Environmental and Social Management Framework (ESMF) Project: Improving Early Childhood Development (ECD) (P168295) Version for Restructuring September, 2021 List of Acronyms ADHD Attention Deficit Hyperactivity Disorder D.G. Directorate General CAE Child Abuse/Exploitation ECD Early Childhood Development EHSO Environmental, Health, and Social Officer EHS Environmental, Health, and Safety EHSG Environmental, Health, and Safety Guidelines EIA Environmental Impact Assessment EQA Environment Quality Authority ESC Environmental and Social Consultant EM Environmental Matrix EMP Environmental Management Plan ES Environmental and Social ESCHIA Environmental, Social, and Cultural Heritage Impact Assessment ESCP Environmental and Social Commitment Plan ESF Environmental and Social Framework ESHS-MP Environmental, Social, Health, and Safety Management Plan EIA Environmental Impact Assessment ESIA Environmental and Social Impact Assessment ESMF Environmental and Social Management Framework ESMP Environmental and Social Management Plan ESMS Environmental and Social Management System ESO Environmental and Social Officer ESRC Environmental and Social Risk Classification ESSs Environmental and Social Standards FIDIC The International Federation of Consulting Engineers GBV Gender Based Violence GM Grievance Mechanism IEE Initial Environmental Examination/Evaluation KG2 Kindergarten Grade 2 LAL Land Acquisition Law LMP Labor Management Procedures LTC Local Technical Consultant LVC Land Valuation Committee M&E Monitoring and Evaluation MDLF Municipal Development and Lending Fund MHPSS Mental Health and Psychosocial Support MOE Ministry of Education MOH Ministry of Health 1|Page MOSD Ministry of Social Development MOT Ministry of Transportation MoTA Ministry of Tourism and Antiques MoPWH Ministry of Public Works and Housing OHS Operation Health and Safety PA Palestinian Authority PCRs Physical Cultural Resources PCU Projects Coordination Unit PEAP Palestinian Environmental Assessment Policy PEL Palestinian Environmental Law PLA Palestinian Land Authority PMU Project Management Unit SEF Stakeholder Engagement Framework SEP Stakeholder Engagement Plan TLM Teaching and Learning Materials WB World Bank 2|Page Table of Contents Executive Summary................................................................................................................... 7 ‫ الملخص التنفيذي‬.......................................................................................................................... 15 Chapter one: Introduction ...................................................................................................... 22 1.1. Background .............................................................................................................. 22 1.2. Organization of the Framework .............................................................................. 23 Chapter Two: Project Description ........................................................................................... 24 2.1 Introduction.............................................................................................................. 24 2.2 ECD Project Components (parent project and restructuring) ................................. 24 2.3 ECD Project Environmental and Social Progress ...................................................... 27 Chapter Three: Environmental and Social Legal Framework ................................................. 30 3.1 Introduction.............................................................................................................. 30 3.2 Palestinian Laws and Regulations Related to Environmental Management ........... 30 3.2.1 Palestinian Environment Law ........................................................................................ 30 3.2.2 Palestinian Environmental Assessment Policy .............................................................. 30 3.2.3 General Rules for the Protection of Historic Areas ....................................................... 31 3.2.4 Other Laws and Regulations relating to Environment Management ........................... 31 3.2.5 Laws and Regulations for Waste Management ............................................................ 32 3.2.6 Medical Waste Bylaw (2012) ........................................................................................ 33 3.2.7 Laws and Regulations Relating to Labor ....................................................................... 33 3.2.8 Labor and Occupational Health and Safety related to COVID-19 ................................. 33 3.3 World Bank ESF ........................................................................................................ 34 3.4 WB ESF and Palestinian Laws and Regulations Gap Analysis................................... 35 Chapter Four: Environmental and Social Baseline Information ............................................. 39 4.1 Introduction.............................................................................................................. 39 4.2 Available reports on the baseline environmental and social information .............. 39 Chapter Five: Environmental and Social Impacts .................................................................. 40 5.1. Assessment of Environmental and Social Risks of the ECD project ......................... 40 5.2. Environmental and Social Risk Classification (ESRC) ................................................ 41 i. Type, location, sensitivity and scale of the project including the physical considerations of the project..................................................................................................................................... 41 ii. Nature and magnitude of the potential ES risks and impacts (e.g., whether they are irreversible, unprecedented, or complex). ................................................................................... 42 3|Page 5.3. Applicability of WB ESSs and risk assessment.......................................................... 44 5.3.1 ESS1 Assessment and Management of Environmental and Social Risks and Impacts: 44 5.3.2 ESS2 Labor and Working Conditions ............................................................................. 45 5.3.3 ESS3 Resource Efficiency and Pollution Prevention and Management ........................ 46 5.3.4 ESS4 Community Health and Safety.............................................................................. 46 5.3.5 ESS5 Land Acquisition, Restrictions on Land Use, and Involuntary Resettlement: ...... 47 5.3.6 ESS6 Biodiversity Conservation and Sustainable Management of Living Natural Resources ...................................................................................................................................... 47 5.3.7 ESS7 Indigenous Peoples/Sub-Saharan African Historically Underserved Traditional Local Communities ........................................................................................................................ 47 5.3.8 ESS8 Cultural Heritage .................................................................................................. 47 5.3.9 ESS9 Financial Intermediaries ....................................................................................... 47 5.3.10 ESS10 Stakeholder Engagement and Information Disclosure....................................... 47 5.4 Summary of ECD sub-projects’ Environmental and Social Risks and Impacts ......... 49 5.4.1 Summary of risks associated with construction and operation phases........................ 49 5.4.2 Summary of potential risks ........................................................................................... 50 Chapter Six: Procedures To Address Environmental And Social Issues ................................. 52 6.1 The Environmental and Social Screening Process .................................................... 52 6.2 Mitigation Measures ................................................................................................ 53 6.2.1 Mitigation Measures for Air Quality ............................................................................. 53 6.2.2 Mitigation Measures for Noise ..................................................................................... 54 6.2.3 Mitigation Measures for Generated Non-Hazardous and Hazardous Waste ............... 54 6.2.4 Measures for addressing GBV, SEA/SH Risks and Impacts ........................................... 54 6.2.5 Measures for management of Occupational Health and Safety .................................. 55 6.3 Environmental and Social Management Plan (ESMP) ............................................. 56 Chapter Seven: Stakeholder Engagement, Grievance Mechanism and Information Disclosure 58 7.1 Consultation and Disclosure..................................................................................... 58 7.2 Grievance Mechanism .............................................................................................. 59 7.3 Grievance mechanism and process for complaints related to GBV and SEA/SH..... 61 7.4 Workers’ Grievance Mechanism .............................................................................. 62 7.5 Code of Conduct and SEA/SH Measures .................................................................. 62 4|Page Chapter Eight: Institutional Arrangements , Responsibilities and Capacity Building Requirements .......................................................................................................................... 63 8.1 Institutional Structure .............................................................................................. 63 8.1.2 Organizational Structure of the D.G. of Buildings ......................................................... 63 8.2 Institutional arrangements and responsibilities ............................................................... 64 8.3 Environmental and Social Capacity Building ............................................................ 67 8.4 Environmental and Social Liability of Contractors ................................................... 68 8.5 Environmental and Social Monitoring and Evaluation Arrangements .................... 70 8.5.1 Environmental and Social Monitoring .......................................................................... 70 8.5.2 Environmental and Social Monitoring and Reporting................................................... 70 8.6 Budget and resources for the implementation of the ESMF ................................... 71 Annexes ................................................................................................................................... 73 Annex 1: Applicable WB ESSs .................................................................................................. 73 Annex 2: Chance Find Procedures .......................................................................................... 77 Annex 3: Environmental and Social screening checklist ........................................................ 78 Annex 4: Environmental and Social screening checklist (For Projects in Gaza Strip affected by the hostilities) .................................................................................................................... 83 Annex 4: ESMP Template ........................................................................................................ 89 Annex 6: ESMP Checklist for the Small-Scale Rehabilitation Sub-projects ............................ 95 Annex 7: Environmental and Social Management Guidelines for Contractors .................... 112 Annex 8: Contractor’s Commitment of Environmental and Social Compliance and Penalties 116 Annex 9: Duties and Responsibilities of MOE throughout Project Cycle ............................. 117 Annex 10: Form for Environmental and Social Management and Monitoring .................... 118 Annex 5: Grievance Mechanism Checklist ............................................................................ 122 Annex 12: Brief Overview of Labor Legislation: Terms and Conditions ............................... 123 Annex 13:The Code of Conduct (Arabic)............................................................................... 125 Annex 14: Environmental and Social capacity Assessment of MOE..................................... 128 Current Structure of D.G. of Buildings ....................................................................................... 128 Environmental and Social Capacity Assessment ....................................................................... 129 Capacity Risk Assessment .......................................................................................................... 130 Capacity Assessment Results ..................................................................................................... 131 Required Capacity Building ........................................................................................................ 132 5|Page Annex 15: ESMF Compliance Forms and Penalties Deduction Methodology for National Competitive Bids and Shopping Bids .................................................................................... 134 List of Charts Chart 1: Parties involved in construction/refurbishment activities in West Bank and Gaza ................ 63 Chart 2: Institutional Structure of D.G. of Building ............................................................................... 64 Chart 3: Duties and Responsibilities of MOE throughout Project Cycle ............................................. 117 Chart 4: Institutional Structure of D.G. of Building ............................................................................. 129 List of Tables Table 1: List of Equipment to be procured under MoH Subcomponent 1.1 ........................................ 28 Table 2: Gap Analysis of Applicable ESSs and Palestinian’s National laws and Regulations ................ 35 Table 3: Project Activities and Potential Impacts during Construction Phase ...................................... 50 Table 4: Main ES Risks for New, Extension, and Refurbishment KGs/Schools in West Bank and Gaza, and minor Civil Works at Health Care Centers. .................................................................................... 51 Table 5: Proposed Workshops/Seminars for different Target Groups ................................................. 68 Table 6: ESMF Cost Estimate................................................................................................................. 72 Table 7: World Bank ESSs and Core Requirements.............................................................................. 73 Table 8: Capacity Risk Analysis............................................................................................................ 130 6|Page Executive Summary Improving Early Childhood Development (ECD) project, approved in December 2019, aims to improve the coverage and quality of early childhood development services for children from gestation until age 5 in the West Bank. The project components are as follows: • Component 1: Health Care: Promoting early health development: Subcomponent 1.1: Strengthening prenatal and postnatal care Subcomponent 1.2: Strengthening early nutrition and simulation during the first 1,000 critical days of life This component will be under the leadership of the Ministry of Health (MOH). • Component 2 – Education: Improving access to high quality KG services Subcomponent 2.1: Expanding access to Kindergarten Grade 2 KG2 Subcomponent 2.2: Enhancing quality of KG services This component will be under the leadership of Ministry of Education (MOE). • Component 3 –: Improving availability of ECD Data This component will be under the leadership of the MOE, in close collaboration with the Ministry of Social Development (MOSD). Given the substantial needs of KG age children in Gaza, MOE has requested reallocating the financing under Component 3 of the project, to repair infrastructure damages to KGs and provide learning materials. • Component 4: Project management and implementation support Subcomponent 4.1: Project management and implementation support for MOH- under the leadership of MOH. Subcomponent 4.2: Project management and implementation support for MOE- under the leadership of MOE. The project will be implemented by three-line ministries including MOE, MOH and MOSD. The project components, especially those implemented by MOH and MOSD, have no major adverse environmental and social (E&S) risks/impacts, but rather positive E&S impacts. These components include improving coverage and quality service delivery types of activities or supply of equipment and these activities do not include construction of infrastructure and/or waste management aspects. The second component of the ECD project, within the responsibility of MOE, includes construction activities such as refurbishment of KGs/schools’ classrooms, possibly supply of furniture, play areas, kitchen and rest rooms that are likely to have negative environmental and social impacts. The classification of risks associated with this kind of activities is assessed as medium to low risk. These risks are addressed in this Environmental and Social Management Framework (ESMF), therefore when proceeding with preparation of any subproject with construction activities, it is necessary to follow this ESMF. Project Restructuring Eleven days of war and hostilities afflicted Gaza in May 2021. The human toll in the strip mounted to almost 2,000 Palestinians physically injured, including over 600 children; and 260 Palestinians killed, including 66 children and 41 women. Core physical infrastructure, also including schools and health centers, was also damaged. Children in the 0-5 age bracket were 7|Page especially vulnerable to the devastation and shocks caused by the war in Gaza. In particular, the war had a dramatic impact on children’s physical and psychological health and children in Gaza are in dire need of mental health and psychosocial support services (MHPSS). Beyond the direct impact on children’s wellbeing, the war also destroyed or impaired the delivery of key services for children including access to KG services and loss of learning materials. In order to address the emergency in Gaza, the MOH and the MOE have requested that the project be restructured, and unutilized funds be reallocated to finance activities in Gaza. Given the substantial needs of KG age children in Gaza, MOE has requested reallocating the financing under Component 3 of the project, to repair infrastructure damages to KGs and provide learning materials. While activities under Component 3 (“Improving availability of ECD data”) of the project are important, the MOE considers that they are not a priority in the current context of humanitarian crisis. Where: • Approximately US$140,000 will be reallocated to subcomponent 2.1 to finance reparations of infrastructure damages to KGs in Gaza. Damages to KG infrastructure in Gaza range from minor to moderate. • Roughly US$460,000 will be reallocated to subcomponent 2.2 to finance relevant teaching and learning materials to KG age children in Gaza. To help address the urgent mental health and psychosocial needs of children in Gaza, the MOH has requested the redistribution of funds under sub-component 1.2 US$600,000 from sub-component 1.2 that will be reallocated to support MHPSS services for children and their caregivers where the project will support the establishment and strengthening of MHPSS services in Gaza through a multi-layered approach: (1) identification, referral and immediate care, (2) focused on non-specialized care at the community mental health centers, and (3) specialized services. Legal Framework MOE, when preparing subproject proposal/appraisal to be financed by ECD project, would have complied with the Palestinian laws and regulations including revised Palestinian Basic Law of 2003, Palestinian Environmental Law No. 7, 1999, The National Strategy for Solid Waste Management for the period 2017-2022, The Medical Waste Bylaw related to medical waste management and handling No. 10 for the year 2012, the Environmental Assessment Policy resolution No: 27 23/4/2000, the Palestinian Labor Law No 7, 2000, the Palestinian Public Health Law No 20, 2004, the MOH guidelines to combat COVID-19, the Grievance and Complaints bylaw; approved by the Ministerial Cabinet on 9/3/2005 and updated on 8/3/2009, Palestinian Ministerial Decision (6) of year 2020 on Codes of Conduct which includes generic instructions for conducting the relation between coworkers, the public and administration and the Jordanian Heritage law No. 51 for the year 1966 . In addition, the project implementation complies with the WB Environmental and Social Framework (ESF), and the Bank Environmental Health and Safety Guidelines.. However, the national legislation does not include procedures for screening smaller-scale investments for potential adverse environmental and social impacts. To close this gap between national legislation and the Bank’s ESF, which requires that all investments proposed for Bank-financing are screened against the 10 Environmental and Social Standards 8|Page (ESSs) for potential adverse environmental and social impacts and appropriate environmental instruments, a screening was prepared. Based on the screening results, this ESMF is being prepared. The following standards applies for the project: ESS1, ESS2, ESS3, ESS4 and ESS10. Institutional and Implementation Arrangements MOH will hold the responsibility for procurement under Components 1 and 4.1 while MOE will hold responsibility for procurement under Components 2, the restructured component 3, and 4.2. D.G. of Buildings at the MOE together with PCU will be responsible for following up on the compliance with the environmental and social requirements. An Environmental and Social Officer (ESO) has been hired at the PCU to ensure the implementation of environmental and social requirements. MOH has appointed an Environmental and Health and Safety Officer (EHSO) to coordinate with the ESO at the MOE regarding the MOH related activities. In addition, the PCU has hired a qualified Environmental and Social Consultant (ESC) who will be responsible for the implementation of the project’s environmental and social requirements for activities implemented in the Gaza Strip. Environmental and Social Classification and Assessment of Risks and mitigation measures The rated environmental and social risk of the Project is moderate which indicates a moderate likelihood of adverse impacts associated with project implementation. The environmental and social risks associated with construction activities of the sub-projects during the construction phase include noise, dust, solid waste and wastewater, community and labor health and safety, and traffic safety. These risks and impacts could become a source of grievance. Activities under subcomponent 1.2 and 2.2 are of low risk. This ESMF provides guidance for classification and assessment of risks and impacts and resulting in environmental and social impacts specifically identified in ESSs 1–10. Forms have been developed to facilitate conducting sub-project classification, assessment, risks and impacts, and environmental and social management and monitoring for subprojects including construction activities. As sub-project locations have been determined, MOE and MOH used the forms that were developed in the ESMF to identify and assess the environmental and social impacts, both adverse and beneficial, in the project’s area of influence in order to avoid, or where avoidance is not possible, minimize, mitigate, or compensate for adverse impacts on workers, affected communities, and the environment. The same forms and mitigation requirements apply for the restructuring activities. Sub-projects with construction activities entail risks and mitigation measures as identified in ESS1, ESS2, ESS3, ESS4, and ESS10 in addition to risks related to the, MOE and MoH’s capacity to effectively implement the ESMF and the Environmental and Social Management Plan (ESMP), ESMP checklist, and the stakeholder engagement and information disclosure Plan. All project activities shall be subject to environmental and social screening. 9|Page This ESMF provides ESMP and ESMP Checklist Templates, in addition to identifying generic mitigation measures and monitoring requirements of the risks and impacts of construction subprojects. A site-specific ESMP or ESMP checklist will be prepared once the exact location of subproject is identified. The site-specific ESMP should be included in the tender documentation, so that potential bidders are aware of site specific environmental and social requirements and are able to reflect that in their bids. Further, environmental and social liabilities of MOE section which was adapted from the ESMF prepared for Municipal Development Program Phase III is prepared where breakdown for the cost of each mitigation measure noncompliance is detailed, and will be enclosed in bidding documents. The ESMP also include environmental and social management guidelines for ECD contactors. All site- specific ESMPs or ESMP checklist will be prepared, reviewed and approved by the Ministry of Education, prior to submission to the World Bank team. Labor Management Procedures (LMP) prepared for the original project is being updated in line with the project restructuring to set out the Project’s approach to meet national requirements as well as the objectives of the Bank’s Environmental and Social Fra mework (ESF). Specifically, objectives of ESS 2: Labor and Working Conditions and ESS4: Community Health and Safety. It enables different project-related parties including direct workers who will be assigned to work on this Project, contractors and sub-contractors and contracted workers, to have a clear understanding of what is required on a specific labor issue. Land Acquisition, Restrictions on Land Use and Involuntary Resettlement (ESS5) is not relevant to the ECD construction sub-projects since the expansion of KGs/Schools classrooms in schools, as well as the rehabilitation works of KGs under the restructuring activities will be done within the existing footprints of KGs/schools. ESS6, ESS7, ESS8, and ESS9 are not expected to be relevant to the project. However, a chance find may occur whereby historical and cultural property is inadvertently found. The original project’s Environmental and Social Commitment Plan (ESCP) had been updated in agreement with the Bank that sets out a summary of the material measures and actions for mitigation and monitoring. For the restructuring activities, and to include the activities directed to Gaza the Stakeholder Engagement Plan (SEP) had been updated and disclosed. The risk associated with the current institutional structure setup at the three ministries to handle the implementation and management of the ECD project is assessed and found to be Moderate. Capacity building of MOE was achieved through hiring an ESO and providing required training so that the implementation of the environmental and social aspects of the ECD project can be adequately managed and monitored. The project also benefits from an ESC to support the environmental and social compliance for activities implemented in Gaza Strip. The ESO also coordinates with the EHSO at the MOH for the health-related activities in West Bank and Gaza Strip. This ESMF includes measures to mitigate risks of sexual exploitation and abuse (SEA) and sexual harassment (SH) and labor issues including guidelines for the establishment of a functioning grievance mechanism (GM) for project workers. The project level GM will include specific procedures for SEA/SH including confidential reporting and ethical documentation of gender-based violence (GBV) cases. Information about the existence of the GBV grievance mechanism and of channels to accept and respond to 10 | P a g e anonymous grievances will be communicated to all stakeholders during engagement activities. The project will ensure the avoidance of any form of SEA/SH of affected people and community members at large by relying on the provisions of labor law and the World Bank guidelines on the mitigation of SEA/SH such as the signing of enforceable workers’ codes of conduct. In addition, all project activities shall comply with the provisions included in the ESMF on the health and safety of workers and workers’ rights such as coverage under a valid insurance, provision of proper PPE, and provision of a safe environment for work. Children under 18 years old will not be accepted to work in any of the subprojects. Workers also need to be oriented before the start the work. Code of Conduct shall be written in local language; Codes of Conducts and provisions related to SEA/SH shall be incorporated into the bidding documents. Hence, measures regarding to COVID 19 situation should be followed and complied according to the MoH/WHO guidelines. On the social side, the overall social risk remains moderate. The classroom construction under Component 2 will be done within the existing footprint of the existing schools and hence, no land acquisition is anticipated. This will also be further assessed during preparation of sub- projects. Rehabilitation of damaged private KGs in Gaza will also be done in the existing footprint of the facilities and no land acquisition issues are involved. The primary social risk is of potential exclusion of some vulnerable groups and communities (e.g. those living in remote locations and access restricted areas, women headed households, the forcibly displaced including those living with host families, etc.) and unregistered private KG service providers from project benefits. In general, the private sector is the provider of KG2 classrooms in Gaza and since one of the components of this project is assistance for rehabilitation of KG2 classrooms (Component 2.1), those private sector providers that are not registered due to the cost involved and the children using their services, could be excluded from project benefits. Similarly, there is a potential risk that the most vulnerable groups and communities may not be able to access and benefit from project interventions (e.g. provision and proper use of child kits and access to mental health and psychosocial support at the community and primary health center levels) due to issues with targeting, outreach, and availability of requisite information. Mitigation measures to manage these risks of exclusion are included in this ESMF and in the project design. The rehabilitation works in KGs and small-scale civil works in the community mental health centers (e.g., painting of rooms, installation of machines etc.) entail possible labor and workers’ health and safety risks and impacts. The project’s LMP is being updated to reflect any new project workers as a result of the restructuring and will include health and safety mitigation measures. The updated LMP will be cleared and disclosed, as agreed in the project’s ESCP, in the beginning of September. There is a moderate risk of SEA/SH/GBV due to construction/rehabilitation related activities in schools and healthcare centers and requisite mitigation measures will be included in the relevant E&S plans that will be prepared prior to initiating construction. 11 | P a g e Finally, grievance mechanisms within each ministry are in place and are being coordinated through the PCU for the purposes of the project. These mechanisms will continue to be strengthened as required. Environmental and Social Monitoring Currently, MOE’s ESO has been assigned to be part of the PCU team that is responsible for implementing the Project construction activities. At MoH an EHSO has been assigned to coordinate the health-related component with the ESO. The ESO shall supervise the implementation of the ESMF and monitor the compliance of suppliers/contractors to the provisions of the ESMPs, SEF/SEP, and LMP in coordination with the EHSO. A system and setup for the ESO for environmental and social monitoring and reporting for subprojects has been developed at the MOE. The ESO is responsible to instruct contractors on the compliance with the ESMP, SEF/SEP, and LMP. The ESO shall conduct regular supervisory and environmental and social monitoring visits to verify contractors’ adherence to the requirements set out in the environmental and social instruments and produce the required reports. Duties and responsibility of MOE during project cycle are defined. For the restructuring activities in Gaza Strip, the ESC in Gaza will ensure that the restructuring activities are implemented in accordance with the environmental and social requirements. Forms for site visit reports, monthly/quarterly reports, project final report are prepared and shall be filled by ESO. Frequency of reporting should be determined based on project size, complexity, and duration. These forms include detailed reporting of the status of environmental and social performance under the ECD construction subprojects, including overview of deviations/violations of ESMP and other plans encountered over the report period, instructions given to contractors for addressing noncompliance and identified issues, and follow-up actions on the revealed outstanding matters. ESO’s reports will include, in addition to summary of site visits, documentation of meetings, contractor’s action during construction stage, environmental and social training and on -job training for the workers, summary of the raised environmental and social issue, ES notes, and complaints and how complaints have been followed. ESMF Cost Implications The cost is estimated for ESMF implementation related to beneficiaries and stakeholder trainings, and hiring and training of ESO, EHSO, and ESC to support MOE and MoH in the implementation of the ESMF. The indicative budget associated with implementing the ESMF and monitoring of environmental and social risks associated with the project is estimated at $275,800. Time frame of the updated ESMF This updated ESMF will come into effect upon endorsement by MoE and MoH, and will remain valid during planning, design, construction and operation of proposed investments. The ESMF 12 | P a g e will require periodic updating in view of emerging experiences during planning, design construction and operation stages or due to any changes in Palestinian laws etc. Stakeholder Engagement WB ESS10 recognizes the importance of open and transparent engagement between the Borrower and project stakeholders as an essential element of Good International Industry Practice (GIIP). Effective stakeholder engagement can improve the environmental and social sustainability of projects, enhance project acceptance, and make a significant contribution to successful project design and implementation. During the preparation of the ESMF, stakeholder engagement was ensured via conducting visits to the three-line Ministries and stakeholder consultation. Information about the ECD project components and subcomponents, potential risks and impact from the project were discussed and communicated with the three Ministries and stakeholders. Public Consultation for the Parent Project Due to the emergency situation in Palestine and the COVID 19 restrictions that prohibited the gathering of more than three (03) persons as per the MoH instructions, public consultation meeting was carried out virtually via Microsoft Teams technology on the 4th of May 2021. 