

AHL has established Occupational Health Safety (OHS) and Environment Department, headed by Manager and includes Assistant Manager and two HSE Officers. All four positions are occupied by qualified and experienced personnel.

During construction of the projects, AHL will be responsible for procuring necessary permits, architect and engineers responsible for design, contractor(s) responsible for construction, and EHS section responsible for monitoring of EHS&S performance and implementation of EHS&S management plan.

As described in ESAP #3, the company will review the EHS related responsibilities and obligations under current operations and upcoming projects and develop a capacity building plan to formalize the oversight roles and responsivities of the corporate level team and establish EHS teams at each project/facilities level defining roles and responsibilities, organogram, functions, etc.

Emergency Preparedness and Response:

AHL has developed a “major incident plan” within the corporate emergency preparedness, resilience, and response (EPRR) program for the existing hospital and associated facilities. The emergency scenarios covered under this plan include: fire, earthquake, incidents caused by a violent person/intruder, spills, terrorism, civil unrest, accidents, flooding and natural disasters. Trainings/drills on fire safety, emergency preparedness and evacuation are organized in collaboration with Rescue 1122 (provincial government’s emergency response agency). Mock drills are conducted every 03 months. Firefighting trainings are conducted for biannually for each of the AHL entity.

The hospital will be provided with emergency power system (backup generators) normally located outside of the main hospital building for a 100% hospital energy load requirement.

During the COVID-19 pandemic emergency situation, NWGH managed to retain its business by establishing a well-equipped Covid-19 Ward. Specific equipment and machinery, including ventilators, monitors and PCIR machines, etc, were procured on priority basis to cater high influx of patients. AHL also provided Covid19 allowances to its employees working either in the Covid19 ward or in direct contact with the Covid-19 patients or engaged in Covid-19 test services. Later, with high influx of Covid19 a separate ward was established in Northwest Teaching Hospital (basement level 2). AHL’s significant achievements during the pandemic also include pharmacy medicine delivery services and the COVID-19 test drive-through services.

Monitoring and Reporting:

AHL has notified Audit and Risk Committee and has a procedure for conducting internal audits in context of company’s overall risk management system. All audits, monitoring, performance reports of the committee are reported to the Board of Directors. 

Environmental monitoring plan provided in environmental assessment report comply with the local regulations/standards and the monitoring and reporting requirements as per the local environmental quality standards. As part of ESAP #2, the Environmental Monitoring Plan under ESMP will be updated to comply with the WBG EHS Guidelines.

AHL will develop, as part of ESMP, a documented procedure to carry out review of all Management System at regular intervals to ensure continuing suitability, adequacy and effectiveness of each system to assess the opportunities for improvement and need for changes to the Management Systems.

AHL will monitor during entire construction process/phase the implementation status of the mitigation measures identified under the environmental assessment (IEE) report of the teaching hospital and share reports with IFC.    

As in March 2021 AHL’s combined staff strength is about 1856 including 438 females in NWGH, NWSM, NWIHS, NWTH and other common departments and services. The NWTH, after completion of expansion work, is expected to provide employment to around 3000 employees (including both clinical and non-clinical staff) along with 750 medical and 200 paramedical student enrolments.

Human Resource Policies and Procedures:

AHL has an HR management process for staffing the organization and managing its human resources which includes: ‘services rules, regulations and policy manual’. The HR Policy manual of AHL includes over 40 documents outlining the details about HR procedures being developed through an internal process of consultations and Board approval and keeping in line with labor & industry laws. AHL’s HR procedures are consistent with the requirements of the local labor law and IFC PS2.

AHL will develop, as described under ESAP #4, a corporate level HR policy statement specifying scope and applicability of HR policies and procedures to all of its institutions/projects including the teaching hospital.

All HR policies are placed in the library for full access of the employees. Updates to the policies are posted on the noticeboards and circulated via emails to all head of departments for general circulations. Orientation session are also arranged for new and existing employees. 

AHL has a Board of Directors comprising of 11 members. The Board oversee HR related matters through HR & Remuneration Committee.

