Brookhouse Schools Limited

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	25173
Country	Kenya
Sector	Education Services
Department	Health and Education
Company name	Brookhouse Schools Limited
Environmental category	B
Status	Completed

Date ESRS disclosed	October 12, 2006

Previous Events	Signed: December 7, 2006 Approved: November 29, 2006

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 following potential environment, health and safety and social aspect of the project were analyzed:

- social and environmental assessment and environmental, social, and health and safety management systems;
- labor and working conditions;
- pollution prevention and abatement;
- community health, safety and security; and

The review of this project consisted of appraising technical, environmental and social information submitted by the project Sponsor including a review of:

- Environmental Impact Assessment Project Report (2/8/05), Addendum Report (25/11/2005), and Self Environmental Audit Report for 2005 for the Proposed Brookhouse Primary School Expansion Project prepared by Greenworld Ecosystem Consultants;

- Report of the Visiting Accreditation Team, on Standards for Accreditation, European Council of International Schools (ECIS) May 5-10th 2001 (Received Accreditation July 2001, review expected 2006);

- Water Quality Analysis Report and Waste Waster Analysis Report (December 5, 2005, February 1, 2006 and September 7 2006) prepared by AquaTech Industries;

- Appraisal Information Summary completed by Brookhouse.

In addition, IFC visited the project site, located approximately 13km from downtown Nairobi, to meet with the management and to have a first hand look at the school’s facilities and construction of the new buildings.

Project description

The project entails the expansion of Brookhouse Schools Limited (Brookhouse or the School) a British curriculum co-educational day and boarding school in Kenya and comprises:

- the construction of a modern new primary school on an adjacent plot;
- acquisition of five school buses; and
- refinancing of short and medium term debt to strengthen its Balance Sheet.

The current Brookhouse campus occupies a thirteen-acre site which includes a kindergarten, primary and senior schools and boarding accommodation.

Brookhouse is owned solely by Piyush Mehta and Joyti Mehta (the Sponsors).

Identified applicable performance standards

- 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 PS 5 Land Acquisition and Involuntary Resettlement, PS 6 Biodiversity Conservation and Sustainable Natural Resource Management, and PS 8 Cultural Heritage. In regard to PS5, the project site is located in a peri-urban area and was acquired through a willing buyer seller arrangement. The School has indicated that there were no formal or informal residents or users of resources on the site at the time it was acquired. With respect to PS6, which does not apply, the 13 acre concession is located in an upscale residential neighbourhood of Nairobi, surrounded by housing, commercial property, and undeveloped plots that have been designated for residential or commercial development. PS 7 does not apply as there are no Indigenous People impacted by the Project. Regarding PS 8, no cultural heritage was identified on site. The assessment concluded, therefore, that PS5, PS6, PS7 and PS8 are not applicable.

Environmental and social categorization and rationale

This project involves construction of additional buildings to an existing school, on their 13 acres site located in a upscale peri-urban neighborhood. Key impacts associated with the project include:

- An integrated management system;
- Liquid and solid waste management;
- Water quality;
- Labour and working conditions, employee occupational health and safety and community health and safety during construction;
- Life and fire safety.

Adverse impacts on the environment and socially sensitive areas are not expected to occur. The nature of the School’s operations is such that it will be possible to mitigate any minor, adverse impacts that might result from the project. As a result the project has been categorized as a category B project with minimal environmental or social impacts.

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 environment and social policies and the environmental, health and safety guidelines. The information about how these potential impacts will be addressed by the Sponsor and the project is summarized in the paragraphs that follow. Further information is provided in the attached Environmental and Social Action Plan (ESAP).

- PS1: Social and Environmental Assessment and Management Systems

Environmental and Social Assessment: As per Kenyan Environmental Regulations (Environmental Management and Coordination Act EMCA, 1999 and EIA Guidelines 2003) Brookhouse was required to complete an Environmental Impact Assessment (EIA) for the new primary School, which was completed in August 2005. There is an Environmental Management Plan attached to the EIA which the School has committed to follow and the School was recommended for licensing by their Consultants. In addition, an Environmental Audit prepared in 2005 found that the School was compliant with various government policies and regulations.

