Environmental & Social Audit Report · 2019. 7. 8. · East African Public Health Laboratory Networking Project (EAPHLNP) Wajir Regional Referral Laboratory – Environmental & Social

East African Public Health Laboratory Networking Project (EAPHLNP)

Wajir Regional Referral Laboratory – Environmental & Social Audit Report. Page 1 of 63

Environmental & Social Audit Report

Bonventure Naphtali Okanga P.O. BOX 53317 – 00200

Tel No. +254 723 494820

NEMA Reg. No. 5067

December 2018

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DOCUMENT AUTHENTICATION

This report has been prepared by a registered and licensed EIA/EA Expert.

I, the undersigned, certify that the particulars in this report are correct and righteous to the

best of my knowledge.

NEMA EIA/EA EXPERT:

Mr. Bonventure Naphtali Okanga. EIA/EA Expert (Reg. No. 5067)

Signature………………………………………………………………………..

Date……………………………………………………………………………..

NATIONAL PUBLIC HEALTH LABORATORY SERVICES (NPHLS) REPRESENTATIVE

Name……………………………………………………………………………..

Designation……..………………………………………………………………..

Signature………………………………………………………………………....

Date……..………………………………………………………………………..



ACRONYMS AND ABBREVIATIONS

DOSH Directorate of Occupational Safety and Health

EA Environmental Assessment

EIA Environmental Impact Assessment

EAC East African Community

EAPHLN East Africa Public Health Laboratory Network Project

ESMF Environmental and Social Management Framework

ESMP Environmental and Social Management Plan

EMMP Environmental Monitoring & Mitigation Plan

HAIs Healthcare Associated Infections

HCWH Healthcare Waste Handler

HCWMP Healthcare Waste Management Plan

IPP Indigenous Peoples Plan

IPPF Indigenous Peoples Planning Framework

LIMS Laboratory Information Management System

POPs Persistent Organic Pollutants

NEMA National Environment Management Authority

NGO Non Governmental Organizations

OP Operational Policy

SPIU Single Project Implementation Unit

WHD Wajir District Hospital

WHO World Health Organization

WRRL Wajir Regional Referral Laboratory



TABLE OF CONTENTS

DOCUMENT AUTHENTICATION ...................................... 2

EXECUTIVE SUMMARY.............................................. 6

CHAPTER ONE: INTRODUCTION AND BACKGROUND....................... 8 1.1. Introduction ............................................ 8 1.2 Project description and design ........................... 8 1.2.1 Introduction ......................................... 8

1.2.2 The Project Design ................................... 9 1.2 Objective of the Consultancy ............................ 10 1.3 Project Justification ................................... 10

1.4. Scope of the ESA and Specific Tasks for the Consultancy 11 1.5 Methodology and Approach ................................ 11

CHAPTER TWO: ENVIRONMENTAL AND SOCIAL BASELINE INFORMATION.... 13 2.0 Introduction ............................................ 13

2.1 The Project site ........................................ 13 2.1.1 The laboratory Infrastructure ....................... 13 2.1.2 Water and Power Supply .............................. 13

2.1.3 Laboratory Safety and Sanitation .................... 14 2.1.4 Waste Management .................................... 14

2.2 Wajir County profile .................................... 15 2.2.1 Administrative ...................................... 15

2.2.2 Topography .......................................... 16 2.2.3 Climate ............................................. 16

CHAPTER THREE: POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK..... 17 3.0 Introduction ............................................ 17

3.1 Kenya Constitution 2010 ................................. 17 3.2 Environment Management and Coordination (Amendment) Act,

2015 ........................................................ 18

3.2.1 The EMCA (Waste Management) Regulations 2006 ........ 19 3.2.2 The EMCA (Water Quality) Regulations 2006 ........... 20 3.2.3 The EMCA (Air Quality) Regulations 2014 ............. 21

3.3 Radiation Protection Act, Cap 243 ....................... 22

3.4 Public Health Act Cap. 242 .............................. 22 3.5 Occupational Safety and Health Act, 2007 ................ 22 3.6 Guidelines, Plans and Policy framework ................. 22

3.6.1 Sessional Paper No. 6 of 1999 on Environment and

Development ............................................... 22 3.6.2 The National Environmental policy of 2012 ........... 23 3.6.3 World Bank Safeguards and Disclosure Policies ....... 23

3.6.4 The Kenya Health Policy 2012 to 2030 ................ 24 3.6.5 Injection Safety and Medical Waste Management Policy

2007 ...................................................... 24

3.6.6 National IPC Policy ................................. 25 3.6.7 Health Care Waste Management Strategic Plan 2015-2020 25



3.6.8 National Infection Prevention and Control Guidelines

for Health Care Services in Kenya, 2010 ................... 26

3.6.9 Kenya National Guidelines on Safe Disposal of

Pharmaceutical Waste ...................................... 26 3.7 International Agreements ................................ 26

CHAPTER FOUR: PUBLIC PARTICIPATION & CONSULTATIONS............ 27

4.0 Introduction ............................................ 27 4.1 Methodology ............................................. 27 4.2 Findings ................................................ 28

CHAPTER FIVE: AUDIT FINDINGS.................................. 30 5.0 Introduction ............................................ 30 5.1 Legal and regulatory review ............................. 30 5.1.1 Findings ............................................ 30

5.1.2 Actions required .................................... 30 5.2 Construction phase review ............................... 31 5.2.1 Findings ............................................ 31

5.2.2 Gaps identified ..................................... 31 5.2.3 Conclusion .......................................... 32

5.3 Operation and Maintenance Phase Review .................. 32 5.3.1 Findings ............................................ 32

5.3.2 Gaps identified ..................................... 34 5.3.3 Conclusion and Actions required ..................... 39

CHAPTER SIX: CONCLUSION AND RECOMMENDATIONS................... 43

CHAPTER SEVEN: REFERENCES..................................... 46

CHAPTER EIGHT: APPENDICES..................................... 47 APPENDIX 1: HCWM ASSESSMENT SURVEY TOOL. .................... 47 APPENDIX 2: QUESTIONNAIRE FOR STAKEHOLDER CONSULTATIONS ..... 50

APPENDIX 3: OPERATIONAL PHASE ESMP .......................... 51 APPENDIX 4: MINUTES TO THE STAKEHOLDERS MEETING ............. 54 APPENDIX 5: STAKEHOLDERS MEETING PARTICIPANTS ............... 58 APPENDIX 6: CONSTRUCTION PHASE ESMP. ........................ 59

APPENDIX 7: CONSULTANTS 2017 PRACTICING LICENSE. ............ 63

LIST OF FIGURES

Figure 1: showing the ‘local incinerator’ 35

Figure 2: Showing the open pit burning site................... 35

Figure 3: Showing the malfunctioned incinerator (green roof) &

the new modern incinerator under construction................. 36

Figure 4: Showing animals scavenging waste at the burning site

taking note of the neighboring staff quarters and the large

quantities of plastics........................................ 37

Figure 5: Showing scattered broken sharps at the ‘local

incinerator’.................................................. 39



EXECUTIVE SUMMARY

The WRRL, constructed and operationalized in 2015 is one of the five beneficiary satellite

laboratories in Kenya under the EAPHLNP funding from the International Development

Agency/the World Bank through the Ministry of Health.

The EAPHLN Project in Kenya included the rehabilitation/construction and equipping of 5

satellite laboratories (Nairobi, Machakos, Kitale, Busia and Wajir) as well as national

reference laboratories. An Environmental Management Plan for Wajir was prepared and

approved by NEMA in June 2012 and the construction completed in 2014.

The development objective of the regional project was to establish a network of efficient,

high quality, accessible public health laboratories for the diagnosis and surveillance of

communicable and non-communicable diseases in the five East African Community (EAC)

member states (Burundi, Kenya, Rwanda, Tanzania and Uganda).

This environmental and social audit seeks to ascertain compliance of the activities

implemented under the project, the existing facilities and operations with national

environmental laws and regulations as well as World Bank safeguard requirements and

standards and to plan for the management of potential risks and impacts likely to result from

implementation of subsequent activities related to operation of these laboratory facilities.

This auditing exercise on environmental and social management aspects of the construction

and operation phases of WRRL revealed no major non-compliance issues at the construction

phase. Several commendable compliance areas of the operation phase were established

during the audit; availability of updated safety manuals, waste segregation at source, lockable

and well labelled waste storage area, good laboratory infrastructure and structural integrity,

availability of waste management records, proper chemical management and proper handling

and disposal of sharps.

However, the assessment identified healthcare waste management to be the main challenge

of the WRRL operation highlighting several deficiencies: shallow, unlined and overfilled

burning pit; unrestricted access to the burning site; Burning of waste containing plastics and

proximity of the disposal site to the staff quarters and scattered broken sharps at the ‘local

incinerator’. Besides, a legal and regulatory non-compliance was identified in the failure to

prepare an EIA for the proposed modern incinerator currently under construction against

the provisions of Section 45 of the Waste Management Regulations, 2006.

For the purposes of continuous improvement and compliance, the following

recommendations were formulated;



▪ Improve the on-site burning of waste. The on-site burning can be further improved

by digging an open pit but above the water table or lined with clay or plastic, and

protected by a fence or other effective barrier (e.g., rows of thorny brush).

▪ Increased agency monitoring. The EAPHLNP Project Management Unit should

initiate collaboration with NEMA in enforcement, supervision and monitoring of

waste management in the facility.

▪ With the eminent completion of the modern incinerator, proper incinerator

management measures (use of a well trained operator) need to be put in place to avert

its immature/untimely malfunction.

▪ Acquisition of adequate and dedicated number of transport bins and trolleys with

separate ones for infectious waste to be drawn on paved surfaces to the waste

treatment site.

In general, the compliance of the project activities with existing facilities and operating

procedures were found satisfactory.



CHAPTER ONE: INTRODUCTION AND BACKGROUND

1.1. Introduction

The WRRL, constructed and operationalized in 2015 is one of the five beneficiary satellite

laboratories in Kenya under the EAPHLNP funding from the International Development

Agency/the World Bank through the Ministry of Health.

The EAPHLN Project in Kenya included the rehabilitation/construction and equipping of 5

satellite laboratories (Nairobi, Machakos, Kitale, Busia and Wajir) as well as national

reference laboratories. An Environmental Management Plan for Wajir was prepared and

approved by NEMA in June 2012 and the construction completed in 2014. The project was

operationalized in January 2015.

Environmental and Social Management Framework (ESMF) was prepared in 2012 to ensure

proper assessment and mitigation of potential adverse environmental and social impacts. The

ESMF outlined the steps in the environmental and social screening process, and included

Environmental Guidelines for Contractors, a summary of the Bank’s safeguard policies, an

Environmental and Social Checklist, generic Environmental Assessment (EA) terms of

reference to be applied in the event that the screening results indicate the need for a separate

EA report, and an Environmental and Social Management Plan (ESMP).

The Environmental & Social Impact Assessment (ESIA) Environmental Management Plan

(EMP) were prepared and approved by NEMA in June 2012 and a licence thereto issued. It

was established that the construction and operation phases of the project adhered with the

conditions outlined in the licence.

1.2 Project description and design

1.2.1 Introduction

The development objective of the regional project was to establish a network of efficient,

high quality, accessible public health laboratories for the diagnosis and surveillance of

communicable and non-communicable diseases in the five East African Community (EAC)

member states (Burundi, Kenya, Rwanda, Tanzania and Uganda).

