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 and
The client has an environmental, health and safety (EHS) policy to guide its operations. Its E&S management system (ESMS) is comprised of a set of E&S management plans (ESMP) and procedures including health care waste management plan (HCWMP), life and fire safety master plan, human resources (HR) related policies and procedures, code of professional conduct and employee guide, infection control system and medical waste disposal protocol / standard for management of the hazardous waste. Once UST Hospital in Aden is completed, its ESMS will be mirrored the one developed for the Sana Hospital. As per ESAP item 1, the client will update its ESMP to integrate EHS into the operation of its new healthcare facility. E&S responsibility is delegated to multiple departments, including maintenance, quality, infectious, units. Since currently in UST there is no dedicated senior EHS resource, to oversee the overall implementation of the ESMS, as per ESAP item 2, the client will strengthen its EHS capacity through hiring additional senior staff with primary EHS responsibilities that includes updating the existing ESMS and developing new plans and procedures, as necessary, including an updated process to report EHS performance to the senior management.
In Yemen, there is no requirement to conduct environmental impact assessments (EIA) for the development of private medical and health facilities.
The client is committed to develop its new hospital in compliance with national regulatory requirements, national and international health care standards such as JCI (international standards for hospitals) and World Bank Groups (WBG) EHS Guidelines for Health Care Facilities.
The project will be developed in converted land adjacent to the nearby Aden wetlands protected area. There is no overlap with Protected Areas or identified priority biodiversity values, and no impact is expected from the construction and operation of the hospital on the shore/sea, which are part of a key biodiversity area (KBA). The land for the new hospital construction in Aden belongs to UST and was purchased through willing buyer/seller agreement. No persons have been displaced either physically or economically by the new development.
Before starting the operations, per ESAP item 4, the company will develop and implement the emergency preparedness and response plan (EPRP) for the new hospital, 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.
The climate change risks might include coastal flooding, drought, water scarcity, and elevated temperatures. As per ESAP item 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 if needed. The climate change risk assessment will be integrated into the client’s existing risk management systems.
PS2: Labor and Working Conditions
The current workforce at UST consists of around 900 employees, including approximately 650 male and 250 female employees.
UST has a Code of Professional Conduct and Employee Guide outlining company’s HR policy provisions including recruitment system, probation period for new employees, temporary contracts, wage system, overtime hours, work schedule, leaves (ordinary, official, emergency, marriage, maternity, bereavement, pilgrimage, exam leave), termination of services, employee benefits and services, violations). As per the ESAP item 6 UST will update HR policy and procedures in line with IFC PS2 requirements to cover non-discrimination and equal opportunity, gender-based violence and sexual harassment, freedom of association and collective bargaining, child and forced labor, retrenchment, accommodation, paternity leave and grievance mechanism. In addition, HR policy; will be adequately reflected in their employee guide, employee contracts and induction trainings; with relevant measures to supervise the implementation and compliance.
The UST internal grievance mechanism encourages staff to raise issues through use of complaint boxes available throughout the hospital premises, gathering grievances from workers, patients, and their companions. As per ESAP item 7, UST will update its worker grievance mechanism to be separate from that of patients and their companions, to include GBV and sexual harassment, and effectively communicate these changes to employees and the students.
The company has a roadmap with dedicated resources such as a department, personnel, and budget of its gender equality objectives. Initiatives include childcare services, “The Girl Center” for training and empowering women in the labor market, and dedicated facilities to provide a safe and comfortable environment for women to exercise, relax, and pray.
Occupational Health and Safety: The OHS management system followed at the UST covers safe working practices for its staff during operational phase, that relate to falls, needle stick injuries, management of infectious diseases, radiation exposure, spills, etc. and the hospitals have developed a safety manual which describes procedures on risk management and safety aspects. A similar safety manual will be developed and implemented for Aden Hospital. A set of OHS trainings will be provided to UST staff (safety training, personnel security, safe handling of tools and equipment; healthy working conditions and appropriate PPE for the workforce will be provided (sterilization means in laboratories, respirators, medical computer screens lighting, air conditioning).
Workers Engaged by Third Party: As of May 2024, there are 50 EPC workers at the construction site with several migrant workers, who enjoy the same labour rights as the domestic workforce. The workers do not reside on the site but commute daily in and out the site. The contracts, that UST developed for its contractors, have provisions related to EHS requirements. These include responsibilities for waste management, labor and working conditions on-site, providing safety equipment for their workers and liabilities for any damages or work-related injuries. In addition, the client required the EPC to implement a heat management procedure to protect workers from heat stress. The EPC selected for the development of the hospital has relevant experience in similar construction developments. The client, 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).
The company and its EPC experienced few accidents during the construction. The work force is provided with appropriate PPE (personal protective equipment) and OHS trainings including daily toolbox talks are conducted. The client will monitor, keep statistics and report any accidents during construction to IFC. Client will also develop an incident reporting and investigation system, covering accidents, near misses and hazard/risk reporting, to investigate the root causes and plan and implement mitigation measures. UST will use commercially reasonable efforts to apply requirements of PS2 that relates for (sub)contractors. These requirements, specified in contracts between the sponsor and its sub/contractors, will address compliance with Labor and OHS Laws of Yemen and compliance with PS2; this provision will be reflected in the Contactor Management Plan to be developed by the client (ESAP item 3)
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 UST’s HR policy and procedures in addition to national labor law requirements.
