Nakasero

Environmental & Social Review Summary

This Environmental and Social Review Summary is prepared and distributed in advance of the IFC Board of Directors’ consideration of the proposed transaction. Its purpose is to enhance the transparency of IFC’s activities, and this document should not be construed as presuming the outcome of the Board of Director’s decision. Board dates are estimates only.
Any documentation which is attached to this Environmental and Social Review Summary has been prepared by the project sponsor and authorization has been given for public release. IFC has reviewed this documentation and considers that it is of adequate quality to be released to the public but does not endorse the content.

Project number

28047

Country

Uganda

(IDA)

Region

Sub-Saharan Africa

Sector

Hospitals and Clinics

Department

Reg Manufact, Agri & Services, CAF/CLA

Company name

Nakasero Hospital

Environmental category

Status

Pending Disbursement

Date ESRS disclosed	March 22, 2010
Last Updated Date	February 8, 2012
Previous Events	Signed: June 22, 2010 Approved: June 18, 2010

View Summary of Proposed Investment (SPI), click here

Overview

Category & Applicable Standards

Key Issues & Mitigation

Community Engagements

Client's Documentation

Overview of IFC's scope of review

The IFC’s appraisal of this project included the following:

A meeting with representatives from the National Environmental Management Authority (NEMA)
Meetings with NHL management representatives
Review of the Environmental Impact Assessment and associated environmental authorization
Review of documentation related to human resources, quality management, disaster management, infectious disease control and occupational health and safety
Responses from NHL to the environmental and social appraisal questionnaire
A site visit

Project description

This project involves an investment of up to $3 million in Nakasero Hospital Limited (hereafter referred to as “Nakasero”, the “Hospital” or “NHL”). The Hospital is located in Kampala, Uganda and commenced its operations in March 2009. NHL is owned by 24 Ugandan shareholders, 21 of whom are medical specialists who also practice at the Hospital. Marcantile Global Limited is the majority shareholder with over 50% shareholding.

NHL, which commenced operations in 2009, currently has a capacity of 30-beds and is expected to grow to up 90-beds over the next two years. NHL provides out-patient and in-patient healthcare facilities, while laboratory services are outsourced to Lancet Laboratories Uganda Limited (“LUL”). LUL is a joint venture with Lancet Laboratories of South Africa who own 80% of LUL, while Nakasero owns the remaining 20%.

The Hospital is situated in Nakasero, a residential area in Kampala located in close proximity to central Kampala on a property previously used for residential purposes and owned by Dr. B. Mbonye. The Hospital constitutes a multi-storey building in an “L” shape configuration with the basement providing for psychiatric care. On the ground floor administrative functions, out-patient services, the radiology department, accident and emergency facilities, a pharmacy, small theatre and laboratory are situated. On the first floor there are in-patient rooms and theatres, while on the second floor there are also in-patient rooms, a cafeteria, specialized clinics and administrative offices. The remaining floors accommodate additional in-patient rooms. The front area of the Hospital provides for vehicular access and limited parking. The rear of the Hospital is occupied by structures housing the morgue, a service building, waste storage area, the standby generator and general maintenance areas.

Identified applicable performance standards

While all Performance Standards are applicable to this investment, IFC’s environmental and social due diligence indicates that the investment will have impacts which must be managed in a manner consistent with the following Performance Standards:

PS1: Social and Environmental Assessment and Management Systems
PS2: Labor and Working Conditions
PS3: Pollution Prevention and Abatement
PS4: Community Health, Safety and Security

The Hospital is located in a residential suburb of Kampala on a portion of land previously used for residential purposes. Thus PS 5: Land Acquisition and Involuntary Resettlement does not apply, and neither do PS6: Biodiversity Conservation & Sustainable Natural Resource Management, and PS 8: Cultural Heritage. In addition, there are no Indigenous Peoples (PS 7) in the vicinity of the development.