The project included three mutually reinforcing components which aimed to assist EAC

member states to diagnose communicable diseases of public health importance and to share

information about those diseases to mount an effective regional response as described below;



1. Component #1 - Regional Diagnostic and Surveillance Capacity provided support to

create and render functional a regional laboratory network which aims to enhance

access to diagnostic services for vulnerable groups; improved capacity to provide

specialized diagnostic services and conduct drug resistance monitoring; and

strengthened laboratory based disease surveillance to provide early warning of public

health events.

2. Component #2 - Joint Training and Capacity Building aimed to support training and

capacity building for laboratory personnel, in order to increase the pool of experts in

the sub-region and to improve the effectiveness of public health laboratories.

3. Component #3 - Joint Operational Research and Knowledge Sharing/Regional

Coordination and Program Management will finance operational research and

knowledge sharing activities, which aim to evaluate the impact of the new TB

diagnostic technologies, assess drug resistance patterns for endemic diseases, and

ascertain feasibility of using mobile phone technologies for surveillance reporting;

and support regional coordination and program management functions.

The laboratory network will facilitate the adoption of harmonized policies, strategies, and

protocols to ensure prompt and high quality results. Priority attention will be given to

networking intermediate or satellite laboratories that serve cross border and migrant populations,

and central public health labs that provide specialized services.

1.2.2 The Project Design

The laboratory is well designed providing adequate space, engineering controls and proper

environmental conditions for storage and analysis of specimen in accordance with good

laboratory practices, laboratory safety requirements and applicable regulations.

The facility meets the required environmental conditions including separation of work areas

to ensure that analyses will not be adversely affected within resources provided (laboratories

are separated according to compatibility of testing activities), bio-safety hoods, adequate air

conditioning, lighting, heating and ventilation are controlled and monitored to the level

needed for each type of test,

The development is a one storey building with the ground floor accommodating the Waiting

area, Specimen reception area, Reception area, Reports release desk, Cashier office, Records

room, Patients WCS, Phlebotomy room, washing area, Counselling room, Blood donor room,

Rest room, Blood bank, Pathologists office, Server room, Staff Lounge, Office for in-charge,



Office for County laboratory Technician, Utility Room, Cold Room, Training Room; video

conferencing, Suppliers store and Staff WCs.

The first floor accommodates the Blood transfusion laboratory, Serology laboratory,

Chemistry laboratory, Hematology laboratory, Parasitology laboratory, Histology laboratory,

Microscopy, Freezer room, Media prep room, Specimen Museum, Quality control laboratory,

Molecular laboratory, Virology laboratory, Microbiology laboratory, TB laboratory,

Decontamination room, Glassware washing, Store and Staff WCS.

1.2 Objective of the Consultancy

This environmental and social audit seeks to ascertain compliance of the activities

implemented under the project, the existing facilities and operations with national

environmental laws and regulations as well as World Bank safeguard requirements and

standards and to plan for the management of potential risks and impacts likely to result from

implementation of subsequent activities related to operation of these laboratory facilities.

The audit is necessary to ensure that the safeguard instruments (ESIAs, ESMPs, MWMP,

IPPFs) have been implemented appropriately, and that relevant mitigation measures have

also been identified and implemented. The audit will be able to identify any

amendments/updates to be effected to the safeguard instruments to improve their

implementation effectiveness.

The key objective of the Environmental Audit is to identify gaps in Environmental

Management measures and to prepare an Action Plan that will be implemented during the

rest of the project period.

1.3 Project Justification

The requirement to conduct an annual Environmental & Social Audit (ESA) is a mandatory

legal obligation, a sound precautionary measure and a proactive strategy in today’s closely

regulated environment. ESA plays a valuable role in encouraging the systematic

incorporation and mainstreaming of environmental and social policies and practices into

many aspects of the WRRL’s overall operations and core values.

Since the ESIAs/ESMPs were prepared in the first year of the project prior to construction,

there was need to carry out an initial Environmental and Social Audit (EA) in order to

ensure that there was due diligence in the application of safeguards during construction

phase and operation phase and to plan for mitigating and/or addressing any potential adverse

risks during the operational phase.



1.4. Scope of the ESA and Specific Tasks for the Consultancy

The scope of the audit is therefore limited to the constructed WRRL under the EAPHLP. The

audit covers two main phases of the project, with specific areas of focus:

- Project construction phase: management of construction materials and waste, air, noise and

wastewater, prevention of soil degradation and forests/critical ecosystems encroachment as

well as occupational health and safety measures set in place by the constructor.

- Project operation and maintenance phase: waste generation, management and disposal from

laboratory operations as well as health and safety of the staff and overall environmental

performance.

1.5 Methodology and Approach

This Environmental & Social Audit (ESA) study was undertaken by employing various

methodologies;

a) A review of the documents (including policies and legislation, World Bank’s

Environmental and Social Safeguards, project documentation, supervision reports).

b) Evaluation of existing internal environmental policies and strategies.

c) Appraisal of work processes and environmental management systems employed

within the WRRL.

d) Site inspections and walk through of sampled facilities based on a detailed

checklist conducted in the week of 5th to 9th June 2017.

e) Evaluation of health and safety policies, strategies and measures in place.

f) HCWM Assessment Survey Tool for data collection (APPENDIX 1: HCWM

ASSESSMENT SURVEY TOOL.)

The Consultant designed and administered the tool generate highly detailed

information at each section so that the HCWM system at the facility could be assessed

and to enable the Consultant to speak fairly to the HCWM “system” at the site. The

HCWM Assessment tool used was designed to highlight observable variables,

registering simple ‘ticks’ of yes/no observables for each variable

The tool laid emphasis on the following five areas:



➢ Presence of sharps in black coded bins

➢ Disposal of waste water into common drain

➢ Provision of waste segregation bins

➢ Provision of respirator to waste handlers

➢ Presence of a working incinerator

g) Interviews and public consultations with key stakeholders (NEMA Wajir County

Environmental officer, public health officials (Wajir District Hospital Health &

Safety Officer), medical and laboratory personnel, community representatives)

and waste handlers. Attention was paid to issues of noise, air quality,

environmental stability as well as the waste disposal regime. A questionnaire

(APPENDIX 2: QUESTIONNAIRE FOR STAKEHOLDER CONSULTATIONS)

was used to guide the consultations, interviews and a meeting with the

stakeholders held on 6th and 7th of July 2017 (APPENDIX 5: STAKEHOLDERS

MEETING PARTICIPANTS).



CHAPTER TWO: ENVIRONMENTAL AND SOCIAL BASELINE INFORMATION

2.0 Introduction

This chapter provides the main features of the baseline biophysical and socio-economic

information of the project area. Environmental description, also known as baseline

studies, is intended to establish the present state of the environment, taking into

account changes resulting from natural events and from other human activities. If an

environmental description is flawed, this will reduce the accuracy of subsequent

predictions and mitigation measures.

2.1 The Project site

2.1.1 The laboratory Infrastructure

The WRRL building is located within the Wajir District Hospital compound in the

neighborhood of the Wajir County Health building and the Wajir County Mental

Hospital building. The site has an efficient connection of road network

The site is defined by a public access road and it is flat with a number of trees and sandy

soils and is served by electricity from Kenya Power.

The laboratory is well designed to accommodate movement related to patients,

personnel and specimens. The design clearly indicates how specimens move from the

specimen receiving area to the laboratory for test and dispatch of the results to the

patients.

The worktops/workbenches are constructed with a 25mm TRESPA Toplab Plus thick

solid panels which are acid, solvent, stain and scratch resistant with a marine edge top

and applied backsplash to contain spillage.

The laboratory has an elaborate communication system between the various sections

and also LIMS for electronic transfer of information and data from the laboratory area

to other sections or other satellite labs.

2.1.2 Water and Power Supply

Wajir district hospital has a borehole with an elevated pre-stressed steel water tanks

and also ground tank to improve water storage.

The WRRL sources its water for general use from a borehole located at the Wajir

District Hospital.



The hospital has a generator which also supports the new laboratory. There’s need for

the services of an electrical engineer to design for automatic change over switch and

incorporate solar water heating.

2.1.3 Laboratory Safety and Sanitation

The WRRL and the Wajir District Hospital (WHD) have in place a health and safety

committee and the bio-safety committee respectively and the safety management guidelines

such as the Policy and Procedures Manual and Guidelines for chemical safety handling,

incident, injuries and accidents. Safety measures in place were found satisfactory in the

laboratories.

Sanitation measures and facilities at the WRRL were found sufficient and fully operational.

2.1.4 Waste Management

The waste management and disposal at the two facilities (WRRL and WDH) is handled by

the Wajir County Government who have hence contracted the services to Saelf Cleaning

Services Company. The company is responsible for provision of all waste collection materials

as per the different waste categories, provision of PPEs to the waste handlers and also for the

transportation of the waste to the disposal site located behind the laboratory. There was

however no evidence that Saelf Cleaning Services Company was licensed by NEMA to

provide waste handling services as required by Waste Management Regulation, 2006.

2.1.4.1 HCW Segregation

Waste segregation procedures is well known at the WRRL with the waste separated

according to the biohazard risk (colour codes), waste containers clearly labelled and waste

handlers aware of the importance of precaution measures required for the different category

of waste with infectious and non-infectious waste disposed off in separate containers and

sharp instruments and needles discarded in puncture resistant containers. The infectious

waste and sharps are autoclaved before final disposal.

The Health and Safety Officer at the Wajir District Hospital and the Bio-safety Officer at the

Laboratory supervises the waste collection, segregation and transportation to the disposal

site. The HCW disposal through burning is done thrice a week by a County Government

employee (Health Care Waste Handler) using diesel as fuel.



2.1.4.2 HCW Storage Area

The WRRL has a lockable door storage area located on the first floor of the building. The

storage area is well labelled with a weighing scale and the waste records available from

which the quantities of waste generated can be ascertained.

2.1.4.3 HCW Disposal

The common disposal sites are located behind the laboratory: waste dumping site (open

pit) and sharps burning ‘local incinerator’. The waste burning sites are adjacent to the staff

quarters and the smoke emanating from the burning has been a constant menace to the staff

and the general public. There is an on-going project to construct a modern incinerator

with the old incinerator on site having malfunctioned due to a faulty gasket. As at the

time of the audit, it’s worth noting that the construction was stopped by NEMA since

there was no EIA done for the construction of the incinerator as required by the EMCA

(Amendment), 2015.

2.1.4.4 Waste Water Management

The WRRL has a septic tank and a soak pit located behind the laboratory for waste water

management.

2.2 Wajir County profile

Wajir is located in an arid area prone to drought. It sits at a latitude and longitude of

01°45’00”N 40°03’00”E / 1.75°N 40.05°E / 1.75; 40.05.

As with other areas in the former North Eastern Province, Wajir is mainly inhabited by

Somalis, most belonging to the Degodia sub-clan of the Hawiye.

2.2.1 Administrative

Wajir County is the largest County in the former North-Eastern Province and the

second largest in the Republic of Kenya after Turkana. The County borders the

Republic of Somalia to the east, Garissa County to the south, Isiolo County to the south-

west, Marsabit County to the west, Moyale County to the north-west, the Republic of

Ethiopia to the north and Mandera County to the North-East.