37 of stakeholders from different institutions attended the workshop (more than 20 of stakeholders are representatives from the women, youth, community representatives, municipalities, etc.). Other stakeholders included representatives from the ministries and public authorities such as MOE, MOH and MOSD. The environmental and social risks and mitigation measures were covered and consulted with all attendees. Participants did not raise any concerns regarding the environmental and social issues relating to the project, mainly all of them have a good background from previous similar projects. In turn, the ESO explained and illustrated the WB Environmental and Social standards for all the attendees and discussed the ESSs associated with the project. The ESO discussed the GM Manual during the Public Consultation and presented all the tools available to file a grievance during the project implementation. Consultation meetings for project restructuring A round of public consultations was conducted for project restructuring. The first consultation meeting was conducted on July 11, 2021 in Gaza City. About 40 persons, representing different groups and with different interests, attended the workshop, with representatives from MOE, Projects Coordination Unit (PCU), KGs’ headmistress/owners, KG Children’s parents and local and international NGOs. The second consultation was conducted on August 08, 2021. About 32 persons, representing different groups and with different interests, attended the workshop, with representatives from different departments at the MOH, United Nations Relief and Works Agency for Palestine Refugees (UNRWA), World Health Organization (WHO), MOE, MOSD, KGs’ headmistress/owners, KG Children’s parents and local NGOs providing MHPSS services. The ESO at the MOE and the Project coordinator at the MOH from the West Bank also attended the meeting remotely via Microsoft Teams. 13 | P a g e The consultation meetings introduced the participants to the stakeholder engagement plan (SEP) and the ESMF. Participants were also provided information regarding the Grievance Redress Mechanism (GM) that is in place. The presentation highlighted, in detail, the new emergency areas of intervention under the restructuring, as well as the objective and content of the SEP and the ESMF. The presentation also highlighted the special provisions for vulnerable groups and the details of the GM, including the different steps of the grievance resolution process, focusing on the different complaint uptake channels, and the special referral pathways for the project related GBV/SEA/SH complaints and grievances. The last part of the meeting was dedicated for discussion of the participants’ concerns or expectations associated with the Project and the restructured activities as well as the SEP and the ESMF. All concerns, comments and recommendations raised by the participants during the discussions as well as the provided response to these concerns are detailed in the project’s SEP. Consultation sessions were conducted in compliance with the WB COVD-19 note on “Public Consultations and Stakeholder Engagement in WB-supported operations when there are constraints on conducting public meetings”. A detailed report of the meeting, including participants’ feedback and attendance sheet are include in the project’s updated SEP. 14 | P a g e ‫الملخص التنفيذي‬ ‫يهدف مشروع تنمية الطفولة المبكرة‪ ،‬المعتمد في تاريخ كانون األول ‪ ،2019‬إلى تحسين التغطية وتطوير الخدمات الممنوحة‬ ‫لألطفال من لحظة الوالدة وحتى سن الخامسة في منطقة الضفة الغربية وقطاع غزة‪ .‬ويضم هذا المشروع المكونات التالية‪:‬‬ ‫المكون ‪ :1‬الرعاية الصحية‪ :‬تعزيز العناية الصحية المبكرة‬ ‫•‬ ‫المكون ‪ :1.1‬تحسين الرعاية الصحية قبل الوالدة وبعدها‬ ‫المكون ‪ :1.2‬تطوير التغذية المبكرة والمحاكاة خالل األيام األولى الحرجة من حياة الطفل (أول ‪ 1000‬يوم)‬ ‫وسيتم إدارة هذا المكون من قبل وزارة الصحة‬ ‫المكون ‪ :2‬التعليم‪ :‬تحسين الوصول إلى رياض أطفال ذات جودة‬ ‫•‬ ‫المكون ‪ :2.1‬تحسين الوصول إلى رياض األطفال‬ ‫المكون ‪ :2.2‬تطوير جودة رياض األطفال‬ ‫وسيكون هذا المكون تحت إدارة وزارة التربية والتعليم‬ ‫المكون ‪ :3‬تحسين إمكانية الوصول إلى بيانات الطفولة المبكرة‬ ‫•‬ ‫سيكون هذا المكون تحت إدارة وزارة التربية والتعليم وبالتعاون مع وزارة التنمية االجتماعية‪ ،‬تم تحويل المنحة‬ ‫المخصصة لهذه الفعالية لصالح اعادة تأهيل الحضانات وتوفير المواد التعليمية في قطاع غزة‪.‬‬ ‫المكون ‪ :4‬إدارة المشروع والدعم التنفيذي‬ ‫•‬ ‫المكون ‪ :4.1‬إدارة المشروع والدعم التنفيذي لوزارة الصحة تحت إدارة وزارة الصحة‬ ‫المكون ‪ :4.2‬إدارة المشروع والدعم التنفيذي لوزارة التربية والتعليم تحت إدارة وزارة التربية والتعليم‬ ‫سيتم تنفيذ المشروع من قبل الوزارات الثالث‪ ،‬وهم‪ :‬وزارة التربية والتعليم‪ ،‬وزارة الصحة‪ ،‬ووزارة التنمية االجتماعية‪ .‬إن‬ ‫مكونات مشروع تنمية الطفولة المبكرة‪ ،‬وخاصة تلك التي سيتم تنفيذها من خالل وزارتي الصحة والتنمية االجتماعية‪ ،‬ليس‬ ‫لديها أي أثر بيئي أو اجتماعي يذكر‪ .‬فهذه المكونات ستكون محصورة في تحسين التغطية والجودة للخدمات المقدمة أو‬ ‫التزويد بمعدات‪ ،‬ولذلك طبيعة هذه األنشطة ال تشمل أي عمليات انشاء للبنية التحتية أو ال ينتج عنها أي تلوث‪.‬‬ ‫أما بالنسبة للمكون الثاني‪ ،‬تحت إدارة وزارة التربية والتعليم‪ ،‬فهو يشتمل على أعمال بناء مثل بناء أو ترميم فصول رياض‬ ‫االطفال في المدارس ‪ ،‬باإلضافة إلى توريد األثاث ومناطق اللعب والمطابخ وغرف االستراحة ‪ ،‬والتي من المحتمل أن يكون‬ ‫لها آثار بيئية واجتماعية سلبية‪ .‬يمكن تصنيف المخاطر المرتبطة بأنشطة هذا المكون على أنها مخاطر متوسطة إلى منخفضة‬ ‫‪15 | P a g e‬‬ ‫التأثير‪ .‬وسيتم التطرق إلى هذه المخاطر في هذا التقرير االطار المرجعي لإلدارة البيئية واالجتماعية (‪ ، )ESMF‬وبالتالي‬ ‫عند المضي بالتحضير لجزئية المكون الثاني من هذا المشروع‪ ،‬من الضروري الرجوع إلى اإلطار البيئي واالجتماعي‪.‬‬ ‫إعادة هيكلية المشروع‬ ‫شهد قطاع غزة على احدى عشر يوما ً من الحرب واألعمال العدوانية في مايو ‪ .2021‬وصل عدد المصابين على أثرها في‬ ‫القطاع إلى ‪ 2000‬فلسطيني‪ ،‬منهم أكثر من ‪ 600‬طفل‪ ،‬واستشهاد ‪ 260‬فلسطيني من ضمنهم ‪ 66‬طفل و‪ 41‬امرأة‪ .‬كما‬ ‫وتضررت البنية التحتية األساسية ‪ ،‬بما في ذلك المدارس والمراكز الصحية‪ .‬نتيجة لهذه الحرب على غزة‪ ،‬كان األطفال من‬ ‫عمر ‪ 5-0‬سنوات من األكثر عرضة للصدمات والدمار‪ .‬وعليه‪ ،‬كان للحرب تأثيرا ً كبيرا ً على الصحة النفسية والجسدية‬ ‫لألطفال ‪ ،‬وهم في حاجة ماسة إلى توفير خدمات الصحة النفسية والدعم المعنوي واالجتماعي‪ .‬باالضافة إلى التأثير المباشر‬ ‫على جودة الحياة‪ ،‬منعت الحرب القددرة على تأمين الخدمات األساسية لألطفال مثل الوصول إلى رياض األطفال وخسائر‬ ‫المواد التعليمية‪.‬‬ ‫استجابة لوضع الطوارىء في غزة‪ ،‬طلبت وزارتي الصحة والتربية والتعليم مراجعة هيكلية المشروع‪ ،‬وإعادة تخصيص‬ ‫المصاريف غير المستخدمة لتمويل األنشطة في غزة‪ .‬ون ً‬ ‫ظرا إلحتياجات األطفال األساسية في عمر الطفولة المبكرة في غزة‬ ‫‪ ،‬طلبت وزارة التربية والتعليم إعادة تخصيص حصة المكون رقم ‪ 3‬من مشروع تنمية الطولة المبكرة في تمويل و إصالح‬ ‫األضرار التي لحقت بالبنية التحتية في رياض األطفال وتوفير المواد التعليمية‪ .‬وفي حين أن األنشطة التي كانت ضمن‬ ‫المكون ‪"( 3‬تحسين توافر بيانات تنمية الطفولة المبكرة") من المشروع تعد مهمة‪ ،‬لكنها ليست ذات أولوية في السياق الحالي‬ ‫الناتج عن األزمة االخيرة في قطاع غزة‪ .‬بحيث‪:‬‬ ‫سيتم إعادة تخصيص ما يقارب ‪ 140000‬دوالر أمريكي للمكون الفرعي ‪ 2.1‬لتمويل اصالح أضرار البنية التحتية‬ ‫•‬ ‫التي لحقت برياض األطفال في غزة‪ .‬علما ً بأن األضرار التي لحقت بالبنية التحتية لرياض األطفال في غزة تتراوح‬ ‫من طفيفة إلى متوسطة‪.‬‬ ‫سيتم إعادة تخصيص ما يقارب من ‪ 460000‬دوالر أمريكي للمكون الفرعي ‪ 2.2‬لتمويل تأمين المواد التعليمية‬ ‫•‬ ‫ألطفال الروضات في غزة‪.‬‬ ‫و لتلبيةً لالحتياجات الصحية والنفسية العاجلة لألطفال في غزة‪ ،‬طلبت وزارة الصحة إعادة تخصيص ‪ 600000‬أمريكي من‬ ‫تمويل المكون الفرعي ‪ 1.2‬والذي سيتم إعادة تخصيصه لدعم خدمات الدعم النفسي واالجتماعي لألطفال ومقدمي الرعاية‬ ‫لهم بحيث سيدعم المشروع إنشاء وتعزيز خدمات الصحة النفسية والدعم النفسي االجتماعي في غزة من خالل منهجة متعددة‬ ‫المراحل‪ )1( :‬تحديد الحاالت والرعاية الفورية ‪ )2( ،‬التركيز على الرعاية غير المتخصصة في المراكز المجتمعية للصحة‬ ‫النفسية‪ ،‬و (‪ )3‬تقديم خدمات متخصصة‪.‬‬ ‫االطار القانوني‬ ‫عند تحضير الطلب لتمويل مشروع تنمية الطفولة المبكرة‪ ،‬راجعت وزارة التربية والتعليم القوانين والسياسات الفلسطينية‬ ‫المتعلقة بهذا المكون‪ ،‬ومن ضمنها القانون األساسي الفلسطيني المعدل لعام ‪ ،2003‬قانون البيئة الفلسطيني رقم ‪ 7‬لعام ‪،1999‬‬ ‫واالستراتيجية الوطنية للنفايات الصلبة لفترة ‪ ،2022-2017‬واألنظمة والتشريعات المرتبطة بالنفايات الطبية رقم ‪ 10‬لعام‬ ‫‪ ،2012‬سياسة تقييم األثر البيئي رقم ‪ 27‬لعام ‪ ،2000‬قانون العمل الفلسطيني رقم ‪ 7‬لعام ‪ ،2000‬وقانون الصحة العامة‬ ‫‪16 | P a g e‬‬ ‫الفلسطيني رقم ‪ 20‬لعام ‪ ،2004‬ارشادات وزارة الصحة لمنع تفشي وباء كوفيد‪ ،19-‬األنظمة والتشريعات الخاصة بالمظالم‬ ‫والشكاوى‪ ،‬والموافق عليها من مجلس الوزراء بتاريخ ‪ 2005/3/9‬والمعدلة بتاريخ ‪ ،2009/3/8‬قرار مجلس الوزراء رقم‬ ‫‪ 6‬لعام ‪ 2020‬بخصوص القواعد السلوكية التي تشمل التعليمات العامة للسلوكيات بين العاملين والمجتمع واالدارة‪ ،‬والقانون‬ ‫األردني للتراث رقم ‪ 51‬لعام ‪ ،1966‬قانون تنظيم المباني والقرى والمدن‪ ،‬نظام األبنية والتنظيم للهيئات المحلية رقم (‪)5‬‬ ‫لعام ‪ ،2011‬وقانون البيئة الفلسطيني‪ ،‬باإلضافة إلى ذلك يلتزم المشروع باالمتثال الى االطار البيئي واالجتماعي ‪ -‬للبنك‬ ‫الدولي والذي تضم سياساته المواصفات البيئية واالجتماعية التي يجب أن يتم االلتزام بها من قبل الجهة المنفذة و الرشادات‬ ‫العامة بشأن البيئة والصحة والسالمة‪.‬‬ ‫تم التوجه إلى اعداد هذا التقرير نظرا ً ألن مشروع تنمية الطفولة المبكرة يحتوي على سلسلة من النشاطات التي قد ينتج عنها‬ ‫مخاطر وتأثيرات ال يمكن تحديدها حتى يتم توضيح تفاصيل المشروع الفرعية‪ .‬وعليه‪ ،‬تم أيضا المقارنة بين سياسات‬ ‫الحكومة الفلسطينية والبنك الدولي والبحث عن الفجوات وتم تطبيق قانون البنك الدولي في هذه الحاالت وخصوصا ً في‬ ‫المعايير البيئة واالجتماعية‬ ‫حيث أن سياسات البنك الدولي البيئية واالجتماعية رقم ‪ ESS1, ESS2, ESS3, ESS4, ESS10‬تنطبق على مشروع‬ ‫تنمية الطفولة المبكرة خالل فترة اإلعداد والتنفيذ‪.‬‬ ‫الترتيبات المؤسسية والتنفيذية‬ ‫تقع مسؤولية إدارة المشتريات للمكون ‪ 1‬و ‪ 4.1‬مع وزارة الصحة‪ ،‬بينما تتحمل وزارة التربية والتعليم مسؤولية إدارة‬ ‫المشتريات المتعلقة بالمكون ‪ 2‬والمكون المعدل ‪ 3‬و ‪ .4.2‬وستكون اإلدارة العامة لألبنية بالتنسيق مع وحدة مشاريع البنك‬ ‫الدولي في وزارة التربية والتعليم مسؤولة عن متابعة تنفيذ االعتبارات البيئية واالجتماعية المنصوص عليها في اطار االدارة‬ ‫البيئية واالجتماعية (‪ .)ESMF‬كما وتم تعيين منسق لمتابعة األمور البيئية واجتماعية (‪ )ESO‬في وحدة مشاريع البنك‬ ‫الدولي لمتابعة تنفيذ األمور المتفق عليها في االطار البيئي واالجتماعي وتطوير النظام البيئي واالجتماعي لهذا المشروع بنا ً‬ ‫ء‬ ‫على ما ورد في تلك الوثائق‪ .‬كما وقامت وزارة الصحة بتعيين منسق بيئة وصحة وسالمة لمتابعة األنشطة الخاصة بوزارتهم‬ ‫مع وزارة التربية والتعليم‪ .‬باالضافة إلى ذلك‪ ،‬تم تعيين مستشار بيئي واجتماعي من قبل وحدة المشاريع لمتابعة تنفيذ الجزئية‬ ‫البيئية واالجتماعية من المشروع في قطاع غزة‪.‬‬ ‫التصنيف البيئي واالجتماعي وتقييم المخاطر‬ ‫تعتبر المخاطر البيئية واالجتماعية المقدرة للمشروع معتدلة مما يشير إلى محدودية االثار السلبية المرتبطة بتنفيذ المشروع‪.‬‬ ‫وتشمل المخاطر البيئية واالجتماعية المرتبطة بأنشطة البناء للمشاريع الفرعية‪ :‬الضوضاء والغبار والنفايات الصلبة ومياه‬ ‫الصرف الصحي ومخاطر الصحة والسالمة للعمال والمجتمع والحركة المرورية‪ .‬ومن الممكن أن تصبح هذه المخاطر‬ ‫واالثار المترتبة عليها مصدرا ً للشكاوى‪ .‬أما األنشطة في إطار المكونين الفرعيين ‪ 1.2‬و ‪ 2.2‬فتعد منخفضة المخاطر‪.‬‬ ‫يوفر إطار االدارة البيئية واالجتماعية (‪ )ESMF‬إرشادات لتصنيف وتقييم المخاطر وما ينتج عنها من آثار بيئية واجتماعية‬ ‫وخصوصا ً تلك المذكورة في المعايير البيئية واالجتماعية ‪ .(ESS) 1-10‬تم تطويرنماذج لتسهيل إجراء تصنيف المشاريع‬ ‫الفرعية وتقييم مخاطرها وآثارها واداراتها البيئية واالجتماعية بما في ذلك أنشطة البناء‪ .‬وبعد تحديد مواقع المشاريع‪،‬‬ ‫استخدمت وزارة التربية والتعليم ووزارة الصحة النماذج التي تم تطويرها في إطار اإلدارة البيئية واالجتماعية لتحديد وتقييم‬ ‫‪17 | P a g e‬‬ ‫اآلثار البيئية واالجتماعية‪ ،‬السلبية وااليجابية على حد سواء‪ ،‬في منطقة تنفيذ المشروع من أجل تجنبها أو اذ لم يكن تجنبها‬ ‫ممكنا ً لتقليص أو تعوض اآلثار السلبية على العمال والمجتمعات المتضررة والبيئة‪ .‬تنطبق نفس النماذج على أنشطة إعادة‬ ‫الهيكلة‪.‬‬ ‫سوف ينتج عن أجزاء المشروع المتعلقة بالبناء واالنشاءات مخاطر ومتطلبات كما موضح في ‪ ESS1‬و ‪ ESS4‬و‪, ESS10‬‬ ‫ومن ضمنها مخاطر متعلقة بالبناء والمجتمع وسالمة وصحة العمال والتي سوف تتطلب من وزارة التربية والتعليم تنفيذ‬ ‫االطار البيئي واالجتماعي بشكل فعال‪ ،‬واشراك أصحاب الشأن واالفصاح عن المعلومات الالزمة المتعلقة بالمشروع‪.‬‬ ‫والمخاطر البيئية واالجتماعية المتعلقة بجانب االنشاء من المشروع تشمل ضجيج وغبار ونفايات صلبة ومياه عادمة‪ ،‬صحة‬ ‫واضطرابات اجتماعية مثل أزمة المرور‪ .‬في مراحل تنفيذ المشروع‪ ،‬قد ينتج تزاحم مروري‬ ‫وسالمة العمال والمجتمع‪،‬‬ ‫وسيكون هناك حاجة لمتابعة الموضوع حتى ال ينتج عن هذه المخاطر أي شكاوي‪.‬‬ ‫تم تحديث إجراءات إدارة العمال (‪ )LMP‬الخاصة بالمشروع األصلي لتتناسب مع اعادة الهيكلية للمشروع‪ ،‬وذلك لتحديد‬ ‫منهجية المشروع‪ ،‬بحيث تكون مطابقة للمتطلبات الوطنية وأهداف اإلطار البيئي واالجتماعي للبنك الدولي (‪ .)ESF‬ومنها‪،‬‬ ‫أهداف ‪ ESS2‬الخاصة بالعمال وظروف العمل و‪ ESS4‬الخاصة بالصحة والسالمة المجتمعية‪ .‬من شأن هذه الخطة أن تم ً‬ ‫كن‬ ‫مختلف األطراف ذات العالقة بالمشروع‪ ،‬بما في ذلك العمال الذين سيتم تعيينهم للعمل مباشرة على هذا المشروع والمقاولين‬ ‫والعمال المتعاقدين من الحصول على صورة واضحة للمطلوب في قضية ما خاصة بالعمال‪.‬‬ ‫بالنسبة لحيازة األراضي‪ ،‬ال توجد قيود على استخدام األراضي ألن بناء وتوسعة الصفوف الجديدة في المدارس ضمن‬ ‫مشروع تحسين تنمية الطفولة المبكرة ستكون على أراضي المدرسة‪ .‬وعليه فإن المعايير البيئية واالجتماعية ‪ESS6,‬‬ ‫‪ ESS7, ESS8, ESS9‬ال ينطبقوا على المشروع‪ .‬ولكن‪ ،‬هناك احتمالية وجود ممتلكات أثرية وثقافية في مناطق البناء‬ ‫والترميم المقترحة‪.‬‬ ‫وكذلك‪ ،‬تم تحديث خطة االلتزام البيئي واالجتماعي (‪ )ESCP‬للمشروع األصلي بالتعاون مع البنك والتي تقدم ملخصا ً‬ ‫ألدوات القياس وأنشطة المتابعة‪ .‬أما بالنسبة ألنشطة إعادة الهيكلية‪ ،‬ولعكس األنشطة التي ستتم في قطاع غزة تم تحديث‬ ‫خطة اشراك اصحاب العالقة (‪ )SEP‬واإلفصاح عنها‪.‬‬ ‫وفيما يتعلق بالمخاطر المرتبطة بالمشاريع الفرعية التي تحتوي على أنشطة بناء‪ ،‬فهي بشكل عام متوسطة إلى منخفضة‬ ‫التأثير كما تم ذكره سابقا ً‪ .‬وعليه يجب وضع خطة االلتزام البيئي واالجتماعي (‪ )ESCP‬باالتفاق مع البنك الدولي الذي‬ ‫توضح ملخصا للتدابير واإلجراءات لمتابعة المخاطر ورصدها‪ .‬ويجب الكشف عن اطار أو خطة اشراك أصحاب العالقة‬ ‫)‪ (SEF/SEP‬في مرحلة مبكرة‪ .‬أما بالنسبة لنظام الشكاوى‪ ،‬فيجب تطوير النظام المستخدم حاليا في وزارتي الصحة والتربية‬ ‫والتعليم‪ ،‬ليتمكن من استيعاب حيثيات مشروع تنمية الطفولة المبكرة سواء من جانب البناء أو جانب تزويد المعدات الطبية‬ ‫هذا وقامت وزارة التربية والتعليم بإعداد دليل نظام الشكاوى وكيية ارتباطه مع األنظمة المعمول فيها‪ .‬أما بالنسبة للمخاطر‬ ‫المتعلقة بقدرة وزارة التربية والتعليم على تنفيذ االطار البيئي واالجتماعي‪ ،‬وإجراءات إدارة العمال وما الى ذلك‪ ،‬والمخاطر‬ ‫المتعلقة في هيكلية المشروع ضمن الوزارات الثالثة‪ ،‬فهي تعد متوسطة‪ .‬وللتعامل مع هذا الموضوع‪ ،‬وبناء قدرات وزارة‬ ‫التربية والتعليم‪ ،‬سيتم تعيين موظف لمتابعة األمور البيئية واجتماعية (‪ )ESO‬وتدريبه على إدارة وتنفيذ الجانب البيئي‬ ‫واالجتماعي من مشروع تنمية الطفولة المبكرة‪ ،‬ومن ضمنها تطوير نظام لإلدارة البيئية واالجتماعية‪.‬‬ ‫‪18 | P a g e‬‬ ‫أما بالنسبة للمعيار البيئي واالجتماعي رقم ‪ ،(ESS5) 5‬فهو ال صلة له بجزئية البناء من مشروع تنمية الطفولة المبكرة‪،‬‬ ‫حيث أن التوسعة لصفوف رياض األطفال ستكون ضمن حدود أراضي المدرسة‪ .‬ومن غير المتوقع أن يكون للمعايير ‪ESS6‬‬ ‫و ‪ ESS7‬و ‪ ESS8‬و ‪ ESS9‬ذات صلة بالمشروع كذلك‪ .‬ولكن‪ ،‬يمكن أن يتم العثور على ممتلكات تاريخية وأثرية عن‬ ‫طريق الصدفة‪.‬‬ ‫تم تقييم المخاطر المتعلقة بالهيكل المؤسساتي للوزارات الثالثة التي ستقوم بإدارة وتنفيذ المشروع ووجد أن هذه المخاطر‬ ‫متوسطة‪ .‬وعملت وزارة التربية والتعليم على بناء القدرات من خالل تعيين موظف بيئي واجتماعي وتوفير ما يلزم حتى يتم‬ ‫تنفيذ ومتابعة مشروع الطفولة المبكرة بشكل مناسب‪ .‬وسيتفيد المشروع أيضا ً من خطة االلتزام البيئي واالجتماعي لدعم‬ ‫امتثال األنشطة المنفذة في قطاع غزة بخطة االلتزام‪ .‬كما وسينسق المسؤول البيئي واالجتماعي مع مسؤول البيئة والصحة‬ ‫والسالمة لألنشطة المتعلقة بالصحة في الضفة الغربية وقطاع غزة‪ .‬هذا االطار المرجعي لإلدارة البيئية واالجتماعية يضم‬ ‫معايير لتخفيض مخاطر االستغالل والتحرش الجنسي وقضايا العمال ومن ضمنها ارشادات إلنشاء نظام شكاوي فعال‬ ‫للعاملين على المشروع‪ .‬سيتضمن نظام الشكاوى على مستوى المشروع اليات محددة للتحرش واالستغالل الجنسي بما في‬ ‫ذلك اإلبالغ السري والتوثيق األخالقي لحاالت العنف القائم على النوع االجتماعي‪ .‬سيتم إرسال المعلومات حول وجود نظام‬ ‫شكاوى إلى جميع أصحاب المصلحة خالل فترة التنفيذ‪ .‬سيعمل المشروع على تجنب أي شكل من أشكال االستغالل واالعتداء‬ ‫الجنسي على أفراد المجتمع من خالل اإلعتماد على أحكام قانون العمل وإرشادات البنك الدولي‪.‬‬ ‫باإلضافة إلى ذلك ‪ ،‬يجب أن تتبع جميع أنشطة المشروع لألحكام الواردة في االطار المرجعي لإلدارة البيئية واالجتماعية‬ ‫والخاصة بصحة وسالمة وحقوق العمال مثل توفير تأمين صحي جيد ‪ ،‬وتوفير معدات الحماية الشخصية المناسبة ‪ ،‬وتوفير‬ ‫بيئة آمنة للعمل‪.‬وكذلك لن يتم قبول األطفال الذين تقل أعمارهم عن ‪ 18‬عا ً‬ ‫ما للعمل في أي من المشاريع الفرعية‪ .‬يحتاج‬ ‫العمال أيضًا إلى التوجيه والتدريب قبل بدء بالعمل‪ .‬كما و يجب كتابة مدونة قواعد السلوك باللغة المحلية ؛ يجب دمج قواعد‬ ‫السلوك واألحكام المتعلقة بالتقييم البيئي االستراتيجي ‪ /‬السالمة والصحة المهنية في وثائق العطاء‪ .‬ومن ثم ‪ ،‬يجب اتباع‬ ‫التدابير المتعلقة بوباء كوفيد‪ 19-‬المعلن عنها من قبل ووزارة الصحة الفلسطينية والصحة العالمية‪.‬‬ ‫أما بالنسبة للجانب االجتماعي‪ ،‬تعد المخاطر االجتماعية للمشروع متوسطة‪ .‬بحيث سيتم إنشاء الفصول الدراسية في إطار‬ ‫المكون ‪ 2‬ضمن حدود المدارس المستهدفة‪ ،‬وعليه ال يوجد حاجة ألراضي إضافية‪ .‬وسيتم تقييم ذلك بشكل أوسع أثناء تنفيذ‬ ‫المشاريع الفرعية‪ .‬إعادة تأهيل رياض األطفال الخاصة المتضررة في غزة سيكون كذلك ضمن حدود المدرسة ولن يكون‬ ‫هناك حاجة لحيازة أراضي إضافية‪ .‬إن المخاطر االساسية الناتجة عن المشروع تتمثل في احتمالية استثناء بعض المجموعات‬ ‫والمجتمعات المهمشة من المشروع (سكان المناطق النائية‪ ،‬البيوت القائمة على النساء‪ ،‬النازحين قسرا بما في ذلك أولئك‬ ‫الذين يعيشون مع عائالت مضيفة) ورياض األطفال الخاصة غير المسجلة بسبب التكاليف وبالتالي لن يكون األطفال المسجلين‬ ‫في هذه الروضات من ضمن المستفيدين من المشروع‪ .‬بشكل عام‪ ،‬معظم رياض األطفال في غزة من القطاع الخاص الغير‬ ‫مسجل بسبب تكاليف التسجيل‪ ،‬وبما أن احدى مكونات المشروع اعادة تأهيل رياض االطفال (مكون ‪ ،)2.1‬سيمنع هذا‬ ‫الوصول الى الفئات المستهدفة من األطفال المسجلة في تلك الصفوف‪ .‬وأيضاً‪ ،‬هناك مخاطر محتملة تتمثل في عدم امكانية‬ ‫الوصول للمجتمعات والتجمعات المهمشة والتي هي اكثر حاجة لهذه الخدمات (توفير مجموعات مستلزمات األطفال‬ ‫واالستخدام المناسب لها والحصول على خدمات الصحة النفسية والدعم النفسي االجتماعي على مستوى المجتمع المحلي‬ ‫‪19 | P a g e‬‬ ‫ومراكز الصحة األولية) نتيجة معيقات في االستهداف والتواصل وتوافر المعلومات المطلوبة‪ .‬إجراءات التخفيف وإدارة‬ ‫مخاطر الخاصة بالمجموعات المهمشة موجودة في االطار المرجعي لإلدارة البيئية واالجتماعية وفي تصميم المشروع‪.‬‬ ‫سينتج عن اعادة تأهيل رياض االطفال واالعمال الصغيرة في مراكز الصحة النفسية المجتمعية (والتي تضمن أعمال طراشة‪،‬‬ ‫وتركيب آالالت‪ ،‬الخ‪ ).‬مخاطر وتأثيرات متعلقة بصحة وسالمة العمال‪ .‬خطة ادارة العمال المحدثة ستضم العمال الناتجين‬ ‫عن اعادة الهيكلة وستحتوي على معايير التخفيف لمخاطر الصحة والسالمة‪ .‬سيتم الموافقة على ونشر خطة ادارة العمال‬ ‫وبحسب خطة االلتزام البيئي واالجتماعي (‪ )ESCP‬للمشروع ‪ ،‬في بداية شهر سبتمبر‪.‬‬ ‫هناك خطورة متوسطة بخصوص التحرش واالستغالل الجنسي نتيجة أعمال البناء واعادة تأهيل الصفوف والمراكز‬ ‫الصحية وستم توضيح تدابير التخفيف من المخاطر في الخطط البيئية واالجتماعية ذات العالقة قبل البدء بعملية البناء‪.‬‬ ‫وعليه‪ ،‬تم وضع آليات نظام الشكاوى داخل كل وزارة ويتم متابعتها من خالل وحدة مشاريع البنك الدولي ألغراض‬ ‫المشروع وسيستمر تعزيز هذه اآلليات حسب الحاجة‪.‬‬ ‫المتابعة البيئية واالجتماعية‬ ‫قامت وزارة التربية والتعليم بتعيين مسؤول بيئي واجتماعي ضمن فريق وحدة مشاريع البنك الدولي‪ ،‬بما أنها الوزارة‬ ‫المس ؤولة عن تنفيذ أعمال البناء في المشروع‪ .‬كما وقامت وزارة الصحة بتعيين مسؤول بيئي وصحة وسالمة للتنسيق مع‬ ‫المسؤول البيئي في وزارة التربية والتعليم بخصوص المكونات ذات العالقة بالصحة‪ .‬وستكون من مهام المسؤول البيئي‬ ‫واالجتماعي االشراف على تنفيذ هذا االطار ومتابعة تطبيق المقاولين للخطط البيئية واالجتماعية خطط ادارة العمال بتعاون‬ ‫مع المسؤول البيئة والصحة والسالمة‪.‬‬ ‫ويجب على وزارة التربية والتعليم أن تعمل على تطوير نظام لموظف متابعة األمور البيئية واجتماعية (‪ )ESO‬للمتابعة‬ ‫واالبالغ عن المشروع‪ .‬ويكون موظف متابعة األمور البيئية واجتماعية (‪ )ESO‬مسؤوالً عن توجيه المقاولين على تطبيق‬ ‫التقارير البيئية واالجتماعية المعدةمن خالل الشركة اإلستشارية‪ .‬وسيقوم كذلك بزيارات ميدانية للتأكد من تنفيذ التعليمات‬ ‫الواردة في هذه التقارير‪ .‬وقد تم تحديد مسؤوليات وزارة التربية والتعليم خالل مرحلة تنفيذ المشروع‪ .‬أما بالنسبة ألعمال‬ ‫اعادة التأهيل في غزة‪ ،‬سيتابع المستشار البيئي واالجتماعي تنفيذها بحسب المتطلبات البيئية واالجتماعية‪.‬‬ ‫وسيقوم موظف متابعة األمور البيئية واجتماعية (‪ )ESO‬بتعبئة نماذج تقارير عن الزيارات الميدانية‪ ،‬وتقارير شهرية‬ ‫وربعية‪ ،‬وتقرير نهائي للمشروع‪ .‬سيتم تحديد عدد التقارير بناء على حجم المشروع‪ ،‬ومدى تعقيده‪ ،‬ومدة استمراريته‪.‬‬ ‫وستتضمن هذه النماذج تفاصيل عن األداء البيئي واالجتماعي‪ ،‬ومن ضمنها االنتهاكات التي تم تحديدها حتى تاريخ التقرير‪،‬‬ ‫والتعليمات الموجهة للمقاولين‪ ،‬وانشطة المتابعة المنوي العمل بها‪.‬‬ ‫وستشمل تقارير موظف متابعة األمور البيئية واجتماعية (‪ )ESO‬باإلضافة إلى ملخص للزيارات الميدانية‪ ،‬وثائق‬ ‫االجتماعات واالتفاقيات مع األشخاص المتضررين‪ ،‬وعمل المقاول أثناء مرحلة البناء ‪ ،‬والتدريب البيئي واالجتماعي‬ ‫والتدريب أثناء العمل للعمال ‪ ،‬وملخص للقضايا البيئية واالجتماعية التي طرأت في تلك الفترة‪ ،‬واية مالحظات أخرى لديه‬ ‫والشكاوى وكيف تمت متابعتها‪.‬‬ ‫تكلفة تبعات االطار المرجعي لالدارة البيئية واالجتماعية‬ ‫‪20 | P a g e‬‬ ‫تم تقدير تكلفة تنفيذ االطار المرجعي لإلدارة البيئية واالجتماعية فيما يتضمن من تدريب المستفيدين وأصحاب العالقة‪،‬‬ ‫وتوظيف وتدريب كل من المسؤول البيئي واالجتماعي‪ ،‬مسؤول البيئة والصحة والسالمة‪ ،‬والمستشار البيئي واالجتماعي‬ ‫لدعم وزارة التربية والتعليم ووزارة الصحة في تنفيذ هذا االطار‪.‬و تقدر الميزانية المرتبطة بتنفيذ هذا االطار ورصد المخاطر‬ ‫البيئية واالجتماعية المرتبطة بالمشروع بمبلغ ‪ 275 800‬دوالر امريكي‪.‬‬ ‫اإلطار الزمني الطار االدارة البيئية واالجتماعية المحدث‬ ‫سيدخل إطار لإل دارة البيئية واالجتماعية المحدث حيز التنفيذ عند اعتماده من قبل وزارة التربية والتعليم ووزارة الصحة‪،‬‬ ‫وسيستمر سريانه أثناء مراحل التخطيط والتصميم والبناء وتنفيذ االستثمارات المقترحة‪ .‬وسيتطلب هذا اإلطار تحديثًا مستمراً‬ ‫في ضوء التجارب الناشئة أثناء المراحل المختلفة للمشروع أو بسبب أي تغييرات في القوانين الفلسطينية وما إلى ذلك‪.‬‬ ‫مشاركة أصحاب العالقة‬ ‫يذكر المعيار البيئي واالجتماعي (‪ )ESS10‬اهمية وجود مشاركة شفافة ومنفتحة بين الوزارة وبين اصحاب العالقة باعتبار‬ ‫ذلك عنصر اساسي للممارسات الدولية الجيدة‪ .‬ان المشاركة الفعالة سوف تساعد في تحسين االستدامة االجتماعية والبيئية‬ ‫لهذه المشاريع‪ ،‬تعزز تقبّل هذه المشاريع من قبل المجتمع‪ ،‬كما انها تقدم مشاركة هامة في تصميم وتنفيذ هذه المشاريع‪ .‬خالل‬ ‫عملية اعداد هذه الوثيقة تم التأكد من مشاركة اصحاب العالقة من خالل الزيارات والمشاورات التي نفذت للوزارات الثالثة‬ ‫والتي تم خاللها مناقشة المشروع ومكوناته المختلفة‪ ،‬االخطار المحتملة‪ ،‬وكذلك االثر المتوقع للمشروع‪.‬‬ ‫الجلسة التشاورية العامة للمشروع‬ ‫نتيجة حالة الطوارىء في فلسطين والقيود المفروضة بسبب فيروس كوفيد‪ 19-‬والتي تمنع تجمهر اكثر من ثالثة (‪ )3‬أشخاص‬ ‫بحسب تعليمات وزارة الصحة‪ ،‬تم عقد اجتماع المشاركة العامة عن بعد عبر تطبيق ‪ Microsoft Teams‬في ‪ 4‬مايو‬ ‫‪ .2021‬حضر االجتماع ‪ 37‬شخص من أصحاب العالقة من مؤسسات مختلفة (أكثر من ‪ 20‬شخص كانو ممثلين من النساء‪،‬‬ ‫الشباب‪ ،‬المجتمع المحلي‪ ،‬البلديات‪ ،‬الخ) كذلك‪ ،‬كان هناك ممثلين من الوزارات والسلطات العامة مثل وزارة التربية والتعليم‪،‬‬ ‫ووزارة الصحة‪ ،‬ووزارة التنمية اإلجتماعية‪.‬‬ ‫تمت مناقشة جميع المخاطر البيئية واإلجتماعية وتغطية آليات التخفيف للمخاطر المتوقعة عند تنفيذ نشاطات المشروع مع‬ ‫الحضور‪ .‬لم يطرح المشاركين أي مخاوف بخصوص التبعات البيئية واالجتماعية للمشروع‪ ،‬وكان بشكل عام لدى جميعهم‬ ‫خلفية جيدة من تجارب مشاريع سابقة مشابهة‪ .‬من جهة أخرى‪ ،‬قام المسؤول البيئي واالجتماعي بعرض وتفسير معايير البنك‬ ‫الدولي البيئية واالجتماعية الخاصة بالمشروع ومناقشتها مع جميع الحضور‪ .‬كما وقام بمناقشة دليل نظام الشكاوي وعرض‬ ‫جميع األدوات المتاحة لتقديم شكوى خالل فترة تنفيذ المشروع‪.‬‬ ‫اإلجتماعات التشاورية إلعادة هيكلة المشروع‬ ‫تم عقد مجموعة من المشاركات العامة إلعادة هيكلة المشروع وكان أولها بتاريخ ‪ 11‬تموز ‪ 2021‬في مدينة غزة‪ .‬حضر‬ ‫االجتماع حوالي ‪ 40‬شخصا ً ممثلين عن مجموعات مختلفة وباهتمامات مختلفة ومنهم ممثلين من وزارة التربية والتعليم‪،‬‬ ‫وحدة مشاريع البنك الدولي‪ ،‬أصحاب‪/‬مسؤولين رياض األطفال‪ ،‬أهالي الطالب ومؤسسات غير حكومية محلية وعالمية‪ .‬وتم‬ ‫عقد جلسة ثانية بتاريخ ‪ 8‬آب ‪ .2021‬حضر الجلسة ‪ 32‬شخصا ً ممثلين عن مجموعات مختلفة وباهتمامات مختلفة باإلضافة‬ ‫‪21 | P a g e‬‬ ‫إلى ممثلين من دوائر مختلفة في وزارة الصحة ووكالة الغوث الدولية لالجئين الفلسطنيين (أونروا)‪ ،‬مؤسسة الصحة العالمية‪،‬‬ ‫وزارة التربية والتعليم‪ ،‬وزارة التنمية االجتماعية‪ ،‬أصحاب‪/‬مسؤولين رياض األطفال‪ ،‬أهالي الطالب ومؤسسات غير حكومية‬ ‫محلية‪.‬‬ ‫كما وحضر الجلسة عن بعد عبر تطبيق ‪ Microsoft Teams‬المسؤول البيئي واالجتماعي في وزارة التربية والتعليم‬ ‫ومنسق المشروع في وزارة الصحة في الضفة الغربية‪.‬‬ ‫قامت االجتماعات التشاورية بتعريف المشاركين على خطة مشاركة أصحاب العالقة واإلطار المرجعي لإلدارة البيئية‬ ‫سلط العرض الضو َ‬ ‫ء بالتفصيل على‬ ‫واالجتماعية‪ .‬كما وتم اعطاء المشاركين معلومات عن آلية نظام الشكاوي المستخدم‪ .‬وقد ُ‬ ‫مناطق التدخل الجديدة ضمن إعادة هيكلة المشروع بسبب حالة الطوارئ‪ ،‬باإلضافة إلى أهداف ومحتوى الخطط سابقة الذكر‪.‬‬ ‫كما وسلط العرض الضوء على المخصصات الخاصة بالمجموعات المهمشة وتفاصيل نظام الشكاوي ومن ضمنها الخطوات‬ ‫المختلفة آللية حل الشكاوي مع التركيز على القنوات المختلفة الخاصة في االستغالل والتحرش الجنسي‪.‬‬ ‫تم تخصيص الجزء األخير من االجتماع لمناقشة مخاوف وتوقعات المشاركين من المشروع ومن أنشطة إعادة الهيكلة وكذلك‬ ‫من خطة مشاركة أصحاب العالقة واإلطار المرجعي لإلدارة البيئية واالجتماعية‪ .‬جميع المخاوف والمالحظات والتوصيات‬ ‫من قبل المشاركين واإلجابات عليها موجودة بشكل تفصيلي بتقرير المشروع الخاص بخطة أصحاب العالقة‪.‬‬ ‫تم عقد جميع الجلسات التشاورية وفق مدونة تعليمات البنك الدولي الخاصة بكوفيد‪ 19 -‬تحت عنوان "المشاركات العامة‬ ‫ومشاركة أصحاب العالقة في العمليات المدعومة من البنك الدولي عند وجود معيقات لعقد االجتماعات العامة"‪ .‬التقرير‬ ‫التفصيلي لالجتماع والذي يضم التغذية الراجعة للمشاركين وورقة الحضور موجود في خطة أصحاب العالقة المحدثة‬ ‫الخاصة بالمشروع‪.‬‬ ‫‪Chapter one: Introduction‬‬ ‫‪1.1. Background‬‬ ‫‪This updated Environmental and Social Management Framework (ESMF) is prepared for the‬‬ ‫)‪purposes of implementing the Restructured “Improving Early Childhood Development” (ECD‬‬ ‫‪project, in compliance with the national and local policies and regulations as well as with the‬‬ ‫‪World Bank new ESF.‬‬ ‫‪ESMF approach is selected because this project consists of series of activities, and the risks‬‬ ‫‪and impacts cannot be determined until the sub-project details have been identified.‬‬ ‫‪ESMF is a technical day-to-day guide for implementing the ECD project in sound‬‬ ‫‪environmental and social manner. It provides guidance for environmental and social‬‬ ‫‪management associated with ECD sub-project proposals in accordance with Palestinian‬‬ ‫‪22 | P a g e‬‬ environmental legal and administrative framework and World Bank ESF. ESMF carry uniform templates to facilitate conducting sub-project environmental and social risk classification, assessment of risks, and monitoring and reporting processes. This ESMF is the environmental and social instrument prepared based on the ESF requirements and is to be applied to the screening and assessment of the projects to be financed by the ECD. The ESMF should provide the following key outputs: • Set out the principles, rules, guidelines and procedures to assess the environmental and social risks and impacts. • Provide measures and plans to reduce, mitigate and/or offset adverse risks and impacts, provisions for estimating and budgeting the costs of such measures, and information on the agency or agencies responsible for addressing project risks and impacts, including on its capacity to manage environmental and social risks and impacts. • Include adequate information on the area in which subprojects are expected to be sited, including any potential environmental and social vulnerabilities of the area; and on the potential impacts that may occur and mitigation measures that might be expected to be used. • Set the standards, which will guide sub-project screening, and preparation of Environmental and Social Management Plans (ESMPs) for individual infrastructure sub-projects financed under the program. • Generic ESMP matrices annexed to the ESMF. It provides means to be considered during the main phases of the projects; design, implementation, operation, control and monitoring. 1.2. Organization of the Framework This ESMF is organized as follows: Chapter 1 provides the introduction to the Framework. Chapter 2 presents the project description. Chapter 3 Environmental and Social Legal Framework. Chapter 4 Environmental and Social Baseline Information. Chapter 5 describes the potential environmental and social impacts of the Project. Chapter 6 provides the procedures to address environmental and social issues. Chapter 7 describes Stakeholder Engagement, Grievance Redress Mechanism and Information Disclosure. Chapter 8 provides the institutional setup and responsibilities for environmental and social monitoring and capacity building and training at MOE/MOH and Project’s key partners to ensure efficient implementation of the ESMF. Chapter 9 defines Environmental and Social Monitoring and Evaluation Arrangements. Chapter 10 identifies the updated Budget and resources needed to efficiently implement the ESMF. 23 | P a g e Chapter Two: Project Description 2.1 Introduction In 2017, Palestine launched its National ECD Strategy-a pioneering document that prioritizes the holistic development of young children from gestation (pregnancy) until age 5. This document calls for a multi-sectoral service delivery system, led jointly by MOE, MOH and MOSD to offer high quality integrated services to children and their families. It also identifies a number of challenges faced by the Palestinian ECD sector that should be addressed through concerted efforts and investments. Improving Early Childhood Development (ECD) Project is aligned with the National ECD Strategy. The main purpose of the project is to improve the coverage and quality of early childhood development services for children from gestation until age 5 in the West Bank. As the population of 5-year-olds in Palestine will grow, the current KG2 enrollment rate in public and private supply of services is estimated to decrease to 67%. Regarding the Project Restructuring, children in the 0-5 age bracket are particularly vulnerable to the shocks and devastation caused by the war in Gaza. First and foremost, the war has had a dramatic impact on children’s physical and psychological health. Studies have shown that exposure to sustained high levels of stress, also known as toxic stress, can disrupt young children's physical development and lead to chronic diseases and cognitive impairment.1 This, in turn, affects their ability to learn and become productive members of society. Beyond the direct impact on children’s wellbeing, the war has also destroyed or impaired the delivery of key services for children. Specifically, damages to educational infrastructure risk reducing access to kindergarten (KG) services, which are key to ensure children’s readiness for primary school. Children who have been forcibly displaced or whose housing units were damaged remain at particular risk of being cut off from key services and learning materials. The ECD aims to improve the coverage and quality of early childhood development services for children from gestation until age 5 in the West Bank and Gaza. 2.2 ECD Project Components (parent project and restructuring) The main components of the ECD are: Component 1: Health Care: Promoting early health development: under this component, the project aims to improve the holistic development of children from gestation until age 3 through its two subcomponents. • Subcomponent 1.1: Strengthening prenatal and postnatal care: will strengthen pre- and ante-natal care by financing the procurement of medical equipment for MOH health care facilities in both the West Bank and Gaza 1 Norwegian Refugee Council (2020). Stressed: A special report on the psychological impact of Covid-19 on refugee and displaced children in the Middle East. Norwegian Refugee Council: NRC, Amman. https://www.nrc.no/shorthand/stories/stressed/index.html 24 | P a g e • Subcomponent 1.2: Strengthening early nutrition and simulation during the first 1,000 critical days of life: will enhance caregivers’ parenting skills in West Bank and Gaza by (i) designing and piloting a parenting intervention using existing delivery channels (i.e., MOH and UNRWA PHCs, nurseries, health community and social workers); and (ii) developing a public national ECD website for all families. In doing so, the subcomponent will leverage and build on existing ECD resources developed by MOH, MOSD and development partners (e.g., UNRWA, UNICEF, WHO and Save the Children). To help address the urgent mental health and psychosocial needs of children in Gaza, the MOH has requested the reallocation of funds from subcomponent 1.2 to address these needs. US$600,000 from sub-component 1.2 (Strengthening nutrition and early stimulation during the critical first 1,000 days of life) will be reallocated to support the organization of MHPSS services to address short-term needs resulting from the war, while at the same time strengthening capacity for improved MHPSS service delivery in the medium- to long-term. Specifically, for MOH, the project will support the establishing and strengthening of MHPSS services through a multi-layered approach: at the community level, primary care levels, and at the level of community mental health centers. At the community level, psychosocial support services may include assisted mourning and healing ceremonies, mass communication on constructive coping methods, supportive parenting programs and educational activities to provide key community and family support in emergencies. At the primary care level, where as part of routine care, healthcare providers in primary health care centers screen children under the age of five for potential mental health issues (for example, post-traumatic stress disorders), refer them to more specialized services, and provide treatment when appropriate. Healthcare providers working in primary health care centers will receive training and guidance on screening and referring children to more specialized MHPSS services. At the level of community mental health centers, health care workers will be trained to provide focused individual, family or group MHPSS interventions. The project will support centers that are underserved, under-equipped and lacking trained staff to treat children under 5 with training. This includes renovation of sensory rooms at two health care clinics, and supply of a number of EEG’s. At the level of specialized mental health centers, health care workers will be trained to enhance the quality of the existing services as well as to expand the range of services provided to cover interventions such as applied behavioral analysis for children, speech and language therapy, and sensory integration therapy. The services provided by these centers would be strengthened by setting up the needed equipment for diagnosis and treatment especially for children with developmental delays, and by hiring and/or supporting specialized professionals such as speech therapists, clinical psychologists, social workers, and physicians trained in mental health care, as needed. Given the important role of parents in child development and the association between parental mental health and child development, these services will also target caregivers where appropriate and as needed. MOH will be responsible for the implementation of Component 1 through the existing PCU for the ongoing World Bank-financed project. 25 | P a g e Component 2 – Education: Improving access to high quality KG services: Under this component, the project aims to improve access to KG2 and enhance the quality of KG services, through its two subcomponents. • Subcomponent 2.1: Expanding access to KG2: will increase access to KG2, by financing (i) refurbishments and extensions of public KG2 classrooms, and (ii) the design and piloting of a public-private partnership (PPP) model. For refurbishments and extensions, 36 public schools are expected to be selected where KG2 classrooms to be refurbished and/or constructed, according to the following agreed upon criteria: o High level of poverty o Low private sector penetration o Sufficient KG2 demand PPPs: the PPP model will provide tailored incentives to private providers to expand their capacity. In the first year of project implementation, the subcomponent will hire a university or firm to conduct a market analysis, review the licensing framework for KG2, and develop the technical design of the PPP modality. In years 2-5, the subcomponent will finance the piloting of the PPP model, including the administrative cost for setting up PPPs and transfer payments under PPP agreements. The PPP model will be piloted in selected communities in WBG where KG2 demand is significantly higher than available KG2 supply. As part of the Project Restructuring approximately US$140,000 will be reallocated to subcomponent 2.1 to finance reparations of infrastructure damages to KGs in Gaza.  