THE GOVERNMENT OF VIETNAM MINISTRY OF HEALTH ----------------o0oo--------------- ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK INVESTING AND INNOVATING FOR GRASSROOTS SERVICE DELIVERY REFORM PROJECT (Final Version) February, 2019 ACRONYMS CHS Commune Health Station DH District Hospital DHC District Health Care Center DOH Department of Health DONRE Department of Natural Resources and Environment DPC District People’s Committee EA Environmental Assessment ECOP Environmental Codes of Practice EHS Environmental, Health and Safety EHS Environmental, Health and Safety EIA Environmental Impact Assessment EMDP Ethnic Minority Development Plan EMPF Ethnic Minority Planning Framework EPP Environmental Protection Plan ESHS Environmental, Social, Health and Safety ESIA Environmental and Social Impact Assessment ESMF Environmental and Social Management Framework ESMP Environmental and Social Management Plan GCC General Conditions of Contract GoV Government of Vietnam HBV Hepatitis B virus HCV Hepatitis C virus HCW Health Care Waste HCWM Health Care Waste Management HIV Human Immunodeficiency Virus MONRE Ministry of Natural Resources and Environment PCC Particular Conditions of Contract CPMU Central Project Management Unit PPC Provincial People’s Committee PPMU Provincial Project Management Unit SOP Standard Operating Procedure WB World Bank WBG World Bank Group 1 TABLE OF CONTENTS 1. EXECUTVIE SUMMARY .............................................................................................. 6 2. INTRODUCTION ............................................................................................................ 9 2.1 Project Overview ............................................................................................................ 9 2.2 Purpose of the ESMF...................................................................................................... 9 2.3 Scope of the ESMF ....................................................................................................... 10 3. PROJECT DESCRIPTION ........................................................................................... 12 3.1 Project Objective(s) and Components .......................................................................... 12 3.2 Project target areas........................................................................................................ 15 4. POLICY, LEGAL, AND ADMINISTRATIVE FRAMEWORK .............................. 17 4.1 Applicable National Laws and Regulations ................................................................. 17 4.2 Applicable the World Bank Safeguard Policies ........................................................... 19 4.3 Gap Analysis and Gap Filling Measures ...................................................................... 21 5. POTENTIAL ENVIRONMETAL AND SOCIAL IMPACTS ................................... 28 5.1 Potential Positive Impacts ............................................................................................ 28 5.2 Potential Negative Impacts ........................................................................................... 28 5.3 Social issues related to ethnic minority groups ............................................................ 31 6. MEASURES TO MANAGE ADVERSE ENVIRONMENTAL AND SOCIAL RISKS AND IMPACTS ......................................................................................................... 33 6.1 Design stage .................................................................................................................. 33 6.2 Preconstruction stage .................................................................................................... 33 6.3 Construction stage ........................................................................................................ 33 6.4 Operation stage ............................................................................................................. 34 6.5 Mitigation measures for ethnic minority groups issues ................................................ 44 7. PROCEDURES FOR REVIEW, CLEARANCE, AND IMPLEMENTATION OF SUBPROJECT SAEGUARD INSTRUMENTS .................................................................. 45 7.1 Objective and Approach ............................................................................................... 45 7.2 Safeguard Screening and Impact Assessment .............................................................. 45 7.3 Development of Safeguard Documents ........................................................................ 45 7.4 Review, Approval, and Disclosure of Safeguard Documents ...................................... 48 7.5 Implementation, Supervision, Monitoring, and Reporting ........................................... 48 8. IMPLEMENTATION ARRANGEMENTS ................................................................ 49 8.1 Responsibility for ESMF Implementation .................................................................... 49 8.2 Environmental Compliance Framework ....................................................................... 52 8.3 Reporting Arrangements............................................................................................... 54 8.4 Incorporation of ESMF into Project Operational Manual (POM) ................................ 55 9. CAPACITY BUILDING AND TRAINING ................................................................. 56 9.1 Institutional Capacity Assessment ................................................................................ 56 9.2 Safeguards Capacity Building ...................................................................................... 56 10. ESMF IMPLEMENTATION BUDGET ...................................................................... 57 11. GRIEVANCE REDRESS MECHANISM ................................................................... 58 2 11.1 Subproject Grievance Redress Mechanism (GRM) ................................................. 58 11.2 WB Grievance Redress Service (GRS) .................................................................... 59 12. STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE ......... 60 12.1 Stakeholder engagement process .............................................................................. 60 12.2 Information Disclosure ............................................................................................. 61 13. REFERECNES ............................................................................................................... 62 Annex 1. Standard Operating Procedures for Health Care Waste Segregation.................... 63 Annex 2. Standard Operating Procedures for Health Care Waste Collection ...................... 65 Annex 3. Standard Operating Procedures for Health Care Waste Storage .......................... 67 Annex 4. Guidance on selecting methods for Health Care Waste Treatment and Disposal 68 Annex 5. Standard Operating Procedures for Health Care Waste Treatment and Disposal 70 Annex 6. Standard Operating Procedures for Treatment of Accident due to Sharp Waste . 71 Annex 7: Health Care Waste Management Checklist .......................................................... 73 Annex 8: Safeguard Screening Guidelines ........................................................................... 75 Annex 9: Guidelines for Subproject ESMP Preparation ...................................................... 77 Annex 10: Environmental Codes of Practice (ECOP).......................................................... 84 Annex 11. Template of Grievance Registration Form ....................................................... 113 Annex 12. Suggested Content of an Environmental Monitoring Report for the Project.... 114 3 LIST OF TABLES Table 1. Summary of the World Bank and National EA Processes and proposed gap mitigation for the project............................................................................................................................ 22 Table 2: Treatment and disposal methods for categories of health care waste ....................... 38 Table 3. General HCW management measures at health care facilities during operation ....... 42 Table 4. Applications of ESMF Annexes ................................................................................. 45 Table 5. Institutional responsibilities for the Project and Subproject Safeguard Implementation .................................................................................................................................................. 49 Table 6. Reporting Procedures ................................................................................................. 55 Table 7. Content of safeguard training ..................................................................................... 56 Table 8. Cost estimates for safeguards performance ................................................................ 57 Table 9. Summary of ESMF consultation results ..................................................................... 61 LIST OF FIGURES Figure 1:Schematic Flowchart of Project Safeguards Performance ......................................... 47 Figure 2: Organizational diagram for safeguards performance ................................................ 49 4 Preface This Environment and Social Management Framework (ESMF) has been prepared by the Ministry of Health (MOH) for the Investing and Innovating for Grassroots Service Delivery Reform Project in accordance with the World Bank safeguard policy requirements. It is a safeguard instrument that examines the issues and impacts associated with the proposed project which consists of a series of sub-projects, and the impacts cannot be determined until sub- project details have been identified. The ESMF sets out the principles, rules, guidelines and procedures to assess the environmental and social impacts. It contains measures and plans to reduce, mitigate and/or offset adverse impacts and enhance positive impacts, provisions for estimating and budgeting the costs of such measures, and information on the agency or agencies responsible for addressing project impacts. This framework was developed as a stand-alone safeguard instrument to satisfy the WB’s safeguard policies on Environmental Assessment (OP/BP 4.01) and Indigenous Peoples (OP/BP 4.10).It is also connected to other safeguard instruments such as the Ethnic Minorities Policy Framework (EMPF) as well as the safeguard action plans for the subprojects namely the Ethnic Minority Development Plans (EMDPs) and the Environmental and Social Management Plans (ESMPs), including the Environmental Codes of Practice (ECOP). The ESMF will be applied to all subprojects to be financed under the Project. The Provincial Project Management Unit (PPMU) established at the provincial Department of Health (DoH) in each of the ten provinces is responsible for preparation and implementation of the mitigation measures as described in the subproject specific EMDP and/or ESMP/ECOP in consistency with this ESMF. The subproject specific EMDP and ESMP would be subject to the review and clearance by the Bank before implementation. 5 1. EXECUTVIE SUMMARY Project Development Objective: The development objective is to strengthen quality and efficiency of the grassroots health network in provision of preventive services, primary health care, health promotion, preventive care. Priority is given to mother and child, old people, disadvantaged people in difficult areas, contributing to health, improving longevity, and improving the quality of life of people. This will be achieved by (i) enabling the commune- level facilities to take on the management of select non-communicable diseases, (ii) improving the utilization and quality of services already provided at commune level, and (iii) strengthening the capacity of the district to provide appropriate referral and support services. Project Beneficiaries: The main beneficiaries of this project include (i) People of all ages in 7 poorer provinces and 3 “front-runnerâ€? provinces; (ii) Grassroots Health Staff; (iii) Commune Health Care Stations; (iv) District Hospital/District Health Center; and (v) MoH and DoH in the selected project provinces. Project Components: The project consists of 03 components include: Component 1: Ensure service availability through improving the infrastructure of the CHSs; Component 2: Ensure readiness to deliver the tracer conditions and improvement in the quality of care provided; and Component 3: Creating an enabling policy environment, piloting innovations, evaluation and project coordination. Applicable the World Bank’s safeguard policies: The Project has been classified as category “Bâ€? and triggered the two safeguard policies, including Environmental Assessment (OP/BP 4.01)and Indigenous Peoples (OP/BP 4.10). The project also complies with the Bank policy on Access to Information. Applicable the GoV’s environmental regulations: The project will have to comply with the current GoV’s environmental regulations such as Law on Environmental Protection (No. 55/2014/QH13) and Decree No. 18/2015/ND-CP on Environmental Protection Planning, Strategic Environmental Assessment, Environmental Impact Assessment, and Environmental Protection Plan. Potential project impacts: The overall impacts will be positive. The negative impacts are connected to activities supported under the project, especially those related to: (i) Ethnic minority people, (ii) construction activities which could temporarily increase levels of dust and other air pollutants, noise, vibration, water pollution, local traffic volume, health and safety risk, and other impacts on local residents and businesses, and (iii) generation of medical wastes from operation of commune health care stations and other health care facilities. However, these impacts are envisaged to be of the magnitude ranging from low to moderate. The construction- related impacts are considered low, localized and temporary, and can be mitigated. Good construction management and practices with close supervision of contractors by field/site engineers and in consultation with local authorities and local residents will be measures to effectively mitigate such impacts. In addition, an Environmental Codes of Practice (ECOP) was developed to address the adverse construction-related impacts associated with upgrading and new construction of CHSs. In case, adverse construction-related impacts of a subproject are considered moderate and could not be addressed by ECOP, an ESMP would be required and developed. All mitigation measures for construction-related impacts will be included in the bidding and contractual documents for the environmental compliance purpose of contractors. There might be UXO (unexploded ordnance) risk during site clearance but this risk is considered low as construction activities will exclusively take place within the existing CHSs’ premises and could be mitigated through an UXO examination and clearance (as needed) prior to handing over site to contractors. There are also risks during operation if the CHSs were not properly designed and/or maintained, but considered low and could be avoided through proper design, close consultation among key stakeholders, and the capacity building activities. Environmental and health risks related to health care waste would be minimized and mitigated 6 through the guidelines on Healthcare waste management (HCWM) issued by MOH and MONRE, such as the MOH manual of guideline on health care waste management in hospital, joint circular 58/2015/TTLT-BYT-BTNMT on regulation on health care waste management, and other relevant regulations. The good international practices, i.e. World Bank Group Environment, Health and Safety Guidelines on HCWM should also be referenced. . The Environmental and Social Management Framework (ESMF): Given that the subprojects will be implemented during implementation, this ESMF has been prepared to ensure that the subprojects and activities to be financed under the Project would not create adverse impacts on the local environment and local communities and the residual and/or unavoidable impacts will be adequately mitigated in line with the WB’s safeguard policies. The ESMF describes criteria for safeguard screening and identification of impacts; basic principles for development of mitigation measures; requirements for WB safeguard clearance; and implementation, supervision, monitoring, and reporting. The ESMF also provides guidelines for preparation of an ESMP for an identified subproject, including actions to facilitate effective implementation of the ESMP, institutional arrangements, safeguard training and capacity building, and budget allocation and source of funds. Below provides a brief summary of the ESMF process. • Safeguard Screening and Identification of Potential Impacts: Safeguard screening will apply to all proposed subprojects under component 1. The aim is to ensure that the proposed subprojects will not cause significant adverse impacts on the environment and human health. If a proposed subproject is determined to cause significant adverse impacts on the environment and human health, then it is not considered to be supported under the project. Safeguard screening will help identify potential impacts of the proposed subprojects and develop appropriate safeguard instruments. • Development of Safeguard Instruments: PPMU is required to prepare safeguard instruments for proposed subprojects in accordance with the World Bank policy requirements and the GoV’s environmental regulations. In this case, the Bank requires preparing quality ESMP/ECOP, and EMDP whilst the GoV requires preparing EIA or EPP subject to the scale of proposed subprojects. • Public Consultation and Information Disclosure for subproject: Public consultations will be conducted during project implementation when subproject details have been identified, with locally-affected people and local authorities and NGOs and their views will be taken into account subproject design. Consultations will also be conducted throughout subproject implementation with such groups to address EA-related issues that affect them in a timely manner. Draft and final safeguard instrument such as ESMP and EMDP will be locally disclosed prior to subproject appraisal. • Safeguard Review and Clearance: ESMP/ECOP and EMDP will be reviewed and cleared by the Bank. The EIA or EPP will be reviewed and approved by the responsible agencies of the GoV. Public Consultation and Information Disclosure for ESMF: Public consultations during ESMF preparation have been conducted with key stakeholders and their views have been incorporated into the project design and finalization of this ESMF. The project information and draft ESMF in Vietnamese language were provided to key stakeholders to be consulted prior to consultation meetings. Draft ESMF have been disclosed in-country and at the Bank’s external website prior to project appraisal. The final ESMF will be also disclosed at the same places as the draft version after approved by the Bank. Institutional Arrangements: This will be in line with the overall institutional arrangements of the Project. Contractors will be responsible for implementation of agreed environmental covenants in the contracts. Supervision and monitoring of the compliance with the ESMF will be implemented by MOH CPMU in coordination with PPMUs. Report on the status of 7 safeguards performance of the project will be periodically submitted to the Bank and relevant government agencies for information. The cost for safeguards performance will be included in the Project cost. Safeguards training shall be provided by MOH CPMU to PPMUs, CSC and contractors at the early stage of the project implementation. 8 2. INTRODUCTION 2.1 Project Overview 1. Recent government strategies and masterplans, as well as on-going policy development, reflect an increasing awareness of these challenges and an emphasis on strengthening the grassroots health system. The Ministry of Health and development partners’ recent Joint Annual Health Reviews (JAHR) have focused on the challenges related to the non-communicable disease burden (2014), strengthening primary health care (2015) and healthy ageing (2016). The five-year health sector plan for the period 2016-2020 includes a significant focus on strengthening of the grassroots health system (MOH Plan 139/KH-BYT of 2016). The Government’s Masterplan for easing hospital overcrowding includes actions at the primary care level, including developing a family practice model, bolstering preventive medicine, and strengthening Commune Health Care Stations (Prime Ministerial Decision 92/QÄ?-TTg of 2013). Both the National Strategy to prevent and control cancer, cardiovascular disease, diabetes, chronic obstetric pulmonary disease, asthma and other non-communicable diseases for the period 2015-2025 (Prime Ministerial Decision No. 376/QD-TTg of 2015) and the National Strategy for Population and Reproductive Health for the period 2010-2010 (Prime Ministerial Decision 2013/QD-TTg of 2011) emphasize the importance of strengthening the grassroots-level to prevent and manage non-communicable diseases and improving maternal and child health outcomes. Most importantly, in December 2016, the Government approved the Masterplan for building and developing the grassroots health care network in the new situation (Prime Ministerial Decision 2348/QÄ?-TTg of 2016) which includes plans for both concrete investment and reforms to address the above-mentioned problems. A new basic essential service package for health insurance reimbursement at the commune level, intended to expand the scope of services to include non-communicable disease interventions, is currently under development. Principles of family medicine are being promoted for commune health stations and private primary care facilities. As reforms in the organization and financing of service delivery proceed, and the system attempts to address new challenges related to NCDs, care will also need to be undertaken that coverage of basic health services (such as immunization and maternal care) is sustained – and further improved. 2. The project will contribute to the attainment of the objectives set out in the (new) Vietnam Country Partnership Framework (CPF) FY18-22, in particular Objective 6 which is to “improve access to quality public and private health services and redu ce malnutritionâ€?. This objective explicitly includes the intention to improve the quality of health care service delivery, especially at the primary care level, including “strengthening the grassroots (district and commune) health system in terms of availability/access, quality, integration, and transparency and voiceâ€?. This objective also includes the need to improve the efficiency and sustainability of health financing and service delivery arrangements, including (among others) reducing the over-reliance on hospital-centered delivery, supporting health insurance reform, enhancing financial protection from out-of-pocket health spending, and creating an enabling environment for private sector participation. In this regard, the project will also be relevant to bringing about one of the five strategic shifts envisaged under the CPF, namely achieving “the financial sustainability of public services and transfersâ€?. To a lesser extent, the project will also contribute to the achievement of two other key strategic shifts envisaged in the CPF, namely the strategic shift towards more private sector development and participations across sectors and, also, ethnic minority poverty reduction. 2.2 Purpose of the ESMF 3. To comply with the WB’s Operational Policy on Environmental Assessment (OP/BP 4.01), as the proposed project is adopting a programmatic approach consisting of investment activities that could not be identified by appraisal, preparation and disclosure of an Environment and Social Management Framework (ESMF) is required before appraisal. This is to ensure that 9 the proposed project has a concrete plan and process in place to avoid, minimize, and/or mitigate adverse environmental and social impacts of project investments and interventions when they are identified, planned, and implemented. The Project is classified by OP/BP 4.01 as Category Band two of the ten WB safeguard polices are triggered (see Section 4). The ESMF sets out the principles, rules, guidelines and procedures to assess the environmental and social impacts. It contains measures and plans to reduce, mitigate and/or offset adverse impacts and enhance positive impacts, provisions for estimating and budgeting the costs of such measures, and information on the agency or agencies responsible for addressing project impacts. The ESMF was developed in line with OP 4.01, based on desk reviews of the relevant GoV’s laws and regulations as well as various reports and documents related to environmental and social conditions in the proposed provinces and/or project sites, field visits to some of the proposed subprojects sites including meetings with key stakeholders. 4. The specific objectives of this ESMF are: • to assess the potential environmental and social impacts of the proposed project, whether positive or negative and propose measures which will effectively mitigate these negative impacts and enhance positive impacts; • to establish clear procedures for the environmental and social planning, review, approval and implementation of subprojects to be financed under the project; • to specify appropriate roles and responsibilities, and outline the necessary reporting procedures, for managing and monitoring environmental and social concerns related to subprojects; • to consider different alternatives, options, and relevant mitigation measures during project preparation and implementation; • to determine the training, capacity building and technical assistance needed to successfully implement the provisions of the ESMF; • to establish mechanisms for public consultation and disclosure of project/subproject’s documents as well as redress of possible grievances; and • to establish the project funding required to implement the ESMF requirements and to provide practical resources for implementing the ESMF. 2.3 Scope of the ESMF 5. Following the WB guidelines on preparation of an ESMF for the Bank-financed projects in Vietnam, the ESMF includes the following sections: Executive summary (Section 1); Introduction (Section 2);the project description (Section 3); the policy, legal, and administrative framework (Section 4); Project potential environmental and social impacts (Section 5); Measures to manage environmental and social impacts (Section 6); Procedures for review, clearance and implementation of subproject safeguard instruments (Section 7); Implementation arrangements (Section 8); capacity building, training, and technical assistance (Section 9); ESMF implementation budget (Section 10); Grievance redress mechanism (Section 11); and ESMF consultation and disclosure (Section 12). Annexes provide more details on safeguard screening guideline (Annex 8); guideline for subproject ESMP preparation (Annex 9); ECOP (Annex 10);grievance registration form (Annex 11), and the template of monitoring reports (Annex 12). 6. In addition to the ESMF, there is another related safeguard instrument which will be applied during implementation of the proposed project. The instrument is the Ethnic Minority Policy Framework (EMPF) which provides guidelines for undertaking free, prior and informed consultation with ethnic minorities in the project area and the preparation of Ethnic Minority Development Plan (EMDP) in compliance with Bank Policy on Indigenous Peoples (OP/BP 4.10) and it will be applied when the project activities and/or subprojects are implemented in 10 area inhabited by ethnic minorities that meet the definitions of OP/BP 4.10. The EMDP will be prepared in compliance with OP/BP 4.10.The safeguard screening and preparation of ESMPs and EMDPs for the future subprojects will be carried out during implementation. These instruments are presented separately. 11 3. PROJECT DESCRIPTION 3.1 Project Objective(s) and Components 7. The project development objective is to improve the quality and efficiency of the grassroots health system in the project provinces, with a focus on the management of select tracer conditions. 8. The Project activities will be implemented through the following 03 components: Component 1: Upgrading of CHS infrastructure (US$65mn loan, US$9.75mn provincial counterpart) 9. This component will improve the quality of CHS infrastructure in the project provinces so that the CHSs meet the national standards for CHS infrastructure. Targeted CHSs will be upgraded through either new construction, expansion, or renovation to reach the infrastructure- related standards of the MOH for CHS.1 The component will also allocate a small amount of resources to the construction and renovation of the (dual function) district health center / district hospital (DHC/DH), but this will be limited to cases of special need (e.g. recently bifurcated districts which lack district facilities) and where provinces can demonstrate that CHS infrastructure needs of the province can be adequately funded through other sources. The project will only finance the actual cost of construction, while the associated non-construction costs will be financed by provincial counterpart funding2. 10. A needs-based formula was used for the initial allocation of financing for this component across project provinces. The amount allocated is proportional to the number of rural and disadvantaged CHS in each province, with most rural communes assigned a weight of 1 and especially disadvantaged communes (per the official government lists3) assigned a weight of 1.94. Also, for reasons of equity and economies of scale in implementation, no participating province received less than US$2.5 million. 5 See Annex 2, Error! Reference source not found. in the Project Appraisal Document (PAD), for the initial allocation of funds across project provinces. Provincial allocations may be revised during project implementation based on remaining need and variation in implementation progress. 11. Within each province, the specific CHSs targeted for reconstruction/renovations is based on provincial plans and complemented by a set of criteria that will help to improve the efficiency and equity of project investments. The provincial grassroots investment plans, prepared as part of the Grassroots Master Plan (Prime Ministerial Decision 2348/QÄ?-TTg of 2016), serve as the basis for identifying the CHSs eligible for project support within each province. Complementary criteria for selecting a CHS for upgrading include: the CHS has not 1 The current commune health benchmarks are described in MOH Decision 4667/QÄ?-BYT of 2014, the CHS’s functional space requirements are described in MOH Decision 6070/QD-BYT of 2018 and the minimum architectural standards are laid out in MOH Decision 2271/QD-BYT of 2002. If new CHS infrastructure standards are approved during the course of project implementation, then the new standards will apply to the project sites. 2 These costs include any consulting services for investment planning, detailed design and cost estimates, and procurement documents (before investment); insurance costs and supervision of construction (during investment); and audits (and other post-construction costs). 3 Prime Ministerial Decisions 131/QD-TTg (2017) and 900/QD- TTg (2017) list the disadvantaged communes in coastal/island areas and mountainous areas, respectively. 3 Prime Ministerial Decisions 131/QD-TTg (2017) and 900/QD-TTg (2017) list the disadvantaged communes in coastal/island areas and mountainous areas, respectively. 4 Different options for resource allocation were presented to the provinces during consultations (6 July 2018, Hanoi) and this one was preferred (over the alternatives of one that factored in whether provinces that already reached the benchmarks and one that was purely based on the number of communes without weights for remoteness of disadvantage). 