The county comprises of six sub-counties namely Wajir East, Wajir West, Wajir North,

Wajir South, Eldas, Tarbaj. The siute is located in Wajir East subcounty, with the

highest population density due to the fact that it’s the County headquarters where



businesses, employment opportunities and informal sector income generating activities

are concentrated.

The County is linked to the rest of the country by STANDARD telephone

communication at Wajir town and Habaswein while manual lines are available in Buna,

Bute, Griftu, and Wajir-Bor. The town is served by Wajir Airport, with flights to

Nairobi, Galkacyo and Mogadishu with three other small airstrips in Bute, Griftu and

Habaswein.

2.2.2 Topography

The County consists largely of a featureless plain, prone to flooding during rainy season,

often making roads impassable. The plain is truncated by dry river beds that fill with

water during the rainy season.

2.2.3 Climate

The County lies within the Sahelian climatic region, which is characterized by long dry

spells and short rainy seasons with an annual average rainfall is between 250mm to

300mm.

Maximum temperatures range between 31°C in July and 36°C in March while minimum

temperatures range between 21°C in July and 24°C in April.



CHAPTER THREE: POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK.

3.0 Introduction

Environmental problems are rooted in economic and social policies, they occur at all

levels from local to global, and success requires action by many players over long

periods of time. The Government of Kenya (GoK) is responsible for dealing with these

problems and working towards solutions. Accordingly the government of Kenya has

tried to address this over the years by creating policies, plans and programs enacting

environmental legislation, and through international institutions and treaties, laws and

regulations and expenditures as well as relevant international safeguards such as the

World Bank EHS Guidelines and Safeguard Policies.

The relevant national and international legislations, policies and guidelines are

presented in this section, and the relevant and applicable sections or subsections

identified. This is done to ensure that adequate mitigation measures are put in place to

deal with the negative impacts on the project affected persons, and that all project

related activities are in conformity with the existing laws, and regulations, and

international best practices.

3.1 Kenya Constitution 2010

The promulgation of the Kenya Constitution 2010 marked an important chapter in

Kenya’s environmental policy development. Hailed as a green constitution, it con tains

elaborate provisions with considerable implications for sustainable development. These

range from environmental principles and implications of multilateral environmental

agreements (MEAs) to the right to a clean, healthy environment (article 42), and the

highest attainable standard of health (article 43 (i)) enshrined in the expanded Bill of

Rights, chapter four. It also embodies a host of social and economic rights of an

environmental character, such as the right to water, food, and shelter, among others.

Article 70: (1) If a person alleges that a right to clean and healthy environment

recognized and protected under Article 42 has been, is being or is likely to be, denied,

violated, infringed, or threatened, the per-son may apply to a court for redress in

addition to any other legal remedies that are available in respect to the same matter.

This therefore gives the government the mandate to ensure that the rights of the

Kenyan people are protected and upheld.



3.2 Environment Management and Coordination (Amendment) Act, 2015.

EMCA, 1999 (and its 2015 Amendment) provides a legal and institutional framework

for the protection and conservation of the environment (in line with Article 42 of the

constitution).

The EMCA is very clear about the handling of biomedical waste, in particular, EMCA,

Part V stipulates that:

a. No person shall own or operate any institution that generates bio-medical waste

without a valid environmental impact assessment license issued by the authority

under the provisions of the Act.

b. Every waste generator of biomedical waste shall ensure that the generating

facility has been approved by the appropriate lead agency and the relevant local

authority.

c. Every waste generator of biomedical waste shall at the point of generation and at

all stages thereafter segregate the waste in accordance with the categories

specified in the seventh schedule to the EMCA regulations.

d. All biomedical waste shall be securely packaged in biohazard containers which

shall be labeled with the symbols set out in part i and ii in the eighth schedule of

the EMCA regulations

e. Every waste generator shall treat or cause to be treated all biomedical waste in

the manner set out in the ninth schedule to the EMCA regulations, before such

biomedical waste is stored or disposed of.

f. the relevant lead agency shall monitor the treatment of all biomedical waste to

ensure that such waste are treated in a manner that will not adversely affect

public health and the environment.

g. No person shall store biomedical waste at a temperature above 0˚C for more than

seven days without the written approval of the relevant lead agency, provided

that untreated pathological waste shall be disposed of within 48 hours.

h. No person shall transport biomedical waste without a valid permit issued by the

relevant lead agency in consultation with the relevant local authority.

i. No person shall transport or allow to be transported biomedical waste save in a

specially designed vehicles or other means of conveyance so as to prevent

spillage, leakage or scattering of such waste.



3.2.1 The EMCA (Waste Management) Regulations 2006

The Environmental Management and Coordination (Waste Management) Regulations

2006 is the government’s legal instrument that deals with waste management in Kenya.

The waste Management Regulations are meant to streamline the handling,

transportation and disposal of various types of waste to protect human health and the

environment. The regulations place emphasis on waste minimization, cleaner

production and segregation of waste at source. The regulation requires licensing of

transporters of wastes and operators of disposal site (sections 7 and 10 respectively).

Of immediate relevance to proposed development for the purposes of this project study

report is Part II Sections 4(1-2), 5 and 6.

▪ Section 4 (1) states that “No person shall dispose of any waste on a public

highway, street, road, recreational area or any other public place except in a

designated waste receptacle”. Section 4(2) and 6 explain that the waste generator

must collect, segregate (hazardous waste from non-hazardous) and dispose waste

in such a facility that shall be provided by the relevant local authority.

▪ Section 5 provides method of cleaner production (so as to minimize waste

generation) which includes the improvement of production processes through

conserving raw materials and energy.

▪ Section 11 provides that any operator of a disposal site or plant shall apply the

relevant provisions on waste treatment under the local government act and

regulations to ensure that such waste does not present any imminent and

substantial danger to the public health, the environment and natural resources.

▪ Part VI Section 38, 39 and 40 are relevant as far as biomedical waste segregation,

packaging and treatment is concerned.

▪ Section 38 states that any person who generates biomedical waste shall at the

point of generation and at all stages thereafter segregate the waste in accordance

with the categories provided under the Seventh Schedule to these Regulations.

▪ Section 39 states that all biomedical waste shall be securely packaged in

biohazard containers which shall be labeled with the symbols set out in Part I

and II of the Eighth Schedule to these Regulations.



▪ While section 40 states that any person who generates waste shall treat or cause

to be treated all biomedical waste in the manner set out in the Ninth Schedule to

these Regulations, before such biomedical waste is stored or disposed of.

The Proponent is expected to take full responsibility to ensure that solid waste (both

hazardous and non-hazardous) is properly handled, stored, transported and disposed as

per the procedures provided in these regulations, as well as the various documented

management plans and guidelines on health care waste management such as the

National Health Care Waste Management Plan 2015-2020 and the WHO National

Guidelines on Safe Disposal of Pharmaceutical Waste. The waste must be transported by

licensed transporter and disposed in waste treatment facility that is approved by the

authority.

3.2.2 The EMCA (Water Quality) Regulations 2006

These regulations apply to water used for a variety of purposes, including water used for

domestic purposes, industrial, purposes, agricultural purposes etc. They protect lakes,

rivers, streams, springs, wells and other water sources whereby contravening the

regulations is an offence that attracts a fine not exceeding five hundred thousand

shillings.

Of immediate relevance to the proposed project is Part II Sections 4-6 as well as Part V

Section 24.

▪ Part II Section 4 inhibits acts which directly or indirectly, immediate or

subsequently cause water pollution.

▪ Part II section 6 criminalize discharge of water from sewage treatment works,

industry or other point sources into the aquatic environment without a valid

effluent discharge license.

▪ Part V Section 24 prohibits discharge or application of any poison, toxic, noxious

or obstructing matter, radioactive wastes, or other pollutants, into water meant

for fisheries, wildlife, recreational purposes or any other uses.

All waste water shall therefore be channeled into the sewer line to avoid ground and

surface water pollution, and if a pollution incidence occurs the contractor/proponent

shall notify the authority immediately. The contractor/proponent will handle hazardous

substances in a manner that is not likely to cause water pollution.



3.2.3 The EMCA (Air Quality) Regulations 2014

The Environmental Management and Coordination (Air Quality) Regulations 2014 is

the government’s legal instrument that deals with air quality in Kenya.

The Air Quality Regulations are meant to provide for the prevention, control and

abatement of air pollution to ensure clean and healthy ambient air.

The general prohibitions state that no person shall cause the emission of air pollutants

listed under First Schedule (Priority air pollutants) to exceed the ambient air quality

levels as required stipulated under the provisions of the Seventh Schedule (Emission

limits for controlled and non-controlled facilities) and Second Schedule (Ambient air

quality tolerance limits).

Of immediate relevance to the project are the following sections excerpts;

▪ Section 9 provides that a person, being an owner of premises, who causes or allows

the generation, from any source, of any odour which unreasonably interferes, or is

likely to unreasonably interfere, with any other person’s lawful use or enjoyment of

his property shall ensure that the odour emission limits comply with the ambient

quality limits set out under the First Schedule of these regulations

▪ Section 17 provides that the owner or operator of a controlled facility shall ensure

that exposure of workers to occupational air pollutants is monitored and recorded.

▪ Section 35 states that no person shall cause or allow stockpiling or other storage of

material in a manner likely to cause ambient air quality levels set out under the First

Schedule to be exceeded.

▪ Section 38 states that No person shall cause or allow emissions of priority air

pollutants from the disposal of medical waste, domestic waste, plastics, tyres,

industrial waste or other waste by open burning.

▪ Section 38 states the owner or operator of any controlled facility shall apply to

the Authority for an emission licence within twelve months from the date these

Regulations come into force.

The Proponent is expected to take measures to curb or minimize air emissions in

controlled areas. In case of emissions, the air quality is to be measured and monitored

against the allowable limits.



3.3 Radiation Protection Act, Cap 243

The Radiation Protection Act, Chapter 243, aims to control the import, export,

possession and use of radioactive substances and irradiating apparatus. Under this Act in

section 9, a license is required to handle any radioactive substances or irradiating

apparatus from the National Radiation Protection Board. Handling here includes the

method of disposing of radioactive waste products, transportation of radioactive

materials, storage, use and maximum working hours that employees are expected to

work with radioactive materials. Under this Act also, institutions generating this

category of waste shall be expected to apply for a license from the same board.

The provisions of this act will guide the proponent on the use of radiation and its

control, in the use of X-ray radiation apparatus and related technology.

3.4 Public Health Act Cap. 242

The Act makes provisions for securing and maintaining health. Part IX, section 115, of

the Act prohibits any person or institution from causing nuisance or a condition likely

to cause injury or which might be dangerous to human health.

3.5 Occupational Safety and Health Act, 2007

This Act of Parliament was enacted to provide for the health, safety and welfare of persons

employed in factories and other places of work and for matters incidental thereto and

connected therewith.

This legislation specifically provides for the protection of workers as well as the communities

within the proximity of the places of work.

3.6 Guidelines, Plans and Policy framework

3.6.1 Sessional Paper No. 6 of 1999 on Environment and Development

In 1999, the Government of Kenya produced the Sessional Paper No. 6 on Environment

and Development. The goal of the policy was to integrate environmental concerns into

the national planning and management processes and provide guidelines for

environmentally sustainable development. The policy paper identified areas requiring

action, which included the development of a comprehensive waste management policy,

guidelines, and standards.