Damages to KG infrastructure in Gaza range from minor to moderate. Upon restructuring of the project, funds will be used to rehabilitate approximately 80 private KGs that have been damaged during the war. According to the assessment report received from the MOE, the needed rehabilitation works. These proposed activities will follow the same implementation arrangements as those originally envisioned under subcomponent 2.1. The MOE Directorate General of Constructions in full coordination with the PCU and its staff in Gaza will prepare the bidding documents as per World Bank procurement guidelines, include the new activities in the project procurement plan, and hire the needed contractors to rehabilitate the damaged kindergartens as quickly as possible. The project will aim to complete all needed rehabilitation before KGs are scheduled to reopen for the 2021- 22 school year. The PCU will also work closely with the Directorate General of Constructions at MOE to ensure timely completion of the rehabilitation works and procurement of needed indoor and outdoor furniture.  • Subcomponent 2.2: Enhancing quality of KG services: will enhance the quality of KG services by financing (i) the development and roll-out of a KG Teacher Professional Diploma, (ii) the development and production of a KG Teacher Toolkit, and (iii) the piloting of a KG quality assurance system. KG Teacher Professional Diploma: The in-service professional development program will target private KG teachers who do not have any formal training in early childhood education (ECE). Beneficiaries will include about 1,200 private KG teachers in the West Bank (representing 40 percent of the total stock of unqualified private KG teachers) and 200 KG teachers in Gaza. 26 | P a g e KG Teacher Toolkit: The toolkit will provide hands-on support for KG teachers by equipping them with carefully selected toys, story books and other materials, accompanied by a detailed script with specific guidance on their usage for age-appropriate and play-based activities. KG Quality Assurance System: A robust KG quality assurance system requires four key elements: (1) clearly defined quality standards anchored in an ECE governance strategy, (2) adequate data collection instruments and protocols, (3) regular monitoring visits to KGs, and (4) tailored support mechanisms for continuous improvement of KG teaching. The World Bank will support all four elements of the system through both technical assistance (TA) and financing under the ECD operation. Specifically, the TA will cover a review of Palestinian KG quality standards and ECE governance structure, as well as the adaptation of a classroom observation tool to assess teaching practices. The ECD operation will finance (i) the procurement of tablets for KG supervisors to administer the classroom observation tool, (ii) training on its use, and (iii) the production of short videos on best practices that can be used by KG supervisors to coach teachers during the monitoring sessions. As part of the Project restructuring roughly US$460,000 will be reallocated to subcomponent 2.2 to finance relevant teaching and learning materials to KG age children in Gaza. Reallocated funds will support the provision of approximately 7,500 child kits to the most vulnerable children aged 4-5 who have been forcibly displaced during the war, those living in temporary or damaged housing, and those attending KGs that are in need of repairs. The child kits will include stationary, handicraft materials, educational games, and toys, leveraging existing resources that have been deployed in West Bank and Gaza during the COVID-19 pandemic. The materials may be provided in an age-appropriate school bag. A preliminary list of items to be included in the child kit at the request of MOE and building on the existing child kits developed and locally adapted to the Palestinian context by other partners. In addition, the child kit will be accompanied by an informational leaflet to parents on local psychosocial support services available to them and their children, in close coordination with activities to be supported under Area 3 of the proposed restructuring.  This component will be under the leadership of Ministry of Education. In addition, the MOE will collaborate with relevant UN agencies and international partners (e.g., Save the Children, UNICEF, and UNRWA) to ensure timely procurement of the learning materials and facilitate fast distribution to children in need. This will include leveraging materials from existing resources as needed, building on previous experience of UN agencies and NGOs in providing educational kits during crises. Component 3: Improving availability of ECD Data: Given the substantial needs of KG age children in Gaza, MOE has requested reallocating the financing under Component 3 of the project, to repair infrastructure damages to KGs and provide learning materials Component 4: Project management and implementation support • Subcomponent 4.1: Project management and implementation support for MOH- under the leadership of MOH. • Subcomponent 4.2: Project management and implementation support for MOE- under the leadership of MOE. 2.3 ECD Project Environmental and Social Progress 27 | P a g e The project progress has been slow, following a year of delays due to the COVID-19 emergency situation. In October 2020, the PCU started the project implementation including the requirements of environmental and social compliance. The PCU has updated the Operational Manual to integrate the E&S requirements. On compliance with the ESCP actions: (i) The OHS Manual has beencleared and disclosed including OHS aspects and requirements of the restructuring activities; (ii) The PCU has submitted the first quarterly report and will submit its second one for in November 2021 according to the updated ESCP. The implementation of compnent 1 conisdered the envirnomental and social requirements, while o the civil works has not started yet under component 2. The ESO had received extensive capacity support from the Bank to conduct the screening and preparation of the ESMPs. The following details the progress: For Component 2.1, the PCU has selected nine schools in the West Bank governorates. There has been slow progress in conducting environmental and social risk classification and assessment of the project activities due to the Covide 19, a implmentation. The screening is undergoing to verify risks, the screening will include assessment of potential impacts and risks of the construction activities, and assessment of risks related to GBV and SEA. The PCU will prepare the Site-specific ESMPs. Additonally environmental and social, and health and safety requirements have been addressed in the design and supervision of schools’ Consultant ToR. For subcomponent 1.1 Strengthening prenatal and postnatal care that aims at strengthening pre- and ante-natal care in MOH health care facilities in both the West Bank and Gaza Strip as described in Table 1 below. Table 1: List of Equipment to be procured under MoH Subcomponent 1.1 Item Description QTY Final Destination (Project Site) 1 Otoacoustic Emission 14 All governmental hospitals in WB • 11 for Almuhtaseb Hospital – Hebron Infant Closed Incubator with • 2 for Nassr Pediatric Hospital – Gaza 2 18 Humidifier • 3 for Shifa Hospital – Gaza • 2 for Kamal Edwan Hospital - Gaza 3 GYN/OBS Ultrasound 4 Tubas, Ramallah, Hebron, and Al-Khan Al-Ahmar 4 Direct Ophthalmoscope 3 Hugo Chavez Hospital - Ramallah Binocular Indirect Hugo Chavez Hospital - Ramallah 5 3 Ophthalmoscope Handheld Auto kerato Hugo Chavez Hospital - Ramallah 6 2 Refractometer 28 | P a g e Item Description QTY Final Destination (Project Site) • 1 for Nassr Pediatric Hospital Ultra-Portable Pediatric ECHO 7 2 • 1 for Shifa Hospital Cardiograph • 2 for Nassr Pediatric Hospital • 2 for Shifa Hospital 8 Infusion Pump with Stand 8 • 2 for Tahreer Hospital • 1 for Hilal Emarati Hospital • 1 for Kamal Edwan Hospital • 2 for Nassr Pediatric Hospital • 2 for Shifa Hospital 9 Pulse Oximeter 8 • 2 for Tahreer Hospital • 1 for Hilal Emarati Hospital • 1 for Kamal Edwan Hospital Infant Open System with T- • 1 for Shifa Hospital 10 4 • 1 for Tahreer Hospital Piece Resuscitator • 2 for Kamal Edwan Hospital Infant Transport Incubator • 1 for Aqsa Hospital 11 2 with Ventilator • 1 for Kamal Edwan Hospital The environmental risk rating is low for the selected activities. MOH issued the tender documents, that include all the E&S provisions into the bidding documents. (iii) With the support from the Bank, the PCU has conducted consultation in May 2021, and updated the SEF that has been disclosed at appraisal to include feedback from consultations relevant stakeholders across the project components. The SEP was drafted and shall be updated to reflect the consultations and stakeholder engagement activities conducted for the project’s restructuring. The grievance redress mechanisms were established within each ministry (MoE, MoH and MoSD), and are being coordinated through the PCU for the purposes of the project. Information about the grievance mechanisms has been communicated to the project beneficiaries during the consultation meeting that was conducted with stakeholders and beneficiaries in May 2021, and were circulated to stakeholders and benificiaries during the consultations that took place for the project’s restructuring in July and August 2021. The ESO will handle complaints in line with the GM manual that was established for the project. Complaints will be registered in the complaints log prepared by the ESO. Due to the capacity constraints at the PCU, the ESO attended a 1 day General ESF training in November 2020. In addition, the ESO benfitied from extensive hands-on support through periodic meetings that aimed to assist and guide the PCU ESO in preparing the E&S assessment, the ESMPs and the 29 | P a g e OHS Manual. Further capcity building is required and will continue through the course of the project. Chapter Three: Environmental and Social Legal Framework 3.1 Introduction According to ESF requirements, when a project is proposed for Bank financing, MOE and the Bank will consider whether to use all, or part, of the Palestinians’ ES Framework in the assessment, development, and implementation of a project. Such use may be proposed provided this is likely to address the risks and impacts of the ECD project and enable the project to achieve objectives materially consistent with the ESSs. WB ESF and Palestinian policies and regulations are presented in this section and gap analysis is conducted accordingly. 3.2 Palestinian Laws and Regulations Related to Environmental Management MOE when preparing construction works including building of schools and classrooms would have accomplished all legal requirements acquired by and respecting the revised Palestinian Basic Law of 2003, the Jordanian Law No. 79 of 1966, the Villages and Buildings Regulating Law, and the Buildings and Regulation Bylaw for Local Authorities No. 5 for 2011. 3.2.1 Palestinian Environment Law The Palestinian Environment Law of 1999 covers the main issues relevant to environmental protection and law enforcement. The objectives of this law include: • Protect the environment from all types of pollution • Protect public health and social welfare • Incorporate protection of environmental resources in all social and economic development plans and promote sustainable development to protect the rights of future generations • Conserve ecologically sensitive areas, protect biodiversity, and rehabilitate environmentally damaged areas In accordance with the Palestine Environment Law, EQA in coordination with the competent agencies prepared the Environmental Assessment Policy. 3.2.2 Palestinian Environmental Assessment Policy EQA developed the Palestinian Environmental Assessment Policy of 2000 as a leading authority for the approval of environmental assessment studies. This policy aims to achieve the following goals: 30 | P a g e • Ensure an adequate quality of life in all aspects, and ensure that the basic needs and social, cultural, and historical values of the people are not negatively impacted as a result of development activities • Preserve the capacity of the natural environment • Conserve biodiversity and landscape, and promote the sustainable use of natural resources • Avoid irreversible environmental damage and minimize reversible environmental damage from development activities In accordance with the policy, project proponents are required to submit an application for environmental approval that informs the EQA and relevant approving authorities of the intended project activities. Subsequently, a determination is made whether an initial environmental evaluation (IEE) or a detailed environmental impact assessment (EIA) is required. The IEE is for projects where significant environmental impacts are uncertain, or where compliance with environmental regulations must be ensured, whereas an EIA is required for projects, which are likely to have significant environmental impacts. Stakeholder consultation is mandatory by PEAP for EIA. At the minimum, the proponent must meet with the principal stakeholders to inform them about the proposed project and to solicit their views. The methods and results of the consultations must be documented. 3.2.3 General Rules for the Protection of Historic Areas The Jordanian Heritage law No. 51 for the year 1966 manages case of accidental findings of any antiquities or Physical Cultural Resources (PCRs). The Higher Council of Planning decided on 2006 to approve the General Rules for the protection of historic areas and individual historic buildings. These rules are considered an amendment of the Building and Planning Regulations for the Local Authorities approved by Higher Council of Planning issued on 1996. This amendment prevents demolish or remove any historic buildings or demolish or distort any element of that forming the root of the historic town such as paths, alleys, open spaces, covered passages and portals. 3.2.4 Other Laws and Regulations relating to Environment Management Palestinian Public Health Law No. 20 was developed by the Ministry of Health (MOH) and approved by the Legislative Council in 2004. The law states the role of the Palestinian Authority, as represented by the MOH and other authorities, to control communicable, non- communicable, and genetic diseases by practicable means, including the removal of health nuisances. 31 | P a g e It also states that it is under MOH authority in cooperation with the competent authorities to specify the rules and conditions of transferring, saving, treatment or disposal of the hazardous waste. No one is allowed to do what is stated here above unless it is in accordance with the conditions and rules. The Grievance and Complaints bylaw that has been approved by the Ministerial Cabinet on 2005 and updated on 2009. 3.2.5 Laws and Regulations for Waste Management The major strategies relevant to solid waste management include: The National Strategy for Solid Waste Management (2017-2022), the Environment Sector Strategy (2020-2023), the National Policies Agenda (2018-2022), the Strategic Framework for Ministry of Local Government (MoLG) (2010-2014) and the Cross Sectoral Strategy for Palestinian Local Government and Administration Sectors (2011-2013). Cross Sectoral Strategy for Palestinian Local Government and Administration Sectors The National Strategy for Solid Waste Management for the period 2017-2022 is the second national strategy on solid waste management. The main goal of the strategy is continuous remediation of key issues, setting updated legislative, organizational, technical, and economical foundation for more efficient Solid Waste Management with the key issues, and putting the same into force with the frame of a continuous process not only to alleviate the negative impact of Solid waste on health and environment, but also enhance investment in this section, and thus achieve the necessary development. The strategy includes (8) strategic Objectives and (18) policies. The Environment Cross-Sectorial Strategy (2017-2022) is one of the main cross sectorial strategies announced through the National Policy Agenda (2017-2022) includes main development pillars, national priorities and policies in coordination with the international agencies. The Agenda is the reference to development the cross sectorial development plans and programs national development agenda aiming to ensure social justice and enhancing service quality to citizens. The National Policy consider environment as a cross-sectorial to be integrated in all policies and programs. The Environmental Cross Strategy has (5) goals. The Strategic Framework for MoLG (2010 - 2014) and the Cross Sectoral Strategy for Palestinian Local Government and Administration Sectors (2011 - 2013): of the sectoral strategic objectives identified in the Strategic Framework for MoLG (2010-2014), the following are related to the institutional aspects of solid waste management: (i) increase the level of decentralization between MoLG and Local Government Units (LGU’s); (ii) enhance the institutionalization of community participation; (iii) strengthen partnership between the LGU’s and the private and public sectors, as well as the civil society organizations in order to achieve sustainable development. 32 | P a g e 3.2.6 Medical Waste Bylaw (2012) The Medical Waste Bylaw(http://site.moh.ps/index/ArticleView/ArticleId/4416/Language/ar) related to medical waste management and handling is enacted by Ministerial Cabinet Decision No. 10 for the year 2012. The Medical waste bylaw identifies roles and responsibilities in medical waste management, definition of waste management, procedures and specifications for medical waste separation, storage, collection, transport, treatment as well as waste tracking. 3.2.7 Laws and Regulations Relating to Labor Two major legislations in Palestine govern the rights of the labors and the terms and conditions of the employment are: the Palestinian Labor Law no (7) of (2000) and the Council of Ministers Act 11, 2012 regarding the minimum wage. The Labor Law no (7) and the Council of Ministers Act 11, 2012 provide the basic conditions of employment with a view of improving the status of employees in Palestine. The Palestinian Labor Law explains the working hours, wages, leaves, the reward of work end, work contracts etc. The Council of Ministers Act 11, 2012 deals specifically with the minimum wages in the Palestinian National Authority’s locations and basic terms and conditions of employment. Following the Labor Law, several resolutions and ministerial instructions were issued detailing health conditions and standards related to occupational safety at different workplaces. These include: • The ministerial decrees No. 15, 17, and 21 of 2003 concerning health conditions and standards at workplaces, medical assistance procedures at the workplace, and safety standards at companies. • The Decision of the Council of Ministers No. (49) of 2004 concerning the preventive list of work hazards and career diseases and work accidents. • Instructions by the Minister of Labor no. (1) of 2005 concerning the precautions to protect workers in construction sites. • Instructions by the Minister of Labor no. 2-6 of 2005, defining the range of chemical exposure limits and standards, exposure to ionizing radiation, noise, and safe levels of brightness of light and temperature at the workplaces. The description of the key aspects of Palestinian Labor Law (No. 07 of 2000) and the Council of Ministers Act 11, 2012 is detailed in Annex 12. The attached annex also includes specific provisions for workers contracted during COVID-19. 3.2.8 Labor and Occupational Health and Safety related to COVID-19 The Project will ensure the application of OHS measures as outlined in the Government of Palestine and WHO guidelines such as the procedures for protection workers in relation to infection control precautions and provision of immediate and ongoing training on the procedures to all categories of workers. Additionally, the Project will be mandating hand 33 | P a g e hygiene and personal protective equipment (PPE); ensuring adequate and free of charge supplies of PPE (particularly facemask, gowns, gloves, handwashing soap and sanitizer); and overall ensuring adequate OHS protections in accordance with the measures prescribed by Government of Palestine and the latest guidance by WHO as it develops over time and experience addressing COVID-19 globally MoH developed a guideline /Manual for the COVID 19 pandemic. The Manual for procedures, working mechanisms and prevention of COVID-19 at Palestinian land, 2020. The manual was developed by MoH with reference to several WHO documents. Awareness pamphlets and leaflets were developed by MoH with support from different international and local organizations, such as WHO, UNICEF, UNRWA, World Vision, Bank of Palestine, The Palestinian International Cooperation Agency (PICA), etc. Link: http://site.moh.ps/index/ArticleView/ArticleId/4941/Language/ar WHO has published different resources for compacting COVID-19 including the following links: • Rational use of personal protective equipment (PPE) for coronavirus disease (COVID- 19: https://apps.who.int/iris/bitstream/handle/10665/331498/WHO-2019-nCoV- IPCPPE_use-2020.2-eng.pdf, • Considerations for public health and social measures in the workplace in the context of COVID-19: https://www.who.int/publications/i/item/considerations-for-public- health-and-social-measures-in-the-workplace-in-the-context-of-covid-19 3.3 World Bank ESF The ECD project will be implemented in compliance with applicable Palestinian laws, policies and regulations governing environmental and social issues as well as the applicable World Bank ESF as far as the Bank provides core financing for the project. World Bank’s ESF was approved in August 2016 and became effective on October 1, 2018 and will thereafter apply to the ECD project. It boosts protections for people and the environment; promotes capacity and institution strengthening and country ownership; and enhances efficiency for both the Government and the World Bank. It consolidates the World Bank’s environmental and social policies and harmonizes them with those of other development institutions. It makes important advances for the World Bank in areas such as transparency, accountability, nondiscrimination, and public participation. Environmental and social risk classification and assessment of the sub-projects of the ECD shall be conducted in light of the World Bank’s ESF and the Palestinian ES guidelines. Classification and assessment of sub-project proposal for risks and impacts of deteriorating natural environment and resulting in negative social impacts specifically identified in ESSs1 – ESS10 will be undertaken. Mitigating measures will be identified accordingly. Key stakeholders and potentially affected people will be identified and mechanisms for consultation and disclosure will be determined. 34 | P a g e 3.4 WB ESF and Palestinian Laws and Regulations Gap Analysis A gap analysis was also made to the applicable ESSs and Palestinian’s National laws and International good practice commonly used in Palestine. Table (2) shows this analysis and gives recommendations to be applied for the ECD project. Table 2: Gap Analysis of Applicable ESSs and Palestinian’s National laws and Regulations Issue National WB ESF and gaps with Recommendations Laws/International National Laws Good Practice commonly used ESS1: Assessment and Management of Environmental and Social Risks and Impacts Environmental and Low, medium, Four classifications: WB ESF prevail social risk significant High Risk, Substantial classification and Risk, Moderate Risk or assessment Low Risk. Environmental and Category A, B and C ES instruments ESIA, WB ESF prevail social assessment ESMP, ESMF, strategic instruments environmental and social assessment (SESA) ESS 2: Labor and Working Conditions To promote safety Refer to article 90, There is no gap Apply Palestinian and health at work 91, 92 of the between the national Labor Law Palestinian Labor labor law and the World Law no. 07 of 2000 Bank OHS guidelines (See annex 12) FIDIC 99 clause 4.8 & 6.7 (see annex 12) To promote the fair Refer to article 16, There is a gap in regard Apply World Bank treatment, non- 100, and 106 of the to measures to prevent Guidelines as discrimination and Palestinian Labor and address stipulated in ESS2 equal opportunity of Law no. 07 of 2000 harassment, project workers (See annex 12) intimidation and/or exploitation. Where Palestinian Labor law is inconsistent with this clause, the project will seek to carry out project activities in a manner that is consistent with World Bank guidelines. 35 | P a g e Issue National WB ESF and gaps with Recommendations Laws/International National Laws Good Practice commonly used To protect project Refer to articles 93- There is no gap Apply Palestinian workers against 99 of the Palestinian between the national Labor Law (GBV) and child labor law no. 07 of labor law and the World abuse/exploitation 2000 (see annex 12) Bank OHS guidelines (CAE) issues and that discuss Code of Conduct and regulating the work contracted workers, of minors. Also refer community workers to article (4) of and primary supply amendment #19 of workers, as 2012 and child law appropriate. no. 07 Refer to World Bank Apply World Bank guidelines in regard to Guidelines in ESF No National law in gender-based violence regard to gender- in ESF based violence (GBV) To prevent the use Refer to articles 93- There is a gap in regard Apply World Bank of all forms of forced 99 of the Palestinian to forced labor Guidelines in ESF labor and child labor labor law no.07 for the year 2000 (see annex 12) that discuss regulating the work of minors To support the Refer to article 5 of There is no gap Apply Palestinian principles of the Palestinian labor between the national Labor Law freedom of law no.07 of 2000 labor law and the World association (see annex 12) that Bank OHS guidelines ensures that both workers and employers have the right to establish union organizations To provide project The right of the The ESF requires that a Apply World Bank workers with public to complain is grievance mechanism Guidelines in ESF accessible means to ensured by the will be provided for all raise workplace grievance bylaw direct and contracted concerns/grievances approved by the workers (and, where Ministerial Cabinet relevant, their on 2005 and organizations) to raise updated on 2009 workplace concerns ESS 4: Community Health and Safety 36 | P a g e Issue National WB ESF and gaps with Recommendations Laws/International National Laws Good Practice commonly used To avoid adverse International good There is gap resulted Apply FIDIC & ESS4 impacts on health practice including from the fact that FIDIC (3.3 of the and safety of FIDIC 99 and the only provides general “Environmental, project-affected Jordanian Code for guidelines Health, and Safety communities during construction 2004 (EHS) Guidelines the project lifecycle are commonly used General EHS in Palestine. FIDIC Guidelines: 99 clauses 4.8 and Community Health 6.7 stated that & Safety”) and Safety plan should EHSG guidelines. be provided: Spray the dust with water Work only at the allowable hours. Use safety fence around the site. To avoid or minimize Use boundary There is gap resulting Apply FIDIC, ESS4, community exposure stones around the from the fact that FIDIC and section 3.4 of to project-related hole in the streets. only provides general the Environmental traffic and road Put the necessary guidelines Health and Safety safety risks, diseases warning signs (EHS) Guidelines and hazardous General EHS materials. Guidelines: Community Health & Safety To have in place Based on FIDIC 99 There is gap resulting Apply FIDIC, ESS4, effective measures clause 4.8 & 6.7; from the fact that FIDIC and section 3.7 of to address Safety plan should only provides general the Environmental emergency events be provided. guidelines Health and Safety The emergency (EHS) Guidelines phone numbers General EHS should be available Guidelines: in the site and easy Community Health to access. & Safety Provide a first aid box To ensure that the Safety plan should There is a gap where Apply ESS4 and safeguarding of be provided. there is no coverage for section 3.7 of the personnel and this issue in any national Environmental property is carried document Health and Safety out in a manner that (EHS) Guidelines avoids or minimizes General EHS 37 | P a g e Issue National WB ESF and gaps with Recommendations Laws/International National Laws Good Practice commonly used risks to the project- Guidelines: affected Community Health communities & Safety ESS10: Stakeholder Engagement and Information Disclosure Stakeholder Consultations are The Bank will require WB ESF prevail engagement and required for engage with information EIA. Public stakeholders, through disclosure disclosure is not information disclosure, required for projects consultation, and that do not require a informed participation. full EIA. SEP shall be developed and disclosed. Public disclosure is required for all EA reports. Project grievance The Palestinian The ESS ensures WB ESF prevail mechanism Bylaw sets the rules reception and timely for grievance of the response to any public and the complaints made about improving the the Project and be the performance of the basis for developing Palestinian appropriate mitigation Ministries and strategies Authorities. No project GM is required. The ESMF is also prepared in light of the World Bank’s guidance about labor influx “Managing the Risks of Adverse Impacts on Communities from Temporary Project Induced Labor Influx, 2016”. The guidance identifies, assesses and manages the risks of adverse social and environmental impacts that are associated with the temporary influx of labor resulting from Bank-supported projects. The Note contains guiding principles and recommendations to be considered as part of the design and implementation of projects with civil works that require labor from outside the project’s area of influence. This Note does not introduce new requirements, but rather seeks to provide concrete guidance on how to approach temporary labor influx within the environmental and social assessment process. The following principles are key to properly assessing and managing the risks of adverse impacts on communities that may result from temporary project induced labor influx: • Reduce labor influx by tapping into the local workforce. 38 | P a g e • Assess and manage labor influx risk based on appropriate instruments. • Incorporate social and environmental mitigation measures into the civil works contract. The local labor laws and regulations do not clearly discuss the labor influx issue, and this can be justified that all of projects in the West Bank and Gaza Strip are using local workers, as there are no workers from other countries working in this geographical area and therefore it is easy for workers to work and return to their homes at the end of the working day. The labor influx from governorate to another governorate is possible and should be monitored and mitigation measures should be set for reducing the labor influx by tapping into the local workforce or managing those workers based on appropriate instruments. Chapter Four: Environmental and Social Baseline Information 4.1 Introduction Baseline environmental and social information for Gaza Strip and West Bank are available in the already prepared Environmental and Social Assessment reports such as EIA, ESIA, EMSP, etc. These reports have good documentation about the environmental and social issues including climate, air quality, roads, noise, available water resources, water quality, vegetation cover, agricultural resources, employment and income, occupational health and safety, natural habits and sanctuaries, resettlements, culture and heritage, recreation and tourism, marine life resources, issues. 4.2 Available reports on the baseline environmental and social information The following list gives examples of available reports to refer to: • ESIA for Environmental Assessment Report for Wastewater Treatment Plant in Ramallah; • ESIA for Environmental Assessment Report for Northeast and Southwest Jenin Water Supply Projects Jenin Governorate – West Bank; • Environmental, Social, and Cultural Heritage Impact Assessment (ESCHIA) for Hebron Wastewater Management Project; • Feasibility Study and ESIA for Wastewater Management in Tubas, Tayasir, Aqqaba and Al Aqaba; • Environmental Impact Assessment for Alreehan Neighbourhood; • Environmental Impact Assessment for Rawabi Community; • ESIA for Hebron Solar Photovoltaic (PV) project; • Environmental and Social Impact Assessment (ESIA) & Environmental and Social Management Plan (ESMP) for Gaza Water Supply Rehabilitation and Expansion Project Gaza II Emergency Water Project (GEWPII); • Environmental and Social Impact Assessment (ESIA) for Gaza Solid Waste Management Project; • Environmental and Social Impact Assessment (ESIA) & Environmental and Social Management Plan (ESMP) for Gaza Water Supply and Sewage Systems Improvement Project (WSSSIP), including Additional Financing 1 (AF1); • USAID INP II GAZA Sustainable Water Supply Program Environmental Assessment Report. 