Trinidad and Tobago: COVID-19 Emergency Response Project (P173989): Environmental and Social Commitment Plan (ESCP) The Republic of Trinidad and Tobago Ministry of Health Trinidad and Tobago: COVID-19 Emergency Response Project (P173989) FINAL ENVIRONMENTAL and SOCIAL COMMITMENT PLAN (ESCP) May 24th, 2022 1|Page Trinidad and Tobago: COVID-19 Emergency Response Project (P173989): Environmental and Social Commitment Plan (ESCP) ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN 1. The Republic of Trinidad and Tobago (hereafter, the “Borrower�) is implementing the Trinidad and Tobago: COVID-19 Emergency Response Project (the “Project�) through the Ministry of Health (“MoH�). The International Bank for Reconstruction and Development (hereinafter, the “Bank�) has agreed to provide financing for the Project. 2. The Borrower shall carry out the Project in accordance with the World Bank Environmental and Social Standards (ESSs). This Environmental and Social Commitment Plan (ESCP) sets out material measures and actions, to be carried out or caused to be carried out by the Borrower, including timeframes of the actions and measures, institutional, staffing, training, monitoring and reporting arrangements, grievance management and the environmental and social assessments and instruments to be prepared or updated, disclosed, consulted, adopted and implemented under the ESCP and the ESSs, all in a manner acceptable to the Bank. 3. The Borrower is responsible for compliance with all requirements of the ESCP even when implementation of specific measures and actions is conducted by the Ministry referenced in 1. above. 4. Implementation of the material measures and actions set out in this ESCP shall be monitored and reported to the Bank by the Borrower as required by the ESCP and the conditions of the Loan Agreement, as amended. 5. As agreed by the Bank and the Borrower, this ESCP may be revised from time to time during Project implementation, to reflect adaptive management of Project changes and unforeseen circumstances or in response to assessment of Project performance conducted under the ESCP itself. In such circumstances, the Borrower shall agree to the changes with the Bank and shall update the ESCP to reflect such changes. Agreement on changes to the ESCP shall be documented through the exchange of letters signed between the Bank and the Minister in charge of MoH on behalf of the Borrower. The MoH shall promptly disclose the updated ESCP. 6. Where there are Project changes, unforeseen circumstances, or Project performance results in changes to the risks and impacts during Project implementation, the Borrower shall provide additional funds, if needed, to implement actions and measures to address such risks and impacts. 2|Page MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY/AUTHORITY MONITORING AND REPORTING A REGULAR REPORTING Prepare and submit to the Bank regular monitoring reports on the environmental, Quarterly reporting throughout Project Project Implementation social, health and safety (ESHS) performance of the Project, including but not limited implementation submitted within 45 days Unit (PIU) within the to the implementation of the ESCP, status of preparation and implementation of E&S after the end of each reporting period, Ministry of Health (MoH) instruments required under the ESCP, stakeholder engagement activities, and starting from the Effective Date of the grievances log. Project. Mid-term and completion reports shall also be submitted, as requested by the Bank, during Project implementation. B INCIDENTS AND ACCIDENTS Promptly notify the Bank of any incident or accident related to the Project which has, Notify the Bank within 48 working hours PIU/MoH or is likely to have, a significant adverse effect on the environment, the affected after learning of the incident or accident. A communities, the public or workers, including, inter alia, any COVID-19 outbreak in the report would be provided within a Project area, improper disposal of healthcare wastes from diagnosis, treatment, and timeframe acceptable to the Bank, as immunization activities, cases of sexual exploitation and abuse (SEA), and sexual requested. harassment (SH), and incidents related to security forces/personnel following incident classification defined in the ESMF. Provide sufficient detail regarding the incident or accident, indicating immediate measures taken or that are planned to be taken to address it, and any information provided by any contractor and supervising entity, as appropriate. Subsequently, as per the Bank’s request, prepare a report on the incident or accident and propose any measures to prevent its recurrence. ESS 1: ASSESSMENT AND MANAGEMENT OF ENVIRONMENTAL AND SOCIAL RISKS AND IMPACTS 3|Page MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY/AUTHORITY 1.1 ORGANIZATIONAL STRUCTURE The PIU already established under the Ministry of Health (MoH) shall be responsible An environmental and social specialist shall PIU/ MoH for the implementation of the Project. The MoH shall hire and maintain throughout be contracted or assigned before the first Project implementation one (1) environmental and social specialist with qualifications disbursement for Component 2 but no and experience acceptable to the Bank. In addition, the MoH has already assigned and later than July 15, 2022. The specialist and shall maintain officials