Environmental and social categorization and rationale

This is a Category B project according to IFC’s Environmental and Social Review Procedure because of the limited number of specific - largely environmental - impacts that may occur are site specific, and those impacts can be avoided or mitigated by adhering to generally recognized performance standards, procedures, guidelines or design criteria.

The facility is recently operational and no resettlement or biodiversity issues have been triggered as a result of site establishment. NHL is currently implementing a Total Quality Management System and has appointed a Quality Manager. Further, on-site solid waste management and disposal methods are adequate, although there is a need to formalize this by means of a defined waste management plan. Key issues that need to be addressed are the implementation of site / activity specific environmental management procedures, treatment of waste water, compliance with relevant Life, Fire and Safety standards and training of personnel. All of the issues as identified may be effectively addressed via the project Environmental and Social Action Plan (ESAP).

Key environmental and social issues and mitigation

The Hospital has presented plans to address the environmental and social impacts to ensure that the project will, upon implementation of the specific agreed mitigation measures, comply with policies and standards internal to NHL, applicable national laws and regulations, IFC’s Performance Standards on Social and Environmental Sustainability and IFC’s applicable Environmental, Health and Safety Guidelines. The information about how these potential impacts will be addressed by the project is summarized in the paragraphs that follow, and in the ESAP which is disclosed with this document.

PS1: Social and Environmental Assessment and Management Systems
Assessment. Nakasero commissioned a Uganda-based environmental consultancy to undertake the mandatory Environmental Impact Assessment (EIA) as required in terms of the EIA Regulations as promulgated under the National Environment Act Cap 153. The EIA was submitted to the National Environment Management Authority (“NEMA”) and approval was received in November 2008. The site also required rezoning and planning approval which, along with authorization for the building design, was received from the Kampala Municipality. The Ministry of Health has also issued NHL a license to operate as a health service facility.

Management. The Hospital has developed an Ethics Handbook which addresses issues such as confidentiality and the rights of patients and the hospital. A Total Quality Management System is currently being implemented at NHL and a Quality Manager has been appointed. NHL also has an Occupational Health and Safety Policy and Infectious Disease Policy. As defined in the project ESAP, NHL is required to finalize the quality management system and develop environmental management procedures for specific issues such as waste management and water quality monitoring.

Monitoring and Reporting. As defined in the conditions of approval from NEMA, NHL is required to undertake internal annual environmental audits for submission to the Authority. As part of the Total Quality Management System, there are regular internal audits and reporting thereon. This will need to be extended to environmental management. All waste that is collected and disposed of is monitored and reported upon via an auditable tracking system.

PS2: Labor and Working Conditions
The facility employs 72 individuals on its payroll staff and there are 24 medical consultants with consulting rooms at the Hospital. On-site activities which include the cafeteria, cleaning and maintenance, the laboratory and security are outsourced, which equates to an additional 47 staff. The total number of women either directly or indirectly employed by the Hospital is 73. When the hospital is fully operational and the radiology department is functional, the total staff compliment will approximate 200 individuals.

NHL has developed a Personnel Policy and Procedures Manual and employment contract documentation that complies with this Performance Standard. All payroll staff directly contracted to NHL are provided with written contracts which define their conditions of employment. The Personnel Policy and Procedures Manual includes a statement on equal opportunity of employment, a grievance mechanism, leave requirements, information on benefits and remuneration, along with other human resources related issues. As per national legislation, all employees are free to join unions, although currently none have done so. So as to ensure that personnel undertaking outsourced activities are employed in accordance with the requirement of this Performance Standard, as per the ESAP, NHL will review their conditions and request amendments as may be necessary.

The Hospital has an Occupational Health and Safety Policy which, combined with the Infectious Disease Policy and related procedures provide detailed information on how to manage occupational health and safety risks. The latter policy also manages the potential for hospital-acquired infection for example through inappropriate care. The policies include background information on potential risks e.g., causative reasons for infection, and procedures and guidance on the use of personal protective equipment in differing circumstances that could arise, the use of equipment and disease management. In addition, there is a procedure for ongoing regular medical check-ups for personnel, although NHL are currently engaging with the national Ministry of Health to confirm if this is a mandatory requirement.