39 | P a g e Chapter Five: Environmental and Social Impacts 5.1. Assessment of Environmental and Social Risks of the ECD project The ECD project components especially those which will be implemented in connection with MOH and MOSD include activities having mainly positive environmental and social impacts. However, ECD sub-projects under Component 2.1 include construction activities that are likely to have negative environmental and social impacts. The environmental and social risks of the ECD project are moderate as the project components include construction, rehabilitation activities, and the supply of equipment. Moreover, they include capacity building and in service training programs, technical design of PPP modality, establishing system that ensures the application of quality standards and quality assurance in public and private providers, parental education to promote early stimulation, and establishing a Multi- Sectoral Information Management System for ECD. The equipment to be purchased under subcomponent 1.1 aim to enhance the quality of pre- and ante-natal care. This equipment neither uses nor produces any type of waste or medical waste. It also does not use or produce any harmful radiations. The environmental and social impact for these project activities is classified as positive. MOH’s restructuring activities under subcomponent 1.2, will support MHPSS services and the rehabilitation of support services centers. Two Electroencephalogram (EEG) machines are to be procured to assist in early identification and assessment of mental illnesses of children traumatized by the recent conflict, in addition to the preparation of two sensory rooms. The EEG does not require any input chemicals or material and does not produce any solid, hazardous, or medical waste, and does not produce any radiation. In addition, two sensory rooms are to be prepared at two health centers in Gaza. This work will include potential renovation, decorating, painting, and fitting games and other objects to stimulate and treat children with development disorders and delays. These will be standard rooms furbished with toys, games, and interactive facilities. Additionally, capacity building for children’s caregivers will be conducted for early detection and diagnosis of mental illnesses and disorders, and the recruitment of additional workforce specialized in children’s mental health is expected. The proposed rehabilitation activities risks related to minor rehabilitation work include generation of waste, occupational health and safety for workers, risk of exposure to COVID-19. The environmental and social screening for the activities will be conducted upon identification of the health care facilities that will host the EEG devices, and the sensory rooms The environmental and social risks related to the construction or rehabilitation of existing KG classrooms within the existing footprint of selected schools in West Bank, the rehabilitation of damaged KG’s, and the rehabilitation of health care centers in Gaza Strip under the restructured project include noise, generation of dust, solid waste and wastewater, labor occupational health and safety, community health and safety, and traffic safety, potential risk 40 | P a g e of exposure to COVID-19. However, the KG’s rehabilitation activities may have additional health and safety risks for workers and the community, related to the potential presence of unexploded ordinances (UXO) and non-hazardous and hazardous waste mixed within the rubble. Therefore, the KG sites that were directly shelled or include rubble at the work sites will be initially screened for UXO, and the required clearance and permits will be obtained from UNMAS prior conducting the E&S assessment. The risk of rubble presence would be low, as most of the rubble in Gaza Strip has been removed including the selected KGs zones. The provision of learning materials and capacity building activities under sub-components 2.2 and the supply of equipment under subcomponent 1.2 are of low environmental risk. The environmental and social screening will be conducted for each sub-project 5.2. Environmental and Social Risk Classification (ESRC) This section provides guidelines for ESRC and assessment of potential risks for subprojects particularly under Sub-components 2.1 and 1.2, where construction is envisaged. Where activities under subcomponent 1.1, equipment’s under subcomponent 1.2 and 2.2 are expected of low risk. According to WB ESF classification, four levels were identified: High Risk, Substantial Risk, Moderate Risk or Low Risk. In determining the appropriate risk classification, the following relevant issues are applicable including (i) the type, location, sensitivity, and scale of the project; (ii) the nature and magnitude of the potential environmental and social risks and impacts; (iii) the capacity and commitment of the Borrower (including any other entity responsible for the implementation of the project) to manage the environmental and social risks and impacts in a manner consistent with the ESSs (iv) any other risks. Assessment of the points (i) and (ii) are as flows: i. Type, location, sensitivity and scale of the project including the physical considerations of the project While the specific information of the physical investment on the ECD construction sub- projects, i.e., size and location, are known, the total size of the sub-project is to be small to medium. The expected features of sub-projects suggest that an impact described in ESS1 is at Moderate scale of a few hundred square meters. The environmental baseline in the project area is overall not sensitive or vulnerable, with project implementation expected to affect mainly areas with existing human habitat and infrastructure footprints. Additionally, the identified activities under the Project restructuring will be implemented in the footprints of an operating Private KG’s where minor repairs works is expected to for the identified slightly damaged KG’, on the other hand minor repair and reinvention activities may be required for moderately damaged KG’s. 41 | P a g e The rehabilitation of sensory rooms at the two clinics under subcomponent 1.2 is expected to entail any minor rehabilitation activities but will not require any additional areas beyond the existing buildings and infrastructure. Additionally, the EEG equipment’s will be supplied to operating health care facilities. Therefore, the environmental risk for this project remains classified as Moderate. ii. Nature and magnitude of the potential ES risks and impacts (e.g., whether they are irreversible, unprecedented, or complex). The adverse environmental and social impacts of the project in construction stage include noise, dust, solid waste and wastewater, labor and community health and safety, and traffic and safety. In the operation stage, the project will increase traffic and need maintenance to ensure sustainability. These impacts in operation stage are expected to be at limited magnitude given the overall size of the project. The environmental impacts are moderate, site-specific, predictable and/or reversible. These adverse impacts can be readily and reliably managed through the environmental management hierarchy. In addition to the above-mentioned risk, the KG rehabilitation activities may have additional health and safety risks for workers and the community, related to the potential presence of unexploded ordinances (UXO) and non-hazardous and hazardous waste mixed within the rubble. Therefore, the KG sites that were directly shelled or include rubble at the work sites will be initially screened for UXO, and the required clearance and permits will be obtained from UNMAS prior conducting the E&S assessment. The risk of rubble presence would be low, as most of the rubble in Gaza Strip has been removed including the selected KGs zones. The rehabilitation of two sensory rooms in health care clinics under subcomponent 1.2 aiming to enhancing MHPSS services delivery for children and their caregivers and capacity building activities. The rehabilitation activities expected to have potential risk on community health and safety, dust, noise, solid waste generation, in addition to occupational health and safety for workers, risk of exposure to COVID-19, the safety of the material used to prepare and furbish the sensory rooms. The activities may cause disturbance and nuisance to the staff and patients, therefore proper consideration of work hours and closure of the work areas will be considered in consultation with the health care facilities staff. On the other hand, the provisions for learning materials, and capacity building activities under the restructured sub-components 2.2 are soft activities of positive impact to the children, and doesn’t have any negative environmental impact, the activities are assessed of low risk. Additionally, the supply of EEG equipment is assessed of low environmental risk, as this equipment does not generate waste, and won’t pose OHS risk. On the social side, the project will continue to have overall positive impacts. In particular, the project restructuring will address critical needs for early childhood development in Gaza in the aftermath of the war in May 2021, including through rehabilitation of all 116 damaged private KGs, and provision of learning materials for the most vulnerable children aged 3-5 who have been displaced due to the war and are living in areas that have suffered the most damage. The classroom construction under Component 2 will be done within the existing footprint of the existing schools and hence, no land acquisition is anticipated. This will also be 42 | P a g e further assessed during preparation of sub-projects. The primary social risk, of a moderate level, is the potential exclusion of some vulnerable groups and communities (e.g., those living in remote locations and with access to restricted areas, women headed households, forcibly displaced including those living with host families, etc.) and unregistered private KG service providers from project benefits. In general, the private sector is the provider of KG2 classrooms in Gaza and since one of the components of this project is assistance for rehabilitation of KG2 classrooms (Component 2.1), those private sector providers, and the children using their services that are not registered due to the cost involved could be excluded from project benefits. Similarly, there is a potential risk that the most vulnerable groups and communities may not be able to access and benefit from project interventions (e.g., provision and proper use of child kits) due to issues with targeting, outreach, and availability of requisite information. The Bank’s team will build on the experience of development partners to include tried and tested instructions and to collaborate with local community workers on proper use of the child kits as needed. Moreover, the targeting of the child kits will also be informed by the Rapid Damage Needs Assessment conducted jointly by the World Bank, EU and UN which lays out in much detail the areas that have suffered the most damages in Gaza. Special attention will also be paid to the needs and concerns of vulnerable groups and communities, and the Stakeholder Engagement Plan (SEP), that has been updated in keeping with project restructuring, includes mechanisms to ensure provision of requisite information, in accessible formats, to and meaningful engagement of the most vulnerable and marginalized throughout the lifetime of the project. Grievance redress mechanisms within each ministry are in place and are being coordinated through the PCU for the purposes of the project. These mechanisms will continue to be strengthened as required. For MoH’s sub-component 1.2, in the construction phase, overall social impacts of the sub- component’s operation are expected to be positive. The procurement of the EEG equipment, preparation of two sensory rooms, support for children and capacity building for their caregivers, and the rehabilitation of the clinics will bring overall positive impacts. Nevertheless, risks yet remain in terms of SEA /SH and child abuse as the beneficiaries of this project will be children and their parents who might suffer from trauma and other mental illnesses. Special considerations, therefore, are required to ensure the safety of the children which will be treated by proper induction and capacity building to caregivers and the engagement with the parents, the project’s CoCs, and the project’s GM. During the construction phase, the noise, dust, and traffic on the building might cause nuisance to patients and visitors. This will be mitigated by conducting stakeholder engagement and consultation with the clinics administration and staff to coordinate for the most appropriate time to conduct specific activities (drilling, installation, electrical works). The project will also ensure the avoidance of any form of SEA/SH of affected people and community members at large by relying on World Bank guidelines on the mitigation of SEA/SH such as the signing of enforceable workers’ code of conduct (CoC ), sensitization of workers and affected communities, and establishment of referral pathways. The project will also ensure via stakeholder engagement that stakeholders are informed about the GM. The project level GM include specific procedures for GBV, SEA/SH including confidential reporting and ethical documentation of GBV cases. The project will include clear guidelines in the Project agreements ensuring that (i) contractors are not allowed to employ workers under the age of 18; (ii) all workers shall be covered by a valid insurance and Health care; (iii) workers 43 | P a g e shall be informed of the current health regulations such as COVID-19 safeguarding and shall be provided with proper PPE’s. Provisions of CoC shall be explained for workers as well as mechanisms for communicating grievances shall be made available for all workers. For Component 3, Improving availability of ECD Data, ministries shall apply mitigation measures to ensure data privacy under this component such as anonymized data entry, submission and dissemination, however Component 3 activities has been cancelled under the restructured project, though the risk is not anticipated. The environmental and social risk for this project remains classified as Moderate. 5.3. Applicability of WB ESSs and risk assessment As mentioned earlier, ECD subprojects’ activities under components 1.2 and 2.1 which are related to building new classrooms and refurbishment existing classrooms/spaces in public primary schools in West Bank, in addition to rehabilitation of damaged KG’s and rehabilitation of Health care Centers in Gaza Strip is expected to have moderate level negative impacts during the pre-construction, construction and operation phases. ESO at MOE will conduct the site-specific environmental and social assessment of the subproject to assess the environmental and social risks and impacts of the project. The potential application of the World Bank ESSs should be assessed during the preparation of the subproject prior to appraisal; and if likely to be applicable, appropriate measures will be designed and applied. The assessment will be proportionate to the potential risks and impacts of the subproject, and will assess, in an integrated way, all relevant direct, indirect, and cumulative environmental and social risks and impacts specifically identified in ESS1-ESS10. Based on preliminary identification of ECD sub-project’s construction activities, the objectives and core requirements of applicable ESSs as required by ESF are stated in Annex 1. Description of the potential environmental and social risks and impacts relevant to the ECD construction sub-projects are as follows: 5.3.1 ESS1 Assessment and Management of Environmental and Social Risks and Impacts: The project has education and health components which include activities of construction and rehabilitation of KG classrooms in schools, possibly supply of furniture, play areas and kitchen, and supply of equipment to improve health care to mothers and infants in selected clinics. In addition to rehabilitation of kindergartens; provision of learning material for young children (between the ages of 3 and 5) of displaced families; and support to MoH for addressing urgent mental health and psychosocial needs of children and rehabilitation of two health care clinics in the Gaza Strip. Additonally, the project support the MHPSS services that will include capacity building of service providers and rehabilitation of two community mental health centers support centers that are underserved, under-equipped and lacking trained staff to treat children under 5. These activities entail construction risks, community, and labor OHS risks, and risk of exposure to COVID-19 that need to be managed. The construction and rehabilitation activities will be implemented by local contractors and labor management and occupational health and safety aspects are discussed further under ESS2. There is a low risk of potential presence of unexploded ordinances, that the KG sites that were directly shelled or include rubble at the 44 | P a g e work sites will be initially screened for UXO, and the required clearance and permits will be obtained from UNMAS prior conducting the E&S assessment. In addition to low risk of non- hazardous and hazardous waste mixed within the rubble in Gaza Strip will further be assessed under ESS3. The community health and safety will be further assessed in ESS4. The project will not involve land acquisition; more details will be given under ESS5. Details on stakeholder engagement, consultations, and GM will be addressed under ESS10. The risks associated with this kind of activities are generally Moderate as mentioned before. During implementation, site-specific ESMP shall be prepared as necessary once the exact construction location of these facilities have been identified. Where the environmental and social assessment will be conducted for each sub-project in West Bank (Annex 3), and Gaza Strip (Annex 4). 5.3.2 ESS2 Labor and Working Conditions Direct Workers employed directly by the client for project implementation and contracted workers for implementation of civil works in KGs/schools and clinics will be involved in the Project activities. Potential labor risks are associated with component 1 and sub-component 2.1 of the Project. Key Labor Risks: It is assessed that key labor risks associated with the Project are: • Exposure to construction/refurbishment activities including noise and dust, falling and falling objects, exposure to hazardous materials and exposure to electrical hazards from the use of tools; • Operation of medical equipment (mainly monograms and general stats monitoring equipment such as indirect Ophthalmoscope, direct Retinoscopy, handheld Auto Refracto-Kerato meter, and Neonatal incubators); • GBV, SEA/SH, and Child Abuse/Exploitation (CAE) risks. The risk on this aspect has been assessed as moderate as there will be no large-scale contraction works or labor influx and the presence of workers on site will be limited and controlled; • COVID-19 infection risks if proper infection control measures are not concidered, including the usage of masks, the availability of sanitizers and hand washing stations, disinfection of medical equipment and after each usage among other WHO and MoH recommended measures and actions. The construction activities of the Project will be conducted via local contractors. The provisions of this ESS2 will apply to these contracts and will be part of the bidding documents and specifications, particularly the OHS aspects to construction workers and operators of healthcare equipment. For activities to be implemented after the hostilities in Gaza Strip, the potential risk of presence of Unexploded Ordinances (UXO) will not pose impact on the Project Staff and the sub-project workers as the environmental and social screening for any activity will not commence and the ESC will not be allowed to access the site until receiving clearance from UNMAS in case of rubble presence at the KG sites. Risk associated with current labor and working conditions is classified as Moderate. Labor Management Procedures (LMP), in line with the project restructuring, is prepared to set out the Project’s approach to meeting national requirements as well as the objectives of the Bank’s Environmental and Social Framework, specifically objectives of ESS2 and ESS4. It enables different project-related parties including direct workers, contractors and sub-contractors and contracted workers, to have a clear understanding of what is required on a specific labor requirements. 45 | P a g e The Occupational Health and Safety (OHS) Manual has been prepared in accordance with the Palestinian Labor Law No. 07 of 2000, the Council of Ministers Act 11, 2012, the guidelines set out in ESS2, World Bank EHSG, Good International and Industry Practices (GIIP) and WHO guidelines for COVID-19 related to OHS at different workplaces apply to workers. The manual provides instruction and guidance to the Project team, including contractors and subcontractors, on the development and implementation of project specific Environmental, Social, Health and Safety requirements. The Manual outlines and defines the approach to health and safety to be adopted specifically for the ECD project both during the construction phase of sub-project. It also aims to highlight potential hazards specific to this project, as well as more general hazards, and to define the procedures by which these hazards shall be addressed. Moreover, the manual educates and provide an overview of OHS requirements to be used by the main Contractors and all sub-contractors employed on the project sites. 5.3.3 ESS3 Resource Efficiency and Pollution Prevention and Management This project will not consume large amount of energy and/or raw materials. The project components implemented in West Bank, and the rehabilitation of sensory rooms at to health care facilities in Gaza Strip will not produce toxic waste but general wastes, such as spoils, debris, and wastewater. Proper measures for safe disposal of waste during construction and operation phases are determined in the ESMF. However, projects implemented in Gaza strip include low potential risk related to the presence of unexploded ordnances (UXO), and non- hazardous and hazardous waste mixed within the rubble. the KG sites that were directly shelled or include rubble at the work sites will be initially screened for UXO, and the required clearance and permits will be obtained from UNMAS prior conducting the E&S assessment. Additionally, low risk of waste and hazardous waste mixed with the rubble. Develop and implement detailed waste management, measures, and actions to manage waste and hazardous materials as required in the site-specific ESMPs, and require contractors to prepare, submit, and implement site-specific waste management plans including relating to storage, final disposal, and supervision. The operation of supplied medical equipment for the MOH including hearing test equipment, congenital cataract equipment (indirect Ophthalmoscope, direct Retinoscopy, handheld Auto Refracto-Kerato meter, and Neonatal incubators), detailed Ultrasound for testing fetal organs to enhance the quality of antenatal care, and the EEG will not produce any type of hazardous waste nor any of the equipment’s will emit radiation. 5.3.4 ESS4 Community Health and Safety The construction activities for KGs/Schools’ classrooms (new, extension, and refurbishment) will take place within the existing footprint of schools, most likely during schooling year. The increased traffic of vehicles transporting equipment and materials on the roads near the communities may pose safety impacts. Additionally, there is potential risk of exposure to COVID-19, risk of SEA/SH related to the presence of workers in school premises during school hours, and in the surrounding communities. For MOH related activities, coordination needs to be conducted with administration to ensure suitable working hours in low traffic periods. All impacts and mitigation measures to ensure safety of school kids and the surrounding communities including traffic management plan to prevent any accidents or injuries will be developed by contractors. Measures will also be set in place to minimize any contact between 46 | P a g e workers and children and the school staff and prevent instances of GBV/SEA/SH and the project GMs will also include features to address any complaints. All construction materials, paintings, electrical and mechanical equipment, playgrounds, shall comply with safety standards for school kids. For activities to be implemented after the hostilities in Gaza Strip, the potential risk of presence of Unexploded Ordnances (UXO) will not pose impact on the community as the environmental and social screening for any activity will not commence and the ESC will not be allowed to access the site until receiving clearance from UNMAS in case of rubble presence at the KG sites. 5.3.5 ESS5 Land Acquisition, Restrictions on Land Use, and Involuntary Resettlement: ESS5 is not relevant to the ECD project. The expansion of KG classrooms in schools will be done within the existing footprints of schools, no land acquisition is expected. 5.3.6 ESS6 Biodiversity Conservation and Sustainable Management of Living Natural Resources ESS6 is not relevant to this project given the fact that project activities are conducted in urban areas and within the existing footprints of schools. No Forests or natural habitats will be affected by the project activities. 5.3.7 ESS7 Indigenous Peoples/Sub-Saharan African Historically Underserved Traditional Local Communities ESS7 is not relevant to the project as there are no Indigenous People (IP) present in the project area. 5.3.8 ESS8 Cultural Heritage ESS8 is not expected to be relevant to the project, project activities are unlikely to pose risk to physical cultural property. However, in the course of project implementation a chance find may occur whereby historical and cultural property is inadvertently found. Chance Find Procedures clauses for avoiding potential impacts will be inserted into the civil works contracts to ensure that the necessary measures are in place during construction phase of sub-project. Contractors are to abide to Chance Find Procedures which are described in Annex 2. 5.3.9 ESS9 Financial Intermediaries ESS9 is not relevant to the project given the fact that all ECD project activities will financed by the Bank and will be implemented by the three-line Ministries and no FI are involved. 5.3.10 ESS10 Stakeholder Engagement and Information Disclosure According to WB ESF, ESS10 is applicable for all projects therefore ESS10 is relevant to the Project. Accordingly, meaningful consultations with the involved stakeholders and communities should be conducted. Beneficiaries and stakeholders involved in ECD project, depending on the involved Ministry, include pregnant women, children up to age 5, 47 | P a g e caregivers, parents, teachers and students at schools, nearby affected people from the community, representatives of marginalized groups (e.g. women headed households, persons living in remote areas, displaced families, etc.), private sector providers of KGs/Schools, national and international civil society institutions (e.g., NGOs, INGOs), institutional stakeholders such as municipalities, and, the three implementing ministries including MOE, MOH, and MOSD. During the preparation of the original project, consultations with the three Ministries were carried out for the preparation of the ESMF to get their input and feedback on environmental and social management of the ECD project including identification of risks, capacity to manage the risks in terms of staff and institution. The meetings were held at the Ministries’ offices during the month of January 2019 with key persons from D.G. of Buildings, D.G. of Public Health, and PCU and PMU in the three-line Ministries. The consultation is incorporated when preparing this ESMF. Another round of consultations was conducted in July and August 2021 for project restructuring. Summary of consultation meetings and attendance sheets with the three Ministries are enclosed in the project’s SEP. Grievance Mechanism (GM) for the Parent Project will also be used for the restructured activities. The consultant shall promote the GM during the stakeholder engagement activities and inform affected people about the grievance mechanism including special channels for receiving and handling GBV related complaints. The consultant will carry out consultations with different stakeholders in compliance with the Technical Note on Public Consultations and Stakeholder Engagement in WBG-supported operations during COVID-19 (https://biwta.portal.gov.bd/sites/default/files/files/biwta.portal.gov.bd/page/f3ca1ff6_95b 0_4606_849f_2c0844e455bc/2020-10-01-11-04-717aa8e02835a7e778b2fff46f531a8c.pdf.), and maintain a record of the consultations indicating means of other engagement than consultations. Stakeholder Engagement Plan (SEP) The Stakeholder Engagement Plan (SEP) has been updated and disclosed in accordance with the terms of the World Bank ESF. In accordance with the SEP, MOE and MOH will provide stakeholders with the following information, as early as possible, and in a timeframe that enables meaningful consultations with stakeholders on project design: the purpose, nature and scale of the sub-project, duration of proposed sub-project activities and associated potential risks and impacts, proposed stakeholder engagement process, and the process and means by which grievances can be raised and will be addressed. Grievance Redress Mechanism (GM) for the Parent Project will also be used for the restructured activities. Discussion about GM is present in section 5.3. Annex 3 and Annex 4 provide a tool and guidelines for ESRC and applicable ESSs that should take place at an early stage of sub-project cycle and be prepared by ESO when the exact site of construction is identified. 48 | P a g e 5.4 Summary of ECD sub-projects’ Environmental and Social Risks and Impacts The overall impact of the Project is postive. The project actvities in the education and health sectors include supplying of medical equipments (including hearing test equipment, congenital cataract equipment, and ultrasound), and construction of new KG classrooms within the existing footprint of selected schools in West Bank. The identified restructuring actvities in Gaza Strip after the hostilities include minor rehabilitation works of 772 slightly damaged, including rehabilitation works for 2 moderately damaged private KGs; provision of learning materials for the most vulnerable children aged 3-5, who have been displaced due to the war; capacity building to improve availability and quality of Mental Health and Psychosocial Support Services (MHPSS) provided by the MOH and MOE such as training/on-the-job coaching of MOH and MOE staff in early detection and appropriate referral of children suffering from mental health disorders such as post-traumatic stress disorders and acute stress disorders; establishing psychosocial support services at community level, rehabilitation of sensory rooms at two health care clinics the supply of two EEG machines. The identified medical equipment aims to enhance the quality of antenatal care, the risks include potential health and safety risk during operation, safe disposal of equipment’s at the end of life as none of the equipment use or produce any type of waste, or medical waste. the environmental risks related to the construction or rehabilitation of existing KG classrooms within the existing footprint of selected schools in West Bank, and rehabilitation of KG’s in Gaza Strip under the restructured project include noise, generation of dust, solid waste and wastewater, labor occupational health and safety, community health and safety, and traffic safety, potential risk of exposure to COVID-19. KG rehabilitation activities may have additional health and safety risks for workers and the community, related to the potential presence of unexploded ordinances (UXO) and non-hazardous and hazardous waste mixed within the rubble. Therefore, the KG sites that were directly shelled or include rubble at the work sites will be initially screened for UXO, and the required clearance and permits will be obtained from the United Nations Mine Action Service (UNMAS) prior to conducting the E&S assessment. The risk of rubble presence would be low, as most of the rubble in Gaza Strip has been removed including in the selected KGs zones. On the other hand, the learning materials and capacity building activities under sub-components 2.2 and the supply of equipment under subcomponent 1.2 are of low environmental risk. 5.4.1 Summary of risks associated with construction and operation phases Table (3) summarizes the expected subproject activities during construction and operation phases and the identified potential risks on the significant environmental and social issues. 2 The total number of KGs can be increased up to 116 depends on the discussion with MOE. 49 | P a g e Table 3: Project Activities and Potential Impacts during Construction Phase Significant Environmental and Social Issues Community OHS3 Socio-economic Archaeology Project Activities Air Quality Labor and Accidents Traffic Noise Construction phase Excavation and x x x x x x Earthwork Heavy Machinery x x x x x Operation Construction of x x x X x KGs/Schools Minor Repair Works at x x x x x x KG’s Minor Rehabilitation Works at Health Care x x x x x x Centers Waste Disposal (solid, x X liquid, hazardous, etc.) Wastewater Disposal x x Transportation x x x x x Operation phase Transportation x x x x x Wastewater x Solid waste x Sustainability x x 5.4.2 Summary of potential risks Table (4) summarizes the risks and impacts estimated based on the general information available at this stage of the project as described in the previous section. Later and after sub- projects are identified, this Environmental and Social Evaluation Matrices (ESEMs) can be modified to accommodate the site-specific conditions. 3 Including community, workers, and students at KGs/Schools 50 | P a g e Table 4: Main ES Risks for New, Extension, and Refurbishment KGs/Schools in West Bank and Gaza, and minor Civil Works at Health Care Centers. Risks and Impacts Environmental and Social No. No Risk Low Risk Moderate Component Risk Construction phase 1 Existing public services x 2 Air quality/Dust × 3 Noise x 4 Students’ health and safety x 5 Community health and safety × 6 Workers’ health and safety × 7 Socio-economic4 x 8 Traffic × 9 Water resources × 10 Construction waste X 11 Aesthetic x 12 Archaeology x 13 Labor and working conditions x 14 Existing GM x 15 Hazardous waste x 16 Mixed rubble x 17 Unexploded ordnance or remains x 18 radiation x Operation phase 1 Traffic x 2 Wastewater x 3 Solid waste x 4 Sustainability x 4 The negative socio-economic issues referred to in this table include loss of land, asset, livelihood, lack of access to business’/residences during construction, influx of labor, community level conflicts resulting from project interventions, etc. 51 | P a g e Chapter Six: Procedures To Address Environmental And Social Issues This chapter defines steps, actions and responsibilities for screening potential environmental and social issues and classifying risk levels. 6.1 The Environmental and Social Screening Process The ESO at PCU will use screening and management process as guided in this ESMF to reduce ESHS risk and identify the required EA or mitigation measures. The purpose of this screening process is to determine which activities are likely to have negative environmental and social impacts; determine appropriate mitigation measures for activities with adverse impacts; and incorporate mitigation measures into the sub-projects as appropriate. The extent of environmental and social requirements prior to the commencement of the sub-projects will depend on the outcome of the screening process described below. Public consultations will take place during the environmental and social screening process, and for the ESMP’s drafts and the input from the public consultations will be reflected in the design of the mitigation and monitoring measures. The screening process shall be conducted according to the following steps: Step1: Sub-project Environmental and Social Screening The ESO upon selection of the sub-project site should assess the significance of potential impacts using environmental and social impact rating checklist below. The checklist must be filled, and number of potential impacts marked as None, Low, and Moderate, will be used to determine individual and the overall impact rating of the sub-project. The table below is a guidance to determine what action would be taken before proceeding to the next level based on the results. Rating and classification of potential impacts of Sub-projects For sub-projects with no impact (All These types of subprojects would be labeled as ‘subprojects of impact rating becomes ‘None’) no environmental impact. Those of sub-project will require no further action needed to proceed with the sub-project implementation For sub-projects with low risk These types of subprojects would be labeled as ‘Sub-projects of low environmental and social risk. Those of sub-project will require no further action needed to proceed with the sub-project implementation. Sub-projects of limited moderate These types of subprojects would be labeled as ‘Sub-projects of Risk moderate environmental and social risk. In this case, incorporate potential mitigation measures into the 52 | P a g e design of the subprojects would be integrated and site-specific ESMP Checklist would be prepared. Sub-projects of moderate Impact These types of subprojects would be labeled as ‘Sub-projects of moderate environmental and social risk. In this case, incorporate potential mitigation measures into the design of the subprojects would be integrated and site-specific ESMP would be prepared. Any Subprojects that may cause These types of subprojects would be labeled as ‘subprojects of substantial or high potential impact substantial or high environmental and social risk. In this case, (activities that will not be eligible for these sub-projects will not be financed by the project. this project financing) Step2: Screening including environmental and social actions/instruments The ESO will complete the Environmental and Social Screening Form (Annex 3- Part-2 and Annex 4-Part 2) to facilitate identification of relevant ESSs and due diligence action/instruments. After analyzing data contained in the environmental and social screening form and having identified the right environmental risk and hence scope of the environmental assessment required, the ESO will make a recommendation to MOE as to whether: (a) no further action; (b) implementation of mitigation measures will be required and development of site-specific ESMP; or Site-specific ESMP checklist, in addition to the need of the contractor to prepare OHS plan, ERP, or waste management plan, traffic management Plan, etc. The project ESMP or environmental and social plans will be proposed by the PCU as guided by this ESMF. Step 3: Approval of the screening reports At this stage environmental and social screening reports will be reviewed and approved by the PCU. If the sub-project has moderate environmental and social risks, MOE will ensure that all the necessary plans are prepared, or all mitigation measures are incorporated in the ESMP prior to approval. 