- Management Program: The school has accreditation from the European Council of International Schools (ECIS), and 2006 is a review year for Brookhouse. It meets the ECIS performance standards for Health and Safety including Food Handling Certificates, and has the necessary Fire and Security drills and measures in place. There is a detailed School Handbook of policies and procedures. The Science Laboratories in the school all have extractor fans, gas hoods, automatic shut off valves for gas burners and two fire exits from each lab.

The Sponsor has agreed to develop a more formal and integrated Environmental and Social Management System (ESMS), using the ECIS standards, various policies procedures, and the Environmental Management Plan (EMP) from the EIA, as a basis. A draft of this ESMS will be reviewed by IFC as a condition of disbursement.

- PS2: Labor and Working Conditions

Human Resources Policy and Working Conditions: There are approximately 150 people employed directly as teaching and support staff and 200 employed as labor on the building site during the construction phase. The Head of the Primary School will be responsible for HR and personnel management issues, relating to the management of the new primary school. The existing Headmaster of the School is the person responsible for the HR issues at present.

The School has a Staff Handbook along with relevant Board Policies. There is no collective bargaining agreement and staff have opted out of joining the union as they did not wish to pay the dues. There is a Staff Welfare Committee which addresses all grievances with management. Furthermore, the Staff Handbook has a grievance mechanism, details on working conditions and contracts as well as policies on discipline. There are no special labour laws applicable other than the standard labour laws of Kenya.

The minimum age for employment in Kenya is 18 and Brookhouse and all its contracted suppliers adhere to this minimum age standard. All Brookhouse employees are paid well above the Kenyan minimum wage. The policy for working hours falls within the Kenyan government regulations, professional staff’s hours are based on the ECIS guidelines of 85% contact time on a 35 hour week and support staff work 40 hours a week.

There is no child, forced or migratory labour used by Brookhouse. All contractors and sub contractors adhere to the labor laws of Kenya. Construction staff are housed off site and food service for them is managed by the contractors.

- Occupational Health and Safety: No specific OHS risk assessments have been carried out, however Brookhouse is in the process of their five year audit from the Council of International Schools, which will take place during the 2006 school year and which includes some of these issues. There are no mandatory health checks of teaching staff and all staff are covered by health insurance. New teachers may be asked to have a medical examine upon employment by the insurance company. Support staff working in certain areas such as the kitchen, are required to have three health examinations per year for communicable diseases (typhoid). The overall hygiene of the school is of the required standard, with regular inspections by the local authorities. They are supplemented by informal hygiene control visits by the School nurse.

Brookhouse operates an ongoing programme of staff development that includes training programmes for staff and HIV/AIDS awareness talks for support staff on a regular basis. All staff and new students receive yearly training on Fire Prevention and Fire Fighting as well as Emergency First Aid. Fire Marshalls are nominated among the staff and students to act in the event of an emergency.

- PS3: Pollution Prevention and Abatement

Energy: The School is connected to the National Grid and has 2 - 100KVA standby diesel generators that run on average for 300 hours/year. The Sponsor has committed to adding secondary containment to guard against spills if they upgrade their generators and move to bulk storage of fuels. At the moment there are no plans for this. Additionally the School has solar panels to heat the boarding facility’s water as well as electric water heaters. Energy use was reported at 153,550kwh/month.

- Water Supply and Quality: Water is supplied by a bore hole and there is a small water filtration and treatment plant. Water is primarily used for cooking, washing (showering), irrigation and laundry. Daily requirements are approximately 72,000 litres per day. The Environmental Audit as well as some of the reported water quality testing, had shown that the School’s water from the bore hole had tested very high in fluoride. However with treatment, the fluoride in the drinking water is minimal and meets National and IFC standards.