3.6.2 The National Environmental policy of 2012

The environment policy of 2012, among other comprehensive legal instruments, gives a

broad statement on a number of key areas that have an impact on human health. In the

policy, issues of health are captured in chapters five and six. Chapter five is concerned

with the issues of environmental stewardship, which include climate change, disasters,

the sustainability of human settlements, waste management including management of

hazardous wastes and radioactive wastes, energy, gender, HIV/AIDS, and youth.

3.6.3 World Bank Safeguards and Disclosure Policies

The World Bank Environmental and Social Safeguards Policies include key Operational

policies (OP) designed to ensure that potentially adverse environmental and social

consequences are identified, minimized, and mitigated. The relevant policies are

summarized below. These policies will be replaced during 2018 with the Environmental

and Social Framework (ESF).

3.6.3.1 OP/BP 4.01 Environmental Assessment

This policy is considered to be the umbrella policy for the Bank's environmental

'safeguard policies'. This policy requires Environmental Assessment of projects proposed

for Bank financing to ensure that such projects are environmentally sound and

sustainable. All projects proposed must be screened by the Bank and put into one of

four categories for Environmental Assessment purpose. If a project falls into categories

A or B, a Comprehensive Environmental Assessment (also known as EIA or SEIA for

Social and Environmental Impact Assessment) must be conducted to respond to Bank

requirements. An EIA must include a comprehensive environmental management plan.

3.6.3.2 OP/BP 4.10 Indigenous Peoples

This policy underscores the need for project proponent and Bank staff to identify

indigenous peoples and to engage in a process of free, prior, and informed consultation.

The policy also aims to ensure that adverse impacts on Indigenous People are avoided,

or where not feasible, minimized or mitigated and that they participate in project and

benefit from it in a culturally appropriate way.

An elaborate Indigenous Peoples Plan (IPP) and Indigenous Peoples Policy Framework

(IPPF) for the project were prepared, consulted upon and disclosed.



3.6.3.3 Environment, Health and Safety Guidelines

The General World Bank Environmental, Health, and Safety (EHS) Guidelines are designed

to be used together with the relevant Industry Sector EHS Guidelines which provide

guidance to users on EHS issues in specific industry sectors.

Application of the EHS guidelines to existing facilities may involve the establishment of site

specific targets, with an appropriate timetable for achieving them. When host country

regulations differ from the levels and measures presented in the EHS guidelines, projects are

expected to achieve whichever is more stringent.

3.6.4 The Kenya Health Policy 2012 to 2030

The National Health Policy 2012 – 2030 has laid emphasis on healthcare waste

management to accelerate prevention and minimization of communicable diseases and

epidemics including HIV/AIDs, Tuberculosis, Hepatitis B and C, as well as other viral

hemorrhagic fevers among others. This policy is in line with the Public Health Act Cap

242 laws of Kenya which also addresses environmental health, water and sanitation

including healthcare waste management.

3.6.5 Injection Safety and Medical Waste Management Policy 2007

The mission statement of this policy is to ensure the safety of health workers, patients,

and the community and to maintain a safe environment through the promotion of safe

injection practices and proper management of related medical waste. This is the first

document of the Ministry that is explicit on the need to address HCWM problems. The

policy objectives spell out the need to advocate for support and implementation of

proper management of medical waste, among others.

Some of the guiding principles for the implementation of the policy include:

• Establishing organizational structures at all levels for the implementation of

injection safety and related medical waste.

• Addressing the need for environmental protection through appropriate waste

disposal methods.

• Minimizing risks to patients, health workers, communities, and the environment

through application of safe injection devices and sharps waste-disposal methods.

• Advocating for the strengthening of necessary human-resource capacity through

training and sensitization for safe waste disposal.



One of the policy’s key strategies is the need for appropriate financial mobilization and

allocation of the components of injection safety and medical waste management for

effective policy implementation. The provision of sustained supplies and equipment for

waste management through a strengthened logistics system addresses the need for

commensurate in-vestment in waste-handling requirements. Another unique strategy

recommended by the policy is the advocacy of best waste-management practices

through behavior change communication as a key element in the strategy.

3.6.6 National IPC Policy

In recognizing the need to redesign and strengthen existing systems and implement

evidence based methods to tackle infectious diseases in health care settings and tackle

the gradual development of drug-resistant infections, the MOH in 2010 developed the

National Infection Prevention Policy. The policy was set with the purpose of

preventing and managing HAIs by:

▪ Setting national standards for minimizing hazards that are associated with

biological agents in health care settings.

▪ Providing guidance to health administrators, health care workers, and all

stakeholders to observe these standards.

The policy was to be operationalized through the development of mid term and short

term IPC implementation plans and the development of IPC guidelines for health care

settings. This strategic plan is thus a key step in the implementation process of the

national IPC policy in health care settings in Kenya.

3.6.7 Health Care Waste Management Strategic Plan 2015-2020

The National Health Care Waste Management Plan of Action is a document intended

for use by health managers and programme officers across the health sector (including

those in the private health sector). The purpose of developing this plan was to provide a

tool that gives health managers guidance in planning, implementing and monitoring the

activities of health care waste management in health facilities.

A holistic approach has been recommended to include, clear delineation of

responsibilities, occupational health and safety programmes, waste minimization and

segregation. This document is designed to provide viable options to address the

challenges encountered in planning for health care waste management in Kenya.



3.6.8 National Infection Prevention and Control Guidelines for Health Care Services in Kenya, 2010

These guidelines were formulated by the Ministry of Medical Services and Ministry of

Public Health and Sanitation to provide comprehensive and standardized information

regarding the prevention and control of transmissible infections.

These guidelines are intended to act as a central reference for all health care facilities

and healthcare workers.

Additionally, these guidelines are intended to provide administrators and Health Care

Workers with the necessary information and procedures to implement Infection

Prevention Control (IPC) core activities effectively within their work environment in

order to protect themselves and others from the transmission of infections. They

provide information on the following topics:

▪ The infrastructure, equipment, and supplies that are necessary to implement

standard and additional (transmission-based) precautions for IPC

▪ Procedures for cleaning, disinfecting, and reprocessing reusable equipment

▪ Managing health care waste

▪ Protecting health care workers from transmissible infections

▪ IPC practices in special situations

3.6.9 Kenya National Guidelines on Safe Disposal of Pharmaceutical Waste

The Kenya National Guidelines on Safe Disposal of Pharmaceutical Waste provides a

schedule on how unwanted pharmaceutical waste should be disposed.

3.7 International Agreements

Kenya is a signatory to many agreements and conventions on environmental

management. These include support for the provisions of Agenda 21 amongst other

declarations and statements of principle, such as the Rio Declaration in 1992 on

Environment and Development. Kenya is also a party to the Basel Convention on the

Control of Transboundary Movements of Hazardous Wastes and their Disposal 1992 and

the Stockholm Convention for Persistent Organic Pollutants (POP’s) 1972.



CHAPTER FOUR: PUBLIC PARTICIPATION & CONSULTATIONS

4.0 Introduction

The process mainly involved meetings and consultations exercises by use of open ended

questionnaires and interviews with relevant project affected persons/groups/businesses

and concerned government authorities, documenting their concerns, assessing potential

impacts, and exploring improvement actions. The interviews and consultations were

conducted to seek and input into this report the views of the community during the

construction and operation phases.

Some of the key stakeholders conducted include

1. NEMA Wajir County Environmental officer,

2. Public Health Officials (Wajir District Hospital Health & Safety Officer),

3. The WRRL Bio-safety officer,

4. Medical and laboratory personnel,

5. Community representatives and

6. Waste handlers.

4.1 Methodology

The consultant employed interviews, a structured questionnaire (APPENDIX 2:

QUESTIONNAIRE FOR STAKEHOLDER CONSULTATIONS) and a stakeholder meeting

to review and assess the project impact on the indigenous people. The meeting was held

on 6th June 2017 at the Wajir Guest House and the recorded minutes attached

(APPENDIX 5: STAKEHOLDERS MEETING PARTICIPANTS & APPENDIX 4:

MINUTES TO THE STAKEHOLDERS MEETING).

Attention was paid to issues of noise, air quality, environmental stability as well as the waste

disposal regime.



4.2 Findings

The findings of the public consultation process (interviews, questionnaire and meetings) were found to compliment and are

summarised in Table 1 below;

Table 1: Summary of the Consultations

No. Category Findings

1. Usefulness of the Laboratory

▪ The laboratory testing capacity has greatly increased and patients can be treated according to the accurate results from the lab.

▪ The access to the lab by patients is much easier and they can be treated rapidly as the results are rapidly delivered.

▪ The laboratory testing capacity has greatly increased and patients from all over the region can be rapidly and better treated based on

results generated by the lab.

2. Any benefit to neighboring

regions

▪ The WRRL and the WDH regularly receive patients from the neighboring counties and sub-counties (Wajir East, Wajir West, Wajir North, Wajir

South, Eldas, Tarbaj) to benefit from affordable and reliable

services provided by the lab.

3. Construction waste ▪ Waste, including excavated soil and debris properly disposed off by backfilling and landscaping.

4. Noise pollution: use of

drilling machines.

▪ Construction noise was limited to official working hours

5.

Noticeable Health and safety

measures during construction

phase

▪ Construction workers trained on safe work practices and were wearing protective clothes, hard caps, boots and masks. The site was fenced

to restrict onlookers/scavengers and a specific access road for

trucks was set up.

▪ Signages were used to warn staff and/ or visitors that are not involved in construction activities of areas that pose risk;

▪ Installation of temporary speed bumps for speed control undertaken within the construction site;

6.

Noticeable public hazards from

the construction of the

facility

▪ No hazards identified from construction of laboratory facilities.

7.

Notification and worker

safety.

▪ The public has been notified of the works through appropriate notification all over the Hospital

▪ All legally required permits (construction permit land use, re-source use, dumping, sanitary inspection permit) have been acquired for

construction and/or rehabilitation



8. Noticeable public hazards

since the project is operating

▪ Waste management and smoke emanating from the burning of the HCW to the Staff headquarters. A transfer of the burning site to a distant

site was recommended.

9.

Noticeable improvement of

livelihood (jobs…)

▪ Men and women managed to get jobs from the construction and the lab staff has increased.

▪ House owners, shop-keepers and other small business owners benefited from the presence of construction workers.

10. Overall perception of the

project

▪ Clients using the service of the lab have substantially increased and the Hospital services benefited from the improved quality of results.

11. Adherence with the ESIA

License conditions

▪ All the conditions pursuant to the issuance of the license were adhered with.

▪ It is worth noting that very few respondents were aware of the existence of any conditions to the issuance of the licence.

12. Land acquisition ▪ The WRRL constructed within the Wajir District Hospital (WDH) compound

From the views collected, there was no major environmental or social hazard from the construction of the laboratory. On the

other hand, the whole project was well received by the locals courtesy of the strong sentiments shared.



CHAPTER FIVE: AUDIT FINDINGS

5.0 Introduction

This review and assessment is based on site reconnaissance visit conducted on 23rd to

24th April, 2017 and from the field visits and consultations conducted in the week of 5th

to 9th June 2017.

