ACOMET

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	27503
Country	Afghanistan
Sector	Health Care
Department	Health and Education
Company name	ACOMET Family Hospital
Environmental category	B
Status	Active

Date ESRS disclosed	November 18, 2008

Previous Events	Invested: June 22, 2009 Signed: January 28, 2009 Approved: January 14, 2009

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 collected from the project sponsor over a phone interview on November 5, 2008.

Project description

Afghan Centre of Multi Professional Education and Training (ACOMET) Family Hospital is a greenfield hospital and training center located on the campus of Kabul University in Kabul, Afghanistan. The Hospital officially opened in August 2007 and focuses on cardiology, dermatology, family medicine and general surgery; it also operates a pharmacy, laboratory, x-ray facility and surgical theater. The first stage of construction has been completed and includes a 20-bed inpatient unit, outpatient clinic, pharmacy, laboratory and on-site training center that offer a diploma in family medicine and internship opportunities for students at neighboring medical schools. ACOMET intends to expand to 160 beds by 2010. All facilities are housed in two 3-storey buildings.

Identified applicable performance standards

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

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

The project appraisal also assessed the applicability of PS5: Land Acquisition and Involuntary Resettlement, PS 6: Biodiversity Conservation and Sustainable Natural Resource Management, PS 7: Indigenous Peoples, and PS 8: Cultural Heritage. In regard to PS5, no land was acquired for the project as all facilities are located on the university campus and leased to ACOMET for 99 years by the Ministry of Higher Education. With respect to PS 6, the project site is located in an urban neighborhood and no impact on biodiversity is therefore expected. Regarding 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 key environmental, social, health and safety associated with the project include:

- Emissions to air and water;
- Implementation of an environmental, health and safety management system;
- HR practices and working conditions;
- Occupational health and safety, particularly including life and fire safety, hygiene control mechanisms, and potable water supply;
- Management of hazardous materials, liquid, solid wastes; and
- Community health and safety and community engagement.

Given that the proposed project location is in an urban neighborhood, 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 resulting from the project that are not expected to be diverse or irreversible and will be limited to the project site. For these reasons the project has been classified as a Category B.

Key environmental and social issues and mitigation

The key environmental, social, health and safety associated with the project include emissions to air and water; implementation of environmental, health and safety management system; HR practices and working conditions; occupational health and safety, particularly including life and fire safety, hygiene control mechanisms, potable water supply; management of hazardous materials, liquid, solid wastes, community health and safety and community engagement. The information about how these potential impacts will be addressed by the Sponsor is summarized in the paragraphs that follow.

PS1: Social and Environmental Assessment and Management Systems:

ACOMET was established in August 2007 and construction of the hospital’s two buildings is now complete. The Afghanistan government has only recently developed a framework for assessing and managing environmental impacts, with the creation of the National Environmental Agency (NEPA) in 2005, and adoption of the country’s first environmental legislation, the Environmental Law, in 2007. Because regulations implementing the law have not yet been promulgated, no environmental clearances (either an Environmental Impact Assessment or Environmental Impact Statement) were required. The design master plan for the hospital - including design of fire safety and response, HVAC and ventilation systems, - was carried out against British standards. The master plan was submitted and approved by the Afghan Ministry of Higher Education on 2 December 2006 (23.11.1384 Persian Calendar). In addition, ACOMET has developed health and safety management practices relevant to key issues Environmental, hygiene, and health and safety issues are managed by the Risk Management Quality Manager, who reports directly to ACOMET senior management and the clinic director. ACOMET has established a training program for new and existing staff and conduct emergency and fire drills on regular basis.

ACOMET will provide IFC with copies of all clearance documents including environmental clearance exemption letter from NEPA. In addition, ACOMET will consolidate its existing guidelines and procedures into a comprehensive environmental and social management system (ESMS) that references both applicable host country regulations as well as IFC’s PS, in accordance with a timeframe agreed with IFC.