6.2 Mitigation Measures 6.2.1 Mitigation Measures for Air Quality Risk of air quality deterioration during construction and rehabilitation of the KG buildings, is mainly due dust generation during excavation, construction in addition to transportation of material. Though the following measures should be addressed during the sub-project implementation: • Dust shall be suppressed by ongoing water spraying and/or installing dust screen enclosure at site • Vehicles transferring material to be properly covered. • Work activities causing dust generation should be avoided during windy days. • During interior installation, installing dust screen enclosure at site Demolition, debris shall be kept in controlled area and sprayed with water mist to reduce debris dust • The surrounding environment shall be kept free of debris to minimize dust. • Machinery emissions should be within the Palestinian acceptable standards and store construction materials in pre-identified storage areas. Cover friable materials during storage. Wet the network of unpaved roads on site. Regulation 53 | P a g e of speed to a suitable speed limit (20 km/h) for all vehicles entering/ passing through the project site and promptly repair vehicles with visible exhaust fume. • There will be no excessive idling of construction vehicles at sites 6.2.2 Mitigation Measures for Noise Noise/vibration anticipated to be generated during construction works by operating heavy machinery, i.e., use of excavators, cranes, heavy trucks, and generators, or during transportation of the work materials. Therefore: • Schedule activities with high or continuous source of noise and vibration after the KG/School working hours and define work hours for any similar activity in consultation with the Health Care Facilities Staff. • Proper selection of access route and a restriction on the time for transportation of the work materials in consultation with the stakeholders. • Properly maintained and serviced vehicles • Traffic regulation signs and traffic calming measures • Shutting down equipment/machinery when it is not directly in use 6.2.3 Mitigation Measures for Generated Non-Hazardous and Hazardous Waste The Project different activities including excavation, concrete works, mechanical electrical and external works entail generation of the waste material. The finishing activities may include use of painting where paints should be of non-harmful material. Therefore: • Contractor should prepare non-hazardous and hazardous waste management plan, including handling, storage, disposal, and approvals requirements. • Submit Material Safety Data Sheets (MSDS) and chemical mixture data sheets (CMDS) to the Engineer for approval. • Provide valid licenses of the chemical transportation company and the driver. • Contractor should provide temporary storage on site of all hazardous substances, that should be kept in safe containers labeled with details of composition, properties and handling information. • Maintenance of excavation machineries must be prohibited at work site to avoid spills. 6.2.4 Measures for addressing GBV, SEA/SH Risks and Impacts As discussed earlier, there is a moderate risk of GBV and SEA/SH under the project. The project will implement a number of activities to prevent GBV, SEA/SH risks. In particular, World Bank Group’s ‘Technical Note on SEA/SH for HNP COVID-19 Response Operations, https://www.humanitarianresponse.info/sites/www.humanitarianresponse.info/files/docu ments/files/iasc_interim_guidance_on_covid-19_- _protection_from_sexual_exploitation_and_abuse.pdf, will be used as a guide towards prevention measures. These will involve: • Awareness to communities in contact with project workers to specific issues women face during the pandemic, including safeguarding and responding to GBV and child abuse. • Publicly post or otherwise disseminate messages clearly prohibiting GBV, SEA/SH and providing the contact information for the Project GM, should there be any cases or 54 | P a g e suspicion of sexual exploitation and abuse. • Prepare and implement and train all workers on GBV prevention and child protection protocols during community engagement activities. Identify and prepare a list of GBV psychosocial support services that are available to support victims/survivors. • Codes of Conduct and provisions related to GBV and SEA/SH will be incorporated into the contractors including sanctions. The MOE will have the responsibility for monitoring the contractors’ compliance as mentioned in step 2 above. • The Code of Conduct shall be signed by each project worker/employee, as a first line mitigation measure, to indicate that they have: (i) received a copy of the code; (ii) had the code explained to them; (iii) acknowledged that adherence to this Code of Conduct is a condition of employment; and (iv) understood that violations of the Code can result in serious consequences, up to and including dismissal, or referral to legal authorities. A sample CoC is presented in Annex 13 of this ESMF report. • Ensure that the Project GM will have a mechanism for confidential reporting with safe and ethical documenting of GBV issues. 6.2.5 Measures for management of Occupational Health and Safety As detailed out in the Labor Management Procedure for the Project, and the Occupational Health and Safety Manual, all potential risks to project workers’ health and safety will be identified by all parties who employs workers. The contractors will need to prepare and implement OHS plan and Emergency Response Plan (ERP) to establish and maintain a safe working environment to prevent hazards to project workers, including workplaces, machinery, equipment, and processes under their control and sets out measures for emergency prevention and preparedness and response arrangements to emergency situations. Additional measures to minimize the risk of workers exposure to COVID-19, where all workers, regardless of specific exposure risks, it is always a good practice to do the following: • Frequently wash your hands with soap and water for at least 20 seconds. When soap and running water are unavailable, use an alcohol-based hand rub with at least 70% alcohol. Always wash hands that are visibly soiled. • Avoid touching your eyes, nose, or mouth with unwashed hands. • Practice good respiratory etiquette, including covering coughs and sneezes • Avoid close contact with people who are sick. • Stay home if sick. • Recognize personal risk factors. According to the WHO, certain people, including older adults and those with underlying conditions such as heart or lung disease or diabetes, are at higher risk for developing more serious complications from COVID-19. In order to ensure workers’ Health and Safety procedures, project workers will receive OHS training including protection against COVID-19 at the beginning of their employment. Training will cover the relevant aspects of OHS associated with daily work, including the ability to stop work without imminent danger and respond to emergency situations. Training records will be kept on file. These records will include a description of the training, the number of hours of training provided, training attendance records, and results of evaluations. 55 | P a g e 6.3 Environmental and Social Management Plan (ESMP) Environmental and social management plan (ESMP) is an instrument that details (a) the measures to be taken during the implementation and operation of a project to eliminate or offset adverse environmental and social impacts or to reduce them to acceptable levels; and (b) the actions needed to implement these measures. ESMP is a section in bidding documents of the ECD sub-projects, having construction activities, which is legally binding contractors to comply with environmental and social considerations. ESMP should be prepared in compliance with the Palestinian environmental and social laws and regulations, and WB ESF, the site-specific ESMP’s shall be reviewed and cleared by the Bank, additionally to be disclosed in the country and the Bank websites. The site-specific ESMP is considered the base of environmental and social management of the ECD construction sub-projects and should have the following contents: • Short description of ECD; • Sub-project Description; • Environmental and Social Legal Framework (Palestinian and ESMF); • Sub-project ES classification and assessment; • A description of planned mitigation measures for identified risks, and how and when they will be implemented; • ESMP matrix: The sub-project activities and anticipated impacts and impacts’ significant are determined and mitigation measures are identified and summarized; • Environmental and Social Liabilities of Contractors; • Environmental and Social Grievance Mechanism; • Monitoring Program Responsibilities: The monitoring program should identify what information will be collected, how, where, and how often. The people, groups, or organizations that will carry out the mitigation and monitoring activities are defined; • Capacity Development and Training: the ESMP can recommend specific, targeted training for project staff, contractor, and community groups to ensure the implementation of ES requirements. Based on the above, an ESMP template that define general mitigation measures and monitoring matrix is included in (Annex 5), once the exact location and detailed information of the sub-project are identified, the ESO will have to prepare a site-specific ESMP. For sub-projects of limited environmental and social impacts, an environmental and social management plan checklist will be prepared, the ESMP checklist will include general description of the sub-project, and site description, applicable laws and regulations, stakeholder engagement, capacity development requirements, risk identification checklist, environmental and social mitigation measures, and an environmental and social monitoring plan. Annex (6) provides an Environmental and Social Management Plan (ESMP) Checklist template. 56 | P a g e Contractors will be responsible for implementing the ESMP during the construction phase, which should also include the environmental and social guidelines to be followed by contractor (Annex 7), contractor’s commitment of environmental and social compliance and penalties is presented in Annex 8, and compliance and penalties deduction methodology (Annex 15). ESMP and environmental health and safety requirements for contractors are legally binding and are to be included in the bidding documents and contracts for the ECD construction subprojects. The ESO/MOE is responsible for monitoring contractors’ compliance to ensure overall compliance during the construction and operational phases of the projects. Also, the ESO/MOE is responsible on coordination with the Environmental and Social Consultant in Gaza and the EHSO/MOH to ensure compliance during the construction of both education and health activities. 57 | P a g e Chapter Seven: Stakeholder Engagement, Grievance Mechanism and Information Disclosure 7.1 Consultation and Disclosure Public consultations are critical in preparing effective and sustainable sub-projects. This requirement supports the participatory planning process as required by the WB and the national environmental and social regulations. It is important that beneficiaries are involved in throughout the project cycle, from the design to implementation and monitoring. The same applies to relevant stakeholders. For the ECD project, multiple consultation workshops have been conducted since the approval of the original project: one virtual meeting for the original project (May 2021), and two face to face meetings in July and August 2021 in Gaza for project restructuring. A public consultation workshop under the original or parent project was carried out virtually on May 4, 2021 due to Covid 19 restrictions. 37 stakeholders from different institutions attended the workshop (more than 20 of the stakeholders were representatives from the women, youth, community representatives, Municipalities etc.). The rest were representatives from the governmental ministries and authorities, mainly, Ministry of Education, Ministry of Health and Ministry of Social Development. The environmental and social risks and mitigation measures were covered and consulted with all attendees. Participants did not raise any concerns regarding the environmental and social issues relating to the project, mainly all of them have a good background from previous similar projects. In turn, the ESO explained and illustrated the WB Environmental and Social standards for all the attendees and discussed the Environmental and Social Standards (ESSs) associated with the project. Another round of public consultations was conducted between July and August 2021 as part of the pre-implementation phase of the restructured activities under the ECD project. The first consultation meeting in this round was conducted on July 11, 2021 in Gaza City. About 40 persons, representing different groups and with different interests, attended the workshop, with representatives from MOE Projects Coordination Unit (PCU), KGs’ headmistress/owners, KG Children’s parents and local and international NGOs. The second consultation meeting was conducted on August 08, 2021. About 32 persons, representing different groups and with different interests, attended the workshop, with representatives from different departments at the MOH, UNRWA, WHO, MOE, MOSD, KGs’ headmistress/owners, KG Children’s parents and local NGOs providing MHPSS services. The ESO at the MOE and the Project coordinator at the MOH from the West Bank also attended the meeting remotely via Microsoft Teams. The consultation meetings introduced the participants to the stakeholder engagement plan (SEP), the environmental and social management framework (ESMF) and informed them 58 | P a g e about the grievance redress mechanism that is in place during different phases of the project. The presentation highlighted, in details, the new emergency areas of intervention under the restructuring process, as well as the objective and content of the SEP and the ESMF. The presentation also highlighted the special provisions for vulnerable groups and the details of the GM, including the different steps of the grievance resolution process, focusing on the different complaint uptake channels, and the special referral pathways for the project related GBV and SEA/SH complaints and grievances. A detailed description of the public meetings and additional engagement activities is provided in the project’s SEP. In accordance with the SEP, MOE is required to disclose all the relevant documents and information on the ECD project in a timely manner, and in a form and language that are understandable, to facilitate meaningful consultations. The location of the relevant documents should be advertised through commonly used media. Depending on the public interest in the potential impacts of the sub projects, a consultation session may be required to better convey concerns. As discussed earlier, to fulfill the requirements of ESS10, an updated SEP has been prepared in line with the project restructuring. This SEP explains how stakeholder engagement will be practiced throughout the project life cycle and which methods will be used as part of the process. The SEP also outlines the responsibilities for implementation of stakeholder engagement activities. Stakeholder engagement shall be carried out in compliance with the Technical Note on Public Consultations and Stakeholder Engagement in WBG-supported operations during COVID- 19(https://biwta.portal.gov.bd/sites/default/files/files/biwta.portal.gov.bd/page/f3ca1ff6 _95b0_4606_849f_2c0844e455bc/2020-10-01-11- 04717aa8e02835a7e778b2fff46f531a8c.pdf.) The SEP has been disclosed in-country and on the World Bank’s website. Project information and all key documentations, including ESMF, LMP and the SEP will enable stakeholders to understand the risks and impacts of the project, and potential opportunities. The information will be disclosed in English and Arabic language, taking into account any specific needs of groups that may be differentially or disproportionately affected by the project or groups of the population with specific information needs (such as, disability, literacy, women, mobility, accessibility). The disclosure should include information on: (i) stakeholder engagement process, highlighting the ways in which stakeholders can participate; (ii) time and venue of any proposed public consultation meetings, and the process by which meetings will be notified, summarized, and reported and; (iii) the process and means by which grievances can be raised and will be addressed. 7.2 Grievance Mechanism In Palestine, the right of the public to complain in Palestine is ensured by the grievance bylaw approved by the Ministerial Cabinet in 2005 and updated in 2009. The Bylaw sets the rules for grievance of the public and the improving the performance of the Palestinian Ministries 59 | P a g e and Authorities. WB ESF requires implementing a grievance redress mechanism (GM) to receive and facilitate resolution of affected peoples’ grievances about the project’s performance, including concerning environmental and social impacts and issues. There is a Complaints Unit at the MOE and at the MOH. The units are part of the ministries’ organizational structure and administered by Heads of Unit and equipped with trained staff. The Complaints Unit work is regulated by the Council of Ministers Decision No. (8) of 2016 and by the Procedure Manual No. (20/17) of 2017. Both documents are made public and published in Arabic on the ministries’ websites. The PCU and PMU at both ministries have customized the pre-existing complaints system to meet the project needs. Grievance redress mechanisms were established within each ministry (MOE, MOH and MOSD), and are being coordinated through the PCU for the purposes of the project. These mechanisms will continue to be strengthened as required. Information about the grievance mechanisms shall be communicated to the project beneficiaries during the consultation meetings. The ESO shall handle complaints in line with the GM manual that was established for the project. Complaints will be registered in the complaints log prepared by the ESO. MOE/ESO shall also include in the assessment of potential impacts and risks of the construction activities, an assessment of risks related to GBV and SEA/SH. This assessment of impacts and risks will be prepared prior to initiating construction. The GM that was developed for the original project shall remain accessible and functional to receive and facilitate the resolution of concerns and grievances in relation to the restructured project in accordance with ESS10. Adequate resources shall be provided for the continued operation of the GM and the Bank’s project task team will confirm adequacy of the budget. For Projects in Gaza Strip, the ESC hired at the PCU (engaged on August 18, 2021) will be responsible for receiving project related complaints in coordination with the ESO, the D.G. of Buildings at the MOE and the EHSO at the MOH. The project’s level GM Manual w ill include roles and responsibilities of the PCU-ESO (MOE), PMU-EHSO (MOH) in addition to the ESC. The GM manual for the Parent Project will be used for the restructured activities. Checklist for good practice GM which illustrates the requirements of the ESSs is presented in Annex 11. The process reads as follows: Processing of grievances 1- Citizens submit their grievance to MOE, including the possibility of lodging anonymous grievances. Citizens must receive a receipt during 2 weeks according to the GM Manual. . 2- Reply to grievance shall be in time less than 14 days. 3- The grievances unit pursues the grievance following the procedures as indicated in the checklist. 4- Employee in charge of handling the grievance submitted the grievance to a specialized grievance unit, the unit must submit its response to grievances within three weeks at most. 5- Grievance feedback shall be communicated with complainant by telephone, fax, email, or in writing. 60 | P a g e Feedback/grievance monitoring and recording MOE shall keep a log for grievances and how complaints were resolved within a stipulated time frame within 2 weeks according to the GM Manual and then produce monthly reports for senior management. Grievances/feedback reports include data on numbers of grievances/feedback received, compliance with business standards, issues raised in grievances/feedback, trends in grievances/feedback over time, the causes of grievances/feedback, whether remedial action was warranted, and what redress was provided. MOE shall also make sure that the GM and the complaint system is applied properly according to the related laws and regulations and grievances/feedback made public periodically. 7.3 Grievance mechanism and process for complaints related to GBV and SEA/SH The GM for the restructuring activities shall receive, register, and address concerns and grievances related to GBV and SEA/SH in a safe and confidential manner, including through the referral of survivors to gender-based violence service providers. The project will also ensure via the stakeholder engagement that stakeholders are informed about the GM. The project level GM will include specific procedures for GBV, SEA/SH including confidential reporting and ethical documentation of GBV cases. The ESO will be responsible for addressing and responding to complaints related to children, and women who may be exposed to violence, sexual exploitation and abuse and sexual harassment. A GM email address (tbadawi@palpcu.com) and a telephone number (0598782117) will be communicated to project’s affected parties during consultations and through different stakeholder engagement methods. The ESO will also be responsible for managing complaints with high priority, seriousness, data protection and privacy through channeling the complaint to the Head of PCU/Minister of Education/Minister of Health to follow-up on it. Training will also be provided by a GBV expert for the ESO on detection of cases of gender-based violence and handling of inquiries, complaints and grievances related to GBV. Moreover, national laws, regulations and strategies include some provision to address issues regarding sexual exploitation and abuse and sexual harassment. The key document in this regard is the Charter of Women's Rights that was issued in 2008 by the Ministry of Women Affairs (MOWA) and a coalition of civil society organizations. The charter includes the Declaration on the Elimination of Discrimination against Women, which provides for the protection of women from all forms of violence against them in the workplace, particularly harassment. On the other hand, the MOE (previously named Ministry of Education and Higher Education (MoEHE)) Strategic Plan for 2017–2022 commits to achieving inclusion and equality by focusing on health education, awareness on sexual and reproductive health, and issues relating to combating child marriages, discrimination, violence, and inequality. 61 | P a g e In addition, MOH has recirculated its Palestinian Ministry of Health Codes of Conduct: Ministerial Decision (6) of year 2020 which includes generic instructions for conducting the relation between coworkers, the public and administration. The GBV and SEA/SH procedures are detailed in the SEP that has been disclosed for project restructuring. 7.4 Workers’ Grievance Mechanism A GM for all types of project workers, in line with ESS2 and the updated LMP, will be in place by the end of August and in time for restructuring activities to commence. The MoE will require contractors to conduct an orientation session for their workforce on the grievance mechanism prior to the start of civil works. The grievance mechanism also addresses child labor, GBV and sexual harassment related grievances. Information about the existence of the GM will be available to all project workers. The GM for project workers will be maintained throughout the implementation of the restructured project. The ESC at the PCU, in coordination with the ESO and the EHSO at the MOE and MOH respectively, will be responsible for monitoring the implementation of the workers’ grievance mechanism in Gaza and report these in the progress reports. A workers’ complaints manual is being finalized by the ministries. 7.5 Code of Conduct and SEA/SH Measures The safety measures, complaints, and SEA/SH measures will be detailed in the CoC. The CoC will be written in local language and provisions related to SEA/SH will be incorporated into the bidding documents, including sanctions. MOE will include the CoC in the bidding documents. The contractor will sign the CoC (see Annex 13) and will be made accountable for complying with it; as well orientation for workers will be requested. 62 | P a g e Chapter Eight: Institutional Arrangements , Responsibilities and Capacity Building Requirements 8.1 Institutional Structure ECD project will finance investments and activities that are within the responsibility of MOE, MOH, and MOSD. The D.G. of buildings will be responsible for monitoring and supervision of the sub-project in coordination with the ESO to monitor including the ES issues. 8.1.2 Organizational Structure of the D.G. of Buildings D.G. of Buildings have 17 Engineers at the Headquarter office in Ramallah and 2 Engineers in each Governorate of the West Bank. D.G. of Buildings comprises of three departments and subsections under each department (depicted in Chart 1) as follows: • Department of Design and Engineering Supervision o Engineering Design Section o Supervision and follow-up Section o Documents and Contracts Section o Measurements Section • Department of School Building Services o Follow-up directorates Section o Maintenance Section o Land and Acquisition Section • Department of Engineering Studies o Projects Preparation Section o Engineering Studies and Planning Section D.G. Buildings/ PCU/ ESO Selecting Consulting Engineering & District Offices Offices Contracting Engineers Handover (Design & Supervision) Contractors Workers Chart 1: Parties involved in construction/refurbishment activities in West Bank and Gaza 63 | P a g e D.G. of Buildings Southern Governorates General Director Northern Governorates Department of Design and Department of School Department of Engineering Supervision Building Services Engineering Studies • Engineering Design Section • Follow-up directorates • Department of • Supervision and follow-up Section Engineering Studies Section • Maintenance Section • Projects Preparation • Documents and Contracts • Land and Acquisition Section Section Section • Engineering Studies • Measurements Section and Planning Section Land acquisition and licensing Dept. Chart 2: Institutional Structure of D.G. of Building 8.2 Institutional arrangements and responsibilities ECD project will finance investments and activities that are within the responsibility of MOE, MOH, and MOSD. As described in the project components in the previous section, both PCU and PMU at MOH and MOE shall be responsible for reporting back to the Bank, for implementing and managing the ECD project and for the contracts ’ management of their components and sub-components, and management of the accounts, fiduciary aspects including financial management, incurring disbursement of payments to contractors in compliance with the laws and regulations of WB and Ministry of Finance. Sub-projects to be implemented by MOE will follow the procedures mentioned above for management and financing. For sub-projects including building, extension of KG2 classrooms, and refurbishments, the Directorate General of General Education will be responsible for annual work planning and identification of sub-projects according to the Ministry’s needs for development. The main tasks of D.G. of Buildings are: • Implementation of the general policy of the Ministry and the planning and construction of school and administrative buildings and other educational projects. • Working to provide the requirements of the educational policy in cooperation and coordination with the concerned authorities inside and outside the ministry. • Representing the Ministry in communicating and negotiating with donor countries regarding school building projects, and continuing research to obtain funding for the implementation of projects for school and educational buildings. 64 | P a g e • Participate in the assessment and identification of the needs and priorities of the school buildings, and the preparation of specifications and standards that are adapted to the requirements of the Ministry and in line with the global policies in education. According to the mandate and main tasks mentioned above, D.G. of Buildings is not responsible for construction/rehabilitation activities of projects. However, it is responsible for preparation of project bidding documents and project management including monitoring and supervision. Project technical designs, preparation of specs, and Bills of Quantities (BOQs) are prepared by outsourcing external engineering firm/office registered and accredited by the Engineering Association. The D.G. of buildings will be responsible for monitoring and supervision of the sub-project in coordination with the ESO to monitor including the ES issues. The ESO was hired at the PCU in October 2020 and will coordinate with the D.G. of Buildings to ensure environmental and social compliance during the Project construction activities. The ESO duties and responsibilities are: • Supervise the implementation of the updated ESMF and monitor the compliance of suppliers/contractors to the provisions of the ESMPs, updated ESF/SEP, and updated LMP in both Ministries. • Carry out classification for all ECD’s proposed projects and define the environmental and social risk assessment. • Review and assess the environmental and social feasibility of the proposed subprojects; • Prepare and monitor the sub-projects’ ESMPs. • Carry out supervision and monitoring of activities compliance to environmental, social, health and safety requirements during project implementation; • Liaise with key stakeholders and contractors; • Liaise with the appropriate officials from the Department of Antiquities at the MoTA where needed. An ESC has been hired at the PCU in August 2021, to support the activities implementation in Gaza Strip. The ESC is responsible for implementation of the project’s environmental and social requirements according to the ESCP including supervision of the implementation of the updated ESMF and monitoring the compliance of suppliers/contractors to the provisions of the ESMPs; implementation of the updated SEP and updated LMP for the project activities implemented by the Ministry of Education, the Ministry of Health and the Ministry of Social Development in the Gaza Strip; and, building the capacity of designated team members to implement the E&S measures. However, until the ESC hiring process is completed, the ESO will manage the environmental and social requirements closely with a designated PCU team member. Additionally, MOH has assigned their EHSO to support the activities in July 2021, the EHSO will coordinate with the ESO and the ESC for MOH related activities in West Bank and Gaza 65 | P a g e Strip. The ESOs at both ministries shall ensure that E&S clauses are reflected on bid documents and contracts. A Consultancy Firm will be responsible the design and preparation of sub-project document, will be responsible for supervision and report on the implementation of site-specific ESMP’s and the other environmental, social, health and safety plans of the ECD sub-projects, the consultancy firm shall include an environmental and social specialist in addition to the qualified technical staff to supervise the environmental health and safety of the sub-project implementation. The GM that was developed for the original project shall remain accessible and functional to receive and facilitate the resolution of concerns and grievances in relation to the restructured project in accordance with ESS10. Adequate resources shall be provided for the continued operation of the GM. For Projects in the Gaza Strip, the Environmental and Social Consultant (ESC) to be hired at the PCU will be responsible for receiving project related complaints in coordination with the ESO, the D.G. of Buildings at the MOE and the ESO at the MOH. Chart 3 below shows the relationship between different parties who will be following the construction or refurbishments parts of the project. In addition, Table (7) shows the time expected for each construction/refurbishment site to be completed. 