5 The floor criterion meant that the provinces of Ninh Thuan, Bac Lieu and Hau Giang provinces had their initial allocations augmented, with the allocations to remaining provinces reduced proportionately. 12 yet met commune benchmarks for infrastructure 6 ; the province is willing to make complementary investments in equipment (through project or own resources) and human resources (through own resources) necessary for the CHS to deliver quality services; the CHS is in rural areas (zone 2 and 3)7; the CHS meets or has plans to meet requirements for health insurance reimbursement (and, in so doing, ensure sufficient operating budget for the facility); and, the CHS is willing to commit to improving service delivery in line with the tracer conditions. Finally, CHSs financed under the project should not require new land acquisition, land clearance, or resettlement, and the land area will also be large enough to meet MOH standards8. Component 2: Providing equipment, training, and quality management tools to improve the management of tracer conditions at commune and district level (US$15m loan, US$4m grant, US$2.638 provincial counterpart financing) 2.1. Equipment for tracer conditions (US$15mn loan, US$2.253 counterpart) 12. The project will provide the essential equipment needed to enable the CHS and DHC to manage the tracer conditions in an integrated way. A list of eligible CHS and DHC equipment, aligned with the five tracer conditions, has been developed as part of project preparation (see Annex 2, Error! Reference source not found. in the PAD). The project will only provide the equipment if it is not yet available or if the CHS/DHC needs to replace broken items. The allocation of funds for equipment across provinces is in proportion to the number of CHS and districts in each province. Once participating provinces have ensured that all CHS and DHC/DH have the equipment needed to deliver services related to the tracer conditions, any remaining project funds may be used to purchase other equipment on the official list of equipment and furniture for model CHSs,9 with the exception of x-ray, ultrasound and nasal endoscopy. On a limited basis, and subject to the prior review of the MOH and the World Bank, select equipment may also be purchased for the DH/DHC level. As with the infrastructure component, provincial allocations may be revised during project implementation based on need and implementation progress. 13. Among the equipment financed by the project are two specialized pieces of equipment, linked to the tuberculosis and immunization tracer conditions. First, the project will invest in GeneXpert machines in select districts, in line with the national TB roadmap and guidelines that require the testing of all presumptive tuberculosis cases by 2020. To ensure allocative efficiency, the number and placement of GeneXpert machines at district level was informed by spatial and mathematical modelling (see Technical, Economic and Financial Analysis in the PAD). Second, the project will finance reliable specialized fridges for vaccine storage in CHSs in disadvantaged areas and in the obstetric wards of district hospitals, along with other items related to the vaccine cold chain (e.g. cold boxes and vaccine carriers). Project support to the vaccine cold chain will also serve as the government’s share needed to leverage a matching in- kind grant from GAVI through its Cold Chain Equipment Optimization Platform (CCEOP)10, 6 Since it is possible for CHS to be awarded the certificate for reaching benchmarks with only 75% of the criteria met, some of the CHS that have already met the benchmarks may still be in need of infrastructure investments. The project will prioritize the infrastructure of the CHS that have not yet met the overall benchmarks; CHS that have met the overall benchmarks but not the infrastructure-related benchmarks will be the second priority. 7 CHS in urban / peri-urban areas (Zone 1) only supported if all CHS in other zones currently meet (or will meet through investments funded by other sources) the infrastructure benchmarks. Per the Prime Minister’s decision, zone 1 facilities are defined as those that meet at least one of the following criteria: within 3 km of a hospital, in an urban ward or district capital, or in other locations with convenient transport to easily access such facilities. 8 These standards are 500 m2 for CHSs in region 2 and 3, and 60m2 for CHS in region 1. 9 MOH Decision 4389/QÄ?-BYT in 2018 issued the standard list of equipment and furnishings for CHS for each of the three zones. All equipment items needed for the tracer conditions are also included on this list. 10 Up to a certain agreed value, countries that are in accelerated transition from GAVI, like Vietnam, can benefit from matching in-kind grants from the GAVI Cold Chain Equipment Optimization Platform (CCEOP) in the form 13 thus effectively doubling the impact of the project’s investment in the vaccine cold chain. Funds for GeneXpert machines and the vaccine cold chains, of around US$1 million each, were set aside before allocations were made to each province for other essential equipment. 2.2. Training for tracer conditions (US$3mn grant and US$0.385 in counterpart financing) 14. This sub-component will improve the competencies of primary healthcare (PHC) teams to provide integrated preventive and curative services and better manage tracer conditions. The project will support (i) development of training curricula where needed 11 and e-learning resources, (ii) training of trainers and training of CHS teams, both through short-term modular training and on-the-job training, and (iii) on-the-job supervision (clinical mentoring) of CHS team’s performance after training. Training will follow the approach used by the on -going Health Professionals Education and Training (HPET) project and the two projects will efficiently synergize their training investments. Medical education institutions will use the training curricula on PHC in line with family medicine principles standardized by MOH under the HPET project and, under this project, further customize it to include additional training related to the tracer conditions. In project provinces which benefit from both the HPET and Grassroots SDR projects (i.e. Ha Giang, Son La, Yen Bai), HPET will bear most of the cost of training, while this project will emphasize on-the-job supervision of CHS team’s performance, improving management of the tracer conditions, and meeting the training-related capacity requirements of health insurance reimbursement. 15. For implementation of PHC team training and on-the-job supervision, the Central Project Management Unit (CPMU)/MOH will enter a Memorandum of Understanding (MOU) with the Provincial Departments of Health (DOH) or the training institutions. The MOU will describe the roles and responsibilities of Parties and will be part of the Project Operational Manual (POM). Each DOH will prepare and submit to MOH a training plan for provincial PHC staff that includes the composition of PHC staff at CHS in the province, the number of staff subscribed for each training program, and a proposed schedule for their training. 2.3. Quality scorecards (US$1 million grant) 16. The project will support the implementation of quality scorecards to monitor and improve the quality of care. At the CHS level, the scorecard will cover various quality dimensions related to the tracer conditions including, for example, availability of equipment, availability of essential drugs, staff compliance with technical guidelines (such as clinical practices guidelines and appropriate referrals) related to the tracer conditions and other services, internal quality management processes, outreach, patient follow-up, interactions with the DH / DHC, maintenance of family health records, planning and financial management, information reporting, etc. At the DHC level, the electronic DHC scorecard will be used to monitor and improve the DHC’s performance, especially in the areas of (i) providing supportive supervision to the CHS, and (ii) strengthening the integration and continuity of care through downward patient referral and information exchange with CHS. CHS and DHC scorecards will be visualized on an on-line dashboard and integrated into the MOH’s on-going digitization of its health statistics system and implementation of electronic health records. Training of staff in how to interpret the scores and implement facility action plans to improve scores will be needed. It is expected that the project will support the implementation of scorecards in all project provinces, but only a subset of the districts in each province. The MOH envisages that the of free cold chain equipment. MOH, GAVI and WB have agreed that the project financing can serve as the 50% government share needed to trigger the 50% GAVI CCEOP contribution. Eligible refrigeration equipment includes the purchase, installation, and related training in the bundled price and should be procured via UNICEF-SD. 11 The family medicine curriculum of the MOH does not yet cover training for services related to the tracer conditions of cervical cancer and tuberculosis (screening, detection, and management), and the child health-related curriculum needs strengthening (particularly for activities related to nutrition, immunization, and tuberculosis). 14 electronic quality scorecards would be expanded to other districts later by regulation and financed by the provinces’ own resources. Component 3: Creating an enabling policy environment, piloting innovations, evaluation and project coordination (US$3mn grant, US$1,615mn counterpart financing) 17. First, the component will support the development of relevant policies, regulations and guidelines related to the management of the tracer conditions, as well as overall grassroots health system financing and delivery. Possible areas include provider payment reform needed to better enable and incentivize the CHS to manage NCDs (including support to the ongoing capitation reform); addressing the fragmented financing arrangements that lead to the prioritization of curative care services and selected vertical programs over other effective preventive interventions; correcting incentives to ensure a more effective upward and downward referral system; and better integrating of the activities of community-based private providers. In addition, the development and refinement of evidence-based clinical guidelines for the CHS will be supported12. Other related reforms include the need to establish uniform criteria by which provincial authorities would authorize the CHS to take on the new role (both for service provision and drug dispensing) and be eligible for health insurance reimbursement by the provincial social security office. Policies, regulations, and guidelines to be supported by the project will be identified by the MOH, in consultation with other agencies, and reviewed and agreed with the Bank on an annual basis. 18. Second, the component will support the design, implementation and evaluation of innovative pilots at the grassroots level. Criteria for selection of innovations include alignment with project development objectives, potential to go to scale, and the willingness of project provinces to implement. Pilots will have one of the following goals: improving the clinical quality of care (supply-side), improving patient care-seeking behaviors and treatment compliance (demand-side), improving the organization of service delivery (including through better integration of care and through engaging the private sector), and reforming the CHS-level health financing mechanism(s). If equipment is needed to implement the pilots, then the equipment will be financed by the loan. The component will also support implementation/operational research and evaluation of the project’s pilots and innovations, covering both the effectiveness of these pilots/innovation in achieving their goals and the operational aspects of implementation, in order to create a feedback loop for implementation by learning from both success and failures. 19. Third, the component will finance the costs associated with project management and implementation at the central and provincial level. At the central level, this will include the additional MOH staff and/or consultants hired to staff the Central Project Management Unit (CPMU) and their activities, as well as selected activities of the central Steering Committee consisting of senior officials in the MOF, MOH, and participating provinces. At the provincial level, it will include additional staff and/or consultants hired to supplement the Provincial Project Management Unit (PPMU) and other relevant implementing agencies and entities. 3.2 Project target areas 20. The project covers all regions of Vietnam and is pro-poor in terms of its geographic scope, both across provinces and within provinces. The identification of project provinces took into consideration the following criteria: poverty rates, representation of all three geographic regions of Vietnam, whether provinces had sufficient borrowing room relative to their debt thresholds (per government decree and MOF’s implementation guidelines), and that the province could not be included in the concurrent grassroots-strengthening project of the 12 Some of the existing guidelines for disease management need to be adapted to the service delivery environment of a CHS, while others lack important details to guide practitioners in a systematic evidence-based approach. 15 Asian Development Bank (which covers 15 provinces in three geographic regions). The 13 project provinces are Ha Giang, Bac Kan, Yen Bai, Son La, and Hoa Binh (in the north), Quang Binh, Quang Tri, Quang Ngai, and Ninh Thuan (in the central region), and Long An, Tra Vinh, Hau Giang, and Bac Lieu (in the south). Nine of the provinces are in the poorest third of all provinces, three are in the middle third, and one (Long An) is in the top third, with its inclusion justified as a “front-runnerâ€? province that is able to implement innovations. All but one of the project provinces have poverty rates above the national average and four of the project provinces have poverty rates exceeding 2.5 times the national average. 16 4. POLICY, LEGAL, AND ADMINISTRATIVE FRAMEWORK 4.1 Applicable National Laws and Regulations 21. The following national laws and regulations will be applicable to the project implementation: - Environmental Protection Law No. 55/2014/QH13 of the National Assembly of Vietnam dated June 23, 2014. This law stipulates environmental protection activities; policies, measures and resources for environmental protection; right and obligations of organizations, households and individuals in environmental protection - The Law on Construction No. 50/2014/QH13 approved on 18th June 2014 by 7th National Assembly of the Socialist Republic of Vietnam. Article 12 of Chapter 1 prescribes prohibited actions such as use of materials to cause harm to the public health and environment - The Law on Roadway Traffic No. 23/2008/QH12 dated on 13/11/2008. Articles 8 of Chapter 1 prescribes prohibited actions such as driving vehicles without licenses; driving vehicles with speed exceeding allowed speed; sounding horn between 10 p.m. and 5 a.m.; driving vehicles while the body is positive with drug. Article 55 of Chapter 4 stipulates ensuring technical safety quality and environmental protection for vehicles moving on roadways - The law on People’s Health Protection dated 30 June 1989. This law stipulates the right to get medical examination and treatment. 
 - The Law on Complaint No. 02/2011/QH13 dated 11 November 201. This law stipulates complaint and handling complaint; management and monitoring of complaint handling - The Law on Culture Heritage No. 28/2001/QH10. This law aims to (i) reinforce the state management effectiveness and (ii) raise responsibility of people for participation, protection and promotion of the value of cultural heritages - The Law No.32/2009/QH12. This law stipulates amendment and addition to some articles of the Law on Cultural Heritage No. 28/2001/QH10. - The Law on Labor Sanitation and Safety No. 84/2015/QH13 dated June 25, 2015. This law stipulates ensuring safety and labour sanitation; policy and regulation for labour accident and occupational diseases; responsibility and right of organizations and individuals in safety and labour sanitation and state management of safety and labour sanitation - Labor Law No.10/2012/QH13. This law stipulates labour standard; right and obligation of employee, employer, representative organization of employee, representative organization of employer in labour relations and other relations directly related to labour relations; state management of labour - Law on Fire Prevention and Fighting No.27/2001/QH10 dated June 29, 2001. This law stipulates fire prevention and fighting; establishing human resources, equipment and machineries and policy on fire prevention and fighting - Decree No. 38/2015/ND-CP of 24 April 2015 of the Government on management of waste and discarded materials. Chapter 2 stipulates Management of Hazardous Wastes. Hazardous waste must be classified according to hazardous waste codes in order to store in proper containers. Hazardous wastewater must be treated to satisfy national standards. Hazardous waste must be classified at the timing of storage or transportation to treatment area - Decree No. 39/2015/NÄ?-CP of the Government dated 27 April 2015 on assistance policy applied to ethnic minority and poor women who comply the population policy will take effect as from 15 June 2015 17 - Decree No. 18/2015/ND-CP dated February 14, 2015 of the Government on environmental protection planning, strategic environmental assessment, environmental impact assessment, and environmental protection commitment - Decree No.19/2015/ND-CP of 14 February 2015 of the Government detailing the implementation of a number of articles of the Law on Environmental Protection - Decree No. 155/2016/ND-CP dated 18 November 2016 of the Government prescribing administrative sanctions for environmental protection. This decree stipulates administration violation in environmental protection including (i) violation of environmental protection plan, environmental impact assessment and environmental protection projects; (ii) actions to cause environmental pollution; (iii) violation of management of wastes, etc - Decree No. 25/2013/ND-CP of 29 March 2013 of the Government on environmental protection charges for wastewater. This decree stipulates that organizations or individuals who discharge wastewater into the environment pay environmental protection fee - Decree No. 113/2010/NÄ?-CP dated 3 December 2010 of the Government on valuation of damages caused to the environment. This decree stipulates assessment of environmental damage, calculation of damage, and determination of obligation of compensation for damage due to environmental pollution and degradation - Decree No. 174/2007/ND-CP of 29 November 2007 on environmental protection charges for solid waste. This desree stipulates the environmental protection fee for solid wastes, such as general solid waste (maximum 40,000 VND per ton) and hazardous wastes (maximum 6,000,000 VND per ton) - Decree No. 59/2007/NÄ?-CP dated 09/4/2007 of the Government on the management of solid waste. This decree stipulates right and obligation of organizations and individuals in relation to solid wastes - Circular No. 27/2015/TT-BTNMT dated 19 May 2015 of the Ministry of Natural Resources and Environment on strategic environmental assessment (SEA), environmental impact assessment (EIA), and environmental protection plan (EPP) - Circular No. 36/2015/TT-BTNMT dated 30/6/2015 of Ministry of Natural Resources and Environment on hazardous waste management. This circular stipulates details of execution of Decree 38/2015/ND-CP mentioned above - Circular No. 22/2010/TT-BXD dated 03/12/2010 of Ministry of construction providing labor safety in construction - Circular No. 19/2011/TT - BYT of 06 June 2011 of the Minsitry of Health on guidance on labor hygiene, laborers’ health and occupational diseases - Circular No 13/2007/TT-BXD of December 31st 2007. Providing guidance on a number of articles of decree no. 59/2007/nd-cp dated 09/4/2007 by the government on solid waste management - Joint Circular No. 58/2015/TTLT-BYT-BTNMT dated 31 December 2015 on Health care Waste Management - Decision no. 4667/QD-BYT dated 7 November 2014 and Decision no. 2271/2002/QD- BYT dated 17 June 2002 on design standard for CHSs 22. There are also a number of regulations and technical guidelines related to environmental quality and other requirements that need to be observed during the assessment of potential impacts as well as during implementation of the project and the key ones are highlighted as follows: - QCVN 01:2009/BYT: National technical regulation on drinking water quality 18 - QCVN 02:2009/BYT: National technical regulation on domestic water quality - QCVN 08-MT:2015/BTNMT– National technical regulation on surface water quality - QCVN 09-MT 2015/BTNMT– National technical regulation on ground water quality - QCVN 14:2008/BTNMT: National technical regulation on domestic wastewater - QCVN 03-MT:2015/BTNTM - National technical regulation on the allowable limits of heavy metals in the soils - QCVN 05:2013/BTNMT: National technical regulation on ambient air quality - QCVN 06:2009/BTNMT: National technical regulation on hazardous substances in ambient air - QCVN 02:2012/BTNMT – National technical regulation on Solid Health Care Waste Incinerator - TCVN 6438:2005 - Road vehicles –Maximum allowable limits of gas emission - QCVN 26:2010/BTNMT: National technical regulation on noise - QCVN 27:2010/BTNMT: National technical regulation on vibration - QCVN 28:2010/BTNMT: National technical regulation on healthcare wastewater - QCVN 07:2009/BTNM: National Technical Regulation on Hazardous waste thresholds - Decision 3733/2002/-BYT October 10, 2002: Promulgating 21 labor hygiene standards, 05 principles and 07 labor hygiene measurements - QCVN 18:2014/BXD – National Technical regulation on safety in construction - Other relevant sector technical regulation and standards 4.2 Applicable the World Bank Safeguard Policies 23. The project has been classified as Category B under OP 4.01. Civil works will be mainly upgrading, and a few with new construction of CHSs, which are expected to be of small scale. Construction activities will exclusively take place within the existing CHSs’ premises , generating only small and localized environmental and social impacts that can be easily identified, mitigated, and managed. No large-scale, significant, and/or irreversible impacts are expected. Overall, the potential negative environmental impacts are associated with the construction phase of the upgrading works and include debris management, worker sanitation, noise, dust emission, use of hazardous materials, and operation phase with generation of solid and liquid healthcare waste especially solid hazardous healthcare waste, and risk of exposure to infection and disease. Further screening of subprojects should be undertaken during implementation to ensure their eligibility, and Category A subprojects will be excluded. The potential impacts have been identified and subsequently addressed during project preparation by the Environmental and Social Management Framework (ESMF). The following World Bank safeguard policies have been triggered, including (a) Environmental Assessment (OP/BP 4.01) and(b) Indigenous Peoples (OP/BP 4.10). Environmental Assessment (OP/BP 4.01)13 24. Environmental Assessment (EA) is an umbrella policy for the Bank’s safeguard policies. The overarching objective is to ensure that Bank-financed projects are environmentally sound and sustainable, and that decision-making is improved through appropriate analysis of actions 13 The full treatment of OP/BP 4.01 can be found at http://web.worldbank.org/WBSITE/EXTERNAL/PROJECTS/EXTPOLICIES/EXTSAFEPOL/0,,contentMDK:2 0543912~menuPK:1286357~pagePK:64168445~piPK:64168309~theSitePK:584435,00.html 19 and of their likely environmental impacts. The EA process is intended to identify, avoid and mitigate potential impacts of Bank operations. It is important to note that EA takes into account the natural environment (air, water, and land); human health and safety; social aspects (involuntary resettlement, indigenous peoples, and physical cultural resources); and trans- boundary and global environmental aspects. EA considers natural and social aspects in an integrated way. 25. This policy is triggered due to the potential adverse impacts associated with activities under Component 1, requiring the identification, mitigation and monitoring of potential adverse environmental and social impacts associated with upgrading, construction, and operation of CHSs. The project has been classified as Category B under OP 4.01 since the anticipated scale of potential adverse environmental or social impacts under the project are site specific, few if any of them are irreversible and in most cases, mitigation measures are readily available. Category A subprojects will be excluded from project financing due to the scope of the expected construction works. The Indigenous Peoples policy (OP/BP 4.10)14 26. The Indigenous Peoples policy is designed to ensure that the development process fully respects the dignity, human rights, economies and cultures of Indigenous Peoples. The policy requires projects to identify impacts on indigenous peoples and develop a plan to address the impacts, both positive and adverse. Projects should be designed with benefits that reflect the cultural preferences of indigenous peoples. The borrower should carry out free, prior, and informed consultation and obtain broad community support for the project. 27. An initial screening conducted by the Bank specialist has confirmed that there are ethnic minority communities as per the Bank OP 4.10 definition to be affected by and benefited from the project hence the World Bank policy on Indigenous Peoples OP/BP 4.10 will be triggered. An Ethnic Minority Planning Framework (EMPF) was prepared guiding procedures to ensure free, prior, and informed consultation with affected ethnic minority communities to ascertain their broad community support, measures to ensure they benefit from project supports and minimize/mitigate any adverse impacts on them. The EMPF outlines and guides the preparation and implementation of subproject Ethnic Minority Development Plans (EMDPs) based on social assessment to be carried out to identify ethnic minorities and potential project impacts on them in the project area. The social assessment (SA) and preparation of the EMPF will be carried out early in project implementation stage to allow adequately inform the preparation of site-specific EMDPs. The World Bank policy on Access to Information15 28. The World Bank Access to Information Policy is intended to ensure that persons and groups affected by the project are kept informed of the project objectives and impacts, and are consulted throughout the project to ensure that their interests are represented. Safeguards documents are disclosed locally in the project areas and the World Bank external website, which includes a resource center in Washington DC and an electronic database, offering access to information on World Bank projects and program to the public. 29. The Bank policy requires that during EA process the Government conducts meaningful consultations with stakeholders such as project-affected groups and local NGOs about the project’s environmental and social aspects, and takes their views into account in the design of the project. All draft and final safeguard instruments are disclosed locally in an accessible place 14 Full treatment of OP/BP 4.10 can be consulted at http://web.worldbank.org/WBSITE/EXTERNAL/PROJECTS/EXTPOLICIES/EXTSAFEPOL/0,,contentMDK:2 0543990~menuPK:1286666~pagePK:64168445~piPK:64168309~theSitePK:584435,00.html 15 The World Bank Policy o Access to Information is available at http://www.worldbank.org/en/access-to- information 20 and in a form and language understandable to key stakeholders, and in English at the Bank external website before the project appraisal begins. World Bank Group Environmental, Health, and Safety Guidelines16 30. The World Bank-financed projects should also take into account the World Bank Group Environmental, Health, and Safety Guidelines (known as the "EHS Guidelines"). The EHS Guidelines are technical reference documents with general and industry-specific examples of Good International Industry Practice. It contains the performance levels and measures that are normally acceptable to the World Bank Group and are generally considered to be achievable in new facilities at reasonable costs by existing technology. The environmental assessment process may recommend alternative (higher or lower) levels or measures, which, if acceptable to the World Bank. The more stringent of the requirements as set out in EHS Guidelines or in the national regulations would apply to the project. The website: www.ifc.org/ehsguidelines will provide detailed information. 4.3 Gap Analysis and Gap Filling Measures 31. The application of environmental assessment policies in Vietnam, as well as various efforts directed to policy harmonization between the GoV and donors, has gradually narrowed the gap between the two systems. However, significant differences remain between the GoV’s environmental policies and those of the World Bank. These differences and proposed gap filling measures are described in Table 1 below. The purpose of inclusion of this table into the ESMF is to ensure that PPMUs fully understand the differences of EA process and mandatory compliance with the World Bank safeguard policy requirements and the GoV’s environmental regulations given that PPMUs are not aware of and will have to comply with both. 16 The EHS Guidelines are available at www.ifc.org/ehsguidelines. 