SFG3246 V8 MINISTRY OF LOCAL GOVERNMENT AND RURAL DEVELOPMENT (MLGRD) GREATER ACCRA METROPOLITAN AREA (GAMA) SANITATION AND WATER PROJECT ACCRA METROPOLITAN ASSEMBLY (AMA) Construction of Institutional Sanitation Facilities ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN (ESMP) FINAL ESMP Prepared by: SAL Consult Limited, P. O. Box GP20200, Accra, Ghana May, 2017 SAL Consult Ltd GAMA - AMA BTABLE OF CONTENT ESMP PROJECT TEAM.................................................................................. ERROR! BOOKMARK NOT DEFINED. TABLE OF CONTENT ..........................................................................................................................................I LIST OF FIGURES..............................................................................................................................................III LIST OF TABLES ...............................................................................................................................................III LIST OF PLATES............................................................................................................................................... IV ACRONYMS AND ABBREVIATIONS .................................................................................................................. V EXECUTIVE SUMMARY ................................................................................................................................... VI 1.0 INTRODUCTION ................................................................................................................................... 1 1.1 BACKGROUND ........................................................................................................................................... 1 1.2 OBJECTIVES/PURPOSE OF THE ESMP............................................................................................................. 2 1.3 APPROACH AND METHODOLOGY................................................................................................................... 2 1.3.1 Site Inspections ................................................................................................................................. 2 1.3.2 Stakeholder Consultations ................................................................................................................ 3 1.3.3 Review of Available Literature/project documents ........................................................................... 4 1.3.4 Reporting .......................................................................................................................................... 4 2.0 DESCRIPTION OF THE PROPOSED PROJECT .......................................................................................... 6 2.1 NEED FOR THE PROJECT ............................................................................................................................... 6 2.2 BENEFICIARY SCHOOLS IN AMA AND THEIR LOCATIONS ..................................................................................... 6 2.3 DESCRIPTION/STATE OF EXISTING WASH FACILITIES IN THE BENEFICIARY SCHOOLS ................................................ 8 2.4 PROPOSED SANITATION FACILITIES TO BE PROVIDED BY PROJECT ....................................................................... 14 2.5 DESIGN STANDARDS ................................................................................................................................. 19 2.5.1 General ........................................................................................................................................... 19 2.5.2 Lighting ........................................................................................................................................... 19 2.5.3 Materials for Internal Finishes ........................................................................................................ 20 2.5.4 Water Closets (WCs) ....................................................................................................................... 20 2.5.5 Hand Wash Basin ............................................................................................................................ 20 2.5.6 Service Installations ........................................................................................................................ 20 2.6 LABOUR AND RELATED ISSUES .................................................................................................................... 21 3.0 RELEVANT POLICIES, LEGAL AND ADMINISTRATIVE FRAMEWORKS .................................................. 22 3.1 POLICY FRAMEWORK ................................................................................................................................ 22 3.2 NATIONAL REGULATORY FRAMEWORK ......................................................................................................... 22 3.3 INSTITUTIONAL FRAMEWORK ...................................................................................................................... 25 3.4 WORLD BANK SAFEGUARDS POLICIES .......................................................................................................... 28 4.0 BASELINE ENVIRONMENTAL AND SOCIAL CONDITIONS .................................................................... 30 4.1 LOCATION AND SIZE .................................................................................................................................. 30 4.2 PHYSICAL ENVIRONMENT ........................................................................................................................... 32 4.2.1 Climatic Conditions ......................................................................................................................... 32 Final ESMP _Construction of Institutional Sanitation Facilities. Page i May 2017 SAL Consult Ltd GAMA - AMA 4.2.2 Vegetation ...................................................................................................................................... 32 4.2.3 Geology and Soils ............................................................................................................................ 32 4.3 SOCIO-ECONOMIC ENVIRONMENT............................................................................................................... 33 4.3.1 Demographic Characteristics .......................................................................................................... 33 4.3.2 Education and Literacy.................................................................................................................... 33 4.3.3 Employment and Industry ............................................................................................................... 33 4.3.4 Water Supply .................................................................................................................................. 33 4.3.5 Drainage ......................................................................................................................................... 34 4.3.6 Sanitation and Hygiene ................................................................................................................... 34 4.3.7 Waste Management ....................................................................................................................... 37 5.0 STAKEHOLDER CONSULTATIONS ....................................................................................................... 39 5.1 OBJECTIVES OF CONSULTATION ................................................................................................................... 39 5.2 STAKEHOLDER CONSULTATION STRATEGY AND PLAN ....................................................................................... 39 5.3 STAKEHOLDERS CONSULTED ....................................................................................................................... 43 5.4 OUTCOME OF STAKEHOLDER CONSULTATIONS CARRIED OUT DURING ESMP PREPARATION .................................... 43 5.5 KEY ENVIRONMENTAL AND SOCIAL CONCERNS FROM STAKEHOLDER CONSULTATIONS ........................................... 52 6.0 DESCRIPTION OF ENVIRONMENTAL AND SOCIAL IMPACTS ............................................................... 53 6.1 PROJECT AREA OF INFLUENCE ..................................................................................................................... 53 6.1.1 Geographical Area of Influence ...................................................................................................... 53 6.1.2 Physical Environmental Media Influence ........................................................................................ 53 6.1.3 Community Influence and Vulnerable Persons in the Institutions .................................................. 53 6.1.4 Institutional Influence ..................................................................................................................... 54 6.2 PROJECT ACTIVITIES OF ENVIRONMENTAL AND SOCIAL CONCERN ...................................................................... 54 6.2.1 Preparatory Phase Activities ........................................................................................................... 54 6.2.2 Construction Phase Activities .......................................................................................................... 54 6.2.3 Operations and Maintenance Phase Activities ............................................................................... 55 6.2.4 Decommissioning Phase ................................................................................................................. 55 6.3 CRITERIA OF IMPACT EVALUATION ............................................................................................................... 55 6.3.1 Duration of the Impact.................................................................................................................... 55 6.3.2 Extent of the Impact ....................................................................................................................... 55 6.3.3 Intensity of the Impact .................................................................................................................... 55 6.3.4 Impacts Severity .............................................................................................................................. 56 6.4 EVALUATION OF POTENTIAL POSITIVE IMPACTS .............................................................................................. 56 6.5 EVALUATION OF POTENTIAL ADVERSE IMPACTS ASSOCIATED WITH THE PROPOSED PROJECT ................................... 58 6.6 EVALUATION OF RISKS TO SUSTAINABILITY OF PROJECT .................................................................................... 61 7.0 ENVIRONMENTAL AND SOCIAL MITIGATION AND MANAGEMENT PLAN .......................................... 63 7.1 MITIGATION/ACTION PLAN........................................................................................................................ 63 7.2 MITIGATION/ACTION PLAN FOR IDENTIFIED RISKS TO THE SUSTAINABILITY OF THE PROJECT ................................... 70 7.3 ENVIRONMENTAL AND SOCIAL MONITORING PLAN AND REPORTING.................................................................. 72 7.3.1 Environmental and Social Monitoring Plan .................................................................................... 72 7.3.2 Environmental and Social Monitoring Reporting ............................................................................ 77 7.4 GRIEVANCE REDRESS PROCESS.................................................................................................................... 77 7.4.1 Background ..................................................................................................................................... 77 7.4.2 Objectives of the Grievance Redress Mechanism ........................................................................... 77 Final ESMP _Construction of Institutional Sanitation Facilities. Page ii May 2017 SAL Consult Ltd GAMA - AMA 7.4.3 Grievance Redress Process .............................................................................................................. 78 7.5 CAPACITY BUILDING AND OTHER REQUIREMENTS FOR IMPLEMENTATION OF ESMP AND PERMIT CONDITIONS ........... 83 7.5.1 Objectives of the training ................................................................................................................ 83 7.5.2 Methodology for the training ......................................................................................................... 83 7.5.1 Output of the training ..................................................................................................................... 84 7.6 ESTIMATED BUDGET FOR ESMP IMPLEMENTATION. ....................................................................................... 84 8.0 CONCLUSION ..................................................................................................................................... 86 9.0 BIBLIOGRAPHY .................................................................................................................................. 87 ANNEXES ....................................................................................................................................................... 88 ANNEX 1 STAKEHOLDER CONSULTATIONS ............................................................................................... 89 ANNEX 2 CODE OF CONDUCT .................................................................................................................. 90 ANNEX 3 TEMPLATE FOR REPORTING ON THE IMPLEMENTATION OF THE ESMP ..................................... 91 ANNEX 4 GRIEVANCE FORM..................................................................................................................... 92 LIST OF FIGURES FIGURE 1: INSTITUTIONAL STRUCTURE FOR SHEP IMPLEMENTATION AT THE MUNICIPAL ASSEMBLY AND SCHOOL LEVEL ................ 27 FIGURE 2: MAP OF ACCRA METROPOLIS (SOURCE: GHANA STATISTICAL SERVICE, 2014)........................................................ 31 FIGURE 3: AVAILABILITY AND CONDITION OF TOILETS IN SCHOOLS IN AMA (SOURCE: WASTECARE ASSOCIATES, 2016A) .............. 35 FIGURE 4: METHODS OF SOLID WASTE DISPOSAL IN SCHOOLS UNDER AMA (SOURCE: WASTECARE ASSOCIATES, 2016A) ............. 38 FIGURE 5: GRIEVANCE REDRESS PROCESS FOR THE CONSTRUCTIONAL PHASE INSTITUTIONAL SANITATION FACILITIES PROJECT ....... 80 FIGURE 6: GRIEVANCE REDRESS PROCESS FOR OPERATIONAL PHASE FOR THE INSTITUTIONAL SANITATION FACILITIES PROJECT ....... 82 LIST OF TABLES TABLE 1: DETAILS OF BENEFICIARY SCHOOLS IN AMA ........................................................................................................ 7 TABLE 2: DETAILS OF EXISTING WASH FACILITIES IN SCHOOLS (SOURCE: WASTE CARE ASSOCIATES, 2016A) .............................. 9 TABLE 3: DETAILS OF SANITATION FACILITIES TO BE PROVIDED BY THE PROJECT...................................................................... 15 TABLE 4: SUMMARY OF WORLD BANK SAFEGUARD POLICIES ............................................................................................. 28 TABLE 5: STAKEHOLDER ENGAGEMENT PROGRAMME ....................................................................................................... 40 TABLE 6: DETAILS OF STAKEHOLDER CONSULTATIONS ....................................................................................................... 44 TABLE 7: EVALUATION OF POTENTIAL POSITIVE IMPACTS.................................................................................................... 56 TABLE 8: EVALUATION OF POTENTIAL ADVERSE IMPACTS ................................................................................................... 58 TABLE 9: EVALUATION OF RISKS TO THE SUSTAINABILITY OF THE PROJECT ............................................................................. 61 TABLE 10: MITIGATION MEASURES/ACTIONS FOR POTENTIAL SIGNIFICANT ADVERSE IMPACTS ................................................... 63 TABLE 11: MITIGATION /ACTION PLAN FOR IDENTIFIED RISKS TO THE SUSTAINABILITY OF THE PROJECT ..................................... 70 TABLE 12: ENVIRONMENTAL AND SOCIAL MONITORING PLAN ........................................................................................... 72 TABLE 13: CAPACITY BUILDING PLAN FOR IMPLEMENTATION OF ESMP AND PERMIT CONDITIONS............................................. 83 TABLE 14: ESMP BUDGET. ......................................................................................................................................... 85 Final ESMP _Construction of Institutional Sanitation Facilities. Page iii May 2017 SAL Consult Ltd GAMA - AMA LIST OF PLATES PLATE 1: SITE INSPECTION AT ABOSSEY OKAI 1&2 BASIC SCHOOL......................................................................................... 3 PLATE 2: WATER STORAGE TANK AT OSU CLUSTER (SOURCE: WASTECARE ASSOCIATES, 2016A) ............................................. 34 PLATE 3: CONDITION OF A URINAL AT AYALOLO CLUSTER OF SCHOOLS (SOURCE: WASTECARE, 2016A) .................................... 36 PLATE 4: COMMON HAND WASH FACILITIES IN SCHOOLS UNDER AMA (SOURCE: WASTECARE ASSOCIATES, 2016A) ................... 37 PLATE 5: CONSULTATION BETWEEN ENVIRONMENTAL CONSULTANT, OFFICIAL OF AMA AND HEAD TEACHER OF KANESHIE WEST CLUSTER OF SCHOOLS ........................................................................................................................................ 51 PLATE 6: CONSULTATIONS WITH SHEP COORDINATOR, PREFECTS AND HEALTH CLUB MEMBERS OF SOCCO/M1 CLUSTER OF SCHOOLS ......................................................................................................................................................... 51 PLATE 7: CONSULTATION WITH PREFECTS OF ABOSSEY OKAI R/C SCHOOL ........................................................................... 51 Final ESMP _Construction of Institutional Sanitation Facilities. Page iv May 2017 SAL Consult Ltd GAMA - AMA ACRONYMS AND ABBREVIATIONS AMA Accra Metropolitan Assembly BoQ Bill of Quantities EHSD Environmental Heath and Sanitation Department EPA Environmental Protection Agency ESMF Environmental and Social Management Framework ESMP Environmental and Social Management Plan FMP Facilities Management Plan GAMA Greater Accra Metropolitan Area GES Ghana Education Service GHS Ghana Health Services GoG Government of Ghana GWCL Ghana Water Company Limited JHS Junior High School LI Legislative Instrument MA Municipal Authority MLGRD Ministry of Local Government and Rural Development MMA Metropolitan and Municipal Assembly MMDA Metropolitan, Municipal and District Assembly OP Operational Procedures PPE Personal Protective Equipment SHEP School Health Education Programme S&W Sanitation and Water ToR Terms of Reference WB World Bank WC Water Closet WD Works Department Final ESMP _Construction of Institutional Sanitation Facilities. Page v May 2017 SAL Consult Ltd GAMA - AMA EXECUTIVE SUMMARY The Government of Ghana (GoG) has received financing from the World Bank towards the cost of implementation of the Greater Accra Metropolitan Area (GAMA) Sanitation and Water Project (GAMA S&W Project). The objective of the Project is to increase access to improved sanitation and improved water supply in the GAMA, with emphasis on low income communities; and to strengthen management of environmental sanitation in the GAMA. The GAMA Project, which has four components, supports eleven (11) Metropolitan and Municipal Assemblies (MMAs) spread across the Greater Accra Region. Part of the strategies under Component 1 of the Project is the provision of improved sanitation and water supply facilities in schools in each of the eleven (11) MMAs in GAMA, including hygiene education and campaigns for awareness raising and behavioural changes in low income communities Ghana’s Environmental Assessment Regulations, 1999 (LI1652) requires that for any start-up project which has potential to impact negatively on the environment and people, the undertaking should be assessed for its environmental and social impacts, and the appropriate mitigation measures identified prior to the undertaking for implementation. The Project has also triggered one of the World Bank Safeguards policies: the Environmental Assessment Policy OP4.01. These require that any potential environmental and social issues arising from the project implementation should be mitigated. This ESMP is prepared to guide the construction and operation of the institutional sanitation facilities under the Accra Metropolitan Assembly (AMA) in accordance with the Environmental Assessment Regulations (EAR) 1999, LI 1652 and the World Bank’s Safeguards Policy on Environmental Assessment (OP 4.01). Stakeholder consultations were carried out with key stakeholders to obtain their comments and concerns on the proposed project with respect to the potential environmental and socio-economic issues and impacts that have been addressed in the study. The stakeholders consulted comprise: Project proponents:  Ministry of Local Government and Rural Development/ Project Coordinating Unit - Safeguards Specialist  AMA - Director, Drains Maintenance Unit/GAMA SWP Project Coordinator. Engineering Consultant  Waste Care Associates - Chief Executive Officer Contractor  Milpar Development Investment - Managing Director; and - Foreman Final ESMP _Construction of Institutional Sanitation Facilities. Page vi May 2017 SAL Consult Ltd GAMA - AMA Beneficiary Schools  WASH implementers (Head Teachers; SHEP Coordinators; representatives of School Management Committee and Parent Teacher Association; school prefects and health club executives) in the following institutions: - Abossey Okai R/C Junior High School (JHS); - Abossey Okai 1&2 Basic School; - Kaneshie West Cluster; - Socco/M1 Cluster of Schools; - Dr. F.V. Nanka Bruce JHS; - Osu Salem 1 Primary School; and - Osu Salem 5 Primary School. The following school children were consulted:  Ishmael Selormey- School prefect Boys, Abossey Okai R/C Junior High School (JHS);  Yahwe-Yire Djan- School prefect Girls, Abossey Okai R/C Junior High School (JHS);  Stephen Yeboah-Health club member, Osu Salem 5 Primary;  Claudia Borketey-Health club member, Osu Salem 5 Primary;  Amofah Eva-School prefect/health club secretary, Osu Salem 1 Basic School;  Ninyeh Benjamin –Boys prefect/Health Club Vice president, Osu Salem 1 Basic School;  Boateng Emmanuel-President Health club, Socco/M1 Cluster of schools; and  Wiafe Foster-Vice president Health club, Socco/M1 Cluster of schools. Significant Environmental and Social Impacts The significant adverse impacts (rated as moderate or major) identified from the analysis and evaluation of the potential impacts from the proposed project are stated below. Construction Phase  Soil impacts and sediment transport;  Air quality deterioration;  Vibration and noise nuisance;  Visual intrusion;  Destruction of property and obstruction of walkways;  Generation and disposal of solid waste;  Occupational health & safety;  Public safety & Traffic issues; and  Sanitation and public health. Operational Phase  Nuisance from odour;  Waste generation;  Sanitation issues and public health impacts; and  Sustainability of the institutional facilities. Final ESMP _Construction of Institutional Sanitation Facilities. Page vii May 2017 SAL Consult Ltd GAMA - AMA Decommissioning Phase  Occupational/public safety and traffic impacts; and  Waste management. Mitigation and Monitoring Plan Mitigation and monitoring measures for the significant adverse impacts and identified risks to the sustainability of the project are stated below. Final ESMP _Construction of Institutional Sanitation Facilities. Page viii May 2017 SAL Consult Ltd GAMA - AMA Mitigation and monitoring actions for potential significant adverse impact No. Environmental/ Social Monitoring Parameters Monitoring Frequency Responsibility Component Proposed Mitigation Measures Site (Implementation/ Supervision) PREPARATORY PHASE 1. Approval for  Consult and seek free, prior and informed consent from school authorities -Evidence of consultation and -Beneficiary -Prior to -Contractor/ construction and siting prior to construction work. consent from school institutions construction Engineering of toilet facility  For Missionary schools, seek free, prior and informed consent of Church authorities (including Church Consultant Leadership in addition to Head Teachers. Leadership of Missionary  For all schools, Engineering Consultant to extensively consult school authorities on the siting of toilet facilities in the school. The selection of Schools) sites should be agreed upon with the school authorities. -Complaints on siting of - Daily  The selection of sites should take into consideration compatibility with facilities adjacent school facilities. The adjacent school facilities should not be at Availability of toilets facilities risk from the operation of the proposed toilets. for use by students during  To ensure that students always have access to toilet facilities, the construction contractors/consultants are not to demolish existing toilet facilities until the new toilet facilities are in place. Where the existing toilet facility is the only toilet for the school but has been earmarked for rehabilitation and or reconstruction, then alternative toilet facilities should be provided the school/students during the course of the rehabilitation/reconstruction of the existing toilet facility . Where necessary, mobile toilets should be provided.. CONSTRUCTION PHASE 1. Soil impacts and  Vegetation (grasses and shrubs) should be cleared only when contractor -Observable change in turbidity -Construction Daily Contractor/ sediment transport is fully mobilised for construction. of water in drains site Engineering  Vegetation clearance (where necessary) and excavations should be -Observable oil sheen in drains -Nearby Consultant limited to the demarcated construction site. drains -Observation of rills/gullies  Backfill with excavated soil material where appropriate.  Re-vegetate areas around construction sites to restore the landscape.  Ensure that heaped sand delivered for construction works is covered with tarpaulin to prevent wind and water transport of soil particles. 2. Air quality deterioration  Deliver construction equipment and materials to the construction sites -Observation of air borne Construction Daily Contractor/ Final ESMP _Construction of Institutional Sanitation Facilities. Page ix May 2017 SAL Consult Ltd GAMA - AMA No. Environmental/ Social Monitoring Parameters Monitoring Frequency Responsibility Component Proposed Mitigation Measures Site (Implementation/ Supervision) outside school sessions, such as in the evenings or on weekends. particulates (dust) and exhaust site Engineering  Speed limit for all vehicles and construction equipment should be less fumes -Immediate Consultant than 30km/h within the school environs and less than 50km/h within environs -Records of dust level communities. Provide speed limit signs to guide drivers/operators. measurements (dust  Dampen untarred routes of vehicles/trucks to the construction sites.  Haulage trucks carrying sand should be covered with tarpaulin. concentration should be below  3 Hydraulic concrete mixing machines should be used as much as possible 150 µg/m )- and regularly service all construction equipment and machinery. -Records of dampening of construction sites and routes for vehicles/trucks 3. Vibration and noise  Demolition of old structures should be done outside school sessions, such -complaints on noise nuisance -Construction Daily Contractor/ nuisance as in the evenings or during weekends. site Engineering  Carpentry works, and other noise generating activities should as much as -Immediate Consultant possible be carried outside school sessions. environs  Hydraulic concrete mixing machines should be used as much as possible and regularly service all construction equipment and machinery. 