ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) Food and Agriculture Organization (FAO) And United Nations Development Programme (UNDP) And World Food Programme (WFP) Yemen Food Security Response and Resilience Project (P176129) ENVIRONMENTAL and SOCIAL COMMITMENT PLAN (ESCP) March 19, 2021 1|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN 1. The Food and Agriculture Organization (FAO) and the United Nations Development Programme (UNDP) and the World Food Programme (WFP) (the Recipients) shall jointly implement the Yemen Food Security Response and Resilience Project (the Project) with the involvement of implementing partners (IPs) which include, but are not limited to: the Yemen Social Fund for Development (SFD), the Public Works Project (PWP) and Small Micro Enterprise Promotion Service (SMEPS). The International Development Association (IDA) and the Global Agriculture and Food Security Program (GAFSP) have agreed to provide financing for the Project. 2. The Recipients shall implement material measures and actions so that the Project is implemented in accordance with the World Bank’s Environmental and Social Standards (ESSs). This Environmental and Social Commitment Plan (ESCP) sets out material measures and actions, specific documents and plans for preparation and implementation, as well as the timing for each of these. 3. The Recipients shall also comply with the provisions of any other Environmental and Social (E&S) documents required under the Environmental and Social Framework (ESF) and referred to in this ESCP, such as the Environmental and Social Management Framework (ESMF), Environmental and Social Management Plans (ESMPs), Simplified Pest Management Plan (PMP), Stakeholder Engagement Plan (SEP), Labor Management Procedures (LMP) and the timelines specified in those E&S documents as relevant to each project component, all in a manner acceptable to the IDA. 4. The Recipients are responsible for compliance with all ESCP requirements even where implementation of specific measures and actions is conducted by Implementing Partners (IPs). 5. Implementation of the material measures and actions set out in this ESCP shall be monitored and reported to the IDA by the Recipients as required by the ESCP and the conditions of the legal agreements, and the IDA will monitor and assess progress and completion of the material measures and actions throughout implementation of the Project. 6. As agreed by the IDA and the Recipients, this ESCP may be revised from time to time during Project implementation, to reflect adaptive management of Project changes and unforeseen circumstances or in response to assessment of Project performance conducted under the ESCP itself. In such circumstances, the Recipients shall agree to the changes with the IDA and update the ESCP to reflect such changes. Agreement on changes to the ESCP shall be documented through the exchange of letters signed between the IDA and the Recipients. The Recipients shall promptly disclose the updated ESCP. 7. Where Project changes, unforeseen circumstances, or project performance result in changes to the risks and impacts during project implementation, the Recipients may re-allocate Project funds, as agreed with IDA , and/or undertake additional funds mobilization efforts, if needed, to be able to implement actions and measures to address such risks and impacts including decisions on funding for any extra cost originated by unforeseen circumstances. 2|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY/AUTHORITY MONITORING AND REPORTING A REGULAR REPORTING: Prepare and submit to the IDA regular First report after six months of Project’s FAO, UNDP and WFP, in monitoring reports on the environmental, social, health and safety Effective Date and to be maintained collaboration with the Social Fund (ESHS) performance of the Project, including, but not limited to the throughout Project implementation on a for Development (SFD), the Small implementation of the ESCP, status of preparation and biannual basis. Micro Enterprise Promotion implementation of E&S documents required under the ESCP, Service (SMEPS), and the Public stakeholder engagement activities, functioning of the grievance Works Project (PWP). mechanism(s). Hire and maintain a Third-Party Monitoring Agent for E&S Prior to the start of sub-project activities. FAO, UNDP, and WFP. supervision and reporting. The TPMA will follow the reporting requirements listed for the instruments below. B INCIDENTS AND ACCIDENTS: Promptly notify the IDA of any Throughout Project Implementation. FAO, UNDP, WFP, SFD, PWP, and incident or accident related to the Project which has, or is likely to Initial Investigation