21 Table 1. Summary of the World Bank and National EA Processes and proposed gap mitigation for the project EA WB (stipulating in OP/BP 4.01 on Viet Nam (stipulating in Decree 18/2015/ND- Process Gap Filling Measures Environmental Assessment) CP, Circular 27/2015/TT-BTNMT Stage Screening - Categories (A, B, C, FI) - Categories: I, II, III and IV of Decree - Use the World Bank’s - Non-prescriptive on a case by case basis for 18/2015/ND-CP. discretionary (on a project-by- categorization, safeguards policies - Prescriptive, fixed and regulated criteria in project basis) approaches in application, and EA instrument Annex I, II and III screening of projects the identification. significance of its impacts, and - List of projects subject to requirements of SEA subsequently to ascertain the - The World Bank will classify a proposed and EIA report submission and approval. project’s EA category. project into one of four categories including - All projects are not listed. A, B, C, or FI depending upon the type, - Examine the magnitude and - Normally the project owners self-screen the significance of the project location, sensitivity, and scale of the project project based on the categorization indicated in impacts based on the project type and the nature and magnitude of its potential Decree 18/2015 and consult the Provincial and scale, project location, environmental impacts. Department of Natural Resources and sensitivity of environmental and â–ª Category A: Full EIA is required. In some Environment (DONRE) or Vietnam social issues, and nature and cases, ESMF is also required Environment Administration (VEA) for the magnitude of potential impacts. â–ª Category B: ESIA, ESMF, or ESMP is appropriate classification and EA report required. In most cases, ESMF and/or requirement of the project, such as: ESMP is required â–ª Project falls into Annexes I, II, III: SEA or â–ª Category C: no EA action is required. EIA is required â–ª Category FI: ESMF is the most commonly â–ª Project falls into Annex IV: no EIA and used instrument. In some instances, Environmental Protection Plan (EPP) is details and impacts of sub-projects have required been identified by appraisal, the FI â–ª Project does not fall into Annexes I, II, III prepares specific instruments based on the and IV: EPP is required frameworks, such as ESIA or ESMP. 22 EA WB (stipulating in OP/BP 4.01 on Viet Nam (stipulating in Decree 18/2015/ND- Process Gap Filling Measures Environmental Assessment) CP, Circular 27/2015/TT-BTNMT Stage EA - Depending on the project’s impact, a range of - The type of EA instruments such as SEA, EIA Follow the World Bank instrument instruments are used to meet the World or EPP is determined based on Annex I, II, III requirements on the type of EA s Bank’s requirement, these include: ESMF; and IV of Decree 18/2015/ND-CP. instrument needed specific EA; ESMPs, sectoral & regional EA; 4.3.1 SEA; hazard or risk assessment; environmental audits. The World Bank provides general guidance for implementation of each instrument. Scope - The World Bank helps the Borrower draft the - TORs for EA are not required. TORs for REA, SEA, ESMF, TOR for EA report and identifies the scope - Normally after consultation with the local ESIA, and ESMP are a good of EA, procedures, schedule and outline of DONRE or VEA for the EA category, the practice to follow. the EA report. project owner will proceed with EA report - Follow the World Bank’s TORs, - For Category A projects, ESIA TOR is preparation. scoping, and consultation required, and scoping and consultation are requirements. conducted for preparation of the TORs for 4.3.2 the EA report. Public - During EA process, the Borrower consults - The project owner shall consult with the - EA consultation as per the consultatio project-affected groups and local NGOs People’s Committee of communes, wards and government’s EA regulation is n about the project’s environmental aspects towns (hereinafter referred to as communes) not enough and the Borrower and takes their views into account. where the project is carried out, with and its consultant need to follow - For Category A projects, the Borrower organizations or community under the direct the World Bank’s requirements consults these groups at least twice: (a) impact of the project; research and receive on consultation and disclosure shortly after environmental screening and objective opinions and reasonable requests of of information during before the TORs for the EA are finalized; and relevant entities in order to minimize the EAprocess. (b) once a draft EA report is prepared. In negative effects of the project on the natural - Good consultation brings addition, the Borrower consults with such environment, biodiversity and community benefits to the project design groups throughout project implementation as health. 23 EA WB (stipulating in OP/BP 4.01 on Viet Nam (stipulating in Decree 18/2015/ND- Process Gap Filling Measures Environmental Assessment) CP, Circular 27/2015/TT-BTNMT Stage necessary to address EA-related issues that - The People’s Committee of the commune and contributes to project affect them. where the project is carried out and the environmental outcomes - For Category B project, at least one public organizations under direct impact of the consultation needs to be conducted. project shall be consulted. The project owner shall send EIA reports to the People’s - For meaningful consultations, the Borrower Committee of the commune where the project provides relevant project documents in a is carried out and organizations under the timely manner prior to consultation in a form direct impact of the project together with the and language that are understandable and written requests for opinions. Within 15 accessible to the group being consulted. working days, from the date on which the EIA - Minutes of the public meetings are included reports are received, the People’s Committee in the reports. of the commune and organizations under the direct impact of the project shall send their responses if they do not approve the project. - The consultation with the community under the direct impact of the project shall be carried out in the form of community meeting co- chaired by project owner and the People’s Committee of the commune where the project is carried out together with the participation of representatives of Vietnamese Fatherland Front of communes, socio-political organizations, socio-professional organizations, neighborhoods, villages convened by the People’s Committee of the commune. All opinions of delegates attending the meeting must be sufficiently and honestly stated in the meeting minutes. 24 EA WB (stipulating in OP/BP 4.01 on Viet Nam (stipulating in Decree 18/2015/ND- Process Gap Filling Measures Environmental Assessment) CP, Circular 27/2015/TT-BTNMT Stage Disclosure Before the World Bank proceeds to project - After an EIA report is approved, the project Follow the World Bank’s Policy appraisal the EA report must be made available owner shall formulate, approve and publicly on Access to Information and at public place accessible for project-affected disclose its EMP at the office of the commune- Policy on disclosure of project groups and local NGOs. Once the World Bank level People’s Committee of the locality in information, including EA officially receives the report, it will make the which consultation of the community is made instruments. EA report in English available to the public for people’s information, examination and through the Bank external website. oversight. (Article 16, Decree 18/2015). Independe - For category A project, the Borrower retains - Not regulated in Vietnam policies. Follow the World Bank nt Expert independent EA experts not affiliated with - The project owner shall have to make or hire a requirements to avoid conflict of the project to carry out EA. consultancy agency which satisfies the interest - For category A projects of high risk or multi- conditions specified in Clause 1, Article 13 of dimensional environmental concerns, the Decree No. 18/2015, for making EIA reports. Borrower should also engage an advisory Project owners or consultancy service units panel of independent, internationally must fully meet the following conditions: (i) recognized environmental specialists to staff responsible for EIA must have at least BA advise on aspects of the project relevant to degree and EIA consultancy certificate; (ii) EA. have specialized staff involved in the project - Experts/consulting firm will be selected with a university or higher degree; (iii) Having through bid process under strict observation laboratories and testing equipment certified as of the World Bank. qualified for measuring, sampling, processing and analysis of environmental samples for environmental impact assessment of the project; In the absence of a laboratory, calibration equipment meets the requirements, there must be a contract with a qualified unit. EA review The Bank reviews the findings and - The Ministry of Natural Resources and - In addition to the Government process recommendations of the EA to determine Environment shall review and approve the EIA requirements, follow the World 25 EA WB (stipulating in OP/BP 4.01 on Viet Nam (stipulating in Decree 18/2015/ND- Process Gap Filling Measures Environmental Assessment) CP, Circular 27/2015/TT-BTNMT Stage whether they provide an adequate basis for reports on projects prescribed in Appendix III Bank’s review and clearance processing the project for Bank financing. of this Decree, except for projects subject to procedures. When the borrower has completed or partially national defense and security secrets. completed EA work prior to the Bank's - Ministries, ministerial agencies shall review involvement in a project, the Bank reviews the and approve the EIA reports on projects under EA to ensure its consistency with this policy. their competence in approval for investment, The Bank may, if appropriate, require except for projects in Appendix III of this additional EA work, including public Decree; consultation and disclosure. - The People’s Committee of the province shall 4.3.3 assess and approve EIA reports on projects in the province, except for projects prescribed above. - The appraisal will take place within 45 working days at MONRE level and 30 working days at DONRE level and 5 working days at district level for after receipt of a full eligible EIA or EPP. Number - Number of copies are not specified. - The project owner has to submit at least seven Follow the World Bank’s and - Language requirement: English and copies of EIA report (depend on the number of guidance and the Government language Vietnamese. EA reports in Vietnamese are appraisal council members) and one copy of the requirements of EIA required for in-country disclosure and Feasibility Study or the Economic-Technical required English is required for disclosure at the Bank report for the proposed project. for external website appraisal Content of - For Category A projects, the content of an The content of an EA report should be in line The content of an EA report should EIA report EA report follows Annex B of OP 4.01. with Circular No. 27/2015/TT-BTNMT. satisfy both the Bank policy 26 EA WB (stipulating in OP/BP 4.01 on Viet Nam (stipulating in Decree 18/2015/ND- Process Gap Filling Measures Environmental Assessment) CP, Circular 27/2015/TT-BTNMT Stage - The scope of EA for a Category B project requirements and the GoV’s may vary from project to project, but it is regulations. narrower than that of Category A EA. The EMP is an integral part of Category A EAs (irrespective of other instruments used).EAs for Category B projects may also result in an ESMP with the content outlined in Annex C of OP 4.01. EA - During project implementation, the World - The local DONRE is entrusted to supervise the - Project environmental supervisio Bank supervises the project’s environmental environmental compliance of the project. management system needs to be n aspects on the basis of the environmental - By the end of project construction stage, the established to monitor and provisions and the Borrower’s reporting Environmental Management Agencies will supervise safeguards compliance arrangement agreed in the loan agreement coordinate with Construction Management during implementation. and described in the other project Agencies to supervise the compliance of - Follow requirements in project documentation, to determine whether the environmental management activities stated in Loan Agreement, EMP, and Borrower’s compliance with environmental EA study. contract with contractor to covenant (primarily with EMP) is monitor and supervise satisfactory. If compliance is not satisfactory, safeguards compliance. the World Bank will discuss with the Borrower action necessary to comply. 27 5. POTENTIAL ENVIRONMETAL AND SOCIAL IMPACTS 5.1 Potential Positive Impacts 32. The project will contribute to the attainment of the objectives set out in the (new) Vietnam Country Partnership Framework (CPF) FY18-22, in particular Objective 6 which is to “improve access to quality public and private health services and reduce malnutritionâ€? . This objective explicitly includes the intention to improve the quality of health care service delivery, especially at the primary care level, including “strengthening the grassroots (district and commune) health system in terms of availability/access, quality, integration, and transparency and voiceâ€?. This objective also includes the need to improve the efficiency and sustainability of health financing and service delivery arrangements, including (among others) reducing the over-reliance on hospital-centered delivery, supporting health insurance reform, enhancing financial protection from out-of-pocket health spending, and creating an enabling environment for private sector participation. In this regard, the project will also be relevant to bringing about one of the five strategic shifts envisaged under the CPF, namely achieving “the financial sustainability of public services and transfersâ€?. To a lesser extent, the project will also contribute to the achievement of two other key strategic shifts envisaged in the CPF, namely the strategic shift towards more private sector development and participations across sectors and, also, ethnic minority poverty reduction. 5.2 Potential Negative Impacts 33. Potential negative environmental and social impacts are mainly connected to the CHS construction and operation activities supported by the project under Component 1. The main impacts are described in the following paragraphs while specific impacts and mitigation measures for each physical infrastructure investment will be identified and assessed during project implementation. Upgrading and new construction of Commune Health Stations (CHSs) will take place within the existing CHSs’ premises. 34. The potential adverse social and environmental impacts would be those associated with construction and operation of the proposed physical investments under Component 1. These include commonly known construction impacts and risks, such as (a) safety risks related to unexploded ordinances left from the war; (b) loss of vegetation cover and trees (c) increased level of dust, noise, and vibration; (d) pollution risks related to removal and disposal of substantial quantities of non-hazardous construction materials associated with the demolition of some existing structures (e.g. existing communal health stations) consisting of debris; (e) traffic disturbance and increased traffic accident risks; (f) interruption of health services; (g) disturbance to daily socioeconomic activities in the project areas; (h) health and safety issues related to the public and the workers at construction sites; (i) social impacts associated with business disruption by construction-related activities and mobilization of workers to the sites; and (j) impact on ethnic minority communities in the project areas. (a) During pre-construction phase 35. Some demolition activities of the existing CHS structures would generate dust, noise, debris and accident risk. For new construction, UXO clearance may be required depending upon the location of the CHSs. However, it is known that new construction will take place within the existing CHSs’ premises. Thus, the adverse impact level is small, and the environmental risk is considered low at this stage. (b) During construction phase 36. Main impacts would include dust emission, generation of noise, vibration, waste, accident risks, and disturbance to local residents and other social impacts. Given small scale and 28 simplicity of civil works relating to upgrading and construction of CHSs, the adverse impacts are considered small. The following describes more detail of adverse impacts: • Noise and vibration: During construction activities, noise and vibration may be caused by the operation of pile drivers, earth moving and excavation equipment, concrete mixers, cranes and the transportation of equipment, materials and people. • Air quality: Construction activities may generate emission of fugitive dust caused by a combination of on-site excavation and movement of earth materials, contact of construction machinery with bare soil, and exposure of bare soil and soil piles to wind. A secondary source of emissions may include exhaust from diesel engines of earth moving equipment, as well as from open burning of solid waste on-site. • Waste: Non-hazardous solid waste generated at construction sites includes excess fill materials from grading and excavation activities, scrap wood and metals, and small concrete spills. Hazardous waste associated with construction activities may pose the potential for release of petroleum-based products, such as lubricants, hydraulic fluids, or fuels during their storage, transfer, or use in equipment. • Occupational health and safety: Over-exertion, and ergonomic injuries and illnesses, such as repetitive motion, over-exertion, and manual handling, are among the most common causes of injuries. Falls from elevation associated with working with ladders, scaffolding, and partially built or demolished structures are among the most common cause of fatal or permanent disabling injury. Slips and falls on the same elevation associated with poor housekeeping, such as excessive waste debris, loose construction materials, liquid spills, and uncontrolled use of electrical cords and ropes on the ground, are also among the most frequent cause of lost time accidents. Construction activities may pose hazards related to the potential fall of materials or tools, as well as ejection of solid particles from abrasive or other types of power tools which can result in injury to the head, eyes, and extremities. Vehicle traffic and use of lifting equipment in the movement of machinery and materials on a construction site may pose temporary hazards, such as physical contact, spills, dust, emissions, and noise. Construction sites may pose a risk of exposure to dust, chemicals, hazardous or flammable materials, and wastes in a combination of liquid, solid, or gaseous forms. • Community health and safety: The community may be affected by physical, chemical, or other hazards associated with sites under construction. Risks may arise from inadvertent or intentional trespassing, including potential contact with hazardous materials, contaminated soils and other environmental media, buildings that are vacant or under construction, or excavations and structures which may pose falling and entrapment hazards. Increased incidence of communicable and vector-borne diseases attributable to construction activities represents a potentially serious health threat to project personnel and residents of local communities. Construction activities may result in a significant increase in movement of heavy vehicles for the transport of construction materials and equipment increasing the risk of traffic-related accidents and injuries to workers and local communities. • Interruption to health services. It is envisaged that civil works would possibly cause a temporary interruption of access to health care services at commune health stations. (c) Potential impacts during operation phase 37. The main negative impacts at this stage is connected to operation of health care facilities. For example, operation of communal health stations or district hospitals/health care centers would generate wastes including solid domestic and healthcare wastes and wastewater. If the 29 waste is not properly managed it would cause adverse impacts on the human health and environment e.g. soil, air and water. In addition, there is a risk of exposure to infection and disease, waste gas, and radiation. 38. Unlike the hospitals that focus on medical examination and treatment, CHSs play an important role in primary health care and protection for the people, carrying out a series of prevention activities to the whole community in the area. Besides, CHSs still perform the role of medical examination and treatment center with an average of 11-12 patients per day. All of the above activities generate solid health care waste with different amount and categories, but the most common is sharp infection and general wastes. 39. Most of CHSs do not have the standard incinerator or landfill. For CHSs located near the district town or city where the well-designed incinerators or landfills are available, solid HCW is collected and transported by local environmental unit through a contract for treatment by incineration or landfilling. For CHSs located in remote areas where access to standard incinerators or landfills is impossible, solid HCW is usually openly burned and landfilled onsite within the premises of CHS. Some CHSs use primitive incinerators. Burning, incineration or landfilling of solid HCW especially hazardous HCW onsite would lead to air and water pollution. Thus, upgrading or new construction of CHSs supported by the project should take into account the standard design sepcifications issued by MOH and MONRE to ensure that solid HCW is effectively treated. 40. Solid health care waste: The majority of healthcare waste is general waste which is similar to domestic waste. Only 20% of solid healthcare waste is hazardous. According to MOH’s survey, generation of hazardous health care waste (HCW) from a CHS is about 0.08 kg/bed/day. A typical CHS generates about 0.5 kg of hazardous HCW per day and an inter-commune polyclinic generates from 1 kg to 2 kg of hazardous HCW per day. 41. Wastewater from HCFs often has a quality similar to urban wastewater. Contaminated wastewater may result from discharges from medical wards and operating theaters (e.g. body fluids and excreta, anatomical waste), laboratories (e.g. microbiological cultures, stocks of infectious agents), pharmaceutical and chemical stores; cleaning activities (e.g. waste storage rooms), and x-ray development facilities. Wastewater may also result from treatment disposal technologies and techniques, including autoclaving, microwave irradiation, chemical disinfection, and incineration (e.g. treatment of flue gas using wet scrubbers which may contain suspended solids, mercury, other heavy metals, chlorides, and sulfates). For hospital, wastewater is collected and conveyed to wastewater treatment plant (WTP) which is compulsory constructed and operated as per Decision 43/2007/QD-BYT and Joint Circular No. 58 / 2015 / TTLT-BYT-BTNMT. 42. The volume of health care wastewater from a CHS is small, approximately 1m3 per day and has the same basic component as the domestic wastewater. Currently, it is collected into a septic tank for anaerobic treatment and then disinfection before discharged into the local sewerage sytem. This method is technically and financially feasible. However, not all CHSs have the disinfection system, especially CHSs located in remoted areas. Thus, new construction or upgrading of CHSs supported by the project will be added with the wastewater treatment system in accordance with Decision 43/2007/QD-BYT and Joint Circular No. 58 / 2015 / TTLT-BYT-BTNMT and CHS operator will be provided with training on operation and maintenance of wastewater treatment system. 43. Depending on the effectiveness of hazardous waste management practices (in particular waste segregation strategies described above), hazardous health care wastes may enter the wastewater stream, including microbiological pathogens (wastewater with a high content of 30 enteric pathogens, including bacteria, viruses, and helminthes / parasitic worms), hazardous chemicals, pharmaceuticals, and radioactive isotopes. 44. . 45. Hazards of health care waste. Exposure to hazardous health care waste can result in disease and/or injury. All individuals exposed to hazardous health care waste are potentially at risk, including those within health care establishments and those outside these sources. The main groups at risk are the following: • Health staff: doctors, nurses, technician • Patients visiting the health care facilities • Patient relatives and visitors • Workers in waste disposal facilities including scavengers 46. Pathogens in infectious waste and wastewater may enter the human body by a number of routes: through a puncture, abrasion, or cut in the skin; through the mucous membranes; by inhalation; by ingestion. The existence in healthcare establishments of bacteria resistant to antibiotics and chemical disinfectants may also contribute to the hazards created by poorly managed health-care waste. Sharps may not only cause cuts and punctures but also infect these wounds if they are contaminated with pathogens. Sharp injuries are most popular accidents in health facilities. Sharp injury is the main transmission way of several dangerous infectious diseases such as HIV, HBV, and HCV. About 80% of occupational infections of HIV, HBV, HCV are resulted from injuries by contaminated needles and sharps. The principal area of concern of health care wastewater is high content of enteric pathogens which are easily transmitted through water. 47. In addition to health and environmental impacts, the general public is very sensitive about the visual impact of anatomical waste that is recognizable human body parts, including fetuses. In no circumstances it is acceptable to dispose of anatomical waste inappropriately, such as on a landfill. 48. Unless health care waste is managed strictly, it causes the environmental pollution and health risk. Given small amount of hazardous HCW and wastewater from primary health care (PHC) facilities, the environmental and health risks and impacts are considered moderate. 49. Fire risk: The risk of fire in health care facilities is due to the storage, handling, and presence of chemicals, pressurized gases, boards, plastics, and other flammable substrates. 50. Exposure to Infections / Diseases: Health care providers and personnel may be exposed to general infections, blood-borne pathogens, and other potential infectious materials during care and treatment, as well as during collection, handling, treatment, and disposal of health care waste. (d) Medical equipment supply 51. It is not expected that medical equipment supply financed by the project would generate environmental and health risks as medical equipment provided to CHSs would be very simple and basic medical equipment with the aim of ensuring effective implementation of functions and tasks of the primary examination and cure in family medicine principle. Some test equipment will be provided to DHCs. The most complicated equipment is portable ultrasound machine which would be provided to CHSs. Absolutely, there would be no any medical equipment financed generating the environmental and health hazards or risks. 5.3 Social issues related to ethnic minority groups 52. A social assessment (SA), conducted in Son La, Quang Tri and Tra Vinh provinces, found that the project has broad support from various stakeholders and communities, including those 31 from the EM groups. The EM groups of the H’mong, Thai, XinhMun, Paco, Bru Van Kieu, and Khmer were among those consulted and overall feedback was very positive. Generally, respondents value the important role of CHS in care of their health due to more convenient and cost-efficient location, more convenient visits and care by relatives, more timely service, and familiarity with health staff (thus avoiding language barriers and increasing their comfort around healthcare providers). However, in some communities, local people prefer a district hospital for check-ups, treatment and birth deliveries, especially when the hospital is not far from their communities. They believe that district hospitals have better capacity and that they can get better medicines there. In addition, district hospitals are preferred over the CHS for birth deliveries for a number of reasons, including a lack of delivery facilities and qualified attendants to handle complicated deliveries in CHS. 53. The SA also examines the need for health services among the EM groups. Gynecological diseases and child malnutrition are cited as common diseases among the EM groups, while home delivery remains common and hypertension and diabetes emerging concerns. During fieldtrip to DakRong district in Quang Tri province, many as 70 percent of the women who came CHS for check-ups were found to have contracted gynecological diseases. Local health staff believed that gynecological diseases are caused by a lack of knowledge of hygienic practices and insanitary working conditions. Meanwhile, the common causes of child malnutrition, some of which are related to social norms, include under age marriage, premature delivery, mothers’ malnutrition, lack of breastfeeding due to mothers’ early labor after delivery, inadequate feeding practices, and poor sanitation. Home deliveries remain common in the remote mountainous areas in Quang Tri and Son La. Hypertension and diabetes are described as emerging diseases as a result of changing lifestyles but have not received due attention among many rural people. Local people attributed the situation to a lack of awareness of health risks and unavailability of monitoring and management services in CHS which they can access in a more convenient manner. 32 6. MEASURES TO MANAGE ADVERSE ENVIRONMENTAL AND SOCIAL RISKS AND IMPACTS 6.1 Design stage 54. PPMU should ensure that technical design of CHSs takes into account comments from consultations and complies with Decision no. 4667/QD-BYT dated 7 November 2014 on issuance of a set of national criteria on community health until 2020 and Decision no. 2271/2002/QD-BYT dated 17 June 2002 on design standard for CHSs, such as the land area for construction, water supply, drainage, wastewater and solid waste treatment, fire-fighting, etc. 6.2 Preconstruction stage 55. In order to mitigate UXO risk, UXO clearance for new construction of Commune Health Stations should be completed before handing over the site to construction contractors. PPMU should contract with the specialized military unit to conduct probe and clearance of UXO. UXO clearance should be carried out in accordance with Circular 146/2007/TT-BQP on guiding the implementation of the prime minister’s decision no.96/2006/QD-TTg dated May 4, 2006 on the management and execution of UXO clearance and Circular 121/2012/TT-BQP on issuing QCVN 01:2012/BQP on national technical regulation on UXO clearance. 56. Dust, noise and waste (debris) generated from demolition should be managed in line with ECOP. 6.3 Construction stage 57. Mitigation measures have been designed proportionate to the nature and magnitude of potential negative environmental and social risks and impacts. Namely, an ECOP as annex of this ESMF that consists of a set of measures to minimize and mitigate adverse environmental and social risks and impacts applies to address construction-related impacts associated with the subproject of the upgrading of the existing CHSs and new construction of CHSs given small scale and simplicity of civil works. On the GoV side, an environmental protection plan (EPP) will be prepared by PPMU that also covers a set of mitigation measures consistent with environmental codes of practice (ECOP) for adverse impacts associated with civil works. 58. For upgrading and construction of each CHS, there might be site-specific impacts that require site-specific mitigation measures. The site-specific impacts and corresponding mitigation measures would be determined during technical preparation and detailed design of each CHS. All mitigation measures for construction-related impacts and site-specific impacts shall be incorporated into bidding and contract documents for safeguard compliance purpose. 59. In case the project applies the Standard Procurement Document (SPD), the Bidder shall submit the following additional documents in its Bid, including Code of Conduct, Environment, Social, Health, and Safety (ESHS) and Management Strategies and Implementation Plans (MSIP) to manage the (ESHS) risks. The Contractor shall be required to submit to PPMU/CSC for approval, and subsequently implement, the Contractor’s Environment and Social Management Plan (C-ESMP), in accordance with the Particular Conditions of Contract Sub- Clause 16.1, that includes the agreed Management Strategies and Implementation Plans. The C-ESMP includes setting up a grievance redress mechanism (GRM), and initiate and maintain close relations and consultation with local authorities and communities. 60. The PPMUs will closely supervise and monitor contractor’s safeguards performance and ensure that the construction contractors implement civil works in compliance with Environmental, Social, Health and Safety Requirements. Consultation with local people especially affected people is needed during construction. 33 61. Monitoring of environmental quality during construction is useful to ensure the effectiveness of the mitigation measures being implemented by construction contractors. The monitoring should be proportionate to the subproject’s environmental and social risks and impacts. MOH CPMU should define the need for environmental quality monitoring with specific locations, monitoring parameters, frequency, and an estimated cost proportionate to environmental and social risks and impacts. 