PS 2: Labor and Working Conditions:

ACOMET has a staff complement of approximately 40, including 15 clinical staff (doctors, laboratory and nurses) plus 25 support staff. Although the number of women in the workforce in Afghanistan is very low, ACOMET has made special efforts in this regard and currently employs 7 women. Local residents account for approximately 90% of the ACOMET workforce. Employment contracts for support staff are on a full time basis; medical staff, especially doctors, are generally employed on a part-time basis. All newly-hired employees undergo a mandatory training and probation period of six months. Employee benefits include free medical treatment for the employee plus a 20-50% discount on treatment for family members. Employment of women is treated equally except for pregnant women who are limited to some areas to secure a healthy delivery (only 1 pregnant woman is employed). ACOMET currently has no written Human Resources (HR) policy or procedures manual but will consolidate its employment policies into a formal system, which will be provided to IFC within an agreed timeframe.

As noted above, ACOMET provides training and practice drills to all staff on fire safety and response procedures, and checks all fire extinguishers every month. ACOMET has in place a practical hygiene program for kitchen users, although this has not been formalized in written form. However, ACOMET management expressed commitment in offering a formalized continuing education program to make its employees aware of global standards and good practice in this regard. ACOMET’s laboratory is equipped with a separate ventilation system.

ACOMET has a policy of non-discrimination based on gender. The working hours are announced and published in compliance with the requirements of National labor law. ACOMET has agreed to establish a Grievance mechanism and HR Manual policies and procedures that conform fully to all PS2 requirements as well as Afghanistan labor law and regulations. In addition, ACOMET has agreed to develop a series of Standard Operating Procedures (SOPs) for all aspects of health care services to address employee occupational health and Safety (OHS) procedures and safeguards. As part of preparing the SOPs, ACOMET will make available personal protective equipment (PPE) and OHS procedures for laboratory staff.

PS 3: Pollution Prevention and Abatement:

As noted, all of ACOMET facilities are located on the university campus. Infrastructure facilities of water supply, wastewater collection and power are supplied by the university, which is equipped with both domestic sewage and wastewater treatment plant. Treated effluent is disposed to the municipal system. ACOMET has a septic tank that is to be used for emergencies or failure of the collection system, although it has not had to be used to date. A 100 kVA emergency diesel generator is installed in-site in addition to a boiler and an incinerator.

ACOMET has established a system for the disposal of municipal, pathological and chemical waste. The operating procedures consist of a color coded bags (white and black) and bins in addition to boxes for disposal of needles and sharp objects. Collection is handled by hospital staff to avoid mixing of waste by external contractor. Waste is segregated by category and stored in large bins in the incineration site. General (non-infectious/non-hazardous) solid waste is collected and disposed per municipal regulations in a landfill operated by a private company. X-ray films are not used, as ACOMET depends on a digital system and electronic archiving. Afghanistan’s Environmental Law of 2007 requires issuance of a license for handling of hazardous waste, but ACOMET has confirmed that this is not applicable to their operations. The waste collection system (segregation, collection and autoclave of medical waste) conforms to World Bank group (WBG) guidelines and good industry practice. Because of the small volumes used, ACOMET maintains a disinfection and sterilization program that is consistent with good industry practice but has not been documented as a written SOP. ACOMET follows the UK code for pharmaceutical procurement and checks twice a week for expired treatments.

Although not required under national law, ACOMET has agreed to monitor wastewater discharge and air emissions from the boiler, generator and incinerator as well as stack emissions from the ventilation system to ensure compliance with IFC Environmental and Social Guidelines for Health Care Facilities. In addition, ACOMET has agreed to ensure secondary containment of hazardous or flammable fluid containers including diesel fuel in addition to ensuring proper communication of Material Safety Data Sheets (MSDS) of flammable material as per a written Hazard Communication Plan.

PS 4: Community Health, Safety and Security:

ACOMET has agreed to submit a fire safety Master Plan to IFC that identifies major fire risks, applicable codes, standards and regulations, and mitigation measures. The 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. 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. ACOMET also will adopt a disaster response plan for earthquakes, fires and other large scale emergency situations. The plan would 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.

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