Rockland

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	26248
Country	India
Sector	Health Care
Department	Health and Education
Company name	Rockland Hospitals Limited
Environmental category	B
Status	Active

Date ESRS disclosed	February 15, 2008

Previous Events	Invested: July 22, 2008 Signed: June 6, 2008 Approved: May 27, 2008

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

This is a Category B project according to IFC’s Procedure for Environmental and Social Review of Projects because a limited number of specific environmental and social impacts may result which can be avoided or mitigated by adhering to generally recognized performance standards, guidelines or design criteria. The review of this project consisted of appraising technical, environmental and social information submitted by the project sponsor including:

- review of Rockland’s policies and Standard Operating Procedures related to environmental management and occupational hygiene, health and safety;
- assessment of supplemental information submitted by Rockland on key environmental and social assessment issues;
- review of Rockland’s Human Resources policy and corporate social responsibility programs; and
- meetings with the Project’s management team in February 2008 to discuss IFC’s PSs, guidelines and other requirements.

Project description

The proposed project an expansion of Rockland Hospitals (Rockland), which has an existing 90 bed facility in the Qutab Institutional Area in New Delhi, India. The project has three main components:

- addition of 66 beds and development of a 40 bed satellite unit to the existing 90 bed facility;
- development of a new 250 bed facility in Manesar – an emerging city south of Delhi;
- and a television channel focused on health-related services.

IFC has been requested to provide equity in the project.

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:

- PS 1: Social and Environmental Assessment and Management Systems;
- PS 2: Labor and Working Conditions;
- PS 3: Pollution Prevention and Abatement;
- PS 4: Community Health, Safety and Security; and
- PS 5: Land Acquisition and Involuntary Resettlement.

The project appraisal also assessed the applicability of PS 6: Biodiversity Conservation and Sustainable Natural Resource Management, PS 7: Indigenous Peoples, and PS 8: Cultural Heritage. In regard to PS 6, the project sites are expected to be located in heavily modified urban/peri-urban neighborhoods and no impact on biodiversity is therefore expected. With respect to PS 7 and PS 8, no indigenous peoples or cultural heritage resources will be affected by development of the project.

Environmental and social categorization and rationale

The project involves expansion of an existing facility and development of new hospital facilities in urban/peri-urban areas of India. The key social, environmental, health and safety impacts associated with the project will include: emissions to air and water; management of hazardous materials and wastes; labor and working conditions, employee occupational health and safety and community health and safety during construction and operation. Given that the proposed project locations are all in heavily modified areas, adverse impacts on environmentally sensitive areas are not expected to occur. The nature of hospital operations is such that it will be possible to readily design and implement engineering and management measures to mitigate any adverse impacts that result from the project.

Rockland has stated that, to date, it has acquired project sites from Government entities that had been purchased on a willing buyer-willing seller basis and that had either formal or informal residents or users of resources. Moreover, in light of the fact that mitigation measures can readily be designed, adverse impacts are not expected to be diverse or irreversible and will be limited to project site, and no physical or economic displacement of communities occurred, the project has been classified as a Category B.

Key environmental and social issues and mitigation

The sponsor has presented plans to address these impacts to ensure that the proposed project will upon implementation of the specific agreed measures, comply with the environmental and social requirements - the host country laws and regulations and the World Bank/IFC social and environmental Performance Standards (PS) and environmental, health and safety (EHS) guidelines. The information about how these potential impacts will be addressed by the sponsor/project is summarized in the paragraphs that follow. Further information is provided in the attached documentation.