Report within 48 hours, SMEPS. have, a significant adverse effect on the environment, once confirmed, and Detailed Report communities, or workers including exploitation or abuse of within ten days of the initial report vulnerable groups, sexual exploitation and abuse and sexual indicating possible causes and proposing harassment (SEA/SH), child labor, forced labor, injuries to workers corrective actions. that require off-site medical attention, misuse or spills of pesticides, fatality, among others. Provide sufficient detail regarding the incident or accident, indicating immediate measures taken or that are planned to be taken to address it. Subsequently, prepare a report on the incident or accident and propose any measures to prevent its recurrence. 3|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) C CONTRACTORS/ SUPERVISOR MONTHLY SURVEYS Monthly (throughout Project UNDP, FAO, WFP, SFD, PWP and The Cash-for-Work (CFW) implementation documents and Implementation), with the surveys SMEPS. arrangements shall include the requirements to manage ESHS beginning after the first 30 days of risks, SEA/SH risks and security issues during the construction implementing the contracted activities. activities. The supervision / contractor shall regularly submit implementation monitoring surveys during operations. ESS 1: ASSESSMENT AND MANAGEMENT OF ENVIRONMENTAL AND SOCIAL RISKS AND IMPACTS 4|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) 1.1 ORGANIZATIONAL STRUCTURE: One coordination committee with FAO representatives from the implementing FAO shall establish and maintain a Project Coordination Unit (PCU) institutions established within 30 days of with qualified staff and resources to support the management of the Effective Date. environmental and social risks and impacts of the Project, with composition, mandate and resources satisfactory to the IDA, including one Environmental and one Social Safeguard Specialists. One Environmental and one Social FAO The safeguard specialists will coordinate closely with the Regional Safeguard Specialists hired or appointed Project Coordination Units (RPCU’s) to provide support throughout within 30 days of the Effective Date. project implementation, particularly for reporting requirements. Additional expertise may be outsourced as FAO shall also, in coordination with UNDP and WFP, establish and needed. The PCU shall be maintained thereafter maintain, throughout Program implementation, a throughout Project implementation.) No Coordination Committee, composed of representatives of the sub-project activities may begin until the implementing institutions participating in the implementation, staff are hired and documents are prepared. monitoring and evaluation of the Program� International Environmental and Social UNDP shall establish and maintain a team with qualified staff and Specialist (IESS), Environmental Safeguards UNDP resources, with composition, mandate and resources satisfactory Specialist (ESS), Occupational Health and to the IDA, to support management of E&S risks, including Safety Specialist (OHS), hiring Social International Environmental and Social Specialist (IESS), Safeguard Specialist (SSA) within 30 days of Environmental Safeguards Specialist (ESS), Occupational Health the Effective Date. Staff shall be maintained and Safety Specialist (OHS), hiring Social Safeguard Specialist (SSA) throughout project implementation. No or any relevant position for ESHS. sub-project activities may begin until the staff are hired and documents are prepared. WFP shall establish and maintain a team of qualified staff, with A team of qualified staff including expertise composition, mandate and resources satisfactory to the IDA, in nutrition, gender & GBV, resilience and WFP 5|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) including staff with expertise in nutrition, gender & GBV, resilience livelihoods interventions will be hired or and livelihoods interventions, to implement the Project and to appointed within 30 days of the Effective support the management of ESHS risks and impacts. Furthermore, Date and shall be maintained throughout WFP will define their respective management structures to Project implementation. No sub-project implement the Project and reflect those structures in the final SEP activities may begin until the staff are hired (due two months after the Project Effective Date). WFP will identify and documents are prepared. qualified staff and resources to be funded by the Project, including staff with environmental and social expertise, depending on the nature of the project components implemented by each agency, to be assigned to the Project and to support the management of ESHS risks and impacts. 