While the client does not have a formal code of conduct for contractors and suppliers, its policies include selection procedure that is applied when selecting and hiring contractors and/or suppliers. To harmonize and consolidate its approach, as per ESAP item 3, the client will prepare the Contractor Management Plan (CMP) that includes IFC PS requirement and documentation to be cascaded down into (sub)contractors’ scope of work through inclusion into tender documentation, contracts and their procedures during construction and operation. The client will include legally binding obligations in the EPC / O&M contract (and subcontractor contracts) to ensure compliance with the requirements of the relevant national regulations and IFC PS requirements.
PS3: Resource Efficiency and Pollution Prevention
The company consumes diesel, electricity and natural gas and will annually quantify the hospital related operational greenhouse gases emissions accordance with internationally recognized methodologies and report to IFC in its annual monitoring report.
For the construction of the hospital, the EPC is responsible that the site is supplied with potable water and energy from the city utility companies or from diesel generators. Sanitary wastewater is discharged into the city sewage system. 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.
During the Hospital operations, uninterrupted power supply, particularly for operating theatre, recovery room and outpatient clinics will be provided from the national power grid and gen sets system. In addition to conventional power supply, the client plans to install 1,5 -2 MWp (roof mounted) solar PV over UST’s new hospital building and on the enclosed car park to help cover the UST university and new hospital energy needs. The client will design a hybrid system, which will combine electricity from these sources i.e. national grid, solar PV and diesel-based generators, and eventually add batteries to such system. Detailed engineering design will determine the optimal capacity and number of diesel generators, as well as the capacity of the solar PV plant and the way of operating the entire system. The diesel tanks will be built underground and constructed as per WBG General EHS Guidelines; Underground Storage Tanks and / or Good International Industry Practice (GIIP).
When operational, the hospital will have an onsite water treatment to eliminate any health infectious risk due to potential interruption in water supply. As wet cleaning of PV panels requires high volumes of water during operation, water scarcity and high consumption is likely to be an environmental risk, which the client will mitigate by implementing further energy and water efficiency measures.
As per ESAP item 9, UST Aden Hospital will install a wastewater treatment plant, to treat its wastewater before discharging off to a city sewage system. The treatment system specifications and operational performance will be in line with the requirements specified in Worldbank Group’s (WBG) EHS Guideline for Health Care Facilities - Table 2.
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 disposal site outside Aden city. The management of hazardous wastes, including medical wastes, will be conducted by the hospital infectious control team, which is 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 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. As per ESAP item 10, the client will construct on-site incinerators for health care hazardous waste management. As per ESAP item 8, existing HCWMP will be updated to include incineration process. During operations, emissions from the hospital incinerator will follow maximum allowable emission values prescribed as guidance values in Table 3. of WBG's EHS Guideline for Health Care Facilities (including particulate matter (PM), total organic carbon (TOC), hydrochloric acid (HCl), hydrogen fluoride (HF), sulphur dioxide (SO2), nitrogen oxide (NOx), etc
Radioactive wastes include solid, liquid, and gaseous materials that have been contaminated with radionuclides. Radioactive waste originates from activities such as organ imaging, tumor 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 included 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.
PS4: Community Health, Safety and Security
Community Health and Safety: UST Hospital will be located adjacent to UST University within the same complex/campus. The hospital operations and facilities will be regulated by the National Agency for Sanitary Vigilance, which issues operating licenses, and regularly inspects the hospitals. The Company mitigates the community exposure to diseases in accordance with relevant local norms and regulations and implements clinical and non-clinical risk measures to prevent hospital infections. 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 public.
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.
Contractor for design and construction of the new building has applied construction provisions for structural integrity of the building, which is approved by local authorities, in line with the measures and requirements considering the earthquake risk for the Aden region.
UST has an evacuation policy and emergency plan and will designate duty engineers and safety manager in the hospital to prevent and/or mitigate eventual emergency situations.
Life and Fire Safety (L&FS): L&FS infrastructure and systems design follows local regulations and included different types of fire extinguishers, fire detection and alarm system, fire hose reels at every floor, water storage tanks with fire pumps, that will be constructed during the first phase of construction. As per ESAP item 11, the company will engage a suitably qualified professional, to conduct a review the design and will 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 be modified to 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 as well as (iv) other necessary improvements identified by the L&FS professional.
Additionally, before starting operations, as per ESAP item 12, a suitably qualified L&FS professional, will conduct a review during the commissioning process of the hospital 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: UST Hospital will have 50 trained unarmed security personnel which will be part of the Maintenance and Services Administration. Security personnel are required by local regulation to undergo regular trainings. Security staff will guard entrances to the hospitals and educational facility. The security personnel will also be trained in responding to fire and any other non-security related urgent emergency situations in the hospital.