4. Visual intrusion  The construction sites should be hoarded off from public view. -Hoarding in place -Construction Daily Contractor/  Ensure good housekeeping at the construction site. -Condition of areas around site Engineering  Ensure an acceptable post-construction site as per provisions in the construction site -Immediate Consultant contract. environs  Remove all construction equipment from the site after completion of work. 5. Destruction of property  Ensure construction equipment are not parked haphazardly to obstruct -Evidence of consultations with -Construction Daily Contractor/ and obstruction of walkways. affected property owners site Engineering walkways  As much as possible, do not dump construction materials in walkways. -Record of affected service -immediate Consultant  Provide safe alternative routes for pedestrians where walkways will be line/property and action taken environs obstructed. -Complains on affected  Consult affected property owners/users and seek their consent prior to property and obstruction of construction works. walkways  Realign all affected utility service lines. Final ESMP _Construction of Institutional Sanitation Facilities. Page x May 2017 SAL Consult Ltd GAMA - AMA No. Environmental/ Social Monitoring Parameters Monitoring Frequency Responsibility Component Proposed Mitigation Measures Site (Implementation/ Supervision)  Reinstate any damaged property such as pavements, etc. 6. Generation and  Apply the principles of Reduce, Reuse and Recover for waste -Availability and use of bins Construction Daily Contractor/ disposal of solid waste management. For example: -Records on frequency and site Engineering o Purchase the right quality and quantity of materials; location of waste disposal site Consultant o Ensure judicious use of construction materials such as pipes, of domestic and construction waste laterites, sand, etc.; o Reuse excavated soil material for backfilling and levelling if appropriate.  Provide bins on site for temporary storage of domestic waste such as lubricant containers, drinking water sachets and carrier bags/packaging materials.  Dispose all construction and domestic waste at AMA approved dump sites. 7. Occupational health  Engage experienced artisans for construction works. -Workers’ awareness of Construction Daily Contractor/ and safety (OHS) issues  All workers should be given proper induction/orientation on safety. Contractor’s health and safety site Engineering  The contractors should have a Health & Safety Policy to guide the policy Consultant construction activities. The contractor health and safety policy would -Availability and proper use of take into consideration the World Bank EHS guidelines.  Regularly service all equipment and machinery. PPEs  Ensure first aid kits on site and a trained person to administer first aid. -Availability and proper use of  Provide and enforce the use of appropriate personal protective warning signs equipment (PPE) such as safety boots, reflective jackets, hard hats, hand -Availability of first aid kit gloves, earplugs, nose masks, etc. for the labour force. -Adherence to health and  Comply with all site rules and regulations. safety procedures  Apply sanctions where safety procedures are not adhered to.  Site meetings should create awareness on OHS. -Records on frequency, type and source of illness/accident/injury -Records on non-compliances -Absence of unauthorized Final ESMP _Construction of Institutional Sanitation Facilities. Page xi May 2017 SAL Consult Ltd GAMA - AMA No. Environmental/ Social Monitoring Parameters Monitoring Frequency Responsibility Component Proposed Mitigation Measures Site (Implementation/ Supervision) persons at active construction sites 8. Public safety and traffic  Hoard off the construction sites to prevent access by unauthorised -Availability and proper use of Construction Daily Contractor/ issues persons. warning signs site Engineering  Use caution tapes and warning signs at the construction sites around -Hoarding of site Consultant trenches and excavations. -Use of caution tape around  Deliver construction equipment and materials to the construction sites outside school sessions such as in the evening or weekends. trenches/ excavations  Speed limit for all vehicles and construction equipment should be less -Records on frequency, type than 30km/h within the school environs and less than 50km/h within and source of communities. Provide speed limit signs to guide drivers/public. illness/accident/injury  Do not park at unauthorised places to reduce the risk of accidents. -Absence of unauthorized  Erect temporary road signs at junctions to the beneficiary institutions persons at active construction during the delivery of construction equipment and materials.  Ensure delivery trucks hired/contracted are in good condition to prevent sites breakdowns on roads.  Remove all construction equipment from the site after completion of work. 9. Sanitation issues and  Provide bins on site for temporary storage of domestic waste such as -Availability and use of bins Construction Daily Contractor/ public health impacts lubricant containers, drinking water sachets and carrier bags/packaging -Records on frequency and site Engineering materials. location of waste disposal site Consultant  Dispose all construction and domestic waste at AMA approved dump sites of domestic and construction and in the approved manner. waste  Ensure all trenches or excavations made during the construction works do -Mobile toilet facilities in place not collect stagnant water which could breed mosquitoes. for construction workers  Ensure construction workers do not use existing institutional toilet -Presence of stagnant water in facilities. Either they identify nearby public toilet facilities for use or are trenches provided with temporary toilets (mobile toilets) for use. Final ESMP _Construction of Institutional Sanitation Facilities. Page xii May 2017 SAL Consult Ltd GAMA - AMA No. Environmental/ Social Monitoring Parameters Monitoring Frequency Responsibility Component Proposed Mitigation Measures Site (Implementation/ Supervision) 10. Public Complaints/  Implement Grievance Redress Mechanism, which will include such -Type and nature of complaints Project Weekly Grievance Grievances elements as: and concerns; community Redress -Complaint records (Record of Committee o Lodging and registration of PAPs grievance by grievance grievance and number Section 7.4 redress committee; resolved/unresolved) o Redress decision, feedback and implementation; -Management and Stakeholder oDissatisfaction and alternative action; and Meetings - Carry out monitoring and evaluation. OPERATIONAL PHASE 1. Nuisance from odour  Comply with provisions in the Facilities Management Plan (FMP). -Smell of pungent odour -Beneficiary Daily Authorities of  Ensure good housekeeping at toilet facilities. institution beneficiary  Clean toilet facilities regularly with disinfectants. -Immediate institution/ SHEP  Empty bins in classrooms/offices/wards regularly. environs Coordinator  Liaise with AMA to contract a waste management company to regularly collect and dispose waste at AMA approved dump site.  Dislodge septic tanks outside school sessions, such as on weekends. 2. Waste generation  Regularly empty waste bins at the various locations when full. -Waste disposal records Beneficiary -Daily Authorities of and disposal  Sensitize pupils/ staff on effective use of bins to avoid indiscriminate -Availability of bins institution beneficiary disposal of waste. institution/ SHEP -Litter around waste bin  Damaged waste bins should be replaced as appropriate. Coordinator -Records of inspection and  Liaise with AMA to contract a waste management company to regularly collect and dispose waste at AMA approved dump site. dislodging of septic tanks  Inspect septic tanks periodically and dislodge when full. 3. Sanitation issues and  Ensure pupils/staff wash their hands under running water and soap after -Cleaning roster -Toilet facility -Daily SHEP health impacts use of toilet facilities. -Clean environment -Waste -Week Coordinator/  Ensure good housekeeping at toilet facilities. -Smell of pungent odour storage and Head of  Clean toilet facilities regularly with disinfectants. Institution Availability of disinfectants collection  Ensure bins are properly covered at all times.  Avoid indiscriminate dumping of waste at waste storage and collection -Availability of cleaning PPEs sheds shed and always keep the place clean. and tools/materials  Provide disposable hand gloves for cleaning of sanitation facilities and -Availability of functional hand Final ESMP _Construction of Institutional Sanitation Facilities. Page xiii May 2017 SAL Consult Ltd GAMA - AMA No. Environmental/ Social Monitoring Parameters Monitoring Frequency Responsibility Component Proposed Mitigation Measures Site (Implementation/ Supervision) emptying of bins. wash facility  Create awareness on hygiene and sanitation issues, including proper use of sanitation facilities and proper handling and disposal of waste.  Comply with provisions in the FMP. 4. Complaints/ Grievances  -Implement Grievance Redress Mechanism, which will include such -Type and nature of complaints Project -Weekly Grievance elements as: and concerns community Redress Committee o Lodging and registration of PAPs grievance by grievance -Complaint records (Record of redress committee; grievance and number o Redress decision, feedback and implementation; resolved/unresolved) o Dissatisfaction and alternative action; and Carry out monitoring and evaluation. SUSTAINABILITY OF INSTITUTIONAL FACILITIES 1. Flooding  Raise the foundation of toilet facilities to about 1 meter high, especially in - Extent of flooding during Toilet facility During rains Authorities of flood prone areas. rains Institution/ PTA/  Provide adequate drainage around toilet facilities. - Drains clear of silt Monthly Metropolitan  Provide rain cover over all windows and doors of the toilet facilities. Assembly - Record of state of Rain  Beneficiary schools should ensure all broken louvre blades/or windows are replaced. covers - Record of state of louvre blades 2. Security issues  Provide burglar proof at the doors and windows of toilet facilities. - Security measures (locks, Toilet facility Daily Authorities of  Maintain adequate security in the schools and at the sanitation facilities burglar proof) functional Institution / PTA/ especially. Eg: through hiring a watchman. Metropolitan  MA should consider fencing of schools in future projects to improve Assembly - Watchman hired security.  Sensitize wider communities not to disturb school sanitation facilities 3. Unavailability of water  Confirm the source and reliability of the water supply prior to the - Confirmation of availability Toilet facility Prior to Authorities of commencement of construction. of water supply from GWCL commissioni Institution / PTA/  Ensure that storage tanks are installed for all the facilities to provide - Storage tanks installed and ng of Metropolitan continuous water supply even when GWCL lines are temporarily out of Assembly Final ESMP _Construction of Institutional Sanitation Facilities. Page xiv May 2017 SAL Consult Ltd GAMA - AMA No. Environmental/ Social Monitoring Parameters Monitoring Frequency Responsibility Component Proposed Mitigation Measures Site (Implementation/ Supervision) order. all connections and project/  Ensure connection of water and installation of water storage tanks is plumbing functional Weekly completed and there is regular flow of water at the toilet facilities before - Leaks from plumbing commissioning/handing over of the facilities for use. 4. Funding  The Engineering Consultant to include the relevant recommendations in - Receipts of payment of bills Beneficiary Monthly MLGRD-PCU/ the ESMP in the Facilities Management Plan (FMP). - Programme for fund raising institution Metropolitan  Comply with provisions in the FMP such as: - Audited accounts Assembly/ o Replace damaged equipment/materials with durable ones during Consultant/ maintenance and repair works. Authorities of Beneficiary o The beneficiary schools should hire cleaners for the sanitation Institution/PTA facilities. o Develop and implement a maintenance regime for the facilities. o Report major breakdown of facilities to the Metropolitan GES Director. o Educate and create awareness on proper use of facilities. o Ensure all staff are trained in the effective use and management of the facilities, in collaboration with the Environmental Health and Sanitation Department. 5. Poor maintenance  School authorities and PTA to discuss funding for water supply, electricity - Record of training and -Beneficiary Monthly Authorities of culture bills and maintenance of the facilities at PTA Meetings. awareness creation on institution Institution /  Capacity building of School authorities /PTA for raising, mobilization and Facilities Management Plan SHEP stewardship of fund Coordinators/ - Record of compliance with  MA level stakeholder engagements to discuss innovations in funding for PTA/ O&M. Facilities Management Plan Metropolitan  The project should ensure that all outstanding electricity and water debts - Records on major Assembly of beneficiary institutions are paid and electricity and water connection breakdowns including restored to disconnected institutions. leakages  The beneficiary institutions should ensure regular payment of electricity - Availability of school hygiene and water bills to ensure continuous supply of water and electricity to the clubs Final ESMP _Construction of Institutional Sanitation Facilities. Page xv May 2017 SAL Consult Ltd GAMA - AMA No. Environmental/ Social Monitoring Parameters Monitoring Frequency Responsibility Component Proposed Mitigation Measures Site (Implementation/ Supervision) facility. 6. Lack of awareness of  Stakeholders should be invited to attend monthly progress meetings to be - Monthly progress carried out -Beneficiary Monthly SMC/ PTA/ the project information constantly informed. - Information provided to institution Metropolitan  Before the project resumes, information of the proposed project teachers, students and the SHEP Committee including its benefits should be explained to teachers, students and the PTA. PTA. DECOMMISSIONING PHASE 1. Occupational/ public  Personal protective gear are provided to workers involved with -Availability and proper use of -Project site -Daily Contractor/ safety and traffic decommissioning of facilities. PPEs Engineering -Adherence to health and impacts  Toilet facilities are available throughout the decommissioning period. safety procedures Consultant  Workers still have access to public toilet facilities in the communities or -Records on frequency, type can be conveyed to such facilities where needed, if mobile toilet facilities and source of illness/accident/ have been relocated.  Final movement of vehicles and equipment comply with approved speed injury limits within the communities.  All community complaints are resolved before handing over sanitation project. 2. Waste management  Ensure that any remaining waste streams (after applying hierarchy waste -Availability and use of bins -Project site -Daily Contractor/ management practices of reduce, reuse and recycle) created during -Records on frequency and Engineering construction activities and waste generated during decommissioning location of waste disposal site Consultant activities are collected from the project sites and properly disposed of domestic and construction before handing over the project waste  Inspect the site to ensure that the contractor has properly cleaned up all construction sites before final payment is made to the contractor. 3. Site Restoration  Re-vegetate areas around construction sites to restore the landscape -cleared areas re vegetated -Project Site -Daily Contractor/  Reinstate any damaged property such as pavements, etc. -Property re-instatement Engineering carried out Consultant Final ESMP _Construction of Institutional Sanitation Facilities. Page xvi May 2017 SAL Consult Ltd GAMA - AMA Capacity Building and Other Requirements for Implementation of ESMP and Permit Conditions Capacity building measures and other requirements proposed (See Section 7.5) to ensure effective implementation of the ESMP and environmental permit conditions are:  Training workshop and sensitization programmes for the Engineering Consultants, Contractors and their workers, school authorities, school children, AMA and other key stakeholders on the ESMP ( including Contractors code of conduct, public health and safety, grievance redress mechanism) and its implementation, EPA permit schedule and triggered World Bank Safeguards Policy;  Induction on environmental, social occupational and public health and safety requirements of the works;  Training for use and management of facilities;  Sensitization and awareness creation on use and management of facilities (interactive activity, teaching, demonstrative activity for building habits & knowledge testing during classes, worship time and assembly);  Site Meetings; and  Reporting. Conclusion AMA and the Project Coordinating Unit of MLGRD are committed to ensuring sustainable environmental management and safeguarding the health and safety of the construction workers, pupils/teachers at the beneficiary schools and the general public during the implementation of the proposed project. AMA is also aware of the provisions in the Environmental Assessment Regulations 1999, LI 1652 and the World Bank Operational Policies. In keeping with these laws, this ESMP has identified and assessed key environmental and social impacts and concerns that may arise from the implementation of the proposed project. A monitoring programme to help detect changes arising from the predicted adverse impacts has also been presented in this ESMP. The recommendations outlined in the ESMP for the project will ensure a high level of health, safety and environmental management for the proposed project. It is estimated that the implementation of the ESMP in the Accra Metropolis will cost about GH¢408,700.00. However, the proposed project has the potential to provide numerous benefits to the beneficiary schools and the national economy. These include improved sanitation, hygiene and waste management in the beneficiary schools, improved access to sanitation facilities for vulnerable groups and employment opportunities. Final ESMP _Construction of Institutional Sanitation Facilities. Page xvii May 2017 SAL Consult Ltd GAMA - AMA 1.0 INTRODUCTION 1.1 Background The Government of Ghana (GoG) has received financing from the World Bank towards the cost of implementation of the Greater Accra Metropolitan Area (GAMA) Sanitation and Water Project (GAMA S&W Project). The objective of the GAMA S&W Project is to increase access to improved sanitation and improved water supply in the GAMA, with emphasis on low income communities; and to strengthen management of environmental sanitation in the GAMA. The GAMA Project supports eleven (11) Metropolitan and Municipal Assemblies (MMAs) spread across the Greater Accra Region. The project has four components:  Component 1 – Provision of water and environmental sanitation services to priority low income areas of GAMA;  Component 2 – Improvement and expansion of the water distribution network in the GAMA;  Component 3 – Improvement and expansion of waste water and faecal sludge collection, transportation and treatment in GAMA; and  Component 4 – Institutional Strengthening. Provision of improved sanitation and water supply facilities in schools in each of the eleven (11) MMAs in GAMA, including hygiene education and campaigns for awareness raising and behavioural changes in low income communities, is part of the strategies under Component 1 of the Project. Most schools in GAMA are faced with poor access to quality sanitation. This posed various degrees of risk to the pupils, teachers and other people within the area. The institutional sanitation component seeks therefore to scale-up sanitation, hygiene and waste management in the institutions. Part of the Bank’s funds is to be used by the Metropolitan and Municipal Assemblies (MMAs) to undertake construction of improved sanitation and water supply facilities in schools within their jurisdiction where schools are faced with poor access to quality sanitation issues. Ghana’s Environmental Assessment Regulations, 1999 (LI1652) requires that for any start-up project which has potential to impact negatively on the environment and people, the undertaking should be assessed for its environmental and social impacts, and the appropriate mitigation measures identified prior to the undertaking for implementation. The Project has also triggered one of the World Bank Safeguards policies: the Environmental Assessment Policy OP4.01. These require that any potential environmental and social issues arising from the project implementation should be mitigated. The Ministry of Local Government and Rural Development (MLGRD), is committed to undertake the construction activities in an environmentally and socially friendly manner, and in accordance with the World Bank’s Policy on Environmental Assessment (OP4.01) and GAMA Sanitation and Water Final ESMP _Construction of Institutional Sanitation Facilities. Page 1 May 2017 SAL Consult Ltd GAMA - AMA Project Environmental and Social Management Framework (ESMF) guiding the Project as well as the Environmental laws of Ghana. MLGRD has therefore contracted Messrs SAL Consult Limited to prepare an Environmental and Social Management Plan (ESMP) for the implementation of the proposed institutional sanitation facilities in each of the eleven (11) MMAs. This ESMP is prepared to guide the construction and operation of the institutional sanitation facilities under the Accra Metropolitan Assembly (AMA) in accordance with the Environmental Assessment Regulations (EAR) 1999, LI 1652 and the World Bank’s Safeguards Policy on Environmental Assessment (OP 4.01). 1.2 Objectives/Purpose of the ESMP The objective/purpose of this ESMP is to guide the effective mitigation and management of potential environmental and social issues of the proposed construction and operation of institutional sanitation facilities in AMA. The specific objectives of the ESMP include the following:  Identification of possible direct and indirect significant adverse impacts associated with the proposed interventions implementation in AMA;  Assessment and evaluation of potential impacts of the proposed project on the biophysical and human environment;  Provision of practical, socially acceptable, technically and economically feasible and environmentally sustainable measures to address the potential adverse impacts; and  To comply with the World Bank’s Safeguards Policy on Environmental Assessment (OP 4.01). 1.3 Approach and Methodology The approach and methodology adopted for the study include:  Site inspections;  Stakeholder Consultation;  Review of available literature; and  Reporting. 1.3.1 Site Inspections The Consultants visited some beneficiary schools in AMA between November 2016 and February 2017 to confirm the environmental and social issues and conditions to be affected or are likely to develop from the implementation of the proposed project. Due to time constraints, all beneficiary schools in AMA could not be visited. The Consultants however selected a representative sample of schools based on the environmental and social issues identified from the environmental screening and the extent of construction works. This was done in collaboration with the project proponents and the engineering consultant. The school visited are listed in Section 1.3.2. The inspections covered the following:  the proposed construction sites and environs; Final ESMP _Construction of Institutional Sanitation Facilities. Page 2 May 2017 SAL Consult Ltd GAMA - AMA  existing sanitation facilities in the beneficiary schools (toilets, urinals and hand washing facilities);  existing waste collection and disposal facilities and water supply facilities; and  construction works that have been done for schools where construction has started. For beneficiary schools where some construction works have been done, the inspection also ascertained the health and safety measures that had been put in place by the contractors, such as hoarding of the sites and use of cautionary tapes and warning signs around excavations and trenches. Plates 1 shows site inspection at Abossey Okai 1&2 Basic School. Plate 1: Site inspection at Abossey Okai 1&2 Basic School 1.3.2 Stakeholder Consultations Stakeholder consultations were carried out between November 2016 and February 2017 with some key stakeholders to obtain their comments and concerns on the proposed project with respect to the potential environmental and socio-economic issues and impacts that have been addressed in the study. This includes the project proponents, some beneficiary schools, engineering consultant and some contractors. Details of the stakeholder consultations are presented in Chapter 5. Evidence of stakeholder consultations are provided in Annex 1. Stakeholder consultations have been carried out with the following key stakeholders: Project proponents:  Ministry of Local Government and Rural Development/ Project Coordinating Unit - Safeguards Specialist  AMA - Director, Drains Maintenance Unit/GAMA SWP Project Coordinator. Engineering Consultant  WasteCare Associates - Chief Executive Officer Final ESMP _Construction of Institutional Sanitation Facilities. Page 3 May 2017 SAL Consult Ltd GAMA - AMA Contractor  Milpar Development Investment - Managing Director; and - Foreman Beneficiary Schools  WASH implementers (Head Teachers; SHEP Coordinators; representatives of School Management Committee and Parent Teacher Association; school prefects and school health club executives) in the following institutions: - Abossey Okai R/C Junior High School (JHS); - Abossey Okai 1&2 Basic School; - Kaneshie West Cluster; - Socco/M1 Cluster of Schools; - Dr. F.V. Nanka Bruce JHS; - Osu Salem 1 Primary School; and - Osu Salem 5 Primary School. The following school children were consulted:  Ishmael Selormey- School prefect Boys, Abossey Okai R/C Junior High School (JHS);  Yahwe-Yire Djan- School prefect Girls, Abossey Okai R/C Junior High School (JHS);  Stephen Yeboah-Health club member, Osu Salem 5 Primary;  Claudia Borketey-Health club member, Osu Salem 5 Primary;  Amofah Eva-School prefect/health club secretary, Osu Salem 1 Basic School;  Ninyeh Benjamin –Boys prefect/Health Club Vice president, Osu Salem 1 Basic School;  Boateng Emmanuel-President Health club, Socco/M1 Cluster of schools; and  Wiafe Foster-Vice president Health club, Socco/M1 Cluster of schools. 1.3.3 Review of Available Literature/project documents The following project documents prepared by the Engineering Consultant (WasteCare Associates) for AMA were reviewed:  Hygiene Education Plan;  Final Detailed Design Report, which contains o Baseline Studies; o Assessment of Existing School Facilities; and o Engineering Designs.  Facility Operation and Maintenance Handbook;  Situational Analysis and WASH in Schools; and  Environmental permit schedule. 