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| Max PPP - (Project # 29407) |
| Environmental and Social Review Summary dated the 19th May 2010 |
The review of this project consisted of appraising technical, environmental and social information submitted by the sponsor including a review of: the social and environmental management system, manuals and practices at a corporate level and at the individual hospital level, as understood through IFC's appraisal of earlier investments in MHIL. In addition, IFC supervision and annual monitoring reports from previous MHIL investments were reviewed.
Further, the appraisal included visits to the construction site of the Mohali hospital and discussions with MHIL senior management. |
| Project Description: |
| The proposed project ("Max PPP" or the "Project") encompasses the establishment of two hospitals by Max Healthcare Institute Limited ("MHIL" or the "Company") in Mohali and Bathinda. MHIL currently operates eight hospitals (including 2 medcentres) primarily in the North Capital Region, which includes New Delhi and its approximate surroundings, with a total of 1090 beds. After a bidding process, the State Government of Punjab (SGOP), India, has awarded 50-year concessions to MHIL to build and operate two greenfield hospitals. Each hospital will initially have 200 beds and focus on oncology, with additional specialization of trauma care at Mohali and cardiac care at Bathinda. The construction and operation of the hospitals will be through wholly-owned subsidiaries of MHIL. |
| Identified Applicable Performance Standards: |
| While all Performance Standards (PSs) are applicable to this investment, IFC's environmental and social due diligence indicates that the investment will have impacts which must be managed in a manner consistent with the following Performance Standards: |
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PS1 - Social and Environmental Assessment and Management System; |
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PS2 - Labor and Working Conditions; |
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PS3 - Pollution Prevention and Abatement; |
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PS4 - Community Health, Safety and Security; |
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PS5: Land Acquisition and Involuntary Resettlement is not applicable because the land required for the Project was obtained on lease by way of a 50 year concession agreement from the SGOP The lands for the two proposed hospitals are located adjacent to existing government hospitals and have been designated for hospital use. Furthermore MHIL has adopted a land screening procedure to ensure that no involuntary resettlement has occurred at either site. The lands are situated in suburban residential areas and, as such, no impact on biodiversity, indigenous people and cultural heritage is expected. |
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PS6: Biodiversity Conservation and Sustainable Natural Resource Management; |
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PS7: Indigenous Peoples; and |
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PS8: Cultural Heritage are therefore not applicable to this investment. |
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| E&S Categorization and Rationale: |
An existing IFC client since 2003, MHIL has demonstrated compliance with IFC's PSs, and relevant environmental, health and safety (EHS) guidelines, and continued improvement in its environmental and social performance.
This specific project has been categorized as Category B according to IFC's Environmental and Social Review Procedures. Key environmental, social, health and safety impacts associated with the Project during construction and operation include: environmental, health, safety, and social management - including air emissions control, potable water supply and treatment, waste water management, health care waste management, including non hazardous and hazardous medical waste both liquid and solid; labor and working conditions, employee and contractor occupational health and safety, including training and housekeeping; disinfection, sterilization, hygiene and implementation of good hospital management practices required to prevent infections among patients and employees; community health, safety and security during construction and operational phase - including radiation hazards, traffic management, and security services; and life and fire safety, including emergency response.
The project may result in a limited number of specific environmental and social impacts that can be avoided or mitigated by adhering to generally recognized performance standards, guidelines or design criteria. MHIL will manage its environmental and social performance in accordance with applicable local laws and regulations and international standards, including IFC's Performance Standards on Social and Environmental Sustainability, IFC's Environmental, Health and Safety General Guidelines and Guidelines for Health Care Facilities. |
| Description of key Environmental and Social Issues and Mitigation: |
| The sponsor has presented plans to address these impacts to ensure that the proposed project will, upon implementation of the specific agreed measures, comply with host country laws and regulations, IFC's social and environmental Performance Standards, and relevant EHS guidelines. The information about how these potential impacts will be addressed by the sponsor/project is summarized in the paragraphs that follow. |
| PS1: Social and Environmental Assessment and Management Systems: |
| Social and Environmental Assessment: |
| MHC has taken the required Environment Clearance and has obtained Consent to Establish from the local statutory authorities, in addition it has also obtained registration under the labor act. The Building Plans have been approved by the Design and Approval Committee, a committee set up by the SGOP to monitor and oversee the implementation plan for the hospitals. These approved plans have also been lodged with local government authorities for final approval. For clearances already received, MHIL will provide IFC with copies prior to disbursement. For clearances not yet received, the Company will provide IFC with copies as and when they become available. |
| Management Program and Organization: |
The company has established detailed environmental and occupational health and safety practices and standard operating procedures (SOPs) that conform to international best practices for the hospital sector. These systems have been implemented in each of the MHIL hospitals, five of which have been accredited under ISO 9001:2000, and two of which have ISO 14001:2004, ISO 15189 (laboratory quality and competence), and the National Accreditation Board for Hospitals accreditation. The Environmental, Social, Health and Safety (ESHS) issues are managed by the Heads of Hospitals, who report directly to the Regional Heads, who in turn report to the CEO. The Regional Heads are a part of MHIL's senior management group, to ensure that continuous improvement and instances of non-compliance are addressed immediately.
