Hygeia Expansion

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	25324
Country	Nigeria
Sector	Health Care
Department	Health and Education
Company name	Hygeia Nigeria Limited
Environmental category	B
Status	Active

Date ESRS disclosed	October 20, 2006

Previous Events	Invested: July 26, 2007 Signed: January 30, 2007 Approved: January 25, 2007

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

Environmental and social review of the project included a physical visit to each of the three Hygeia health care facilities in Lagos, Nigeria, to evaluate the project sites and environs and to conduct interviews with key client staff. Proposed modifications and additions to Hygeia’s health care facilities are limited in scope and will affect existing structures exclusively. There is no planned land acquisition or expansion of properties required for this project with the exception of potential acquisition of one parcel that is currently leased.

Additionally, IFC reviewed supplemental information provided by the client including proposed environmental and social affairs management programs, community engagement, labor and community engagement.

IFC communicated with client and consultant staff responsible for environmental and social affairs including :

- Dr/Professor Ade Elebute, Chairman, Lagoon Hospitals
- Mrs. Fola Laoye, Group Managing Director, Lagoon Hospitals
- Dr. AF Oyewumi, Quality Manager, Lagoon Hospitals
- Dr. SA Osunkoya, Director of Clinical Services, Lagoon Hospitals
- Dr. O.O. Onakoya, Medical Director, Lagoon Hospitals
- Ms. Ejiro Ehimah, Group Manager, Human Resources
- Ms. Jumoke Ajure, Assistant General Manager, Group Operations, Lagoon Hospitals

Project description

This project involves expansion of several operations of Hygeia Limited, which is a private sector provider of hospital and health maintenance organization (HMO) services in Nigeria. Through IFC’s African Enterprise Fund (AEF) in 1999, IFC previously invested in Hygeia. The key elements of the current proposed project include: upgrade, renovation and expansion of three Hygeia hospitals:

- Lagoon Apapa, Lagoon Victoria Island (VI), and Lagoon Ikeja;
- a doubling of the overall capacity of the Hygeia’s hospitals in Lagos from 50 to 100 beds;
- establishment of five regional offices and the expansion of information technology infrastructure in relation to its HMO business;
- refinancing of a 5 year loan with a local Nigerian bank used to purchase MRI, CT Scan, and other critical care equipment in 2004 and 2005; and
- funding of working capital to facilitate the company’s expansion program.

Key environmental and social issues and mitigation

Key environmental and social issues are listed below. In addition, specific information defining how elucidated potential impacts will be addressed by the sponsor/project is described. Upon implementation of the featured mitigation measures described below and in the attached environmental action plan (EAP), the project will comply with environmental and social requirements, host country laws and regulations and the World Bank/IFC performance standards as well as applicable environmental, health and safety guidelines.

- Social and Environmental Assessment and Management Systems:

Lagoon Hospitals has an ongoing consulting and strategic alliance arrangement with Apollo Hospitals of India through which Apollo is advising Lagoon on managed health care and certification of hospital operations to international standards. Lagoon’s ultimate target is certification by the Joint Commission International (JCI), which is the international branch of the Joint Commission on Accreditation of Healthcare Organizations (JCAHO). Joint Commission International helps to improve the quality of patient care in many nations. As part of this initiative Lagoon documented its procedures and processes in operations, orients and trains new staff using this documentation, and is engaging in a number of other employee orientation and training initiatives. This systematization of operations provides a management system for all aspects of Lagoon Health Care facilities. Supplemental, supporting aspects of the management program include offering quality certification classes to all Lagoon staff. Hygeia is encouraging all professional staff to obtain the title of Certified Professional in Health Care Quality, which is a US Board Examination. In further coordination with Apollo, Hygeia has formed a number of committees oriented to assessment and monitoring of specific health care activities to ensure that ongoing performance adheres to written documentation of company processes and procedures. The committees at present include Planning and Therapeutics, Medical Records review and Infection control.

Environmental review and permitting for expansion of the three lagoon operations falls under the aegis of the operations manager. To obtain permits for expansions, Hygeia submits an application to the Urban Planning Unit for an Alteration of Use Permit. Urban Planning then reviews drawings and determines if there are environmental impacts associated with the proposed expansion or alteration of facility use. When the review is complete and required modifications have been incorporated into the design the permit is issued. Permits must be visible throughout the construction period. A post construction inspection will be performed by Urban Planning to ensure that the structures were constructed in accordance with approved designs and the permits.

Through existing communication channels with the Apapa Government Reserve Area (GRA) Residents Association, Lagoon Hospital Apapa will explain the scope of expansion activity and present potential impacts and mitigation measures to the host community. Similarly, Lagoon will engage other GRAs and/or other community organizations to explain expansion at Ikeja and Victoria Island. These engagement measures will be conducted to ensure that each community understands potential expansion issues and mitigation measures and is afforded the opportunity to express perceived issues and concerns.

In compliance with the attached Environmental Action Plan (EAP) Lagoon Hospitals will continue to strengthen its management system and to expand the scope of written procedures to address supplemental operations activity including life and fire safety, hazardous materials management, occupational health and safety, and community engagement.