- Liquid and Solid Waste: Liquid effluents include waste water which is treated in septic tanks (with bacterial added to the tanks to aid breakdown), and is recycled for irrigation purposes of school grounds and sports fields. The septic tank is cleaned once every 3 months or as required by Nairobi City Council. Approximately 40,000 litres per day is produced. Laundry water is also used for irrigation and so biodegradable soap is used. Solid waste (about 20kg/day) is collected by a licensed contractor and disposed in approved municipal sites. Bottles are recycled if possible.

- Hazardous Materials: Small amounts of chemicals are used in school laboratories are used under fully supervised conditions.

- Life and Fire Safety: Existing Dormitories In existing dormitories, smoke detectors are installed as well as fire extinguishers located at intervals throughout the blocks. There are two means of egress to the blocks and in all cases, except in the staff living quarters, these are external balcony walkways and no more than two levels above ground. Being external they will in the event of fire offer protection to escaping students as any smoke should be disbursed from the access ways quickly. The main problem occurs when the students arrive at the base of the stairs to access the outside ground level. The stairs at the bottom are locked with open steel grillage. There is a key to the lock installed in a wall mounted glass lockbox. However there are no emergency lights in the dormitory blocks and this is one area where a light is essential to enable escaping students to see, not only the escape route, but enough to unlock the escape door. It is required therefore that self-powered emergency lighting that meets the codes are installed throughout the dormitory blocks to guide escaping students to the escape stairs and to the method of unlocking the escape door grills. In addition to the above lights, illuminated exit signs, which are currently missing, are required to indicate the way along the escape routes to the fire exits.

New Dormitories When the new dormitories are designed and constructed, they will need to incorporate all of the above emergency lights, smoke detectors and illuminated exit signs, as well as providing an acceptable method of unlocking any locked fire exit doors.

New School Blocks. The new school blocks are well under construction and in most respects would meet the requirements of the IFC Life and Fire Safety (L&FS) Guideline. However there are some issues to be revised as follows:

Auditorium: The auditorium as constructed will house some 450 people and it appears to have a sufficient number of escape doors and alternate means of egress to the outside. Some smoke detectors are proposed, as well as a central fire control panel, but no emergency lights or illuminated exit signs. Additional detectors connected back to the control panel and emergency lights and lighted exit signs sufficient to meet the requirements of the guidelines need to be added. The Sponsor agreed to add these.

Classrooms: The classrooms and teaching spaces do not have smoke detectors, illuminated exit signs, or emergency lights. All will be required and the detectors need be at a minimum in the library, arts area, labs and storage areas, all connected back to the control panel. Emergency lights and illuminated exit signs need to be installed at all three levels, ground, first and second level. T here is an additional level at the roof or attic level, which is intended to be used for library, and an exhibition area. There would be a very high probability of this area housing large gatherings of students and visitors from time to time, and as the distances to the two means of egress (which are enclosed at this level) exceed permissible distances, the most economical solution will be to add sprinklers to this area. This is not a hardship as the new buildings are served by a fire hose reel system that can be tapped at the risers to take off a header system for the sprinklers at the attic level. The School Management preferred to do this than to add an additional staircase which would have been the other alternative.

In accordance with IFC’s L&FS Guidelines, Brookhouse will submit an L&FS Master Plan to IFC that identifies major fire risks, applicable codes, standards and regulations, and mitigation measures as a condition of first disbursement. 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, its findings and recommendations, IFC will determine whether additional conditions in a Corrective Action Plan (CAP) are needed, and agree with the Company on a mutually acceptable time frame for implementing these conditions. The qualified professional who prepares the L&FS Master Plan will also 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 also be incorporated into the CAP, as needed, along with a mutually acceptable time frame for implementation.

- PS4: Community Health, Safety and Security:

The School swimming pool is fenced and gated and has a full time lifeguard when open. There is a pump house and water is continually circulated and chlorinated daily, as well as cleaned. The School hires a private security firm for protection: the officers are not armed, although they do use dogs while on patrol. There is a clinic on site staffed by a fulltime nurse with a doctor available on call. There is a hijacking procedure for the buses on which drivers are trained. Additionally the Health and Safety Committee is lobbying the government for requiring fire retardant mattresses for use in dorms.

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