IFC’s appraisal considered the environmental and social management planning process and documentation for the Project and gaps, if any, between these and IFC’s requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and (if applicable) in an agreed Environmental and Social Action Plan (ESAP). Through implementation of these measures, the Project is expected to be designed and operated in accordance with Performance Standards objectives.
PS1: Assessment and Management of Environmental and Social Risks
The project has progressed with construction and is close to commissioning. Staff have been hired for the relevant functional teams; a comprehensive set of policies and procedures are to be put in place.
As per ESAP # 1, the Sponsor will develop a Corporate E&S Policy statement specifying scope and applicability of policies and procedures for the existing and new projects. The policy will guide development of a corporate level Framework for Environment, Health, Safety and Social Management System (ESMS) in accordance with the requirements of IFC Performance Standards, and relevant World Bank Group (WBG) EHS Guidelines such as General Environment, Health, and Safety (EHS) Guideline and EHS Guidelines for Health Care Facilities. The framework ESMS serves as a platform for the Sponsor to guide development and / or update of the project-specific environmental social management plan (ESMPs) for construction and operational phases, as further discussed below.
NHPL has developed an E&S Policy statement, generally in line with the requirements of IFC Performance Standards, WBG EHS Guidelines and applicable Pakistani legislations. NHPL will update its E&S Policy, as needed, to be aligned with that of the Sponsor’s E&S Policy (ESAP #1).
The management system to be developed in NHPL will cover aspects like environmental, quality and safety, food safety and will be aligned with IFC PSs and WBG EHS Guidelines for Health Care Facilities. The company is planning to achieve accreditation by JCI (Joint Commission International, an international standard for hospitals) and ensure high level of clinical hygiene and infection control.
The company will also, as per ESAP #2, develop a Health Care Waste Management System and Plans (HWMSP), adequate for the scale and type of activities and identified hazards as per WBG EHS Guidelines for Health Care Facilities. Typical HWMSP should include the following components: waste minimization, reuse, and recycling, waste segregation, on-site handling, collection, transport and storage, transport to external facilities, treatment, and disposal options.
Identification of Risks and Impacts:
The company has hired an independent EHS consultancy to prepare the Environmental Impact Assessment (EIA) report, which has gone through the 30 days public consultation process with a public hearing that took place on August 8, 2024; the EIA has been approved and a permit obtained by the local authority (EPA). Quarterly EIA compliance reports are submitted on time to the Pakistan EPA, fulfilling the legal notice of compliance (NOC).
Imperial NHS Trust has been engaged during design and planning phases to provide expert review and input on designs and plans pertaining to architectural design, clinical services, medical equipment, technology and systems, and staffing.
As a part of evolving ESMS, NHPL developed ESMP (Environment, Health, and Safety / Occupational Health and Safety (EHS/OHS) Plan) designed to manage all on-site construction related risks, and to safeguard the well-being of all workers, contractors, and other stakeholders. This plan remains adaptable to evolving site conditions, aiming to proactively address and mitigate risks to personnel health, safety, and the environment throughout the construction process. This plan will be updated for the operations phase (ESAP #2).
Organizational Capacity and Competency:
NHPL current EHS operations are managed through few core functions, which include office of Project Director, Project Manager, Assistant Manager for quality assurance / quality control (QS/QA) division, Human Resources (HR) Manager. Project development and risk associated with EHS aspects are managed via three level control mechanisms, which include consultants and contractors EHS teams, NHPL project management team and third-party EHS/OHS consultants and certification bodies.
All major consultancy assignments have been contracted as of January 2024, including the Project Management, Lead Design Consultant, Traffic Consultant, EHS Consultant, Geotechnical Consultant, Structural Engineering Consultant, Mechanical, Electrical, and Plumbing (MEP) / Heating, Ventilation, and Air Conditioning (HVAC) and Life & Fire Safety Consultant.
The Project Director is responsible for all in-house and vendor social and environmental topics related to the construction and fit-out until the site is commissioned, which is currently planned and expected by September 2026. The HR Director is responsible for all social and environmental topics pertaining to NHPL direct employees and the Corporate Office location, which primarily employee OHS, security, emergency preparedness, and managing employee & vendor grievances. Since NHPL is currently a small team, the CEO covers all other topics such as land acquisition, and ethics management. Management of the contractor is defined by EHS/OHS Plan i.e. health and safety requirements for the contractors are part of the bidding processes and are contained in the contractual documents including commitments for resources covering health and safety functions on the site, and specific organizational assignments.