1.3.4 Reporting The major headings of the report include the following: a) Executive Summary; Final ESMP _Construction of Institutional Sanitation Facilities. Page 4 May 2017 SAL Consult Ltd GAMA - AMA b) Introduction; c) Description of Proposed Project; d) Relevant Policies, Legal and Administrative Frameworks; e) Baseline Environmental and Social Conditions; f) Stakeholder Consultation; g) Description of Environmental and Social Impacts; h) Environmental and Social Impact Mitigation and Management Plan; i) Capacity Building Plan for Implementation of ESMP and Permit Conditions; j) Conclusions; k) Bibliography; l) Annexes. Final ESMP _Construction of Institutional Sanitation Facilities. Page 5 May 2017 SAL Consult Ltd GAMA - AMA 2.0 DESCRIPTION OF THE PROPOSED PROJECT 2.1 Need for the Project Most schools in GAMA are faced with poor access to quality sanitation. This is as a result of inadequate toilet facilities to meet the schools’ population needs, poor condition of existing toilet facilities, waste management challenges, lack of water, etc. This poses various degrees of risk to the pupils, teachers and other people within the area. There is therefore the need to improve sanitation facilities within schools. The institutional sanitation component of the GAMA Project therefore seeks to scale-up sanitation, hygiene and waste management in the schools. The objective of the GAMA S&W Project is to increase access to improved sanitation and improved water supply in GAMA, with emphasis on low income communities and to strengthen management of environmental sanitation in GAMA. Part of the World Bank’s funds is to be used by the Metropolitan and Municipal Assemblies to undertake construction of improved sanitation and water supply facilities in schools within their jurisdiction where the schools are faced with poor access to quality sanitation issues. 2.2 Beneficiary Schools in AMA and their Locations The beneficiary Metropolitan Assembly is the Accra Metropolitan Assembly (AMA). The project sites cover the ten (10) sub-metropolitan areas (sub-metro) of AMA with each sub-metro having at least two (2) schools selected for the project. Thirty (30) schools have been selected in AMA to benefit from the proposed sanitation facilities under the project. The details of the beneficiary schools in AMA (including the names of the schools, sub-metro, location, and GPS coordinates) are provided in Table 1. An area of not more than 1 acre will be utilised for the project in each beneficiary school. Final ESMP _Construction of Institutional Sanitation Facilities. Page 6 May 2017 SAL Consult Ltd GAMA - AMA Table 1: Details of Beneficiary Schools in AMA No. Name of School Sub-Metro Location GPS Coordinates 1 Abossey Okai 1&2 Cluster Ablekuma Abossey Okai N5.334272°; W0.141365° 2 Kaneshie West 1&2 Cluster Central Kaneshie N5.334120°; W0.141365° 3 Mataheko R/C Cluster Mataheko N5.335546°; W0.142623° Kaneshie 4 Korle Gonno R/C Boys Ablekuma Korle Gonno N5.315225°; W0.132239° 5 Owusu Mills Primary/JHS South Korle Gonno N5.322735°; W0.142865° 6 Socco/M1 Cluster of Schools Korle Gonno - 7 Sempe 8/12 JHS Korle Gonno - 8 Dr F.V. Nanka Bruce JHS Korle Gonno N5.314014°; W0.135547° 9 ANT 4&11 Primary Ayawaso Accra Newtown N5.345948°; W0.124867° 10 ANT 6&8 Primary Central Accra Newtown N5.345988°; W0.124872° 11 Kwame Nkrumah JHS Accra Newtown N5.350086°; W0.124637° 12 Ayalolo Cluster of Schools Ashiedu Keteke Ayalolo N5.324331°; W0.130859° 13 Independence 1&2 Cluster Accra N5.324713°; W0.121574° 14 Osu Presby Cluster Osu Klottey Osu N5.331806°; W0.110100° 15 Farisco Cluster of Schools Osu N5.332118°; W0.124453° 16 Osu St. Barnabas Anglican Schools Osu N5.325863°; W0.111269° 17 Osu Salem 1 Primary School Osu N5.332230°; W0.110925° 18 Osu Salem 5 Primary School Osu N5.332062°; W0.110522° 19 Unity Cluster Ayawaso East Kanda N5.352548°; W0.120484° 20 Kanda Cluster Schools Kanda N5.343115°; W0.114604° 21 Anumle Cluster of Schools Okaikoi North Anumle N5.375848°; W0.125098° 22 Shiayennor 1&2 Primary Shiayennor N5.363710°; W0.135089° 23 Shiayennor A&B JHS Shiayennor N5.363183°; W0.134865° 24 Kaneshie 6 Primary /Kaneshie Kingsway 1 JHS A&B Okaikoi South Kaneshie N5.342213°; W0.135775° 25 Kaneshie 8 Primary /Kaneshie Kingsway 2 JHS A&B 26 La Bawaleshie Presby Cluster Ayawso West La Bawaleshie N5.383510°; W0.100502° 27 Maamobi Prisons Cluster Maamobi N5.361359°; W0.112090° 28 Dzorwulu JHS Dzorwulu N5.365125°; W0.121347° 29 Kwashieman Cluster Ablekuma Kwashieman N5.352276°; W0.160734° 30 Darkuman 1 JHS North Darkuman N5.353688°; W0.150946° Final ESMP _Construction of Institutional Sanitation Facilities. Page 7 May 2017 SAL Consult Ltd GAMA - AMA 2.3 Description/State of Existing WASH Facilities in the Beneficiary Schools The current state/description of the existing WASH facilities in the beneficiary schools; including the facilities available, population dependent on the facilities (pupils and teachers), waste disposal and remarks from assessment made by the Supervising Consultant (WasteCare Associates) are presented in Table 2. Final ESMP _Construction of Institutional Sanitation Facilities. Page 8 May 2017 SAL Consult Ltd GAMA - AMA Table 2: Details of Existing WASH Facilities in Schools (Source: Waste Care Associates, 2016a) Cluster School Enrollment Staff Assessments of WASH facilities Boy Girl Total Male Female Total Toilet Urinal Water Waste HWF Comments (No. of availability disposal cubicles) Abossey Abossey Okai 111 125 236 5 9 14 10 0 x burn 3 WC closed down due to lack of Okai 1&2 2 Basic water. Unable to pay for refuse Cluster Abossey Okai 179 223 402 5 15 20 0 x burn pick up service Cluster 1 JHS Kaneshie Kaneshie 177 193 370 3 14 20 12 0 √ burn 5 4 cubicles damaged West West 2 JHS & 1&2 Cann B Cluster Primary Kaneshie 231 277 508 5 14 22 10 0 √ burn 7 2 cubicles damaged West 1 Basic Mataheko 586 627 1213 11 29 40 14 1 x burn Urinal not segregated, tap not R/C Cluster flowing, refuse dump occasionally maintained at a fee by zoomlion. Toilet is hazardous Korle Gonno 424 424 8 9 17 9 3 √ burn R/C Boys Owusu Mills 150 129 279 4 13 17 0 0 x burn x Toilet and urinal broken down, Primary/JHS water bought from neighbour, hand washing done in bowls Socco/M Mamprobi 319 309 628 3 19 22 0 3 x 2 bins 5 Waste bins in poor condition. 1 Cluster of Socco HH Schools Mamprobi 159 172 331 2 9 11 10 0 √ 3 bins 1 Use toilet for urinating South 6 Sempe 8 146 145 291 5 13 18 0 0 x burn 0 Pupils practice open Basic defecation. Teachers have one toilet. 1 bin Final ESMP _Construction of Institutional Sanitation Facilities. Page 9 May 2017 SAL Consult Ltd GAMA - AMA Cluster School Enrollment Staff Assessments of WASH facilities Boy Girl Total Male Female Total Toilet Urinal Water Waste HWF Comments (No. of availability disposal cubicles) Dr F.V. Nanka 172 154 326 6 6 12 4 2 √ burn Bruce JHS ANT 4&11 111 104 215 1 8 9 1 0 √ burn 2 HWF in poor condition Primary ANT 6&8 93 100 193 2 8 10 4 0 √ burn/bury 4 A separate toilet cubicle for Primary teachers Kwame 170 5 7 12 2 3 √ burn/bury 2 Nkrumah Memory Ayalolo Ayalolo 1 106 114 2205 3 13 16 20 0 √ pick 1 Toilet is used for urinating. 2 Cluster of &2JHS 0 5 up/burn bins Schools Ayalolo 1 &2 0 √ pick 2 Tri-cycle service expensive KG /Primary up/burn hence mainly burn. Irregular flow of water. 2 bins Independence Independenc 500 0 3 √ dump 2 1 urinal for teachers. Pupils 1&2 e Avenue 1 carry refuse to public dump. Cluster JHS HWF used by primary only Osu Osu Pesby 1 197 197 5 7 12 5 3 √ burn 3 Water not regular. Teachers Presby JHS(Girls) use one toilet cubicle Cluster Osu Presby 350 350 1 7 8 5 0 √ burn 6 Some HWF in poor condition Boys primary Farisco Liberty 147 143 290 12 5 6 √ Public 1 Water not connected to toilet. Cluster of Avenue JHS dump Only toilet paper is burnt Schools Liberty 142 148 290 1 7 8 5 3 √ burn 1 5 Refuse bins were donated by Avenue 1&4 FunMilk Ghana Primary Final ESMP _Construction of Institutional Sanitation Facilities. Page 10 May 2017 SAL Consult Ltd GAMA - AMA Cluster School Enrollment Staff Assessments of WASH facilities Boy Girl Total Male Female Total Toilet Urinal Water Waste HWF Comments (No. of availability disposal cubicles) Osu St. 242 285 527 7 12 19 10 2 √ burn Urinal has no doors and Barnabas structure is weak. Only 4 Anglican toilets is functional and Schools conditions is unhygienic. Osu Salem 1 151 205 356 3 12 15 12 0 x pick up 9 HWF is available for each class Primary /burn but most are in poor condition. School 16 seater but only 12 are functional. Noble house restaurant pay for refuse collection. 4 bins Osu Salem 5 300 0 11 11 6 0 √ pick up 5 refuse collected 2x a month at Primary /burn a fee, hence occasionally burn School Unity Ayebeng 380 4 9 13 0 0 x 2 6 1 toilet for teachers. Pupils use Cluster Memorial bins/burn public toilet and open defecations A&B Primary Unity JHS 275 5 8 13 0 1 x public 1 dump Kanda Kanda 1 91 104 195 2 8 10 20 0 √ pick up 10 seater toilet available but Cluster of /burn not in use yet. Pay for weekly Schools refuse collection. Ring Road 129 139 268 5 13 18 √ pick up 3 refuse picked up every 2 weeks East 2 47 45 92 √ service/ at a fee and occasionally burnt. Primary& burn Pupils use public toilet Kanda 1 JHS and little ones squat on drains behind school. Ring Road 16 0 √ burn 1 East 1 Basic Final ESMP _Construction of Institutional Sanitation Facilities. Page 11 May 2017 SAL Consult Ltd GAMA - AMA Cluster School Enrollment Staff Assessments of WASH facilities Boy Girl Total Male Female Total Toilet Urinal Water Waste HWF Comments (No. of availability disposal cubicles) Anumle 705 776 1481 27 52 79 20 12 √ burn Another 2No. 6-seater Cluster of Uncompleted. 2No. 8-seater Schools for staff. Water not always available Shiayennor 209 237 446 0 17 17 20 0 √ burn 8 toilet facility shared with other 1&2 Primary schools on compound Shiayennor 137 140 277 5 8 13 0 4 x burn 4 A&B JHS Kaneshie 6 Primary 181 194 375 6 14 20 20 2 √ burn √ Pupils use running water from /Kaneshie Kingsway 1 JHS A&B tap for handwashing. Kaneshie 8 Primary 134 176 328 5 17 22 0 √ burn √ Use nearby house for urinating /Kaneshie Kingsway 2 JHS A&B La La 272 273 545 1 6 1 10 2 √ open 2 irregular flow of water to Bawaleshie Bawleshie dump existing 10 seater toilet, pupils Presby Primary B have to carry water to flush Cluster La 163 165 328 9 7 16 √ open after use. KGs practice open Bawleshie dump defecations on public dump. JHS New 20 seater has no water connected yet. Not in use. Maamobi Maamobi 40 43 83 6 3 9 2 0 √ burn 2 Water flows 3 times a week. Prisons Prisons 2 Additional 1 toilet for teachers. Cluster JHS Maamobi 161 179 340 2 16 18 20 1 √ pick up 3 Refuse are burnt when pick up Prisons 1 service service is not regular Primary Final ESMP _Construction of Institutional Sanitation Facilities. Page 12 May 2017 SAL Consult Ltd GAMA - AMA Cluster School Enrollment Staff Assessments of WASH facilities Boy Girl Total Male Female Total Toilet Urinal Water Waste HWF Comments (No. of availability disposal cubicles) Dzorwulu 200 220 420 7 15 22 11 2 √ burn 3 Condition of toilet very poor JHS Kwashieman 122 138 2612 25 92 117 12 7 √ pick up An additional 6 for KG, Nursery Cluster 9 3 service (4) and teachers (2) with bathroom built by mission. Darkuman 170 7 6 13 3 3 x pick up 2 1 toilet used by teachers JHs service Final ESMP _Construction of Institutional Sanitation Facilities. Page 13 May 2017 SAL Consult Ltd GAMA - AMA 2.4 Proposed Sanitation Facilities to be provided by Project The overview of sanitation facilities to be provided in the selected schools in AMA under the proposed project are as follows:  Construction of new water closet (WC) and septic tank facilities with internal urinal;  Rehabilitation of existing WC toilets;  Fixing of poly tanks overhead and underground for water supply to the toilet facility;  Construction of refuse/solid waste holding bay;  Construction of U450 perimeter drain;  Laying of pavement around toilet facilities; and  Laying of 3-inch diameter water supply pipeline from GWCL to toilet facility. The construction of furnace fitted with smoke stack will no longer be carried out in all the schools due to air pollution concerns as provided in Annex 5. Construction works are expected to be carried out over a period of 12 months. The specific sanitation facilities to be provided under the project in each of the beneficiary schools are provided in Table 3. Final ESMP _Construction of Institutional Sanitation Facilities. Page 14 May 2017 SAL Consult Ltd GAMA - AMA Table 3: Details of Sanitation Facilities to be provided by the Project Lot Name of School Description of Works Abossey Okai 1& 2 Completion of new 16-seater 2-storey toilet with septic tank Cluster Rehabilitation of 10-seater WC with septic tank Connection of water from GWCL and provision of 2No. Rambo 2000 and 1No. Ram 500 Provision of a 32.84 m2 refuse holding bay and 4No. 240L bins Provision of 68m length U-drain Paving 236.42 m2 of the site 1 2 Kaneshie West 1&2 Provision of 0.91m Rehabilitation of with furnace fitted and remodeling smoke existing stack to 20-seater to meet GES 16-seater Cluster standards. Provision of new 3-seater and 10-seater WC with septic tank Connection of water from GWCL and provision of 2No. Rambo 2000 and 1No. Rambo 500 Provision of a 32.84m2 refuse holding bay and 4No. 240L bins Provision of 74m length U-drain Paving 340.9 m2 of the site Mataheko R/C Cluster and 2 Provision of 0.91m Rehabilitation furnace fitted remodeling with smoke of 24-seater WC stack with septic tank Connection of water from GWCL and provision of 2No. Rambo 2000 and 1No. Rambo 1000 2 Provision of a 32.84 m2 refuse holding bay and 4No. 240L bins Provision of 60 m length U-drain 2 Paving 188.88m of the site. Osu Presby Cluster Provision and2remodeling of 0.91m Rehabilitation furnace fitted with smoke of existing stack WC to meet GES standards. 20-seater Connection of water from GWCL and provision of 2 No Rambo 2000. Provision of 32.84 m2 refuse holding bay and 4No. 240L bins. 3 Provision of 28m length of U-drain. Paving 188.88m2 of the site. Osu Salem 1 Primary Rehabilitation and remodeling of existing 8-seater WC with septic tank Schools Connection of water from GWCL and provision of 1 No Rambo 1000 and 1No. Rambo 500. Provision of 24.75 m2 refuse holding bay and 3No. 240L bins. Provision of 20 m length of U-drain. Paving 75.04 m2 of the site. 4 Osu Salem 5 Primary Rehabilitation and remodeling of 10-seater WC with septic tank. School Connection of water from GWCL and provision of 1 No Rambo 2000. Provision of 24.75 m2 refuse holding bay and 3No. 240L bins. Provision of 20 m length of U-drain. Paving 86.34 m2 of the site. Farisco Cluster of Rehabilitation and remodeling of existing 20-seater facility to meet GES Schools standards. Connection of water from GWCL and provision of 1 No Rambo 2000 and 1 No 5 Rambo 1000. Provision of 24.75 m2 refuse holding bay and 3No. 240L bins Provision of 28m length of U-drain. Paving 188.88 m2 of the site. Final ESMP _Construction of Institutional Sanitation Facilities. Page 15 May 2017 SAL Consult Ltd GAMA - AMA Lot Name of School Description of Works Osu St. Barnabas Rehabilitation and remodelling of existing 10-seater WC facility to 14-seater Anglican Schools WC. Connection of water from GWCL and provision of 1 No Rambo 2000 and 1 No Rambo 500. 6 2 Provision of 24.75 m refuse holding bay and 3No. 240L bins. Provision of 20m length of U-drain. Paving 86.34 m2 of the site. Independence 1&2 Provision of new 10-seater WC with septic tank. Cluster Connection of water from GWCL and provision of 3 No Rambo 2000. Provision of 32.84 m2 refuse holding bay and 4No. 240L bins. 7 Provision of 28m length of U-drain. Paving 172.68 m2 of the site. Ayalolo Cluster of Rehabilitation and remodelling of the existing 3 facilities (8, 12 and 20- seater Schools WCs toilets) to meet GES standards. Connection of water from GWCL and provision of 5 No Rambo 2000. 8 Provision of 32.84 m2 refuse holding bay and 4No. 240L bins. Provision of 44m length of U-drain. Paving 469.7 m2 of the site. Korle Gonno R/C Boys Provision of new 14-seater WC with septic tank Connection of water from GWCL supply line. Provision of 1No. Rambo 2000 Provision of a 24.75 m2 refuse holding bay and 3No. 240L bins Provision of a 78 m length of U-drain Paving 175.96 m2 of the site 9 Dr F.V. Nanka Bruce JHS Provision of new 10-seater WC with septic tank. Connection of water from GWCL and provision of 1No. Rambo 2000 Provision of 24.75 m2 refuse holding bay and 3No. 240L bins. Provision of 38 m length of U-drain. Paving 86.34 m2 of the site. Socco/M1 Cluster of Provision of new 10-seater WC with septic tank. Schools Provision Connection of water from GWCL and provision of 1No. Rambo 1000 and 1No. Rambo 500 10 Provision of 24.75 m2 refuse holding bay and 3No. 240L bins Provision of 68 m length of U-drain Paving 231.02m2 of the site. 2 Sempe 8/12 JHS Provision of 0.91m Rehabilitation furnace fitted and remodeling with smoke of existing stackWC to 12-seater WC. 16-seater Connection of water from GWCL and provision of 1No. Rambo 1000. 2 Provision of 24.75 m refuse holding bay and 3No. 240L bins. Provision of 40 m length of U-drain. Paving 90.86 m2 of site. 11 Owusu Mills Primary/ Rehabilitation and remodeling of existing 16-seater WC facility to 12-seater WC JHS with septic tank. Connection of water from GWCL and provision of 1No. Rambo 1000. Provision of 24.75 m2 refuse holding bay and 3No. 240L bins. Provision of 38m length of U-drain. Paving 90.86 m2 of the site. Provision of 0.91m2 furnace fitted with smoke stack Final ESMP _Construction of Institutional Sanitation Facilities. Page 16 May 2017 SAL Consult Ltd GAMA - AMA Lot Name of School Description of Works Accra Newtown 6&8 Rehabilitation and remodelling of 8-seater WC with septic tank. 12 Primary Classroom Block Provision of new 10-seater WC with septic tank. Accra Newtown 4&11 Connection of water from GWCL and provision of 1No. Rambo 1000 and 2No. Primary Classroom Block Rambo 500. Provision of 2No 24.75 m2 refuse holding bay and 3No. 240L bins. Provision of 54 m length of U-drain Paving 161.38 m2 of the site. Kwame Nkrumah JHS Rehabilitation of existing bio-fill toilet Connection of water from GWCL and provision of 2 No. Rambo 500. Provision of 24.75 m2 refuse holding bay and 3No. 240L bins. Provision of 14 m length of U-drain. Paving 23.54 m2 of the site Unity Cluster Provision of new 10 and 20-seater WC with septic tanks. Connection of water from GWCL and provision of 2 No Rambo 2000, 1 Rambo 1000 and 1 No Rambo 500. 2 Provision of 32.84 m refuse holding bay and 4No. 240L bins. Provision of 28 m length of U-drain. Paving 161.38 m2 of the site. Rehabilitation and remodelling of existing 20-seater to 24-seater WC with septic tank. Connection of water from GWCL and provision of 2 No Rambo 2000, 1 Rambo 1000 and 1 13 Kanda Cluster No Rambo 500. 2 Provision of 32.84 m refuse holding bay and 4No. 240L bins. Provision of 41 m length of U-drain. Paving 419.9 m2 of the site. 2 Provision of 0.91m Rehabilitation ofwith furnace fitted and remodelling smoke stack 20-seater WC and 2No 10-seater WC and provision of a new 3-seater WC. Connection of water from GWCL and provision of 3 No Rambo 2000 and 1 No Anumle Cluster of Rambo 500. 14 2 Schools Provision of 32.84 m refuse holding bay and 4No. 240L bins. Provision of 40 m length of U-drain. Paving 368.34 m2 of the site. Rehabilitation and remodelling of existing 10-seater WC with septic tank. Connection of water from GWCL and provision of 1 No Rambo 2000. 2 Provision of 24.75 m refuse holding bay and 3No. 240L bins. Shiayennor 1&2 Primary Provision of 20 m length of U-drain. Paving of 86.34 m2 of the site. 15 Rehabilitation and remodelling of 10-seater with septic tank. Connection of water from GWCL and provision of 1 No Rambo 1000 and 1 No Rambo 500. Shiayennor A&B JHS Provision of 24.75 m2 refuse holding bay and 3No. 240L bins. Provision of 20 m length of U-drain. 2 Paving 86.34 m of the site. Final ESMP _Construction of Institutional Sanitation Facilities. Page 17 May 2017 SAL Consult Ltd GAMA - AMA Lot Name of School Description of Works Rehabilitation and remodelling of 20, 10 and 12-seater WC with septic tank. Kaneshie 6 Primary/ Connection of water from GWCL and provision of 2 No Rambo 1000, 1 No Kaneshie Kingsway 1 Rambo 2000 and JHS A&B and Kaneshie 8 1No Rambo 100. 16 Primary/ Provision of 48m length of U-drain and 20m length of U-drain Kaneshie Kingsway 2 Provision of 2 No 24.75 m2 refuse holding bay and 3No. 240L bins. JHS A&B Paving of 372.86 m2 of the site. 17 La Bawaleshie Presby Rehabilitation and remodelling of existing 10-seater facility with septic tank. Cluster Connection of water from GWCL supply line. Provision of 2 No Rambo 2000. Provision of 24.75 m2 refuse holding bay and 3No. 240L bins. Provision of 20m length of U-drain. 2 Paving 86.34 m of the site. Rehabilitation and remodelling of existing 10-seater facility and provision of ancillary facilities to meet GES standards. Connection of water from GWCL supply line. 2 Provision of 24.75 m refuse holding bay and 3No. 240L bins. Maamobi Prisons Cluster Provision of 20 m length of U-drain. 2 Paving of 86.34 m of the site. Rehabilitation and remodelling of 2 No 10-seater WC with septic tanks. Connection of water from GWCL and provision of 2 No Rambo 1000. Provision of 24.75 m2 refuse holding bay and 3No. 240L bins. 18 Dzorwulu JHS Provision of 20 m length of U-drain. Paving 86.34 m2 of the site. Rehabilitation and remodelling of existing 20-seater WC to 24-seater WC with septic tank. Rehabilitation of existing 12-seater WC facility to meet GES standards. Provision of new 24-seater WC with septic tank. Kwashieman Cluster Connection of water from GWCL and provision of 6 No Rambo 2000 Provision of 32.84 m2 refuse holding bay and 4No. 240L bins Provision of 48 m length of U-drain. 19 Paving 540.34 m2 of the site. Provision of new 10-seater WC with septic tank. Connection of water from GWCL and provision of 1 No Rambo 1000. Provision of 24.75 m2 refuse holding bay and 3No. 240L bins. Darkuman 1 JHS Provision of 18 m length of U-drain. Paving of 86.34 m2 of the site. Final ESMP _Construction of Institutional Sanitation Facilities. Page 18 May 2017 SAL Consult Ltd GAMA - AMA 2.5 Design Standards 2.5.1 General Good engineering designs of WC toilets and ancillary facilities must incorporate sound design principles. The following general and specific standards of WC toilet designs have been adopted for use and incorporated in the production of architectural/structural designs and working drawings. a) Designs are cost effective. This means that the schools should be able to bear the maintenance cost of the facility to ensure sustainability. b) Designs are technically sound and therefore meet the technical criteria below:  Privy rooms are adequately sized, well ventilated and have squatting/sitting arrangements selected according to the school’s preference.  Locally available building materials will be used during construction of the facilities.  Designs are simple and easy to construct and therefore local persons/artisans in the project area with no special skills would be engage in the construction as a means of job creation.  Designs are simple therefore will be easy to use and maintain.  Designs have adequately sized and functionally well designed septic tanks to efficiently handle wastewater hence prevent environmental pollution and associated health problems. c) Designs are “child-friendly�, gender sensitive and safe for use. Toilet seats have been carefully selected to offer the desired convenience to both male and female pupils. Additional devices/fixtures are fitted to ensure that smaller children are comfortable and feel safe in the use of facilities. Ramps and sizes of cubicles are designed to provide access to disabled pupils. d) Installations that ensure good hygiene have been considered. The facilities prevent contact with faeces, by humans and flies. e) Designs are environmentally friendly. The operation and use of the recommended sanitation facilities will not create any adverse effect on the natural environment (i.e. air, surface water and ground water pollution). 2.5.2 Lighting Thoughtful selection of fixtures and lamps coupled with careful replacements is very crucial in lighting design. The following are the lighting design standards adopted:  Energy saving bulbs will be used  The minimum general lighting level is 300 lux  Warm-colour lighting will be used in the general lighting scheme because it creates better ambience in the toilets, which in turn encourages more care and responsibility from the users  Adequate number of windows with a good spread around the building will be incorporated to: o Provide maximum daylight effect, and o help create a softer and friendlier environment. Final ESMP _Construction of Institutional Sanitation Facilities. Page 19 May 2017 SAL Consult Ltd GAMA - AMA 2.5.3 Materials for Internal Finishes Materials that will be used for internal walls, floors and ceiling finishes will be durable and resistant to vandalism and neglect. The following are the good examples of finishes that have been adopted:  Floors of the toilet rooms will be tiled with non-slip ceramic tiles. Non-slip floor tiles have been selected because they are durable and relatively easy to clean and maintain as well as friendly  Internal walls of toilets will be ceramic wall tiled  The minimum size of tile will be (100mm x 200mm) Ceiling works should be made with the following materials depending on their availability on the market, cost and ease of maintenance:  Mineral fibre board,  Fibrous plaster board,  ½ “ plywood boards  Aluminium panels or strips The Consultant has opted for the use of ½ inch plywood boards based on availability and cost of materials on the local market. Ceilings will be painted white to brighten the toilet rooms, create the interest and produce conducive environment during use. 2.5.4 Water Closets (WCs) 1. All WC cisterns will be wall hung and robustly fitted against the cubicle wall 2. All plumbing fixtures connecting the WC suites will be concealed for easy maintenance and to deter vandalism. 2.5.5 Hand Wash Basin 1. Minimum size of handwash basins will be 500mm length x 400mm width. 2. Minimum spacing between any two (2) wash hand basins will be 800mm. 3. Minimum space between center of the basin and any end wall will be 500mm. 4. Minimum room dimension for hand-washing area with one wash hand basin will be 1800mm length X 1000mm width. 5. Water pressure and tap/wash basin will be positioned such that water splash is avoided. 2.5.6 Service Installations 1. All pipe works will be concealed, except for final connections to fixtures. 2. All electrical cables will be fully concealed 3. Coved tiles or PVC strips should be provided along edges as far as possible 4. Panels to pipe ducts will be located as far as possible in inconspicuous areas Final ESMP _Construction of Institutional Sanitation Facilities. Page 20 May 2017 SAL Consult Ltd GAMA - AMA 2.6 Labour and Related Issues There are thirty (30) construction sites under AMA and these are expected to be handled by six (6) different contractors. It is envisaged that each contractor would require up to a maximum of ten (10) workers per site. The contractors are expected to ensure that the number of workers engaged per site are in proportion to the project work load and contract duration Workers will be employed from among artisans in the local community and will return to their homes after completion of their daily assignments. The conduct of workers on site will be guided by the model code of ethics provided in Annex 2 to be adopted by the contractor. The working hours will as much as possible be limited to non-school periods to minimize the interaction between students and construction workers and will therefore avoid exposure of students to any indecent behavior that may be exhibited by the workers. Final ESMP _Construction of Institutional Sanitation Facilities. Page 21 May 2017 SAL Consult Ltd GAMA - AMA 3.0 RELEVANT POLICIES, LEGAL AND ADMINISTRATIVE FRAMEWORKS The relevant national and sector policies and plans, national legal and institutional frameworks and World Bank safeguards policies to guide the proposed construction of institutional sanitation facilities in Metropolitan and Municipal assemblies to ensure sustainable development and compliance with national and international regulations are briefly described below. 