1.2 ENVIRONMENTAL AND SOCIAL ASSESSMENT In accordance with ESS1, assess the environmental and social risks The final ESMF shall be prepared, disclosed, FAO, UNDP, WFP (in close and impacts of proposed Project activities and prepare, disclose, consulted upon, and adopted within 30 days collaboration with SFD, SMEPS, consult upon, adopt, and implement thereafter an Environmental of the Effective Date, and prior to the and PWP). and Social Management Framework (ESMF) which shall include carrying out of any project activities that measures to address risks relating to Occupational Health and have any E&S risks. The ESMF will be Safety (OHS) and SEA/SH. implemented throughout the project. 1.3 ENVIRONMENTAL & SOCIAL MANAGEMENT TOOLS AND INSTRUMENTS Prepare, disclose, consult upon, adopt, and implement subsequent Plans or instruments to be prepared, FAO, UNDP, WFP (in close Environmental and Social Management Plans (ESMPs) and/or disclosed, consulted upon, and adopted at collaboration with SFD, SMEPS, other instruments (e.g. LMP, Simplified PMP, etc.) as required for least three weeks prior to the and PWP). the respective Project activities based on the safeguards screening implementation of the relevant Project for that subproject. All documents must abide by the ESSs, activities and implemented throughout the recognized Environmental, Health, and Safety Guidelines (EHSGs), project. and other relevant Good International Industry Practice (GIIP). 6|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) 1.4 MANAGEMENT OF CONTRACTORS & SUB-PROJECT IMPLEMENTATION Ensure that the relevant environmental and social requirements Update procurement documents and FAO, UNDP, WFP, SFD, SMEPS, (e.g. ESCP, including, inter-alia, ESMPs, Labor Management contracts by incorporating relevant E&S and PWP. Procedures, and any other ESHS measures) are incorporated into provisions: (i) prior to launching the the project tender/procurement and contractual documents and procurement process for the relevant Cash- reflected in the implementation partners’/contractor’s ESMP (C- for-Work and other Project activities (e.g. ESMP). Contractors are thereafter obliged by law to comply with Community Assets activities); and (ii) as the ESHS specifications of their respective contracts. needed throughout project implementation, in instances where project These requirements include obligations: activities have changed. • To develop a site-specific GBV/SEA/SH action plan, Labor FAO, UNDP, WFP, SFD, SMEPS, Management Procedures, ESHS specifications and waste Collect the monthly monitoring surveys from the contractors throughout Project and PWP. management, the EHSGs and other relevant GIIP; a security plan. Implementation, with the surveys • An Environmental, Social, Health and Safety (ESHS) Specialist beginning after the first 30 days of as the Contractor’s Key Personnel at the Site. implementing the contracted activities. • The obligation to sign Code of Conduct (CoC) for all cash-for- work laborers / Contractors’ employees and subcontractors. Ensure thereafter that the supervision team /contractors comply with the above during their contract execution. 7|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) 1.5 EXCLUSIONS: The following types of activities will be excluded/ineligible for An exclusion list will be created during the FAO, UNDP, WFP (with financing under the Project, and will be reflected in the updated assessment process described under action implementation monitoring ESMF: 1.2 of this ESCP and included in the ESMF. supported by local partners – SFD, Exclusion of activities will be ongoing SMEPS, and PWP). • Activities that may cause long term, permanent and/or throughout implementation. irreversible adverse impacts (e.g. loss of major natural habitat). • Activities that have high probability of causing serious adverse effects to human health and/or the environment (not related to COVID-19 cases); • Activities that may have significant adverse social impacts and may give rise to significant social conflict. • Activities that may affect lands or vulnerable minorities. • Activities, including new construction or expansions, that involve larger scale/longer-term land acquisition/physical relocation and/or adverse impacts on cultural heritage. 