The report provides findings, analysis and recommendations from the assessment of the

WRRL at the construction and operation phase besides the legal and regulatory review in

the construction and operation phases of the laboratory.

5.1 Legal and regulatory review

5.1.1 Findings

The assessment noted an on-going project to construct a modern incinerator. As at

the time of the audit, the construction had been stopped by NEMA since there was

no EIA done for the construction of the incinerator as required by the EMCA

(Amendment), 2015.

The original design of the project included the design for the construction of the

laboratory building but did not include the construction of the proposed modern

incinerator. Besides, the scope of the EIA prepared did not cover the proposed modern

incinerator though the assessment had proposed incorporation of a new standard

incinerator for the facility

The EIA waste regulations require that an EIA be done for any waste incinerator and a

licence be issued for its operation.

Section 45 of the Waste Management Regulations, 2006, stipulates that no person shall

own or operate a biomedical waste disposal site or plant without an EIA licence issued by

the Authority under the provisions of the Act and an operating license issued by the

Authority. Within six months after the commencement of these Regulations, operators of

bio-medical waste disposal sites or plants shall submit an Environmental Audit reports

and thereafter annual Audit Reports to the Authority.

5.1.2 Actions required

There was need to construct a well functioning incinerator under clause 7.4 (Operational

Phase EMP) of the prepared ESIA’s (Appendix 3).

As at the time of the audit, the project management had commissioned a consultant who

is assisting to complete the EIA for the modern incinerator as requested by NEMA Wajir

County Office, in order to comply with legal requirements and regulations. It is worth

noting that most of the non-conformities highlighted in the operation of the WRRL are



linked to the lack of a functional modern incinerator. The completion and commissioning

of the new incinerator, therefore, is crucial in the ultimate mitigation of most of the non-

compliance issues as far as HCWM at the facility is concerned.

5.2 Construction phase review

5.2.1 Findings

The construction of the WRRL started in 2012 on a site within the Wajir District Hospital

compound. It was completed and operationalized in 2015.

The project had triggered OP 4.01 and OP 4.10, World Bank safeguard policies on

Environmental Assessment and on the Indigenous people respectively. The audit

therefore sought to address any gaps in the GOK regulations and the safeguards set

to mitigate some of the negative impacts identified at the construction phase besides

ascertaining the impact of the project on the local community.The construction phase

of the WRRL project was completed in 2015.

In the construction of the WRRL, the construction activities did not result in any land

take, no displacement of people or loss of assets, incomes or livelihoods, and no risks to

vulnerable or marginalized groups since the site was within the existing Wajir District

hospital.

From the views collected, there was no major environmental or social hazard from the construction of the laboratory an indicator of the effective implementation of the proposed mitigation measures and monitoring as per the prepared ESMP for the construction phase (



APPENDIX 6: CONSTRUCTION PHASE ESMP.).

Besides, the whole project was well received by the locals courtesy of the strong sentiments

shared as per the attached summary of the consultations (APPENDIX 4: MINUTES TO

THE STAKEHOLDERS MEETING).

5.2.2 Gaps identified

From the public consultations conducted and the questionnaire administered, it was noted

that no significant nuisances could be reported and safety measures such as fencing, PPE for

construction staff and public notices were set up. Most of the environmental and social

nuisances from the construction phase were limited in time and were of negligible impact.

5.2.3 Conclusion

The procedures required by the ESMF for the construction phase of the WRRL were fully

applied, including the preparation of an Environmental Impact Assessment (EIA) and the

Environmental Management and Monitoring Plan (EMMP) prior to the commencement of

construction activities. No fatal social and environmental flows could be observed due to the

low significance of the project impacts and the existing regulations in place.

5.3 Operation and Maintenance Phase Review

5.3.1 Findings

The World Health Organization Africa has set up the Stepwise Laboratory Quality

Improvement Process towards Accreditation (SLIPTA), a framework for improving quality of

public health laboratories in developing countries to achieve ISO 15189 standards. From the

2017 peer review audit, which had among other objectives to determine scores of WRRL

towards accreditation using the SLIPTA checklist, it was reported that the laboratory has

improved its performance substantially, reaching three stars, and surpassing the project

target of two stars, on a scale of five.

The annual SLIPTA audit assessment and monitoring on four key areas recorded a substantial

improvement in the management of biomedical waste at the site. This is depicted in the

trend in the composite scores table below;

Table 2: SLIPTA Composite Scores

Section Checklist item Max score Score

12.9 Is a laboratory safety manual available, accessible, and

up-to-date? 3 3



12.10 Is sufficient waste disposal available and is waste

separated into infectious and non-infectious waste, with

infectious waste autoclaved, incinerated, or buried?

2 2

12.11 Are hazardous chemicals/materials properly handled? 2 2

12.12 Are ‘sharps’ handled and disposed of properly in ‘sharps’

containers that are appropriately utilized? 2 2

9 9/9

Source: WRRL 2017 SLIPTA Audit Report

During the field assessment several commendable observations were made;

a. Safety manuals are readily available in work areas and the manuals specifically include

guidelines on key topics e.g. blood and body fluid precautions, hazardous waste

disposal, personal protection equipment; post-exposure prophylaxis, fire safety,

electrical safety, etc.

b. Good laboratory infrastructure and structural integrity. The laboratory is well designed

providing adequate space, engineering controls and proper environmental conditions

for storage and analysis of specimen in accordance with good laboratory practices,

laboratory safety requirements and applicable regulations;

▪ Clearly separated rooms (individual laboratories are separated according to

compatibility of testing activities).

▪ Biometric access control, adequate air conditioning, lighting, heating, and

ventilation are controlled and monitored.

▪ The individual laboratories are equipped with bio-safety hoods and chemical

hoods with adequate face velocities and minimal distortion of air movement (cross

drafts) to capture hazardous or odorous materials used or produced in the analyses

and to protect personnel from airborne toxic substances.

c. Waste Segregation at source. Waste is separated according to biohazard risk, with

infectious and non-infectious waste disposed of in separate containers and whether

sharp instruments and needles are discarded in puncture resistant containers.

d. Waste Management Records are well maintained at the Waste Storage Area. The

WRRL has a well labelled and lockable Waste Storage Area on the first floor with up to

date and well maintained waste management records. It’s therefore to ascertain the

quantities of waste generated by the laboratory and whether it has all been disposed of

in the recommended way.



e. Good laboratory safety and sanitation. The laboratory has in place a health and safety

committee and safety management guidelines such as the Policy and Procedures

Manual and Guidelines for chemical safety handling, incident, injuries and accidents.

Safety measures in place were found satisfactory at the WRRL. Sanitation measures

and facilities were found sufficient and fully operational at the laboratory.

f. Fire fighting equipment provided mostly comprised smoke detectors, hose reels and

fire extinguishers. These were located in strategic positions in and within the

laboratory premise. The fire fighting extinguishers were in good conditions as records

showed they were regularly inspected. Information, warning, and direction sign posts

were placed in all strategic areas.

g. Availability of well maintained waste management records at the lockable waste storage area

located on the first floor of the building.

h. Compliance with handling and disposal of sharps (syringes, needles, lancets, and other

bloodletting devices) capable of transmitting infection are used only once and are properly

discarded in puncture resistant containers that are not overfilled.

In conclusion, the assessment and the annual peer review report carried out in March 2017

indicates the general compliance of the WRRL in most of the areas audited.

5.3.2 Gaps identified

From the socioeconomic angle, the project comes with positive impacts. These include

job creation, improvement of the local economy and as a source of revenue to the local

and national governments. However, at this stage of project development, there are a

number of areas that need attention to ensure that the project meets acceptable

environmental and social performance and sustainability.

Like many health facilities in Kenya, the main challenge facing the WRRL operation

continues to be healthcare waste management (HCWM). Areas of particular concern in

HCWM practice involve how waste incineration and wastewater removal are treated, as

both have broader impacts beyond the level of individual facilities.

Waste at the facilities is disposed of by burning in an open pit and the sharps in a ‘local

incinerator’. The County Government incinerator malfunctioned on 20th January 2016

having been commissioned in June 2015. As a result, a ‘local incinerator’ for disposal of

sharps and a shallow burning pit are being used for the disposal of the HCW (Figure 1 &

Figure 2 below).



Figure 1: showing the ‘local incinerator’

Figure 2: Showing the open pit burning site



Figure 3: Showing the new modern incinerator under construction.

Health Care wastes (HCW) include sharps (syringes, disposable scalpels, blades, etc.), non-

sharps (swabs, bandages, disposable medical devices, etc.), blood and anatomic waste (blood

bags, diagnostic samples, body parts, etc.), chemicals (solvents, disinfectants, etc.),

pharmaceuticals, and others, and may be infectious, toxic, create injuries or be radioactive.

The Wajir County Government has contracted the HCWM and general cleanliness at the

facilities to Saelf Cleaning Services Company. During the assessment no complaint was raised

against the service provision of the company. The company is responsible for availing all the

waste collection materials as per the different waste categories and provision of PPEs to the

waste handlers and also for the transportation of the waste to the disposal site located behind

the laboratory.

Saelf Cleaning Services Company however did not have a NEMA license to collect and dispose

of healthcare waste and to manage other types of solid waste at the time of assessment. Thus,

Saelf’s operation was not in compliance with the stipulations of the Environmental Management

and Coordination (Waste Management) Regulations, 2006.

The Health and Safety Officer at the Wajir District Hospital and the Bio-safety Officer at the

Laboratory supervises the waste management at the respective facility.



The assessments held at the facility highlighted various challenges and deficiencies of the

HCWM system:

1. Shallow, unlined and overfilled burning pit.

Transmission of disease through infectious waste is the greatest and most immediate

threat from healthcare waste. If waste is not treated in a way that destroys the pathogenic

organisms, dangerous quantities of microscopic disease causing agents - viruses, bacteria,

parasites or fungi - will be present in the waste. These agents can enter the body through

punctures and other breaks in the skin, mucous membranes in the mouth, by being

inhaled into the lungs, being swallowed, or being transmitted by a vector organism.

Unlined pits can easily contaminate groundwater if the pits have been dug below the

water table. Wajir is known to have a low water table and there’s therefore need to align

the pits with bricks or polythene.

2. Unrestricted access to the burning site.

Open access to disposal area allows insect and animal vectors to spread pathogens

contained in he waste. Wastepickers, health workers and children at play are directly

exposed to infectious agents.

Figure 4: Showing animals scavenging waste at the burning site taking note

of the neighboring staff quarters and the large quantities of plastics.



3. Burning of waste containing plastics and proximity of the disposal site to the staff

quarters.

This is not only a violation of the laws in place but also a threat to the people and the

environment at large. There are no measures for emission control in place, and can

therefore be a source of air pollution, putting the community at risk of diseases like upper

respiratory tract infection.

This is because dioxins and furans are released from incomplete combustion processes

that characterize low temperature burning of hazardous wastes that are known to contain

carcinogenic materials such as various plastics. Thus, persistent organic pollutants (PoPs),

acidic and corrosive fumes are released which are inhaled by adjacent populations to

HCFs, who themselves are unaware of the ill respiratory effects of the smoke plumes.

Additionally, the release of pathogens from incomplete combustion poses other public

health risks

From the interviews conducted, already there are complaints from the staff quarters

concerning the smoke and smell emanating from the onsite waste burning. The quarters

are adjacent to the waste burning site (Figure 4).