3.1 Policy Framework The National Environment Policy (2013) The Ghana National Environmental Policy was formulated in 1995 and revised in 2013. The ultimate aim of the National Environmental Policy of Ghana is to improve the surroundings, living conditions and the quality of life of the entire citizenry, both present and future. It seeks to promote sustainable development through ensuring a balance between economic development and natural resource conservation. The policy thus makes a high quality environment a key element supporting the country’s economic and social development. The National Environmental Sanitation Policy dated April 2010 The revised environmental sanitation policy seeks to refocus the priorities of the sector, so it is forward looking and effectively embraces the challenges of changing life-styles associated with modernization and improving wealth status. The policy lays the basis for developing a systematic approach and framework for identifying and harnessing resources for value-for-money (economy, effectiveness and efficiency) services to all. The Community Water Supply and Sanitation Programme (1994) The Government has adopted a national water supply and sanitation programme to rationalize the water sector to promote and improve the delivery of water services in terms of economy, efficiency, effectiveness and satisfaction. The long term goals of the programme are generally directed at covering the entire country with potable water and adequate sewage disposal system by the year 2020 with emphasis on payment of adequate tariffs by consumers to ensure full cost recovery and to provide revenue for operations and maintenance and replacement of systems. National Health Policy (2007) The National Health Policy document which aims at creating wealth through health, among other things places emphasis on improvements in personal hygiene, immunisation of mothers and children. The National Health Policy also argues that a healthy population could only be achieved if there were improvements in environmental hygiene and sanitation, proper housing and town planning, provision of safe water, safe food and nutrition and encouragement of regular physical exercise. 3.2 National Regulatory Framework The Constitution of the Republic of Ghana (1992) The Constitution includes some provisions to protect the right of individuals to private property, and also sets principles under which citizens may be deprived of their property in the public interest (described in Articles 18 and 20). Article 18 provides that “…Every person has the right to own property either alone or in association with others.� Final ESMP _Construction of Institutional Sanitation Facilities. Page 22 May 2017 SAL Consult Ltd GAMA - AMA In Article 20, the Constitution describes the circumstances under which compulsory acquisition of immovable properties in the public interest can be done: “No property of any description, or interest in, or right over any property shall be compulsorily taken possession of or acquired by the State unless the following conditions are satisfied:  The taking of possession or acquisition is necessary in the interest of defence, public safety, public order, public morality, public health, town and country planning or the development or utilization of property in such a manner as to promote the public benefit; and  The necessity for the acquisition is clearly stated and is such as to provide reasonable justification for causing any hardship that may result to any person who has an interest in or right over the property.� Article 20 of the Constitution provides further conditions under which compulsory acquisition may take place: no property “shall be compulsorily taken possession of or acquired by the State� unless it is, amongst other purposes, “to promote the public benefit (Clause 1). Ghana Investment Promotion Centre Act 1994, Act 478 The Ghana Investment Promotion Centre Act 1994 (Act 478) requires that every investor wishing to invest in the country must in its appraisal of proposed investment projects or enterprises, “…have regard to any effect the enterprise is likely to have on the environment and measures proposed for the prevention and control of any harmful effects to the environment...�. Environmental Protection Agency Act 1994, Act 490 The Environmental Protection Agency Act 1994 (Act 490) gave mandate to the Agency to ensure compliance of all investments and undertakings with laid down Environmental Assessment (EA) procedures in the planning and execution of development projects, including compliance in respect of existing ones. Environmental Assessment Regulations 1999, LI 1652 The Environmental Assessment Regulations 1999 (LI 1652) enjoins any proponent or person to register an undertaking with the Agency and obtain an Environmental Permit prior to commencement of the project. Fees and Charges (Amendment) Instrument 2015 (LI 2228) The Fees and Charges (Amendment) Instrument 2015 (L.I. 2228) replaces the Fees and Charges (Amendment) Instrument, 2014 (LI 2216), and gives regulation to the fees and charges (Miscellaneous Provision) Act 2009, Act 793. The law provides a comprehensive rates, fees and charges collectable by Ministries, Department and Agencies (MDAs) for goods and services delivered to the public. Water Resources Commission Act 1996, Act 522 The Water Resources Commission Act 1996 (Act 522) establishes and mandates the Water Resources Commission as the sole agent responsible for the regulation and management and the utilisation of water resources and for the co-ordination of any policy in relation to them. Section 13 prohibits the use of water (divert, dam, store, abstract or use water resources or construct or maintain any works for the use of water resources) without authority. The Act states under Section 24 that any person Final ESMP _Construction of Institutional Sanitation Facilities. Page 23 May 2017 SAL Consult Ltd GAMA - AMA who pollutes or fouls a water resource beyond the level that the EPA may pre-scribe, commits an offence and is liable on conviction to a fine or a term of imprisonment or both. GWCL Act/Statutory Corporations (Conversion to Companies) Act 461 of 1993 (as amended by LI 1648) The Statutory Corporations (Conversion to Companies) Act 461 of 1993 as amended by LI 1648, on 1st July 1999, transformed Ghana Water and Sewage Corporation into a 100% state owned limited liability, Ghana Water Company Limited (GWCL), with the responsibility for urban water supply only. The mandate of GWCL is to provide, distribute and conserve the supply of water in Ghana for public, domestic and industrial purposes in urban communities. GWCL may, after giving notice to the owner or occupier of any land or premises, enter on that land or premises and dig trenches, lay pipes and do any other acts reasonably necessary for the carrying out its functions. Local Government Act, 1993 Act 462 This Act establishes and regulates the local government system and gives authority to the Regional Coordinating Council (RCC) and the District Assembly to exercise political and administrative power in the Regions and District, provide guidance, give direction to, and supervise all other administrative authorities in the regions and district respectively. The Assembly is mandated to initiate programmes for the development of basic infrastructure and provide municipal works and services as well as being responsible for the development, improvement and management of human settlements and the environment in the district. Lands (Statutory Wayleaves) Act, 1963 (Act 186) The Lands (Statutory Wayleaves) Act, 1963 (Act 186) details the process involved in the occupation of land for the purpose of the construction, installation and maintenance of works of public utility, and for the creation of rights of way for such works. Further to this act, the statutory wayleave registration 1964 provides procedural details and grievance redress mechanism. The State Lands Act, 1963 (Act 125) The Act 125 vests the authority to acquire land for the public interest in the President of the Republic. It also gives responsibility for registering a claim on the affected person or group of persons, and provides details of the procedure to do this. The State Lands Act, 1962 provides some details to be taken into consideration when calculating compensation such as definitions for (1) cost of disturbance, (2) market value, (3) replacement value, and so on. Lands Commission Act, 2008 (Act 767) This Act provides for the management of public lands and other lands and for related matters. The Commission manages public lands and any other lands vested in the President by the Constitution or by any other enactment or the lands vested in the Commission. The Act advises the Government, local authorities and traditional authorities on the policy framework for the development of particular areas to ensure that the development of individual pieces of land is coordinated with the relevant development plan for the area concerned. The Minister may, with the approval of the President, give general directions in writing to the Commission on matters of policy in respect of the management of public lands. The Commission has the following divisions: Final ESMP _Construction of Institutional Sanitation Facilities. Page 24 May 2017 SAL Consult Ltd GAMA - AMA  Survey and Mapping;  Land Registration;  Land Valuation; and  Public and Vested Lands Management. The Labour Act, 2003 (Act 651) Section 118(1) of the Labour Act 2003 (Act 651) stipulates that it is the duty of an employer to ensure that every worker employed works under satisfactory, safe and healthy conditions. Act 651 contains a number of specific provisions relating to an employer’s duty to its workers. These include providing and maintaining “at the workplace, plant and system of work that are safe and without risk to health� and taking “steps to prevent contamination of the workplaces by, and protect the workers from, toxic gases, noxious substances, vapours, dust, fumes, mists and other substances or materials likely to cause risk to safety or health�. A worker is required to report situations that he believes may pose “an imminent and serious danger to his or her life, safety or health�. Workmen’s Compensation Law, 1987, PNDCL 187 It is to provide for the payment of compensation to workmen for personal injuries caused by accidents arising out and in the course of their employment. The tenets of the law places a large share of the burden of supporting workers injured at the workplace on the shoulders of the employers. 3.3 Institutional Framework Ministry of Local Government and Rural Development The Ministry of Local Government and Rural Development (MLGRD) exists to promote the establishment and development of a vibrant and well-resourced decentralized system of local government for the people of Ghana to ensure good governance and balanced rural based development. The Environmental Health and Sanitation Directorate (EHSD) of MLGRD has oversight responsibility for sanitation. The Ministry has developed and is currently implementing a National Environmental Sanitation Policy and an accompanying plan, the National Environmental Sanitation Strategy and Action Plan (NESSAP) and Strategic Environmental Sanitation Investment Plan (SESIP). The Ministry has a Project Coordinating Unit (PCU) which is coordinating the GAMA project. There is a safeguard specialist and a social safeguards specialist at the PCU to ensure that environmental and social issues are addressed during project implementation. Metropolitan, Municipal and District Assemblies Metropolitan, Municipal and District Assemblies (MMDAs) are responsible for the provision of water and sanitation services within their respective areas of jurisdiction, including the planning and implementation of projects where necessary. They serve as the planning authority responsible for the overall development of their areas of jurisdiction. The proposed construction of institutional sanitation facilities is being carried out by 11 MMDAs in the Greater Accra Metropolitan Area (GAMA). There is a GAMA Project Coordinator at AMA to coordinate the activities at the local level and to provide feedback and progress on implantation to the PCU. The GAMA project coordinator is not a Final ESMP _Construction of Institutional Sanitation Facilities. Page 25 May 2017 SAL Consult Ltd GAMA - AMA safeguard specialists and would require some training/capacity building for the ESMP implementation. Environmental Protection Agency The Environmental Protection Agency is the body responsible for regulating the environment and ensuring the implementation of government policies on the environment. The functions of the Agency include:  ensuring compliance with any laid down environmental impact assessment procedures in the planning and execution of development projects, including compliance in the respect of existing projects;  promoting effective planning in the management of the environment;  imposing and collecting environmental protection levies in accordance with the Environmental Protection Agency Act 1994, Act 490 or regulations made under the Act; and  acting in liaison and co-operation with government agencies, District Assemblies and other bodies and institutions to control pollution and generally protect the environment. The EPA has the capacity and will corporate with the municipal Assembly (i.e. the GAMA project coordinator) to ensure the protection of the environment during project implementation. Ministry Of Education/ Ghana Education Service (GES) The Ministry of Education/Ghana Education Service provides oversight responsibility for basic, secondary and tertiary education in Ghana. The School Health Education Program (SHEP) Unit under the Ghana Education Service is responsible for health promotion in schools up-to pre-tertiary level. The SHEP Unit facilitates the effective mobilization and deployment of available human, material and financial resources to equip school children with basic life skills for healthy living through skills- based health education, promoting good health and preventing diseases among the school population. There are SHEP Coordinators at the Metropolitan and Municipal levels and also at the school level. In the schools, the SHEP Coordinators are responsible for coordinating water, sanitation and hygiene (WASH) issues. The institutional arrangements for SHEP implementation at the Municipal level is illustrated in Figure 1 as follows:  Municipal SHEP Committee (at the apex): They are mandated by the SHEP Policy to amongst other things mobilize schools and communities for SHEP action and mobilize funds for SHEP implementation activities.  The School Management Committee is (SMC) is a community level stakeholder grouping that fosters community participation in educational development. The SMC plays a major role in the management of the school. Their establishment mandate includes roles in ensuring that the school premises are in a sanitary and structurally safe condition and to ensure that facilities are generally in a good state of repair.  The School-based Health Coordinator is a teacher on roll who is assigned the role of coordinating all school health related activities  School Health Club is a vehicle to activate pupils’ participation in school health activities. Final ESMP _Construction of Institutional Sanitation Facilities. Page 26 May 2017 SAL Consult Ltd GAMA - AMA Municipal SHEP Committee School Management Head Teacher Committee School based Health Coordinator School Health Club Figure 1: Institutional structure for SHEP implementation at the Municipal Assembly and School level The SHEP coordinator is not a safeguards specialist and would require some training/capacity building in the implementation of the ESMP. Ghana Health Service The Ghana Health Service (GHS) is the public service body responsible for implementation of national policies under the control of the Minister for Health through its governing Council - the Ghana Health Service Council. The mandate of GHS is to provide and prudently manage comprehensive and accessible health service with special emphasis on primary health care at regional, district and sub-district levels in accordance with approved national policies. The functions of GHS include to:  undertake management and administration of the overall health resources within the service;  Promote healthy mode of living and good health habits by people;  establish effective mechanism for disease surveillance, prevention and control; and  perform any other functions relevant to the promotion, protection and restoration of health. The School Health Education Programme is a joint mandate of the Ministries of Health and Education. Ghana Water Company Limited (GWCL) GWCL is the state utility company responsible for portable water supply to all urban communities in Ghana. The mandate of GWCL is to provide, distribute and conserve the supply of water in Ghana for public, domestic and industrial purposes in urban communities. The connection of water supply to the toilet facilities under the project will mainly be from GWCL supply lines. Community Water and Sanitation Agency Community Water and Sanitation Agency (CWSA) facilitate water supply and sanitation delivery for rural communities and small towns. CWSA plays a facilitative role in providing technical assistance for the planning and implementation of water and sanitation facilities in the districts. Final ESMP _Construction of Institutional Sanitation Facilities. Page 27 May 2017 SAL Consult Ltd GAMA - AMA 3.4 World Bank Safeguards Policies The World Bank (WB) has published policies/procedures to guide the safe development of projects it is funding. Among the ten (10) WB Safeguards Policies, one (1) – OP 4.01 – is triggered by the proposed project. The WB safeguards policies and a summary of their core requirements are provided in Table 4. Table 4: Summary of World Bank Safeguard Policies No World Bank Summary of core requirements Potential for Remarks or Safeguard Trigger under recommendation for Policy proposed project proposed project 1 OP 4.01 Requires environmental assessment (EA) of Triggered The entire GAMA Environmental projects proposed for Bank financing to help project being funded by Assessment ensure that they are environmentally sound and the WB, including the sustainable, and thus to improve decision Construction of making. The EA takes into account the natural Institutional Sanitation environment (air, water, and land); human Facilities in MAs and health and safety; social aspects (involuntary Construction of Road resettlement, indigenous peoples, and physical Culvert Drains falls cultural resources); and trans boundary and under category B, and global environmental aspects. It categorizes this EMP is in line with proposed projects into categories A, B, C or FI the requirement of the based on the extent of adverse impacts policy. anticipated from the project. For Category A and B projects, an ESMP is to be prepared to guide the Implementation of mitigation measures for all identified environmental impacts from the proposed project. 2 OP 4.04: Do not finance projects that degrade or convert Not triggered Project locations and Natural critical habitats. Support projects that affect design will not affect Habitats non- critical habitats only if no alternatives are any critical habitats. available and if acceptable mitigation measures are in place. The policy strictly limits the circumstances under which any Bank-supported project can damage natural habitats (land and water areas where most of the native plant and animal species are still present). 3 OP 4.09: Pest Support integrated approaches to pest Not triggered The project will not Management management, identify pesticides that may be involve the use of financed under the project and develop pesticides. appropriate pest management plan to address this. 4 OP 4.36: Aim is to reduce deforestation, enhance the Not triggered Project location and Forest environmental contribution of forested areas, design will not affect promote afforestation, reduce poverty, and any critical forests. encourage economic development. Final ESMP _Construction of Institutional Sanitation Facilities. Page 28 May 2017 SAL Consult Ltd GAMA - AMA No World Bank Summary of core requirements Potential for Remarks or Safeguard Trigger under recommendation for Policy proposed project proposed project Support sustainable and conservation oriented forestry. Do not finance projects that involve significant conversion or degradation of critical forest areas. 5 OP 4.11: Investigate and inventorise cultural resources Not triggered No culturally sensitive Physical potentially affected. Include mitigation sites identified. Cultural measures when there are adverse impacts on Resources physical cultural resources or avoid if possible 6 OP 4.12: Assist displaced persons in their effort to Not triggered The study did not find Involuntary improve or at least restore their standards of any evidence of Resettlement living. Avoid resettlement where feasible or existence or occurrence minimise. Displaced persons should share in of Involuntary project profits. Resettlement. The policy aims to avoid involuntary resettlement to the extent feasible, or to minimize and mitigate its adverse social and economic impacts. The policy prescribes compensation and other resettlement measures to achieve its objectives and requires that borrowers prepare adequate resettlement planning instruments prior to Bank appraisal of proposed projects. 7 OP 4.10: Screen to determine presence of indigenous Not triggered No indigenous groups Indigenous peoples in project area. Policy triggered were identified. Peoples whether potential impacts are positive or negative. Design mitigation measures and benefits that reflect indigenous peoples’ cultural preferences. 8 OP 4.37: Requires that experienced and competent Not triggered The proposed project Safety of professionals design and supervise construction, does not involve the Dams and that the borrower adopts and implements construction of dams. dam safety measures through the project cycle. The policy distinguishes between small and large dams by defining small dams as those normally less than 15 meters in height. Large dams are 15 meters or more in height. 9 OP 7.50: Ascertain whether riparian agreements are in Not triggered The proposed project Projects on place, and ensure that riparian states are does not involve International informed of and do not object to project international waters. Waterways interventions. 10 OP 7.60: Ensure that claimants to disputed areas have no Not triggered No issues of land Projects in objection to proposed project. dispute were identified. Disputed Areas Final ESMP _Construction of Institutional Sanitation Facilities. Page 29 May 2017 SAL Consult Ltd GAMA - AMA 4.0 BASELINE ENVIRONMENTAL AND SOCIAL CONDITIONS Baseline conditions give the existing status of the environment in the area before the commencement of the proposed project. The information serves the purpose of a base reference against which the changes due to the implementation of the project are measured. The ensuing therefore constitutes the baseline conditions of the proposed project area, which includes the existing physical and socioeconomic environment. 4.1 Location and Size The proposed project district is the Accra Metropolitan Assembly (AMA), which is one of the sixteen (16) Metropolitan, Municipal and District Assemblies (MMDAs) in the Greater Accra Region of Ghana. AMA has a total land area of 139.674 square kilometres and shares boundaries with the Ga South Municipal to the West, La Dadekotopon Municipal to the East and Ga West Municipal to the North. The Gulf of Guinea is on the South of the Metropolis (See Figure 2). Final ESMP _Construction of Institutional Sanitation Facilities. Page 30 May 2017 SAL Consult Ltd GAMA - AMA Figure 2: Map of Accra Metropolis (Source: Ghana Statistical Service, 2014) Final ESMP _Construction of Institutional Sanitation Facilities. Page 31 May 2017 SAL Consult Ltd GAMA - AMA 4.2 Physical Environment 4.2.1 Climatic Conditions The Accra Metropolitan Area lies in the dry equatorial climatic zone. It experiences two rainy seasons: May to mid-July and mid- August to October. It has an average annual rainfall of about 730mm. There is very little variation in temperature throughout the year. The mean monthly temperature ranges from 24.7°C in August (the coolest) to 33°C in March (the hottest) with annual average of 26.8°C. As the area is close to the equator, the daylight hours are practically uniform throughout the year. Relative humidity is generally high varying from 65% in the mid-afternoon to 95% at night (Ghana Statistical Service, 2014). 4.2.2 Vegetation There are three broad vegetation zones in the Accra Metropolitan area: shrub land, grassland and coastal lands. The shrub land occurs more commonly in the western outskirts and in the north towards the Aburi Hills. It consists of dense clusters of small trees and shrubs, which grow, to an average height of about five metres. The grasses are mixture of species found in the undergrowth of forests. They are short and rarely grow beyond one metre. Ground herbs are found on the edge of the shrub. They include species which normally flourish after fire (Ghana Statistical Service, 2014). The coastal zone comprises of two vegetation types, wetland and dunes. Mangroves, comprising of two dominant species, are found in the tidal zone of all estuaries sand lagoons. Salt tolerant grass species cover substantial low-lying areas surrounding the lagoons. There are a number of wetlands and water bodies which create micro climates in some parts of the Metropolitan Area. However, the original vegetation of the Metropolitan Area has been altered in the more recent past century by climatic and human factors (Ghana Statistical Service, 2014). The proposed project sites are within schools and are close to existing sanitation facilities. The vegetation at the project sites, if any, are common grasses and shrubs found in other areas of the schools and in the Metropolis. Trees are generally not expected to be affected from the project construction. 4.2.3 Geology and Soils The geology of AMA consists of Precambrian Dahomeyan Schists, Granodiorites, Granites Gneiss and Amphibolites to late Precambrian Togo Series comprising mainly Quartzite, Phillites, Phylitones and Quartz Breccias. Other formations found in the Metropolis are the Palaeozoic Accraian Sediments - Sandstone, Shales and Interbedded Sandstone-Shale with Gypsum Lenses. The coastline of the Metropolis has a series of resistant rock outcrops and platforms and sandy beaches near the mouth of the lagoons. The coastline is exposed and because of the close proximity of the continental shelf, a strong coastal and wind action, it is subject to severe erosion. The soils in the Metropolitan area can be divided into four main groups: i. drift materials resulting from deposits by windblown erosion; ii. alluvial and marine motted clays of comparatively recent origin derived from underlying shales; Final ESMP _Construction of Institutional Sanitation Facilities. Page 32 May 2017 SAL Consult Ltd GAMA - AMA iii. residual clays and gravels derived from weathered quartzites, gneiss and schist rocks; and iv. lateritic sandy clay soils derived from weathered Accraian sandstone bedrock formations. In many low lying poorly drained areas, pockets of alluvial ‘black cotton’ soils are found 4.3 Socio-Economic Environment The socioeconomic characteristics AMA are presented below. 