AHL did not relinquish any of its staff during the COVID-19 pandemic crisis, however, implemented a policy of reduced working hours for the continuity of essential business operations in the light of government policy. The company had flexibility for the staff opting for flexible working hours or unwilling to service in COVID-19 wards. However, as an appreciation and encouragement, special COVID-19 allowance was introduced for the staff working in COVID-19 wards or engaged with COVID-19 related operations.

Workers’ Organization:

AHL has no registered labour union for collectively bargaining for employees. The company does not impede employees from exercising freedom of association and collective bargaining. AHL management engages with the employees through grievance redressal processes described in the following paragraphs.

Non-Discrimination and Equal Opportunity:

AHL provides equal opportunities for its employees. Process of hiring is conducted in each AHL institution through a committee headed by its CEO/lead person.  AHL’s policies are framed to develop non-partisan and gender sensitive working environment and provide equal opportunities to all employees to grow in their respective fields.

Protecting the Workforce:

There is no child or forced labor in AHL operations. Holding of national identity cards (issued at 18 years of age) is a mandatory requirement for any job at AHL.

Workers’ Grievance Mechanism:

AHL has a documented Policy of Grievance and communicated to the employees through documentation in HR policy manual. Employees are encouraged to discuss grievances with immediate supervisors, as level one redressal mechanism. A documented procedure is available for escalating concerns through a ‘Grievance Advice Form’ to manager HR, if employee remains unsatisfied with the level one mechanism. Complaint box is placed at reception to receive complaints from employees, patients, or community, including anonymously. The grievances are registered formally by the HR department and discussed at appropriate forum for redressal.

Occupational Health and Safety, Infection Control:

AHL has developed Healthcare Quality Assessment Tool that incorporates core international standards based on JCI standards and covers issues such as OHS and infection control. NWGH has Infectious Prevention and Control Manual to ensure that every employee understands and trained for standard precautionary measures as good international practice.

The OHS management / infection control program at AHL includes policies on disinfection, sterilization, hygiene and implementation of good hospital management practices that are required to prevent infections among patients, employees and surrounding communities.

AHL ensures that all incidents that occur during routine business operations are properly documented and reported, using ‘Incident Report Form’, and corrective/preventive actions are undertaken accordingly. Failure to report an incident is liable for disciplinary action. In the existing facilities, AHL has not recorded accidents/fatalities/injuries (including traffic accidents or those during construction).

AHL has a ‘permit to work’ procedure to ensure that tasks having OHS risks are conducted only by authorized persons at a specific time, under strict controls.

AHL has a policy of pre-medical fitness examination to ensure that employees engaged for healthcare services are fit for the job. Recommended pre-employment tests are conducted at NWGH at subsidized rates. 

AHL took complete responsibility of its staff’s treatment expense who got infected during their services at COVID-19 ward or related services. The staff was provided all the necessary PPE and was adequately trained for safety while treating patients in COVID-19 ward and for their family safety at home. AHL also initiated psychological support program where Psychologists were appointed for counselling of staff and patients during the pandemic crises and stressful situations.

Trainings:

AHL has a process to provide a two-day orientation program on its policies to its new inducted employees and annually for all employees. Trainings/drills on fire safety, emergency preparedness and evacuation are organized in collaboration with Rescue 1122 (provincial government’s emergency response agency). Mock drills are conducted after every 03 months. Firefighting trainings are conducted for biannually for each of the AHL entity. OHSE Department also conducts internal trainings for staff and workers on regular basis which includes sessions on infection prevention and control strategies, waste segregation, biomedical safety, crisis management and conflict management, prevention of traffic accidents, public relations, customer service, communication, etc.

AHL is conducting staff trainings during implementation phase of JIC International Patient Safety Goals (IPSG) which include developing policies, procedures and compliance tools.

Management of Third-Party Workers:

AHL has no 3rd party contractual staff in its business operations. All staff positions, including security personnel, are employees of AHL. However, the HR manual has a policy on engagement of contractual/temporary employment. AHL adopts same processing and procedures for selection and appointment of contract employees as applicable to the general cadre employees.