8|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) ESS 2: LABOR AND WORKING CONDITIONS 2.1 LABOR MANAGEMENT PROCEDURE: The Project shall be carried LMP to be prepared, disclosed and FAO, UNDP and WFP. out in accordance with the applicable requirements of ESS2 and in adopted within 30 days of the Effective a manner acceptable to the IDA, including through, inter alia, Date and before hiring project workers implementing adequate occupational health and safety measures implemented throughout the project (including emergency preparedness and response measures), implementation. setting out a Grievance Mechanism (GM) for Project workers, and The inclusion of the LMP requirements, incorporating labor requirements into the ESHS specifications of ESHS specifications, and labor specific the procurement documents and contracts with contractors. GM into procurement documents and Prepare, adopt and implement the Labor Management Procedures contracts shall occur prior to launching (LMP) in a manner acceptable to the IDA and consistent with ESS2. the procurement process for the relevant Project activities. Ensure that contracts are signed with Project Workers in line with the applicable national framework and ESS 2 as set out in the LMP. All other actions under ESS2 (including Ensure all workers sign a Code of Conduct. monitoring of contractual compliance) shall be ongoing throughout Project implementation. 9|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) 2.2 GRIEVANCE MECHANISM FOR PROJECT WORKERS The grievance mechanism system to be FAO, UNDP, and WFP, with The grievance mechanism required under ESS2 shall be described operational within 30 days after the implementing partners (SFD, PWP in the LMP. A reporting system for GRM issues, maintained by each Effective Date, prior to engaging Project and SMEPS) under their supervision implementing partner and based on the common UN approach workers, and maintained throughout and management. and principles, shall be easily accessible to the Project Workers as project implementation. it is described in the LMP in accordance with ESS2. The GRM shall be operational within 30 days after the Effective Date and shall be maintained throughout Project implementation. While greivances will be received within the main GRM reporting systems of the implementing agencies (FAO, WFP, UNDP), grievances specifically concerning GBV/SEA/SH will be triaged and referred to GBV/SEA/SH specialists for adequate support and redress. 10 | P a g e ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) 2.3 OCCUPATIONAL HEALTH AND SAFETY (OHS) MEASURES Prepare, adopt and implement (or monitor implementation of) Daily implementation of OHS measures SFD, PWP and SEMPS under the occupational, health and safety (OHS) measures as described in the throughout the project implementation. supervision and management of ESMF and ESMPs. Implementing partners shall develop and FAO, UNDP and WFP. implement, either as sub-section of the LMP or a standalone document (and prior to the commencements of any construction work), a site-specific OHS management plan and shall perform SFD, PWP and SEMPS under the safety audits and site visits to be carried out monthly. OHS Monitoring and implementation of OHS supervision and management of requirements shall be incorporated in all contracts as part of the measures throughout Project FAO, UNDP and WFP. bidding/contractual agreements. implementation and monthly safety inspections. The Recipients shall ensure that Implementing partners will also: • Ensure that an appropriate level of management and resources are in place to comply with the OHS requirements, OHS requirements to be incorporated FAO, UNDP and WFP. including fire management, the free distribution of personal into all contracts as part of the bidding/ protective equipment (PPE) and first aid kits; contractual documents, prior to the • Provide visible commitment and leadership to occupational launching of the biding process and health and safety; throughout Project implementation. • Identify and evaluate risks and normalize the activities (rules, instructions, and procedures) to the best extent possible; • Prepare emergency plans; • Analyze all incidents and accidents; • Evaluate the indicators of OHS performance; • Carry out the internal audits of OHS MS; • Evaluate the OHS training requirements; • Carry out the medical follow-up of the workers. 