62. Measures to mitigate impacts on primary health care services at commune health stations during construction would be set up based on careful consultations with leaders of CHSs, designers, and local authorities. The agreed measures shall ensure that primary health care services are not interrupted and local people access to the health care services at any time. These measures shall be reflected in the mitigation plan. 6.4 Operation stage 63. The Ministry of Health issued the Decision No. 43/2007 / QD-BYT on the regulation on management of healthcare waste on November 30, 2007 and in 2015, together with the Ministry of Natural Resources and Environment issued Joint Circular No. 58 / 2015 / TTLT-BYT- BTNMT. This is considered as the guideline for all actions of waste management, as well as requirements on infrastructure, material, means and tools to serve each action. Therefore, in order to implement solid healthcare waste management according to regulations, medical staff should be trained regularly based on the content of these documents. 64. Waste from health care facilities (HCF) can be divided into two separate groups. The first consists of general waste, similar in composition to domestic waste, generated during administrative, housekeeping, and maintenance functions. The second group consists of specific categories of hazardous health care waste, as detailed in Table 2. 65. Health care facilities should establish, operate and maintain a healthcare waste management plan (HWMP) adequate for the scale and type of activities and identified hazards. Facility operators should undertake regular assessment of waste generation quantities and categories to facilitate waste management planning, and investigate opportunities for waste minimization on a continuous basis. Each CHS should actively set up objectives, solutions, activities, as well as projected resources (including human resources, materials and budget) for solid HCW management activities. The contents of the plan should be based on the actual situation of CHS. In cases where the annual budget for activities is not available or not enough, the CHS management board should initiate a proposal for funding from the commune people’s committee or district health center. The following paragraphs present good international practices for healthcare waste and health risk management 17 that should be followed by operators of CHSs. 66. Waste Minimization, Reuse, and Recycling: Facilities should consider practices and procedures to minimize waste generation, without sacrificing patient hygiene and safety considerations, including: • Source reduction measures: o Consider options for product / material substitution to avoid products containing hazardous materials that require the product to be disposed as hazardous or special waste (e.g. mercury or aerosol cans), and preferring products with less packaging or products that weigh less than comparable products that perform the same function o Use of physical rather than chemical cleaning practices (e.g. using microfiber mops and cloths), where such practices do not affect disinfection and meet relevant standards for hygiene and patient safety 17 World Bank Group Environment, Health, and Safety Guidelines (WBG EHS Guidelines) 34 • Waste toxicity reduction measures: o Consider options for product/material substitution for equipment containing mercury or other hazardous chemicals; products that may become hazardous waste when disposed; products made of polyvinyl chloride (PVC); halogenated compounds; products that off-gas volatile organic compounds (VOCs), or products that contain persistent, bio-accumulative and toxic (PBT) compounds; products that contain substances which are carcinogenic, mutagenic or reproductive toxins (CMR) • Use of efficient stock management practices and monitoring (e.g. for chemical and pharmaceutical stocks), including: o Small / frequent orders for products that spoil quickly and strict monitoring of expiry dates o Complete use of old product before new stock is used • Maximization of safe equipment reuse practices, including: o Reuse of equipment following sterilization and disinfection (e.g. sharps containers) 67. Waste Segregation Strategies: At the point of generation, waste should be identified and segregated. Non-hazardous waste, such as paper and cardboard, glass, aluminum and plastic, should be collected separately and recycled. Food waste should be segregated and composted. Infectious and / or hazardous wastes should be identified and segregated according to its category using a color-coded system. If different types of waste are mixed accidentally, waste should be treated as hazardous. Other segregation considerations include the following • Avoid mixing general health care waste with hazardous health care waste to reduce disposal costs; • Segregate waste containing mercury for special disposal. Management of mercury containing products and associated waste should be conducted as part of a plan involving specific personnel training in segregation and clean up procedures; • Segregate waste with a high content of heavy metals (e.g. cadmium, thallium, arsenic, lead) to avoid entry into wastewater streams; • Separate residual chemicals from containers and remove to proper disposal containers to reduce generation of contaminated wastewater. Different types of hazardous chemicals should not be mixed; • Establish procedures and mechanisms to provide for separate collection of urine, feces, blood, vomits, and other wastes from patients treated with genotoxic drugs. Such wastes are hazardous and should be treated accordingly; • Aerosol cans and other gas containers should be segregated to avoid disposal via incineration and related explosion hazard; • Segregate health care products containing PVC to avoid disposal via incineration (see Air Emissions below) or in landfills. 68. On-site Handling, Collection, Transport and Storage: • Seal and replace waste bags and containers when they are approximately three quarters full. Full bags and containers should be replaced immediately; • Identify and label waste bags and containers properly prior to removal; • Transport waste to storage areas on designated trolleys / carts, which should be cleaned and disinfected regularly; • Waste storage areas should be located within the facility and sized to the quantities of waste generated, with the following design considerations: o Hard, impermeable floor with drainage, and designed for cleaning / disinfection with available water supply o Secured by locks with restricted access 35 o Designed for access and regular cleaning by authorized cleaning staff and vehicles o Protected from sun, and inaccessible to animals / rodents o Equipped with appropriate lighting and ventilation o Segregated from food supplies and preparation areas o Equipped with supplies of protective clothing, and spare bags / containers • Unless refrigerated storage is possible, storage times between generation and treatment of waste should not exceed the following: o Temperate climate: 72 hours in winter, 48 hours in summer o Warm climate: 48 hours during cool season, 24 hours during hot season • Store mercury separately in sealed and impermeable containers in a secure location; • Store cytotoxic waste separately from other waste in a secure location; • Store radioactive waste in containers to limit dispersion, and secure behind lead shields. 69. Transport to External Facilities: • Transport packaging for infectious waste should include an inner, watertight layer of metal or plastic with a leak-proof seal. Outer packaging should be of adequate strength and capacity for the specific type and volume of waste; • Packaging containers for sharps should be puncture-proof; • Waste should be labeled appropriately, noting the substance class, packaging symbol (e.g. infectious waste, radioactive waste), waste category, mass / volume, place of origin within hospital, and final destination; • Transport vehicles should be dedicated to waste and the vehicle compartments carrying waste sealed 70. Treatment and Disposal Options: Facilities receiving hazardous health care waste should have all applicable permits and capacity to handle specific types of health care waste. Wastes from each category should be treated according to the treatment methods and technologies described in Table 2. When selecting a waste disposal technology, operators should consider other potential health and environmental issues that may be generated by the treatment. The main types of treatment and disposal technologies and techniques available for health care waste are described below, which are in accordance with the relevant GoV’s regulations on health care waste management Operator of CHS may choose one or more of the following treatment and disposal options. During implementation, CHS healthcare waste management plan will specify treatment methods to be applied. • Incineration is a high temperature dry oxidation process to reduce organic, combustible waste to significantly smaller quantities of inorganic, incombustible matter. Incineration may produce gaseous air emissions, ash residues, and wastewater. Depending on the amount of waste generated and the other factors, HCFs may operate on-site incinerators, or waste may be transported to an off-site incineration facilities. Incinerators should have permits to accept health care waste and be properly operated and maintained. As per Decision no. 43/2007/QD-BYT dated 30 November 2011 on regulation on healthcare waste management, incineration is one among methods of treatment of hazardous healthcare waste. Thus, incineration will be also applied to treatment of hazardous healthcare waste generated from CHS. For CHSs located near the district town and city center where a standard concentrated incinerator is available, solid hazardous HCW generated from CHS should be collected and transported to there for incineration. For CHSs located in remote areas where access to a standard concentrated incinerator is not possible, upgrading and new construction of CHSs supported by the project should take into account the requirements of Decision no. 43/2007/QD-BYT on solid waste treatment by incineration onsite and the incinerator design must comply with QCVN 02:2012/BTNMT (National Technical Regulation on Solid Health Care Waste 36 Incinerator). • Chemical disinfection involves the addition of chemicals to kill pathogens in health care waste. Waste should be mechanically shredded prior to treatment. Treatment involves the use and handling of hazardous chemicals, in addition to disposal of hazardous residues following treatment. • Wet thermal treatment disinfects waste by exposing shredded waste to high temperatures / pressure steam inside an exposure tank. Wastewater discharges and odor may result. Autoclaving is a type of wet thermal disinfection process typically used to sterilize reusable medical equipment. Dry thermal disinfection involves the shredding, heating, and compacting waste in a rotating auger. Air emissions and wastewater may be generated, and residues require disposal. • Microwave irradiation involves the destruction of microorganisms through the microwave heating action of water contained within the waste. Following irradiation, waste is compacted and disposed of as part of the municipal waste stream. Contaminated wastewater may also be generated. • Land disposal involves the disposal of health care waste into landfill facilities. Properly designed and operated sanitary landfills will protect against air and groundwater contamination. Disposal of waste into open dumps is not considered good practice and should be avoided. Pretreatment of waste prior to land disposal may involve encapsulation (filling containers with waste and an immobilizing material and sealing the containers). • Inertization involves mixing waste with substances (e.g. cement) to minimize leaching of toxic waste into ground or surface water. 37 Table 2: Treatment and disposal methods for categories of health care waste18 Type of waste Summary of treatment and disposal options / notes Infectious waste: Includes waste suspected to Waste Segregation Strategy: Yellow or red colored bag/container, marked “infectiousâ€? with contain pathogens (e.g. bacteria, viruses, international infectious symbol. Strong, leak proof plastic bag, or container capable of being parasites, or fungi) in sufficient concentration autoclaved. or quantity to cause disease in susceptible hosts. Treatment: Chemical disinfection; Wet thermal treatment; Microwave irradiation; Safe burial on Includes pathological and anatomical material hospital premises; Sanitary landfill; Incineration (Rotary kiln; pyrolytic incinerator; single-chamber (e.g. tissues, organs, body parts, human fetuses, incinerator; drum or brick incinerator) animal carcasses, blood, and other body fluids), • Highly infectious waste, such as cultures from lab work, should be sterilized using wet thermal clothes, dressings, equipment / instruments, and treatment, such as autoclaving. other items that may have come into contact • Anatomical waste should be treated using Incineration (Rotary kiln; pyrolytic incinerator; with infectious materials. single-chamber incinerator; drum or brick incinerator). Sharps: Includes needles, scalpels, blades, Waste Segregation Strategy: Yellow or red color code, marked “Sharpsâ€?. Rigid, impermeable, knives, infusion sets, saws, broken glass, and puncture-proof container (e.g. steel or hard plastic) with cover. Sharps containers should be placed nails etc. in a sealed, yellow bag labeled “infectious wasteâ€?. Treatment: Chemical disinfection; Wet thermal treatment; Microwave irradiation; Encapsulation; Safe burial on hospital premises; Incineration (Rotary kiln; pyrolytic incinerator; single-chamber incinerator; drum or brick incinerator)e • Following incineration, residues should be landfilled. • Sharps disinfected with chlorinated solutions should not be incinerated due to risk of generating POPs (persistent organic pollutants). • Needles and syringes should undergo mechanical mutilation (e.g. milling or crushing) prior to wet thermal treatment Pharmaceutical waste: Includes expired, Waste Segregation Strategy: Brown bag / container. Leak-proof plastic bag or container. unused, spoiled, and contaminated Treatment: Sanitary landfillª; Encapsulationª; Discharge to sewerª; Return expired drugs to supplier; pharmaceutical products, drugs, vaccines, and Incineration (Rotary kiln; pyrolytic incineratorª); Safe burial on hospital premisesª as a last resort. sera that are no longer needed, including • Small quantities: Landfill disposal acceptable, however cytotoxic and narcotic drugs should not containers and other potentially contaminated be landfilled. Discharge to sewer only for mild, liquid pharmaceuticals, not antibiotics or materials (e.g. drug bottles vials, tubing etc.). cytotoxic drugs, and into a large water flow. Incineration acceptable in pyrolytic or rotary kiln incinerators, provided pharmaceuticals do not exceed 1 percent of total waste to avoid hazardous 18 WBG EHS Guidelines 38 air emissions. Intravenous fluids (e.g. salts, amino acids) should be landfilled or discharged to sewer. Ampoules should be crushed and disposed of with sharps. • Large quantities: Incineration at temperatures exceeding 12000C. Encapsulation in metal drums. Landfilling not recommended unless encapsulated in metal drums and groundwater contamination risk is minimal. Chemical waste: Waste may be hazardous Waste Segregation Strategy: Brown bag / container. Leak-proof plastic bag or container resistant depending on the toxic, corrosive, flammable, to chemical corrosion effects. reactive, and genotoxic properties. Chemical Treatment: Return unused chemicals to supplier; Encapsulationª; Safe burial on hospital premisesª; waste may be in solid, liquid, or gaseous form Incineration (Pyrolytic incineratorª; and is generated through use of chemicals • Facilities should have permits for disposal of general chemical waste (e.g. sugars, amino acids, during diagnostic / experimental work, salts) to sewer systems. cleaning, housekeeping, and disinfection. • Small hazardous quantities: Pyrolytic incineration, encapsulation, or landfilling. Chemicals typically include formaldehyde, • Large hazardous quantities: Transported to appropriate facilities for disposal, or returned to the photographic chemicals, halogenated and non- original supplier using shipping arrangements that abide by the Basel Convention. Large halogenated solvents, organic chemicals for quantities of chemical waste should not be encapsulated or landfilled. cleaning / disinfecting, and various inorganic chemicals (e.g. acids and alkalis). Waste with high content of heavy metals: Waste Segregation Strategy: Waste containing heavy metals should be separated from general Batteries, broken thermometers, blood pressure health care waste. gauges, (e.g. mercury and cadmium content). Treatment: Safe storage site designed for final disposal of hazardous waste. • Waste should not be burned, incinerated, or landfilled. Transport to specialized facilities for metal recovery. Pressurized containers: Includes containers / Waste Segregation Strategy: Pressurized containers should be separated from general health care cartridges / cylinders for nitrous oxide, ethylene waste. oxide, oxygen, nitrogen, carbon dioxide, Treatment: Recycling and reuse; Crushing followed by landfill compressed air and other gases. • Incineration is not an option due to explosion risks • Halogenated agents in liquid form should be disposed of as chemical waste, as above. General health care waste(including food Waste Segregation Strategy: Black bag / container. Halogenated plastics such as PVC should be waste and paper, plastics, cardboard): separated from general health care facility waste to avoid disposal through incineration and associated hazardous air emissions from exhaust gases (e.g. hydrochloric acids and dioxins). Treatment: Disposal as part of domestic waste. Food waste should be segregated and composted. Component wastes (e.g. paper, cardboard, recyclable plastics [PET, PE, PP], glass) should be segregated and sent for recycling. 39 Source: Safe Management of Wastes from Health-Care Activities. International Labor Organization (ILO), Eds. Pruss, A. Giroult, and P. Rushbrook (1999) Notes: a. Small quantities only b. Low-level infectious waste only c. Low-level liquid waste only d. Halogenated and non-halogenated solvents (e.g. chloroform, TCE, acetone, methanol) are usually a laboratory-related waste stream for fixation and preservation of specimens in histology / pathology and for extractions in labs. e. Note on incinerators. Pyrolytic and rotary kiln incinerators should be used. Use of single-chamber and drum / brick incinerators are not normally considered good practice, except in emergency situations as a last option. 40 71. Wastewater: Waste segregation measures should be employed to minimize entry of solid waste into the wastewater stream, including: • Procedures and mechanisms for separate collection of urine, feces, blood, and vomit from patients treated with genotoxic drugs to avoid their entry into the wastewater stream (as described above under waste segregation for hazardous and other wastes); • Collection of large quantities of pharmaceuticals for separate treatment or return to manufacturer (see Table 2). Small quantities of mild, liquid pharmaceuticals, excluding antibiotics or cytotoxic drugs, may be discharged to sewer systems with a large water flow. 72. Municipal Wastewater Treatment: If wastewater is discharged to sanitary sewage treatment systems, the HCF should ensure that wastewater characteristics are in compliance with all applicable permits, and that the municipal facility is capable of handling the type of effluent discharged. 73. Fire safety: The risk of fire in health care facilities is significant due to the storage, handling, and presence of chemicals, pressurized gases, boards, plastics, and other flammable substrates. Fire safety recommendations applicable to occupational areas are presented under ‘Occupational Health and Safety’ in the General EHS Guidelines. Recommendations applicable to buildings accessible to the public, including health care facilities, are presented under ‘Life and Fire Safety’ in the General EHS Guidelines. Additional recommendations for fire safety include: • Installation of smoke alarms and sprinkler systems • Maintenance of all fire safety systems in proper working order, including self-closing doors in escape routes and ventilation ducts with fire safety flaps • Training of staff for operation of fire extinguishers and evacuation procedures • Development of facility fire prevention or emergency response and evacuation plans with adequate guest • information (this information should be displayed in obvious locations and clearly written in relevant languages) 74. Exposure to Infections/Diseases: The following measures are recommended to reduce the risk of transferring infectious diseases to health care providers: • Formulate an exposure control plan for blood-borne pathogens • Provide staff members and visitors with information on infection control policies and procedures • Establish Universal / Standard Precautionsto treat all blood and other potentially infectious materials with appropriate precautions, including: o Immunization for staff members as necessary (e.g. vaccination for hepatitis B virus) o Use of gloves, masks, and gowns o Adequate facilities for hand washing. Hand washing is the single most important procedure for preventing infections (e.g. nosocomial and community). Hand washing should involve use of soap / detergent, rubbing to cause friction, and placing hands under running water. Washings of hands should be undertaken before and after direct patient contacts and contact with patient blood, body fluids, secretions, excretions, or contact with equipment or articles contaminated by patients. Washing of hands should also be undertaken before and after work shifts; eating; smoking; use of personal protective equipment (PPE); and use of bathrooms. If hand washing is not possible, appropriate antiseptic hand cleanser 41 and clean cloths / antiseptic towelettes should be provided. Hands should then be washed with soap and running water as soon as practical o Procedures and facilities for handling dirty linen and contaminated clothing, and preparing and handling food o Appropriate cleaning and waste disposal practices for the health care workplace • The following recommendations should be implemented when using and handling of needles / sharps: o Use safer needle devices and needleless devices to decrease needlestick or other sharps exposures o Do not bend, recap, or remove contaminated needles and other sharps unless such an act is required by a specific procedure or has no feasible alternative o Do not shear or break contaminated sharps o Have needle containers available near areas where needles may be found o Discard contaminated sharps immediately or as soon as feasible into appropriate containers o Used disposable razors should be considered contaminated waste and disposed of in appropriate sharps containers • Establish policies to exclude animals from facility property 75. In addition to the above recommendations, the following measures are applicable to personnel involved in waste management to reduce the risk of transferring infectious diseases: • Implement immunization for staff members, as necessary (e.g. vaccination for hepatitis B virus, tetanus immunization); • Provide adequate supplies of PPE for personnel involved in waste management including: overalls / industrial aprons, leg protectors, boots, heavy duty gloves, helmets, visors / face masks and eye protection (especially for cleaning of hazardous spills), and respirators (for spills or waste involving toxic dust or incinerator residue) as necessary; • Provide washing facilities for personal hygiene, particularly at waste storage locations. 76. Exposure to Hazardous Materials and Waste: In addition to the guidance provided above, hazardous materials and wastes should be handled according to occupational health and safety guideline provided in the WBG General EHS Guidelines. 77. In addition, the following table shows general measures to mitigate impacts from wastes generated and other health risks during operation and annexes 1 to 7 cover SOPs for handling medical wastes generated from healthcare facilities as per MOH’s guidelines. Table 3. General HCW management measures at health care facilities during operation Impacts/Risks Mitigation measures Applicable national technical regulations Solid health care The principles of solid health care waste Decision waste management are in accordance with Decision 43/2007/QÄ?- 43/2007/QÄ?-BYT on regulation on HCWM BYTdated 30 below. The SOPs for HCWM are described in November 2007 Annexes on HCWM regulation Segregation of solid HCW - Need to distinguish the waste immediately at the place of waste generation - Health care solid waste shall be segregated into 5 categories: infectious waste (sharp, non-sharp, highly infectious and anatomical 42 waste), hazardous chemical waste, pressurized containers and general waste Collection of solid HCW - Each commune health station has to specify the location of waste containers for each type of health care waste where they are generated. - The location of waste containers must have the instruction of waste classification and collection. - Each group of health care waste must contain in the bag or box fitted the code color and the technical standard which is suitable for the Regulations on health care waste management. Treatment and Disposal of solid HCW Applying one or several treatment options as below: - Transporting to the nearest disposal sites - Handling immediately by friendly environment methods such as needle shredder machine, concrete tank - The annex introduces the applicable methods for health care wastes treatment and disposal Wastewater - Wastewater shall be collected separately Decision 43/2007/QÄ?- from rainwater BYT dated 30 - Hygiene latrines shall be available and November 2007 on accessible to patients, health staff and visitors HCWM regulation - Wastewater shall be treated by on-site primary treatment facilities and disinfected TCVN before discharge into environment 7957:2008 –Drainage - The wastewater treatment system must have a and Sewerage – sludge collection tank External Networks - Sludge discharged from the wastewater and Facilities – treatment system must be disposed of as Design standard medical solid waste QCVN - To periodically inspect the quality of 28:2010/BTNMT – wastewater treatment. Having a book on National technical operation management and results of quality regulation on health control care wastewater - Treated wastewater must meet national technical regulation on healthcare wastewater Waste gases - Laboratories, chemical and pharmaceutical Decision 43/2007/QÄ?- warehouses must have ventilating systems BYT dated 30 and toxic gas cylinders up to the prescribed November 2007 on standards HCWM regulation - Equipment using toxic gas must have a standardized gas treatment system before QCVN being discharged into the environment 06:2006/BTNMT – - Waste gases from medical waste incinerators National technical must be treated to meet Vietnamese regulation on environmental standards hazardous substances in ambient air 43 Risks associated with - All of the heath providers will be provided MOH’s guidelines exposure to hazards labor protection items for HIV/AIDS - Solving unexpected situations (injured caused diagnosis and by needles) treatment (issued in - The annex introduces sample SOPs for accordance with treatment of accident due to sharp waste. Decision 3003/QD- BYT dated 19 August 2009 6.5 Mitigation measures for ethnic minority groups issues 78. The Project involves ethnic minority and a stand-alone EMPF has been prepared in line with OP 4.10 (Indigenous Peoples). This EMPF was prepared on the basis of (i) a social assessment survey in the project area; (ii) consultation with villagers and people living in the project area; (iii) consultation with the project stakeholders, including district health workers, commune health workers, village health workers and representatives of the commune authorities who participate in social assessment activities. The EMPF has been prepared to provide guidance for the preparation of Ethnic Minority Development Plans (EMDPs) in provinces where EM people live. 79. The EMPF will help to ensure that: (i) affected ethnic minority peoples receive culturally appropriate social and economic benefits; and (ii) where there are potential adverse effects on ethnic minority peoples, the impacts are identified, avoided, minimized, mitigated, or compensated for. 80. The draft EMPF has been locally disclosed and at the Bank’s external website prior to appraisal. The final EMPF will be disclosed in the same places after being cleared by the Bank. 44 7. PROCEDURES FOR REVIEW, CLEARANCE, AND IMPLEMENTATION OF SUBPROJECT SAEGUARD INSTRUMENTS 7.1 Objective and Approach 81. Main objective of the ESMF process is to ensure that the subprojects and other project activities to be financed by the project will not create significant adverse impacts on the local environment and local communities and the residual and/or unavoidable impacts will be adequately mitigated in line with the WB’s safeguard policies. The ESMF comprises four steps and the process is schematically shown in Figure 2. This section briefly describes key steps while more details are provided in annexes.Table 4summarizes the application of annexes in the ESMF process. • Step 1: Safeguard screening and impacts assesment; • Step 2: Preparation of safeguard instruments as required including development of mitigation measures and public consultation; • Step 3: Safeguard clearance and information disclosure; and • Step 4: Implementation, monitoring, and reporting. 82. The safeguard screening, impact assessment, and preparation of safeguard documents for all subprojects will be carried out during the Project implementation and the safeguard documents (e.g. EMDP sand ESMPs) will be submitted to the WB for review and clearance prior to appraisal. Small scale and simplicity of civil works to be carried out under Component 1will incorporate the ECOP into the bidding and contract documents and consultant contracts and contractor’s compliance performance will be closely monitored by field engineers. Table 4. Applications of ESMF Annexes Annex Content Scope of Application 1-7 Good practices of health care waste All subprojects of upgrading and management construction of CHSs 8 Safeguard Screening All subprojects of upgrading and construction of CHSs 9 Subproject ESMP preparation Subproject that its potential adverse impacts are considered moderate 10 ECOP Small scale and simplicity of civil works 11 Sample grievance registration form All subprojects of upgrading and construction of CHSs 12 Suggested content of the monitoring report The project 7.2 Safeguard Screening and Impact Assessment 83. This step (Step 1) aims to confirm the eligibility of subproject and/or activities to be financed by the Project as well as identify the potential environmental and social impacts of the subprojects/activities including categorization of the subproject into A, B, or C, identification of the WB safeguard policies to be triggered, and identification of safeguard documents to be prepared as required by OP/BP 4.01 and OP/BP 4.10 (see details in Annex 8). MOH CPMU will be responsible for signing the screening for each subproject. Consultation with the WB safeguard specialist for a complex subproject is required. 7.3 Development of Safeguard Documents 84. This step (Step 2) aims to prepare safeguard documents in line with the issues identified in Step 1. The guideline on the ESMP preparation is provided in Annex 9 while those for EMPDs are provided in EMPF. PPMUs will be responsible for preparation of safeguard 45 documents. Consultation with WB safeguard specialist for a complex subproject should be conducted as needed. 