66 | P a g e Chart 3: Responsibilities of different parties for MOE components 8.3 Environmental and Social Capacity Building As illustrated above, the main parties that will be responsible for the implementation of the ESMF are the MOE and MOH. However, the MOE will be the party that supervise and monitor the construction works in the KGs. Consequently, the staff assigned from these two ministries requires a capacity building program. A capacity assessment was conducted for the MOE staff in the DG of Buildings to determine the capacity building needs. Details of this assessment and its outcome are presented in Annex 14. According to the capacity building assessment, the ESO and PCU team at the MOE and the EHSO at the MOH is to attend capacity building programs that will ensure gaining sound knowledge in the World Bank ESF, as well as supporting MOE and MOH in their efforts to 67 | P a g e comply with these procedures. The proposed training and capacity building for the ESO and the EHSO shall cover the following topics: • Stakeholder mapping and engagement • Specific aspects of environmental and social assessment • Environmental and Social Management Plan • Environmental and social monitoring and reporting • Emergency preparedness and response • Community health and safety. • GM procedures and implementation. The ESO and the EHSO after training should be able to educate the project beneficiaries and relevant stakeholders and the contractors on the World Bank environmental and social safeguards especially the ESMF, SEP and LMP. Table 5 shows proposed seminars/workshops that seem to be held by the ESO and the EHSO for the different target groups during the project implementation stages. The D.G. of Buildings will liaise with contractors to ensure identification of the ESMF and ESMP within the pre-bid meeting and during the project implementation. Table 5: Proposed Workshops/Seminars for different Target Groups By Target Group Workshop/ Seminars Notes Whom Beneficiaries An orientation session on contractor ESO and and liability, health and safety measures, EHSO Stakeholders ESMP A training on complaints mechanism GM procedures and implementation A seminar concerning: ESO and As part of The use of the mitigation form and EHSO implementation environmental and social guidelines. stage preparation in Contractors The implementation of mitigation project pre-bid measures. meeting GM procedures and implementation 8.4 Environmental and Social Liability of Contractors With the aim of harmonizing the WB effort for managing the environmental and social activities financed by the Bank in Palestine, this section is adapted from the ESMF prepared for Municipal Development Program Phase III to suit the ECD project. For each sub-project, the site-specific ESMP is legally binding and is to be included in the bidding of ECD sub- projects, so that potential bidders are aware of environmental and social performance standards expected from them and are able to reflect that in their bids. The ESMP includes the environmental and social management guidelines for ECD contactors, to be implemented also as per stated in Annex 7. Contractors will be responsible for 68 | P a g e implementing the ESMP during the construction phase, which should also include the environmental and social guidelines to be followed by contractor (Annex 7), contractor’s commitment of environmental and social compliance and penalties is presented in Annex 8, and compliance and penalties deduction methodology (Annex 15). Furthermore, in accordance with the LMP and in compliance with the Palestinian labor law, contractors are responsible on complying with health and safety requirements where they are to provide insurance for construction labors, and staff attending to the construction site, citizens for each sub-project. Monitoring of these components is integrated in bidding evaluation, and site visits reports. Presence of labor influx or labor camp is not expected due to the small size of ECD sub- projects where short-term jobs are provided. The environmental and social management of the construction works become essential parts of a works’ contract upon its conclusion and their implementation is mandatory for a contractor. MOE, as the owner of construction works, will be responsible for enforcing compliance of contractor with the terms of the contract, including adherence to the ESMF and the subproject ESMP, and the other environmental, social and health and safety documents. The following procedures prevail, in addition to ESO & EHSO/supervisor engineer/ESC in Gaza: ▪ Deduction of environmental non-compliance will be added as a clause in the Bill of Quantities (BOQ) section, referring to annex in the bidding document detailing the deduction procedures; ▪ Environmental penalties shall be calculated and deductions are to be included in each submitted invoice; ▪ Mitigation measures in ESMP is the reference for environmental notes and penalties; ▪ Each impact depicted in the ESMP if not properly mitigated, will be counted as an environmental/social note; ▪ For minor infringements and social complaints, an incident which causes temporary but reversible damage, the contractor will be given environmental and social note/stop and alert to remedy the problem and to restore the environment. If reviewing the action by ESO/EHSO/Supervisor Engineer/ESC in Gaza showed that restoration is done satisfactorily, no further actions will be taken; ▪ For social notes: ESO/EHSO/Supervisor Engineer/ESC in Gaza will stop and alert the contractor to remedy the social impact, ESO/EHSO/Supervisor Engineer will follow the issue until solved. If contractor didn’t comply to remediation request, stop will be considered under no excused delay; ▪ If the contractor hasn’t remedied the environmental impact during this given time, ESO/EHSO/Supervisor Engineer/ESC in Gaza will: o stop the work and give the contractor an environmental and social note correlated to financial penalty according to the non-complied mitigation measure depicted in the biding document and the following procedures for National Competitive Bids and Shopping Bidding Documents; 69 | P a g e o ESO/EHSO/Supervisor Engineer/ESC in Gaza after the given time frame are to review the action, if engineer sees that restoration is done satisfactorily, no further actions will be taken, otherwise and if Contractor hasn’t remedied the situation within 1 day any additional days of stopping work will be considered no excused delay; ▪ When ESO/EHSO/Supervisor Engineer/ESC in Gaza issue an environmental/social note, it might depict one or more environmental penalty; and ▪ If repeating the non-compliance to ESMP penalties approached (3-5) % of the contract value, ESO/EHSO/Supervisor Engineer/ESC in Gaza will raise the formal recorded environmental and social notes and the deduction history to MOE in order to take a legal action. Considering that bidding document include environmental penalty in the BOQ, ESMP and deduction procedures in annexes and referred to in particular conditions. ▪ The environmental and social note form, in addition to details of deduction calculations for national competitive bids and shopping bid templates are detailed in Annex 15. 8.5 Environmental and Social Monitoring and Evaluation Arrangements 8.5.1 Environmental and Social Monitoring MOE and MOH will monitor the environmental and social performance of the project in accordance with the updated ESCP, the updated LMP, the OHS Manual, and this document which includes the restructuring environmental and social requirements. A system and setup for ESO for environmental and social monitoring and reporting for sub- projects will be developed at the MOE. Environmental and social monitoring will be an integral part of this system during the sub-project implementation. ESO in coordination with the ESC in Gaza will be responsible to instruct contractors on the compliance with the ESMP. ESO in coordination with the ESC in Gaza will conduct regular supervisory and environmental and social monitoring visits to verify contractors’ adherence to the requirements set out in the ESMP document and produce the required reports. MOH shall conduct monitoring in a similar manner and in coordination with the ESC for activities in Gaza. MOH will share its reports with MOE for the project’s progress reports and periodic updates. Annex 9 provides duties and responsibility of MOE during project cycle. 8.5.2 Environmental and Social Monitoring and Reporting During sub-projects’ construction phase in West Bank and Gaza strip, the ESO and EHSO in West Bank and the ESC in Gaza Strip will prepare the environmental and social monitoring reports using the form in Annex 10 for each school listed in sub-project packages: (a.) for site visit reports and, (b.) for monthly/quarterly reports, and sub-project final report. Frequency of reporting should be determined based on project size, complexity, and duration. These forms include detailed reporting of the status of environmental and social performance under the ECD project, including overview of deviations/violations of ESMP encountered over the report period, deviations/violations of environmental and social management guidelines for contractors, instructions given to contractors for addressing non-compliance and identified issues, and follow-up actions on revealed matters. Furthermore, ESO will use the 70 | P a g e Environmental form in Annex 10 to facilitate comparing environmental and social mitigation measures recorded in the appraisal stage and what has been implemented on ground. ESO’s reports will also include documentation of meetings and agreements with affected people, contractor’s action during construction stage, summary of site visits, environmental and social training and on-job training for the workers, summary of the raised environmental and social issue, ES notes, and complaints and how complaints have been followed. Moreover, ESO will verify the presence and application of health and safety measures. Regarding workers’ insurance, it will be checked during bidding evaluation process, where in case of accident during sub-project implementation, based on contractor’s reports and ESO’s reports, ESO is to report what the accident was, when it occurred, how the citizen or worker was treated following the insurance procedures. Contractor’s report will include any changes in public service on shop drawings, hazards or accidents within the project site and their resolution procedures, workers’ grievances and their resolution, chemical transport and storage log sheets, log of all disposed items and location of disposal, and spill accidents and any formation of stagnant water pools. Additionally, the ES Consultant in Gaza will be responsible on the above for the restructured sub-projects in Gaza, in coordination with the PCU team in Gaza and the PCU ’s ESO. The PCU’s ESO is also responsible on the Project Quarterly Environmental and Social Progress Reports, and any other form of environmental and social reporting. 8.6 Budget and resources for the implementation of the ESMF The cost for ESMF implementation shall cover costs related to stakeholder trainings, hiring, and training of ESO, and hiring ESC to support MOE in the implementation of the ESMF. The cost associated with implementing the ESMF and monitoring of environmental and social risks associated with the project is estimated at 275,800 $. Table 6 presents an indicative budget for the actions of ESMF implementation covering (i) cost of hiring ESO, (ii) cost of training, (iii) cost of orientation seminar for contractors, and cost of hiring ESC. The cost of mitigation measures of the ESMP, which is part of the project tender documents, will be included in the BOQ and the Bidding documents. Example of mitigation measures’ costs including: • Costs of dust suppression during excavation works and costs of monitoring noise during construction (shall be calculated based on the frequency of monitoring and cost of equipment); • Costs of installing erosion control measures shall be estimated as part of the engineering costs; and • Cost of clean-up and disposal of construction debris and waste. 71 | P a g e • Environmental and Social Consultant in Gaza for restructuring. The costs will be included in the sub-project contract financed by the Grant. This is estimated to cost on average around 2-3% of the ECD’s project Grant. Table 6: ESMF Cost Estimate Activities Quantity Unit Rate Total ($) ($) Remuneration of ESO 485 3,0006 144,000 Renumeration of EHSO 48 2100 100,800 Capacity Building for ESO by ESC 1 6,000 6,000 Training Beneficiaries and When required ESO - Stakeholders Environmental orientation 1 6,000 6,000 Seminar for contractors Environmental and social 1 3,000 3,000 management cost under LTC contract ESMS establishment at D.G. of 1 Will be covered -Once the ESO is Buildings by MOE in place there is no additional cost for establishing the ESMS Miscellaneous 6,000 6,000 Environmental and Social LS 10,000 10,000 Consultant in Gaza. Total 275,800 5 Considering the ECD will have 48 months 6 including social charges and taxes 72 | P a g e Annexes Annex 1: Applicable WB ESSs The ESSs 1-10 are designed to help Governments manage project risks and impacts, and improve environmental and social performance, consistent with good international and industry practice (GIIP) and national and international obligations. The objectives and core requirements of the applicable ESSs to ECD construction sub-projects are shown in Table (7). Table 7: World Bank ESSs and Core Requirements ESSs Objectives Core requirements ESS1: • Identify, assess, evaluate, and • The types of ES risks and impacts Assessment manage environment and social that should be considered in the and risks and impacts in a manner environmental and social Management consistent with the ESF assessment of • Adopt a mitigation hierarchy • The use and strengthening of the Environmental • Adopt differentiated measures Government’s environmental and & Social Risks so that adverse impacts do not social framework for the and Impacts fall disproportionately on the assessment, development and disadvantaged or vulnerable, implementation of world Bank and they are not disadvantaged financed projects where in sharing development benefits appropriate and opportunities • An Environmental and Social • Utilize national environmental Commitment Plan (ESCP), and social institutions, systems, developed in agreement with the laws, regulations, and World Bank, that sets out a procedures where appropriate summary of the material measures and actions for mitigation and monitoring ESS2: Labor & • Promote safety and health at • Requirements for the Government Working work to prepare and adopt labor Conditions • Promote the fair treatment, management procedures non-discrimination, and equal • Provisions on the treatment of opportunity of project workers direct, contracted, community, and • Protect project workers, with primary supply workers, and particular emphasis on government civil servants vulnerable workers • Requirements on terms and • Prevent the use of all forms of conditions of work, non- forced labor and child labor discrimination and equal • Support the principles of opportunity and workers freedom of association and organizations 73 | P a g e ESSs Objectives Core requirements collective bargaining of project • Provisions on child labor and workers in a manner consistent forced labor with national law • Requirements on occupational • Provide project workers with health and safety, in keeping with accessible means to raise the World Bank Group’s EHSG workplace concerns • Requirement for a grievance mechanism • Develop and disclose an Occupational Health and Safety manual for relevant OHS provisions in compliance with the Bank’s General EHSGs applied to the Project, and Ministry of labor guidelines to address: ▪ Identification of potential hazards to the Project workers including (ERW/UXO); ▪ Provision of preventive and protective measures; ▪ Training of the Project workers and maintenance of training records on health and safety measures, awareness on ERW/UXO; ▪ Documentation and reporting of occupational accidents, diseases and incidents. ESS3: • To promote the ▪ Requirements to assess risks Resource sustainable use of associated to waste generations, where generation Efficiency and resources, including of waste and hazardous Pollution energy, water and raw materials shall be avoided or Prevention and materials. minimized in all possible Management • To avoid or minimize measures, and develop waste adverse impacts on human management plan. health and the ▪ Provisions to exclude the use of environment by avoiding chemicals and hazardous or minimizing pollution materials subject to from project activities. international bans identified by • To avoid or minimize the relevant national authority. project-related emissions ▪ Requirments to coordinate with UNMAS in Gaza Strip to screen 74 | P a g e ESSs Objectives Core requirements of short and long-lived the site in case of the presence climate pollutants. of rubble, explosive remnants of war (ERW), and unexploded • To avoid or minimize ordinances in the rubble. generation of hazardous UNMAS clearance shall be and non-hazardous waste obtained prior to proceeding • To minimize and manage with the implementation of the risks and impacts relevant activities. associated with pesticide use ESS4: • Anticipate or avoid adverse • Requirements on traffic and road Community impacts on the health and safety safety, including road safety Health & of project-affected communities assessments and monitoring Safety during project life-cycle • Requirements to assessment risks • Promote quality, safety, and associated with security personnel, climate change considerations in and review and report unlawful infrastructure design and and abusive acts to relevant construction authorities • Avoid or minimize community exposure to project-related traffic and road safety risks, diseases and hazardous materials • Have in place effective measures to address emergency events • Ensure that safeguarding of personnel and property is carried out ESS5: Land Not relevant to the project Acquisition, Restrictions on Land Use & Involuntary Resettlement ESS 8 Cultural CHANCE FINDS: • Chance Finds procedures isincluded in Heritage Develop and document ‘Chance Annex 2 These procedure will be Find procedures that will detail included in all contracts for civil what the construction contractors works involving excavations. must do in case valuable artefacts or culturally valuable materials or buried, Physical Cultural Resources 75 | P a g e ESSs Objectives Core requirements (PCR) are unexpectedly encountered. ESS10: • Establish a systematic approach • Requires stakeholder engagement Stakeholder to stakeholder engagement that throughout the project life-cycle, Engagement & helps Governments identify and preparation and Information stakeholders and maintain a implementation of a Stakeholder Disclosure constructive relationship with Engagement Plan (SEP) them • Requires early identification of • Assess stakeholder interest and stakeholders, both project-affected support for the project and parties and other interested enable stakeholders’ views to be parties, and clarification on how taken into account in project effective engagement will take design place • Promote and provide means for • Stakeholder engagement to be effective and inclusive conducted in a manner engagement with project- proportionate to the nature, scale, affected parties throughout the risks, and impacts, and appropriate project life cycle to stakeholders’ interests • Ensure that appropriate project • Specifies what is required for information is disclosed to information disclosure and to stakeholders in a timely, achieve meaningful consultation understandable, accessible, and • Requires an inclusive and appropriate manner responsive grievance mechanism, accessible to all project-affected parties, and proportionate to project risks and impacts 76 | P a g e Annex 2: Chance Find Procedures Contracts for civil works involving excavations should normally incorporate procedures for dealing with situations in which buried Physical Cultural Resources (PCR) are unexpectedly encountered. The final form of these procedures will depend upon the local regulatory environment, including any chance find procedures already incorporated in legislation dealing with antiquities or archaeology. For ECD construction sub-components, chance finds procedures contain the following elements: 1. PCR Definition The definition of PCRs includes any movable or immovable objects, sites, structures, groups of structures, and natural features and landscapes that have archaeological, paleontological, historical, architectural, religious, aesthetic, or other cultural significance. PCRs may be located in urban or rural settings, and may be above or below ground, or under water. 3. Recognition A clause on chance finds should be included in general specifications section of the bidding document of sub-project. 4. Chance Find Procedures In case of accident findings of any antiquities or PCRs that might occur during the implementation of the subproject, the contractor must notify ESO/MOE who will immediately liaise with appropriate officials from MoTA. According to the applicable Jordanian Heritage law No. 51 for the year 19667, Article 15 MOE must stop the contractor and notify MoTA within 3 days to take necessary actions. In addition, the contractor should be familiar with the following “Chance Finds Procedures” in case accident chance find of any culturally valuable materials during excavation: ▪ Stop work immediately following the chance find of any possible archeological, historical, paleontological, or other cultural value; inform the ESO; ▪ Protect artifacts as well as possible using plastic covers; implement measures to stabilize the area, if necessary, to properly protect artifacts; ▪ Prevent and unauthorized access where finding occurred; and ▪ Restart construction works only upon the authorization of the relevant authorities. 7 MOE adopting the Jordanian Heritage law No. 51 for the year 1966 -Article 15 for the cultural heritage, noting the many that most of the Palestinian Laws are adopting the Jordanian Law, As a result, some ministries adopted the Jordanian Law during the implementation of the project. Accordingly, MOE is adopting using this law. 77 | P a g e Annex 3: Environmental and Social screening checklist Part – 1 : Screening Form for Potential Environmental & Social Safeguards Issues This form is to be used by the Project Coordination Unit (PCU) and the ESO to screen for the potential environmental and social risks and impacts of a proposed subproject. It will help the PCU and ESO in identifying the relevant Environmental and Social Standards (ESS), establishing an appropriate ES risk rating for these sub-projects, and specifying the type of environmental and social assessment required, including specific instruments/plans. Use of this form will allow the PCU and the ESO to form an initial view of the potential risks and impacts of a subproject. It is not a substitute for project- specific ES assessments or specific mitigation plans. The PCU should follow the form attached in Annex 4 for Gaza Sub-projects that been affected by the hostilities. A note on Considerations and Tools for ES Screening and Risk Rating is included in this Annex to assist the process. 1. Subproject name: ……………………………………………………………………………………. 2. Brief description of the subproject: [the description can be copied from the Site Visit and sub-Project Documents [size, location, surrounding] Will the project have impacts on the environmental and social parameters listed below during the construction or operational phases? Indicate, with a check, during which phase impacts will occur and whether mitigation measures are required A. Environmental and Social Screening Checklist for Construction of KG’s in West Bank: Activity Parameter Design Construction Operation Mitigation Possibly impacted Stage phase Phase measures [Indicate [Indicate with a [Indicate are required with a Check if with a Check or no [ ]Yes Check if impacted] if impacted] or [ ]No impacted] • Notification and Worker OHS • Community Health and Safety • Noise • Air Quality • Exposure to transmitted diseases including COVID-19 A. General Conditions • Community Exposure to GBV/SEA/SH • Exposure of facility personnel and students to GBV/SEA/SH • Universal Access • Material • Energy and Water Efficiency 78 | P a g e Activity Parameter Design Construction Operation Mitigation Possibly impacted Stage phase Phase measures [Indicate [Indicate with a [Indicate are required with a Check if with a Check or no [ ]Yes Check if impacted] if impacted] or [ ]No impacted] B. General Rehabilitation and /or Construction Activities Excavation • Noise Works • Workers OHS • Risk of accidents • Air Quality • Solid Waste Generation • Water Quality • In-site Public Services • Exposure to transmitted diseases including COVID-19 • Community Exposure to GBV/SEA/SH • Exposure of facility personnel and students to GBV/SEA/SH Construction • Noise Works • Workers OHS (Foundations, • Risk of accidents Concert, Block • Solid Waste Generation • Water Quality • Exposure to transmitted diseases including COVID-19 • Community Exposure to GBV/SEA/SH • Exposure of facility personnel and students to GBV/SEA/SH External Works • Noise including Walls, • Workers OHS yards, retaining • Risk of accidents walls, • Air Quality playgrounds • Solid Waste pavement, gates, Generation boundary walls) • Water Quality • In-site Public Services • Exposure to transmitted diseases including COVID-19 • Community Exposure to GBV/SEA/SH • Exposure of facility personnel and students to GBV/SEA/SH Mechanical • Noise Works • Workers OHS 79 | P a g e Activity Parameter Design Construction Operation Mitigation Possibly impacted Stage phase Phase measures [Indicate [Indicate with a [Indicate are required with a Check if with a Check or no [ ]Yes Check if impacted] if impacted] or [ ]No impacted] (Sanitation, • Risk of accidents Water) • Air Quality • Solid Waste Generation • Water Quality • In-site Public Services • Exposure to transmitted diseases including COVID-19 • Community Exposure to GBV/SEA/SH • Exposure of facility personnel and students to GBV/SEA/SH Electrical Works • Noise • Workers OHS • Risk of accidents • Solid Waste Generation • Water Quality • In-site Public Services • Exposure of facility personnel and students to GBV/SEA/SH Finishing Works • Noise • Workers OHS • Risk of accidents • Air Quality • Solid Waste Generation • Exposure to transmitted diseases including COVID-19 • Community Exposure to GBV/SEA/SH • Exposure of facility personnel and students to GBV/SEA/SH Furniture Supply • Nuisance • Air Quality • Health and Safety Transportations of • Nuisance materials and equipment • Air Quality to the work site (For All • Health and Safety Projects) Aesthetic view and Green • Damage to aesthetic Cover due construction works • Uprooting trees C. Historic building(s) Cultural Heritage 80 | P a g e Activity Parameter Design Construction Operation Mitigation Possibly impacted Stage phase Phase measures [Indicate [Indicate with a [Indicate are required with a Check if with a Check or no [ ]Yes Check if impacted] if impacted] or [ ]No impacted] • Project Located within or in the vicinity of any cultural heritage site • Potential impact on cultural heritage building due the construction works • Non-hazardous waste D. Toxic materials management • Workers OHS (Example: Paint) • Hazardous waste • Management • Workers OHS B. Environmental and Social Screening For Equipment’s: Mitigation measures are required or no [ Yes] or [No] Does the requested Yes NO equipment require medical material to operate? Is there appropriate PPE’s to Yes NO operate Is there Trained worker to Yes NO operate the equipment’s Does the Equipment produce Yes NO hazardous or nonhazardous waste Does the requested Yes No If Yes, please refer to equipment require Section A or B dependent rehabilitation activities at the on the beneficiary facility location C. Classification and Conclusion Conclusion of the environmental and social classification: 1. No risk 2. Low risk 3. Moderate risk If accepted, and based on risk assessment, subproject preparation requires: 81 | P a g e Risks to be addressed at Design Stage: (Please include according to the checklist) Part B Identification of Relevant ESSs and Due Diligence Action/Instruments ESSs Applicable / Not applicable Requirement (include only the Required Instrument) ESS1 No further action Completion of the Environmental and Social Management Plan Completion of the Environmental and Social Management Plan Checklist ESS2 OHS Plan ERP ESS3 Waste Management Plan Hazardous Waste Management Plan ESS4 Traffic and Road Safety Plan ESS5 ESS6 ESS7 ESS8 chance find procedures ESS9 ESS10 Site-Specific Stakeholder Engagement Plan 82 | P a g e Annex 4: Environmental and Social screening checklist (For Projects in Gaza Strip affected by the hostilities) The ESC will not Enter the Site if potential Rubble is expected at the site, until receiving clearance from UNMAS Part – 1 : Screening Form for Potential Environmental & Social Safeguards Issues This form is to be used by the Project Coordination Unit (PCU) and the ESO to screen for the potential environmental and social risks and impacts of a proposed subproject. It will help the PCU and ESO in identifying the relevant Environmental and Social Standards (ESS), establishing an appropriate ES risk rating for these subprojects and specifying the type of environmental and social assessment required, including specific instruments/plans. Use of this form will allow the PCU and the ESO to form an initial view of the potential risks and impacts of a subproject. It is not a substitute for project-specific ES assessments or specific mitigation plans. 1. Subproject name: ……………………………………………………………………………………. 2. Brief description of the subproject: [the description can be copied from the Site Visit and sub-Project Documents [size, location, surrounding] 3. Will the project have impacts on the environmental and social parameters listed below during the construction or operational phases? Indicate, with a check, during which phase impacts will occur and whether mitigation measures are required. A. Environmental and Social Screening Checklist for KGs and Health Care Centers Rehabilitation in Gaza Strip: 1) Has the site been directly shelled? Yes No 2) Does the site include rubble Yes No If the answer is No, please answer the scale of damage and please proceed to section B If the answer is Yes, please answering the following questions 3) What is the scale of Damage? Low Moderate Severe Please define the damage: 4) Have UNMASS screened the site? Yes No If the answer is Yes, Is the site clear from UXO? (Please attach UNMASS Assessment Report) Yes No If No, please identify the timeframe UNMASS will clear the site. No works shall be commenced prior clearing the site. 83 | P a g e Please approach UNMASS to conduct the UXO Assessment and include the UNMASS Assessment and Clearance Report 5) Does the site include uncleaned mixed rubble (mixed with equipment’s, vehicles, Batteries, PV cells, solid waste, e-waste, medical waste, wastewater? Yes No If Yes, please include UNMASS Report, and Ask Contractor to prepare Hazardous Waste Management Plan. Activity Parameter Design Construction Operation Mitigation Possibly impacted phase phase Phase measures are [Indicate [Indicate with a [Indicate required or with a Check if with a Check no [ Yes] or Check if impacted] if impacted] [No] impacted] • Notification and Worker OHS • Community Health and Safety • Noise • Air Quality • Exposure to transmitted diseases including COVID-19 A. General Conditions • Community Exposure to GBV/SEA/SH • Exposure of facility personnel and students to GBV/SEA/SH • Universal Access • Material • Energy and Water Efficiency B General Rehabilitation and /or Construction Activities Excavation • Noise Works • Workers OHS • Air Quality • Solid Waste Generation • Water Quality • In-site Public Services • Exposure to transmitted diseases including COVID-19 • Community Exposure to GBV/SEA/SH • Exposure of facility personnel and 84 | P a g e students to GBV/SEA/SH Construction • Noise Works (Concert, • Workers OHS Block • Risk of accidents • Solid Waste Generation • Water Quality • Exposure to transmitted diseases including COVID-19 • Community Exposure to GBV/SEA/SH • Exposure of facility personnel and students to GBV/SEA/SH External Works • Noise including Walls, • Workers OHS yards, retaining • Risk of accidents walls, • Air Quality playgrounds • Solid Waste pavement, gates, Generation boundary walls ) • Water Quality • In-site Public Services • Exposure to transmitted diseases including COVID-19 • Community Exposure to GBV/SEA/SH • Exposure of facility personnel and students to GBV/SEA/SH Mechanical • Noise Works • Workers OHS (Sanitation, • Risk of accidents Water) • Air Quality • Solid Waste Generation • Water Quality • In-site Public Services • Exposure to transmitted diseases including COVID-19 • Community Exposure to GBV/SEA/SH • Exposure of facility personnel and students to GBV/SEA/SH Electrical Works • Noise • Workers OHS • Risk of accidents • Solid Waste Generation • Water Quality In-site Public Services Exposure of facility personnel and 85 | P a g e students to GBV/SEA/SH Finishing Works • Noise • Workers OHS • Risk of accidents • Air Quality Painting works, • Solid Waste Carpentry works Generation Aluminum works • Exposure to transmitted diseases including COVID-19 • Community Exposure to GBV/SEA/SH • Exposure of facility personnel and students to GBV/SEA/SH Rehabilitation Works Damaged Solid waste Carpentry works Workers OHS GBV/SEA/SH Damage to Tile Solid waste (external, internal) Workers OHS Dust GBV/SEA/SH Damaged Glass Solid waste (windows) , Tempered glass Workers OHS (doors/internal GBV/SEA/SH walls) Damaged • Polluted Solid waste Sanitary • Water Quality Appliance • Workers OHS • GBV/SEA/SH Damaged • Solid waste Aesthetic/Green • Workers OHS Cover • GBV/SEA/SH Damaged Solar • Hazardous Waste PV System • Workers OHS • GBV/SEA/SH Furniture Supply Transportations of • Nuisance materials and equipment • Air Quality to the work site (For All • Health and Safety Projects) • GBV/SEA/SH 86 | P a g e Atheistic view and Green Damage to aesthetic Cover due construction works Uprooting trees C. Historic building(s) Cultural Heritage Project Located within or in the vicinity of any cultural heritage site Potential impact on cultural heritage building due the construction works • Hazardous waste D. Toxic materials • Management • Workers OHS (Example: Paint) E. GBV/SEA/SH Exposure • Community Exposure to GBV/SEA/SH • Exposure of facility personnel and students to GBV/SEA/SH B. Classification and Conclusion Conclusion of the environmental and social classification: 4. No risk 5. Low risk 6. Moderate risk If accepted, and based on risk assessment, subproject preparation requires: Risks to be addressed at Design Stage: (Please include according to the checklist) D. Classification and Conclusion Conclusion of the environmental and social classification: 7. No risk 8. Low risk 9. Moderate risk If accepted, and based on risk assessment, subproject preparation requires: Risks to be addressed at Design Stage: (Please include according to the checklist) 87 | P a g e Part B- Identification of Relevant ESSs and Due Diligence Action/Instruments ESSs Applicable / Not applicable Requirement (include only the Required Instrument) ESS1 No further action Completion of the Environmental and Social Management Plan Completion of the Environmental and Social Management Plan Checklist ESS2 OHS Plan ERP ESS3 Waste Management Plan Hazardous Waste Management Plan ESS4 Traffic and Road Safety Plan ESS5 ESS6 ESS7 ESS8 chance find procedures ESS9 ESS10 Site-Specific Stakeholder Engagement Plan 88 | P a g e Annex 4: ESMP Template Introduction Environmental and social management plan (ESMP) is an instrument that details set of mitigation, monitoring, and institutional measures to be taken during implementation and operation of a project to eliminate adverse environmental and social risks and impacts, offset them, or reduce them to acceptable levels. The ESMP also includes the measures and actions needed to implement these measures. The MoH will (a) identify the set of responses to potentially adverse impacts; (b) determine requirements for ensuring that those responses are made effectively and in a timely manner; and (c) describe the means for meeting those requirements. The ESMP includes the following components: Introduction An overview of the project and the proponent including information such as: i) project name and general description; ii) background; iii) objectives of the ESMP. Policy and Legal Framework Brief outline relevant policies, guidelines and laws that apply to the project and the approvals that need to be obtained from different government agencies Sub-Project description and Justification Brief description of the subproject including project location and footprint (including maps), summary of key design features, resource requirements and source, predicted type and quantify of waste outputs, work force size and accommodation, and implementation schedule Brief justification including benefits accruing to the local area, and project relevance in light of local or national needs Description of the subproject area A brief description of the environmental, socio-economic and cultural characteristics relevant to the project and its area of influence Consultation and Information Dissemination A summary of consultation and information dissemination activities during the ESMP process and including general issues raised, and responses to those issues; Impact Assessment and Mitigation Measures The ESMP identifies measures and actions in accordance with the mitigation hierarchy that reduce potentially adverse environmental and social impacts to acceptable levels. The plan will include compensatory measures, if applicable. Specifically, the ESMP: a) identifies and summarizes all anticipated adverse environmental and social impacts; b) describes—with technical details—each mitigation measure, including the type of impact to which it relates and the conditions under which it is required, together with equipment descriptions, and operating procedures, as appropriate; c) estimates any potential environmental and social impacts of these measures; and d) takes into account, and is consistent with, other mitigation plans required for the project. 