11 | P a g e ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) 2.4 PROJECT WORKERS’ TRAINING: The Recipients shall ensure that Implementing partners provide The training program will commence at SFD, PWP and SMEPS under the training to all their workers, prior to any site work, on basic ESHS least one week prior to the start of supervision and management of risks associated with the proposed construction works and the activities (to ensure sensitization) and FAO, UNDP and WFP. workers’ responsibility. shall occur throughout the sub-project’s implementation. Site specific ESMPs shall include weekly toolbox meetings at the work sites with a focus on the following themes: child labor; forced labor; gender-based violence, including the mechanism for submitting GBV/SEA complaints; health and safety; compliance with codes of conduct; etc. Site engineers will provide a weekly or ad-hoc (if and when required) toolbox talks and/or meetings with the construction workers on ESHS risks associated with the construction activities, which have been executed during the past week and for those which are foreseen to be carried out during the next week. 12 | P a g e ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) ESS 3: RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT 3.1 Prepare, disclose, and implement a simplified Pest Management The PMP shall be prepared within two FAO Plan (PMP) and include measures to mitigate water, air, and soil months of the Effective Date. impacts, in accordance with ESS3 and in a manner acceptable to the IDA. The PMP will serve as a supplement to the ESMF and reflect recommendations of FAO Desert Locust Guidelines, section Implementation and monitoring for 6; the Safety and Environmental Precautions issued 2003; the FAO (in close collaboration with compliance throughout Project International Code of Conduct on Pesticide Management of the SMEPS and any local implementing implementation. WHO FAO of the United Nations issued 2014; Good Practices for partners supporting the agricultural Aerial and Ground Application of Pesticides and it will develop activities envisaged under community outreach and communication guidelines as part of the Component 2) SEP. ESS 4: COMMUNITY HEALTH AND SAFETY 4.1 TRAFFIC AND ROAD SAFETY: Recipients shall ensure that Implementing partners develop and Implementation and monitoring for SFD, PWP and SMEPS under the implement a site-specific traffic management plan (as part of the compliance will occur throughout Project supervision and management of FAO ESMP) with details on traffic volume, routes and time of travel. implementation and follow the same UNDP and WFP. The plan shall ensure placing adequate measures such as: timeframe for the preparation of the flagmen and signs along the routes, providing alternative routes, ESMPs. trained drivers employed, and vehicle safety is regularly inspected. 13 | P a g e ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) 4.2 COMMUNITY HEALTH AND SAFETY: Prepare, adopt, and implement measures to assess and manage Implementation and monitoring for SFD, PWP and SMEPS under the specific risks and impacts to the community health and safety compliance will occur throughout Project supervision and management of FAO arising from Project activities, and include these measures in the implementation and follow the same UNDP and WFP. ESMPs to be prepared in accordance with the ESMF, in line with timeframe for the preparation of the ESS4 and in a manner acceptable to the IDA. ESMPs. Recipients shall ensure that Implementing partners adopt and implement measures to minimize and mitigate risks due to communicable diseases as part of Project activities, including the risk of exposure to the Covid-19 virus for Project workers and the community. 14 | P a g e ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) 4.3 GBV AND SEA/SH RISKS: A. Prepare, adopt, and implement a Gender-Based Violence Action Plan (GBV Action Plan), to assess and manage the risks of gender-based violence (GBV) and sexual The GBV action plan as part of the ESMF FAO, UNDP, WFP, and implementing exploitation and abuse and sexual harassment (SEA/SH). to be prepared and adopted in partners (SFD, PWP, SMEPS). The action plan will include institutional and services accordance with the ESMF timeframe delivery, a Theory of Change, Standard Operating and implemented throughout Project Procedures (SOPs), a referral pathway, and clear implementation. mitigation and prevention measures. B. Mapping and situation analysis to identify the gaps and to develop mitigation measures to GBV and SEA safeguards in Yemen. C. Recruit a gender and GBV focal point. D. Provide capacity building on Gender, GBV, and in particular SEA/SH, targeting: A. senior and mid-level staff; B. Technical staff and practitioners; C. Awareness raising to the workers in the field. 4.5 SECURITY MANAGEMENT: Prepare, adopt, and implement a stand-alone Security Prior to the carrying out of any project FAO, UNDP, WFP in coordination Management Plan consistent with the requirements of ESS4, in a activities that have any security risks, and with IPs (SFD, PWP, SMEPS). manner acceptable to the IDA thereafter implemented throughout Project implementation. 