85. PPMUs will also prepare documents such as EPP or EIA as required by the current GoV’s environmental regulation19 and secure approval of responsible agencies. 19The GoV procedures, namely, Decree No. 18/2015/ND-CP dated February 14, 2015 of the Government on environmental protection planning, strategic environmental assessment, environmental impact assessment, and environmental protection commitment, and Circular No. 27/2015/TT-BTNMT dated 19 May 2015 of the Ministry of Natural Resources and Environment on strategic environmental assessment, environmental impact assessment, and environmental protection plan. 46 Figure 1: Schematic Flowchart of Project Safeguards Performance MOH CPMU - Determine the eligibility of a proposed subproject. If a proposed subproject was considered ineligible (e.g. a subproject causes significant adverse impacts like Category A that requires development of an ESIA, and/or triggers new safeguard policies), it would be excluded - An eligible subproject shall be treated with next steps in the following diagram Subprojects with small scale and Subprojects that adverse Subprojects involve simplicity of civil works – adverse impacts are considered issues of Indigenous impacts are considered small moderate Peoples PPMU prepares EPP in PPMU prepares ESMP and PPMU prepares an line with the current submits to the Bank for review EMDP in line with GoV’s environmental and clearance the approved EMPF regulations and submits including public to DPC PPMU prepares EPP or EIA in consultation line with the current GoV’s PPMU discloses EPP and environmental regulations and PPMU submits the the ECOP at subproject submits it to DONRE for review EMDP to the Bank sites accessible to local and clearance for review and people and NGOs clearance PPMU discloses both ESMP and EIA/EPP at subproject sites PPMUs disclose the PPMU incorporates the EMDP at subproject accessible to local people and ECOP into bidding and sites accessible to NGOs contract documents local people and PPMU incorporates ESMP into NGOs bidding and contract documents PPMU, assisted by Construction Supervising Consultant (CSC) and/or field engineer, monitors and supervises contractor’s performance, conducts consultations with local people and NGOs, and reports the results periodically to MOH CPMU for consolidation and submission to the WB WB will periodically review and monitor implementation of safeguards requirements (through implementation support mission and reports) 47 7.4 Review, Approval, and Disclosure of Safeguard Documents 86. WB review and clearance: The WB will review and approve the subproject ESIA, ESMP and EMDP prepared during project implementation. PPMU ensures that all required safeguards documents such as ESIA, ESMP and EMDP of the subproject are prepared and submitted to the WB for review and clearance, and public disclosure before subproject appraisal. However, in the context of the project an ESIA is not expected given the project design, the nature and small scale of physical investments. During the project implementation, if a proposed physical investment that its potential adverse impacts are considered moderate20 or significant21, MOH CPMU should consult the Bank to determine the appropriate extent and type of EA instrument. All safeguard documents will be disclosed in the project website and made available at PPMU office and the subproject sites accessible to local people and NGOs in Vietnamese language. A notification will be published about the disclosure and comments will be sought within one month of the disclosure date. The English version will be disclosed at the Bank external website. 87. Government review and approval: The WB also requires that EIA or EPP documents as required by the GoV will be reviewed and approved by the GoV’s responsible agencies. The EIA or EPP in Vietnamese as well as the approval decision will be provided to the Bank for information. The approved EIA or EPP reports will also be disclosed to the public. However, the EIA is not expected in the context of the project given the project design, the nature and small scale of physical infrastructure investments 22 .PPMU should consult the provincial DONRE about the appropriate extent of an EPP for upgrading and new construction of CHSs before technical preparation of subproject. 7.5 Implementation, Supervision, Monitoring, and Reporting 88. Safeguard implementation, supervision, monitoring, and reporting is an integral part of the Project implementation and responsibility of MOH CPMU and PPMU. The WB safeguard specialists will also supervise and monitor the implementation of safeguard as part of the WB implementation support mission. Detailed responsibilities of relevant agencies are described in Table 5 below. 20 A stand-alone ESMP is required for the subproject. 21 A stand-alone ESIA is required for the subproject and ESMP is an integral part of the ESIA. 22 As per the criteria in Annex 2 (list of projects requiring EIA) of Decree 18/2015/ND-CP on Environmental protection planning, Strategic environmental assessment, Environmental impact assessment, and Environmental protection plan, an EIA is required for construction of the health care facilities above 50 beds. 48 8. IMPLEMENTATION ARRANGEMENTS 8.1 Responsibility for ESMF Implementation 89. At project level, MOH as the implementing agency (IA) is overall responsible for the project safeguards performance. At subproject level, PPMU will be responsible for subproject safeguards performance in accordance with this ESMF. The table and figure below summarize the roles and responsibilities of the key parties and their relationships regarding safeguards performance. Figure 2: Organizational diagram for safeguards performance World Ministry of Health Bank MOH CPMU’s Safeguard Staff PPMU’s Safeguard Staff DONRE Local CSC Contractor communities Table 5. Institutional responsibilities for the Project and Subproject Safeguard Implementation Community/Agencies Responsibilities - Be responsible for overall coordinating project’s safeguard performance in line with this ESMF in coordination with PPMUs. - Assign safeguard staff in charge of the project safeguard issues shortly after the project effectiveness date. - Recruit and mobilize the safeguard consultants to support the project safeguards performance. MOH CPMU - Periodically report to the Bank on the status of the project’s safeguard performance. - Notify the Bank promptly of any incident or accident relating to the project which has, or is likely to have, a significant adverse effect on the environment, the affected communities, the public or workers. The notification will provide sufficient detail regarding such incident or accident, including any fatalities or serious injuries. - Be responsible for supervision and monitoring the project safeguards performance throughout the project implementation in coordination MOH CPMU’s with its safeguards consultants and PPMUs. safeguard staff - Specifically, the safeguards staff will be responsible for: (i) helping PPMU incorporate ESMP into the detailed technical designs and civil works bidding and contractual documents; (ii) helping PPMU 49 Community/Agencies Responsibilities incorporate responsibilities for ESMP and EMDP monitoring and supervision into the TORs, bidding and contractual documents for the Construction Supervision Consultant (CSC); iii) providing relevant inputs to the consultant selection process; (iv) reviewing safeguard monitoring reports submitted by the PPMUs; (v) conducting periodic site visits; (vi) helping the PPMU on solutions to handle safeguard issues of the subproject; and vii) assist MOH CPMU in preparing periodic safeguard monitoring reports to submit to the World Bank. - Be responsible for supervision and monitoring the safeguards performance of the subprojects to ensure compliance with the approved ESMP/ECOP/EMDP throughout subproject implementation. - Specifically, to (i) closely coordinate with local authorities and communities during subproject preparation and implementation; (ii) ensure that the detailed design take into account all safeguard recommendations as indicated in the ESMP/ECOP and EMDP; (iii) PPMU comply with ESHS requirements in the SPDs; monitor and supervise contractor’s compliance with ESHS requirements; (iv) ensure that an environmental and social management system is set up and functions properly; and (v) periodically report the status of the safeguards performance to MOH CPMU. - Hire CSC and assign Safeguards Staff to help with safeguard aspects of the subproject and coordinate with MOH CPMU safeguard staff. - Assign Environmental and Social Staff(s) and will be responsible for routine supervising and monitoring of all construction activities and for ensuring that Contractors comply with the ESHS requirements of the contracts. Construction - Engage sufficient number of qualified staff (e.g. Environmental Supervision Engineers) with adequate knowledge on environmental protection and Consultant (CSC) construction subproject management to perform the required duties. - Provide training in ESHS requirements to contractors if required. - Assist the PPMU in reporting and maintaining close coordination with the local authorities and communities. - Submit to PPMU/CSC for approval, and subsequently implement, the Contractor’s Environment and Social Management Plan (C-ESMP), in accordance with the Particular Conditions of Contract Sub-Clause 16.1, that includes the agreed Management Strategies and Implementation Plans. - Appoint a competent individual as the contractor’s on-site Safety and Environment Officer (SEO) who will be responsible for monitoring the compliance with ESHS requirements and MSIP, which is set out in the Contractor Section VII – Works’ Requirements of SPDs. - Take actions to minimize and mitigate all potential negative impacts in line with the objective described in the C-ESMP. - Actively communicate with local communities and take actions to prevent disturbance during construction. - Ensure that all staff and workers understand the procedure and their tasks in C-ESMP. - Refuse to implement illegal requirements. 50 Community/Agencies Responsibilities - Propose change in design so that it is suitable for construction reality to ensure the quality and effectiveness. - Stop construction when construction activities cause dangerous for people. - Manage influx of labor on site and ensure security and order. - Report to the PPMU and CSC on any difficulties and their solutions. - Report to local authorities and PPMU/CSC if environmental accidents occur and closely coordinate with relevant agencies and key stakeholders to resolve these accidents in a timely manner. - Has right to participate and contribute their views to the subproject design to ensure that the design is suitable for the local context. Local authorities and - Routinely monitor and supervise the subproject implementation to ensure that it follows the approved design and agreed safeguard communities, recommendations. especially affected people - Has right to send complaints and request resolving the complaints through the established GRM to ensure that the subproject is implemented in accordance with the Bank safeguards policies and the GoV’s regulations. - Supervise and monitor compliance with the current GoV’s environmental regulations. Provincial DONRE - Report the status of the environmental compliance of the project activities to provincial people’s committee. 90. Each ESMP/ECOP is to be included in bidding documents and in any awarded contracts. The EMPF and EMDPs will be sent to local authorities and relevant organizations for implementation under the PPMU’ guidance. The PPMU will be responsible for supervising EMDP/ESMP/ECOP implementation and reporting to MOH CPMU as an element of normal project reporting requirements. The PPMU will establish a coordination and implementation group to address environmental and social issues, including environmental and social focal point. The focal point will be responsible for (a) coordination of environmental and social safeguards; (b) leading the preparation and implementation of safeguards instruments; (c) leading the environmental and social safeguard experts (consultants) and overseeing the training and capacity building activities; and (d) coordinating all safeguard activities with donors, implementing agencies, including local authorities, and/or other potential financial supporters. There will be a regular report on safeguard performance. 91. The implementation of safeguard instruments will be internally monitored by the PPMUs in close coordination with the respective peoples' committees, line departments at different administrative levels, and externally supervised by independent monitoring agencies. The PPMUs will ensure that activities related to environmental and social safeguards will be properly tracked, reported, and documented. Independent monitoring will start around the same time as implementation of activities and will continue until the end of the project/subproject. The performance of and compliance with safeguard instruments will also be subject to regular supervision by the World Bank task team. 92. The PPMUs will be responsible for the preparation and implementation of safeguard instruments and its monitoring. During project implementation, the PPMUs will be responsible for preparing and ensuring the effective implementation of safeguard measures (such as EMDPs, ESMPs/EPPs/ECOP) and regularly liaising with local authorities and communities. 51 93. A capacity needs assessment will be made at the outset of project implementation and if appropriate a capacity development plan for each province will be prepared and implemented. Enhanced training on safeguard policies and requirements will also be provided to the PPMU safeguards staff during project preparation and implementation. The PPMU, contractor and CSC will receive training in the project’s safeguard aspects. 94. After the approval of the ESMP, the PPMU is responsible for ensuring that the ESMP is effectively implemented and that for all civil contracts, the agreed mitigation measures are included in the Bidding Document and Contract Document and that contractor is aware and committed to effectively implementing of the agreed mitigation measures and the cost is part of the contract cost. Before construction, the PPMU will hire the CSC and/or field engineer to be responsible for day-to-day supervision of contractor performance on safeguard and report the results in the subproject progress report. PPMU will work closely with DONRE during implementation of the subprojects. 8.2 Environmental Compliance Framework 95. Duties of the Contractor, the Safety, Social and Environmental Officer (SSEO) and the CSC set out here that are not already addressed within the SPDs should be incorporated into the Employers Requirements (section 7 of the SPDs). (i) Environmental Duties of the Contractor23 96. The contractor firstly shall adhere to minimize the impact that may be result of the project construction activities and secondly, apply the mitigation measures under ESMP to prevent harm and nuisances on local communities and environment caused by the impacts in construction and operation phases. 97. The Contractor shall be required to submit for approval, and subsequently implement, the Contractor’s Environment and Social Management Plan (C-ESMP), in accordance with the Particular Conditions of Contract Sub-Clause 16.2 24 , that includes the agreed Management Strategies and Implementation Plans. 23 If the Contractor was, or is, failing to perform any ESHS obligations or work under the Contract, the value of this work or obligation, as determined by the Project Manager, may be withheld until the work or obligation has been performed, and/or the cost of rectification or replacement, as determined by the Project Manager, may be withheld until rectification or replacement has been completed. Failure to perform includes, but is not limited to the following: • failure to comply with any ESHS obligations or work described in the Works’ Requirements which may include: working outside site boundaries, excessive dust, failure to keep public roads in a safe usable condition, damage to offsite vegetation, pollution of water courses from oils or sedimentation, contamination of land e.g. from oils, human waste, damage to archeology or cultural heritage features, air pollution as a result of unauthorized and/or inefficient combustion; • failure to regularly review C-ESMP and/or update it in a timely manner to address emerging ESHS issues, or anticipated risks or impacts; • failure to implement the C-ESMP; • failing to have appropriate consents/permits prior to undertaking Works or related activities; • failure to submit ESHS report/s (as described in Appendix C of SPDs), or failure to submit such reports in a timely manner; • failure to implement remediation as instructed by the Engineer within the specified timeframe (e.g. remediation addressing non-compliance/s). 24 The Contractor shall not commence any Works, including mobilization and/or pre-construction activities (e.g. limited clearance for haul roads, site accesses and work site establishment, geotechnical investigations or investigations to select ancillary features such as quarries and borrow pits), unless the Project Manager is satisfied that appropriate measures are in place to address environmental, social, health and safety risks and impacts. At a minimum, the Contractor shall apply the Management Strategies and Implementation Plans and Code of Conduct, submitted as part of the Bid and agreed as part of the Contract. The Contractor shall submit, on a continuing basis, for the Project Manager’s prior approval, such supplementary Management Strategies and Implementation Plans as are necessary to manage the ESHS risks and impacts of ongoing works. These Management Strategies and Implementation Plans collectively comprise the Contractor’s Environmental and Social 52 98. Remedial actions that cannot be effectively carried out during construction should be carried out on completion of the works (and before issuance of the acceptance of completion of works). The duties of the Contractor include, but not limited to: - Compliance with relevant legislative requirements governing the environment, public health and safety; - Work within the scope of contractual requirements and other tender conditions; - Organize representatives of the construction team to participate in the joint site inspections undertaken by the Environmental Staff of the CSC; - Carry out any corrective actions instructed by the Environmental Staff of the PPMU and CSC; - In case of non-compliances/discrepancies, carry out investigation and submit proposals on mitigation measures, and implement remedial measures to reduce environmental impact; - Stop construction activities, which generate adverse impacts upon receiving instructions from the Environmental Staffof PPMU and CSC. Propose and carry out corrective actions and implement alternative construction method, if required, in order to minimize the environmental impacts; Non-compliance by the Contractor will be cause for suspension of works and other penalties until the non-compliance has been resolved to the satisfaction of the ES of PPMU and CSC. (ii) Contractor’s Safety, Social and Environmental Officer (SSEO) 99. The contractor shall be required to appoint competent staff(s) as the Contractor’s on-site safety, social and environment officer (SSEO). The SSEO must be appropriately trained in environmental management and must possess the skills necessary to transfer environmental management knowledge to all personnel involved in the contract. The SSEO will be responsible for monitoring the contractor’s compliance with the ESMP requirements and the environmental specifications. The duties of the SSEO shall include but not be limited to the following: - Carry out environmental site inspections to assess and audit the contractors' site practice, equipment and work methodologies with respect to pollution control and adequacy of environmental mitigation measures implemented; - Monitor compliance with environmental protection measures, pollution prevention and control measures and contractual requirements; - Monitor the implementation of environmental mitigation measures; - Prepare audit reports for the site environmental conditions; - Investigate complaints and recommend any required corrective measures; - Advise the contractor on environment improvement, awareness and proactive pollution prevention measures; - Recommend suitable mitigation measures to the contractor in the case of non- compliance. Carry out additional monitoring of noncompliance instructed by the Safeguard Staff of PPMU and CSC; Management Plan (C-ESMP). The C-ESMP shall be approved prior to the commencement of construction activities (e.g. excavation, earth works, bridge and structure works, stream and road diversions, quarrying or extraction of materials, concrete batching and asphalt manufacture). The approved C-ESMP shall be reviewed, periodically (but not less than every six (6) months), and updated in a timely manner, as required, by the Contractor to ensure that it contains measures appropriate to the Works activities to be undertaken. The updated C-ESMP shall be subject to prior approval by the Project Manager. 53 - Inform the contractor and ES (of PPMU and CSC) of environmental issues, submit contractor’s ESMP Implementation Plan to the Safeguard Staff of PPMU and CSC, and relevant authorities, if required; - Keep detailed records of all site activities that may relate to the environment. (iv) Environmental Supervision by Construction Supervision Consultant (CSC) during Construction 100. The contractor will be supervised by CSC against the contract requirements. CSC will ensure that the ESHS requirements are appropriately incorporated into the employers requirements and therefore the contract, such that they are confident that the contractor will meet the obligations. One of the obligations of the contractor (via CSC) is to report to the PPMUs: the information they are required to report should be adequate, when supplemented with the PPMU’s own checks and supervision, to enable the PPMUs to report to the Bank on whether the measures contained in the ESMP are being delivered adequately. (v) Compliance with Legal and Contractual Requirements 101. The constructions activities shall comply not only with contractual environmental protection and pollution control requirements but also with environmental protection and pollution control laws of the Socialist Republic of Viet Nam. 102. All the works method statements submitted by the Contractor to the CSC and PPMU for approval to see whether sufficient environmental protection and pollution control measures have been included. 103. The CSC and PPMU shall also review the progress and program of the works to check that relevant environmental laws have not been violated, and that any potential for violating the laws can be prevented. 104. The Contractor shall copy relevant documents to the SSEO and the safeguard staff of CSC and PPMU. The document shall at least include the updated work progress report, the updated work measure, and the application letters for different license/permits under the environmental protection laws, and all the valid license/permit. The SSEO and the safeguard staff shall also have access, upon request, to the Site Log-Book. 105. After reviewing the documents, the SSEO or the safeguard staff shall advise the PPMU and the contractor of any non-compliance with the contractual and legislative requirements on environmental protection and pollution control for them to take follow-up actions. If the SSEO or the safeguard staff concludes that the status on license/permit application and any environmental protection and pollution control preparation works may not comply with the work measure or may result in potential violation of environmental protection and pollution control requirements, they shall advise the Contractor and the PPMU accordingly. 8.3 Reporting Arrangements 106. In addition to the progress report, the Contractor shall also provide a report on the Environmental, Social, Health and Safety (ESHS) metrics set out in Appendix B of SPDs. In addition to Appendix B reports, the Contractor shall also provide immediate notification to the PPMU of incidents in the following categories. Full details of such incidents shall be provided to the PPMU within the timeframe agreed with the PPMU. â–ª confirmed or likely violation of any law or international agreement; â–ª any fatality or serious (lost time) injury; 54 â–ª significant adverse effects or damage to private property (e.g. vehicle accident, damage from fly rock, working beyond the boundary); â–ª major pollution of drinking water aquifer or damage or destruction of rare or endangered habitat (including protected areas) or species; or â–ª any allegation of sexual harassment or sexual misbehavior, child abuse, defilement, or other violations involving children. Table 6. Reporting Procedures No. Report Prepared by Submitted to Frequency of Reporting 1 Contractors CSC Immediately of certain aspects and monthly with respect to a wider range of aspects 2 Construction Supervision PPMU Immediately or monthly consultant (CSC) 4 Community Monitoring PPMU When the community has any complaint Board (CMB) about the subproject safeguards implementation 5 PPMU MOH CPMU Once every three months DONRE In accordance with the current GoV’s environmental regulations 6 MOH CPMU WB Once every six months in accordance with the Section II of the Loan Agreement 8.4 Incorporation of ESMF into Project Operational Manual (POM) 107. The ESMF process and requirements will be incorporated into the Project Operation Manual (POM) and MOH CPMU will provide training to ensure that the PPMU understands them as well as will supervise and monitor the ESMF implementation periodically. 55 9. CAPACITY BUILDING AND TRAINING 9.1 Institutional Capacity Assessment 108. At subproject level, some PPMUs may have experience with the WB-financed projects in terms of safeguard requirements, but however their capacity remains limited. Moreover, most national consultants and local authorities also do not have adequate knowledge of the WB safeguard requirements therefore safeguard training program will be necessary during the implementation of the Project. 9.2 Safeguards Capacity Building 109. The MOH CPMU will be responsible for strengthening safeguards capacity for PPMUs and other stakeholders throughout project implementation. Safeguards training shall be organized as early as the project implementation. MOH CPMU will prepare the content of training which cover all safeguard aspects of the project so that helps PPMUs and other stakeholders effectively perform safeguard requirements in accordance with the ESMF. The Bank safeguard specialist will participate in the training workshops as much as possible. 110. Priority for training should include, but not limited to, the following: (i) The scope of application and objectives of the Bank safeguard policies applicable to the Project; (ii) Safeguards Instrument preparation and implementation (e.g. ESMF, EMPF, ESMP, ECOP); (iii) Specific training on EMDP planning and implementation including the application of GRM that could be effective in responding to local complaints; (iv) ESHS requirements in SPDs, C-ESMP preparation and ESHS compliance; and (v) Safeguard performance monitoring and reporting expertise Table 7. Content of Safeguards Training No Key content Target Groups for Training 1 The scope of application and objectives of PPMU safeguard staff the Bank safeguard policies applicable to the Project 2 Safeguard Instrument preparation and PPMU safeguard staff implementation (e.g. ESMF, EMPF, ESMP, EPP, ECOP, EMDP) 3 Specific training on EMDP planning and PPMU safeguard staff implementation including the application of GRM 4 ESHS requirements in SPDs , C-ESMP PPMU safeguard staff, Contractors preparation and ESHS compliance 5 Safeguard performance monitoring and PPMU safeguard staff, CSC reporting expertise 56 10. ESMF IMPLEMENTATION BUDGET 111. The ESMF implementation budget comprises: • Cost for preparation of safeguard documents (ESMPs, EPPs and EMDPs); • Cost for safeguards capacity building • Cost for implementation of agreed mitigation measures within ESMP/EPP/ECOP/EMDP • Cost for supervision, monitoring and reporting of safeguards performance 112. The PPMUs will be responsible for the breakdown of the costs for every activities of safeguards performance during project implementation. Table 8. Cost estimates for safeguards performance Item Cost estimates (in US$) Preparation of subproject safeguard 100,000 instruments, e.g. ESMP, EPP and EMDP Safeguards capacity building 100,000 Implementation of agreed mitigation Included in construction cost measures Safeguard supervision/monitoring 150,000 consultancy service 57 11. GRIEVANCE REDRESS MECHANISM 11.1 Subproject Grievance Redress Mechanism (GRM) 113. Within the Vietnamese legal framework citizen rights to complain are protected. As part of overall implementation of the subproject, a Grievance Redress Mechanism (GRM) will be established by PPMUs, identifying procedures, responsible person and contact information. It will be readily accessible, handle grievances and resolve them at the lowest level as quickly as possible. The mechanism will provide the framework within which complaints about environmental, health and safety issues can be handled, grievances can be addressed and disputes can be settled quickly. The GRM will be in place before the subproject construction commences. 114. During construction, the GRM will be managed by the Contractor under supervision of the CSC. This requirement shall be set out in the employer requirements of the SPDs.The Contractor will inform the communities and communes affected by the subproject about the GRM in place to handle complaints and concerns about the subproject. This will be done via the Information Disclosure and Consultation Process under which the Contractor will communicate with the affected communities and interested authorities on a regular basis: hold meetings at least quarterly, publish a monthly information brochure, place announcements in local media, post notices of upcoming planned activities, and so on. 115. All complaints and corresponding actions undertaken by the Contractor will be recorded in the subproject safeguard monitoring report. Complaints and claims for damages could be lodged as follows: • Verbally: direct to the CSC and/or the contractor safeguard staff or representative at the subproject Office • In writing: by hand-delivering or posting a written complaint to the address specified • By telephone, fax, e-mail: to the CSC, the contractor safeguard staff or contractor’s representative. 116. On receipt of a complaint, the CSC, contractor safeguard staff or representative will register the complaint in the Complaints File and maintain a Log of events pertaining to it thereafter until its resolution. Immediately after receipt, three copies of the complaint will be made. The original will be kept in the file, one copy will be used by the contractor’s safeguard staff, one copy will be forwarded to the CSC and the third copy to the PPMU within 24 hours of the complaint being made. Information to be recorded in the Complaints Log will include: • The date and time of the complaint; • The name, address and contact details of the complainant; • A short description of the issue of complaint; • Actions taken to address the complaint, including persons contacted and findings of each step in the complaint redress process; • The dates and times when the complainant is contacted during the redress process; • The final resolution of the complaint; • The date, time and manner in which the complainant was informed thereof; and • The complainant’s signature when resolution has been obtained. 