4. Scattered broken sharps at the ‘local incinerator’.

Even if disinfected, sharps in ashes still pose physical hazard.



Figure 5: Showing scattered broken sharps at the ‘local incinerator’

5. Manual Waste Transportation

Waste is transported manually to the disposal and burning site, putting the waste

handlers at risk of injuries and infections.

5.3.3 Conclusion and Actions required

The operation and maintenance phase of the laboratory meets the safeguards requirements in

terms of staff health and safety and quality of service. This finding is consistent with the

improved score of the laboratory, as measured through the SLIPTA composite scores. The

laboratory management shall however enforce the existing regulations to ensure that safety

and quality measures are fully applied.

Finally, healthcare waste disposal can be improved at the facilities with the management

setting up sustainable measures for waste management (waste burning) and enforcement of

the existing regulations.

Taking into account the prepared ESMP for the project operation phase, a revised

Environmental and Social Monitoring and Mitigation Plan (ESMMP) (Table 3) has been

developed with regard to the formulated recommendations to assist the proponent in

mitigating the non-compliance issues identified during the audit and for continuous

improvement. It is noteworthy that key factors and processes may change in the course of

the project life and considerable provisions have been factored for dynamism and flexibility

of the ESMMP. As such, the EMMP will be subject to a regular regime of periodic review.



Table 3: Action plan (ESMMP) to address potential adverse effects during the operation phase at the WRRL

Component Action/Mitigation Measures Monitoring Required

Indicators Evaluation Monitoring

responsibility

Cost Estimate (KShs.)

Waste Generation & Management

▪ Consider practices & procedures to minimize waste generation without sacrificing patient hygiene and safety considerations;

▪ All waste to be handled and managed in accordance with the Environmental Management and Coordination (Waste Management) Regulations of 2006;

▪ Transport waste to storage areas on designated trolleys which should be cleaned and disinfected regularly;

▪ Ensure construction of the new incinerator meets the standards specified in the Environmental Management and Coordination (Waste Management) Regulations of 2006 and applicable international standards.

▪ Monitor implementation to ensure proper management of the incinerator once completed.

▪ Implement & check record keeping for temperature, waste segregation & quantities of waste arriving for incineration.

▪ Increased monitoring by the lead agency, NEMA.

▪ Assess implementation of revised EMMPs

▪ Efficient solid waste management.

▪ Records/Logs of solid waste quantities.

▪ Proper waste segregation

▪ Waste management training programs

Reports on

▪ Anomalies in segregation practices of waste arriving at incinerator;

▪ Incinerator functioning (upper limit temperatures obtained; liner cracking etc.); (c) exhaust venting; (d) complaints from adjacent community etc.

▪ Compliance with the EMCA requirements for the annual EA report

▪ Public Health Officer

▪ Health and Safety committee

▪ Bio-safety committee.

▪ EAPHLNP project management unit.

▪ NEMA

2M



Collection, management and disposal of Healthcare waste and other solid wastes.

County Government of Wajir to ensure waste handling is done by a company which is duly licensed by NEMA

▪ Verification of waste transportation licenses from NEMA.

▪ Verification of tracking documents vis-à-vis waste generation records

▪ Valid NEMA licenses for the management of all types of waste, including for healthcare waste.

▪ Waste disposal records to be monitored continuously

Annual EA report ▪ Bio-safety committee.


▪ NEMA

0.5M

Occupational health and safety

▪ Development and implementation of operational guidelines/directives on health and safety during the operations of the lab.

▪ Conduct statutory assessments i.e. risk assessments, fire safety audits and Occupational Safety and Health audits annually through licensed advisors and auditors by the Directorate of Occupational Safety and Health Services (DOSHS);

▪ Conduct basic occupational training programs and statutory trainings under OSHA, 2007 and Rules under it. i.e. basic first aid, fire safety training, and Occupational Safety and Health committee training through approved training institutions by the DOSHS;

▪ Conduct drills at reasonable

▪ Visit sites and use Assessment tool in (APPENDIX 1: HCWM ASSESSMENT SURVEY TOOL.) to assess compliance

▪ Periodic inspections by the EAPHLNP management team

▪ Health & safety committee to inspect the available fire detection and fire fighting equipment and address their efficiency and

▪ Efficient solid waste management.

▪ Health and safety operational guidelines/directives are developed and implemented.

▪ Occupational Safety and Health audits

▪ Annual Fire risk assessments

▪ Bio-safety, occupational safety and health trainings.

▪ Safety and Health committees.

▪ Incidents monitoring

▪ No Injuries or

Annually

Compliance with the OSHA requirements for the annual audit report.

Compliance of the air measurements with the permissible levels under the air quality regulations 2014.

▪ Health and Safety committee

▪ Bio-safety committee.


▪ NEMA

3.5M



intervals to test the disaster preparedness level at the workplace, using the results to improve the response mechanisms;

▪ Ensure proper PPE is consistently available to staff and that this is used.

▪ Regular training for emergency response.

▪ Restriction of access to high risk areas to authorized personnel only i.e. radiation rooms, surgery rooms;

▪ Air quality measurements

adequacy.

▪ Weekly checks of PPE use in Year One.

▪ Assess implementation of revised EMMP.

▪ Reports on air measurements from the incinerator and open pit burning

cross infections.

▪ Safety and Health management and monitoring plan

▪ Annual documentation of PPE checks.

▪ Reduced complaints from the staff quarter residents

Lack of

enough

vegetation

cover around the Health

Care Facility

▪ Implement an appropriate re-vegetation programme to restore the site to its original status.

▪ Consider use of indigenous plant species in re-vegetation.

▪ Trees should be planted at suitable locations so as to interrupt slight lines (screen planting), between the adjacent residential area and the development.

▪ Harvest rainwater from roof for non-portable uses e.g. cleaning and watering plants during the dry season.

▪ The management should plan for the establishment of trees and other aesthetic plants within and around the facility

▪ Observation Continuous ▪ WRRL Management

10,000

per month



CHAPTER SIX: CONCLUSION AND RECOMMENDATIONS

The project can be termed as a success owing to the positive sentiments shared with

regard to the provision of quality health care which is accessible and accommodative to

all Wajir town residents and beyond.

From the socioeconomic angle, the project comes with positive impacts. These include

job creation, improvement of the local economy and as a source of revenue to the local

and national governments. However, at this stage of project development, there are a

number of areas that need attention to ensure that the project will meet acceptable

environmental performance and sustainability. Most of the issues have been discussed

in the earlier sections of this report and should be followed up and implemented.

For the purposes of compliance and continuous improvement, the following

recommendations were formulated;

6.1 Improve the on-site burning of waste

The on-site burning can be further improved by digging another open pit but above the

water table or lined with clay or plastic, and protected by a fence or other effective barrier

(e.g., rows of thorny brush).

Appropriate handling, treatment, and disposal of waste by type can help to reduce costs and

does much to protect public health.

Spattered broken sharps at the burning site pose a health hazard and their frequent collection

will reduce the accidents.

6.2 Waste Transportation

Acquisition of adequate and dedicated number of transport bins and trolleys with separate

ones for infectious waste to be drawn on paved surfaces to the waste treatment site.

6.3 Proper Incinerator Management.

The old incinerator malfunctioned due to non-adherence to the six month maintenance

schedule leading to the gasket failure. With the expected completion of the modern

incinerator, the management should put incinerator management at the pinnacle of the

HCWM program.

Not to be treated cavalierly by being manned by casual labourers (often not well educated)

for proper operation, keeping records on temperature levels attained, weighing and

recording the waste by segregated category (extremely hazardous, hazardous, or general).



This is an important job pivotal to HCWM and it requires dedicated effort of a well trained

professional.

Most of the challenges and deficiencies highlighted earlier can be well addressed with the

completion and proper operation of the modern incinerator.

The need to expedite the completion of the modern incinerator should be addressed through

finalization of the requested EIA to avert further delays and ensure compliance with national

environmental laws and regulations.

6.4 Monitoring

The National Environment Management Authority (NEMA) is a body that was

established by an Act of parliament as the principal agency in charge of coordination,

monitoring and supervision of all environmental management issues in the country.

This it does in coordination with the County Environmental officers resident in every

County in Kenya. Although NEMA largely relies on a system of ‘self compliance’,

improved monitoring will ensure the facility receives technical guidance that would be

derived from the monitoring visits to enable them take corrective or preventative

action where possible.

There is also need to monitor and report on the implementation of environmental

management tools like ESMF, EMP prepared at the beginning of the project so as to keep

historical records and facts. This would help in improving compliance and serve as a written

basis for other environmental initiatives like environmental auditing.

6.5 Initiate Waste Recycling System

Organisations and cities will always have a challenge in the disposal of wastes, the by

products and the residual wastes thereof. With traditional techniques being flawed, the need

for disposal has been made harder because of the legal requirements in all countries, which

require safe disposal.

The need to produce without pollution is the preferred model and the strategy of waste

minimization is seen as the best way forward. This is particularly relevant; where large

quantities of wastes are produced this always pose formidable disposal problems.

Waste minimization usually benefits the waste producer in terms of costs for; the purchase of

goods, waste treatment, and disposal of hazardous waste. It is important to investigate

feasible options for waste minimization / reduction, recycling. The procurement department



and the lab head should be involved in making these important decisions on the choice of

health products or equipment for use.

Significant reduction of waste generated may be encouraged by the implementation of

certain policies and practices such as;

➢ Source reduction: measures such as purchasing restrictions to en-sure the selection of

methods or supplies that are less wasteful or generate less hazardous waste.

➢ Recyclable products: use of materials that may be safely recycled, either on-site or off

site.

➢ Good management and control practices: apply particularly to the purchase and use of

chemicals and pharmaceuticals. i.e. frequent ordering of small quantities of supplies

and using old batches of a product first.

Besides the above recommendations, a comprehensive Environmental and Social

Management and Monitoring Plan (ESMMP) has been formulated and sufficient

mitigation measures for the operational non-compliance have been proposed therein. In

this regard, it’s therefore recommended that the laboratory management fully

implement the ESMMP (Table 3).



CHAPTER SEVEN: REFERENCES

i. Kenya gazette supplement number 56. Environment Impact Assessment and Audit

Regulations 2003. Government printer, Nairobi.

ii. Kenya gazette supplement number 69. Environmental Management and Coordination

(waste Management) Regulations 2006. Government Printer Nairobi.

iii. Kenya gazette supplement number 68. Environmental Management and Coordination

(water quality) Regulations 2006. Government Printer.

iv. Kenya gazette supplement Acts 2000, Environmental Management and Coordination

Act Number 8 of 1999.Government Printers, Nairobi.

v. Operational Policies, The World Bank Operational Manual, Jan 1999.

vi. EIA Project report for the proposed laboratory for Wajir district hospital in Wajir,

2012.

vii. USAID Kenya environmental compliance health care waste management in Kenya,

2012.

viii. Ministry Of Health Kenya, The National Health Care Waste Management Plan 2016 –

2021

ix. Ministry of Health Kenya, 2007, National Policy on Injection Safety and Health Care

Waste Management.

x. Parker MT (1978). Hospital-acquired infections: guidelines to laboratory methods.