as the Environmental Focal Point and Social Focal Point. The the focal points shall be retained MoH shall ensure adequate time is allocated for the specialist and the Focal Points for throughout Project implementation. Before the Project’s environmental and social risk management. The Project Coordinator shall the appointment is complete, the Focal have overall responsibility for coordinating the environmental and social aspects with Points shall provide the necessary support the support of the environmental and social specialist and respective focal points. The to the management of E&S risks and MoH shall also convene a technical oversight committee with the relevant technical impacts. lead for environmental and social risk management. Adequate resources shall be allocated to support management of the ESHS risks of the Throughout Project implementation. PIU/MoH Project. 4|Page 1.2 ENVIRONMENTAL AND SOCIAL ASSESSMENT AND ENVIRONMENTAL AND SOCIAL MANAGEMENT PLANS a. Prepare/Update, adopt and disclose the ESMF to address risks and impacts a. The adoption and disclosure of the PIU/MoH related to the procurement and deployment of vaccines., including the ESMF, acceptable to the Bank, shall results of a rapid E&S assessment. The ESMF will assess the environmental occur no later than 60 (sixty) days after and social risks and impacts of proposed Project activities, in accordance with the Effective Date of the amendment ESS1, including ensuring that individuals or groups who, because of their to the Loan Agreement, and in addition particular circumstances, may be disadvantaged or vulnerable, have access to shall be a withdrawal condition for the development benefits resulting from the Project including, as relevant, Category 2 of the Loan Agreement. with regards to vaccines. The ESMF shall also build on a comprehensive review of the Code of Practice for Bio-Medical Waste Management and a rapid assessment of relevant incinerator facilities to determine whether they currently meet WB/WHO standards. The ESMF shall identify critical gaps (if any) and propose appropriate measures to overcome the gaps. b. The MOH shall ensure, document, and certify through a rapid environmental b. The rapid E&S assessment will be part and social assessment, that the activities subject to retroactive financing of the ESMF, and it will follow the same comply with the Environmental and Social Standards of the World Bank. The timeframe as 1.2. a. rapid E&S assessment shall be undertaken by the GoTT and the final report shall be integrated into the updated ESMF as described in 1.2.a above. The rapid assessment should confirm that adequate waste management practices, appropriate laboratory facilities, training of key staff on the use of the supplies and equipment that follows the Trinidad and Tobago’s ‘Code of Practice for Bio-Medical Waste Management’ and ‘Occupational Safety and Health Management Policy’ and the relevant World Health Organization (WHO) Guidelines for medical waste management, are implemented in a manner consistent with the ESSs. c. Prepare, disclose, adopt, and implement an Environmental and Social Management Plan (ESMP), Infection Control and Waste Management Plan c. Plans or instruments prepared, (ICWMP), Community Health and Safety Plan (CHSP), and any other adopted, and disclosed before the environmental and social management plans, measures or other instruments carrying out of the relevant Project required for the respective Project activities based on the assessment activities, and thereafter implemented process, in accordance with the ESSs, the ESMF, and other relevant Good throughout the carrying out of such International Industry Practice (GIIP) including relevant WHO Guidelines on activities. COVID-19 to, inter alia, ensure access to and allocation of Project benefits in a fair, equitable and inclusive manner, taking into account the needs of individuals or groups who, because of their particular circumstances, may be 5|Page MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY/AUTHORITY disadvantaged or vulnerable, including, as relevant, with regards to vaccines. This includes access to Project benefits for non-nationals, as set out in the Stakeholder Engagement Plan (SEP). d. Incorporate the relevant aspects of this ESCP, including, inter alia, any d. Before initiating the procurement environmental and social management plans or other instruments, ESS2 process for the relevant activities and requirements, and any other required Environmental, Social, Health and thereafter throughout the Safety (ESHS) measures, into the ESHS specifications of the procurement implementation of such Project documents and contracts with suppliers. Thereafter ensure that the suppliers activities. comply with the ESHS specifications of their respective contracts. e. Adopt procedures, protocols and/or other measures to ensure Project e. Before initiating the vaccination beneficiaries that receive vaccines under the Project do so under a program program and thereafter implemented that does not include forced vaccination and is acceptable to the Bank, as set throughout the carrying out of such out in the ESMF. activities. 1.3 EXCLUSIONS: Exclude the following types of activities as ineligible for financing under the Project: During the assessment process conducted PIU/MoH  Activities that may cause long term, permanent and/or irreversible (e.g., loss of major under action 1.2.c. above. natural habitat) adverse impacts.  