The MHIL environmental and occupational health and safety practices and SOPs will be rolled out in the Bathinda and Mohali hospitals and it is expected that they will receive ISO accreditation within the first full year of operations. |
| Community Engagement: |
MHIL's relationship with the local community is managed both by the individual hospitals and through Max India Foundation.
MHIL has a "healthy neighbor programme" which has tie-ups with the local Residents Welfare Associations (RWAs) and provides free health education and outpatient consultations in the form of health check up camps. |
| PS2: Labor and Working Conditions: |
MHIL expects to employ up to approximately 1,100 staff at the Mohali hospital, of which around 230 will be contract staff; and up to 780 staff at the Bathinda hospital, of which around 120 will be contract staff. All will be employed by MHIL with the exception of catering, security, housekeeping and engineering staff.
Working Conditions and Management of Workers Relationship
As concluded in the environment and social review of IFC's earlier investments, MHIL has in place a Human Resources policy and procedures that are consistent both with the relevant Government of India (GoI) statutes and regulations and international best practices for the sector. For previous investments, MHIL reviewed IFC PS2 and confirmed that its policies and procedures conform fully with all PS2 requirements and to the International Labour Organisation (ILO) core labor standards.
The HR policy and procedures are available for all staff to view on the company intranet and access is provided via PC and kiosks in each hospital. Every member of staff has a login id and password, giving them secure access to their pay slips, leave, reward and recognition initiatives and company announcements.
MHIL has a well developed employee grievance redressal system which is accessible through the intranet. There is an "Ask CEO" initiative which invites employees to write to the CEO and quarterly town halls are held for each unit involving the CEO and senior management. |
| Occupational Health and Safety: |
| Construction of both the hospitals at Bathinda and Mohali is underway and is closely managed by the MHIL Projects Department. MHIL has contracted a Project Management Company at each site to manage the contractors during construction. MHIL has a site safety manual and emergency plan. On each site, there is a Safety Committee with representatives of all contractors and all construction teams are fully educated through safety site toolbox talks and participate in regular drills. Appropriate health and safety clauses have been included in all contracts and MHIL and its construction contractors have confirmed that, to date, there has not been any major/fatal accident on site. |
| PS3: Pollution prevention and abatement: |
MHIL is committed to ensuring its compliance with both local and regulatory requirements and IFC guidelines for air quality, waste water discharges, hazardous waste, ambient noise and workplace conditions. MHIL has acquired all necessary regulatory permits and authorizations to commence construction and will continue to ensure all permits are obtained throughout the operation of the hospitals.
MHIL has adopted a comprehensive program to conserve energy at all of its facilities and monitors power, water, paper and waste carefully. Both the Bathinda and Mohali hospitals will utilize grid power supplemented by diesel generators and UPS for back up. In order to minimize energy consumption for air conditioning, an energy efficient screw compressor will be used; temperatures will be increased in operating theaters when not in use; and in the Bathinda hospital, the wards will be maintained around 4°C higher than the private rooms. At both hospitals, 20 % of water heating requirements will be met by solar power.
The hospitals in Bathinda and Mohali will use a mixture of water from the municipal water supply system and from a borewell. All potable water will be treated by on-site reverse osmosis (RO) plants.
Waste water at each hospital will be segregated. Infectious effluent from the operating theatres, blood bank, laboratory, etc will first receive chemical pre-treatment in the effluent treatment plant before being further treated, together with non-infectious effluent from the hospital, in a sewage treatment plant (STP). The STP will provide primary, secondary and tertiary treatment and all treated waste water will be reused in the toilets, garden and cooling tower.