Copenhagen, World Health Organization Regional Office for Europe (European

Series, No.4).

xi. Republic of Kenya, Reversing the Trends: The Second National Health Sector

Strategic Plan-Annual Performance Report July 2007–June 2008 (Annual Operational

Plan 3 Report)

xii. WHO, 2005, Decision making Guide, Management of Solid Health Waste at Primary

Health Care Centres.



CHAPTER EIGHT: APPENDICES

APPENDIX 1: HCWM ASSESSMENT SURVEY TOOL.

The following is an example of the 50 samples collected under this HCWM Assessment. The findings reported in the previous

sections reflect the full collection and analysis of the data collected.

OPERATION AREA/ACTIVITY

ITEM No.

PARAMETER (CHECKLIST ITEMS) COMMENTS

Laboratory unit 1 Do you do cultures and sensitivity tests?

1.2 If yes do you autoclave highly infectious waste?

1.21 For waste water disposal in the lab, Ask following questions:

Is Waste water mixed with other waste water into one common drain

Is waste water Pretreated prior to release into to the common drain.

1.3 Is another method used?

1.31 Is a bio-safety hood/cabinet provided?

1.32 Is the hood functioning?

1.33 Are safety boxes provided?

1.34 If yes above were they three quarters full [also above 3/4 full applies]

1.35 Are the bins provided with a foot pedal/ alternative lid technology?

1.4 Where do you dispose the samples in the lab[ blood, urine, sputum etc];

1.41 Red bin

1.42 Yellow bin

1.43 Black bin

1.5 Are the bins labeled correctly as indicated below?

Red (highly infectious waste )

Yellow ( infectious waste )

Black ( general waste )

1.6 Do you see a container with disinfectant

1.61 Do you see Standard Operating procedures for handling blood/waste spillages?

1.62 Do you see segregation posters?

2.7 Does the x ray operator have the radiation monitoring badge?

Health Care Waste Handler

2 For the health care Waste handler working in the incineration unit, is she/he wearing:

2.1 Boots?

2.2 Helmets?

2.3 Gloves?



2.4 Respirator?

2.5 Industrial Gloves

2.6 Apron/Overall?

Waste treatment practices

3 Are wastes collected daily?

3.1 Are wastes treated with a frequency appropriate to the climate and season?

3.1.1 Warm season in warm climates within 24 hrs

3.1.2 In the cool season in warm climates within 48 hrs

3.1.3 In the warm season in temperate climates within 48 hrs

3.1.5 In the cool season in temperate climates within 72 hrs

3.2 Are wastes disinfected before disposal?

3.3 Are wastes being burned in the open air, in a drum or brick incinerator, or a single-chamber incinerator?

3.4 If not are they being buried safely (in a pit with an impermeable plastic or clay lining)?

3.5 Is the final disposal site (usually a pit) surrounded by fencing or other materials and in view of the facility to prevent accidental injury or scavenging of syringes and other medical supplies?

3.6 If the waste is transported off-site, are precautions taken to ensure that it is transported and disposed of safely?

Health Care Handling & Waste storage Area.

4 Please observe the presence /absence of the following:

4.1 Are all doors locked?

4.2 Holes in the walls?

4.3 Vents?

4.4 Leakage from roofing?

4.5 Pot holes?

4.6 Tilting floor toward the door?

4.7 Is the designated area labeled:

4.71 Highly infectious Waste?

4.72 Infectious Waste?

4.73 Sharps waste?

4.74 General waste

4.8 Is a record book available?

4.81 Are records for waste received at the storage unit visible for each of the last 7 days?

4.9 Minimization, reuse, and recycling procedures?

Incinerator/Waste treatment area

5 Do you see an incinerator?

5.1 If no, ask to see records for HCW disposal that is outsourced.

5.2 If outsourced, are there records proving outsourcing at least for the past 4 weeks?

5.3 Do you see an incinerator shed?



5.4 If there is an incinerator, is the incinerator area fenced?

Is the incinerator door locked?

Do you see at least 4 temperature readings recorded for the last 6 weeks?

Is there a Standard Operating Procedure document available within the incineration unit?

Is there an incineration log? (Last 4 weeks/at least once per week)

Go to records proceeding the month of January. Do you see entries for incinerator use that week?

Go to the preceding month of June. Do you see at least four entries for incineration?

Is there an ash pit visible in the vicinity?

Do you see a concrete slab covering the ash pit?

Is the distance between the principal incinerator and the community greater than 30 meters?

Is the distance between the principal incinerator and any patient ward greater than 30 meters?

Is there any cropping within 300metres of the incinerator?

Waste Transport Unit 6 Are waste transport trolleys with bins provided?

6.1 Are they color coded? (Red, yellow & black)

6.3 (Ask the person) Is the floor smooth enough to transport the waste from generation to disposal without spillage?

Is Health Care waste transported by mixing all types of wastes together[red, yellow, black]

Is each type of waste transported separately to the waste storage room

Staff Training, Practices, and Protection

7 Staff trained in safe handling, storage, treatment, and disposal.

7.1 Do staff exhibit good hygiene, safe sharps handling, proper use of protective clothing, proper

7.2 Packaging and labeling of waste, and safe storage of waste?

7.3 Do staff know the correct responses for spills, injury, and exposure?

7.4 Protective clothing available for workers who move and treat collected infections waste such as surgical masks and gloves, aprons, and boots.

7.5 Good hygiene practices. Are soap and, ideally, warm water readily available workers to use and can workers be observed regularly washing.

7.6 Workers vaccinated for against viral hepatitis B, tetanus infections, and other endemic infections for which vaccines are available.

Written Plans and Procedures

8 Written waste management plan Describing all the practices for handling, storing, treating, and disposing of hazardous and non-hazardous waste, as well as types of worker training required.

8.1 Internal rules for generation, handling, storage, treatment, and disposal of healthcare waste.

8.2 Clearly assigned staff responsibilities that cover all steps in the waste management process.

8.3 Staff waste handling training curricula or a list of topics covered.

8.4 Waste minimization, reuse, and recycling procedures



APPENDIX 2: QUESTIONNAIRE FOR STAKEHOLDER CONSULTATIONS



APPENDIX 3: OPERATIONAL PHASE ESMP

The necessary objectives, activities, mitigation measures, and allocation of responsibilities pertaining to prevention, minimization and monitoring of

significant negative impacts and maximization of positive impacts associated with the operational phase of proposed Health Care Project are outlined in the

table below.

Table 7: Environmental Management Plan for the operation phase

Environmen Tal Concerns

Mitigation Responsibility Monitoring means Monitoring frequency

Monitoring by

Duration & budget

Safety Likely open

Such holes should be filled with soil or covered with a concrete cover should be fitted with openable grills.

Management Observation to ensure that any open pits

One off activity

An EIA Expert and the

Ksh.20, 000

Health and Safety For Patients and general public

Waste bins should never be placed within the patients’ waiting shades, especially those holding medical waste

Management Observation to ensure that this is implemented

Continuous activity

An EIA Expert and the management

Ksh.5, 000 per month

Health and Safety Lack of protective gears

All staff within the facility should be in protective gears at all times


Continuous activity

An EIA Expert & the management

Ksh.5, 000

Health and Safety within the facility Accidents

Reporting all incidents and accidents to include details of: -The nature of the accident or incident; The place and time of the accident or incident; The staff who were directly involved; Any other relevant circumstances


Continuous activity


Health and Safety spillages

-Evacuate the contaminated area; Decontaminate the eyes and skin of exposed personnel immediately; Inform the designated person (usually the Waste Management Officer), who should coordinate the necessary actions.; Determine the nature of the


Continuous activity




spill; Evacuate all the people not involved in cleaning up if the spillage involves a particularly hazardous substance; Provide first aid and medical care to injured individuals; Secure the area to prevent exposure of additional individuals; Provide adequate protective clothing to personnel involved in cleaning-up; Limit the spread of the spill; Neutralize or disinfect the spilled or contaminated material if indicated; Collect all spilled and contaminated material. [Sharps should never be picked up by during this process, because this will spread the contamination. The decontamination should be carried out by working from the least to the most contaminated part, with a change of cloth at each stage. Dry cloths should be used in the case of liquid spillage; for spillages of solids, cloth impregnated with water (acidic, basic, or neutral as appropriate) should be used. -Rinse the area, and wipe dry with absorbent cloth. -Decontaminate or disinfect any tools that were used. -Remove protective clothing and decontaminate or disinfect it if necessary. -Seek medical attention if exposure to hazardous material has occurred during the operation.

Latrines and other public areas

The walls and floors of the latrines and walls of public areas should be fitted with white smooth tiles for easy cleaning


One off activity


Ksh.300, 000



Water harvesting and storage facilities

Initiate roof water harvesting and install water storage tanks

Management Observation are fixed One off activity


Ksh.200, 000

Poor waste disposal

-Construct a well functioning incinerator -sort waste at source -connect all laboratory sink to a functioning biomedical liquid waste treatment system.

Management Observation

A continuous activity to ensure that appropriate solid and liquid waste management is established


Ksh.500,000

Lack of Enough vegetation cover around the Health Care Facility

-The management should plan for the establishment of trees and other aesthetic plants within and around the facility

Management Observation

A continuous activity


Ksh.10,000



APPENDIX 4: MINUTES TO THE STAKEHOLDERS MEETING

Minutes of Consultations with

Stakeholders of Wajir Town on the

Environmental & Social Impacts of

the

Constructed Wajir Regional Referral

Laboratory under the World Bank

funded EAPHLN Project.



Introduction

The Consultant engaged the stakeholders to gather knowledge, concerns and their awareness

of the constructed new public health laboratory (Wajir regional referral laboratory) at the

Wajir District Hospital under the East Africa Public Health Networking Project. This was

held on 6th June 2017 at Wajir Guest House in Wajir town and follow-up discussions were

conducted on the 7th June 2017. The Consultant together with Mr. Abbey (Head of WRRL)

engaged the local community to share their knowledge on any social and environmental

hazards experienced at the construction phase, any benefits and complaints since the

commissioning of the constructed laboratory and the way forward.

Agenda

To engage the community of Wajir county in Wajir town as key stakeholders on the

environmental and social performance of the constructed WRRL.

Minute 1

The meeting started at 10:00 am

The Consultant took the public through the project step by step as follows:

a. Introduction of the project - East Africa Public Health Networking Project (EAPHLN) that

included WRRL as one of the locations to benefit from the establishment of a new public

health laboratory.

b. The objective of the audit ascertain the effectiveness of the safeguard policies put in place

before and during the construction and operation phases.

Participants’ views and concerns about the project During the Construction and operation

phases were sought using simple questions and recordings for those able to read and write.

They were encouraged to freely express their views, and to cite any complaints in the

questionnaire based on the explanations provided by the Consultant. The Consultant engaged

the local community Representatives and officials on one to one basis to gather insight on the

overall performance of the project. All the participants were aware of the project existence

and were enthusiastic about the gains and services, including the increase in the number and

type of laboratory diagnostic tests, leading to better healthcare management and shortening of

the time patients will spend waiting for laboratory results.

The team then explained to participants that there are potential risks associated with the

project during construction and during the operational stages. In view of the project’s

magnitude and activities, it lead to some positive impacts, such as the creation of job

opportunities (both directly and indirectly), and provision of the much-needed hospital

laboratory services for the people of Wajir and its surroundings.

One of the participants narrated the youth (from the surrounding communities) job creation as

one of the most realized impact not to mention that the unemployment was a major concern.