Activities that have high probability of causing serious adverse effects to human health and/or the environment not related to COVID-19 treatment.  Activities that may have significant adverse social impacts and may give rise to significant social conflict.  Activities that may involve any resettlement or land acquisition/use restriction or adverse impacts on cultural heritage.  All the other excluded activities set out in the ESMF of the Project. 1.4 AVAILABILITY OF RESOURCES FOR WASTE MANAGEMENT Throughout Project implementation. PIU/MoH Ensure that resources, including human and financial resources, are available to cover the incremental costs associated with the management of increased waste volumes, including biomedical waste, and vaccination related waste (expired and opened vaccine vials), resulting from Project activities. ESS 2: LABOUR AND WORKING CONDITIONS 6|Page MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY/AUTHORITY 2.1 LABOUR MANAGEMENT PROCEDURES Prepare, disclose, adopt, and implement Labor Management Procedures (LMP) as part Same timeframe as 1.2. a. Until then, the PIU/MoH of the ESMF, in accordance with the applicable requirements of ESS2, in a manner recommendations referenced in the acceptable to the Bank, including, inter alia: interim guidelines for workplace safety and infection control and existing grievance  Implementing adequate occupational health and safety measures (including personal mechanism shall apply. protective equipment, emergency preparedness and response measures) to ensure the health and safety of Project workers. World Health Organization (WHO) guidelines LMP to be implemented throughout on COVID19 shall be followed in all facilities, including laboratories, quarantine and Project implementation. isolation centers, and screening posts.  Establishing and maintaining a Grievance Redress Mechanism (GRM) for health workers and any other Project.  Incorporating labor requirements into the ESHS specifications of the procurement documents and contracts. ESS 3: RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT 7|Page MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY/AUTHORITY 3.1 MEDICAL AND HAZARDOUS WASTE MANAGEMENT: a. Relevant aspects of this standard shall be considered, as needed, under a. Throughout Project implementation. PIU/MoH action 1.2 above, including, inter alia, measures to: carry out the purchase, storage, transportation, handling and deployment of vaccines (including, ultra-cold chain management) in a safe manner and in accordance with the EHSGs, and other relevant GIIP including relevant WHO guidelines. b. Prepare, disclose, adopt, and implement the Infection Control and Waste b. Same timeframe as for the preparation Management Plan (ICWMP) as per the requirements of the ESMF. and implementation of the ESMP, under action 1.2.c. c. Adequately manage and dispose of health care wastes (including vaccines) c. Throughout Project implementation. and other types of hazardous and non-hazardous wastes, including appropriate selection and safe usage and disposal of personal protective equipment (PPE) and relevant medical evaluation and health surveillance of PPE users following actions 1.2a-d. MoH shall adopt technologies and procedures on medical waste management including rapid assessment for appropriate treatment and disposal. Given the potential resource scarcity in the face of an outbreak, MoH shall commit to the provision of services and supplies based on the urgency of need, in line with the latest data related to the prevalence of the cases. ESS 4: COMMUNITY HEALTH AND SAFETY 8|Page MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY/AUTHORITY 4.1 COMMUNITY HEALTH AND SAFETY a) Relevant aspects of this standard shall be considered, as needed, under a) Throughout Project implementation PIU/MoH action 1.2 above including, inter alia, measures to: minimize the potential for community exposure to communicable diseases; ensure that the public is safe from potential wastes, especially disposed biohazardous materials and PPE; reduce risk associated with visits to health centers; ensure that individuals or groups who, because of their particular circumstances, may be disadvantaged or vulnerable, have access to the development benefits resulting from the Project; manage the risks of the use of security personnel; manage the risks of labor influx; and prevent and respond to sexual exploitation and abuse, and sexual harassment (SEA/SH). b) Same timeframe as for the preparation PIU/MoH b) A Community Health and Safety Plan (CHSP) shall be developed as part of the and implementation of the ESMF, ESMF. under action 1.2.a 9|Page MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY/AUTHORITY 4.2 USE OF SECURITY FORCES: In case the Borrower’s security forces (e.g., Trinidad and PIU/MoH Tobago Defense Force) are used in the implementation of Project activities and/or for provision of security to Project workers, sites and/or assets, the MoH shall adopt the following measures, in coordination with other competent authorities, as needed and as relevant: a. Assess the risks and impacts of engagement of the security forces, as part of the a) Assessment carried out in the same assessment referred to in action 1.2 a above, and implement measures to manage timeframe than action 1.2 