As per ESAP item #3, the Company will document EHS related responsibilities and obligations for the operation phases and develop a capacity building plan by defining roles and responsibilities, organogram, functions, and authority to implement and improve its ESMS.
As part of the construction ESMP (EHS/OHS), the company will monitor implementation of mitigation measures. Once the project is operational, training will be conducted on a quarterly basis. All audits, monitoring, and performance reports undergo management review and overall monitored by the Quality Council on a quarterly basis.
The company has an emergency preparedness and response plan (EPRP) for construction covering the event of injury, fire, or any other emergency. Before starting the operations, as per ESAP #4, the company will develop and implement the EPRP for the new hospital and feeder clinics, addressing the foreseeable risk scenarios (e.g., fire, earthquake, civil unrest, flooding, etc.), focusing on patient safety, and mobilization of patients during emergencies, shelter-in-place procedures, or total evacuation of the hospital. The EPRP will include clear definition of the responsible in charge of ordering the evacuation, training plans on emergency evacuation and use of firefighting equipment, process to get support by first responders (e.g., fire department, police) and other applicable aspects identified in the planning process.
In addition, as per ESAP #5, the client will conduct a detailed climate change risk assessment (CCRA) of climate change impacts on physical assets and on workers’ occupational health and safety and the environment and will develop mitigation plans as needed. The climate change risk assessment will be integrated into the client’s existing risk management systems.
PS2: Labor and Working Conditions
As of October 2025, the company has 35 full time employees (FTE) and three advisors. The hospital and feeder clinics once completed and commissioned (planned for September 2026), will, towards the end of 2027 have approximately 700 full time employees.
NHPL HR policies and procedures related to employment rights if and to the extent applicable under local law (hours of work, overtime, labor rights), child labor, forced labor, non-discrimination and equal opportunities, diversity and inclusion, gender-based violence (GBV) / workplace harassment, freedom of association and collective bargaining are being developed. Approximately 30 HR Policies & Procedures will be developed in the next 12 months, which will define functional responsibilities among different departments for management of relevant EHS and HR aspects. NHPL employees are/will be issued with a standard employment contract. NHPL will develop and publish an Employee Handbook, to include information on terms of employment, such as types of contracts, workhours, compensation, benefits, rights and responsibilities, disciplinary procedure. Through NHPL internal grievance mechanism (GM), workers (both direct and indirect employees like local and migrant workforce employed via the contractors) can raise issues and complaints related to employment under NHPL’s policies and procedures and as per provision of IFC PS2.
As per the ESAP #6, NHPL will update / develop its HR policy and procedures, in line with IFC PS2 requirements, including (but not be limited to) updating of its workers (GM to include patients and their companions, include issues of GBV and sexual harassment, and effectively communicate these changes to employees, as further discussed below. In addition, HR policy will be adequately reflected in their employee guide, employee contracts and induction training courses, with relevant measures to supervise the implementation and compliance.
Contractors are not allowed to hire workers below 18 years of age and that provision is a part of their contract with NHPL. Identification verifications and record keeping related to age is part of the contractors’ contracts. While NHPL contractors are not expected to hire migrant labour, provision for labour rights (referring also not to employ forced and/or trafficked person), safe and secure working environments for all workers including migrant, if employed, will be incorporated to HR documents (ESAP#6) and monitored by the company as per construction ESMP (EHS/OHS).
ESMP (EHS/OHS) plan for construction phase is developed and made part of current tenders / contracts. Each contractor is also responsible for further developing this plan based on method statements of his activities. For the operations phase, OHS aspect related to e.g. falls, needle stick injuries, management of infectious diseases, radiation exposure, spills, etc. will be part of the hospital safety manual which describes procedures on risk management and safety aspects. A set of OHS trainings will be provided to NHPL workers (safety training, personnel security, safe handling of tools and equipment); healthy working conditions and appropriate Personnel Protective Equipment (PPE) for the workforce will be provided (sterilization equipment in laboratories, respirators, medical computer screens lighting, air conditioning). The NHPL will use the same protocols and standards (with adaptation to local context where required), guidelines and clinical Standard Operating Procedures (SOPs) as Imperial NHS Trust Hospitals in London.
As of October 2025, there are almost 350 workers and managers from the Engineering, Procurement and Construction (EPC) at the hospital construction site. The workers and managers do not reside on the site but commute daily in and out of the site. The construction contracts, have provisions, including responsibilities for waste management, labour and working conditions on-site, providing safety equipment for their workers and liabilities for any damages or work-related injuries. In addition, the company required the EPC to implement a heat management procedure to protect workers from heat stress.