117. Small complaints will be dealt with within one week. Within two weeks (and weekly thereafter), a written reply will be delivered to the complainant (by hand, post, fax, e-mail) indicating the procedures taken and progress to date. 58 118. The main objective will be to resolve an issue as quickly as possible by the simplest means involving as few people as possible, at the lowest possible level. Only when an issue cannot be resolved at the simplest level and/or within 15-days, will other authorities become involved. Such a situation may arise, for example, when damages are claimed and the amount to be paid cannot be resolved or the cause of the damages determined. 11.2 WB Grievance Redress Service (GRS) 119. WB’ s GRS:Communities and individuals who believe that they are adversely affected by a World Bank (WB) supported project may submit complaints to existing project-level grievance redress mechanism or the WB’s Grievance Redress Service (GRS). The GRS ensures that complaints received are promptly reviewed in order to adddress project-related concerns. Project affected communities and individuals may submit their complaints to the WB’s independent Inspection Panel which determines whether harms occurred, or could occur, as a result of WB non-compliance with its policies and procedures. Complaints may be submitted at anytime after concerns have been brought directly to the WB’s attention, and Bank Management has been given an opportunity to respond. For information on how to submit complaints to the World Bank’s corporate Grievance Redress Service (GRS), please visit www.worldbank.org/grs. For information on how to submit complaints to the World Bank Inspecition Panel, please visit www.inspectionpanel.org. 59 12. STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE 12.1 Stakeholder engagement process 120. Stakeholder engagement is an inclusive process conducted throughout the project life cycle. Where properly designed and implemented, it supports the development of strong, constructive and responsive relationships that are important for successful management of the project’s environmental and social risks. Stakeholder engagement is most effective when initiated at an early stage of the project development process and the assessment, management and monitoring of the project’s environmental and social risks and impacts. 121. The objectives of stakeholder engagement are: • To establish a systematic approach to stakeholder engagement that will help MOH identifies stakeholders and build and maintain a constructive relationship with them, in particular project-affected parties. • To assess the level of the stakeholder interest and support for the project and to enable stakeholders’ view to be taken into account in project design and environmental and social performance. • To promote and provide means for effective and inclusive engagement with project- affected parties throughout the project life cycle on issues that could potentially affect them. • To ensure that appropriate project information on environmental and social risk and impacts is disclosed to stakeholders in a timely, understandable, accessible and appropriate manner and format. • To provide project-affected parties with accessible and inclusive means to raise issues and grievances, and allow MOH to respond to and manage such grievances. 122. At project level, during preparation of the ESMF, consultations with key stakeholders have been done through face-to-face meetings. Key stakeholders include MOH Health Environment Management Agency (HEMA)and Department of Health (DOH) of project provinces of Son La, Quang Binh and Bacl Lieu. For meaningful consultations, MOH CPMU has provided relevant material in a timely manner such as project paper and draft ESMF to the consulted groups to seek their views prior to consultation. Comments and recommendations received during the consultations were taken into account in project design and finalization of the ESMF. Table 9 summarizes results of the public consultations on the ESMF. 123. At subproject level, MOH CPMU will support PPMUs to identify key stakeholders (e.g. locally-affected people, local NGOs and authorities) to be consulted and determine appropriate methods for consultations with key stakeholders during subproject preparation. Consultations with key stakeholders should be conducted at the early stage of subproject preparation. PPMU ensures that subproject information and subproject’s environmental and social risks and impacts and mitigation measures in understandable language will be provided to consulted groups prior to consultations. Also, PPMU provides information about such as timing and venue of consultation meetings to key stakeholders to be consulted in a timely manner to ensure that all invited stakeholders are present at the meeting. Comments and recommendations received during consultations shall be taken into account during subproject design. Consultations with such groups should be conducted as necessary during subproject implementation to address environmental and social risks and impacts that affect them. 60 Table 9. Summary of ESMF consultation results Stakeholders Date Stakeholder’s comments MOH CPMU’s Responses th HEMA 8 April - Agreed on the content of the Acronyms in the Vietnamese 2018 ESMF version will be spelled out and - Some acronyms in the typos will be corrected Vietnamese version should be spelled out and typos should be corrected DOH of Son 5 April - Agreed on the content of the - The project will surely be La province 2018 ESMF implemented in accordance in the - The project implementation with this framework northern will have to comply with this - The project implementation region framework will be closely monitored and DOH of 13 April supervised by responsible agencies, local authorities, Quang Binh 2018 people and NGOs province in the central region DOH of Bac 20 April Lieu 2018 province in the southern region 12.2 Information Disclosure 124. Incompliance with the WB policy on access to information, the draft ESMF in Vietnamese language was locally disclosed on MOH’s website on March 5th, 2018. The English version were disclosed at the Bank’s external website on 28th February 2018. The final ESMF will be disclosed at the same places as the draft ESMF after the Bank approves it. 125. All safeguard instruments such as ESMP, EPP and EMDP prepared during project implementation will be locally disclosed on the project’s website and at public places accessible to locally-affected people and local NGOs in Vietnamese language prior to subproject appraisal. 61 13. REFERECNES 1. Environmental and Social Management Framework Toolkit for World Bank-financed projects in Vietnam, 2015. 2. Ministry of Health, 2015. Guidelines on Health Care Waste Management in Hospital. 3. Ministry of Health, 2017. Status of solid healthcare waste at commune health station in Vietnam. 4. The Environmental and Social Management Framework for Vietnam Health Professionals Education and Training for Health System Reforms Project. 5. The Environmental and Social Management Framework for Vietnam Emergency Natural Disaster Reconstruction Project. 6. WBG EHS Guidelines. Environmental, Health and Safety Guidelines for Health Care Facilities. 62 Annex 1. Standard Operating Procedures for Health Care Waste Segregation 1. Purpose: ensure correct segregation of healthcare waste. 2. Scope of application: all rooms in Commune Health Station generating health care waste shall apply this procedures 3. Responsibility: all persons working in Commune Health Station (including staff, medical students, patients and their relatives) generating health care waste shall apply these procedures. 4. Equipment and supplies: Waste bags shall meet the following requirements: color coding (yellow, green, white, black); Yellow and black waste bags must be made of PE or PP, do not use PVC bags; Health care waste bags’ minimum thickness is 0,1mm, bag capacity is appropriate to waste volume, maximum capacity is 0,1 m3 ; The outside of bags must have horizontal line at level ¾ and have sentence of “DO NOT CONTAIN WASTE OVER THIS LEVELâ€?; Waste bags must comply with regulations of color system in Clause 7 of this Decision and be used in the right way. The outside of hazardous or recycled health care waste bags and must include the suitable logo for each type of waste as follows: Yellow bags and containers for infectious waste must have logo of hazardous biological waste; White bags, containers for recycled waste must have logo of recycled waste. Sharp containers shall meet the following requirements: Hard wall and bottom are hardly penetrable, leak-proof capacity, suitable size, the lid easy to open/close, the opening is big enough to contain sharp items without propulsive force, marked with the inscription “for sharp items onlyâ€?, a horizontal line running at the height of 3/4 of the bag with the inscription of "no storing beyond this line", yellow color, with handle or enclosed with fixation system, sharp items inside aren’t dropped out during transportation. 5. Methods: - Definition of healthcare waste Waste generated from Commune Health Station is classified into the following categories: infectious waste, chemical waste, and general waste. Infectious waste includes 4 groups as follows: - Sharp waste (group 1A): is waste that can cut, puncture including: needles, syringe, scalpels, knives, nails, bladders, broken glass and other sharp objects used in health activities. - Infectious non-sharp waste (group 1B): is waste in contact with blood, humor and waste generated from sterile rooms. - Highly infectious waste (group 1C): generates from laboratories such as: autopsies and tools in contact with autopsies. - Anatomical waste (group 1D): includes parts of human body, tissues, placentae, foetus and animal carcasses Chemical waste includes Pharmaceuticals that are expired, low-graded or no longer needed; and Harmful chemical substances in health care activities General waste which does not contain hazardous agents include non-recycled waste and recycled waste - Segregation: 63 o Health care waste must be segregated as soon as it is generated. o Each type of waste must be contained in specialized bags and containers with suitable logos. o Infectious waste is segregated into yellow color bags o Sharp waste is segregated into sharp containers o Chemical waste is segregated into black color bags o General waste is segregated into green color bags o Recycled waste is segregated into white color bags 64 Annex 2. Standard Operating Procedures for Health Care Waste Collection 1. Purpose: ensure correct collection of healthcare waste. 2. Scope of application: all rooms in Commune Health Station generating health care waste shall apply this procedures 3. Responsibility: persons in charge of environment in Commune Health Station 4. Equipments and supplies: Waste bags shall meet the following requirements: color coding (yellow, green, white, black); Yellow and black waste bags must be made of PE or PP, do not use PVC bags; Health care waste bags’ minimum thickness is 0,1mm, bag capacity is appropriate to waste volume, maximum capacity is 0,1 m3 ; The outside of bags must have horizontal line at level ¾ and have sentence of “DO NOT CONTAIN WASTE OVER THIS LEVELâ€?; Waste bags must comply with regulations of color system in Clause 7 of this Decision and be used in the right way. The outside of hazardous or recycled health care waste bags and must include the suitable logo for each type of waste as follows: Yellow bags and containers for infectious waste must have logo of hazardous biological waste; White bags, containers for recycled waste must have logo of recycled waste Waste container shall be made of high- density, thick, rigid PE or of metal that have a lid able to open by foot. Containers with large capacity (over 50 litres) must have wheels; Yellow containers are used to collect yellow waste bags and boxes; Black containers are used to collect black waste bags. The containers for radioactive waste must be metal; Green containers are used to collect green waste bags; White containers are used to collect white waste bags; Capacity depends on an amount of generated waste, from 10 litres to 250 litres; The outside of containers must have a horizontal line at level or ¾ and a sentence of “DO NOT CONTAINS SHARPS OVER THISLEVELâ€?. 5. Methods: - Location of waste bags andcontainers: o all rooms in Commune Health Stationhas to identify heath care waste containers locations for each category of waste. Appropriate bags and containers must be located in all places where waste is generated. o The waste containers locations must have instructions for classification and collection. o Waste containers must be used following to set standards and cleaneddaily. o Clean waste bags must be available in places where health care waste is generated in order to replace bags with the same type delivered to temporary storages of health facilities. - Each category of waste must be collected to waste bags and containers according to prescribed color codes and must label places of waste generation - Hazardous waste and general waste are not collected together. If they are collected together, the mixture of waste will be treated as hazardous waste. - The volume of waste in each bag is about 3/4 full and then closed by tying the necks. - Frequency of collection: Hospital orderly or staff is assigned a duty to collect hazardous health care waste and general waste from generating places to department’s waste storage at 65 least once a day and when needed. - Highly infectious waste must be primarily treated in a place where it is generated before colleting to central waste locations of health facilities 66 Annex 3. Standard Operating Procedures for Health Care Waste Storage 1. Purpose: ensure correct storage of health care waste. 2. Scope of application: The area/department of storage in Commune Health Station 3. Responsibility: persons in charge of health care waste storage area in Commune Health Station 4. Equipments and supplies: Storages place shall meet the following requirements: be far from food-preparing places, patients’ wards, crowded sites and public paths at least 10 m; have roofs, doors and locks to prevent animals, rodents and unassigned persons from freely penetrating therein; the area is suitable to the waste volumes generated from the health care establishments; be built with water drainage systems, water -resistant floor and wall, good ventilation. Storage equipments for sharp waste are containers made of high density plastic, having thick and rigid wall, capacity of 70 liters and yellow color. The container’s outside is marked with bio-hazard symbol, inscription of “sharp waste onlyâ€?, a line at level of 3/4 and inscription of "not storing beyond this line". 5. Methods: - Different waste streams are stored separately - Health care waste is stored in standard storage equipment - Storage time of health care waste does not exceed 48hours - Anatomical waste must be buried or disposed daily - Storage area and equipment must be cleaned and disinfected regularly 67 Annex 4. Guidance on selecting methods for Health Care Waste Treatment and Disposal Treatment model: According to Regulations on health care waste management and official letter No.7164/BYT- KCB dated 20/10/2008 of Minister of MOH, the health facilities are allowed to apply one of following models of treatment: - In central managed cities where density of health care facilities is high, traffic system is favorable, health care facilities apply centralized model of hazardous health care solid waste treatment, one treatment facility treat all hazardous health care solid waste generated in city in order to save investment and operational cost. - In other provinces and cities, health care facilities apply cluster model of hazardous health care solid treatment for hospitals, health care facilities locating within or surround cities and towns (distance to treatment facility is less than 30km). - Health care facilities locating in remote area and poor traffic area apply onsite waste treatment, use suitable treatment technology. Treatment technologies While incineration is adequate to many types of health care waste, non-incineration technologies are adequate to certain types of waste. Disinfection by steam, microwave or chemicals is applicable to most of infectious waste, but not suitable to treat anatomical waste, sharps and chemical waste. Concrete bury pit is only applied to anatomical waste and sharps. Inertization is only adequate to chemical and pharmaceutical waste (see Table 4.1). Based on socio-economic conditions and availability of technologies, the CHC should select the treatment technologies which are most suitable to its specific circumstances (see Table4.2). Table 4.1: Treatment and disposal methods suitable for different categories of health care waste Pyrolytic Wet thermal Microwave Chemical Safe Innertiza- Others incinerator disinfection irradition disinfection burying tion Infectious waste Sharps Yes Yes Yes Yes Yes No - Non-sharps Yes Yes Yes Yes Yes No - Highly infectious Yes Yes Yes Yes Yes No - Anatomical Yes No No No Yes No - Chemical waste Pharmaceuticals For small Return to quantities No No No Yes Yes supplier Table 4.2: Main advantage and disadvantages HCW treatment technologies 68 Technology Advantages Disadvantages Non-incineration technologies Needle cutter - Prevent needle reuse - Needles need further treatment after cut and separated - Easy to operate, low cost - Syringe can berecycled Needle destroyer - Needle is disinfected - Require electricity and destroyed - Stem of needle still exists byelectricity after destroying. - Easy to operate, low cost - Syringe can be recycled Innertization - Applicable to chemical waste and - Not applicable to other waste pharmaceutical waste - Simple to operate, low cost Cement bury pit - Applicable to sharps - Requires land and space and pathological waste - Potential impact to underground - Simple to operate, low cost water if poor design, construction Safe burying - Relatively safe if access to site is - Only apply to hospitals in restricted and where natural mountainous and rural area infiltration is limited. - Low investment and operation cost Disinfection by - Highly efficient disinfection - Inadequate for anatomical, steam (autoclave) pharmaceutical and chemical waste, - Reduction in waste volume and/or microwave and waste that is not readily steam if shredder available permeable. - Low operational cost - Requires trained operator - Environmentally sound - High investment cost, - Well-known technology requires thermal resistant waste in hospitals bags Incineration technologies Two chamber or - Adequate for all infectious waste, - Incomplete destruction of cytotoxics Pyrolytic most chemical waste, and - Relatively high investment incinerator pharmaceutical waste - High operational cost - Drastic reduction of weight and volume of waste - Requires qualified operator - Emissions of air pollutants in case of improper operation and maintenance 69 Annex 5. Standard Operating Procedures for Health Care Waste Treatment and Disposal 1. Purpose: ensure safe treatment and disposal of health care waste. 2. Scope of application: The treatment and disposal location 3. Responsibility: persons in charge of health care waste treatment and disposal for Comnune Health Station 4. Selected equipments and methods: (Mark "X" to selected equipments and methods) Treatment Treatment and disposal methods and disposal models In Outside Pyrolytic Wet thermal Microwave Chemical Safe Innertiza- Others CHS CHS incinerator disinfection irradiation disinfection burying tion Infectious waste Sharps Non-sharps Highly infectious Anatomical Chemical waste Pharmaceuticals 70 Annex 6. Standard Operating Procedures for Treatment of Accident due to Sharp Waste 1. Purpose: Ensure effective prophylaxis treatment of injury due to sharp waste. 2. Scope of application: all departments in the hospital shall be responsible for applying this procedure 3. Responsibility: - Injured person shall be responsible for treating wound site, reporting to the supervisor and complete the report form, complying with testing and post-exposure prophylaxis treatment. - Head of department: sent completed report form to Center for Preventive Medicine - Center for Preventive Medicine: shall be responsible for counseling and providing anti- retrovirus therapy. - Head of Infection control department: update the incident and take measures to prevent similar exposure. 4. Equipments and supplies: - First aids tools for treatment of exposure site - Equipment for HIV, HBV, HCV testing - Anti-retrovirus treatment drugs 5. Methods: - Step 1: Treat the exposure site: Flush the wound with tap water, Let the wound bleed for a short time 3 – 5 minutes, do not squeeze; clean the wound thoroughly with soap and water; disinfect wound by disinfectants (Dakin, Javel 1/10, alcohol 70 0) in at least 5minutes. - Step 2: Report to the manager and complete the report form: Indicate the date, time and the context of exposure, describe the wound and assess the level of risk. Get the signatures of the witnesses and the supervisor. - Step 3: Assess the risk of exposure Risk presents with: Bleeding percutaneous wounds caused by containing blood needles: the risk is higher in case of deep wounds caused by large-bore needle containing a lot of blood compared with that of shallow wounds from fine needles with less blood; Deep percutaneouswoundscausedbyscalpelsorbrokentubescontainingpatient'sbloodandbo dy fluids; Existing lesions, ulcers or scratches on the skin or mucus membranes exposed to patient's blood and body fluids (even when the status of ulcers is unclear): the risk is higher with large ulcers or scratches. No risk: normal skin exposed to patient's blood or body fluids. - Step 4: Determine the HIV, HBV, HCV status of the source of exposure: If the source patient is HIV (+), HbsAg (+), Anti HCV (+): get information on the use of and response to ARV treatment; If the HIV, HBV, HCV status of the source is unknown: provide counseling and perform HIV, HBV, HCV tests. In some cases it is impossible to identify the HIV status of the source (being exposed while on duty, the subject ran away), treat as HIV (+), HbsAg (+), Anti HCV (+) cases. 71 - Step 5: Determine the HIV, HBV, HCV status of the exposed person: Provide pre-test and post-test counseling as regulated. If the exposed person has positive test result right after the exposure incident: HIV, HBV or HCV infection occurred before, not due to the exposure incident; If HIV (-), HBV (-), HCV (-) then HIV, HBV or HCV test is required after 3 months and 6 months. - Step 6: Counsel the exposed person on. Risk of infection with HIV,HBV, HCV; Information and services of the prophylaxis, its benefits and risks; Side effects of ARV and signs of primary HIV infection: fever, rash, nausea or vomiting, anemia, lymphadenopathy, etc; Prevention of HIV transmission to others: exposed person may transmit HIV to others even if the test is negative (the window period) and they, therefore should practice all prevention measures; Adherence to treatment and psychological support. - Step 7: ARV prophylaxis for the exposed person: Provide ARV treatment as soon as possible, best within 2 – 6 hours after and before 72 hours after the exposure to all exposure cases with risk. At the same time, assess the HIV status of the source of exposure and the exposed person. If the source of exposure is HIV (+): continue the treatment. If the source of exposure is HIV (-): it is possible to discontinue the treatment. If the source is suspected having risk factor and is in the period window, the treatment should be continued. If the exposed person is HIV (+): do not provide prophylaxis, refer for follow-up and provide treatment as a normal HIV positive case. If the exposed person is HIV (-): continue the treatment; Exposure with no risk: no treatment is needed; If the HIV status of the source of exposure cannot be determined: treat as a case of exposure to the HIV (+)source. 72 Annex 7: Health Care Waste Management Checklist 1. Assessment of current situation No. Criteria Status Notes Health care waste is correctly and safely 1 segregated at generating source Sharp waste is segregated correctly and safely ï‚£ Yes No 1.1 at generating source Infectious waste is segregated correctly and ï‚£ Yes No 1.2 safely at generating source Chemical waste is segregated correctly and ï‚£ Yes No 1.3 safely at generating source General waste is segregated correctly and ï‚£ Yes No 1.4 safely at generating source Recyclable waste is segregated correctly and ï‚£ Yes No 1.5 safely at generating source Visible pictures or posters instructing health 1.6 ï‚£ Yes No care waste segregation in department Health care waste is safely collected at 2 Commune Health Station CHS designates a dirty room or area for waste 2.1 ï‚£ Yes No collection At collection place, there are visible instruction 2.2 ï‚£ Yes No on waste collection 2.3 Infectious waste is safely collected in CHS ï‚£ Yes No 2.4 Chemical waste is safely collected in CHS ï‚£ Yes No 2.5 General waste is collected safely in CHS ï‚£ Yes No 2.6 Recyclable waste is safely collected in CHS ï‚£ Yes No Waste containers cleaned and disinfected 2.7 ï‚£ Yes No daily or regularly so that there is not dirt and bad odor 3 Health care waste is safely stored in CHS 3.1 Health care waste storage area is in place ï‚£ Yes No Health care waste storage area, if available, 3.2 ï‚£ Yes No meet the regulatory requirements 3.3 Infectious waste is stored safely ï‚£ Yes No 3.4 Chemical waste is stored safely ï‚£ Yes No 3.5 General waste is stored safely ï‚£ Yes No Waste storage area and equipment are cleaned 3.6 ï‚£ Yes No and disinfected daily Health care waste is safely treated and 4 disposed on- site or off-site 73 In case of off-site treatment, hazardous health care waste is transported to legal treatment and Applicability 4.1 disposal facilities by special means in a ï‚£ Yes No controlled manner and in line with hazardous ï‚£ Yes No health care waste management regulations. In case of on-site treatment, infectious waste Applicability 4.2 is sterilized and shredded, then continued to ï‚£ Yes No ï‚£ Yes No treatfor disposal as general waste In case of on-site treatment, some hazardous Applicability health care waste (anatomical waste, sharps, ï‚£ Yes No 4.3 and some chemical waste) is encapsulated or ï‚£ Yes No isolated in concrete pits being designed and operated in line with regulations on hazardous waste management In case of on-site treatment, chemical health Applicability 4.4 care waste is innertized by cement, then ï‚£ Yes No ï‚£ Yes No transported to legal landfill for disposal In case of on-site treatment, health care waste Applicability is safely treated by existing incinerator applied 4.5 ï‚£ Yes No ï‚£ Yes No stringent pollution control measures so that secondary pollution due to incinerator’s gas emission and bottom ash are avoided Wastewater from CHS is collected and 5 treated properly Health care wastewater is collected separately 5.1 from storming water in collection network ï‚£ Yes No which meet regulatory requirements Latrines are sufficient to health staff and 5.2 patients. ï‚£ Yes No Latrines meet technical regulations on design, operation and maintenance of hygienic latrine Wastewater is treated properly before 5.2 ï‚£ Yes No discharge into environment Health care waste management procedures 6 ï‚£ Yes No are developed correctly and systematically. CHS’s staff are provided with sufficient 7 ï‚£ Yes No personal protective equipment and use them properly 2. Main findings and recommendations Main findings Recommendations 74 Annex 8: Safeguard Screening Guidelines Subprojects proposed to be financed by the project should be screened for eligibility at first. The purpose of this process is to help ensure that the proposed subprojects are suitable for the project’s objectives and environmentally sound and sustainable. PPMU’s environmental staff should closely work with PCU’s environmental staff to conduct screening as early as possible to determine whether a proposed subproject is eligible for financing. A set of the following exclusion criteria shall be applied for eligibility screening. In case a subproject involves one or more of the followings, it is considered ineligible for financing by the project. â–ª Causing land acquisition and resettlement â–ª Causing degradation or conversion of natural habitats â–ª Causing negative impact on forests â–ª Causing negative impact on Physical Cultural Resources â–ª Having significant adverse environmental impacts that are sensitive, diverse, or unprecedented â–ª New construction and/or upgrading of provincial and district hospitals â–ª Purchase of medical equipment emitting radiation â–ª Use of hazardous materials (e.g. unbounded asbestos fibers, lead paint) â–ª Purchase of products containing PCB (Polychlorinated Biphenyl) â–ª Purchase of equipment containing substances which cause ozone depleting subject to international phase out â–ª Purchase of pesticides/herbicides Table below presents the technical guideline on safeguard screening for physical investments (subprojects) under Component 1 for which subproject’s potential impacts will be identified and corresponding safeguard documents and mitigation actions are required. Technical Guideline on Safeguard Screening and Actions to be taken Potential Required Required mitigation actions Remarks negative document (If Yes) impacts (1) Likely EMDP Carry out social assessment process Prior involve ethnic through free, prior, and informed consultation minorities issues consultations and prepare an EMDP in with WB, and/or adversely accordance with guidance in the EMPF. proper affecting ethnic The project will support increasing documentation, minority groups awareness of affected population, in and Post respective languages of ethnic minority review by WB groups, about the Grievance Redress may be mechanisms, and building capacity of necessary those involved in the existing Grievance Redress mechanism on the required tasks, including dealing with or mediating complaints from individual and/or ethnic groups, recording and reporting, and monitoring proposed resolutions. (2) Likely UXO PPMU would contact and work with the UXO clearance involve UXO clearance competent military agencies to develop should be risk plan an UXO clearance plan in accordance completed with current regulations of the GoV. before handing 75 Potential Required Required mitigation actions Remarks negative document (If Yes) impacts over the site to contractor. (3) Involve civil ESMP or ESMP or ECOP sets out a set of Provisions for works which will ECOP mitigation measures to address CSC’s ESHS generate construction-related impacts. PPMU supervision construction- will ensure that the all mitigation will be related impacts measures are included in bidding and explicitly such as air contractual documents. described in pollution, noise, the TOR vibration, PPMU and its wastes, health CSC will risks, etc. supervise contractor’s compliance with ESHS requirements (4) Likely cause N/A N/A Such physical impacts on investments PCRs, natural would be habitats, forests excluded given or involve that the project pesticide uses has not and land triggered the acquisition and policies on resettlement Physical Cultural Resources, Natural Habitats, Forests, Pest Management and Involuntary Resettlement 76 Annex 9: Guidelines for Subproject ESMP Preparation This annex presents technical guideline for preparation of an ESMP for subproject including scope of ESMP report (Section A3.1), public consultation (Section A3.2), and preparation of EIA/EPP as required by the Government’s EIA regulations (Se ction A3.4). Result from technical screening and issues identified in Annex 8 will be used as the basis of preparation of scope and extent of the mitigation measures. A3.1 Preparation of an ESMP Report This section provides technical guidelines for preparing an ESMP as a standalone document as part of Category B subproject to be submitted to the World Bank through the outline and content of the ESMP report. The ESMP is the key documents to be used during the implementation of the subproject and monitoring of safeguard compliance