- Labor and Working Conditions:

Lagoon Hospitals’ employs a Group Manager for Human Resources. The client has developed a Staff Handbook to explain employment rights and non specific wages and benefits information. Precise wages and benefits information is detailed in each letter of employment. The Staff Handbook is made available to all employees and is updated periodically. Salary ranges are reviewed and updated annually based upon a survey conducted by the human resources manager. The Staff Handbook incorporates an employee grievance mechanism. As Lagoon routinely seeks and hires highly qualified professionals there are no labor organizations to coordinate with and there are no collective bargaining agreements. Employment is offered to individuals in accordance with the terms of employment in the Staff Manual and in position-specific appointment letters. Selection criteria for employment include appropriate job requirement credentials and successful interviews. Lagoon does not hire anyone under the age of 18, which is the minimum age for employment in Nigeria. There are no discriminatory practices in hiring; however state law requires that employees meeting job requirements pass a medical examination.

Hygeia’s Lagoon Hospitals are regulated and certified by the State Hospital Management Board. Each facility is subject to an annual review that constitutes a validation exercise to confirm continuing quality operations. Credentials for the physicians and nurses are checked by the Human Resources Manager. Positive results from the annual review and credential certification leads to award of a Certificate of Practice for the operation.

Although a number of labor and working conditions considerations are addressed through existing committees and activities aimed at improving quality, there is at present no formal occupational health and safety program. In accordance with the attached EAP, Lagoon will refine existing operations to ensure implementation of a program that complies with the IFC occupational health and safety guideline.

- Pollution Prevention and Abatement:

Potable water for all three Lagoon operations is provided by the local utility, Lagos State Water Corporation. Because water service is intermittent all three Lagoon hospitals are required to be prepared for water outages. When the water service is operating it flows to a primary cistern and is filtered and disinfected prior to being pumped to supplemental storage tanks situated on the roofs or at higher levels. Water samples are collected by Willy Jameson Ltd., a private water services contractor, and then analyzed for physical, chemical and microbiological parameters. When test results indicate a water supply problem the facilities take immediate action to resolve the issue. When water pressure is lost in water supply mains external contaminants can flow into non pressurized mains. In accordance with the EAP, Lagoon will ensure that supplemental disinfection capability is available for raw water storage and deployed during water supply outages to ensure adequate disinfection of raw water supplies.

Lagoon Hospitals’ sanitary wastewater is collected in concrete storage tanks for removal by a private contractor. Collected sanitary sewage is transported to Nigerian Cleaning Service, a Lagos State government sanitary sewage treatment center on Victoria Island. Storm water and air conditioning condensate and are evacuated through storm water drains servicing surface areas and the streets.

Aside from segregation of sharps (e.g. glass, needles, syringes, etc.) there is no formal segregation of health care wastes principally because there are no specialized services to manage segregated wastes. However, there is a great deal of awareness of AIDS transmission; thus preventive measures and attention to disposal is emphasized. Solid waste is collected in a segregated area in covered bins on the Apapa properties. A private contractor collects accumulated solid waste from the facilities and transports it to solid waste facilities owned and operated by Lagos State Waste Management. Lagoon is working with Lagos State Health Commission and others to rectify the existing situation in which there are no available specialty contractors or facilities for managing sharps or other health care waste aside from the disposal site where the state reportedly burns solid waste.

Electric power is supplied to the three facilities by the Power Holding Company of Nigeria PLC (PHCN). Power outages are common in Lagos thus local generation capacity is required. Generators use diesel fuel stored at Apapa. Drums of diesel are filled from the principal storage tank at Apapa and transported to the other operations for use. The annual generation of CO2 for all three facilities through national grid and local generation consumption is less than 2000 tons CO2/year, which is well under the IFC threshold of 100,000 tons/year. Nevertheless, the cost of energy and maintenance of electric power generators and UPS devices as well as the actual consumption from diagnostic equipment (MRIs, CTs, xRay, and others) is high. The company will benefit from energy consumption and use audit indicating benefits to be derived from specific ameliorative expenditures.

Lagoon Apapa recently completed installation of a centralized oxygen supply that provides oxygen to patient rooms, surgery and other locations. The central store of oxygen bottles provides chains for bottles but use is intermittent. Similarly full and empty cylinders awaiting use or collection are standing without restraint. As part of occupational health and safety system formalization described above, improved management of oxygen and other hazardous materials will be highlighted in specific procedures and in employee training.

- Community Health Safety and Security:

As part facility expansion designs, Lagoon will conduct a review of life and fire safety for the three proposed expansions in accordance with the attached EAP. Emergency response planning developed as part of formalized occupational health and safety activities described above will coordinate essential activities with host communities to ensure adequate communication of potential emergencies and appropriate response activity. Lagoon hospitals employ a combination of subcontractor security services and direct hire employees to provide entry and exit and traffic control, personnel entrance, and internal security for building and contents. None of the security guards are armed; all internal and outsourced security services are advised to call the police in the event of any type of incident.

- Land Acquisition and Involuntary Resettlement:

Lagoon Hospitals is negotiating the purchase of currently leased parcels utilized for Ikeja and Victoria Island operations. Purchase of these properties in the offing will be between a willing buyer and a willing seller. There will be no physical or economic displacement associated with these transactions. The land use will remain the same.

IFC PROJECTS