a) above and such risks and impacts, guided by the principles of proportionality and GIIP, and by any required measures shall be adopted applicable law, in relation to hiring, rules of conduct, training, equipping, and before deploying security forces under the monitoring of such forces. Project and thereafter implemented throughout Project implementation. b. Adopt and enforce standards, protocols, and codes of conduct, in coordination b) and c) before deploying security or with other competent authorities, for the selection and use of such forces, and military personnel under the Project and screen such personnel to verify that they have not engaged in past unlawful or thereafter throughout Project abusive behavior, including SEA/SH or excessive use of force. implementation. c. Ensure that such forces are adequately instructed and trained, prior to deployment and on a regular basis, on the use of force and appropriate conduct (including in its relations to civilian, SEA and SH, and other relevant areas) d. Ensure that the stakeholder engagement activities under the Stakeholder d) and e) as set out under actions 10.1 and Engagement Plan (SEP) include a communication strategy on the involvement of 10.2 respectively. such forces under the Project. e. Ensure that any concerns or grievances regarding the conduct of such forces are received, monitored, documented (taking into account the need to protect confidentiality) and resolved through the Project’s grievance mechanism (see action 10.2 below) and reported to the Bank no later than 5 days after being received. ESS 5: LAND ACQUISITION, RESTRICTIONS ON LAND USE AND INVOLUNTARY RESETTLEMENT ESS5 is not currently relevant. ESS 6: BIODIVERSITY CONSERVATION AND SUSTAINABLE MANAGEMENT OF LIVING NATURAL RESOURCES ESS6 is currently not relevant 10 | P a g e MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY/AUTHORITY ESS 7: INDIGENOUS PEOPLES/SUB-SAHARAN AFRICAN HISTORICALLY UNDERSERVED TRADITIONAL LOCAL COMMUNITIES ESS7 is currently not relevant. ESS 8: CULTURAL HERITAGE ESS8 is currently not relevant. ESS 9: FINANCIAL INTERMEDIARIES ESS 9 is currently not relevant ESS 10: STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE 10.1 STAKEHOLDER ENGAGEMENT PLAN PREPARATION AND IMPLEMENTATION PIU/MoH Update, consult, adopt, disclose, and implement a Stakeholder Engagement Plan (SEP) A draft SEP was already prepared and consistent with ESS10, which shall include measures to, inter alia, provide stakeholders disclosed prior to project appraisal and with timely, relevant, understandable, and accessible information, and consult with updated for the restructuring of the them in a culturally appropriate manner, which is free of manipulation, interference, Project. coercion, discrimination, and intimidation. The SEP shall be consulted, finalized and redisclosed no later than 60 (sixty) days after the Effective Date of the amendment to the Loan Agreement, and in addition shall be a withdrawal condition for Category 2 of the Loan Agreement. The SEP shall be implemented throughout Project implementation. 11 | P a g e 10.2 PROJECT GRIEVANCE MECHANISM PIU/MoH An accessible grievance mechanism shall be established, publicized, maintained, and The GRM is already in place and shall be operated to receive and facilitate resolution of concerns and grievances in relation to adjusted, maintained, and implemented the Project, promptly and effectively, in a transparent manner that is culturally throughout Project implementation. The appropriate and readily accessible to all Project-affected parties, at no cost and existing GRM arrangements are described without retribution, including concerns and grievances filed anonymously, in a manner in the SEP. consistent with ESS10. The grievance mechanism shall also receive, register, and address concerns and grievances related to the SEA/SH in a safe and confidential manner, including through the referral of survivors to gender-based violence service providers. CAPACITY SUPPORT (TRAINING) CS1 TRAINING PIU/MoH The PIU and other relevant implementing support staff responsible for the Project No later than one month after adoption of shall receive training on the Project’s ESHS plans and E&S instruments as well as on this ESCP, SEP and ESMF and periodically fair, equitable and inclusive access and allocation of Project benefits, including with with the addition of new Project team regards to vaccines, and the roles and responsibilities of different key agencies in the members as they join the Project and ESF implementation. throughout implementation. Project workers shall receive training on the contents and requirements detailed in the ESMF, the Infection Control and Waste Management Plan and Emergency Preparedness and Response Plan to ensure compliance with environmental and social requirements. The MoH shall ensure that the Regional Health Authorities are aware of the Project GRM and its functioning and contact points for referrals. Security forces shall be trained on the applicable standards and code of conduct in line with the guidance provided in the Bank’s Technical Note “Use of Military Forces to Assist in Covid-19 Operations� and as defined in the updated ESMF and stated under 4.2. The Borrower shall ensure that resources, including human and financial resources, are available to cover costs associated with such training requirements. 12 | P a g e