4.3.1 Demographic Characteristics The population of Accra Metropolitan Assembly AMA, according to the 2010 Population and Housing Census, is 1,665,086 representing 42% of the region’s total population. Males constitute 48.1% and females represent 51.9%. The Metropolis is entirely urban. It has a sex ratio of 93 and youthful population (children under 15 years) (42.6%) depicting a broad base population pyramid which tapers off with a small number of elderly persons (60+ years) constituting 5.9 percent. The total age dependency ratio is 48.5%, the child dependency ratio is higher (42.6%) than that of old age dependency ratio (5.9) (Ghana Statistical Service, 2014). 4.3.2 Education and Literacy For the population 3 years and older in the Metropolis, Out of the 533,291 persons enumerated as being in school, 38.4% were at the primary level, 18.2% were at the JSS/JHS level while 12.8% were at the Senior High School level. More females (26.1%) than males (23.2%) ended their education at the JHS/JSS levels while more males (14.3%) than females (8.2%) completed tertiary education in the Accra Metropolis. Of the population 11 years and above, 89% are literate and 11% are non-literate. The number of non-literate females (98,439) was more than twice that of males (39,567) (Ghana Statistical Service, 2014). 4.3.3 Employment and Industry About 70.1% of the population aged 15 years and older are economically active while 29.9% are economically not active. The economically active population, 93% are employed while 7.0% are unemployed. More than a third (35.2%) of the total population who worked were in the wholesale and retail, repair of motor vehicles and motor cycles category. Of this number, females constituted the highest proportion (41.2%), indicating that females prefer working in those industries. More males (8.3%) worked in the construction industry compared to females (0.3%). In general, informal sector employment is predominant in the Metropolis. The private informal sector employs about 74% of the population (Ghana Statistical Service, 2014). 4.3.4 Water Supply Of the 30 beneficiary schools, 26% do not have water available and 74% have water. This is because either they did not have a GWCL piped water connecting to the school at all or they had been cut Final ESMP _Construction of Institutional Sanitation Facilities. Page 33 May 2017 SAL Consult Ltd GAMA - AMA due to accumulated and non-payment of bills. The measures used by these schools to meet their water needs include pupils fetching water from outside the school compound as a form of punishment, fetching of water by pupils as a school activity on the daily duty roaster and asking pupils to bring water to school (WasteCare Associates, 2016a). The 74% who had water also had some challenges with the service. Some of the schools complain that the water supply service which is usually GWCL water service is sporadic with frequent cut in the service. Some additionally complained that bills continued to pile up and they did not have any means of paying these bills and feared that service will be cut in the near future. Those schools who share compounds with the mission (church) depended on them for water. However some of the head-teachers reported that they had been threatened to pay up their share of the bills or risk being cut off (WasteCare Associates, 2016a). Water tanks and other means of water storage are used by most of the schools to store water. These water tanks are sometimes vandalized or even stolen by unscrupulous characters in the community. Plate 2 shows a water storage tank at Osu Presby Cluster. Plate 2: Water storage tank at Osu Cluster (Source: WasteCare Associates, 2016a) 4.3.5 Drainage Drains on school compounds are mostly non-existent. The common practice in many schools for liquid waste disposal is the throwing of waste water on the compound. This is also employed as a means to reduce dust as many of the school compounds are not cemented. 4.3.6 Sanitation and Hygiene Toilets Out of the 30 schools and clusters visited 32% of them have no toilets at all 7% have their toilets closed down for a number of reasons, 51% are in very poor conditions and remaining 10% are in relatively good condition (Figure 3). Final ESMP _Construction of Institutional Sanitation Facilities. Page 34 May 2017 SAL Consult Ltd GAMA - AMA Figure 3: Availability and condition of toilets in schools in AMA (Source: WasteCare Associates, 2016a) Of the 7% of toilets that were closed at the time of assessment, the common reasons were the lack of water for the effective operation of the toilet. Other reasons given were damaged septic systems and blocked toilets due to vandalism and improper use of the facility. A number of reasons accounted for the 51% toilets in poor condition. Some of the facilities are not being operated at their full capacity. It was common to see that, for example, a 20 seater toilet facility may be operating only at half capacity due to some broken fixtures or blocked toilets (drop holes). The few functional ones were under pressure. Again, due to the lack of water or irregular water supply, pupils or cleaners are unable to properly use and clean the facility. In most of the cases cleaning of the facility is left to pupils or in some cases those under punishment. There is usually very little or no supervision from teachers and hence the condition of the facility keep deteriorating. Children in schools without toilets resorted to the use of public toilets and/or engaged in open defecation. Open defecation is particularly common among the smaller children who are unable to go by themselves to public toilets, or do not have money for the fees, and are unable to hold an urgent need to defecate. They squat around the school compound, or use poly bags, open spaces or refuse dumps around the school and other open drains. In some cases teachers or attendants superintend over such acts because they have no other options. For the 10% toilets that are relatively in good condition, there is a designated cleaner who is paid, regular flow of water and in some cases the facility is relatively new and not under pressure. Of the 30 schools assessed, only 30% of schools that have toilet facilities met the Ghana Education Service (GES) minimum standard of 50 pupils per drop hole. A third of these facilities still presented poor condition due to irregular flow of water, absence of a designated full time cleaner and in some cases broken fixtures linked to improper use (WasteCare Associates, 2016a). Though it is mandated by law for schools to have disability friendly facilities, none of the schools assessed had disability friendly facilities (WasteCare Associates, 2016a). Final ESMP _Construction of Institutional Sanitation Facilities. Page 35 May 2017 SAL Consult Ltd GAMA - AMA Urinals About half (51%) of the 30 beneficiary schools have no urinals. Where toilets are available, pupils used them for that purpose. Where there are no toilets to be used as urinals, pupils urinate around the school compound. Where urinals are available, they are usually in poor condition and poorly managed. In some cases doors to the urinals are damaged, compromising security and privacy. Out of the 49% who have urinals, half are segregated for boys and girls. But for the remaining half both boys and girls have to share a cubicle. In about 90% of the school both male and female teachers have to share a single urinal (WasteCare Associates, 2016a). Plate 3 shows a dilapidated urinal in use at Ayalolo Cluster of Schools. Plate 3: Condition of a urinal at Ayalolo Cluster of Schools (Source: WasteCare, 2016a) Hand wash The common hand wash facilities currently used in most schools are Veronica buckets or any bucket, barrel, gallon or jerry can fitted with a tap to facilitate hand washing under running water. Some challenges experienced by schools include irregular water supply, un-sustained supply of soap and frequent breakdown of the hand wash facilities. Due to the frequent breakdown of hand wash facilities, most schools did not have hand wash facilities at the required designated areas and in some cases a whole school resorts to sharing one hand wash facility. In some schools, toilets did not have hand wash facilities and pupils have to use hand wash facilities provided in front of classrooms. Schools which had regular supply of water in some cases did not have hand wash facilities at all because pupils could easily walk to the tap to wash their hands (WasteCare Associates, 2016a). Plate 4 shows common hand wash facilities in schools under AMA. Final ESMP _Construction of Institutional Sanitation Facilities. Page 36 May 2017 SAL Consult Ltd GAMA - AMA Plate 4: Common hand wash facilities in schools under AMA (Source: WasteCare Associates, 2016a) 4.3.7 Waste Management The most widely used methods of solid waste disposal in the Accra Metropolis is collected from home (57.4%) and by public dump (container) accounting for 32.9%. Liquid waste is mostly disposed into gutters (48.0%), through a drainage system into a gutter (26.6%) and through a sewerage system (7.8 %) (Ghana Statistical Service, 2014). Generally all the beneficiary schools have some form of waste receptacles before refuse are finally disposed, though they are inadequate. Burning is the most common practice of waste disposal. This accounted for 60% of schools followed by the use of communal or public dump. A number of the schools use a combination of methods. Figure 4 shows the methods of waste disposal in schools under AMA. Final ESMP _Construction of Institutional Sanitation Facilities. Page 37 May 2017 SAL Consult Ltd GAMA - AMA Figure 4: Methods of solid waste disposal in schools under AMA (Source: WasteCare Associates, 2016a) Most schools resorted to burning as they were not in the position to pay the monthly service fee of Gh₵ 25 - Gh₵ 30 charged by the waste management companies. In other cases the waste collection service is unreliable and irregular that some schools had to burn what can easily be burnt on regular bases and leave the rest to be collected by waste management companies. The pick-up time is ideally once a week but usually done twice in a month. Burning is usually done daily in the morning or after school or weekly on Fridays or as and when needed. Some school heads indicated that neighbouring community members complain about the smoke whenever they burn, but do not have any other option available to them. Some of the schools practiced waste separation for plastics. They collected all plastics and sell to individuals who collect these plastics or to venders who buy these plastics. Some of the schools claimed though they were separating in the past, they had stopped due to the irregular pick up by venders and the lack of space to store plastics for long periods. Others do not separate at all because it was considered a laborious exercise. Many of the schools did not consider waste separation as a means to reduce waste and generate some income (WasteCare Associates, 2016a). Final ESMP _Construction of Institutional Sanitation Facilities. Page 38 May 2017 SAL Consult Ltd GAMA - AMA 5.0 STAKEHOLDER CONSULTATIONS Stakeholder participation during project planning, design and implementation is widely recognized as an integral part of environmental and social management for projects. It is a two-way flow of information and dialogue between project proponents and stakeholders, which is specifically aimed at developing ideas that can help shape project design, resolve conflicts at an early stage, assist in implementing solutions and monitor ongoing activities. Key project stakeholders were identified for consultations and these included AMA, the beneficiary institutions, local communities, and their representatives and local government institutions. 5.1 Objectives of Consultation The main objective of the consultations with stakeholders is to discuss the proposed project ’s environmental and social implications and to identify alternatives for consideration. Specifically, the consultations seek to achieve the following objectives:  To provide some information about the proposed project;  To provide opportunities for stakeholders to discuss their concerns and offer recommendations;  To gain insight on the role of each stakeholder in the implementation of the environmental and social safeguards as well as structures in place for the management of the proposed facilities;  To provide and discuss with stakeholders the alternatives considered to reduce anticipated impacts;  To identify and verify significance of environmental, social and health impacts; and  To inform the process of developing appropriate mitigation and management options. 5.2 Stakeholder Consultation Strategy and Plan Stakeholder consultation is a process and would continue through the ESMP study stages through to its implementation. Table 5 summarizes the proposed approach for stakeholder engagement. Final ESMP _Construction of Institutional Sanitation Facilities. Page 39 May 2017 SAL Consult Ltd GAMA - AMA Table 5: Stakeholder Engagement Programme No. Activity Identified Stakeholders Focus of Consultation/ Engagement Timelines/ Forms of communication Facilitator Frequency 1. Preparation of  Ministry of Local Government and  Challenges with WASH implementation Throughout the  One on one Interviews SAL Consult Rural Development/ Project in schools,  Field visitation ESMP/ Project design  Potential environmental and social issues ESMP study Limited Coordinating Unit,  Sharing and review of relevant  WasteCare Associates, of concern from the proposed project’s period reports  GWCL implementation  Email and phone calls  AMA (SHEP Coordinator/SHEP  Compliance with World Bank and EPA Committee), requirements for GAMA S&W Project  Head Teachers, student  Strategies for mitigating the potential representatives, School impacts and successful maintenance of Management Committee, non- the proposed facility during their teaching staff in schools operation  Public and occupational health and safety at construction sites  Scope of interventions of proposed works for institutional facilities construction and adequacy of sanitation facilities 2. Site preparation prior  School authorities  Information on schedule of preparation Two weeks prior  General stakeholder meeting WasteCare  Students and construction for school authorities, to construction  Awareness creation on the potential to construction Associates/ AMA  Community/ Assembly member Consultant, and contractor  WasteCare Associates/ Contractor impacts and remedial measures to  Announcement at School Works students and community Assembly Department/  Integration of the ESMP into planning for  Utilisation of WASH Notice construction (impacts and mitigation Head teacher/ “Talk� boards for students/staff measures) and notice board at site School based  Grievance redress procedures including safety signs Health  Capacity building for stakeholders for the  Community notifications. implementation of the ESMP Coordinator 3. Start of construction  School authorities  Information on Schedule of construction Throughout the  General stakeholder meeting WasteCare  Students works, activities and progress of for school authorities, construction construction Associates / AMA  Community/ Assembly member Consultant, and contractor  WasteCare Associates / Contractor  Awareness creation on the potential period  Announcement at School Works impacts and remedial measures to Assembly Department/ students and community  Utilisation of WASH Notice  Training Head teacher/ Final ESMP _Construction of Institutional Sanitation Facilities. Page 40 May 2017 SAL Consult Ltd GAMA - AMA No. Activity Identified Stakeholders Focus of Consultation/ Engagement Timelines/ Forms of communication Facilitator Frequency o ESMP Implementation (impacts and “Talk� boards for students/staff School based mitigation measures) and notice board at site o Code of Conduct including safety signs Health  Grievance redress mechanism  Community notification. Coordinator 4. End of construction /  School authorities  Information on Schedule of Decommissioning  General stakeholder meeting WasteCare  Students decommissioning works, activities and for school authorities, Decommissioning of progress of decommissioning phase Associates /AMA  Community/ Assembly member Consultant, and contractor construction  WasteCare Associates/ Contractor  Awareness creation on the potential  Announcement at School Works equipment and impacts and remedial measures to Assembly Department/ students and community  Utilisation of WASH Notice machinery  Training Head teacher/ “Talk� boards for students/staff o ESMP Implementation (impacts and and notice board at site School based mitigation measures) including safety signs Health o Code of Conduct  Community notification.  Grievance redress mechanism Coordinator 5. Commissioning and  School Management Committee  Operation and Maintenance (O&M) Prior to operation  General stakeholder meeting WasteCare (SMC) requirements of the toilets for school authorities, handing over of  Roles and responsibilities in the O&M of the facility Associates /  Parents Teacher Association (PTA) Consultant, and contractor Institutional  School based Health Coordinator  Training on the Facilities Management  Announcement at School Metropolitan sanitation facility (SBHC) Plan Assembly and SHEP Committee  School Health Club (SHC)  Utilisation of WASH Notice and Coordinator/ “Talk� boards for students/staff Head teacher/ School based Health Coordinator 6. Operation and  School Management Committee/  Hygiene education During operation  General stakeholder meeting WasteCare Parents Teacher Association  Operation and Maintenance (O&M)  Training workshops maintenance of requirements of the toilets and maintenance Associates /  School based Health Coordinator facility  Teachers/staff  Roles and responsibilities in the O&M period Metropolitan  School Health Club  Training on the Facilities Management SHEP Committee  Students Plan and Coordinator /  Review of grievance Metropolitan SHEP Coordinator Final ESMP _Construction of Institutional Sanitation Facilities. Page 41 May 2017 SAL Consult Ltd GAMA - AMA No. Activity Identified Stakeholders Focus of Consultation/ Engagement Timelines/ Forms of communication Facilitator Frequency  Students  Interactive activity teaching and testing 3 times a week  Classroom activity Class Teacher knowledge  Demonstration activity for building habits  Entire School  Teaching knowledge and motivating Fortnightly  Main school lesson during School health pupils for change of habits worship time club and SBHC.  Reinforcing/repeating key messages from 3 times a week  Morning Assembly School health Worship Time Sessions club and SBHC.  Reinforcing/repeating key messages from 3 times a week  WASH Notice “Talk� boards School health Worship Time Sessions club and SBHC.  All classes and all schools in  Activities focusing on testing knowledge Once a term  Competitions and SBHCs/ Metropolis dissemination to the entire school and demonstrative activities indirectly parents and communities Metropolitan SHEP Coordinator  Parents and Teachers  Support to activities/actions as well as Once a term  WASH Session during PTA  PTA reports on progress meeting for schools  Funding for the O&M of facilities  School Management Committee  Support to activities/actions as well as Once a term  WASH Session during SMC SMC (SMC) reports on progress. Meeting  support to School Health Club activities as well as individual support as club patrons  Support to SBHC Final ESMP _Construction of Institutional Sanitation Facilities. Page 42 May 2017 SAL Consult Ltd GAMA - AMA 5.3 Stakeholders Consulted Key stakeholders to the proposed Institutional Sanitation Facilities in the Accra Metropolitan Area have been identified and sampled for consultation. The Consultation of the stakeholders was carried out from November 2016 to February 2017 to gather information, comments and concerns on the proposed project with respect to the potential environmental and social issues and impacts. The approach adopted for the stakeholder consultations involved one-on-one interviews and focus group discussions. The stakeholders consulted during the ESMP study are listed below. Project proponents:  Ministry of Local Government and Rural Development/ Project Coordinating Unit - Safeguards Specialist  AMA - Director, Drains Maintenance Unit/GAMA SWP Project Coordinator. Engineering Consultant  WasteCare Associates - Chief Executive Officer Contractor  Milpar Development Investment - Managing Director; and - Foreman Beneficiary Schools  WASH implementers (Head Teachers; SHEP Coordinators; representatives of School Management Committee and Parent Teacher Association; school prefects and health club executives) in the following institutions: - Abossey Okai R/C Junior High School (JHS); - Abossey Okai 1&2 Basic School; - Kaneshie West Cluster; - Socco/M1 Cluster of Schools; - Dr. F.V. Nanka Bruce JHS; - Osu Salem 1 Primary School; and - Osu Salem 5 Primary School. 5.4 Outcome of Stakeholder Consultations carried out during ESMP Preparation A summary of the outcome of the stakeholder consultations is provided in Table 6. Further evidence of stakeholder consultations with the various stakeholders/institutions have been provided as Annex 1. Final ESMP _Construction of Institutional Sanitation Facilities. Page 43 May 2017 SAL Consult Ltd GAMA - AMA Table 6: Details of Stakeholder Consultations Stakeholder Contact Person Role Contact Date Concerns raised / information Received number PROJECT PROPONENTS/CONSULTANT/CONTRACTOR Ministry of Local George Awudi Safeguard Specialist 0506152780 Ongoing  Provided relevant information and documents on project implementation and Government and environmental and social concerns  Provided input on requirements for compliance with World Bank safeguards Rural  The ESMP must ensure it incorporates the provision of constant water supply to the Development/ sanitation facilities Project Coordinating Accra Graham O. Sarbah Director, Drains Maintenance 0243235530/ Nov. – Dec.  Provided relevant information and documents on project implementation and Metropolitan Unit/ GAMA SWP Project 0202019170 2016 environmental and social concerns including project description, screening reports, Facilities Management Plan, Baseline studies and other relevant reports of studies Assembly Coordinator (AMA). carried out.  Also served as liaison between the Environmental Consultant and the beneficiary institutions, as well as the Engineering Consultants. Engineering Lukeman Salifu CEO 0302786072 Nov.- Dec.  Provided a description of the proposed project scope and schedule for construction Consultant 2016  Provided information on environmental and safety measures to be put in place during (WasteCare construction works. Associates) Contractors -Milpar Christian Managing Director 0244377744 28/11/2016  Provided details of project and information on safety measures to be put in place at Development Hammond project sites. Investment Paul Danquah Foreman 0244605312 28/11/2016 HEADS OF INSTITUTIONS/SHEP COORDINATORS/ PAROCHIAL CHURCH COUNCIL (PCC)/ PARENT TEACHER ASSOCIATION (PTA) Dr. F.V. Nanka Rita Allotey Addo 0244121456 28/02/2017 Current Practices/ Challenges SHEP Coordinator Bruce JHS  The existing facility is a compositing toilet. Students pour about a handful of sawdust into the toilet after using it. Final ESMP _Construction of Institutional Sanitation Facilities. Page 44 May 2017 SAL Consult Ltd GAMA - AMA Stakeholder Contact Person Role Contact Date Concerns raised / information Received number Cherie Sam Teacher 0244786401  A philanthropist built the existing facility but it is inadequate to accommodate the entire school population.  The students come along with toiletries for their personal use in school.  Some students sometimes go home to use toilet facilities due to pressure on the existing facility Water availability  There is no water supply in the school. The GWCL lines have been disconnected due to the fact that accumulated utility bills have not been paid. Security  The people from the community come to use the existing facility as well and break the padlock when the door is locked, especially outside school sessions.  The school has written formally to the Assembly for the provision of a security person to help improve security in the school. Socco/ M1 Mercy Kusi- Circuit Supervisor 0208291439 28/02/2017 Current Practices/Challenges Cluster of Schools Appiah  There is also no toilet facility in the school currently. The students pay to use a public toilet opposite the school. Vincentia S. Banim Head Teacher 0244582671  The female students do not come to school during their menstrual period because there are no changing rooms available.  There is only one dustbin for the cluster. Theresa Owusu SHEP Coordinator 0243138281  Rubbish is sometimes dumped at a public dumpsite at Chorkor which is cheaper, but very far from the school. Daniel Acquah PTA Chairman 0241138538  There is a borehole but no GWCL connections in the school.  There are only few veronica buckets in the school.  The students are asked to bring soap and other toiletries to school at the beginning of the term sometimes.  Most of the classrooms are temporal structures made of wood.  The churches that use the classrooms for service pay the electricity bills sometimes.  There is a dilapidated structure where the new facility is to be sited.  Students are educated about sanitation issues and how to practice personal hygiene. Final ESMP _Construction of Institutional Sanitation Facilities. Page 45 May 2017 SAL Consult Ltd GAMA - AMA Stakeholder Contact Person Role Contact Date Concerns raised / information Received number  The school conducts inspection once every week as part of its role to promote personal hygiene. Management of new facilities  Part of the capitation grant given to the school by the government could be used as funds to maintain the new facility.  The P.T.A would also help with the provision of funds to maintain the new facility Osu Salem 1 Basic Akuaku Joe Bright Head Teacher 0243312253 28/02/2017 Current Practices/Challenges School  The existing facility was being rehabilitated by Football for WASH (an NGO) but the project has been stalled due to inadequate funds rendering only two out of ten toilet Okyere Monica SHEP Coordinator/ Teacher 0203001192 facilities to be used by both pupils and teachers. This has led to pressure on the toilet facilities because of the large school population.  There is no changing rooms for the girls.  There is no water supply currently although there is a poly tank that was donated by the NGO.  Most of the waste bins are broken hence it becomes difficult to dispose rubbish when the bins are full  The utility bills are paid with monies collected from churches and individuals who use the classrooms as places of worship. Comment on GAMA Project  School will like the Contractor to provide more details on the project to the school authorities. Osu Salem 5 Mrs. Salamatu 0244597126 28/02/2017 Current Practices/Challenges Primary Abdul-Karim  The existing 10-seater toilet facility which serves two schools (5no. each) was built by Head teacher Pronet (an NGO) is not adequate for the two schools. Miss. Matilda 0261696078  The source of water supply is a well but it is not sufficient especially in the dry season.  The people from the community come and use the existing facility during weekends Lokko SHEP Coordinator/ Teacher and on holidays.  The school caters for the utility bills using internally generated funds. Role of Health Club Final ESMP _Construction of Institutional Sanitation Facilities. Page 46 May 2017 SAL Consult Ltd GAMA - AMA Stakeholder Contact Person Role Contact Date Concerns raised / information Received number  The health club is responsible for educating the students on hygiene. Comments/Recommendations for GAMA Project  Noise was generated during construction activities, so it would be expedient if construction is done on weekends.  Water connection to the new facility can be tapped from the Osu Presby Cluster which is not far from the school. Kaneshie West Emelia Ohemeng Head Teacher 0244360212 28/11/2017 Challenges Cluster of Schools (See Plate 5)  The water bills are very huge.  