PS1: Social and Environmental Assessment and Management Systems:

Rockland has established detailed health and safety management practices and Standard Operating Procedures (SOPs) that conform to international best practice for hospitals. Rockland has submitted these for certification by the National Accreditation Board for Hospitals, and expects to receive accreditation by May 2008. Environmental, hygiene, and health and safety issues are managed by the Heads of Infection Control, who reports directly to Rockland’s senior management group, to ensure that continuous improvement and instances of non-compliance are addressed immediately. Rockland has established a training program structure and schedule for new and existing staff. Rockland has received all relevant Government clearances for its existing facility, including plot Allotment Letters, Possession Letters and Sanction of Building Plans and consents under the Water (Prevention & Control of Pollution) Act, 1974; Air (Prevention & Control of Pollution) Act, 1981; Environment Protection Rules, 1986; Environmental Impact Assessment Notification, 1994; Bio-Medical Waste (Management and Handling) Rules, 1998; and Hazardous Waste (Management and Handling) Amendment Rules, 2003. Rockland will provide IFC with copies of all clearance documents for future developments with submission of the Annual Environmental and Social Monitoring Report (AMR) submitted to IFC.

Although key environmental impacts are addressed in the context of the existing HR and Safety management systems, these have not been formally assembled into an overall environment and social management system (ESMS). Rockland will develop a corporate level ESMS that references both applicable government regulations as well as IFC’s PS, in accordance with a timeframe agreed with IFC.

PS 2: Labor and Working Conditions:

Rockland has a Human Resources policy and procedures manual that are consistent both with relevant Government of India (GoI) statutes and regulations, as well as international good practices. Rockland currently employs 356 regular employees, 7 contract employees, 49 professionals (primarily physicians) on retainers, and 39 trainees. Security and catering services are provided by Rockland staff, while housekeeping services are outsourced. Rockland has reviewed PS2 and confirmed that its policies and procedures conform fully with all PS2 requirements and to the four key ILO conventions. Rockland has established a Grievance Redressal Committee, chaired by a full-time senior consultant. Employee OHS procedures and safeguards are detailed in a series of SOPs that have been developed by Rockland for all aspects of health care services including radiology, pathology, ambulance operations, pharmacy operations and emergency medicine. Rockland has detailed employee training programs to ensure that all staff understand and manage the specific occupational hazards to which they are exposed. Rockland utilizes Materials Safety Data Sheets to familiarize employees with the hazards and personal protective equipment required for specific chemical compounds that they use, or to which they may be exposed in their work. In addition, it monitors in-house occupational safety and health statistics to ensure that training programs are continuously updated to reflect the needs of each facility’s staff and patients. For all staff, Rockland sponsors annual health checks and required immunization of high risk groups. It provides all government-mandated employee stipulated benefits, as well comprehensive health Insurance, accident insurance, and free outpatient consultations for all staff.

Rockland has provided details on the life and fire safety (LFS) design, management and monitoring systems in its existing hospital. These include a fire ring and mains with connectable hoses and dedicated water supply; central alarm, smoke detectors and sprinkler systems; and adequate and appropriately signed means of egress. In addition, its HR department has in place training programs for staff that cover fire prevention and response, and designates trained fire responders throughout the organization. These teams are responsible for training, demonstrating, and monitoring the implementation of the LFLS programs. As new hospitals are designed, Rockland will submit an L&FS Master Plan to IFC that identifies major fire risks, applicable codes, standards and regulations, and mitigation measures. The L&FS Master Plan will be prepared by a suitably qualified professional acceptable to IFC who will certify that the design meets the requirements of IFC’s Life and Fire Safety guidelines. On the basis of the Master Plan and its findings and recommendations, IFC will determine whether additional conditions to the attached Environmental and Social Action Plan (ESAP) are needed, and agree with Rockland on a mutually acceptable time frame for implementing these conditions. The qualified professional who prepares the L&FS Master Plan also will undertake a review at the time of L&FS systems testing and commissioning and certify that construction of these systems has been carried out in accordance with the accepted design. Findings and recommendations of this review may be incorporated into the ESAP, as needed, along with a mutually acceptable time frame for implementation.

Environmental, health and safety during construction will be monitored by Rockland. Construction contracts will contain specific environmental, health and safety (EHS) provisions, compliance with which is overseen by Rockland personnel who are on site at all times during construction. Rockland will provide IFC with documentation that these provisions have been added to its standard construction contracts prior to commencement of construction at any of the new facilities. Non-compliance with EHS provisions will be grounds for financial penalties or termination of construction contracts.