Construction would be carried out by workers engaged by the contractors. As project sites being located within urban areas, no workers camps would be developed at site. 

AHL will require the construction contractor to develop, as described under ESAP #5, NWTH project specific monitoring plan for construction safety and monitoring KPIs and would include provision for externa/internal safety audits.                                                  

Resource Consumption:

Energy: Primary source of energy at AHL is the electricity supply from the grid whereas diesel generators are installed as backup power supply. To meet the electric demand of the teaching hospital project AHL plans to install additional 4 generators of 1.25 MW capacity each and one generator of 500 KW capacity being operated on diesel fuel.

Water Supply: The current operations of AHL require approximately 400 m3 of water per day and is mainly used for heating, laundry, canteens, cleaning, washing, and in washrooms. Groundwater is extracted from boreholes installed within the AHL premises with permission acquired from the local authority.  Bottled water is used for drinking purposes. Reverse Osmosis units are installed for supply of purified water to some departments such as dialysis unit, operation theaters, labs, etc.

Resource Conservation:

At existing facilities, AHL has initiated replacement of conventional lights to LEDs and installation of sewage treatment plants with provision of reuse of treated wastewater. At the under-construction facility, resource conservation plans includes usage of LED lights, installation of double glazed windows to minimize heat losses, installation of water efficient plumbing fixtures and low flow taps, recycling of wastewater for use in cooling towers and horticulture. AHL also plans to initiate paper free working environment and use of solar energy at the new facility.

Under the energy conservation policy, AHL upcoming teaching hospital facility will have 33% LEDs and 66% conventional light sources with energy efficient sources.

The environmental assessment report for the project requires the contractor to monitor energy consumption during construction phase, set targets for reduction of energy use, and develop energy management plan.

Pollution Prevention:

Wastewater Treatment: The domestic wastewater generated mainly from canteen, washing, cleaning and washrooms is discharged into the public drainage network as per the permit condition. The project includes installation of a package type sewage treatment plant (STP) of 70 m3/day capacity, with provision of reuse of a portion of treated wastewater for horticulture needs. The infectious wastewater from the laboratory area, specific operational theaters and other sources, collected separately, would be diverted to neutralizing and disinfection tank through chlorine dosing before diverting to STP. AHL will ensure that the quality of the treated effluent released into the municipality sewers comply with the local standards and WBG Guidelines for disposal into the inland water / surface water as the sewers finally discharge the collected wastewater into the surface waterbodies due to non-availability of any centralized or municipal wastewater treatment system in the area. As described under ESAP #6, AHL will ensure that the STP is designed to meet the limits mentioned in Table 2 of WBG EHS Guidelines for Healthcare Facilities and to meet the requirements mentioned under WBG/IFC General EHS Guidelines for land applicability (for reuse) of the treated effluent. AHL will share the STP design with IFC. AHL will also acquire a performance guarantees from the STP supplier and/or the contractor to ensure compliance of installed STP with the designed parameters and discharge limits.  AHL has a procedure to store radiation waste at a separate containment from 2 to 45 days to reduce to safe half-life levels, as per the government regulatory agency policy.

Air Emissions: Air emissions sources at AHL include stacks of power generators which are monitored for basic pollution parameters (CO, SO2, NOx, PM) against the local emissions standards.

The EHS&S Management Plans for the project developed under ESAP # 2 will specify the parameters to be monitored in wastewater and emissions under the monitoring plan.

Solid & Hazardous Wastes: AHL has hired services of a private waste management contractor for collection, transportation and disposal of hazardous waste at their incineration facility, which is approved by the local regulatory authority. AHL has a process of waste segregation at source of generation and color-coded bags are used for non-hazardous (white bags) and hazardous/infectious waste (red and yellow bags). Sharps are stored in hard plastic containers. Infectious waste is collected on separate trolleys and stored in a temperature-controlled room.