The EPC EHS Officer provides all workers with a formal presentation of project safety and health expectations and plans; toolbox meetings are typically conducted once each week. For activities which require specific safety training such as confined space entry, scaffold erection, and fall protection, the EPC prepares documentation confirming that all affected employees have received training in e.g. use of PPE, accident / incident reporting, emergency responses and site evacuation procedure. No fatalities reported during the construction. Seven minor incidents were recorded which are all classified as minor and logged via the Company’s Pro Code online system with root cause analysis and corrective actions. First-aid facilities are available on-site, supported by OHS signage, ongoing training, and awareness programs, with records maintained. The company, via its independent engineer, oversees execution of technical work and implementation of certain EHS requirements as per national requirements and good international industry practice (GIIP), and will keep statistics and report any accidents during construction to IFC.
For the operational phase, the company will hire third party service providers for cleaning, gardening, catering where it will require the agencies to adapt and implement NHPL’s HR policy and procedures in addition to national labour law requirements.
PS3: Resource Efficiency and Pollution Prevention
The company will consume diesel, electricity, and eventually natural gas, and it will, on an annual basis, quantify the hospital related operational greenhouse gases emissions in accordance with internationally recognized methodologies and report to IFC on its annual monitoring report.
For the construction of the hospital, NHPL is responsible to ensure that the site is supplied with (i) potable water through water tankers for construction activities and human consumption and (ii) electricity from the city utility companies or from diesel generators. Sanitary wastewater is discharged into the on-site septic tanks to treat sewage generated by the camp. For the construction equipment and vehicle, around 1000 litres per day of diesel is consumed during the peak construction period. Air emissions during the construction phase are mainly from mobile construction machinery and are not expected to be significant. All hazardous and non-hazardous wastes are collected for disposal by authorized public service agencies specialized in each type of waste. Construction waste management plan with maximum target waste, which goes to landfill is expected to be below 2.5 lb per sq ft.
During the operations, uninterrupted power supply, particularly for operating theatre, recovery room and outpatient clinics will be provided from the national power grid via a dedicated power line and low emission generator sets system, as needed. In addition to conventional power supply, the client will install approximately 0.6 MWp solar PV on the roof of the main building and car parking in the hospital. This action will reduce GHG emissions by approximately 420 tons of carbon dioxide gas equivalent emission as compared to the traditional energy mix of Pakistan. The diesel tanks to supply generators will be built as per ESAP # 7, underground and constructed as per WBG General EHS Guidelines; Underground Storage Tanks and / or Good International Industry Practice (GIIP).
Noise pollution from backup generators or HVAC equipment will be avoided by placing equipment indoors away from occupied areas and/or with sound attenuating canopies. All equipment will be designed to meet national and /or relevant WBG General Environmental, Health, and Safety (EHS) Guidelines: Environmental Noise Management.
The hospital will have an onsite water treatment facility. Excessive water and energy use will be prevented by (i) a combination of air cooled chillers and variable refrigerant flow - direct expansion (DX-VRF) systems to reduce water consumption and by selection of water efficient lab equipment and low flow domestic water fixtures; and (ii) selection of highly efficient HVAC systems i.e. operational loads/cost of major systems/equipment like elevators, generators, water treatment plants, medical equipment are expected to be part of evaluation criteria at the time of selection and purchase.
As per ESAP item #8, NHPL will install a wastewater treatment plant, to treat its wastewater before discharging to municipal sewage systems. The treatment system specifications and operational performance will be in line with the requirements specified in World Bank Group’s (WBG) EHS Guideline for Health Care Facilities and/or national maximum allowable limits as per National Environmental Quality Standards (NEQS) (whichever is more stringent).