Both hospitals will follow MHIL's SOPs for the segregation, storage and disposal of solid and hazardous waste. These SOPs conform to IFC guidelines, Indian regulations, and industry good practices. At each site, waste will be segregated by category and stored temporarily as per internationally and local accepted procedures. Biomedical waste will be removed by authorized vendors in both Bathinda and Mohali. Domestic and biodegradable waste will be disposed according to municipal regulations.
MHIL has in place a detailed Infection Control Policy and Procedures Manual that is periodically reviewed by an Infection Control Committee (ICC) made up of the members of various medical departments and including nursing, housekeeping, operating room and laboratories, The ICC's role is to serve as both a monitor and a resource in maintaining control standards for nosocomial (hospital-acquired) infection in order to minimize risk to both staff and patients. |
| PS4: Community health, safety and security: |
| Life and Fire Safety: |
| MHIL has provided information on the fire and life safety provisions it makes in each of its hospitals, including the hospitals at Bathinda and Mohali. These include a fire detection system, fire fighting system and emergency communication system. The fire fighting system includes automatic sprinklers and gas flooding system and manually operated hoses, hydrants and extinguishers. The infrastructure of both hospitals has been designed in accordance with national building codes as well as local standards , Both facilities will include fire retardant wiring and doors and each room has its own circuit breaker. The hospital plans will be cleared by the fire officer in the Bathinda and Mohali authorities prior to start up of operations. MHIL will commission an independent assessment of its architectural designs against IFC's Life and Fire Safety requirements, and submit to the IFC a certification from competent third party professional. The suitably qualified professional will also conduct a review at the time of life and fire safety systems testing and commissioning to certify that construction of the systems has been carried out in accordance with the accepted design. |
| Emergency preparedness and response: |
MHIL has in place detailed SOPs for a number of possible disaster situations, such as civil disturbances, earthquakes, flooding, bomb threats and external disasters. The Company has formed Emergency Response Teams (ERTs) in every facility, which act as first responders in the event of any security or disaster situation. As part of its ESHS management system, MHIL also has SOPs for medical related emergencies, including policies and procedures to prevent community exposure to disease, pathogens and other bio-hazards during normal and emergency scenarios. These SOPs will be extended to the new hospitals at Bathinda and Mohali.
MHIL contracts security staff from reputed and recognized security agencies. The security staff will not carry fire arms and will receive training in customer care and public relations.
MHIL has a tested local community grievance mechanism. The company has a designated 'May I Help You?' desk in each of its existing hospitals. Staffs at these desks are responsible for receiving and responding to questions, concerns and grievances raised by the nearby communities or other stakeholders, and each hospital is required to keep a register of such inquiries. Contact details are posted at the hospital entrance.
At construction sites, MHIL has signage with details of the onsite emergency plan and reporting system as well as contact details of senior management who are able to respond to the concerns of any stakeholders. There is also an onsite mechanism to record grievances of the local community on issues related to construction. The Head of Projects is responsible for reviewing and acting on any complaints.
On the basis of the above information and through the implementation of the Environmental and Social Action Plan, it is expected that the Project will be operated in compliance with IFC's PS, relevant environmental, health and safety guidelines, and host country requirements. |
| Client's Community Engagement: |
| Max India Foundation was launched in January 2008. It is funded by 0.2% of profits from the Max Group together with contributions and donations from satisfied customers. The programme involves employees on a voluntary basis on a number of activities: blood donation camps, in which MHIL employees donate blood; palliative care for cancer victims; prosthetics and polio calipers; health day care centres for treatment of the underprivileged; health awareness activities, including films and health camps; surgeries for the underprivileged; and immunization. The drugs, vaccines and prosthetics and polio calipers are provided by Max Foundation free of cost. |
| Local Access of Project Documentation |
Company will disclose this ESRS and the ESAP at its website: http://www.maxhealthcare.in/ppp/,
as well as locally at the following address:
Max Healthcare Institute Limited
Max House
1 Dr Jha Marg
Okhla New Delhi 110 020
All inquiries and comments may be directed to:
Mr SL Narayanan
Chief Financial Officer
Max Healthcare Institute Limited
Max House
1 Dr Jha Marg
Okhla New Delhi 110 020
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