AHL has a process for radioactive waste management as pre local regulatory requirements.

Hazardous Materials Management:

Hazardous Materials:

AHL has a Hazardous Materials Program which provides guidance for the management of hazardous materials in laboratories and other associated areas. It provides information to the workers/staff about health effects to exposure to hazardous substance, provides techniques for safe handling, and requires regular monitoring of workplace. The procedure requires placement of Material Safety Data Sheets (MSDS) at the department level, where the chemicals are handled and used.

In the construction process, the project has prohibited usage of high alumina cement, asbestos in any form, Lead based paints, and any other material not in accordance with the recommended good building practices.

Pesticide Use and Management: The Company has a policy on pest management and has hired a professional contractor services for insect/pest control and fumigation/spray in AHL facilities.

GHG Emissions:

GHG emissions for the AHL is mainly from operations of power generators and grid supplied electricity. Based on electricity consumption estimates, GHG emissions from the AHL facilities will be below 25,000 tons of CO2-equivalent annually.                                                  

Infrastructure Design and Safety:

AHL facilities are located in urban city centre and are easily accessible by the general public. AHL complies with Pakistani structural, seismic and fire safety codes for the design of new facilities and for the improvement of existing hospitals and other facilities, including student accommodations (dormitories) and other educational and assembly occupancy areas of the complex (i.e large classrooms, auditoriums, restaurants, retail establishments and exhibition halls, among others). NWTH will be designed and constructed to provide universal accessibility measures and to facilitate the mobilization of patients, including ramps and elevators for easy access. The radiology areas of the future facilities will be planned considering the requirements of the local authorities and good international industry practices. The company normally engages specialized professionals to verify compliance with radiation protection measures as per local laws.

AHL facilities have access control at all entrance gates and have parking facilities within the facility premises. Traffic disruption on the adjoining roads have been addressed in NWTH with development of a parking area in the basements.

Life and Fire Safety

The requirements of L&FS are aligned with corporate guidelines and local legislation for patient safety and quality of the medical service. The design of the future hospital follows the requirements of the local fire and construction codes. and includes provisions for fire resistance rating (enclosed) emergency exit staircases, fire detection and alarms and fire protection elements (e.g. fire extinguishers, standpipe and fire hose reel systems). The company engages specialized architecture and engineering design companies with recognized experience in healthcare facilities.

Under ESAP #7, AHL will engage the professional services of a qualified L&FS engineer to prepare a “L&FS Master Plan” in line with local fire safety regulations and an Internationally recognized L&FS code, that will have mandatory provisions for the use of adequate fire compartmentation for all patient areas, smoke control (e.g. stair pressurization system), fire sprinkler system,  and suitable means of egress in all areas of the hospital. Additionally, upon physical completion of the hospitals, the company will engage the L&FS engineer to verify the final post-construction conditions and certify that the facilities were constructed as designed, following the approved L&FS Master Plan.

Security Management:

AHL has a security policy in place to plan and manage the security of staff, patients, visitors, buildings and related infrastructure. Procedures has also been developed to respond to the risks of active shooter/hostile intruder, bomb threats, demonstrations/protests or civil disturbance in the campus or the hospital facility.

AHL employs about 146 security personnel (including 5 females) to manage the security of its four institutions some of whom are armed. Security team is headed by a Manager Security, who is an ex-police cadre senior officer. AHL has a process for screening the security personnel at hiring stage which includes verification from local police station. AHL security team includes majority of retired forces personnel which are aware and trained on use of arms.  Inhouse training sessions are conducted regularly for the security team. AHL has dedicated room for security management and premises remain under CCTV surveillance 24/7 by security personnel.

AHL will document a specific security policy/Code of Conduct, as described under ESAP #8, consistent with the requirements of PS 4 and aligned with Voluntary Principles on Security and Human Rights (http://www.voluntaryprinciples.org). This will include the guards’ behavior with the patients and their attendants, community, workers and clear guidelines on use of arms. The policy shall be communicated to the security guards as part of the induction as well as refresher trainings.                                                  

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