There is currently a borehole in the school but it is salty hence it needs to be treated to enable the school use it instead of the water provided by GWCL.  There are no waste bins in the school so rubbish is burnt which causes a lot of health problems. Abossey Okai R/C Marian H. Head Teacher 0244607528 28/11/2016 Current Practices/ Challenges JHS Commeh  The existing toilet facility is a 12- seater KVIP which serves over 1000 students, hence putting pressure on the facility.  The louvre blades of the existing toilet have been removed, so when it rains it gets inside the toilet.  The school pays Zoomlion (a waste management company) to collect and dispose their solid waste.  There is water supply in the school currently but the water ceases to flow during the dry season.  A cleaner is paid by the school to clean the existing facility although the students also clean the place occasionally. This procedure will continue if the new facility is built. Comments on New Toilet  The school authorities have not been briefed on the project that the construction of the new facility Final ESMP _Construction of Institutional Sanitation Facilities. Page 47 May 2017 SAL Consult Ltd GAMA - AMA Stakeholder Contact Person Role Contact Date Concerns raised / information Received number Abossey Okai R/C Eunice S. Asante SHEP Coordinator 0243831883 28/02/2017 Current Practices/ Challenges  There is strong odour from the existing toilet facility. Pascal Mensah PCC Member 0260755521  The entire school population is about 2000.  The existing facility is not enough to accommodate the number of pupils hence there is pressure on it.  The female pupils are prone to infectious diseases due to the bad hygienic conditions of the existing toilets.  There is an existing borehole in the school which serves as a source of water supply.  The students pay levy and the church also supports with the payment of utility bills.  The teachers’ staff common room is very small and not convenient.  Recommendations/Suggestions for GAMA Project  The school would prefer a pour flush toilet facility as to water closets to help in easy maintenance of the new facility PREFECTS/HEALTH CLUB Socco/ M1 Boateng President (Health Club) - 28/02/2017 Current Practices/ Challenges Cluster of Schools Emmanuel  The students defecate in the nearby houses or community public toilets when they have stomach upset. They are charged 50pesewas when they go to the public toilets. Wiafe Foster Vice President (Health Club)  The students fetch water from nearby taps outside the school. A gallon costs Gh₵1.00.  The school has limited hand wash facilities (veronica buckets). Pappoe Juliet Secretary (Health Club)  The female students are inconvenienced during their menstrual period because there are no changing rooms for them. Osei Benjamin Organizer (Health Club)  Students go and fetch water during class hours for use sometimes due to the unavailability of water in the school. Antwi Naomi Treasurer (Health Club) Role of Health Club  There would be sensitization of students on how to use the new facility and also how -Members (Health Club) to properly dispose rubbish. (See Plate 6) Suggestions/Recommendations for Project  The students would be glad if the project provides them with toiletries even though Final ESMP _Construction of Institutional Sanitation Facilities. Page 48 May 2017 SAL Consult Ltd GAMA - AMA Stakeholder Contact Person Role Contact Date Concerns raised / information Received number they suggested that each of them could pay Gh₵1.00.to be used to purchase the toiletries. Osu Salem 1 Basic Amofah Eva School Prefect/ Health Club - 28/02/2017 Current Practices/ Challenges School Secretary  The existing toilet facility is not adequate to accommodate the school population.  There is no supply of water and hand washing facilities (veronica buckets) in the Ninyeh Benjamin Boys’ Prefect/ Health Club Vice school.  The girls have to change themselves in the latrines during their menstrual period, due President to no changing rooms. Role of Health Club in Sanitation and Hygiene Management  The Health Club Executives of the school organize fellow students to clean up the toilet facilities.  The health club organizes a programme to educate all students on the importance of good hygiene practice once in a month. Osu Salem 5 Joshua Bonsu Asst. Porter (Health Club) - 28/02/2017 Current Practices/ Challenges Primary  The toilet seats and handles of most of the existing water closets are spoilt, hence Stephen Yeboah Member (Health Club) needs to be rehabilitated  There are no changing rooms for the girls.  The Sanitation Prefects are to ensure the existing facility is kept clean. Claudia Borketey Member (Health Club)  The existing facility is cleaned both in the mornings and in the afternoons.  There is water available to be used to maintain the new facility.  Existing hand washing facilities (Veronica buckets) are inadequate and in a bad condition.  The school has inadequate dustbins. Role of Health Club in Managing New Facilities  The sanitation prefect and the health club executives will ensure that the new facility is kept clean and also ensure students do not squat on the water closets. Final ESMP _Construction of Institutional Sanitation Facilities. Page 49 May 2017 SAL Consult Ltd GAMA - AMA Stakeholder Contact Person Role Contact Date Concerns raised / information Received number Abossey Okai R/C Ishmeal Selormey School Prefect - 28/02/2017 Current Practices/ Challenges  The existing facility is a KVIP. Yahwe- Yire Djan Girls’ Prefect  Existing toilet is inadequate for the school’ population.  There are no changing rooms for the females.  The rubbish in the school is burnt and this pollutes the air Gilbert Jones Sectional Prefect  There are only few waste bins in the school, this makes waste management a challenge. Joyce Brooke Office Girl  The school has no library and the ICT is very small  There are holes in some parts of the roofing hence the sun and rains get into the Josephine Sackey Asst. School Prefect classrooms. (See Plate 7) Role of Prefects in Sanitation and Hygiene Management  Consultant explained to student their role in managing the new facilities and improving sanitation and hygiene in the school. Final ESMP _Construction of Institutional Sanitation Facilities. Page 50 May 2017 SAL Consult Ltd GAMA - AMA Plate 5: Consultation between Environmental Consultant, Official of AMA and Head Teacher of Kaneshie West Cluster of Schools Plate 6: Consultations with SHEP Coordinator, Prefects and Health Club Members of Socco/M1 Cluster of Schools Plate 7: Consultation with Prefects of Abossey Okai R/C School Final ESMP _Construction of Institutional Sanitation Facilities. Page 51 May 2017 SAL Consult Ltd GAMA - AMA 5.5 Key Environmental and Social Concerns from Stakeholder Consultations The main environmental and social concerns raised during the stakeholder consultations are as follows: i. Security Security in all the schools visited (refer to Section 1.3.2) is currently a major challenge. The schools mostly do not have a fence/wall and security personnel. Members of the neighbouring communities therefore use the schools’ toilet facilities, especially outside school sessions. This is more prominent in communities that do not have public toilet facilities. Locks installed by school authorities at the toilet facilities to keep out the public are usually destroyed. Security needs to be improved at the schools in general, and the toilet facilities especially to ensure the sustainability of the facilities. ii. Payment of utility bills Some schools complained of hire water bills and their inability to pay the water bills which results in disconnection of water supply from Ghana Water Company Limited. For example, water supply to Abossey Okai 1&2 Basic School had been disconnected due to non-payment of water bills by the school. iii. Lack of awareness of the project among school authorities and pupils Majority of the pupils in the various schools and some school authorities had seen the construction work ongoing and were aware there was a new toilet facility project. However they were not aware of the projects key components. Final ESMP _Construction of Institutional Sanitation Facilities. Page 52 May 2017 SAL Consult Ltd GAMA - AMA 6.0 DESCRIPTION OF ENVIRONMENTAL AND SOCIAL IMPACTS Field inspections and observations, concerns arising from stakeholder consultations and project description and designs formed the basis for the identified potential environmental issues and impacts likely to be associated with the proposed construction of institutional sanitation facilities in AMA. 6.1 Project Area of Influence 6.1.1 Geographical Area of Influence The immediate geographical area of influence for the proposed sanitation facilities is a maximum of 1 acre land in each of the beneficiary schools. The larger geographical area of influence covers the Accra Metropolis of the Greater Accra Region of Ghana. 6.1.2 Physical Environmental Media Influence The physical environmental media to be potentially influenced by the activities of the proposed project are land (landscape), air quality, groundwater and any adjacent drain to any of the project sites. The landscape features include soil, flora and fauna at the proposed project site which will be impacted by the project activities. Any adjacent drain to any of the project sites will be the recipient of runoff water from the project site. Any percolation of fuels during construction works and leachates from poorly constructed or improperly sited septic tanks through the soil may impact on groundwater resources. The air quality may also be impacted by dust and gaseous emissions from construction activities. 6.1.3 Community Influence and Vulnerable Persons in the Institutions The implementation of the proposed project could have an impact on the economic and socio- cultural conditions of the various project communities (as indicated in Table 1) and other neighbouring localities in AMA. Vulnerable Groups Vulnerable groups are those at risk of becoming disadvantaged and require special provisions in the project design. Vulnerable people include, but not limited to:  Physically challenged (disabled) pupils/teachers;  Pre-school children; and  Female pupils/teachers. The project will not result in the displacement of any person. The construction sites are within and belong to the beneficiary institutions, and are not inhabited by any persons. The toilet facilities to be provided are disability friendly, with a special cubicle provided in each toilet for disabled persons and ramp provided to aid access to the toilet. Adequate segregation and protection have been provided between toilet facilities for boys and girls to keep girls from aggressive boys (or any other potential attackers). Special facilities have also been included in the designs for toddlers. Final ESMP _Construction of Institutional Sanitation Facilities. Page 53 May 2017 SAL Consult Ltd GAMA - AMA 6.1.4 Institutional Influence The major institutions to be influenced or involved in the proposed project include:  Ministry of Local Government and Rural Development;  Ministry of Education;  Ghana Education Service;  Ministry of Health;  Ghana Health Services;  Environmental Protection Agency;  Accra Metropolitan Assembly;  WasteCare Associates;  The various Contractors;  The various beneficiary schools; and  Ghana Water Company Limited. 6.2 Project Activities of Environmental and Social Concern Activities of potential environmental and social impacts identified with the proposed project are outlined under four (4no.) main phases of the project activities; namely preparatory; construction; operations and maintenance; and decommissioning phases. 6.2.1 Preparatory Phase Activities Preparatory phase activities include among others:  Assessment of existing sanitation facilities, selection of beneficiary schools, field studies and environmental screening;  Preparation of environmental and social screening reports;  Statutory permitting activities from EPA. The preparatory phase activities had been completed prior to commencement of the preparation of the ESMP. 6.2.2 Construction Phase Activities Construction activities include among others:  Demolition of existing defective septic tanks ;  Demolition of existing defective WC toilets;  Site clearing (where applicable) and excavation works;  Identification of storage area for construction material;  Transportation and handling of materials and equipment;  Construction of WC toilet (with internal urinal) and septic tank;  Construction of U450 perimeter drain;  Connection of facilities to GWCL main supply lines and Installation of water storage poly tanks overhead and underground;  Rehabilitation of existing toilet facilities;  Laying of pavement around toilet facilities; and  Construction of refuse/solid waste holding bay. Final ESMP _Construction of Institutional Sanitation Facilities. Page 54 May 2017 SAL Consult Ltd GAMA - AMA 6.2.3 Operations and Maintenance Phase Activities Operations and maintenance phase activities include:  Housekeeping;  Waste management (collection and disposal);  Maintenance and repair works; and  Materials management and storage (including disinfectants, cleaning tools, personal protective equipment, etc.). 6.2.4 Decommissioning Phase Decommissioning activities after construction works will involve:  Disposal of construction spoil and waste in general;  Restoration of landscape around construction site; and  Removal of construction equipment. The sanitation facilities to be provided by the project will be utilized by the beneficiary schools as long as they are well maintained. Decommissioning during the operational phase is therefore unlikely. 6.3 Criteria of Impact Evaluation 6.3.1 Duration of the Impact  A temporary impact can last days, weeks or months, but must be associated to the notion of reversibility.  A permanent impact is often irreversible. It is observed permanently or may last for a very long term. 6.3.2 Extent of the Impact  The extent is regional if an impact on a component is felt over a vast territory or affects a large portion of its population.  The extent is local if the impact is felt on a limited portion of the zone of study or by a small group of its population.  The extent is site-specific if the impact is felt in a small and well defined space or by only some individuals. 6.3.3 Intensity of the Impact  The intensity of an impact is qualified as strong when it is linked to very significant modifications of a component.  An impact is considered of average intensity when it generates perceptible disturbance in the use of a component or of its characteristics, but not in a way to reduce them completely and irreversible. Final ESMP _Construction of Institutional Sanitation Facilities. Page 55 May 2017 SAL Consult Ltd GAMA - AMA  A weak intensity is associated with an impact generating only weak modifications to the component considered, without putting at risk some its utilization or its characteristics. 6.3.4 Impacts Severity  Major Impact: An impact of major significance is one where an accepted limit or standard may be exceeded, or large magnitude impacts occur to highly valued/sensitive resource/receptors. Repercussions on the environment are very strong and cannot easily be reduced.  Moderate Impact: An impact of moderate significance is within accepted limits and standards. Moderate impacts may cover a broad range, from a threshold below which the impact is minor, up to a level that might be just short of breaching an established (legal) limit. Repercussions on the environment are substantial but can be reduced through specific mitigation measures.  Minor Impact: An impact of minor significance is one where an effect will be experienced, but the impact magnitude is sufficiently small and well within accepted standards, and/or the receptor is of low sensitivity/value. Repercussions on the environment are significant but subdued and may or may not require the application of mitigation measures. 6.4 Evaluation of Potential Positive Impacts The potential positive impacts of the proposed construction of institutional sanitation facilities in AMA are stated and evaluated in Table 7. Table 7: Evaluation of potential positive impacts. No. Impact Key receptor(s) Evaluation Significance 1. Improved Students/staff/ The current sanitation infrastructure (toilets, urinals) in the Major beneficiary schools are inadequate and in a poor state. hygiene and visitors of Changing rooms for girls are not available. sanitation in beneficiary beneficiary schools The proposed project, through the construction and schools rehabilitation of toilet facilities, including urinals and hand washing facilities will improve hygiene and sanitation infrastructure as well as access in the beneficiary schools. The provision of changing rooms for girls will improve privacy for girls especially during their menstrual period and menstrual hygiene. The proposed project will therefore lead to a major improvement in hygiene and sanitation in the beneficiary schools in AMA. 2. Improved Disabled people The existing sanitation facilities in the beneficiary schools Major are not disability-friendly, which makes access to the access to in the disabled a challenge. The sanitation facilities to be provided hygiene and beneficiary by the project will have toilets specially made and reserved sanitation schools for disabled people. Ramps will also be made to ease access facilities by to the toilet facilities by disabled people on wheel chairs. disabled people The impact will be major. Final ESMP _Construction of Institutional Sanitation Facilities. Page 56 May 2017 SAL Consult Ltd GAMA - AMA No. Impact Key receptor(s) Evaluation Significance 3. Improved waste Students/staff/ Waste management is a challenge in many schools due to Major inadequate bins and lack of proper storage areas of bins management in visitors of prior to collection. Some schools resort to dumping of beneficiary beneficiary refuse in open areas and open burning as a means of waste schools; schools management due to inadequate or lack waste collection bins and storage areas. The proposed project will improve waste storage and disposal through the provision of refuse/solid waste holding bay. The impact on waste management in the beneficiary schools is major. 4. Improved water Beneficiary Water supply for use and cleaning of existing sanitation Major facilities in the beneficiary schools is unavailable or where supply in schools available, is unreliable. This leads to poor hygiene and beneficiary cleaning in the toilets and urinals which poses health risks schools to the users. The proposed project will improve water supply for use in the sanitation facilities through connection of water and provision of poly tanks overhead and underground for water supply to the toilet facilities. The impact will be major. 5. Employment Community The proposed project will create employment opportunities Major for skilled and unskilled labour during the construction and generation members, operational phases. These include direct employment people from opportunities such as masons, carpenters and labours to be other engaged by the contractor during construction works, and communities indirect employment opportunities such as food vendors, petty traders and suppliers of raw materials for construction. During the operational phase, job opportunities will be created for maintenance workers and suppliers of disinfectants, waste management companies, etc. The project will have a major positive impact on the socioeconomic conditions of the various project communities, and AMA a whole through the creation of permanent and temporary direct jobs, and indirect jobs. 6. Improvement in Neighbouring The creation of direct and indirect job opportunities during Major the construction and operational phases of the project will local and communities, boost the local and national economy. Improved hygiene national AMA and and access to sanitation facilities, as well as improved waste economy national management in the beneficiary schools will reduce economy sanitation and hygiene related diseases and associated cost. The impact will be major and last throughout the duration of the project. Final ESMP _Construction of Institutional Sanitation Facilities. Page 57 May 2017 SAL Consult Ltd GAMA - AMA 6.5 Evaluation of Potential Adverse Impacts Associated with the Proposed Project The adverse environmental and social issues which could potentially arise from the proposed project activities are stated and evaluated in Table 8. Table 8: Evaluation of potential adverse impacts No. Impact Key Evaluation Significance receptor(s) Preparatory Phase 1. Approval for Beneficiary Approval must be sort from school authorities in the selection of Major schools and prior to construction works. Especially for Construction schools Missionary Schools, which are owned and managed by Churches, and Siting of the Church Leadership must be consulted in addition to the Head toilet facility Teachers for their approval as they will play a key role in the management of the facilities. It is important that siting of the proposed sanitation facilities is compatible with activities in its close proximity. For instance, where the proposed construction sites are close to canteens, this may influence the hygienic conditions of food sold at the canteen. Construction Phase 1. Loss of Flora, fauna, The construction of the various project facilities will require Minor limited vegetation clearance at some selected sites. The vegetation and soil vegetation to be lost are mainly grasses or shrubs. Individual impacts on stands of trees occur at very few schools, example Kaneshie fauna West Cluster of Schools. A tree will be removed only where it is unavoidable after review by an Environmental Specialist. The vegetation clearance will therefore not result in the loss of any species of conservation value. Insects which may inhabit these vegetation may be disturbed and will escape to adjoining vegetation. Impact on vegetation is site-specific. The impact on fauna (insects) is negligible as the project sites are already disturbed due to ongoing human activities. 2. Soil impacts and Soil, drains Excavation works, vegetation clearance, levelling and other Moderate ground works will expose and loosen the soil making it sediment susceptible to erosion. Transported soil from erosion may end up transport in nearby drains. Improper handling and storage of fuel at the construction site could lead to oil/fuel spills which could contaminate the soil. The impact is temporary lasting during the construction works. But can be managed through good construction practices. 3. Air quality Ambient air Loosed and exposed soils from land preparation, dumping of Moderate sand/laterite for construction works and movement of vehicles deterioration environment, delivering construction materials to the sites may release dust in construction the immediate vicinity of the project. This may temporarily affect workers, air quality in the schools. Exhaust fumes from vehicles and pupils and concrete mixing machines may also impact on air quality. teachers The impact is local and temporary, lasting during the land preparation and construction phase. 4. Vibration and Air, fauna, The operation of concrete mixing machines, movement of Major delivery trucks, tooting of horns of delivery trucks and carpentry noise nuisance workers, works will generate noise. This will create a nuisance for the pupils and beneficiary schools, especially when school is in session. The Final ESMP _Construction of Institutional Sanitation Facilities. Page 58 May 2017 SAL Consult Ltd GAMA - AMA No. Impact Key Evaluation Significance receptor(s) teachers demolition of old sanitation facilities may also lead to minor vibrations. The impact is temporary and of local extent. 5. Visual intrusion Landscape, Construction of new sanitation facilities will result in alteration in Moderate the landscape character and features. Poor housekeeping pupils and practices at the site may also reduce the aesthetic value of the teachers area. The presence of the workers at site and their activities may attract the attention of the pupils. This impact will be local and temporary. 6. Destruction of Public, The movement of delivery trucks through the compound of Moderate beneficiary schools to the construction sites may result in property and property destruction of pavements and concreted areas. The dumping of obstruction of construction materials and waste in pathways may also obstruct walkways movement of people. Excavations for laying of pipelines for water connection may also obstruct movement where it crosses walkways or destroy pavements and concreted areas along the route. The affected pavements or concreted areas may belong to individuals where the water connection point is outside the schools’ compound. The impact, though temporary and lasting during the construction phase, will create inconvenience for the pupils/teachers and may result in public complaints. 7. Generation and Soil, water Vegetative material, excavated soil and construction spoils will Major form the bulk of construction waste generated at the project disposal of solid bodies, sites. Construction spoils will mainly consist of demolished waste school structures, used nails, wood chippings, plastics and pieces of iron premises rods, etc. Construction workers may also generate human and domestic wastes such as used polythene bags, food wastes, used water sachets and bottles, etc. The impact is of local extent and temporary, lasting during the construction phase. 8. Occupational Workers Occupational health and safety issues associated with the Major proposed project construction include: health & safety  Exposure of workers to excessive noise, vibrations and dust;  Accidents in the use and handling of equipment and machinery;  Injury to the body during the use and handling of equipment and machinery; and  Illness caused by exposure to wastes and odour. The extent of impact could be temporary or permanent. 9. Public safety & Public, The transportation of construction materials to site and the Major movement of equipment to and from the project site may pose Traffic issues school safety risk to school children especially during break periods community when school children are playing. The movement of delivery trucks to the construction sites may also potentially disrupt traffic especially at junctions leading to the schools. Unsecured construction sites and excavations may pose safety risks to school children in particular who may go playing at the construction sites. The non-removal/abandoning of construction equipment from sites after completion of construction works may pose safety risks to pupils/teachers/public. The impact could be temporary or permanent and could have major safety consequences. 10. Sanitation and Land, water Key potential sanitation and public health issues that may arise Major from the proposed project include: Final ESMP _Construction of Institutional Sanitation Facilities. Page 59 May 2017 SAL Consult Ltd GAMA - AMA No. Impact Key Evaluation Significance receptor(s) public health bodies,  unsightly conditions of poorly managed construction site and workers, indiscriminate disposal of waste;  indiscriminate disposal of human waste could also lead to public spread of diseases; and  open trenches and containers could collect water and breed mosquitoes. The duration of the impact is temporary. Operational Phase 1. Nuisance from Public, pupils Odour may emanate from the toilets and urinals if they are not Moderate properly and frequently cleaned. Dislodging of septic tanks when odour and teachers full will also generate odour which will be a nuisance to nearby residents and members of the beneficiary schools. Odour may also emanate from the waste storage and collection sheds if the bins are not regularly emptied. The odour may be intense within the vicinity of the facilities. 