PS3: Pollution Prevention and Abatement
All services required by the facility are provided by the Kampala Municipality. Electricity is supplied via the national grid and, given the primary national power source is hydro-electric, is considered reliable. Nonetheless, there is a standby generator with a 900 liter above ground diesel storage tank which is bunded. The total CO2 emissions as a result of NHL’s activities are estimated to be 200 tons per annum.

Potable water is supplied by the National Water and Sewerage Corporation with current consumption being approximately 300,000 liters per month. To ensure the water is of an acceptable standard, NHL will implement a water quality monitoring program in accordance with IFC’s requirements; this is defined in the ESAP.

Sewerage and waste water from the cafeteria, laundry, laboratory and ablution facilities is disposed of via the municipal sewerage system which discharges into the Kampala sewerage treatment works. This treatment works does not comply with the national requirements for waste water discharge. Whilst there are plans to construct a new municipal waste water treatment facility, the commencement date has not been confirmed. Therefore, in accordance with the ESAP, NHL is required to install a waste water treatment plant to accommodate all waste water generated by the facility. Further, the plant is required to treat waste water such that it is compliant with national standards and IFC’s requirements.

Stormwater is collected in on-site drains and discharged directly into the adjacent road which has stormwater channels so as to divert stormwater into the municipal stormwater system.

Solid waste generated on-site includes general i.e., domestic, waste from the cafeteria and administrative functions and hazardous (including medical) waste i.e., from the laboratories, general surgical waste (e.g., sharps and bandages) and body parts. There are suitable receptacles for the collection of hazardous and general waste which are located at designated points throughout the hospital and color coded for ease of use. This waste is collected and stored in dedicated waste disposal bins situated in a covered area at the rear of the hospital. The management of this storage area, along with the collection and disposal of the waste, is sub-contracted to A&M Cleaning Services and there is auditable documentation to confirm acceptable disposal. The general waste is transported to the municipal landfill site, while hazardous waste is incinerated at a facility owned and operated by the Joint Medical Research Council. So as to formalize environmental management on-site, NHL will compile environmental management procedures, including a waste management plan, and ensure ongoing training in the implementation thereof.

From time to time the property will be fumigated for pests and the chemicals used in these activities will be compliant with the IFC’s requirements for such.

PS4: Community Health, Safety and Security
The primary identified risk associated with the development is fire. Various measures have been included in the design of the facility to manage such a risk including:

An alarm system
Fire hose reels and fire extinguishers on all levels
Directional signs displayed throughout the building indicating exit and fire assembly points, amongst other aspects
A ramp leading from the respective floors to the ground floor so as to evacuate patients

The above have been installed in response to a Master Plan compiled for the Hospital which defines the minimum design requirements for NHL so as to be compliant with national fire and safety requirements. This plan was approved by the Kampala municipality planning department. To confirm the facility was constructed in accordance with the Plan, a post construction audit will be undertaken. This audit will also assess the adequacy of the life, fire and safety requirements relative to an accepted international fire, life and safety standard. Based on the findings of the audit, NHL will then be required to develop a corrective action plan if necessary to address any deficiencies identified.

The Hospital has been designed so as to facilitate access by disabled persons and there are ramps for wheel-chairs at all access points and, aside from the lift, there is an access ramp between all floors. In addition, all floors are equipped with toilets designed to accommodate disabled persons.

NHL also has a detailed Disaster Management Plan which is applicable in the event of a fire and security or bomb threat. This includes actions required in the event of a particular situation, and staff roles and responsibilities. As with the other Hospital policies, this plan has only recently been completed and training of personnel thereon is still required.

Security for the Hospital is outsourced and provided on a 24 hour basis. The guards as stationed at the entrance are armed. Thus a security protocol will be developed concerning the use of firearms, and the armed security personnel will be trained according to the protocol.

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