covering both environment and social aspects during construction and operation of the subprojects (non-resettlement and ethnic peoples that are required to comply with OP/BP 4.10 and OP/BP 4.12). It is important to ensure the following: • Detailed design and preparation of bidding and contract documents: To minimize the impact during land clearance, construction, and operation, it is important for the Bidder to submit the following additional documents in its Bid, including Code of Conduct (ESHS), and Management Strategies and Implementation Plans (MSIP) to manage the (ESHS) risks. • Before starting construction, the subproject owners and/or supervisor certify that (a) all compensation for land acquisition and affected facilities, the relocation of households and / or recovery of land / land donation has been completed, (b) subproject environmental impact assessment and / or the specific mitigation measures approved by the government, and (c) the ESMP above was approved by the Government. The Contractor shall submit for approval, and subsequently implement, the Contractor’s Environment and Social Management Plan (C-ESMP), in accordance with the Particular Conditions of Contract Sub-Clause 16.2, that includes the agreed Management Strategies and Implementation Plans. • During construction, the subproject owners and/or supervision consultant closely monitor and supervise Contractor’s compliance with Environment, Social, Health and Safety Requirements set out within Section 7 – Works’ Requirements of SPD and include the contractor performance on the Environmental, Social, Health and Safety (ESHS) metrics set out in Appendix B of SPDsin the subproject progress report. • After completing the construction, the subproject owners and/or supervision consultant confirms contractor’s compliance with the ESHS requirements including ensuring that any damage incurred by the contractor has been properly addressed. If necessary, it should be ordered to pay compensation/rehabilitation of the construction sector as stipulated in the contract. (a) Scope and Content of ESMP report The ESMP outline and content should be as follows: • Executive summary: The executive summary summarizes the key findings of the ESMP. It should be clear and concise, ranging from 3-5 pages, and briefly address the following topics: Introduction (based on Section I); World Bank’s safeguard policies and national laws and regulations applied to the project (based on Section II), Project description (based on Section III), baseline datas (based on Section IV), Environmental 77 and social impacts and mitigation measures (based on Section V), monitoring (based on Section VI), ESMP implementation arrangement (based on Section VII), Capacity building, training and technical assistance (based on Section VII), ESMP Implementation budget (based on Section IX) and ESMP consultation and disclosure (based on Section X). • Introduction (Section I): This should provide brief but concise information on: (a) the ESMP context: describe how the EMP fits into the overall planning process of the project, listing project/subproject environmental studies such as EIA/EPP, approval documentation; (b) the ESMP’s connection with the ESMF and the project; (c) the objectives of the ESMP: describe what the ESMP is trying to achieve. The objective should be subproject specific, not broad policy statements. The project-specific ESMP shall form part of the subproject contract specifications. • Policy, legal and administrative framework (Section II): GOV’s regulations: provide brief description of the GoV’s regulations related to EIA and technical regulations and standards applied to the subproject. World Bank’s safeguard policy: list World Bank safeguard policies triggered. • Subproject description (Section III):The subproject objective and description should be provided in sufficient detail to define the nature and scope of the subproject. These should include: (a) Subproject location: site location should be described with location of the activities provided including location maps showing location in the subproject area as well as details at the subproject level; (b) Construction/operation activities: the description may include a brief description of construction and operation processes; working or operating hours, including details of any activities required to be undertaken outside the hours; employment numbers and type; the plant and equipment to be used; the location and site facilities and worker camps; bill of quantities for civil works; and (c) timing and scheduling: anticipated commencement and completion dates should be indicated. If the subproject is to be completed in stages then separate dates for each stage should be provided. • Baseline data (Section IV): This should provide key information on the environmental background of the subproject as well as its connection with the subproject area, including maps. Focus should be given to provide clear data on topography, major land use and water uses, soil types, flow of water, and water quality/pollution. Brief description on socioeconomic condition and EM (if relevant) should also be provided. Photos showing existing conditions of subproject sites should be included. • Potential impacts and mitigation measures (Section V): This section summarizes the predicted positive and negative impacts associated with the proposed subproject/subproject, particularly those presenting impacts of medium to high significance. A summary should be provided of the predicted positive and negative impacts associated with the proposed subproject that require management actions (i.e. mitigation of negative impacts or enhancement of positive impacts). The necessary information for this section should be obtained from the EA process, including the EIA and EPP reports. The impacts should be described for pre-construction, construction, and operation phases. Using a matrix format could help understanding connection between the impacts and mitigation better (See Table 1 below for a sample mitigation measures matrix.). Cross-referencing to the EIA/EPPs reports or other documentation is recommended, so that additional detail can readily be referenced. While commonly- known social and environmental impacts and risks of construction activities can be addressed through Environmental Codes of Practice (ECOP), specific mitigation measures should also be proposed to addressed sub-project specific impacts predicted 78 based on site-specific conditions and typology of investments. Some measures can be proposed for incorporation into engineering design to address potential impacts/risks and/or bring about added values of the works provided (e.g. road/access path improvement combined with canal lining). Mitigation measures should include a communication program and grievance redress mechanism to address social impacts. It is necessary to ensure that this section responds to appropriate suggestions and adequately addresses the issues and concerns raised by communities as recorded in the consultation summary presented in Section A3.5. Depending on impacts of a subproject, Physical Cultural Resources (OP/BP 4.11) or Pest Management (OP 4.09) may be triggered and physical cultural resources and pest management plans may need to be developed and included in the ESMP. Table 1. Template of mitigation measure matrix Phase Issue Mitigati Locatio Applicabl Cost of Responsi Verification on ns for e Mitigati ble party Required to Measur mitigati Standard on determine e on (e.g. effectiveness measur country, of measures es WB, EU) Design/Pre- Construction Construction Operation Decommissioni ng • Monitoring (Section VI): Monitoring of ESMP implementation would encompass environmental compliance monitoring and environmental monitoring during subproject implementation as described in details below: − Environmental compliance monitoring includes a system for tracking environmental compliance of contractors such as checking the performance of contractors or government institutions against commitments expressed in formal documents, such as contract specifications or loan agreements. − The objectives of environmental monitoring is: a) to measure the effectiveness of mitigating actions (e.g. if there is a mitigating action to control noise during construction, the monitoring plan should include noise measurements during construction); b) To meet Borrower’s environmental requirement; and c) to respond to concerns which may arise during public consultation (e.g. noise, heat, odor, etc.), even if the monitoring is not associated with a real environmental issue (it would show good faith by the Borrower). The monitoring program should clearly indicate the linkages between impacts identified in the EA report, indicators to be measured, methods to be used, sampling locations, frequency of measurements, detection limits (where appropriate), and definition of thresholds that will signal the need for corrective actions, and so forth. The cost of environmental monitoring should be estimated and included in sub-project’s total investment costs. It is crucial to monitor and collect data that is useful and will actually be used. There is no value in spending money to collect data that is not properly analyzed, that is not reported 79 or even if reported, no actions can or will be taken. It is useful to know the kinds of analysis to which the data will be subjected before collecting the data to ensure that one can do the anticipated analyses. Table below provides an example of how monitoring is structured. Template of monitoring plan Phase What Where is How is When is Responsible Party parameter the parameter parameter to parameter is to be to be be monitored/ to be monitored? monitored? type of monitored/ (Note if it is monitoring frequency of against a set equipment? measurement standard) or continuous? Pre-construction Construction Operation Decommissioning • ESMP Implementation arrangements (Section VII): The following subsections are recommended: − Responsibility for ESMP implementation: This describes how the implementing agency plans to assign responsibilities to assure proper flow and use of environmental information for efficient and effective environmental management. For a World Bank- financed subproject, the stakeholders involved in ESMP implementation and monitoring usually include the subproject implementing agency, the PMU, construction contractors, construction supervision consultant (CSC), independent environmental monitoring consultant (IEMC), local environmental management authorities, NGOs, and communities. Each player should be assigned with practical responsibilities. Good coordination among these actors ensures effective implementation of the ESMP. Responsibilities of the CSC and IEMC for monitoring and supervision of ESMP compliance during construction and supervision should be indicated in some detail. Generic Terms of Reference for CSC and IEMC should be included in the ESMP as annexes. − Incorporation of ESMP into detailed technical design and bidding and contractual document: The bidding and contractual documents should include ESMP requirements documents to ensure that obligations are clearly communicated to contractors. The bidding documents might also include environmental criteria as part of the basis for selecting contractors. Contractors should also be obliged to follow appropriate environmental, health, and safety standards to reduce associated risks during construction and operation. Therefore, this section should also elaborate on how PMU and its staff will incorporate ESMP into the subproject detailed design and tendering documents. − Environmental compliance framework: During subproject implementation, the Borrower reports on compliance with environmental commitments, the status of mitigative measures, and the findings of monitoring programs as specified in the subproject documents. The World Bank bases supervision of the subproject’s 80 environmental aspects of the ESMP as set out in the legal agreements for the subproject. This subsection elaborates on the environmental duties of the contractor and its safety and environment officer, compliance with legal and contractual requirements, and environmental supervision during construction supervision, and a penalty framework. − Reporting procedures: Procedures to provide information on the progress and results of mitigation and monitoring measures should be clearly specified. As a minimum, the recipients of such information should include those with responsibility for ensuring timely implementation of mitigation measures, and for undertaking remedial actions in response to breaches of monitoring thresholds. In addition, the structure, content and timing of reporting to the World Bank should be designed to facilitate supervision. Responsibility of different actors for reporting and the type of reports should also be clearly indicated. • Institutional Strengthening Plan (Section VIII): This section describes institutional needs to assure successful implementation of the mitigation and monitoring plans. This may include equipment purchases, training, consultant services, and special studies. Most subprojects would mainly require capacity strengthening in ESMP implementation through training for different stakeholders. All relevant stakeholders should undergo general environmental awareness training and training about their responsibilities under the ESMP. The training should ensure that they understand their obligation to exercise proper environmental management during subproject implementation. Environmental training should include: a site induction, familiarization with the requirements of the ESMP; environmental emergency response training; familiarization with site environmental control; targeted environmental training for specific personnel such as environmental staff of PMU, safety and environment officer of the contractor, construction supervision engineer. The need for additional or revised training should be identified and implemented from the outputs of monitoring and reviewing the ESMP. Records of all training should be maintained and include: who was trained; when the person was trained; the name of the trainer; and a general description of the training content. • Estimated Budget for ESMP Implementation (Section IX): These should be specified for both the initial investment and recurring expenses for implementing all measures contained in the ESMP, integrated into the total project costs, and factored into loan negotiations. It is important to capture all costs, including administrative, training, environmental monitoring and supervision, costs for mitigation measures to be implemented by contractors, costs for additional environmental studies, and operational and maintenance costs. The aim is to satisfactorily mitigate adverse impacts at least cost. The costs of preparing an ESMP, which are borne by the Borrower, vary depending on factors such as the complexity of potential impacts, the extent to which international consultants are used, and the need to prepare separate ESMPs for subprojects. (b) Consultation and Information Disclosure (Section X) Consultation: The ESMP should clearly describe and justify the proposed mitigation measures to facilitate public consultation. Consultation with affected people and NGOs should be integral to all Category A and B projects in order to understand the acceptability of proposed mitigation measures to affected groups. In some situations, the development of environmental awareness amongst stakeholders is important to ensure effective consultation on the ESMP. Where projects involve land acquisition or resettlement, these issues should be fully addressed in resettlement action plan (RAP), and where appropriate in ethnic minority development plan (EMDP). 81 • The consultation process can also be used help to design achievable mitigation measures. This process is particularly important when it depends on the buy-in of the affected people. Where appropriate, this may be supported by including formal requirements within the TOR for public participation in developing the ESMP. • Public consultation of ESMP should be an integral part of EIA/EPP consultation. If consultation has not been conducted or not adequately carried out during EIA/EPP preparation process, it must be undertaken to capture the feedbacks of the affected people and communities. This section provides summary on consultation activities to stakeholders, particularly affected households, on the final draft ESMP at project/subproject level. This summary should indicate the date and location where consultation meeting took place, the number of participants from affected households, the numbers of female and ethnic minority participants, and suggestions, and concerns raised and responses. Locations and dates of ESMP to be disclosed should be provided. Disclosure of the ESMP: Information disclosure: According to the World Bank’s policy on access to information, draft and final ESMP are disclosed locally in an accessible place and in a form and language understandable to key stakeholders and in English at the Bank external website before the appraisal mission. A3.2 Guidance on Public Consultation The Bank’s safeguard policies require the subproject’s owner to facilitate public consultation and information disclosure. Accordingly, consultation with project affected people (PAPs) and local NGOs is required for this project and its subprojects. During the preparation of ESMPs, public consultation must be carried out in line with the Bank’s requirements in a form convenient to the local people (e.g. survey, meeting, leaflet, signboard etc.) and information on the main findings of environmental impacts and proposed mitigation measures must be provided in the local language understandable for the majority of the affected people. Records of feedback from public consultation should be attached to final draft ESMP while the main EMP should include a section summarizing public concerns and suggestions. The ESMP should clearly state that environmental concerns and suggestions for environmental improvement made by the public have been incorporated. It is required that ESMPs include a summary table to show the number of meetings, the place, the number of PAPs attended meetings. The subproject’s owner should confirm with the Bank that hard copies of draft ESMP (in Vietnamese) are disclosed at the subproject areas, at the PPMU office and Commune People Committee’s office, and place accessible to the public and the time for such disclosure. The subproject owner also sends ESMP in English language to the Bank for disclosure at the Bank external website. A3.4 Preparation of EIA/EPP per the GOV’s EIA Regulations In addition, the subproject is that funded within the framework of the project will be prepared with EAdocuments required by the Government of Vietnam. The details areas follows: • Government’s review and approval. If a subproject requires review and approval according to the GoV’sEA regulation, the subproject owner will prepare and submit the EA report as required for review and secure the approval by relevant government authorities before subproject appraisal. The guidelines for appraisal and approval of an EIAs or EPPs are included in the respective government regulation (namely, Decree 18/2015/NÃ?-CP dated 14 February 2015 regarding regulations on strategic environmental assessment, environmental impacts assessment and environmental protection plan, and Circular 27/2015/TT-BTNMT dated 29 May 2015 detailing some articles of Decree 18/2015/NÃ?-CP). The approval decision will be provided to the 82 World Bank for information. 83 Annex 10: Environmental Codes of Practice (ECOP) Note: This ECOP might be adjusted proportionate to environmental and social risks and impacts of an identified subproject in consultation with the Bank during project implementation. Environmental and Mitigation measures Applicable Standards, Responsibility social issues Regulations and Implementation Supervision Guidelines Air pollution - Minimizing dust from material handling sources, such as conveyors - TCVN 6438-2005: Contractor PPMU, its and bins, by using covers and/or control equipment (water Road vehicles - CSC, local suppression, bag house, or cyclone). Maximum permitted community emission limits of - Minimizing dust from open area sources, including storage piles, by exhaust gas using control measures such as installing enclosures and covers, and increasing the moisture content. - Decision No. 35/2005/QD-BGTVT - Dust suppression techniques should be implemented, such as on inspection of applying water or non-toxic chemicals to minimize dust from quality, technical vehicle movements. safety and - Selectively removing potential hazardous air pollutants, such as environmental asbestos, from existing infrastructure prior to demolition. protection - Managing emissions from mobile sources. - QCVN 05: 2013/MONRE: - Avoiding open burning of solid. National technical regulation on ambient air quality - WBG EHS Guidelines 84 Environmental and Mitigation measures Applicable Standards, Responsibility social issues Regulations and Implementation Supervision Guidelines Noise and vibration - Planning activities in consultation with local communities so that - QCVN Contractor PPMU, its activities with the greatest potential to generate noise are planned 26:2010/BTNMT: CSC, local during periods of the day that will result in least disturbance. National technical community regulation on noise - Using noise control devices, such as temporary noise barriers and deflectors for impact and blasting activities, and exhaust muffling - QCVN devices for combustion engines. 27:2010/BTNMT: National technical - Avoiding or minimizing project transportation through community regulation on areas. vibration - WBG EHS Guidelines Soil erosion and - Scheduling to avoid heavy rainfall periods (i.e., during the dry - WBG EHS Contractor PPMU, its Sedimentation season) to the extent practical. Guidelines CSC, local community - Contouring and minimizing length and steepness of slopes. - Mulching to stabilize exposed areas. - Re-vegetating areas promptly. - Designing channels and ditches for post-construction flows. - Lining steep channel and slopes (e.g. use jute matting). - Reducing or preventing off-site sediment transport through use of settlement ponds, silt fences, and water treatment, and modifying or suspending activities during extreme rainfall and high winds to the extent practical. 85 Environmental and Mitigation measures Applicable Standards, Responsibility social issues Regulations and Implementation Supervision Guidelines Water pollution - The Contractor must be responsible for compliance with the relevant - QCVN 09- Contractor PPMU, its Vietnamese legislation relevant to wastewater discharges into MT:2015/BTNMT: CSC, local watercourses. National technical community regulation on - Portable or constructed toilets must be provided on site for groundwater quality construction workers. Wastewater from toilets as well as kitchens, showers, sinks, etc. shall be discharged into a conservancy tank for - QCVN removal from the site or discharged into municipal sewerage 14:2008/BTNMT: systems; there should be no direct discharges to any waterbody. National technical regulation on - Wastewater over standards set by relevant Vietnam technical domestic wastewater standards/regulations must be collected in a conservancy tank and removed from site by licensed waste collectors. - QCVN 08- MT:2015/BTNMT – - Make appropriate arrangements for collecting, diverting or National technical intercepting wastewater from worker camps to ensure minimal regulation on surface discharge or local clogging and flooding. water quality - Segregating or diverting clean water runoff to prevent it mixing with - WBG EHS water containing a highsolids content, to minimize the volume of Guidelines water to be treated prior to release. - Providing adequate drainage systems to minimize and control infiltration. - Before construction, all necessary wastewater disposal permits/licenses and/or wastewater disposal contract have been obtained. - At completion of construction works, wastewater collection tanks and septic tanks shall be safely disposed or effectively sealed off. 86 Environmental and Mitigation measures Applicable Standards, Responsibility social issues Regulations and Implementation Supervision Guidelines Biodiversity - The Contractor shall prepare a Clearance, Revegetation and - Law on Biodiversity Contractor PPMU, its Restoration Management Plan for prior approval by the No.20/2008/QH12 CSC, local Construction Engineer, following relevant regulations. The community Clearance Plan shall be approved by Construction Supervision Consultant and followed strictly by contractor. Areas to be cleared should be minimized as much as possible. - Site clearance in a forested area is subject to permission from Department of Agriculture and Rural Development. - The Contractor shall remove topsoil from all areas where topsoil will be impacted on by rehabilitation activities, including temporary activities such as storage and stockpiling, etc; the stripped topsoil shall be stockpiled in areas agreed with the Construction Supervision Consultant for later use in re-vegetation and shall be adequately protected. - The application of chemicals for vegetation clearing is not permitted. - Prohibit cutting of any tree unless explicitly authorized in the vegetation clearing plan. - When needed, erect temporary protective fencing to efficiently protect the preserved trees before commencement of any works within the site. - No area of potential importance as an ecological resource should be disturbed unless there is prior authorization from CSC, who should consult with PPMU and the relevant local authorities. This could include areas of breeding or feeding of birds or animals, fish spawning areas, or any area that is protected as a green space. - The Contractor shall ensure that no hunting, trapping shooting, poisoning of fauna takes place. 87 Environmental and Mitigation measures Applicable Standards, Responsibility social issues Regulations and Implementation Supervision Guidelines Stockpiles and Borrow - Large-scale borrow pits or stockpiles will need site-specific Contractor PPMU, its pits measures that go beyond those in this ECOP. CSC, local community - All locations to be used must be previously identified in the approved construction specifications. - An open ditch shall be built around the stockpile site to intercept wastewater. - Stockpile topsoil when first opening a borrow pit and use it later to restore the area to near natural conditions. - If the need for new sites arises during construction, they must be pre- approved by the Construction Engineer. - If landowners are affected by use of their areas for stockpiles or borrow pits, they must be included in the subproject RAP. - If access roads are needed, they must have been considered in the environmental assessment. 88 Wastes I. General Wastes - QCVN Contractor PPMU, its 14:2008/BTNMT: CSC, local (a) Wastewater National technical community - The Contractor shall be responsible for compliance with the relevant regulation on Vietnamese regulations on wastewater discharges into surroundings. domestic wastewater - Consider hiring local workers to reduce wastewater generation on - QCVN 40: 2011/ site. BTNMT: National technical regulation - Septic systems shall be provided for treatment and disposal of on industrial domestic sanitary sewage in areas with no sewerage collection wastewater networks. Septic systems should only be used for treatment of sanitary sewage. When septic systems are the selected form of - Decree No. wastewater disposal and treatment, they should be: 38/2015/NÄ?-CP dated 24/04/2015 on • Properly designed and installed in accordance with local waste and scrap regulations and guidance to prevent any hazard to public health management or contamination of land, surface or groundwater. - Circular No. • Well maintained to allow effective operation. 36/2015/TT- • Installed in areas with sufficient soil percolation for the BTNMT on design wastewater loading rate. management of hazardous wastes • Installed in areas of stable soils that are nearly level, well drained, and permeable, with enough separation between the - Decision No. drain field and the groundwater table or other receiving waters. 59/2007/NÄ?-CP on solid waste - Wastewater from washing vehicles and construction equipment management shall be collected into a settling pond before discharged into local drainage system. - WBG EHS Guidelines - At completion of construction works, wastewater collection tanks and septic tanks shall be safely disposed of or effectively sealed off. (b) Storm water 25 - Storm water should be separated from process and sanitary wastewater streams in order to reduce the volume of wastewater to be treated prior to discharge. 89 25 Storm water includes any surface runoff and flows resulting from precipitation, drainage or other sources. Typically storm water runoff contains suspended sediments, metals, petroleum hydrocarbons, Polycyclic Aromatic Hydrocarbons (PAHs), coliform, etc. Rapid runoff, even of uncontaminated storm water, also degrades the quality of the receiving water by eroding stream beds and banks. 90 - Surface runoff from process areas or potential sources of contamination should be prevented. - Where this approach is not practical, runoff from process and storage areas should be segregated from potentially less contaminated runoff. - Runoff from areas without potential sources of contamination should be minimized (e.g. by minimizing the area of impermeable surfaces) and the peak discharge rate should be reduced (e.g. by using vegetated swales and retention ponds). - Where stormwater treatment is deemed necessary to protect the quality of receiving water bodies, priority should be given to managing and treating the first flush of stormwater runoff where the majority of potential contaminants tend to be present. - When water quality criteria allow, stormwater should be managed as a resource, either for groundwater recharge or for meeting water needs at the facility. - Oil water separators and grease traps should be installed and maintained as appropriate at refueling facilities, workshops, parking areas, fuel storage and containment areas. - Sludge from stormwater catchments or collection and treatment systems may contain elevated levels of pollutants and should be disposed in compliance with local regulatory requirements, in the absence of which disposal has to be consistent with protection of public health and safety, and conservation and long term sustainability of water and land resources. (c) Solid waste - Before construction, a solid waste control procedure (storage, provision of bins, site clean-up schedule, bin clean-out schedule, etc.) shall be prepared by Contractors and it must be carefully followed during construction activities. - Before construction, all necessary waste disposal permits or licenses 91 shall be obtained. - Measures shall be taken to reduce the potential for litter and negligent behavior with regard to the disposal of all refuse. At all places of work, the Contractor shall provide litter bins, containers and refuse collection facilities. - Solid waste shall be temporarily stored on site in a designated area approved by the Construction Supervision Consultant and relevant local authorities prior to collection and disposal through a licensed waste collector. - Waste storage containers shall be covered, tip-proof, weatherproof and scavenger proof. - No burning, on-site burying or dumping of solid waste shall occur. - Recyclable materials such as wooden plates for trench works, steel, scaffolding material, site holding, packaging material, etc shall be collected and separated on-site from other waste sources for reuse, for use as fill, or for sale. - If not removed off site, solid waste or construction debris shall be disposed of only at sites identified and approved by the Construction Supervision Consultant and included in the solid waste plan. Under no circumstances shall the contractor dispose of any material in environmentally sensitive areas, such as in areas of natural habitat or in watercourses. II. Hazardous Wastes (a) Storage of hazardous wastes Hazardous waste should be stored so as to prevent or control accidental releases to air, soil, and water resources in area location where: - Waste is stored in a manner that prevents the commingling or contact between incompatible wastes, and allows for inspection between containers to monitor leaks or spills. Examples include sufficient space between incompatibles or physical separation such as walls or containment curbs. 