2. Ground water Ground Poorly constructed septic tanks may result in leakages which Minor could potentially contaminate ground water, especially in areas contamination water, public where the water table is high. This could have serious health implications for people who depend on ground water as the leakage may occur for long periods without being detected. This impact can be prevented/minimized through proper designing and construction. No areas with high water table have been identified in the beneficiary schools. The probability of the impact is therefore minimal. 3. Waste Land, public, The main solid waste to be generated on a daily basis at the Major toilet facilities are faecal matter, used tissue paper, toilet roll and generation school sanitary pads. These have to be regularly and properly disposed or could lead to odour, attract flies and have health implications. Bins at waste storage and collection sheds also have to be regularly emptied to prevent overflows which will be a nuisance and have health implications. Septic tanks may also overflow if they are not emptied when full. Waste generation will be permanent, lasting throughout the life span of the project. 4. Sanitation Public, Rodents, flies, cockroaches and other insects may transmit Major diseases to humans from contact with exposed feacal matter and issues and school rubbish at waste storage and collection sheds. The impact could public health occur through the life span of the project. impacts Decommissioning Phase 1. Occupational/ Workers, The relocation of all construction facilities and remaining Moderate public safety pupils, materials including concrete mixer, trucks, water tanks to new and traffic teachers, sites or contractor’s office could result in accident and injury to workers. The removal and transport of such equipment and impacts public materials could also pose traffic risks and public safety concerns within the schools and along the routes. The duration of the impact is temporary and could be local or of regional extent. 2. Waste Workers, The dismantling and removal of equipment and materials at the Moderate site, as well as landscape restoration works could generate waste management pupils, such as scraps metal, wood, concrete debris, vegetative material, teachers, and garbage (pieces of plastic bags, food wrappers, etc.). Final ESMP _Construction of Institutional Sanitation Facilities. Page 60 May 2017 SAL Consult Ltd GAMA - AMA No. Impact Key Evaluation Significance receptor(s) public The duration of the impact is temporary, the extent local and the severity minor. 6.6 Evaluation of Risks to Sustainability of Project The potential risks to the sustainability of the proposed project, as identified by the stakeholder consultations, review of project documents and field inspections, are evaluated in Table 9. Table 9: Evaluation of risks to the Sustainability of the Project No. Risk Key receptor(s) Evaluation Significance 1. Flooding Groundwater, Heavy rains may result in flooding of areas around the toilet Major facilities which may end up flooding the toilets if adequate beneficiary preventive measures are not incorporated into the design. institution Flooding at toilet facilities may also result from rain water getting into toilets which do not have proper windows and adequate drains around the facility. Flood waters may carry feacal matter which may end up contaminating surface and ground water bodies and the soil. 2. Security issues Beneficiary Poor security in the institutions could lead to community Major institution members entering the institutions’ compounds to use the toilet facilities or break into the toilets to use them. This could lead to damage to equipment parts such as door handles or damage to the water closet. Security is currently a challenge in many schools and the risk is high. 3. Unavailability of Students/staff/ The success of the proposed facilities hinges heavily on the Major water regular availability of water at the toilets and beneficiary visitors institutions. Damage to water supply lines and unavailability of water/irregular flow of water for flushing and cleaning may pose serious health risks. Water supply to the beneficiary institutions is currently unavailable or where available, is unreliable. The health risk is high. 4. Poor Sanitation The installation of less durable equipment such as water Major maintenance closets, hand wash basins and their fittings may lead to facilities, culture frequent breakdowns or early damage of the equipment. beneficiary Improper use of the sanitation facilities and poor institutions maintenance culture by the beneficiary institutions will also result in frequent damage to parts of the facilities, which may result in the facilities not functioning properly. This may also result in high cost of repairs. Maintenance of the existing toilet facilities is currently a challenge in many schools. 5. Inadequate Sanitation Funds are required for facility cleaning, provision of Major supplies, desludging services, maintenance and repairs and funds facilities, other related activities. The GES-SHEP Facilities beneficiary Management Guide indicates the Capitation Grant as the institutions main source of funds for implementing the school’s facilities management plan (FMP). This allocation is however inadequate and must be supplemented to meet the maintenance needs of the proposed facilities. Final ESMP _Construction of Institutional Sanitation Facilities. Page 61 May 2017 SAL Consult Ltd GAMA - AMA No. Risk Key receptor(s) Evaluation Significance Payment of water and electricity bills in most schools is a challenge. Some schools have accumulated debts which must be paid to avoid any potential disconnection of electricity and water to the schools in future. 6. Lack of Beneficiary In order to obtain the full support of the beneficiary Minor institutions, it is important to ensure they are fully aware of awareness of institutions the scope and schedule of the facilities to be provided for the project each beneficiary institution. information Consultations indicate that the level of awareness of the project is mainly limited to the head teachers and SHEP Coordinators, other staff and students have minimum knowledge and this may affect the extent to which they take ownership of the project. Final ESMP _Construction of Institutional Sanitation Facilities. Page 62 May 2017 SAL Consult Ltd GAMA - AMA 7.0 ENVIRONMENTAL AND SOCIAL MITIGATION AND MANAGEMENT PLAN 7.1 Mitigation/Action Plan Mitigation and management measures for the significant adverse impacts (rated as moderate or major) identified from the analysis and evaluation of the potential impacts from the proposed project activities are provided in Table 10. Table 10: Mitigation measures/actions for potential significant adverse impacts No. Potential Project Activities Proposed Mitigation Measures/Actions Responsibility Cost Estimates per Environmental and project site (Gh₵) Social Impacts PREPARATORY PHASE 1. Approval for  Stakeholder Consultations  Consult and seek free, prior and informed consent from school authorities prior to Contractor/Engineering Already captured construction and siting  Siting of toilet facilities construction work. Consultant in Bill of Quantities of toilet facility  For Missionary schools, seek free, prior and informed consent of Church Leadership (BoQ) in addition to Head Teachers.  For all schools, Engineering Consultant to extensively consult school authorities on the siting of toilet facilities in the school. The selection of sites should be agreed upon with the school authorities.  The selection of sites should take into consideration compatibility with adjacent school facilities. The adjacent school facilities should not be at risk from the operation of the proposed toilets.  To ensure that students always have access to toilet facilities, the contractors/consultants are not to demolish existing toilet facilities until the new toilet facilities are in place. Where the existing toilet facility is the only toilet for the school but has been earmarked for rehabilitation and or reconstruction, then alternative toilet facilities should be provided the school/students during the rehabilitation/reconstruction of the existing toilet facility. Where necessary, mobile toilets should be provided. Where necessary, mobile toilets should be provided. Final ESMP _Construction of Institutional Sanitation Facilities. Page 63 May 2017 SAL Consult Ltd GAMA - AMA No. Potential Project Activities Proposed Mitigation Measures/Actions Responsibility Cost Estimates per Environmental and project site (Gh₵) Social Impacts CONSTRUCTION PHASE 1. Soil impacts and  Site clearing and excavation works  Vegetation (grasses and shrubs) should be cleared only when contractor is fully Contractor/ Already captured sediment transport  Water connection from GWCL mobilised for construction. Engineering Consultant in Bill of Quantities supply line.  Vegetation clearance (where necessary) and excavations should be limited to the (BoQ) demarcated construction site.  Backfill with excavated soil material where appropriate.  Re-vegetate areas around construction sites to restore the landscape.  Ensure that heaped sand delivered for construction works is covered with tarpaulin to prevent wind and water transport of soil particles.  Consult affected property owners/users and seek their consent prior to construction works.  Realign all affected utility service lines.  Reinstate any damaged property such as pavements, etc. 2. Air quality deterioration  Site clearing and excavation works  Deliver construction equipment and materials to the construction sites outside Contractor/ Already captured  Demolition of existing school school sessions, such as in the evenings or on weekends. Engineering Consultant in BoQ sanitation facilities (where  Speed limit for all vehicles and construction equipment should be less than 30km/h applicable) within the school environs and less than 50km/h within communities. Provide  Transportation of materials and speed limit signs to guide drivers/operators. equipment  Dampen untarred routes of vehicles/trucks to the construction sites.  Construction of facilities  Haulage trucks carrying sand should be covered with tarpaulin.  Disposal of construction spoil and  Hydraulic concrete mixing machines should be used as much as possible and waste in general. regularly service all construction equipment and machinery. 3. Vibration and noise  Demolition of existing school  Demolition of old structures should be done outside school sessions, such as in the Contractor/ Already captured nuisance sanitation facilities (where evenings or during weekends. Engineering Consultant in BoQ applicable);  Carpentry works, and other noise generating activities should as much as possible  Site clearing and excavation be carried outside school sessions. Final ESMP _Construction of Institutional Sanitation Facilities. Page 64 May 2017 SAL Consult Ltd GAMA - AMA No. Potential Project Activities Proposed Mitigation Measures/Actions Responsibility Cost Estimates per Environmental and project site (Gh₵) Social Impacts works;  Hydraulic concrete mixing machines should be used as much as possible and  Transportation of materials and regularly service all construction equipment and machinery. equipment;  Construction of facilities 4. Visual intrusion  All construction phase activities  The construction sites should be hoarded off from public view. Contractor/ Already captured  Ensure good housekeeping at the construction site. Engineering Consultant in BoQ  Ensure an acceptable post-construction site as per provisions in the contract.  Remove all construction equipment from the site after completion of work. 5. Destruction of property  Demolition of existing school  Ensure construction equipment are not parked haphazardly to obstruct walkways. Contractor/ Already captured and obstruction of sanitation facilities (where  As much as possible, do not dump construction materials in walkways. Engineering Consultant in BoQ walkways applicable);  Provide safe alternative routes for pedestrians where walkways will be obstructed.  Site clearing and excavation  Consult affected property owners/users and seek their consent prior to works; construction works.  Transportation of materials and  Realign all affected utility service lines. equipment;  Reinstate any damaged property such as pavements, etc.  Excavation works;  Disposal of construction spoil and waste in general. 6. Generation and disposal  All construction activities  Apply the principles of Reduce, Reuse and Recover for waste management. For Contractor/ Already captured of solid waste example: Engineering Consultant in BoQ - Purchase the right quality and quantity of materials; - Ensure judicious use of construction materials such as pipes, laterites, sand, etc.; - Reuse excavated soil material for backfilling and levelling if appropriate.  Provide bins on site for temporary storage of domestic waste such as lubricant containers, drinking water sachets and carrier bags/packaging materials. Final ESMP _Construction of Institutional Sanitation Facilities. Page 65 May 2017 SAL Consult Ltd GAMA - AMA No. Potential Project Activities Proposed Mitigation Measures/Actions Responsibility Cost Estimates per Environmental and project site (Gh₵) Social Impacts  Dispose all construction and domestic waste at AMA approved dump sites. 7. Occupational health and  All construction activities  Engage experienced artisans for construction works. Contractor Already captured safety (OHS) issues  All workers should be given proper induction/orientation on safety. in BoQ  The contractors should have a Health & Safety Policy to guide the construction activities. The contractor health and safety policy would take into consideration the World Bank EHS guidelines  Regularly service all equipment and machinery.  Ensure first aid kits on site and a trained person to administer first aid.  Provide and enforce the use of appropriate personal protective equipment (PPE) such as safety boots, reflective jackets, hard hats, hand gloves, earplugs, nose masks, etc. for the labour force.  Comply with all site rules and regulations. Engineering Consultant  Apply sanctions where safety procedures are not adhered to.  Site meetings should create awareness on OHS. 8. Public safety and traffic  Construction activities  Hoard off the construction sites to prevent access by unauthorised persons. Contractor/ Already captured issues  Transport of equipment and  Use caution tapes and warning signs at the construction sites around trenches and Engineering Consultant in BoQ materials to and from site excavations.  Deliver construction equipment and materials to the construction sites outside school sessions such as in the evening or weekends.  Speed limit for all vehicles and construction equipment should be less than 30km/h within the school environs and less than 50km/h within communities. Provide speed limit signs to guide drivers/public.  Do not park at unauthorised places to reduce the risk of accidents.  Erect temporary road signs at junctions to the beneficiary schools during the delivery of construction equipment and materials.  Ensure delivery trucks hired/contracted are in good condition to prevent Final ESMP _Construction of Institutional Sanitation Facilities. Page 66 May 2017 SAL Consult Ltd GAMA - AMA No. Potential Project Activities Proposed Mitigation Measures/Actions Responsibility Cost Estimates per Environmental and project site (Gh₵) Social Impacts breakdowns on roads.  Remove all construction equipment from the site after completion of work. 9. Sanitation issues and  All construction phase activities  Provide bins on site for temporary storage of domestic waste such as lubricant Contractor/ Already captured public health impacts containers, drinking water sachets and carrier bags/packaging materials. Engineering Consultant in BoQ  Dispose all construction and domestic waste at AMA approved dump sites and in the approved manner.  Ensure all trenches or excavations made during the construction works do not collect stagnant water which could breed mosquitoes.  Ensure construction workers do not use existing school’s toilet facilities. Either they identify nearby public toilet facilities for use or provided with temporary toilets (mobile toilets) for use. Public All construction phase  Implement Grievance Redress Mechanism, which will include such elements as: Refer to Redress Refer to Grievance concerns/Grievance o Lodging and registration of PAPs grievance by grievance redress mechanism Chapter Redress Budget at redress committee; table 14 o Redress decision, feedback and implementation; o Dissatisfaction and alternative action; and  Carry out monitoring and evaluation. OPERATIONS PHASE 1. Nuisance from odour  Operation of sanitation facilities  Comply with provisions in the Facilities Management Plan (FMP). Authorities of 4,000 (per school  Ensure good housekeeping at toilet facilities. beneficiary school/ per year)  Clean toilet facilities regularly with disinfectants. SHEP Coordinator  Empty bins in classrooms/offices regularly.  Liaise with AMA to contract a waste management company to regularly collect and dispose waste at AMA approved dump site.  Dislodge septic tanks outside school sessions, such as on weekends. 2. Waste generation and  Use of sanitation facilities  Regularly empty waste bins at the various locations when full. Authorities of 4,000 (per school Final ESMP _Construction of Institutional Sanitation Facilities. Page 67 May 2017 SAL Consult Ltd GAMA - AMA No. Potential Project Activities Proposed Mitigation Measures/Actions Responsibility Cost Estimates per Environmental and project site (Gh₵) Social Impacts disposal  Waste management  Sensitize pupils/staff on effective use of bins to avoid indiscriminate disposal of beneficiary school / per year)  Maintenance and repair works. waste. SHEP Coordinator  Damaged waste bins should be replaced as appropriate.  Liaise with AMA to contract a waste management company to regularly collect and dispose waste at AMA approved dump site.  Inspect septic tanks periodically and dislodge when full. 3. Sanitation issues and  Use of sanitation facilities  Ensure pupils/staff wash their hands under running water and soap after use of SHEP Coordinator/ 1,000 (per school health impacts  Waste management (collection toilet facilities. Head of school / per year) and disposal)  Ensure good housekeeping at toilet facilities. Administrator  Maintenance and repair works;  Clean toilet facilities regularly with disinfectants. and  Ensure bins are properly covered at all times.  Materials management and  Avoid indiscriminate dumping of waste at waste storage and collection shed and storage (including disinfectants, always keep the place clean. cleaning tools, personal protective  Provide disposable hand gloves for cleaning of sanitation facilities and emptying of equipment, etc.). bins.  Create awareness on hygiene and sanitation issues, including proper use of sanitation facilities and proper handling and disposal of waste.  Comply with provisions in the FMP. DECOMMISSIONING PHASE 1. Occupational/public All decommissioning activities The contractor will be required to ensure that: Contractor/ No additional cost safety and traffic  personal protective gear are provided to workers involved with decommissioning Engineering Consultant required aside of facilities. impacts BoQ  toilet facilities are available throughout the decommissioning period.  workers still have access to public toilet facilities in the communities or can be conveyed to such facilities where needed, if mobile toilet facilities have been relocated.  final movement of vehicles and equipment comply with approved speed limits Final ESMP _Construction of Institutional Sanitation Facilities. Page 68 May 2017 SAL Consult Ltd GAMA - AMA No. Potential Project Activities Proposed Mitigation Measures/Actions Responsibility Cost Estimates per Environmental and project site (Gh₵) Social Impacts within the communities.  all community complaints are resolved before handing over sanitation project. 2. Waste management All decommissioning activities  Ensure that any remaining waste streams created during construction activities and Contractor/ No additional cost waste generated during decommissioning activities are collected from the project Engineering Consultant required aside sites properly disposed before handing over the project. BoQ  Inspect the site to ensure that the contractor has properly cleaned up all construction sites before final payment is made to the contractor. 3. Site Restoration All decommissioning activities  Re-vegetate areas around construction sites to restore the landscape Contractor/ No additional cost  Reinstate any damaged property such as pavements, etc. Engineering Consultant required aside BoQ Sub-Total: 9,000 (per school per year) Grand Total: 270,000 per year for AMA Final ESMP _Construction of Institutional Sanitation Facilities. Page 69 May 2017 SAL Consult Ltd GAMA - AMA 7.2 Mitigation/Action Plan for Identified Risks to the Sustainability of the Project Table 11: Mitigation /Action Plan for Identified Risks to the Sustainability of the Project No. Risk Proposed Mitigation Measures/Actions Implementation Phase Responsibility Cost Estimates per project site (Gh₵) 1. Flooding  Raise the foundation of toilet facilities to about 1 meter high, especially in  Construction Contractor/ Engineering -Already captured in flood prone areas. Consultant BoQ / If not revise  Provide adequate drainage around toilet facilities.  Construction BoQ accordingly  Provide rain cover over all windows and doors of the toilet facilities.  Construction  Beneficiary schools should ensure all broken louvre blades/or windows are  Operation -500.00 per school replaced. per year 2. Security issues  Provide burglar proof at the doors and windows of toilet facilities.  Construction Contractor/ Engineering -Already captured in  Maintain adequate security in the schools and at the sanitation facilities Consultant/ Metropolitan BoQ/ If not revise especially. Eg: through hiring a watchman. Assembly/ Authorities of BoQ accordingly  MA should consider fencing of schools in future projects to improve  Operation Beneficiary Institution -2,400.00 per security. institution per year  Sensitize wider communities not to disturb school sanitation facilities - - 3. Unavailability of  Confirm the source and reliability of the water supply prior to the  Construction Contractor/ Engineering -Already captured in water commencement of construction. Consultant BoQ/ If not revise  Ensure that storage tanks are installed for all facilities to provide continuous  Construction BoQ accordingly water supply even when GWCL lines are temporarily out of order.  Ensure connection of water and installation of water storage tanks is completed and there is regular flow of water at the toilet facilities before  Construction - commissioning/handing over of the facilities for use. 4. Poor  The Engineering Consultant to include the relevant recommendations in the  Construction Contractor/ Engineering -Already captured in maintenance ESMP in the Facilities Management Plan (FMP). Consultant/SHEP BoQ / If not revise culture  Comply with provisions in the FMP such as: Coordinators/Heads of BoQ accordingly o Replace damaged equipment/materials with durable ones during  Operational Institutions -Refer to FMP Final ESMP _Construction of Institutional Sanitation Facilities. Page 70 May 2017 SAL Consult Ltd GAMA - AMA No. Risk Proposed Mitigation Measures/Actions Implementation Phase Responsibility Cost Estimates per project site (Gh₵) maintenance and repair works. Budget o The beneficiary schools should hire cleaners for the sanitation facilities.  Operational o Develop and implement a maintenance regime for the facilities.  Operational o Report major breakdown of facilities to the Metropolitan GES Director.  Operational o Educate and create awareness on proper use of facilities.  Operational o Ensure all staff are trained in the effective use and management of the  Operational facilities, in collaboration with the Environmental Health and Sanitation Department. 5. Inadequate  School authorities and PTA to discuss funding for water supply, electricity  Operational MLGRD-PCU/ Metropolitan - funds bills and maintenance of the facilities at PTA Meetings. Assembly/ Consultant/  Capacity building of School authorities /PTA for raising, mobilization and  Operational Authorities of Beneficiary -Refer to Capacity stewardship of fund Institution Building Budget  MA level stakeholder engagements to discuss innovations in funding for  Operational - O&M.  The project should ensure that all outstanding electricity and water debts of  Operational - beneficiary institutions are paid and electricity and water connection restored to disconnected institutions.  The beneficiary institutions should ensure regular payment of electricity  Operational - and water bills to ensure continuous supply of water and electricity to the facility. 