89 | P a g e Environmental and social Mitigation Plan Activit Potential Proposed Responsibility Period for Mitigation y Environmental and Mitigation for Implementati Measures social Impact Measures Implementati on of Implementati on of Mitigation on Costs (and Mitigation Measures who bears it) Measures Construction Stage 1 2 Operational Phase 1 2 Environmental and Social Monitoring and Reporting The ESMP identifies monitoring objectives and specifies the type of monitoring, with linkages to the impacts assessed in the environmental and social assessment and the mitigation measures described in the ESMP. Specifically, the monitoring section of the ESMP provides (a) a specific description, and technical details, of monitoring measures, including the parameters to be measured, methods to be used, frequency of measurements, limits (where appropriate), and definition of thresholds that will signal the need for corrective actions; and (b) monitoring and reporting procedures to (i) ensure early detection of conditions that necessitate particular mitigation measures, and (ii) furnish information on the progress and results of mitigation. Environmental and Social Monitoring Plan What Where How When Who Cost parameter is is the is the is the monitors the of monitoring to be parameter to parameter to parameter to parameter the parameter monitored? be be be monitored (responsibility (and who monitored? monitored? (time and )? bears it) frequency)? Construction Stage 1 2 Operational Phase 90 | P a g e 1 2 Institutional Arrangements, Capacity Development and Training The ESMP provides a specific description of institutional arrangements, identifying which party is responsible for carrying out the mitigation and monitoring measures (e.g., for supervision, monitoring of implementation, liabilities, reporting, and staff training). The overall monitoring and reporting of the environmental and social requirements are the responsibility of the PCU ESO, the ESMF provides description of the roles and responsibilities. Implementation Schedule and Cost Estimates For all mitigation, and monitoring, the ESMP provides (a) an implementation schedule for measures that must be carried out as part of the subproject, showing phasing and coordination with other relevant environmental health and safety plans; and (b)where needed the capital and recurrent cost estimates and sources of funds for implementing the ESMP, these figures are also integrated into the subproject Bill of quantities where applicable. 91 | P a g e Potential Impact Mitigation Measures Operation/ Supervision Monitoring Responsibility Construction Phase Damage to existing ▪ Additional survey for potential sites Contractor Supervision Engineer ESO aboveground and underground ▪ Repair any damage occurs in coordination with the appropriate service provider public services (Water, ▪ Monitoring of site excavation Wastewater, electricity, etc.) Transportations of materials ▪ Ensuring that vehicles are loaded in such a manner as to prevent falling off or Contractor Supervision Engineer Supervision and equipment to the work site spilling of construction materials and by sheeting the sides and tops of all vehicles Engineer/ESO carrying mud, sand, other materials, and debris Dust generated by construction ▪ Monitor the excavations Contractor Supervision Engineer Supervision activities ▪ Applying (spraying) water where possible Engineer/ESO ▪ Avoid work during windy days ▪ Covering the construction area very well ▪ Covering the transportation trucks ▪ Monitoring and maintaining equipment from emissions or fumes Traffic congestion and increase ▪ Proper scheduling of any risky activities Contractor Supervision Engineer Supervision the risk of accidents ▪ Ensure placing proper traffic signs to ensure proper routing and distribution of Engineer/ESO traffic ▪ Closure of work site and limit access to verified personnel only Construction waste generated ▪ Clear site management plans and dumping at proper and approved sites Contractor Supervision Engineer Supervision and left in site Engineer/ESO Improper disposal of generated Ensure that the facilities are connected to either wastewater network and if not Contractor Supervision Engineer Supervision waste available to a septic tank that is regularly maintained Engineer/ESO Noise generation during ▪ Construction management of working hours and respecting normal working hours Contractor Supervision Engineer Supervision construction activities ▪ Proper maintained and serviced vehicles Engineer/ESO ▪ Traffic regulation signs and traffic calming measures ▪ Shutting down equipment when it is not directly in use ▪ Postpone the working by high voice machinery and shakiness machinery until school classes finished (around 12:pm) ▪ Postpone the working by high voice machinery and shakiness machinery until school classes finished (around 2:pm) and for MoH facilities coordination needs to be conducted with administration to ensure suitable working hours in low traffic periods 92 | P a g e Potential Impact Mitigation Measures Operation/ Supervision Monitoring Responsibility Localized disturbance of Contractor Supervision Engineer Supervision ▪ Proper construction management and reshape the site conditions to its origin surrounding areas ▪ Check drivers' credentials Engineer/ESO ▪ Traffic plan, warning signs, protection of excavation sites, providing detours and Contractor Supervision Engineer Supervision Traffic increasing around the coordination with traffic department Engineer/ESO schools, localized disturbance ▪ Coordinate with the school administration to take appropriate measures of of traffic and accidents risks student safety ▪ Provide safe access and passages Loss of aesthetic due to Proper design of landscaping for the area and around the school which may include Contractor Supervision Engineer Supervision construction activities some plantation activities Engineer/ESO Potential uncover and damage Follow “Chance Finds Procedures” Contractor Supervision Engineer Supervision of archaeological remains Engineer/ESO Land Use (Property Rights) Avoid any use of private land during construction, except of presence of legal Contractor Supervision Engineer Supervision document between contractor and citizen to use the land for short time Engineer/ESO Improper implementation of ▪ Prepare OHS plan Contractor Supervision Engineer Supervision Workers health and safety ▪ Workers commitment to OHS (vests, gloves, HD wearing apparel, helmet and Engineer/ESO others… ▪ Provide a first aid box close to the construction site ▪ Provide sanitary lavatory for workers Potential risk on Pedestrians' ▪ Maintain and commitment to traffic signs, road markings, barriers and traffic Contractor Supervision Engineer Supervision safety in the nearby area due control signals and such other measures as may be necessary for ensuring traffic Engineer/ESO machinery movement safety around the construction site ▪ Blocking and isolating the working area Potential risk to Students and ▪ Install Canopy around the construction area, and close the site access, further to Contractor Supervision Engineer Supervision teachers safety close the footing works area from access Engineer/ESO ▪ Provide safe and healthy passages for them ▪ Provide safety measures for them (mask when needed) Use of Toxic and Hazardous ▪ Provide valid licenses of the chemical transport company and the driver Contractor Supervision Engineer Supervision Materials such as asphalt and ▪ Submit Material Safety Data Sheets and chemical mixture data sheets to the Engineer/ESO thermoplastic paint Engineer for approval ▪ Store and dispose of residual hazardous material by an experienced professional 93 | P a g e Potential Impact Mitigation Measures Operation/ Supervision Monitoring Responsibility Generation of solid Waste ▪ Prepare a waste management plan prior to commencement of construction Contractor Supervision Engineer Supervision activities Engineer/ESO COVID-19 Guidelines ▪ The WHO regulated the guideline to protect and avoid any infection summarized Contractor/Consultancy Supervision Engineer Supervision Engineer below: stay safe by taking some simple precautions, such as physical distancing, Firm, Administration, wearing a mask, keeping rooms well ventilated, avoiding crowds, cleaning your MoE hands, and coughing into a bent elbow or tissue. Operational Phase Building new schools/ classes ▪ Ensure appropriate traffic circulation and necessary steel guards on sidewalks KGs/Schools KGs/Schools MOT increase traffic ▪ Traffic signs to reduce the traffic (one-way sign) and traffic calming signs administration administration and ▪ GM and how complaints were resolved traffic police Improper disposal of generated ▪ Ensure proper connection to wastewater network and if septic tank is used, proper KGs/Schools KGs/Schools EQA wastewater disposal is maintained administration administration ▪ Inspect any improper collection/disposal Generation of solid Waste ▪ Waste management is properly maintained KGs/Schools KGs/Schools EQA administration administration ▪ Sustainability of the Project ▪ Ensure financial sustainability KGs/Schools KGs/Schools MOE ▪ Failure to sustain safe and ▪ Ensure technical sustainability by proper training and capacity building of relevant administration administration good condition of the institutions subproject due to damage, ▪ Use and maintain checklists and monitoring tools to conduct frequent checks on misuse, and lack of subproject conditions maintenance 94 | P a g e Annex 6: ESMP Checklist for the Small-Scale Rehabilitation Sub- projects The ESMP Checklist is composed of four parts: A. General Project and Site Information B. Safeguards Information C. Mitigation Measures D. Monitoring Plan Part A: General Project and Site Information SITE DESCRIPTION Name of site Describe site location Attachment: Site map [ ]Y [ ] No Who owns the land? Description of geographic, physical, biological, geological, hydrographic and socio-economic context Locations and distance for material sourcing, especially aggregates, water, stones? LEGISLATION Identify national & local legislation & permits that apply to project activity PUBLIC CONSULTATONS Identify when / where the public consultation process took place INSTITUTIONAL CAPACITY BULDING Will there be any capacity building? [ ] N or [ ]Y if Yes, Attachment 2 includes the capacity building program 95 | P a g e Part B: Safeguards Information This part includes Environmental and social screening for : [a] West bank works [b] Gaza strip works. A. Environmental and Social Screening Checklist for Construction of KGs in West Bank: For Projects implemented in Gaza Strip, please start with Section [b] Please Copy the Input from the Screening Report Activity Parameter Design Construction Operation Mitigation Stage phase Phase measures Possibly impacted are required or [Indicate [Indicate with [Indicate no [ ]Yes or with a a Check if with a [ ]No Check if impacted] Check if impacted] impacted] • Notification and Worker OHS • Community Health and Safety • Noise • Air Quality • Exposure to transmitted diseases including COVID-19 A. General Conditions • Community Exposure to GBV/SEA/SH • Exposure of facility personnel and students to GBV/SEA/SH • Universal Access • Material • Energy and Water Efficiency B. General Rehabilitation and /or Construction Activities Excavation • Noise Works • Workers OHS • Risk of accidents • Air Quality • Solid Waste Generation • Water Quality • In-site Public Services • Exposure to transmitted diseases including COVID-19 96 | P a g e Activity Parameter Design Construction Operation Mitigation Stage phase Phase measures Possibly impacted are required or [Indicate [Indicate with [Indicate no [ ]Yes or with a a Check if with a [ ]No Check if impacted] Check if impacted] impacted] • Community Exposure to GBV/SEA/SH • Exposure of facility personnel and students to GBV/SEA/SH Construction • Noise Works • Workers OHS (Foundations, • Risk of accidents Concert, Block • Solid Waste Generation • Water Quality • Exposure to transmitted diseases including COVID-19 • Community Exposure to GBV/SEA/SH • Exposure of facility personnel and students to GBV/SEA/SH External Works • Noise including Walls, • Workers OHS yards, retaining • Risk of accidents walls, • Air Quality playgrounds • Solid Waste pavement, gates, Generation boundary walls) • Water Quality • In-site Public Services • Exposure to transmitted diseases including COVID-19 • Community Exposure to GBV/SEA/SH • Exposure of facility personnel and students to GBV/SEA/SH Mechanical • Noise Works • Workers OHS (Sanitation, • Risk of accidents Water) • Air Quality • Solid Waste Generation • Water Quality • In-site Public Services 97 | P a g e Activity Parameter Design Construction Operation Mitigation Stage phase Phase measures Possibly impacted are required or [Indicate [Indicate with [Indicate no [ ]Yes or with a a Check if with a [ ]No Check if impacted] Check if impacted] impacted] • Exposure to transmitted diseases including COVID-19 • Community Exposure to GBV/SEA/SH • Exposure of facility personnel and students to GBV/SEA/SH Electrical Works • Noise • Workers OHS • Risk of accidents • Solid Waste Generation • Water Quality • In-site Public Services • Exposure of facility personnel and students to GBV/SEA/SH Finishing Works • Noise • Workers OHS • Risk of accidents • Air Quality • Solid Waste Generation • Exposure to transmitted diseases including COVID-19 • Community Exposure to GBV/SEA/SH • Exposure of facility personnel and students to GBV/SEA/SH Furniture Supply • Nuisance • Air Quality • Health and Safety Transportations of • Nuisance materials and equipment • Air Quality to the work site (For All • Health and Safety Projects) Aesthetic view and Green • Damage to aesthetic Cover due construction works 98 | P a g e Activity Parameter Design Construction Operation Mitigation Stage phase Phase measures Possibly impacted are required or [Indicate [Indicate with [Indicate no [ ]Yes or with a a Check if with a [ ]No Check if impacted] Check if impacted] impacted] • Uprooting trees C. Historic building(s) Cultural Heritage • Project Located within or in the vicinity of any cultural heritage site • Potential impact on cultural heritage building due the construction works • Non-hazardous waste D. Toxic materials management • Workers OHS (Example: Paint ) • Hazardous waste • Management • Workers OHS B. Environmental and Social Screening Checklist for KGs and Health Care Centers Rehabilitation in Gaza Strip: 1. Has the site been directly shelled? Yes No If the answer is No, please continue to section B If the answer is Yes, please answering the following questions 1. What is the scale of Damage? Low Moderate Severe Please define the damage: 2. Have UNMASS screened the site? Yes No If the answer is Yes, Is the site clear from UXO? (Please attach UNMASS Assessment Report) 99 | P a g e Yes No If No, please identify the timeframe UNMASS will clear the site. No works shall be commenced prior clearing the site. Please approach UNMASS to conduct the UXO Assessment and include the UNMASS Assessment and Clearance Report 3. Does the site include uncleaned mixed rubble (mixed with equipment’s, vehicles, Batteries, PV cells, solid waste, e-waste, medical waste, wastewater? Yes No If Yes, please include UNMASS Report, and Ask Contractor to prepare Hazardous Waste Management Plan Environmental and Social Screening Checklist for KGs and Health Care Centers Rehabilitation in Gaza Strip: Please Copy the Input from the Screening Report Activity Parameter Design Construction Operation Mitigation phase phase Phase measures Possibly are impacted required or [Indicate [Indicate [Indicate no [ ]Yes with a with a Check with a or [ ]No Check if if impacted] Check if impacted] impacted] • Notification and Worker OHS • Community Health and Safety • Noise • Air Quality • Exposure to transmitted diseases including COVID-19 A. General Conditions • Community Exposure to GBV/SEA/SH • Exposure of facility personnel and students to GBV/SEA/SH • Universal Access • Material • Energy and Water Efficiency 100 | P a g e B General Rehabilitation and /or Construction Activities Excavation • Noise Works • Workers OHS • Air Quality • Solid Waste Generation • Water Quality • In-site Public Services • Exposure to transmitted diseases including COVID-19 • Community Exposure to GBV/SEA/SH • Exposure of facility personnel and students to GBV/SEA/SH Foundation • Noise Work • Workers OHS • Risk of accidents • Solid Waste Generation • Water Quality • Exposure to transmitted diseases including COVID-19 • Community Exposure to GBV/SEA/SH • Exposure of facility personnel and students to GBV/SEA/SH Construction • Noise Works (Concert, • Workers OHS Block • Risk of accidents • Solid Waste Generation • Water Quality • Exposure to transmitted diseases including COVID-19 • Community Exposure to GBV/SEA/SH • Exposure of facility personnel and 101 | P a g e students to GBV/SEA/SH External Works • Noise including Walls, • Workers OHS yards, retaining • Risk of accidents walls, • Air Quality playgrounds • Solid Waste pavement, gates, Generation boundary walls ) • Water Quality • In-site Public Services • Exposure to transmitted diseases including COVID-19 • Community Exposure to GBV/SEA/SH • Exposure of facility personnel and students to GBV/SEA/SH Mechanical • Noise Works • Workers OHS (Sanitation, • Risk of accidents Water) • Air Quality • Solid Waste Generation • Water Quality • In-site Public Services • Exposure to transmitted diseases including COVID-19 • Community Exposure to GBV/SEA/SH • Exposure of facility personnel and students to GBV/SEA/SH Electrical Works • Noise • Workers OHS • Risk of accidents • Solid Waste Generation • Water Quality In-site Public Services Exposure of facility personnel and students to GBV/SEA/SH 102 | P a g e Finishing Works • Noise • Workers OHS • Risk of accidents • Air Quality Painting works, • Solid Waste Carpentry works Generation Aluminum works • Exposure to transmitted diseases including COVID-19 • Community Exposure to GBV/SEA/SH • Exposure of facility personnel and students to GBV/SEA/SH Rehabilitation Works Damaged Solid waste Carpentry works Workers OHS GBV/SEA/SH Damage to Tile Solid waste (external, internal) Workers OHS Dust GBV/SEA/SH Damaged Glass Solid waste (windows) , Tempered glass Workers OHS (doors/internal GBV/SEA/SH walls) Damaged • Polluted Solid Sanitary waste Appliance • Water Quality • Workers OHS • GBV/SEA/SH Damaged • Solid waste Aesthetic/Green • Workers OHS Cover • GBV/SEA/SH Damaged Solar • Hazardous Waste PV System • Workers OHS • GBV/SEA/SH Furniture Supply Transportations of • Nuisance materials and equipment • Air Quality 103 | P a g e to the work site (For All • Health and Safety Projects) • GBV/SEA/SH Atheistic view and Green Damage to Cover aesthetic due construction works Uprooting trees C. Historic building(s) Cultural Heritage Project Located within or in the vicinity of any cultural heritage site Potential impact on cultural heritage building due the construction works • Hazardous waste D. Toxic materials • Management • Workers OHS (Example: Paint) E. GBV/SEA/SH Exposure • Community Exposure to GBV/SEA/SH • Exposure of facility personnel and students to GBV/SEA/SH C. Environmental and Social Screening For Equipment’s: Mitigation measures are required or no [ ]Yes or []No Does the requested Yes NO equipment require medical material to operate? Is there appropriate PPE’s to Yes NO operate Is there Trained worker to Yes NO operate the equipment’s Does the Equipment produce Yes NO hazardous or nonhazardous waste 104 | P a g e Does the requested Yes No If Yes, please refer to equipment require Section A or B dependent rehabilitation activities at the on the beneficiary facility location Part C: Mitigation measures 1. Environmental impacts mitigation measures checklist Activity Parameter Possibly Mitigation measures checklist impacted • The local construction and environment inspectorates and communities have been notified of upcoming activities. • The public has been notified of the works through appropriate notification in the media and/or at publicly accessible sites (including the site of the works). • All legally required permits have been acquired for construction and/or rehabilitation. Notification and • The Contractor formally agrees that all work will be carried out in a safe and A. General Worker disciplined manner designed to minimize impacts on neighboring residents Conditions and environment and to sign the related commitment letter. Safety • Workers PPE will comply with international good practice (always hardhats, as needed masks and safety glasses, harnesses, and safety boots) • Site is fully secured in compliance with OHS measures. • Occupational Health and Safety Plan (OHS) Plan, and Emergency Preparedness and Response Plan (EPR), and Waste Management Plan will be prepared, followed, and monitored. • Appropriate signposting of the sites will inform workers of key rules and regulations to follow. • Proper maintained and serviced vehicles • Traffic regulation signs and traffic calming measures • Shutting down equipment when it is not directly in use Noise • Postpone the working by high voice machinery and shakiness machinery until school classes finished (around 2:00 pm) and for MoH facilities coordination needs to be conducted with administration to ensure suitable working hours in low traffic periods B. General • Wastewater services (underground pipes and septic tanks) locations should Rehabilitation and Water quality be identified prior excavation works, appropriate control measures should /or Construction be taken to prevent spill. • During excavation and construction works, dust shall be suppressed by Activities ongoing water spraying and/or installing dust screen enclosure at site • Vehicles transferring material to be properly covered. • Avoid work during windy days Air quality • During interior installation installing dust screen enclosure at site Demolition debris shall be kept in controlled area and sprayed with water mist to reduce debris dust • The surrounding environment (side-walks, roads) shall be kept free of debris to minimize dust. 105 | P a g e Activity Parameter Possibly Mitigation measures checklist impacted • There will be no excessive idling of construction vehicles at sites • Contractor to prepare and implement waste management plan approved by the ESO. The plan to include handling, storage, transport and disposal to Solid waste landfill taking into consideration workers health and safety measures, and management measures to minimize exposure to COVID-19. • Proper stockpiling, haulage and disposal of non-hazardous, normal construction waste • Contractor will prepare non-hazardous and hazardous waste management plan, including handling, storage, disposal, and approvals requirements • Temporarily storage on site of all hazardous or toxic substances will be in Potential Toxic / safe containers labeled with details of composition, properties and handling C. Toxic materials hazardous waste information. (Example: Paint) • The containers of hazardous substances shall be placed in a leak-proof management container to prevent spillage and leaching • The wastes shall be transported by specially licensed carriers and disposed in a licensed facility. • Paints with toxic ingredients or lead-based paints will not be allowed. D. Transportations Noise • See Section B above in this table. of materials and equipment to the Air quality work site • See Section B above in this table. E. Aesthetic View Loss of Aesthetic • Proper design of landscaping for the area and around the school which may and Green Cover View include some plantation activities • Relocate uprooted trees in the vicinity of the school 2. Social impacts mitigation measures checklist Activity Parameter Possibly Mitigation measures checklist impacted • Contractor to prepare OHS plan to be approved by the ESO and implement works in compliance with the Occupational Health and Safety Plan (OHS) Plan, and Emergency Preparedness and Response Plan (EPR). • Workers commitment to OHS (vests, gloves, HD wearing apparel, helmet and others… E. General Workers OHS • Provide a first aid box close to the construction site Rehabilitation and • Provide sanitary lavatory for workers /or Construction • In case of sites with identified rubble, UNMAS has assessed that the site is clear from UXO. However, in case of potential sighting of UXO or weapon Activities remains or unidentified object during rehabilitation, the contractor shall immediately evacuate the workers from the site, secure the site and contact the PCU for further action. Sites shall not be open until cleared by UNMASS • Follow Ministry of Health (MOH) and WHO regulations related to compacting Workers and Covid-19. Community • Contractor to sign commitment letter aiming to follow the MOH and WHO Exposure guidelines. 106 | P a g e Activity Parameter Possibly Mitigation measures checklist impacted transmitted diseases to COVID-19 Land use criteria • Works will utilize vacant government land, occur within existing footprint, or F. Land follow right-of-way or easements Rehabilitation of classrooms will follow the footprint of the existing KGs. Avoid Use of private lands any use of land during construction, except of presence of legal document between contractor and owner to use the land for short time • Code of conduct to be developed and signed by the contractor. It should include prevention of sexual exploitation and abuse and sexual harassment G. Contractor staff (SEA/SH) and gender-based violence (GBV) at workplace. and workers • The project level GM will include specific procedures for GBV, SEA/SH Gender Based activities including confidential reporting and ethical documentation of GBV cases. Violence [GBV] • Contractors will establish a workers’ complaints system for workers and staff. Contractors to conduct an orientation session for their workforce on the grievance mechanism prior to the start of civil works. The grievance mechanism also addresses child labor, GBV and sexual harassment related grievances. • If works will be implemented in designated historical or cultural area, the MOE/MOH will get approval and design and construction requirements for from the Ministry of Antique. H. Historic Cultural Heritage • Measures to include restriction of use of heavy machinery and building(s) entry of large vehicles to the construction area. • Chance Find Provisions is included in the bidding document, where the Contractor shall implement those provisions of chance finds” in case of potential findings during excavation. • Provide valid licenses of the chemical transport company and the driver I. Toxic materials Public and workers • Submit Material Safety Data Sheets and chemical mixture data sheets to the safety/OHS Engineer for approval (Example: Paint) • Contractor will prepare non-hazardous and hazardous waste management plan, including handling, storage, disposal, and approvals requirements • Maintain and commitment to traffic signs, road markings, barriers and traffic J. Transportations control signals and such other measures as may be necessary for ensuring of materials and Public and workers traffic safety around the construction site. equipment to the safety • Ensuring that vehicles are loaded in such a manner as to prevent falling off or work site spilling of construction materials and by sheeting the sides and tops of all vehicles carrying mud, sand, other materials and debris • Blocking and isolating the working area 107 | P a g e Part D: Environmental and Social Monitoring Plan Potential Impact Mitigation Measures Operation/ Supervision Monitoring Responsibility Construction Phase Damage to existing ▪ Additional survey for potential sites Contractor Supervision Engineer ESO aboveground and underground ▪ Repair any damage occurs in coordination with the appropriate service provider public services (Water, ▪ Monitoring of site excavation Wastewater, electricity, etc.) Transportations of materials ▪ Ensuring that vehicles are loaded in such a manner as to prevent falling off or spilling Contractor Supervision Engineer Supervision and equipment to the work site of construction materials and by sheeting the sides and tops of all vehicles carrying Engineer/ESO construction materials and debris Dust generated by construction ▪ During excavation and construction works, dust shall be suppressed by ongoing water Contractor Supervision Engineer Supervision activities spraying and/or installing dust screen enclosure at site Engineer/ESO ▪ Vehicles transferring material to be properly covered. ▪ Avoid work during windy days ▪ During interior installation installing dust screen enclosure at site Demolition debris shall be kept in controlled area and sprayed with water mist to reduce debris dust ▪ The surrounding environment (sidewalks, roads) shall be kept free of debris to minimize dust. ▪ There will be no excessive idling of construction vehicles at sites Traffic congestion and increase ▪ Proper scheduling of any risky activities Contractor Supervision Engineer Supervision the risk of accidents ▪ Ensure placing proper traffic signs to ensure proper routing and distribution of traffic Engineer/ESO ▪ Closure of work site and limit access to verified personnel only Construction waste generated ▪ Clear site management plans and dumping at proper and approved sites Contractor Supervision Engineer Supervision and left in site Engineer/ESO Improper disposal of generated Ensure that the facilities are connected to either wastewater network and if not Contractor Supervision Engineer Supervision waste available to a septic tank that is regularly maintained Engineer/ESO 108 | P a g e Potential Impact Mitigation Measures Operation/ Supervision Monitoring Responsibility Noise generation during ▪ Construction management of working hours and respecting normal working hours Contractor Supervision Engineer Supervision construction activities ▪ Proper maintained and serviced vehicles Engineer/ESO ▪ Traffic regulation signs and traffic calming measures ▪ Shutting down equipment when it is not directly in use ▪ Postpone the working by high voice machinery and shakiness machinery until school classes finished (around 2:pm) Localized disturbance of ▪ Proper construction management and reshape the site conditions to its origin Contractor Supervision Engineer Supervision surrounding areas ▪ Check drivers' credentials Engineer/ESO ▪ Inform the community about GM ▪ Traffic plan, warning signs, protection of excavation sites, providing detours and Contractor Supervision Engineer Supervision Traffic increasing around the coordination with traffic department Engineer/ESO schools, localized disturbance ▪ Coordinate with the school administration to take appropriate measures of student of traffic and accidents risks safety ▪ Provide safe access and passages Loss of aesthetic due to Proper design of landscaping for the area and around the school which may include Contractor Supervision Engineer Supervision construction activities some plantation activities Engineer/ESO Potential uncovers and damage Follow “Chance Finds Procedures”/ Contractor Supervision Engineer Supervision of archaeological remains Engineer/ESO Land Use (Property Rights) Avoid any use of private land during construction, except of presence of legal document Contractor Supervision Engineer Supervision between contractor and citizen to use the land for short time Engineer/ESO Improper implementation of ▪ Contractor to prepare OHS plan to be approved by the ESO and Contractor Supervision Engineer Supervision Workers health and safety implement works in compliance with the Occupational Health and Safety Engineer/ESO Plan (OHS) Plan, and Emergency Preparedness and Response Plan (EPR). ▪ Workers commitment to OHS (vests, gloves, HD wearing apparel, helmet and others… ▪ Provide a first aid box close to the construction site ▪ Provide sanitary lavatory for workers 109 | P a g e Potential Impact Mitigation Measures Operation/ Supervision Monitoring Responsibility COVID-19 Guidelines ▪ The WHO regulated the guideline to protect and avoid any infection summarized Contractor, Supervision Engineer Supervision Engineer below: stay safe by taking some simple precautions, such as physical distancing, Administration, wearing a mask, keeping rooms well ventilated, avoiding crowds, cleaning your hands, MoE/MOH and coughing into a bent elbow or tissue. Potential risk on Pedestrians' ▪ Maintain and commitment to traffic signs, road markings, barriers and traffic control Contractor Supervision Engineer Supervision safety in the nearby area due signals and such other measures as may be necessary for ensuring traffic safety around Engineer/ESO machinery movement the construction site ▪ Blocking and isolating the working area Potential risk to Students and ▪ Install Canopy around the construction area, and close the site access, further to close Contractor Supervision Engineer Supervision teachers safety the footing works area from access Engineer/ESO ▪ Provide safe and healthy passages for them ▪ Provide safety measures for them (mask when needed) Use of Toxic and Hazardous ▪ Provide valid licenses of the chemical transport company and the driver Contractor Supervision Engineer Supervision Materials such as asphalt and ▪ Submit Material Safety Data Sheets and chemical mixture data sheets to the Engineer Engineer/ESO thermoplastic paint for approval ▪ Store and dispose of residual hazardous material by an experienced professional Generation of solid Waste ▪ Prepare a waste management measures prior to commencement of construction Contractor Supervision Engineer Supervision activities Engineer/ESO Operational Phase Building new schools/ classes ▪ Ensure appropriate traffic circulation and necessary steel guards on sidewalks School School MOE/MOT increase traffic ▪ Traffic signs to reduce the traffic (one-way sign) and traffic calming signs administration administration and ▪ GM and how complaints were resolved traffic police Improper disposal of generated ▪ Ensure proper connection to wastewater network and if septic tank is used, proper School School EQA wastewater disposal is maintained administration administration ▪ Inspect any improper collection/disposal Generation of solid Waste ▪ Waste management is properly maintained School School EQA administration administration ▪ Sustainability of the Project ▪ Ensure financial sustainability School School MOE administration administration 110 | P a g e Potential Impact Mitigation Measures Operation/ Supervision Monitoring Responsibility ▪ Failure to sustain safe and ▪ Ensure technical sustainability by proper training and capacity building of relevant good condition of the institutions subproject due to damage, ▪ Use and maintain checklists and monitoring tools to conduct frequent checks on misuse, and lack of subproject conditions maintenance 111 | P a g e Annex 7: Environmental and Social Management Guidelines for Contractors Purpose The purpose of these environmental and social management guidelines for contractors is to define minimum standards of construction practice acceptable to the MOE. General Specifications 1. These general environmental guidelines apply to any work to be undertaken under the ECD subprojects. The contractor shall comply with the approved ESMP. If the contractor fails to implement the approved ESMP, MOE reserves the right to arrange for execution of the missing action by a third party on account of the Contractor. 2. Notwithstanding the contractor’s obligation under the above clause, the contractor shall implement all measures necessary to avoid undesirable adverse environmental and social impacts wherever possible, restore work sites to acceptable standards. 