92 - Store in closed containers away from direct sunlight, wind and rain. - Storage should be on an impermeable surface that readily able to be cleaned, and that is appropriately bunded to contain any spills or leaks. The storage area should be covered to prevent rainwater from accumulating in the bunded area. - Secondary containment systems should be constructed with materials appropriate for the wastes being contained and adequate to prevent loss to the environment. - Secondary containment is included wherever liquid wastes are stored in volumes greater than 220 liters. The available volume of secondary containment should be at least 110 percent of the largest storage container, or 25 percent of the total storage capacity (whichever is greater), in that specific location. - Provide adequate ventilation where volatile wastes are stored. (b) Hazardous Wastes Transportation - On-site and Off-site transportation of waste should be conducted so as to prevent or minimize spills, releases, and exposures to employees and the public. - All waste containers designated for off-site shipment should be secured and labeled with the contents and associated hazards, be properly loaded on the transport vehicles before leaving the site, and be accompanied by a shipping paper (i.e., manifest) that describes the load and its associated hazards, consistent with the guidance. (c) Disposal of hazardous wastes - Chemical wastes of any kind shall be disposed of at an approved appropriate landfill site and in accordance with local legislative requirements. The Contractor shall obtain needed disposal certificates. - The removal of hazardous wastes shall be performed and disposed of by specially trained and certified workers. 93 Environmental and Mitigation measures Applicable Standards, Responsibility social issues Regulations and Implementation Supervision Guidelines - Used oil, lubricants, cleaning materials, etc. from the maintenance of vehicles and machinery shall be collected in holding tanks and removed from site by a specialized oil recycling company for disposal at an approved hazardous waste site. - Unused or rejected tar or bituminous products shall be returned to the supplier’s production plant. 94 Hazardous materials Hazardous Materials Transfer - WBG EHS Contractor PPMU, its Guidelines CSC, local - Use of dedicated fittings, pipes, and hoses specific to materials in community tanks (e.g., all acids use one type of connection, all caustics use - Decree No. another), and maintaining procedures to prevent addition of 38/2015/NÄ?-CP hazardous materials to incorrect tanks. dated 24/04/2015 on waste and scrap - Use of transfer equipment that is compatible and suitable for the management characteristics of the materials transferred and designed to ensure safe transfer. - Circular No. 36/2015/TT-BTNMT - Regular inspection, maintenance and repair of fittings, pipes and on hazardous waste hoses. management - Provision of secondary containment, drip trays or other overflow and drip containment measures, for hazardous materials containers at connection points or other possible overflow points. Overfill Protection - Prepare written procedures for transfer operations that includes a checklist of measures to follow during filling operations and the use of filling operators trained in these procedures. - Installation of gauges on tanks to measure volume inside. - Use of dripless hose connections for vehicle tank and fixed connections with storage tanks. - Provision of automatic fill shutoff valves on storage tanks to prevent overfilling. - Use of a catch basin around the fill pipe to collect spills. - Use of piping connections with automatic overfill protection (float valve). - Pumping less volume than available capacity into the tank or vessel by ordering less material than its available capacity. - Provision of overfill or over pressure vents that allow controlled release to a capture point. 95 Reaction, Fire and Explosion Prevention - Storage of incompatible materials (acids, bases, flammables, oxidizers, reactive chemicals) in separate areas, and with containment facilities separating material storage areas. - Provision of material-specific storage for extremely hazardous or reactive materials. - Use of flame arresting devices on vents from flammable storage containers. - Provision of grounding and lightning protection for tank farms, transfer stations, and other equipment that handles flammable materials. - Selection of materials of construction compatible with products stored for all parts of storage and delivery systems, and avoiding reuse of tanks for different products without checking material compatibility. - Storage of hazardous materials in an area of the facility separated from the main production works. Where proximity is unavoidable, physical separation should be provided using structures designed to prevent fire, explosion, spill, and other emergency situations from affecting facility operations. - Storage should be on an impermeable surface that readily able to be cleaned, and that is appropriately bunded to contain any spills or leaks. The storage area should be covered to prevent rainwater from accumulating in the bunded area. - Prohibition of all sources of ignition from areas near flammable storage tanks. Secondary Containment (Liquids) - Transfer of hazardous materials from vehicle tanks to storage in areas with surfaces sufficiently impervious to avoid loss to the environment and sloped to a collection or a containment structure 96 not connected to municipal wastewater/stormwater collection system. - Where it is not practical to provide permanent, dedicated containment structures for transfer operations, one or more alternative forms of spill containment should be provided, such as portable drain covers (which can be deployed for the duration of the operations), automatic shut-off valves on storm water basins, or shut off valves in drainage or sewer facilities, combined with oil-water separators. - Storage of drummed hazardous materials with a total volume equal or greater than 1,000 liters in areas with impervious surfaces that are sloped or bermed to contain a minimum of 25 percent of the total storage volume. - Provision of secondary containment for components (tanks, pipes) of the hazardous material storage system, to the extent feasible. - Conducting periodic (e.g. daily or weekly) reconciliation of tank contents, and inspection of visible portions of tanks and piping for leaks. - Use of double-walled, composite, or specially coated storage and piping systems particularly in the use of underground storage tanks (USTs) and underground piping. If double walled systems are used, they should provide a means of detecting leaks between the two walls. Training - Employees should be provided training on Hazmat management. The training program should include: - A list of employees to be trained. - Specific training objectives. - Mechanisms to achieve the objectives (i.e., hands-on workshops, videos, etc.). - The means to determine whether the training program is effective. 97 Environmental and Mitigation measures Applicable Standards, Responsibility social issues Regulations and Implementation Supervision Guidelines - Training procedures for new hires and refresher courses for existing employees. Community Involvement and Awareness - Availability of general information to the potentially affected community on the nature and extent of project operations, and the prevention and control measures in place to ensure no effects to human health. - The potential for off-site effects to human health or the environment following an accident at planned or existing hazardous installations. - Specific and timely information on appropriate behavior and safety measures to be adopted in the event of an accident including practice drills in locations with higher risks. - Access to information necessary to understand the nature of the possible effect of an accident and an opportunity to contribute effectively, as appropriate, to decisions concerning hazardous installations and the development of community emergency preparedness plans. - DONRE and DOH shall be promptly informed of any accidental spill or incident. - Prepare and initiate a remedial action following any spill or incident. In this case, the contractor shall provide a report explaining the reasons for the spill or incident, remedial action taken, consequences/damage from the spill, and proposed corrective actions. 98 Traffic safety - Contractor shall strictly comply with Law on Roadway Traffic - Law on traffic and Contractor PPMU, its transport No. CSC, local - Adoption of best transport safety practices across all aspects of 23/2008/QH12; community subproject operations with the goal of preventing traffic accidents and minimizing injuries suffered by subproject personnel and the - Decree 46/2016/ND- public. Measures should include: CP on administrative penalty for traffic • Emphasizing safety aspects among drivers. safety violation • Improving driving skills and requiring licensing of drivers. - Circular No. • Adopting limits for trip duration and arranging driver rosters to 22/2010/TT-BXD on avoid overtiredness. regulation on labour safety in construction • Avoiding dangerous routes and times of day to reduce the risk of accidents. - WBG EHS Guidelines • Use of speed control devices (governors) on trucks, and remote monitoring of driver actions. - Regular maintenance of vehicles and use of manufacturer approved parts to minimize potentially serious accidents caused by equipment malfunction or premature failure. - Minimizing pedestrian interaction with construction vehicles. - Collaboration with local communities and responsible authorities to improve signage, visibility and overall safety of roads, particularly along stretches located near schools or other locations where children may be present. Collaborating with local communities on education about traffic and pedestrian safety (e.g. school education campaigns). - Coordination with emergency responders to ensure that appropriate first aid is provided in the event of accidents. - Using locally sourced materials, whenever possible, to minimize transport distances. Locating associated facilities such as worker camps close to subproject sites and arranging worker bus transport to minimizing external traffic. 99 Environmental and Mitigation measures Applicable Standards, Responsibility social issues Regulations and Implementation Supervision Guidelines - Employing safe traffic control measures, including road signs and flag persons to warn of dangerous conditions. Workers’ camp - The Contractor and worker camps will be constructed on the land - Law on Labor Contractor PPMU, its temporarily acquired by the subproject. No.10/2012/QH13 CSC, local community - The camps will be constructed far enough from the places to be used for stockpile of construction materials, fuel storage, garbage storage, wastewater drainage canal, sensitive sites such as school, hospital, church, pagoda, temple, and other dangerous areas such as landslide, land subsidence, and erosion. - The camps must be ensured with good environmental conditions such as ventilation, full sunlight, clean water, garbage collection, hygienic toilets, mosquito net, fire extinguishers, first-aid kits, and other health protection measures to all workers. 100 Where the risk and identification process determines that there is a Chance Find - Law on cultural Contractor PPMU, its chance of impacts to cultural heritage, the Contractor will retain Procedures heritage No. CSC, local competent professionals to assist in the identification and protection of 28/2001/QH10; community cultural heritage. If the Contractor discovers archeological sites, historical sites, remains - Amended and and objects, including graveyards and/or individual graves during supplemented Law excavation or construction, the Contractor shall: on cultural heritage No. 32/2009/QH12; + Stop the construction activities in the area of the chance find; - Amended and + Delineate the discovered site or area; supplemented Decree + Secure the site to prevent any damage or loss of removable No. 98/2010/ND-CP objects. In cases of removable antiquities or sensitive remains, a night guard shall be arranged until the responsible local authorities or the Department of Culture and Information takes over; + Notify the Construction Supervision Consultant who in turn will notify responsible local or national authorities in charge of the Cultural Property of Viet Nam (within 24 hours or less); + Relevant local or national authorities would be in charge of protecting and preserving the site before deciding on subsequent appropriate procedures. This would require a preliminary evaluation of the findings to be performed. The significance and importance of the findings should be assessed according to the various criteria relevant to cultural heritage; those include the aesthetic, historic, scientific or research, social and economic values; + Decisions on how to handle the finding shall be taken by the responsible authorities. This could include changes in the layout (such as when finding an irremovable remain of cultural or archeological importance) conservation, preservation, restoration and salvage; + If the cultural sites and/or relics are of high value and site preservation is recommended by the professionals and required 101 Environmental and Mitigation measures Applicable Standards, Responsibility social issues Regulations and Implementation Supervision Guidelines by the cultural relics authority, the subproject owner will need to make necessary design changes to accommodate the request and preserve the site; + Decisions concerning the management of the finding shall be communicated in writing by relevant authorities; and + Construction works could resume only after permission is granted from the responsible local authorities concerning safeguard of the heritage. 102 Occupational health Over-exertion - Directive No. 02 Contractor PPMU, its and safety /2008/CT-BXD on CSC, local - Training of workers in lifting and materials handling techniques in community labour safety and construction and decommissioning, including the placement of sanitation in weight limits above which mechanical assists or two-person lifts are construction necessary. agencies; - Planning work site layout to minimize the need for manual transfer - Circular No. of heavy loads. 22/2010/TT-BXD on - Selecting tools and designing work stations that reduce force regulation on labour requirements and holding times, and which promote improved safety in construction postures, including, where applicable, user adjustable work stations. - QCVN - Implementing administrative controls into work processes, such as 18:2014/BXD: job rotations and rest or stretch breaks. Technical regulation on safety in Slips and Falls construction - Implementing good house-keeping practices, such as the sorting and - WBG EHS placing loose construction materials or demolition debris in Guidelines established areas away from foot paths. - Cleaning up excessive waste debris and liquid spills regularly. - Locating electrical cords and ropes in common areas and marked corridors. - Use of slip retardant footwear. Work in Heights - Training and use of temporary fall prevention devices, such as rails or other barriers able to support a weight of 200 pounds, when working at heights equal or greater than two meters or at any height if the risk includes falling into operating machinery, into water or other liquid, into hazardous substances, or through an opening in a work surface. - Training and use of personal fall arrest systems, such as full body harnesses and energy absorbing lanyards able to support 2,268 kg 103 (also described in this section in Working at Heights above), as well as fall rescue procedures to deal with workers whose fall has been successfully arrested. The tie in point of the fall arresting system should also be able to support 2,268 kg. - Use of control zones and safety monitoring systems to warn workers of their proximity to fall hazard zones, as well as securing, marking, and labeling covers for openings in floors, roofs, or walking surfaces. Struck By Objects - Using a designated and restricted waste drop or discharge zones, and/or a chute for safe movement of wastes from upper to lower levels. - Conducting sawing, cutting, grinding, sanding, chipping or chiseling with proper guards and anchoring as applicable. - Maintaining clear traffic ways to avoid driving of heavy equipment over loose scrap. - Use of temporary fall protection measures in scaffolds and out edges of elevated work surfaces, such as hand rails and toe boards to prevent materials from being dislodged. - Evacuating work areas during blasting operations, and using blast mats or other means of deflection to minimize fly rock or ejection of demolition debris if work is conducted in proximity to people or structures. - Wearing appropriate PPE, such as safety glasses with side shields, face shields, hard hats, and safety shoes. Moving Machinery - Planning and segregating the location of vehicle traffic, machine operation, and walking areas, and controlling vehicle traffic through the use of one-way traffic routes, establishment of speed limits, and on-site trained flag-people wearing high-visibility vests or outer 104 clothing covering to direct traffic. - Ensuring the visibility of personnel through their use of high visibility vests when working in or walking through heavy equipment operating areas, and training of workers to verify eye contact with equipment operators before approaching the operating vehicle. - Ensuring moving equipment is outfitted with audible back-up alarms. - Using inspected and well-maintained lifting devices that are appropriate for the load, such as cranes, and securing loads when lifting them to higher job-site elevations. Dust - Dust suppression techniques should be implemented, such as applying water or non-toxic chemicals to minimize dust from vehicle movements. - PPE, such as dusk masks, should be used where dust levels are excessive. Confined Spaces and Excavations - Controlling site-specific factors which may contribute to excavation slope instability including, for example, the use of excavation dewatering, side-walls support, and slope gradient adjustments that eliminate or minimize the risk of collapse, entrapment, or drowning. - Providing safe means of access and egress from excavations, such as graded slopes, graded access route, or stairs and ladders. - Avoiding the operation of combustion equipment for prolonged periods inside excavations areas where other workers are required to enter unless the area is actively ventilated. Other Site Hazards - Use of specially trained personnel to identify and remove waste materials from tanks, vessels, processing equipment or 105 Environmental and Mitigation measures Applicable Standards, Responsibility social issues Regulations and Implementation Supervision Guidelines contaminated land as a first step in decommissioning activities to allow for safe excavation, construction, dismantling or demolition. - Use of specially trained personnel to identify and selectively remove potentially hazardous materials in building elements prior to dismantling or demolition including, for example, insulation or structural elements containing asbestos and Polychlorinated Biphenyls (PCBs), electrical components containing mercury. - Use of waste-specific PPE based on the results of an occupational health and safety assessment, including respirators, clothing/protective suits, gloves and eye protection. 106 A. General Site Hazards Community’s health - Law on Roadway Contractor PPMU, its and safety - Subproject should implement risk management strategies to protect Traffic No. CSC, local the community from physical, chemical, or other hazards associated 23/2008/QH12 community with sites under construction. - Directive No. 02 - Restricting access to the site, through a combination of institutional /2008/CT-BXD on and administrative controls, with a focus on high risk structures or labour safety and areas depending on site-specific situations, including fencing, sanitation in signage, and communication of risks to the local community. construction agencies; - Removing hazardous conditions on construction sites that cannot be controlled affectively with site access restrictions, such as covering - Circular No. openings to small confined spaces, ensuring means of escape for 22/2010/TT-BXD on larger openings such as trenches or excavations, or locked storage of regulation on labour hazardous materials. safety in construction B. Disease Prevention - QCVN Communicable Diseases 18:2014/BXD: Technical regulation - Providing surveillance and active screening and treatment of on safety in workers. construction - Preventing illness among workers in local communities by: - WBG EHS Guidelines • Undertaking health awareness and education initiatives, for example, by implementing an information strategy to reinforce person-to-person counseling addressing systemic factors that can influence individual behavior as well as promoting individual protection, and protecting others from infection, by encouraging condom use. • Training health workers in disease treatment. • Conducting immunization programs for workers in local communities to improve health and guard against infection. • Providing health services. • Providing treatment through standard case management in on- 107 site or community health care facilities. Ensuring ready access to medical treatment, confidentiality and appropriate care, particularly with respect to migrant workers. • Promoting collaboration with local authorities to enhance access of workers families and the community to public health services and promote immunization. Vector-Born Diseases - Prevention of larval and adult propagation through sanitary improvements and elimination of breeding habitats close to human settlements. - Elimination of unusable impounded water. - Increase in water velocity in natural and artificial channels. - Considering the application of residual insecticide to dormitory walls. - Implementation of integrated vector control programs. - Promoting use of repellents, clothing, netting, and other barriers to prevent insect bites. - Use of chemoprophylaxis drugs by non-immune workers and collaborating with public health officials to help eradicate disease reservoirs. - Monitoring and treatment of circulating and migrating populations to prevent disease reservoir spread. - Collaboration and exchange of in-kind services with other control programs in the subproject area to maximize beneficial effects. - Educating subproject personnel and area residents on risks, prevention, and available treatment. - Monitoring communities during high-risk seasons to detect and treat cases. 108 Environmental and Mitigation measures Applicable Standards, Responsibility social issues Regulations and Implementation Supervision Guidelines - Distributing appropriate education materials. - Following safety guidelines for the storage, transport, and distribution of pesticides to minimize the potential for misuse, spills, and accidental human exposure. 109 Communication with Contractor PPMU, its local communities - Maintain open communications with the local government and - Decree No. CSC, local concerned communities; the contractor shall coordinate with local 167/2013/ND-CP on community authorities (leaders of local wards or communes, leader of villages) administrative for agreed schedules of construction activities at areas nearby penalty for violations sensitive places or at sensitive times (e.g., religious festival days). related to social security, order and - Copies in Vietnamese of this ECOP and of other relevant safety issues environmental safeguard documents shall be made available to local communities and to workers at the site. - WBG EHS - Reduced playground space, loss of playing fields and car parking: Guidelines The loss of amenities during the construction process is often an unavoidable source of inconvenience to users in sensitive areas. However, early consultation with those affected, provides the opportunity to investigate and implement alternatives. - Disseminate subproject information to affected parties (for example local authority, enterprises and affected households, etc) through community meetings before construction commencement. - Provide a community relations contact from whom interested parties can receive information on site activities, subproject status and subproject implementation results. - Provide all information, especially technical findings, in a language that is understandable to the general public and in a form of useful to interested citizens and elected officials through the preparation of fact sheets and news release, when major findings become available during subproject implementation phase. - Monitor community concerns and information requirements as the subproject progresses. - Respond to telephone inquiries and written correspondence in a timely and accurate manner. - Inform local residents about construction and work schedules, interruption of services, traffic detour routes and provisional bus routes, blasting and demolition, as appropriate. 110 Environmental and Mitigation measures Applicable Standards, Responsibility social issues Regulations and Implementation Supervision Guidelines - Limit construction activities at night. When necessary ensure that night work is carefully scheduled and the community is properly informed so they can take necessary measures. - At least 15 days in advance of any service interruption (including water and electricity supply, telephone service, bus service, etc.) the community must be advised through postings at the subproject site, at bus stops, and in affected homes/businesses. - Provide technical documents and drawings to local authority and community. - Notification boards shall be erected at all construction sites providing information about the subproject, as well as contact information about the site managers, environmental staff, health and safety staff, telephone numbers and other contact information so that any affected people can have the channel to voice their concerns and suggestions - If a local community may be at risk from a potential emergency arising at the construction site, the contractor should implement communication measures to alert the community, such as: + Audible alarms, such as fire bells or sirens. + Fan out telephone call lists. + Vehicle mounted speakers. + Communicating details of the nature of the emergency. + Communicating protection options (evacuation, quarantine). + Providing advise on selecting an appropriate protection option. Environmental quality monitoring In case an environmental quality monitoring is required during construction, the followings are implemented. 111 IMPACT PARAMETERS TO BE APPLICABLE LOCATION FREQUENCY MONITORED NATIONAL STANDARD NO. Dust emission TSP QCVN 05:2013/BTNMT – Vicinity of clearing works, materials In windy conditions or National technical stockpile, and/or community areas when traffic is heavy regulation on ambient air quality Noise generation Noise level (Leq) QCVN 26:2010/BTNMT – In the vicinity of sensitive receivers In response to complaints National technical such as habitation, church, school, regulation on noise hospital… Surface water quality pH, TSS, BOD, DO, oil&grease, QCVN 08- Nearby receiving waters After heavy rains and/or degradation Coliform and E.coli MT:2015/BTNMT – once every three or six National technical months regulation on surface water quality 112 Annex 11. Template of Grievance Registration Form This annex applies to all subprojects to be financed by the project. The subproject owner (PPMU) will be responsible for implementation of the GRM process (see ESMF main text Section XI) and complete the GRM registration form and report the results as part of the safeguard monitoring report to be submitted to WB. It is expected that a Community Development Committee (CDC) is established to take the lead in responding to the GRM process. Training will be provided to responsible staff. Grievance Number: ____________ LOCATION: District: _________ Village: ________________________ CDC Name: ___________________________________________ NAME OF COMPLAINANT: ____________________________________ ADDRESS:____________________________________Telephone #: __________________ DATE RECEIVED: Classification of the grievance (Check boxes) ï‚£ Water Use ï‚£ Dispute with contractors ï‚£CDC formation ï‚£ Inter-community dispute ï‚£Land acquisition and Compensation ï‚£ Technical/operational coordination ï‚£ Financial ï‚£ Process delays ï‚£ Water Quality ï‚£ Noise ï‚£ Sanitation ï‚£ Water Use ï‚£ Other (specify)__________________________________________________ Brief description of the grievance: What is the perceived cause? Suggested action (by complainant) to address grievance: 113 Annex 12. Suggested Content of an Environmental Monitoring Report for the Project26 Introduction • Purpose of the report • Report preparation • Brief introduction to the project • Brief project progress Environmental Safeguards Performance • WB safeguard policies applicable to the project List all WB environmental safeguard policies applicable to the project. • PPMU performance Assess PPMU performance in accordance with institutional responsibilities, which are set out in the ESMF or ESMP. • CSC performance Assess CSC performance in accordance with the approved TOR and the provisions in the signed contract. • Contractor performance Assess the contractor’s compliance with ESHS requirements set out in the signed contract and C-ESMP. Assessment should be based on reviewing reports submitted from PPMUs, consultations with local communities and authorities and regular field visits. • Community participation Assess the community participation during implementation, and their contribution to supervision and monitoring of environmental safeguards performance of PPMU and contractors. • GRM operation Assess the effectiveness of the operation of the designed GRM. Identify hindrance in operation of the designed GRM that need to be tackled based on consultation with locally- affected people, and local NGOs and authorities, and workers. • Applied mitigation measures corresponding to each safeguard policy triggered Assess the effectiveness of each mitigation measure applied to minimize and mitigate environmental and social risks and impacts associate with each environmental safeguards policy triggered and identify hindrance that needs to be handled. • Ambient environmental quality The ambient environmental quality during construction and decommissioning should be monitored and compared with national standards or WBG EHS guidelines to evaluate the effectiveness of applying mitigation measures and propose additional measures as necessary. • Incidents or accidents 26 Prepared by MOH CPMU 114 Describe any incidents or accidents if any that happen during implementation. Also, analyse consequences of incidents or accident and remedies to be taken. • Corrective actions Describe any actions to be corrected if any during implementation that aims to improve environmental safeguards performance of the project. • Recommendations and timeframe Describe recommendations to improve environmental safeguards performance and specify the timeframe to successfully implement these recommendations. 115