Another talked of the laboratory services having indirectly spruced up the gain of business

opportunities of the local business community courtesy of the increased activity at the district

hospital by the construction.



To minimize public health hazards posed by the project construction, some measures were

taken, including scaffolding/fencing of the site during the construction period, provision of

protective gears to all workers, provision of sanitation facilities to the workforce during the

construction period, provision of first aid kits on site, erection of the appropriate signage to

direct the public and provisions were made in case of fires and emergency exits proposed.

The Consultant engaged the participants on whether the proposed measures were

implemented and effective.

Most of the people acknowledged the fencing off of the construction site and they fully

supported the work since they knew most of the workers employed at the site. They

supported the wearing of uniform protective gear and noted that the hospital had provided

one of the public ablutions for the workers at the site.

At the operationalization of the laboratory they noted quicker delivery of tests (services)

serving the communities in Wajir town and others from within the County, including patients

from different regions coming for services at the facility. The influx has created a bigger

market opportunity for the business community and improved social interactions.

The participants expressed satisfaction of the employment opportunities created for children

and several clinical officers and nurses. One resident reiterated that the support for

tuberculosis testing was very important to him since the disease was a big challenge to the

poor people in the vicinity.

Despite the numerous sentiments shared, the participants raised concerns with the project

operationalization especially with the open pit dumping and burning of the waste collected

from the Laboratory and the Wajir District Hospital. Some of the members complaint of the

smoke and strong stange emanating from the waste burning, regretting the failure of the

County Government incinerator located behind the Laboratory. The participants

(complainants) were later realized to be the staff residing in the staff quarters adjacent to the

poorly fenced dumping and burning site. They talked of the need to dig another pit for

dumping since the current one was filled up causing littering in the area and their desire to

have the site relocated to save them from the persistent toxic fumes. As part of the mitigation,

the Consultant informed the participants that a modern incinerator will be installed and that

all dangerous hospital waste will be disposed off through the incinerator and thereby creating

a clean environment.

The stakeholders included members of the community such as professionals, business people,

travelers and members of Non Governmental Organizations who were willing to contribute to

the consultation at the stakeholder’s forum. Attached please find the list of participants.

Suggestions from participants

▪ The need to dig another pit for dumping since the current one was filled up causing

littering and affecting the aesthetic value of the area;

▪ Proper fencing of the dumping site to prevent access of vectors to the infectious

waste;



▪ Relocation of the burning site (off-site burning of waste) to save them from the

persistent toxic fumes.

▪ Community actors highlighted the need to educate the public about the importance of

seeking health services through educational materials.

▪ Continual monitoring and oversight on the project environmental impact and of other

impacts is important.

▪ Means of evaluating performance should be developed jointly with the local public

health office and the supporting partner, the WB.

CONCLUSION

I take this opportunity to appreciate support from the EAPHLN Project Management Unit

and the WRRL management for this exercise that has definitely had a positive impact on the

community. The implementation of the recommendations will ensure sustainability and

continual improvement of the project.

Report prepared by

Bonventure N. Okanga

Consultant



APPENDIX 5: STAKEHOLDERS MEETING PARTICIPANTS No. Name Designation/profession/jo

b

Email/telephone

1. Winfred Jerusha Health Officer – Wajir

district hospital

0728659634

2. Mr. Siachi Head – NEMA Wajir 0720328873

3. Mohamed A.

Muktar

Businessman [email protected]

4. Abdirahman M

Abdille

PHO [email protected]

5. Farhiya H. Ali Grocery [email protected]

6. Sahara Humey Sub-County Laboratory

7. Abdiaziz Omar Teacher [email protected]

8. Abdullahi

Abdille

Nurse [email protected]

9. Mohamed A.

Abdille

Driver

10. Fatuma Farah Nurse

11. Muktar Hassan [email protected]

12. Mohamed Hussein Businessman [email protected]

m

13. Osongo Justus Lab Tech

14. David Okoth Head teacher - Faulu Sec 0729273353

15. Chief Ibrahim Wajir Township 0720597941

16. Halima Omar Business lady

17. Haji Rashid

Yakub

Hotel 0722307892

18. Ambia Ahmed Student Wajir college

19. Shukri Ali

Mohamed

Clinical Officer [email protected]

20. Abdullahi Adow

Hamza

Electronic business 0724421777

21. Nasra H. Ali Business lady in Wajir

town

0723977075

22. Josphine PHO [email protected]

23. Elama Abdi Dep Disable 0722179214

24. Mercy Munene Clinical Officer 0720212628

25. Fatuma Sahara

Ahmed

Housewife 0727441111

26. Mohamed hasan

abdi

Driver – golden coach 0720016741

27. Maryan Ali Grocery 0724810668

28. Hadha Adan Veterinary Officer 0727918843

29. Mzee Abdille Businessman 0724815753

30. Jenniffer Okoth Dental Technician 0711887165

31. Hassan Issack KPLC 0723970185

32. Maalim

Abdullahi

Imam 0720341514

mailto:[email protected]












APPENDIX 6: CONSTRUCTION PHASE ESMP.

Table 6: Environmental monitoring/Management plans for the construction phase.

Expected Negative Impacts

Recommended Mitigation Measures

Responsible Party Time Frame Estimated Cost (Kshs)

High Demand of Raw materials

1. Source building materials from local suppliers who use environmentally friendly processes in their operations.

Resident Project Manager & Contractor

Throughout construction period

Part of the main budget

2. Ensure accurate budgeting and estimation of actual construction material requirements to ensure that the least amount of material necessary is ordered.



3. Ensure that damage or loss of materials at the construction site is kept minimal through proper storage.



4. Use of some recycled/refurbished or salvaged materials to reduce the use of raw materials and divert material from landfills.



5. Specify locations for trailers and equipment, and areas of the site that should be kept free of traffic, equipment, and storage.

Civil Engineer, Architect and Resident Project Manager

1 month

6. Designate access routes and parking within the site. Civil Engineer, Architect and Resident Project Manager

1 month

100, 000.00 7. Introduction of vegetation (trees, shrubs and grass) on open spaces and their maintenance, especially at the front side of the development

Architect, Resident Project Manager & Landscape specialist

Monthly to Annually

8. Design and implement and appropriate landscaping programme to help in re-vegetation of part of the project area after construction.

Architect & Landscape specialist

During the beginning phase of the project

Increased storm water, runoff and soil erosion

1. Roof water to be harvested and stored in underground/ground reservoirs for use in cleaning and in the toilets. To ensure the use of such water for the stated purposes, the building should be fitted with a dual water distribution system.

The Civil Engineer, Mechanical Engineer and Resident Project Manager

During the beginning phase of the project

100, 000.00

2. A storm water management plan that minimizes impervious area infiltration by use of recharge areas and use of detention and/or retention with graduated outlet control structure will be


1 month 50, 000.00



designed.

3. Apply soil erosion control measures such as leveling of the project site to reduce run-off velocity and increase


1 months

Increased solid Waste generation

1. Use of an integrated solid waste management system i.e. through a hierarchy of options: reduction, sorting, re-use, recycling and proper disposal



50,000

2. Through accurate estimation of the sizes and quantities of materials required, order materials in the sizes and quantities they will be needed, rather than cutting them to size, or having large quantities of residual materials.


One off

3. Ensure that construction materials left over at the end of construction will be used in other projects rather than being disposed of.


One off

4. Ensure that damaged or wasted construction materials including cabinets, doors, plumbing and lighting fixtures, marbles and glass will be recovered for refurbishing and use in other projects


One off

5. Donate recyclable/reusable or residual materials to local community groups, institutions and individual


One off

6. Use of durable, long-lasting materials that will not need to be replaced as often, thereby reducing the amount of construction waste



7. Provide facilities for proper handling and storage of construction materials to reduce the amount of waste caused by damage or exposure.


One off

8. Purchase of perishable construction materials such as paints should be done incrementally to ensure reduced spoilage of unused materials



9. Use building materials that have minimal or no packaging to avoid the generation of excessive packaging waste



10. Use construction materials containing recycled content when possible and in accordance with accepted standards.



11. Reuse packaging materials such as cartons, cement bags, empty metal and plastic containers to reduce waste at the site



12. Dispose waste more responsibly by dumping at designated dumping sites



Exhaust emission

1. Vehicle idling time shall be minimized Resident Project Manager & Contractor


50,000



2. Alternatively fuelled construction equipment shall be used where feasible; equipment shall be properly tuned and maintained



3. Sensitize truck drivers to avoid unnecessary racing of vehicle engines at loading/offloading points and parking areas, and to switch off engines at these points



Noise and vibration

1. Sensitize construction vehicle drivers and machinery operators to switch off engines of vehicles or machinery not being used.



50,000

2. Sensitize construction drivers to avoid gunning of vehicle engines or hooting especially when passing through sensitive areas such as churches, residential areas and hospitals



3. Ensure that construction machinery are kept in good condition to reduce noise generation



4. Ensure that all generators and heavy duty equipment are insulated or placed in enclosures to minimize ambient noise levels.



5. The noisy construction works will entirely be planned to be during day time when most of the neighbors will be away at work.



Increased energy consumption

1. Ensure electrical equipment, appliances and lights are switched off when not being used




2. Install energy saving fluorescent tubes at all lighting points instead of bulbs which consume higher electric energy



3. Ensure planning of transportation of materials to ensure that fossil fuels (diesel, petrol) are not consumed in excessive amounts



4. Monitor energy use during construction and set targets for reduction of energy use.



Generation of wastewater

1. Provision of means for handling sewage generated by construction workers

Mechanical Engineer, proponent and Resident



2. Conduct regular checks for sewage pipe blockages or damages since such vices can lead to release of the effluent into the land and water bodies


One off

3. Monitor effluent quality regularly to ensure that the stipulated discharge rules and standards are not violated



Machinery/ equipment safety

1. Arrangements must be in place for the medical examination of all construction employees before, during and after termination of employment

Resident Project Manager, Developer & Contractor

Continuous 50,000



2. Ensure that machinery, equipment, personal protective equipment, appliances and hand tools used in construction do comply with the prescribed safety and health standards and be appropriately installed maintained and safeguarded


One off

3. Ensure that equipment and work tasks are adapted to fit workers and their ability including protection against mental strain


Continuous

4. All machines and other moving parts of equipment must be enclosed or guarded to protect all workers from injury

Resident Project Manager One off

5. Arrangements must be in place to train and supervise inexperienced workers regarding construction machinery use and other procedures/operations

Resident Project Manager Continuous

6. Equipment such as fire extinguishers must be examined by a government authorized person. The equipment may only be used if a certificate of examination has been issued


7. Reports of such examinations must be presented in prescribed forms, signed by the examiner and attached to the general register


Occupational health and safety risks during construction period and occupational phase

1. Well stocked first aid box which is easily available and accessible should be provided within the premises


One-off

50,000 2. Provision must be made for persons to be trained in first aid, with a certificate issued by a recognized body.


One-off

3. Fire fighting equipment such as fire extinguishers and hydrant systems should be provided at strategic locations such as stores.


One-off



APPENDIX 7: CONSULTANTS 2017 PRACTICING LICENSE.

Documents

Environmental & Social Audit Report · 2019. 7. 8. · East African Public Health Laboratory Networking Project (EAPHLNP) Wajir Regional Referral Laboratory – Environmental & Social