6. Lack of  Stakeholders should be invited to attend monthly progress meetings to be  Operational Consultant - awareness of the constantly informed. project  Before the project resumes, information of the proposed project including  Operational information its benefits should be explained to teachers, students and the PTA. Sub-Total: 2,900 (per institution per year) Grand Total: 87,000 per year for AMA Final ESMP _Construction of Institutional Sanitation Facilities. Page 71 May 2017 SAL Consult Ltd GAMA - AMA 7.3 Environmental And Social Monitoring Plan and Reporting 7.3.1 Environmental and Social Monitoring Plan The environmental and social monitoring plan proposed for the Institutional Sanitation Project in AMA is presented in Table 12. Table 12: Environmental and Social Monitoring Plan No. Environmental/ Monitoring Parameters Monitoring Site Frequency Responsibility Cost Estimate/ Year Social Component (Implementation/ (GH) Supervision) PREPARATORY PHASE 1. Approval for -Evidence of consultation and consent from school -Beneficiary institutions -Prior to -Contractor/ Engineering No additional cost construction and authorities (including Church Leadership of Missionary construction Consultant required aside BoQ siting of toilet Schools) facility -Complaints on siting of facilities - Daily -availability of alternative toilets for school/students during construction -Availability of toilet facilities for use by construction workers other than school toilet CONSTRUCTION PHASE 1. Soil impacts and -Observable change in turbidity of water in drains -Construction site Daily Contractor/ Engineering No additional cost sediment transport -Observable oil sheen in drains -Nearby drains Consultant required aside BoQ -Observation of rills/gullies 2. Air quality - Observation of air borne particulates (dust) and exhaust -Construction site Daily Contractor/ Engineering No additional cost deterioration fumes -Immediate environs Consultant required aside BoQ 3 - dust concentration should be below 150 µg/m -Records of dampening of construction sites and routes for vehicles/trucks 3. Vibration and noise -Complaints on noise nuisance Construction site Daily Contractor/ Engineering No additional cost Final ESMP _Construction of Institutional Sanitation Facilities. Page 72 May 2017 SAL Consult Ltd GAMA - AMA No. Environmental/ Monitoring Parameters Monitoring Site Frequency Responsibility Cost Estimate/ Year Social Component (Implementation/ (GH) Supervision) nuisance -Immediate environs Consultant required aside BoQ 4. Visual Intrusion -Hoarding in place Construction site Daily Contractor /Engineering No additional cost -Condition of areas around construction site -Immediate environs consultant required aside BoQ 5. Destruction of -Evidence of consultations with affected property owners -Construction site Daily Contractor /Engineering No additional cost property and -Record of affected service line/property and action taken -immediate environs consultant6 required aside BoQ -Complains on affected property and obstruction of obstruction of walkways walkways Reinstatement of damaged property and landscape 6. Waste -Availability and use of bins Construction site Monthly Contractor/ Engineering No additional cost Management -Records on frequency and location of waste disposal site Consultant required aside BoQ of domestic and construction waste 7. Occupational -Workers’ awareness of Contractor’s health and safety Construction site Daily Contractor/ Engineering No additional cost Health & Safety policy (The contractor health and safety policy would take Consultant required aside BoQ into consideration the World Bank EHS guidelines) -Availability and proper use of PPEs -Availability and proper use of warning signs -Availability of first aid kit -Adherence to health and safety procedures -Records on frequency, type and source of illness/accident/injury -Records on non-compliances -Absence of unauthorized persons at active construction sites 8. Public safety and Availability and proper use of warning signs Construction Site Daily Contractor/Engineering No additional cost traffic issues -Hoarding of site consultant required aside BoQ -Use of caution tape around trenches/ excavations Final ESMP _Construction of Institutional Sanitation Facilities. Page 73 May 2017 SAL Consult Ltd GAMA - AMA No. Environmental/ Monitoring Parameters Monitoring Site Frequency Responsibility Cost Estimate/ Year Social Component (Implementation/ (GH) Supervision) -Records on frequency, type and source of illness/accident/injury -Absence of unauthorized persons at active construction sites 9. Sanitation issues, -Availability and use of bins Construction site Daily Contractor/ Engineering No additional cost health and safety -Records on frequency and location of waste disposal site Consultant required aside BoQ impacts of domestic and construction waste -Mobile toilet facilities in place for use by contarctor -Presence of stagnant water in trenches 10. Public Complaints/ -Type and nature of complaints and concerns; Project community Weekly Grievance Redress Refer to Grievance Grievances Redress -Complaint records (Record of grievance and number Committee Redress Budget in resolved/unresolved) Table 14 -Management and Stakeholder Meetings OPERATIONAL PHASE 1. Nuisance from -Smell of pungent odour Beneficiary school Daily School Authorities/SHEP 1500.00 odour -Immediate environs Coordinator 2. Waste -Waste disposal records Beneficiary Institution -Daily SHEP Coordinator/ School 800.00 Management -Availability of bins Heads -Litter around waste bin -Records of inspection and dislodging of septic tanks 3. Sanitation, hygiene, -Cleaning roster -Toilet facility -Daily SHEP Coordinator/ School 500.00 health and safety -Clean environment -Waste storage and -Week Heads -Smell of pungent odour collection sheds -Availability of disinfectants -Availability of cleaning PPEs and tools/materials -Availability of functional hand wash facility -Payment of utility bills Final ESMP _Construction of Institutional Sanitation Facilities. Page 74 May 2017 SAL Consult Ltd GAMA - AMA No. Environmental/ Monitoring Parameters Monitoring Site Frequency Responsibility Cost Estimate/ Year Social Component (Implementation/ (GH) Supervision) -Records on accidents/injury 4. Complaints/ -Type and nature of complaints and concerns; Beneficiary institution -Weekly Grievance Redress 1000.00 Grievances -Complaint records (Record of grievance and number Committee resolved/unresolved) Sustainability of the institutional facilities 1. Flooding - Extent of flooding during rains Toilet facility During rains School Authorities / PTA/ 700.00 - Drains clear of silt Metropolitan Assembly - Record of state of Rain covers Monthly - Record of state of louvre blades 2. Security issues - Security measures (locks, burglar proof) functional Toilet facility Daily School Authorities/ PTA/ 1500.00 - Watchman hired Metropolitan Assembly 3. Unavailability of - Confirmation of availability of water supply from GWCL Toilet facility Prior to School Authorities/ PTA/ 1000.00 water - Storage tanks installed and all connections and commissioning of Metropolitan Assembly plumbing functional project/ - Leaks from plumbing Weekly 4. Funding - Receipts of payment of bills Beneficiary institution Monthly MLGRD-PCU/ Metropolitan 1500.00 - Programme for fund raising Assembly/ Consultant/ School Authorities /PTA - Audited accounts 5. Poor maintenance - Record of training and awareness creation on Facilities -Beneficiary institution Monthly School Authorities / SHEP 1200.00 culture Management Plan (FMP) Coordinators/ PTA/ Metropolitan Assembly - Record of compliance with FMP. - Records on major breakdowns including leakages - Availability of school hygiene clubs 6. Lack of awareness - Monthly progress carried out -Beneficiary institution Monthly SMC/ PTA/ Metropolitan - of the project - Information provided to teachers, students & PTA. SHEP Committee information DECOMMISSIONING Final ESMP _Construction of Institutional Sanitation Facilities. Page 75 May 2017 SAL Consult Ltd GAMA - AMA No. Environmental/ Monitoring Parameters Monitoring Site Frequency Responsibility Cost Estimate/ Year Social Component (Implementation/ (GH) Supervision) 1. Occupational/publi - Availability and proper use of PPEs -Beneficiary institution -Daily Contractor/WasteCare 500.00 c safety and traffic - Adherence to health and safety procedures Associates/ AMA - Records on frequency, type and source of illness/accident/injury 2. Waste disposal - Availability and use of bins -Beneficiary institution Daily Contractor/ WasteCare 500.00 - Records on frequency and location of waste disposal site Associates/ AMA of domestic and construction waste TOTAL: 11,700.00 Final ESMP _Construction of Institutional Sanitation Facilities. Page 76 May 2017 SAL Consult Ltd GAMA - AMA 7.3.2 Environmental and Social Monitoring Reporting Environmental monitoring is an essential component to ensure the successful implementation of the ESMP. A report on the monitoring programme will provide the contractor and AMA with relevant data and information to better understand the extent of implementation of the ESMP. All monthly and progress reports should capture health, safety and environment issues arising from the implementation of the ESMP. A template for reporting on the implementation of the ESMP is provided in Annex 3. The format requires the implementing body to specify evidence of completion for each mitigation measure (e.g. a document that proves the completion of the measure or a short description of the expected achievement or pictures). If implementation is ongoing, the status of implementation should be described. The monitoring report concludes by summarising the main findings and by indicating the overall status of ESMP implementation using a three-point ranking scale: on track (green), slightly delayed (yellow) or delayed (red). Opportunity is provided for indicating any additional environmental or social risks that may have emerged since the project start and the appropriate mitigation measures taken or planned for any significant new risk. 7.4 Grievance Redress Process 7.4.1 Background A grievance is any query, call for clarification, problems and concerns raised by individuals or groups related to activities undertaken or processes applied by the project. Grievances can be an indication of growing stakeholder concerns and can escalate if not identified and resolved. A Grievance Redress Mechanism (GRM) is a system by which queries or clarifications about a project are responded to, problems that arise out of implementation are resolved and grievances are addressed efficiently and effectively. An effective and efficient GRM should have multiple avenues or channels for lodging complaints, transparency, promptness and timeliness of responses and clear procedures. During the planning of the planning stages of the projects in each school, the school authorities, PTA and the SHEP Coordinators were consulted by the AMA Management, AMA GAMA Project Team and the Engineering Consultant for AMA (WasteCare Associates). The consultation helped to identify the plot boundaries of the institutions, the appropriate toilet types for the institutions and the location of toilets. Since the entire project implementation programme was carried out with consultation and participation of the beneficiary institutions and AMA, many grievances are not anticipated to arise from the project implementation and any unforeseen grievances may be resolved amicably and easily. Nevertheless, appropriate channels have been provided for expression and resolution of grievances during the implementation and operation of the project. 7.4.2 Objectives of the Grievance Redress Mechanism The objectives of the grievance redress mechanism are as follows: 1. To provide affected people and institutions with channels to lodge complaints or resolve any disputes that may crop up during project implementation; Final ESMP _Construction of Institutional Sanitation Facilities. Page 77 May 2017 SAL Consult Ltd GAMA - AMA 2. Provide a mechanism for stakeholder concerns to be addressed in a mutually acceptable and timely manner, and by the most appropriate officers; 3. Identify and monitor stakeholder concerns to support effective stakeholder and risk management; 4. Enhance the reputation of the project implementers as transparent and environmentally and socially responsible; and, 5. Meet requirements of international best practice. 7.4.3 Grievance Redress Process The grievance redress process has been discussed below under the construction and operational phases of the proposed project. Any grievance received from affected stakeholders shall be treated confidentially and resolved in a transparent and fair manner. Construction Phase Grievance Redress Grievance registration The School based Health Coordinator/SHEP Coordinator of each beneficiary school will be officially responsible for receiving grievances which may be channeled to them directly through face-to-face communication, phone calls, letters, e-mail, text messages, etc. Complaints received shall be forwarded to the grievance redress committee. The members of the committee shall be the Head Teacher, the School Management Committee and the SHEP Coordinator, who will be secretary to the grievance redress committee. All grievances, presented in writing or verbally, will be logged by the Head Teacher by filling a grievance redress form. The SHEP Coordinator will ensure that each complaint has an individual reference number, and is appropriately tracked and recorded actions are completed. A sample of a Grievance Mechanism Form is included in Annex 4. Grievances may also be channeled to the GAMA Project Coordinator at AMA. The SHEP Coordinator shall have a log book for keeping records of all grievances received and copies of the records kept with all the relevant authorities. A review of grievances will be conducted at least every three months during implementation in order to detect and correct systemic problems. The log book should take into account the following: date the complaint was reported; date on which the grievance form was submitted to the grievance committee, date information on proposed corrective action sent to complainant (if appropriate); the date the complaint was closed out and date response was sent to complainant. Redress decision, feedback and implementation The redress committee will make a decision on all matters received, in consultation with the complainant, if necessary, in not more than two working days. The agreed redress action should be implemented within an agreed timeframe of not more than five days, depending on the nature of the complaint. If field verification is required, the redress committee, in company with the complainant, will visit the complaint area to verify satisfactory redress action is carried out. When the complainant is Final ESMP _Construction of Institutional Sanitation Facilities. Page 78 May 2017 SAL Consult Ltd GAMA - AMA satisfied with the redress action, the complaint will be closed and logged in the grievance log book and endorsed by the complainant. Dissatisfaction and alternative action 1. If no understanding or amicable solution is reached, or the affected person does not receive a response from the redress committee within 5 working days, the affected person can appeal to the GAMA Project Coordinator, who shall seek to resolve the issue in collaboration with the Project’s Engineering Consultant and the AMA Works Engineer. It is expected that the complaint/grievance will be resolved within 5 working days of its filing. 2. If the grievance remains unresolved, the affected person can appeal to the Safeguards Specialist at the PCU, who in consultation with the GAMA Project Director at the MLGRD, GAMA Project Coordinator at the PCU and the Chief Director will mediate on the issue within five working days. 3. If a resolution is not reached from the first three steps, the complainant may seek legal action for redress. However, noting that court cases can be cumbersome and time consuming, it is of high opinion that Court cases should be the last ‘resort’ and all effort must be made to reach amicable settlement at the very early stages of complaints by affected persons. Monitoring and Evaluation Monitoring and evaluation activities will be conducted by the PCU to ensure complaint and grievances lodged by the affected persons are followed-up and amicably resolved. The grievance redress process for the construction phase is illustrated in Figure 5. Final ESMP _Construction of Institutional Sanitation Facilities. Page 79 May 2017 SAL Consult Ltd GAMA - AMA TIER 1 Grievance received and screened by SHEP Coordinator Redress Committee of meet and take decision 2 wkn TIER 2 days Complainant not Feedback to satisfied (Grievance complainant unresolved Complainant satisfied Grievance sent to GAMA with decision Project Coordinator, Project’s (Grievance resolved) Engineering Consultant and AMA Works Engineer 5 wkn days TIER 3 Decision taken through discussion Complainant not with beneficiary satisfied (Grievance institution and unresolved Complainant Complainant Grievance sent to Safeguard satisfied (Grievance Specialist PCU, the GAMA resolved) Project Director at the MLGRD, GAMA Project Coordinator at the PCU and the Chief Director 5 wkn days TIER 4 Decision taken Complainant not through discussion satisfied (Grievance with all parties unresolved Complainant Complainant takes satisfied (Grievance legal action resolved) Law Court Rules Figure 5: Grievance Redress Process for the Constructional Phase Institutional Sanitation Facilities Project Final ESMP _Construction of Institutional Sanitation Facilities. Page 80 May 2017 SAL Consult Ltd GAMA - AMA Operational Phase Grievance Redress The School based Health Coordinator/SHEP Coordinator of each beneficiary school will be officially responsible for receiving grievances which may be channeled to them directly through face-to-face communication, phone calls, letters, e-mail, text messages, etc. Complaints received shall be forwarded to the School Management Committee (SMC) for redress. All grievances, presented in writing or verbally, will be logged by the SHEP Coordinator by filling a grievance redress form. The SHEP Coordinator will ensure that each complaint has an individual reference number, and is appropriately tracked and recorded actions are completed. A sample of a grievance mechanism form is included in Annex 4. The SHEP Coordinator shall have a log book for keeping records of all grievances received and copies of the records kept with all the relevant authorities. A review of grievances will be conducted at least every three months during implementation in order to detect and correct systemic problems. The log book should take into account the following: date the complaint was reported; date on which the grievance form was submitted to the grievance committee, date information on proposed corrective action sent to complainant (if appropriate); the date the complaint was closed out and date response was sent to complainant. Redress decision, feedback and implementation The SMC will make a decision on all matters received, in consultation with the complainant, if necessary, in not more than two working days. The agreed redress action should be implemented within an agreed timeframe of not more than five days, depending on the nature of the complaint. If field verification is required, the redress committee, in company with the complainant, will visit the complaint area to verify satisfactory redress action is carried out. When the complainant is satisfied with the redress action, the complaint will be closed and logged in the grievance log book and endorsed by the complainant. Dissatisfaction and alternative action 1. If no understanding or amicable solution is reached, or the affected person does not receive a response from the redress committee within 5 working days, the affected person may appeal to the Metropolitan SHEP Committee, through the Metropolitan SHEP Coordinator, who should act on the complaint/grievance within 5 working days of its filing. Grievances from the school stakeholders, where necessary, will be resolved in collaboration with the beneficiary institution and the complainant. Grievances involving the community members will be resolved in consultation with the community leadership and complainant, as necessary. 2. If the grievance remains unresolved, the affected person can appeal to the Regional SHEP Coordinator at the Ministry of Education who, in consultation with the Metropolitan SHEP Committee will mediate on the issue. 3. If a resolution is not reached from the first three steps, the complainant may seek legal action for redress. However, noting that court cases can be cumbersome and time consuming, it is of high opinion that Court cases should be the last ‘resort’ and all effort must be made to reach amicable settlement at the very early stages of complaints by affected persons Monitoring and Evaluation Monitoring and evaluation activities will be conducted by the PCU to ensure complaint and grievances lodged by the affected persons are followed-up and amicably resolved. The grievance redress process for the operational phase is illustrated in Figure 6. Final ESMP _Construction of Institutional Sanitation Facilities. Page 81 May 2017 SAL Consult Ltd GAMA - AMA TIER 1 Grievance received and screened by SHEP Coordinator School Management Committee meet and take decision TIER 2 2 wkn days Complainant not Feedback to satisfied (Grievance complainant unresolved Complainant satisfied Grievance sent to Metropolitan with decision Assembly/GES (Metropolitan (Grievance resolved) Committee/ Municipal SHEP Coordinator to receive) 5 wkn days TIER 3 Decision taken through discussion with Complainant not beneficiary institution/ satisfied (Grievance community leadership unresolved and Complainant Complainant Grievance sent to satisfied (Grievance Regional SHEP resolved) Coordinator at GES - TIER 4 Decision taken Complainant not through discussion satisfied (Grievance with all parties unresolved Complainant Complainant takes satisfied (Grievance legal action resolved) Law Court Rules Figure 6: Grievance Redress Process for Operational Phase for the Institutional Sanitation Facilities Project Final ESMP _Construction of Institutional Sanitation Facilities. Page 82 May 2017 SAL Consult Ltd GAMA - AMA 7.5 Capacity Building and other Requirements for Implementation of ESMP and Permit Conditions Training Workshop will be organized to guide the implementation of the ESMP, Permit Schedule, Triggered World Bank Safeguards Policy and environmental management. The training on the ESMP implementations will include the Code of Conduct for contractor and his/her labour force, public health and safety issues, Grievance Redress Mechanism for the project, ESMP monitoring and reporting. 7.5.1 Objectives of the training The main objective of the capacity building and training activities is to create, enhance and develop the necessary skills and abilities for successful implementation of the proposed project. 7.5.2 Methodology for the training The methodology to implement the training will include:  Workshops and site meetings;  Sensitization for students during School Assembly, Morning Devotion or in the classrooms;  Sensitization at PTA meetings. It is recommended that the site meetings discuss the ESMP issues and any health and safety issues identified in the course of the month. Non-compliances identified during monitoring should reviewed and corrective actions taken. A capacity building measure proposed to achieve this is provided in Table 13. Table 13: Capacity building plan for implementation of ESMP and Permit Conditions No. Activity Target Timeline/Duration Proposed Facilitator Estimated Group/Participants Cost/(Gh₵) 1. Training Engineering Prior to Consultant/Metropolitan 15,000.00 Workshop on Consultant resumption/ Assembly/ Safeguards ESMP, Permit -Resident Engineer commencement of Specialist/ Consultant Schedule, -Clerk of Works construction works Triggered World -Safeguards Officer Bank Safeguards Policy Contractor -Manager -Foreman -Engineer AMA -Project Coordinator Metro Engineer -Metro Environmental Health Officer Metro SHEP Coordinator Final ESMP _Construction of Institutional Sanitation Facilities. Page 83 May 2017 SAL Consult Ltd GAMA - AMA No. Activity Target Timeline/Duration Proposed Facilitator Estimated Group/Participants Cost/(Gh₵) 2. Induction on All construction workers Prior to Consultant/Lead 10,000.00 occupational and commencement of Contractor/ Engineering public health and construction works Consultant safety requirements of the works and environmental management 3. Training for use and -SHEP Coordinators Prior to -Engineering Consultant 10,000.00 management of -Teachers commissioning and -GAMA Coordinator facilities -SMC handing over of -Metropolitan SHEP -School Health Club facilities to schools Committee & Coordinator -school children 4. Sensitization and -Students Throughout -SHEP Coordinators As part of awareness creation operation of facilities -School Health Club duties of on use and SHEP management of Coordinators, facilities (interactive School and activity, teaching, School Health demonstrative Club. activity for building habits & knowledge testing during classes, worship time and assembly) 35,000.00 TOTAL COST 7.5.1 Output of the training Capacity building on the health, safety, environmental and social management measures provided in this chapter is required to ensure the effective implementation of the ESMP and the permit conditions. All monthly and progress reports should capture health, safety and environment capacity building activities carried out. 7.6 Estimated Budget for ESMP Implementation. It is estimated that an amount of Four Hundred and Eight Thousand, Seven Hundred Ghana Cedis (GH¢408,700.00) will be required to implement the provisions of the ESMP for all the beneficiary institutions in AMA as shown in Table 14. This figure is subject to review following confirmation from cost studies to be carried out after project development phase. Final ESMP _Construction of Institutional Sanitation Facilities. Page 84 May 2017 SAL Consult Ltd GAMA - AMA The budget for the monitoring activities by the MLGRD-PCU are not captured in the monitoring costs presented in the Environmental and Social Monitoring Plan and reporting. This is because, the monitoring roles of the PCU is already included in the GAMA Project cost. Table 14: ESMP Budget. No. Programme Cost/year (GH) 1. Mitigation Action for Identified Impacts (Table 10): Operation phase only {GH¢ 9000 270,000.00 per institution/yr} there are 30 schools. 2. Mitigation Action for Identified Risks To The Sustainability of the Project (Table 11) 87,000.00 3. Environmental And Social Monitoring Plan (Table 12) 11,700.00 4. Grievance Redress 5,000.00 5. Capacity Building (Table 13) 35,000.00 Total 408,700.00 Final ESMP _Construction of Institutional Sanitation Facilities. Page 85 May 2017 SAL Consult Ltd GAMA - AMA 8.0 CONCLUSION AMA and the Project Coordinating Unit of MLGRD are committed to ensuring sustainable environmental management and safeguarding the health and safety of the construction workers, pupils/teachers at the beneficiary schools and the public during the implementation of the proposed project. AMA is also aware of the provisions in the Environmental Assessment Regulations 1999, LI 1652 and the World Bank Operational Policies. In keeping with these laws, this ESMP has identified and assessed key environmental and social impacts and concerns that may arise from the implementation of the proposed project. Consultations with stakeholders, review of relevant literature, field inspections and studies underpinned the identification of the project adverse environmental and social impacts. A monitoring programme to help detect changes arising from the predicted adverse impacts has also been presented in this ESMP. The recommendations outlined in the ESMP for the project will ensure a high level of health, safety and environmental management for the proposed project. It is estimated that an amount of Four Hundred and Eight Thousand, Seven Hundred Ghana Cedis (GH¢408,700.00) will be required to implement the provisions of the ESMP for all the beneficiary institutions in AMA as shown in Table 14. This figure is subject to review following confirmation from cost studies to be carried out after project development phase. The budget for the monitoring activities by the MLGRD-PCU are not captured in the monitoring costs presented in the Environmental and Social Monitoring Plan and reporting. This is because, the monitoring roles of the PCU is already included in the GAMA Project cost. The proposed project has the potential to provide numerous benefits to the beneficiary schools and the national economy. These include improved sanitation, hygiene and waste management in the beneficiary schools, improved access to sanitation facilities for vulnerable groups and employment opportunities. Final ESMP _Construction of Institutional Sanitation Facilities. Page 86 May 2017 SAL Consult Ltd GAMA - AMA 9.0 BIBLIOGRAPHY Ghana Statistical Service (2014) 2010 National Population & Housing Census. District Analytical Report. Accra Metropolis. WasteCare Associates (2016a). Situational Analysis and WASH in Schools. Accra Metropolitan Assembly. WasteCare Associates (2016). Facility Operation and Maintenance Handbook. Accra Metropolitan Assembly. WasteCare Associates (2016). Final Detailed Design Report. Accra Metropolitan Assembly. WasteCare Associates (2016). Hygiene Education Plan. Accra Metropolitan Assembly. Final ESMP _Construction of Institutional Sanitation Facilities. Page 87 May 2017 SAL Consult Ltd GAMA - AMA ANNEXES Annex 1 Stakeholder Consultations Annex 2 Code of Conduct Annex 3 Template for reporting on the implementation of the ESMP Annex 4 Grievance Form Annex 5 Letter from AMA instructing the removal of furnace/incinerator Final ESMP _Construction of Institutional Sanitation Facilities. Page 88 May 2017 SAL Consult Ltd GAMA - AMA ANNEX 1 STAKEHOLDER CONSULTATIONS Final ESMP _Construction of Institutional Sanitation Facilities. Page 89 May 2017 SAL Consult Ltd GAMA - AMA ANNEX 2 CODE OF CONDUCT Final ESMP _Construction of Institutional Sanitation Facilities. Page 90 May 2017 SAL Consult Ltd GAMA - AMA ANNEX 3 TEMPLATE FOR REPORTING ON THE IMPLEMENTATION OF THE ESMP Final ESMP _Construction of Institutional Sanitation Facilities. Page 91 May 2017 SAL Consult Ltd GAMA - AMA ANNEX 4 GRIEVANCE FORM Final ESMP _Construction of Institutional Sanitation Facilities. Page 92 May 2017