Nonhazardous solid wastes will consist of domestic waste generated during administrative, housekeeping, and maintenance functions, which will be collected separately, and disposed by city utility on the central municipal disposal site. The management of hazardous wastes, including medical wastes, will be conducted by the hospital infectious control team, which will be trained and adequately equipped with proper PPE. Such waste will be collected daily in special bags or hard plastic containers (sharps, needles) and disposed temporarily in a locked cool storage area with limited access, awaiting final disposal. The client will have in place an infection control system and medical waste disposal protocol / standard for management of hazardous waste. The company will hire an authorized agency to collect and dispose healthcare hazardous waste in an off- site licenced incinerator that complies with emission as specified in WBG's EHS Guideline for Health Care Facilities and will apply the “principle of duty of care” i.e. obtain chain of custody documentation to the final destination. Radioactive wastes include solid, liquid, and gaseous materials that have been contaminated with radionuclides originates from activities such as organ imaging, tumour localization, radiotherapy, and research / clinical laboratory procedures, among others, and may include glassware, syringes, solutions, and excreta from treated patients. Company’s management of such waste includes waste segregation strategy, placement in lead box, with the labelling radioactive symbol, and the treatment according to national requirements and current guidelines from the International Atomic Energy Agency. As per ESAP #2, NHPL will develop healthcare waste management plan (HCWMP) to include all hazardous and non-hazardous waste streams.
PS4: Community Health, Safety and Security
The land of project site is located close to residential area on a plot already owned by the company. There are no communities in the immediate vicinity of the construction site. The closest settlement is Defence Housing Authority (DHA) located approximately 500 meters from the construction site.
Structural engineering design and tender process have been completed. Contractor for design and construction of the new building has included provisions for structural integrity of the building, which is approved by local authorities, considering the earthquake risk for the Islamabad region.
During the construction phase, the movement of heavy machinery and transportation of construction material and equipment may have traffic related impacts on the DHA Expressway Road. On average, 8-10 truckloads per day during the peak construction period is supplying different types of construction materials to the project site. As a mitigation measure, the company has developed Traffic Impact Study to avoid traffic jams/public inconvenience. Movement of vehicles carrying construction materials is restricted during the nighttime to reduce traffic load and inconvenience to the residents. The company and its contractors coordinate with the Traffic Police, residents / travellers, to facilitate traffic movement during the construction stage.
Rooms and areas with equipment emitting ionizing radiation (e.g., X-ray, imaging) will have appropriate lead-based protection and will be periodically certified to protect the health of the operators and the patients. For infection control purposes and air quality, the operating theatres block, neonatal unit and other critical patient areas will be provided by air handling units with high efficiency particulate air filters which will be replaced regularly, and the quality of air will be checked by using handheld particle counter. All operating theatres will be equipped with laminar flow units. All flammable and potentially toxic substances (such as formaldehyde ethanol, hydrogen peroxide, orthophthaldehyde, ethylene oxide, concentrated sulfuric acid, cleaning sprays, paint thinner, bleach) will be segregated, stored controlled temperatures and proper protective wear and ventilation will be provided.
Life and Fire Safety (L&FS) infrastructure and systems design follow local Building Code of Pakistan - Fire Safety Provisions - 2016 regulations and National Fire Protection Association (NFPA) relevant codes. As per ESAP #9, the company will engage a suitably qualified professional, to conduct a review the design and provide a professional certification that the design of life and fire safety systems for the project complies with the L&FS requirements of the WBG General EHS Guidelines. Particularly, the design will include (i) fire sprinkler systems throughout the complete hospital; (ii) fire rated enclosure of staircases and on other vertical openings (e.g., shafts, atriums); (iii) smoke compartmentation; and (iv) other necessary improvements identified by the L&FS professional. In addition, before starting operations, as per ESAP #10, a suitably qualified L&FS professional, will conduct a review during the commissioning process of the project and will certify that the construction of the L&FS systems has been carried out in accordance with the accepted design and the L&FS section of the WBG General EHS Guidelines. As needed, a corrective action plan, with a time frame for implementation, will be developed after the professional’s first review. Completion will not be certified until the professional has received confirmation of satisfactory completion of the corrective action plan.
Security Personnel:
NHPL has third party armed security personnel at the construction site. Security personnel are required to undergo regular trainings by local regulation. Before the hospital is operational, the client will, as per ESAP # 11, prepare security management plan (SMP) to assess risks posed by its security arrangements to those within and outside the project site. In making such arrangements, the client will be guided by the principles of proportionality and good international practice in relation to hiring, rules of conduct, training, equipping, and monitoring of such workers, as defined by the applicable federal and provincial regulations and requirements of the Pakistani accredited agencies.
At the operational stage, NHPL will have established Security Department to implement the SMP by carrying out risk/vulnerability analysis and developing action plans, as needed. The security personnel will be trained in responding to fire, personal safety/security incidents, handling security incidents, crime prevention, identification of patients, visitors, employees, security preparedness and response and any other non-security related urgent emergency situations in the hospital and feeder clinics, as appropriate.