PS 3: Pollution Prevention and Abatement:

The existing Rockland facility receives water from the municipal water supply system. Water quality is regularly monitored both in-house and by independent laboratories. Potable water is derived from on-site reverse osmosis (RO) plants or from licensed bottled water suppliers. All facilities are equipped with sewage and /or wastewater treatment plant as required. Treated effluent is disposed to the municipal system in compliance with guidelines of the relevant State Pollution Control Board, which are consistent with World Bank Group (WBG) guidelines. The Hospital maintains on-site storage facilities to ensure adequate water supply for operations. Although it only operates one facility at present, Rockland has undertaken initiatives to reduce its energy consumption, including use of CFL tubes for conservation of electricity, installation of power factor improvement equipment, and planned installation of solar water heater. These same initiatives will be deployed at its new facilities.

Rockland has established standard operating procedures (SOPs) for the disposal of general, pathological and chemical waste. These SOPs conform to WBG guidelines, Indian regulations, and good industry practice. At each facility, waste is segregated by category and stored temporarily on site as per internationally accepted procedures. General (non-infectious/non-hazardous) solid waste is collected and disposed per municipal regulations. Rockland has contracted with Synergy Waste Management Company for the removal and disposal of all biomedical waste. Synergy is licensed by the New Delhi Pollution Control Committee to collect, store, treat and dispose of bio-medical waste per national regulations. This authorization must be renewed annually.

Rockland maintains a comprehensive infection control program, detailed in its Safety Policy and SOPs, which is periodically reviewed by the Head of Infection Control as well as members of other departments including nursing, housekeeping, operating room and laboratories. The purpose of these reviews in to monitor control standards for nosocomial infection in order to minimize risk to both staff and patients. Rockland provides in-house training for all newly employed healthcare providers and housekeeping staff aimed at preventing infections as well as annual refresher training for existing staff. This training includes modules in the hospital’s SOPs for bio-medical waste management as outlined above. All facilities follow a regular schedule of disinfection – with a dedicated staff for laboratory and operating theatre – that is undertaken in accordance with occupational safety and health objectives described below and monitored on a weekly basis.

PS 4: Community Health, Safety and Security:

As part of its Safety management system, Rockland prepares disaster response plans for its facilities, including policies and procedures to prevent community exposure to disasters including earthquakes, fires and other large scale emergency situations. These will be revised to include scenarios in which disease, pathogens and other bio hazards might be released under during normal and emergency scenarios, based on a risk assessment and analysis. All employees in Rockland’s in-house security department receive training on disaster scenarios, as well as how to interact with hospital patients under normal and emergency situations. This training will be amended to ensure that security employees receive training on how to direct enquiries from other stakeholders who may have queries or complaints regarding the operation of Rockland facilities and the impacts on nearby communities. Rockland is revising its hospital entrance signage and information desk placards to include contact details (name, phone number and email address) of staff at each of its facilities who are responsible for receiving and responding to questions, concerns or complaints raised by communities or other stakeholders. Each hospital will maintain a register of such inquiries and how they have been addressed.

PS 5: Land Acquisition and Involuntary Resettlement:

Land for Rockland’s one existing and two planned hospitals has been acquired either on a willing buyer-willing seller basis or through concession under government programs designating areas for health care developments. Rockland’s management team has confirmed that none of its land acquisition and facility developments to date have entailed involuntary resettlement, and that it seeks to acquire land that will not displace residents, either physically or economically. To formalize this policy, Rockland will adopt a land acquisition ‘screening’ procedure consistent with PS5 to assess and document formally that no involuntary resettlement has occurred as a result of its expansion program. Rockland is in full compliance with all applicable national and local laws on land acquisition and has confirmed that all requisite permits, consents and approvals have been obtained.

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