15 | P a g e ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) ESS 5: LAND ACQUISITION, RESTRICTIONS ON LAND USE AND INVOLUNTARY RESETTLEMENT 5.1 RESETTLEMENT FRAMEWORK: Prepare, disclose, adopt, and implement a Resettlement Prepare, disclose, and adopt the RF within UNDP, FAO, and IP (SFD, PWP, Framework (RF) in accordance with ESS5 for potential 30 days of the Effective Date and prior to SMEPS). resettlement issues for activities under component 1 in a manner such specific activities take place and acceptable to IDA. The grievance redress mechanism (GRM) to implement the RF throughout the project address resettlement related complaints shall be described in the implementation. RF. Though large scale resettlement is included as part of the negative list, the RPF will cover minor, temporary resettlement which could arise during small works. ESS 6: BIODIVERSITY CONSERVATION AND SUSTAINABLE MANAGEMENT OF LIVING NATURAL RESOURCES 6.1 Implement relevant screening procedures and key measures from Relevant measures to be prepared and FAO (in collaboration with local the ESMF. adopted as part of the ESMF in implementing partners). accordance with the ESMF timeframe and implemented throughout the life of the project. ESS 7: INDIGENOUS PEOPLES/SUB-SAHARAN AFRICAN HISTORICALLY UNDERSERVED TRADITIONAL LOCAL COMMUNITIES 7.1 Not relevant N/A N/A ESS 8: CULTURAL HERITAGE 16 | P a g e ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) 8.1 CHANCE FINDS: Prepare, adopt and implement the chance find Chance finds procedures shall be UNDP, FAO, and implementing procedure as described in the ESMF developed for the Project included in ESMPs in accordance with the partners (SFD, PWP, SMEPS). and site-specific ESMPs. ESMP timeframe and any contractual documents shall be adopted prior to the implementation of any relevant sub- project activity. ESS 9: FINANCIAL INTERMEDIARIES Not relevant N/A N/A ESS 10: STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE 10.1 STAKEHOLDER ENGAGEMENT PLAN: Update, disclose, adopt and The preliminary SEP which is prepared FAO, UNDP and WFP. implement the Stakeholder Engagement Plan (SEP), building on and disclosed prior to Board Approval the preliminary SEP already disclosed and consistent with ESS10, shall be updated, disclosed, and adopted in a manner acceptable to the IDA. within two months of the Effective Date. The SEP shall be implemented throughout the Project implementation period. 10.2 GRIEVANCE MECHANISM: Accessible grievance arrangements The grievance mechanism system shall FAO, UNDP and WFP. shall be made publicly available to receive and facilitate resolution be operational within 30 days after the of concerns and grievances in relation to the Project, including Effective Date, prior to implementing GBV/SEA/SH allegations (to be triaged/referred to a specialist), project activities that may have any E&S consistent with ESS10, in a manner acceptable to the IDA. risks, and maintained throughout project implementation. The implementing partners (FAO, UNDP and WFP) may have a separate reporting systems for GM issues, but overall capture of Quarterly capture of project grievances FAO project grievances (as shared by other implementing partners) received by fellow implementation must be tracked by FAO, the FAO/UNDP/WFP shall be responsible partners for unified reporting purposes, for coordinate with the local partners for reporting. throughout project implementation. 17 | P a g e ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) CAPACITY SUPPORT (TRAINING) Training topics for personnel involved in Project implementation Throughout Project implementation, FAO, UNDP and WFP. will include, but are not limited to: with initial sensitization trainings held at • Training of FAO, UNDP, WFP and implementing partners’ least one week prior to the start of sub- staff on ESS procedures, including implementation, project activities. management of contractors, and monitoring and evaluation. • Training of Trainers (TOT) training on environmental and social assessment and management (for UNDP, FAO, WFP and implementation partners’ professional staff); • Training on the GRMs (project level, ESS2, and handling of GBV/SEA/SH reports when received through those GRMs) • Code of conduct to prevent SEA/SH • TOT on gender, GBV, and community response and protection • Training of contracted parties on labor management and monitoring/reporting requirements • Training of field staff/workers on community management of acute malnutrition, awareness on the prevention of the spread of infectious diseases and health practices. • Training of field staff/workers on OHS measures • Training of technicians on pesticide management, application techniques, and necessary personal protective equipment (PPE). 18 | P a g e