3. These Environmental Guidelines, as well as ESMP, apply to contractor. They also apply to any sub-contractors present on project work sites at the request of the contractor with permission from the MOE. Movement of Trucks and Construction Machinery The contractor moving solid or liquid construction materials and waste shall take strict measures to avoid littering at roads by ensuring that vehicles are loaded in such a manner as to prevent falling off or spilling of construction materials and by sheeting the sides and tops of all vehicles carrying mud, sand, other materials, and debris. Traffic Safety Measures The contractor shall provide, erect, and maintain traffic signs, road markings, barriers and traffic control signals and other measures as may be necessary for ensuring traffic safety around the construction site. The contractor shall properly close the work site and ensure access of right personnel only. The contractor shall not commence any work that affects the public motor roads and highways until all traffic safety measures necessitated by the work are fully operational. Access-across Construction Site In carrying out the construction works, the contractor shall take all reasonable precautions to prevent or reduce any disturbance or inconvenience to the students and teachers in school if construction is to be made in operated schools, citizens of adjacent facilities, and to the public in general. The contractor shall install Canopy around the construction area, and close the site access, further, to close the footing works area from access. He shall maintain any existing right of way across the whole or part of the construction site and public and private access to adjoining frontages in a safe condition and to a standard not less than that pertaining at the commencement of the contract. If required, the contractor shall provide 112 | P a g e acceptable alternative means of passage or access to the satisfaction of the persons affected. Protection of the Existing Installations Contractors shall properly safeguard all existing installations from harm, disturbance or deterioration during the concession period. Contractors shall take all necessary measures required for the support and protection of all buildings, structures, pipes, cables, sewers and other apparatus during the concession period, and to repair any damage occurs in coordination with Municipality and concerned authorities. Noise and Dust Control Contractors shall take all practicable measures to minimize nuisance from dust and noise from the construction sites. This includes: • Respecting normal working hours for school when work is commenced within. • Maintaining equipment in a good working order to minimize extraneous noise from mechanical vibration, creaking and squeaking, as well as emissions or fumes from the machinery; • Shutting down equipment when it is not directly in use. Regarding Dust control, contractor is asked to provide a water tanker, and apply water spraying when required to minimize the impact of dust. Where work in areas dust might spread to existing classrooms or neighboring facilities, additional to spraying, proper isolation of the work area is mandatory. Waste Disposal Contractors must agree with the municipality about arrangements for construction waste disposal. The municipality shall designate a dumping site or landfill for the disposal of solid waste. Disposal of residues in right of way or nearby land is prohibited. Protection of Trees and Other Vegetation Contractors shall avoid loss of trees and damage to other vegetation wherever possible. Adverse effects on green cover within or in the vicinity of the construction site shall be minimized. Clearance of Rehabilitation Site on Completion Contractors shall clear up all working areas both within and outside the work site and accesses as work proceeds and when no longer required for the carrying out of the construction works. All surplus soil and materials, sheds, offices and temporary fencing shall be removed, post holes filled and the surface of the ground restored to its original condition. 113 | P a g e Site Construction Safety and Insurance Further to enforcing the compliance of environmental and social management, contractors are responsible on providing insurance for construction labors, staff attending to the construction site, citizens for each subproject, the insurance requirements and clauses are stated in the bidding documents complying to the labor law. Labor and Working Conditions Contractors responsible for the construction work should prepare their labor management procedure, in compliance with the labor management procedure prepared by MOE and MOH before the initiation of the construction work. LMP promotes health and safety at work, fair treatment, non-discrimination, and equal opportunity of project workers, protects project workers, prevent the use of all forms of forced labor and child labor, support the project workers (direct and contracted) in a manner consistent with national law and ESS2, and provide project workers with accessible means to raise workplace concerns. Contractor’s Environment, Social, Health, and Safety Management Plan (ESHS-MP) Contractors shall prepare an ESHS-MP to ensure the adequate management of the environmental and social aspects of the works, health and safety in addition to LMP as indicated above. Contractor’s ESHS-MP shall provide description of procedures and methods for complying with LMP. Contractor’s ESHS-MP will be reviewed and approved by MOE before start of the works. COVID-19 Guidelines The WHO regulated the guideline to protect and avoid any infection summarized below: stay safe by taking some simple precautions, such as physical distancing, wearing a mask, keeping rooms well ventilated, avoiding crowds, cleaning your hands, and coughing into a bent elbow or tissue. Management of (hazardous and nonhazardous) Waste The contractor to prepare Waste Management Plan (hazardous and nonhazardous). Also, provide valid licenses of the chemical transport company and the driver. In addition to Submit Material Safety Data Sheets and chemical mixture data sheets to the Engineer for approval. Moreover, Store and dispose of residual hazardous material by an experienced professional. ESMP, ESHS-MP, and LMP Reporting Contractors shall prepare monthly progress reports to MOE on compliance with general specifications, the project ESMP, LMP, and his own ESHS-MP. Contractors’ reports will include information ESHS management actions/measures taken and problems encountered in relation to HSE aspects (incidents, including delays, cost consequences, injuries, remedial actions, etc. Details of ESHS performance will be reported to MOE. Training of Contractor’s Personnel 114 | P a g e Contractors shall provide sufficient training to his own personnel to ensure that they are all aware of the relevant aspects of these general conditions, any project ESMP, and his own HSE-MP, and are able to fulfill their expected roles and functions. Specific training will be provided to those Employees that have particular responsibilities associated with the implementation of the HSE-MP. Training activities will be documented for review by MOE. Other Requirements Other requirements that contractors shall consider include: community relations and the acceptable behavior expected from Contractor staff and labor, location of contractor’s office if any to ensure the privacy of residences, and existence of a grievance mechanism for conflicts among the labors and with the community. 115 | P a g e Annex 8: Contractor’s Commitment of Environmental and Social Compliance and Penalties [Contractor’s name and address on letterhead] I hereby acknowledge that I have read and understood the requirements of the ESMP attached to the Bidding Document. Furthermore I acknowledge that any costs for meeting the conditions and requirements of the ESMP or other requirements expressed in the Bill of Quantities are included in the Bid Price. If awarded the Contract, I will appoint Mr. --------------------------------- to ensure that Environmental and social conditions are met and complied with and to receive all environmental and social notes on behalf of contractor. Signed -------------------------------- Date: ------------------------------- Contractor Name: --------------------------------- 116 | P a g e Annex 9: Duties and Responsibilities of MOE throughout Project Cycle D.G of General Education Identification of subprojects by ESO Classification and assessment according to ESMF Preparation Phase ESO Identification of Risks and Impacts High Risk, Substantial Risk Moderate, Low No Risk ESO/Consultant ESO No Further Action ESIA ESMP ESO Implementation Phase ESMP Monitoring Field Checks Compliance and Reports Chart 3: Duties and Responsibilities of MOE throughout Project Cycle 117 | P a g e Annex 10: Form for Environmental and Social Management and Monitoring a. Site Visit Report Project Location: …………………………..… Project Name:…………………………...... Date:……………………………………... Mitigation # Impact to check Yes No Remarks measure/s carried out 1 Damage to existing public services 2 Noise/alarm generation 3 Dust spreading out 4 Odor emission 5 Traffic problems (hindering, detours, closure …etc.) 6 Solid Waste Services problems 7 Sewerage Services problems 8 Student and pedestrians' safety endangered 9 Stagnant water pools 10 Landscape / aesthetic element/s deteriorated 11 Natural Resources negatively affected 12 Biodiversity & Wildlife threatened 13 Heritage and archaeological sites negatively affected 14 Workers safety and health considered 15 Workers commitment to OHS (vests, gloves, etc.) 16 Working machines suitability Do Equipment / machinery produce radiation? Emissions? 17 Presence of Toxic and Hazardous materials 118 | P a g e Project Location: …………………………..… Project Name:…………………………...... Date:……………………………………... Mitigation # Impact to check Yes No Remarks measure/s carried out Documentation of 18 community concerns/complaints 19 Presence of UXO materialize Existing Rubble (hazardous and 20 nonhazardous) If the rubble includes 21 hazardous material Is the shared glass scattered 22 around the location? What is the size of destruction 23 of the location? Are the doors 24 (Internal/External) destroyed? Are the tiles (Internal/External) 25 destroyed? Is the location containing any 26 destroyed asbestos or sekourite? What is the decree of 27 bathroom destruction? What is the work nature 28 needed for the bathroom? Is the location containing a 29 destroyed tree? Is the location containing a 30 destroyed solar panel? 119 | P a g e Project Location: …………………………..… Project Name:…………………………...... Date:……………………………………... Mitigation # Impact to check Yes No Remarks measure/s carried out 22. Comments: …………………………………………………………………………………………………………………………………………… ……………………………………………………………………………………………………………………………………… 23. Recommendations: ……………………………………………………………………………………………………………………….……………….. ………………………………………………………………………………………………………………………………………… Environmental and Social Officer (ESO) Signature …………………………………………………………. Date…………………………………………….. 120 | P a g e b. Suggested Environmental and Social Monthly/Quarterly Monitoring Report Template (For Consultants and Internal Reporting) No. Key Environmental Implementation Status of Corrective actions Environmental and Social and monitoring compliance needed/Penalties and social issues mitigation of ESMP measure taken Complaints received ……………………………………………………………………………………………………………………………………………… ……………………………………………………….. Status of complaints ……………………………………………………………………………………………………………………………………………… ……………………………………………………….. 22. Comments: ……………………………………………………………………………………………………………………………………………… ……………………………………………………….. 23. Recommendations: ……………………………………………………………………………………………………………………….…………………… ………………………………… Environmental and Social Officer (ESO) Signature ……………………………………… Date……………………………………… 121 | P a g e Annex 5: Grievance Mechanism Checklist Project Location: …………………………..… Project Name:…………………………...... Date:……………………………………... Type of managed Grievances in a timely # Impact to check Yes No Remarks manner ( Yes/No) 1 System issues Does the project invite grievance feedback? Does the grievance mechanism have clarity, procedures, system for keeping complaints and recording feedback, and system for protecting confidentiality? 2 Staff management Is there a grievance manual for workers? Do the grievance procedures provide guidance on grievance feedback, and remedies? Are adequate resources allocated for the grievance mechanism to function effectively? Does MOE provide training on grievance management to staff? Communication to grievance 3 mechanism users How users submit grievance feedback? 4 Feedback/grievance recording Are all feedback/grievances recorded? 5 Business standards Are there business standards in place for the process and timing with which grievances/feedback are dealt with? Is there a quality control system? Remarks and Recommendations 122 | P a g e Annex 12: Brief Overview of Labor Legislation: Terms and Conditions Two major legislations in Palestine govern the rights of the labors and the terms and conditions of the employment are: the Palestinian Labor Law no (7) of (2000) and the Council of Ministers Act 11, 2012 regarding the minimum wage. The Labor Law no (7) and the Council of Ministers Act 11, 2012 provide the basic conditions of employment with a view of improving the status of employees in Palestine. The Palestinian Labor Law explains the working hours, wages, leaves, the reward of work end, work contracts etc. The Council of Ministers Act 11, 2012 deals specifically with the minimum wages in the Palestinian National Authority’s locations and basic terms and conditions of employment. Many laws, resolutions, and ministerial instructions and decisions have addressed, inter alia, issues of occupational safety and health, and suitability of the working conditions. The Palestinian Labor Law No. 7 of 2000 guarantees workers' rights to occupational safety and health at workplace and regulate inspection of work conditions by the competent authorities, and other areas, as follows: Occupational Health and Safety Regulations Articles No. 90, 91, and 92 of the law provided that, the cabinet shall issue the regulations governing the occupational safety and health and work environment. Such regulations shall in particular provide for personal protection and prevention methods for workers from the work hazards and occupational diseases; the necessary health conditions in workplaces; first medical aid means at the establishment; and routine medical examinations of workers. The law also prohibits cutting any expenses or deductions from the workers’ wages in return for the provision of occupational safety and health requirements at the workplace. Following the Labor Law, several resolutions and ministerial instructions were issued detailing health conditions and standards related to occupational safety at different workplaces. These include: • The ministerial decrees No. 15, 17, and 21 of 2003 concerning health conditions and standards at workplaces, medical assistance procedures at the workplace, and safety standards at companies. • The Decision of the Council of Ministers No. (49) of 2004 concerning the preventive list of work hazards and career diseases and work accidents. • Instructions by the Minister of Labor no. (1) of 2005 concerning the precautions to protect workers in construction sites. • Instructions by the Minister of Labor no. 2-6 of 2005, defining the range of chemical exposure limits and standards, exposure to ionizing radiation, noise, and safe levels of brightness of light and temperature at the workplaces. In addition to the Palestinian laws and regulations, the World Bank Group’s Environmental Health and Safety Guidelines (EHSGs) also ensure that occupational safety and health requirements at the workplace are respected. 0. COVID-19 CONSIDERATIONS The Project will employ workers/labors for civil works. Specific provisions are listed below: 123 | P a g e Construction/Civil Works if applicable. The contractors will ensure adequate precautions are in place to prevent or minimize an outbreak of COVID-19, and provisions when a worker gets sick. This will include: • Confirming workers are fit for work, to include temperature testing and refusing entry to sick workers. • Considering ways to minimize entry/exit to site or the workplace and limiting contact between workers and the community/general public. • Training workers on hygiene and other preventative measures and implementing a communication strategy for regular updates on COVID-19 related issues and the status of affected workers. • Treatment of workers who are or should be self-isolating and/or are displaying symptoms • Assessing risks to continuity of supplies of medicine, water, fuel, food and PPE, taking into account international, national and local supply chains. • Adjustments to work practices, to reduce the number of workers and increase social distancing • Establishing a procedure to follow if a worker becomes sick (following MoH and WHO guidelines). 124 | P a g e ‫)‪Annex 13:The Code of Conduct (Arabic‬‬ ‫‪The Code of Conduct will be prepared for workers to indicate that they have:‬‬ ‫;‪• received a copy of the code‬‬ ‫;‪• had the code explained/oriented to them‬‬ ‫;‪• acknowledged that adherence to this Code of Conduct is a condition of employment‬‬ ‫‪and‬‬ ‫‪• understood that violations of the Code can result in serious consequences, up to and‬‬ ‫‪including dismissal, or referral to legal authorities.‬‬ ‫‪Code of Conduct: will be prepared and used for all sub-activities. The COC will be dealt with‬‬ ‫‪as the following:‬‬ ‫‪The below Code of Conduct is an example and can be edited to be appropriate with the nature‬‬ ‫‪of the sub-project activities and location.‬‬ ‫مدونة قواعد السلوك واخالقيات العمل‬ ‫مقدمة‬ ‫يأتي ااالهتمام بمواثيق سلوك وأخالقيات العمل والتشغيل كأحد مداخل تطوير االداء للعاملين واصحاب العمل‪.‬‬ ‫إن إعداد مدونة قواعد السلوك وأخالقيات العمل من شأنه تعزيز قيم والممارسات االيجابية في العمل ‪،‬‬ ‫وتعد مدونة السلوك إطارا ً عاما ً يجب على العاملين في المشروع التقيد به والعمل بمقتضاه‪ ،‬فهي مدونة تلقي‬ ‫الضوء على المعايير و االخالق والقيم التي يجب أن يتحلى بها العامل أثناء أداء واجباته‪ ،‬ومن ثم فهي قواعد‬ ‫ستسهم على نحو فاعل في االرتقاء بمستوى جودة االداء واالرتقاء به‪ .‬إن هذه المدونة تشكل جزءاً من‬ ‫مقتضيات العمل في المشروع بالتركيز على اجراءات الوقاية والسالمة والصحة العامة المتعلقة بكوفيد ‪،19‬‬ ‫ويجب تطبيقها في كل اوقات العمل وطوال فترة التشغيل‪ ،‬وسوف يتم تزويد كل عامل بنسخة منها‪ ،‬ليقرأها‬ ‫ويعمل بموجبها‪.‬‬ ‫أوال‪ :‬المبادئ االساسية لمدونة السلوك واخالقيات العمل‬ ‫إن جودة االداء ونجاح العمل تتوقف على االلتزام بقواعد السوك العامة واخالقيات العمل‪ ،‬والتصرف بطريقة‬ ‫عادلة وصادقة كأفراد مسئولين اجتماعيا انطالقا من ايماننا الراسخ بمسؤوليتنا االجتماعية التي لها أثرا‬ ‫إيجابيا كبيرا على المشاريع التي نعمل بها ‪.‬ولتحقيق هذا‪ ،‬يجب علينا احترام هذه المبادئ االساسية‪:‬‬ ‫النزاهة واالمانة ‪ :‬إاليمان بتعزيز التصرف بأمانة في جميع العالقات مع التقيد الصارم بجميع القوانين‬ ‫المعمول بها ‪ ،‬احترام كرامة كل شخص والحفاظ على سالمتهم ‪.‬‬ ‫الشفافية‪ :‬االحترام المتبادل والحوار والشفافية هي أساس العالقة مع اصحاب العمل والسلطات ذات العالقة‬ ‫‪ ،‬والتي تتوافق مع مبادئ التعاون والصدق وااالنفتاح‪.‬‬ ‫الموضوعية واإالستقاللية ‪ :‬العمل بموضوعية واستقاللية وتجنب أي نوع من أنواع الفساد أو تضارب‬ ‫المصالح الذي قد يؤثر على اتخاذ القرارات المتعلقة بالعمل‪.‬‬ ‫المسؤولية‪ :‬توفير بيئة عمل آمنة وصحية للعمال ‪ ،‬واحترام الحقوق والتقيد بالواجبات من مقتضى المسؤولية‬ ‫‪ ،‬واحترام المجتمعات التي نعمل فيها‪.‬‬ ‫‪125 | P a g e‬‬ ‫ثانيا‪ :‬قواعد السلوك واخالقيات العمل‬ ‫القسم االول ‪ :‬الحقوق العامة‬ ‫يلتزم العامل بتأدية عمله بإخالص وأمانة وبالمحافظة علي أسرار العمل وأدواته‪ ،‬ويعتبر مسؤوال عن االدوات‬ ‫▪‬ ‫التي في عهدته وعليه الحفاظ عليها‪ ،‬وفي حالة وجود ظرف خارج عن ارادته او قوة قاهرة‪ ،‬فان العامل ال‬ ‫يعتبر مسؤوالً عن خلل األدوات أو ضياعها‪.‬‬ ‫على العامل أن يلتزم بأخالقيات العمل والحفاظ على خصوصية السكان والعمال في منطقة العمل‪ ،‬دون‬ ‫▪‬ ‫االشتباك معهم أو التسبب بأي أذى لهم بأي شكل كان‪ .‬ويجب االمتناع عن المشاركة في أي عنف بدني او‬ ‫لفظي ألي من العاملين أو السكان‪.‬‬ ‫على العامل التقيد بساعات العمل المطلوبة‪ ،‬وكذلك التقيد واالمتثال بالمهام المكلف بها‪.‬‬ ‫▪‬ ‫على العامل اإللتزام بإجراءات السالمة المتبعة في الموقع‪ ،‬خاصة عند استخدام األالت الخطرة‪ ،‬وأي إجراءات‬ ‫▪‬ ‫إضافية يتم طلبها من قبل المقاول أو الوزارة‪.‬‬ ‫يجب على العامل اإلبالغ فورا عن أي أمراض مزمنة يعاني منها أو عند الشعور باإلعياء‪ ،‬وعن أي عقاقير‬ ‫▪‬ ‫يتلقاها العامل‪.‬‬ ‫اإلمتناع عن التسبب بأي نوع من المضايقات سواء اللفظية المباشرة او غير المباشرة ألي شخص أثناء فترة‬ ‫▪‬ ‫العمل‪ ،‬وخاصة من فئة النساء واألطفال وذوي االحتياجات الخاصة‪.‬‬ ‫من حق العامل أن يوقع عقد عمل مع صاحب العمل علي أن يكون باللغة العربية‪ ،‬وذلك لحفظ حقوق العامل‬ ‫▪‬ ‫‪ ،‬علما ً بأن عقد العمل يجب أن يتضمن ‪ :‬األجر‪ ،‬نوع العمل‪ ،‬مكانه ومدته‪ ،‬ساعات وأوقات العمل‪ ،‬كما ويجب‬ ‫ان يتضمن العقد االجراءات الصحية وشروط الوقاية المتعلقة ب كوفيد ‪ ،19‬والتي اقرتها وزارة الصحة‬ ‫الفلسطينية‪ ،‬و يجب أن يوقع العقد من قبل صاحب العمل والعامل بحيث يحتفظ العامل بنسخة أصلية من العقد‪.‬‬ ‫علي صاحب العمل أن يلتزم بالتامين على جميع عماله عن إصابات العمل لدي الجهات المرخصة في فلسطين‪.‬‬ ‫▪‬ ‫يجب أن تتخلل ساعات العمل اليومي فترة أو أكثر لراحة العامل ال تزيد في مجموعها عن ساعة مع مراعاة‬ ‫▪‬ ‫أال يعمل العامل أكثر من خمس ساعات متصلة دون تخصيص وقت للراحة‪.‬‬ ‫التقيد بأوقات العمل وتكريس اوقات العمل للقيام بالمهام والواجبات المتعلقة بطبيعة العقد ‪ ،‬كما نص عليها‬ ‫▪‬ ‫عقد العمل‪.‬‬ ‫ضمان حق العامل في التظلم او الشكوى من اي انتهاك لحقه او من اتخاذ قرار خاطيء بحقه‪.‬‬ ‫▪‬ ‫القسم الثاني‪ :‬حماية حقوق النساء‬ ‫معاملة النساء باحترام بغض النظر عن العرق أو اللون أو اللغة أو الدين أو الرأي السياسي أو غير السياسي‬ ‫▪‬ ‫أو األصل او اإلعاقة او أي وضع آخر‪.‬‬ ‫عندما يكون لدى المرأة العاملة مخاوف أو شكوك فيما يتعلق بأعمال العنف القائم على النوع االجتماعي من‬ ‫▪‬ ‫قبل اصحاب العمل او اي طرف ذو عالقة بالعمل‪ ،‬يجب عليها اإلبالغ عن هذه المخاوف وفقًا إلجراءات‬ ‫الشكاوى المعتمدة في المشروع‪ .‬على ان يتم التعامل مع هذه الشكاوي بخصوصية كبيرة للحفاظ على كرامة‬ ‫المشتكية‪.‬‬ ‫يجب توفير الحماية للنساء وتهيئة أماكن امنة في العمل للنساء وخاصة الحوامل والتاكد من عدم نقل أي‬ ‫▪‬ ‫امرأة حامل بشكل غير صحيح ‪ ،‬والعمل على ازالة او منع تعرض النساء الحوامل للمخاطر‪.‬‬ ‫يجب توفير أماكن للنظافة الشخصية الستخدامها من قبل النساء العامالت بعد االنتهاء من العمل‪ .‬وايضا توفير‬ ‫▪‬ ‫مرافق صحية ( دورات مياه) خاصة بالنساء في اماكن العمل‪ ،‬ويجب أن يتم تعقيم هذه األماكن بشكل يومي‪.‬‬ ‫يجب تنفيذ لقاءات توجيهية قبل بدء العمل في الموقع للتأكد من أن الجميع على دراية بقواعد السلوك الخاصة‬ ‫▪‬ ‫بالعنف القائم على النوع االجتماعي‪.‬‬ ‫‪126 | P a g e‬‬ ‫القسم الثالث ‪ :‬حماية حقوق ذوي االعاقات‬ ‫يلتزم اصحاب العمل بتهيئة البيئة المالئمة الحتياجات ذوي االحتياجات الخاصة وتوفير تسهيالت الحركة‬ ‫▪‬ ‫والتنقل في اماكن العمل‪.‬‬ ‫عدم التمييز بحق المعاقين والمعاقات في العمل‪ ،‬واحترام حقهم ‪ /‬هن في اختيار نوعية االعمال التي تناسب‬ ‫▪‬ ‫قدراتهم ‪/‬تهن ‪ ،‬واهتماماتهم‪/‬هن واحتياجاتهم‪/‬هن‪.‬‬ ‫االلتزام بتوفير خدمات ومرافق صحية مواءمة الستخدامات ذوي االعاقة الحركية في مواقع العمل‪.‬‬ ‫▪‬ ‫القسم الرابع ‪ :‬الصحة والسالمة المهنية‬ ‫على العامل التقيد بتطبيق شروط واجراءات الصحة والسالمة العامة الصادرة عن وزارة الصحة الفلسطينية‬ ‫▪‬ ‫‪ ،‬وااللتزام بقواعد السالمة والصحة المهنية في العمل‪.‬‬ ‫على صاحب العمل تقديم اإلسعافات األولية الالزمة للعامل في حال االصابة ونقله إلي اقرب مركز للعالج‪.‬‬ ‫▪‬ ‫اإللتزام باجراءات ومتطلبات السالمة والصحة العامة المتعلقة بكوفيد ‪ 19‬بما فيها التباعد الجسدي واللبس‬ ‫▪‬ ‫الواقي وكل ما ينص عليه البروتوكول الصحي‪.‬‬ ‫‪127 | P a g e‬‬ Annex 14: Environmental and Social capacity Assessment of MOE This Annex presents the assessment that was conducted to assess the capacity of the MOE staff (especially the Directorate General of Buildings) to implement the ESMF of this project and to determine their capacity building needs. The main points presented in this assessment are: • Current D.G. of Buildings Main Tasks • Current Structure of D.G. of Buildings • Environmental and Social Capacity Assessment • Capacity Risk Assessment • Capacity Assessment Results • Required Capacity Building The main tasks of D.G. of Buildings are: • Implementation of the general policy of the Ministry and the planning and construction of school and administrative buildings and other educational projects. • Working to provide the requirements of the educational policy in cooperation and coordination with the concerned authorities inside and outside the ministry. • Representing the Ministry in communicating and negotiating with donor countries regarding school building projects, and continuing research to obtain funding for the implementation of projects for school and educational buildings. • Participate in the assessment and identification of the needs and priorities of the school buildings, and the preparation of specifications and standards that are adapted to the requirements of the Ministry and in line with the global policies in education. Current Structure of D.G. of Buildings D.G. of Buildings have 17 Engineers at the Headquarter office in Ramallah and 2 Engineers in each Governorate of the West Bank. D.G. of Buildings comprises of three departments and subsections under each department (depicted in Chart 1) as follows: • Department of Design and Engineering Supervision o Engineering Design Section o Supervision and follow-up Section o Documents and Contracts Section o Measurements Section • Department of School Building Services o Follow-up directorates Section o Maintenance Section 128 | P a g e o Land and Acquisition Section • Department of Engineering Studies o Projects Preparation Section o Engineering Studies and Planning Section D.G. of Buildings Southern Governorates General Director Northern Governorates Department of Design and Department of School Department of Engineering Supervision Building Services Engineering Studies • Engineering Design Section • Follow-up directorates • Department of • Supervision and follow-up Section Engineering Studies Section • Maintenance Section • Projects Preparation • Documents and Contracts • Land and Acquisition Section Section Section • Engineering Studies • Measurements Section and Planning Section Land acquisition and licensing Dept. Chart 4: Institutional Structure of D.G. of Building Environmental and Social Capacity Assessment According to the mandate and main tasks mentioned above, D.G. of Buildings is not responsible for construction/rehabilitation activities of projects. However it is responsible for preparation of project bidding documents and project management including monitoring and supervision. Project technical designs, preparation of specs, and BOQs are prepared by outsourcing external engineering firm/office registered and accredited by the Engineering Association. The D.G. of buildings will be responsible for monitoring and supervision of the subproject in coordination with the ESO to monitor ES issues. While the external engineering firm/office, in addition to the design and preparation of subproject document, will be responsible for implementation of the ESMP of the ECD subprojects. To this end, assessment of the organizational structure and capacity of D.G. of buildings is carried out to determine the capacity building needed to ensure that the MOE has the staff, skills, equipment and system to manage and supervise the ESMF and ESMP and the needs to strengthen its capacity. The criteria for assessment are as follow: 129 | P a g e • Presence of full-time engineer to daily supervise the subproject, with the experience to follow up one environmental and social considerations and coordinate with the PCU’s ESO; • Presence of a supervision engineer for each subproject sector, with the experience in managing projects environmentally and socially; • Presence of a dedicated safety engineer who monitors environmental impacts; • Presence of functioning and documented system to screen subprojects for environmental impact assessment, according to WB or EQA criteria; • Presence of a written Occupational Safety and Health (OSH) policy for its staff; • Presence of a functioning and documented system to keep track of site visits during construction; • Presence of a clause, or clauses, which provide legally binding environmental management guidelines in subprojects; and • Presence of a complaints’ mechanism, which is well-known to all citizens. Capacity Risk Assessment Table (4) depicts the capacity risk assessment of D.G. of Buildings/MOE to manage the environmental and social risks and impacts. Table 8: Capacity Risk Analysis Stage Issue Mitigation Presence of ES There is no ES staff present 1. ESO has been appointed in October 2020 at staff in D.G. of buildings the PCU in the MOE 2. Hiring ESC in Gaza in addition to capacity building of technical Team in Gaza to implement the E&S requirements. 3. ESC to train the designated staff in Gaza Environmental D.G. of Buildings has no 1. ESO have had on-job training on E&S risk and Social previous experience in classification and screening. More training is Classification conducting environmental required. Assessment and social classification 2. Provide the ESO and EHSO with adequate training on the ESF and E&S risk classification and screening. 3. ESC to provide training for the Gaza team on ES screening and risk identification ESMP D.G. of Buildings is to Train the ESO and PCU team in West Bank and Gaza preparation introduce site specific impacts, mitigation into the site-specific ESMP’s, in 130 | P a g e Stage Issue Mitigation addition to ensure inserting ESMP, compliance annexes into bidding document Environmental Potential noncompliance of Penalties will be imposed on contractor. and social contractor to ESMP management guidance during In cases where complaints raised to MOE regarding construction, contractor contractor noncompliance, auditing revealed engineer is not considering noncompliance environmental management during construction. Presence of unsolved complaints Presence of D.G. of Buildings didn’t have Implement the OHS Manual for the Project OHS enough experience in implementation conducting directly OHS. Capacity Assessment Results The assessment revealed that there is neither environmental specialist nor ESMS are present to implement the ESMF and ESMP. MOE has appointed full time ESO in October 2020, the ESO to assist the PCU carrying out the day-to-day activities in relation to the ECD project cycle. MoH EHSO has been assigned to the coordinate with the ESO in July 2021. The duties and responsibility of ESO are: • Carry out classification for all ECD’s proposed projects and define the environmental and social risk assessment; • Review and assess the environmental and social feasibility of the proposed subprojects; • Support in designing ESMP for proposed subprojects, where needed and make the necessary reviews; • Carry out supervision and monitoring activities during project implementation; • Hold field visits to projects sites to ensure compliance with the environmental and social safeguard procedures; • Liaise with key stakeholders and contractors; • Liaise with the appropriate officials from the Department of Antiquities at the MoTA where needed. 131 | P a g e The PCU hired an E&S Consultant (ESC) in August 2021, the ESC will be responsible for implementation of the project’s environmental and social requirements according to the ESCP including supervision of the implementation of the updated ESMF and monitoring the compliance of suppliers/contractors to the provisions of the ESMPs; implementation of the updated SEP and updated LMP for the project activities implemented by Ministry of Education, Ministry of Health and Ministry of Social Development in the Gaza Strip; and, building the capacity of designated team members to implement the E&S measures. For MOH activities at Gaza Strip, the ESC will conduct the E&S screening, prepare the ESMP checklist for low risk projects, conduct site-specific consultation, and will coordinate with the MOH EHSO in West Bank for the Bank approvals where needed. Once implementation commences, the ESC will monitor the compliance with the E&S requirements and report to the PCU/MOE and MOH/EHSO. MOH/EHSO will be responsible for GM on MOH component in Gaza. Required Capacity Building The ESO officer is to attend capacity building programs that will ensue gaining sound knowledge in the World Bank ESF, as well as supporting MOE in their efforts to comply with these procedures. The proposed training and capacity building for the ESO at the MOE and the EHSO at the MOH shall cover the following topics: • Stakeholder mapping and engagement • Environmental and social assessment • Environmental and Social Management Plan • Environmental and social monitoring and reporting • Emergency preparedness and response • Community health and safety. The D.G. of Buildings will liaise with contractors to ensure identification of the ESMF and ESMP within the pre-bid meeting. The following table shows proposed seminars/workshops that seen to be held for the different target groups during the project implementation stages. Proposed Workshops/Seminars for Target Groups Target Group Workshop/ Seminars By Whom Notes Beneficiaries ▪ An orientation session on ESO and contractor liability, health and Stakeholders safety measures, ESMP ▪ A training on complaints mechanism 132 | P a g e Target Group Workshop/ Seminars By Whom Notes A seminar concerning: ESO As part of ▪ The use of the mitigation form and implementation Contractors environmental and social stage preparation in guidelines. project pre-bid ▪ The implementation of mitigation meeting measures. 133 | P a g e Annex 15: ESMF Compliance Forms and Penalties Deduction Methodology for National Competitive Bids and Shopping Bids Table 15.1 : Form of the environmental/social note Environmental and Social Note No ( ) MOE Date Project Name Site Location Contractor The Environmental Note ESO/Supervisor Engineer Contractor Representative on time of note Submitted to Contractor Representative Hour Date Procedures for National Competitive Bids and Shopping Bidding Documents: Environmental and social notes might contain one or more environmental penalty applicable for deduction. ▪ For social notes: stop and alert the contractor to remedy the action; ▪ For environmental notes: refer to the ESMP for the note to verify how many notes illustrated in the note; ▪ Deduction rate starts with 0.1% of contract value; and ▪ Deduction rate increase by 0.05% of the contract amount after each fifth note. 134 | P a g e For National Competitive Bids: Table 15.2 : ESMF Compliance Penalty for National Competitive Bids ESMF Compliance Penalty Environmental and No. Penalty Social Note 1 1 Stop and alert Stop and deduct 0.1% of the contract amount for each 2 2+3+4+5+6 mitigation measure in the environmental note. Minimum amount of deduction is 180 $. Stop and deduct 0.15% of the contract amount for each 3 7+8+9+10+11+12 mitigation measure in the environmental note Minimum amount of deduction is 270 $. Each 5 notes + deduction would be: N= percentage of deduction of (N-1) + (0.5* percentage of deduction of (N-1)) 3+1 Next five notes For example: Stop /Deduct 0.1%+0.05(0.1%) of the contract amount for each mitigation measure in the environmental note. Minimum amount of deduction is 360 $. If penalty rate approach 5% of contract cost it is 5 Note +1 recommended to stop work and take action according to bidding documents. Deduction is to be calculated by ESO who is to consider the environmental Note (N), and the deduction for N. Deduction for N= [percentage of deduction of (N-1) + (0.5* percentage of deduction of (N- 1)]* contract Amount. If Penalties Rate approach 5% of Contract cost its recommended to stop work and take action according to bidding documents. Municipality can decide if a mitigation measure has a significant impact and might municipality require setting its noncompliance penalty rate based on its significance. For Shopping Bidding Documents: ▪ For social notes: stop and alert the contractor to remedy the action; ▪ For environmental notes: refer to the ESMP for the note to verify how many notes illustrated in the note; ▪ Deduction rate starts with 0.1% of contract value; and ▪ Deduction rate increase by 0.05% of the contract amount after each fifth note. 135 | P a g e Table 15.3: ESMF Compliance Penalty for Shopping Bidding Documents ESMF Compliance Penalty Environmental and No. Penalty Social Note 1 1 Stop and alert Stop and deduct 0.1% of the contract amount for each 2 2+3+4+5+6 mitigation measure in the environmental note. Minimum amount of deduction is 48 $. Stop and deduct 0.15% of the contract amount for each 3 7+8+9+10+11+12 mitigation measure in the environmental note Minimum amount of deduction is 72 $. Each 5 notes + deduction would be: N= percentage of deduction of (N-1) + (0.5* percentage of deduction of (N-1)) 3+1 Next five notes For example: Stop /Deduct 0.1%+0.05(0.1%) of the contract amount for each mitigation measure in the environmental note. Minimum amount of deduction is 96 $. If penalty rate approach 3% of contract cost it is 5 Note +1 recommended to stop work and take action according to bidding documents. Deduction is to be calculated by ESO who is to consider the environmental Note (N), and the deduction for N. Deduction for N= [percentage of deduction of (N-1) + (0.5* percentage of deduction of (N-1)] * contract Amount. If Penalties Rate approach 3% of Contract cost its recommended to stop work and take action according to bidding documents. ESO can decide if a mitigation measure has a significant impact and might MOE require setting its noncompliance penalty rate based on its significance. 136 | P a g e