THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) The Republic of Ghana Ministry of Health GHANA COVID-19 EMERGENCY PREPAREDNESS AND RESPONSE PROJECT ADDITIONAL FINANCING (P174839) Draft ENVIRONMENTAL and SOCIAL COMMITMENT PLAN (ESCP) OCTOBER 19, 2020 1|Page THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN 1. The Republic of Ghana is implementing the GHANA COVID-19 Emergency Preparedness and Response Project (the Project), and Additional Financing Project with the involvement of the Ministry of Health and the Ghana Health Service (GHS). The International Development Association (hereinafter the Association) has agreed to provide financing for the Project. 2. The Republic of Ghana will implement material measures and actions so that the Project is implemented in accordance with the Environmental and Social Standards (ESSs). This Environmental and Social Commitment Plan (ESCP) sets out material measures and actions, any specific documents or plans, as well as the timing for each of these. 3. The Republic of Ghana will also comply with the provisions of any other E&S documents required under the ESF and referred to in this ESCP, such as Environmental and Social Management Plans (ESMP), Resettlement Action Plans (RAP), and Stakeholder Engagement Plans (SEP), and the timelines specified in those E&S documents. 4. The Republic of Ghana is responsible for compliance with all requirements of the ESCP even when implementation of specific measures and actions is conducted by the Ministry, agency or unit referenced in 1. above. 5. Implementation of the material measures and actions set out in this ESCP will be monitored and reported to the Association by the Republic of Ghana as required by the ESCP and the conditions of the legal agreement, and the Association will monitor and assess progress and completion of the material measures and actions throughout implementation of the Project. 6. As agreed by the Association and the Republic of Ghana, 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 Republic of Ghana will agree to the changes with the Association and will update the ESCP to reflect such changes. Agreement on changes to the ESCP will be documented through the exchange of letters signed between the Association and the Republic of Ghana. The Republic of Ghana will promptly disclose the updated ESCP. 7. Where Project changes, unforeseen circumstances, or Project performance result in changes to the risks and impacts during Project implementation, the Republic of Ghana shall provide additional funds, if needed, to implement actions and measures to address such risks and impacts, which may include environmental, health, and safety impacts, medical waste management and community health and safety impacts labor influx, sexual exploitation and abuse and sexual harassment. 2|Page THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBILE ENTITY/AUTHORITY MONITORING AND REPORTING A REGULAR REPORTING Quarterly throughout the Project Ministry of Health, Ghana/ The Ministry of Health (MOH) will prepare and submit to the implementation period. Ghana Health Service World Bank regular monitoring reports on the environmental, social, health and safety (ESHS) performance of the Project. The report will, among others, include (i) status of implementation of the ESCP; (ii) conditions, if any, which interfere or threaten to interfere with the implementation of the ESCP; and (iii) corrective and preventive measures taken or required to be taken to address such conditions (iv) stakeholder engagement activities and functioning of the grievance mechanism. B INCIDENTS AND ACCIDENTS Submission to the Bank should take Overall responsibility will be with the Contractors, through the MOH, will promptly notify the Bank of place within 48 hours and no later than Ministry of Health, Ghana/ any incident or accident related or having an impact on the 72 hours after learning of the incident Ghana Health Service Project which has, or is likely to have, a significant adverse effect or accident. on the environment, the affected communities, the public or workers including situations of fatalities or serious bodily harm and incidents such as fire injuries, physical violence, Sexual Exploitation and Abuse and Sexual Harassment (SEA/SH), construction accident, communicable diseases and infections etc. The report will include full detail of the incident or accident, indicating immediate measures taken to address it, and include 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. C CONTRACTORS MONTHLY REPORTS The reports shall be submitted to the Ministry of Health and Ghana Health Contractors shall provide monthly monitoring reports, including MOH, and to the Bank upon request Service E&S Specialists procurement report to the MOH. ESS 1: ASSESSMENT AND MANAGEMENT OF ENVIRONMENTAL AND SOCIAL RISKS AND IMPACTS 3|Page THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBILE ENTITY/AUTHORITY 1.1 ORGANIZATIONAL STRUCTURE The Ministry of Health has already Ministry of Health, Ghana/ The Ministry of Health/ GHS shall maintain a PIU with qualified appointed an Environmental and Social Ghana Health Service staff resources to support management of environmental and Officer at the national level. social risks and impacts of the Project including environmental and social risk. The Ministry of Health/GHS has appointed an This will be replicated at the regional Environmental and Social Officer at the national level. With the and district level as necessary expanded project scope, additional qualified environmental and social safeguards officers will be assigned, as necessary, to supplement the existing staff in the implementation of the social and environment standards under this Project. 1.2 ENVIRONMENTAL AND SOCIAL ASSESSMENT Throughout project implementation Ministry of Health, Ghana/ Ghana Health Service Subprojects will be screened for Environmental and Social risks and impacts as per the procedures outlined in the ESMF, in a manner acceptable to the Bank. Based on the screening results, detailed environmental and social assessments may be conducted and accompanied by the relevant ESMPs to address any risks identified during the process All ESIA will be comprehensive to include assessment of waste management and pollution, Labor, SEA/SH risk assessment, social diversity and gender, impacts on vulnerable and disadvantaged groups or individuals, etc., and preparation of a draft ESMP, Labor Management Procedure and SEA/SH Action Plan. 4|Page THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): 1.3 MANAGEMENT TOOLS AND INSTRUMENTS Ministry of Health, Ghana/ Ghana Health Service/PIU E&S a. The project has updated the stakeholder engagement a. The ESMF and the updated SEP Specialists plan (SEP) for the parent project. The Environmental and will be approved by the World Social Management Framework (ESMF) for the parent Bank prior to project project will be updated, cleared by the World Bank and effectiveness. disclosed prior to project effectiveness. The ESMF includes Screening Forms to be used to screen all sub- b. Throughout project project to determine requirement for follow up ESIA, implementation. ESMPs, RAPs etc. b. If during implementation there is need for any construction activities where private land is acquired or purchased, the project will prepare Resettlement Framework and Resettlement Action Plans and Abbreviated Resettlement Action Plans as may be c. Throughout project implementation. required. c. Secure environmental permits for all new construction and rehabilitation under the Project. d. Prepare, disclose, adopt, and implement an ESIA/ESMP and/or any other instruments, if required for the respective subproject activities based on the assessment process, in accordance with the ESSs, the ESMF, the d. Throughout project EHSGs, and other relevant Good International Industry implementation. Practice (GIIP) including the relevant part of COVID-19 Quarantine Guidelines and WHO COVID-19 biosafety guidelines in a manner acceptable to the World Bank. e. Incorporate the relevant aspects of this ESCP, including, inter alia, any environmental and social management plans or other instruments, ESS2 requirements, and any other required ESHS measures, into the ESHS specifications of the procurement documents and contracts with contractors and supervising firms. e. Throughout project 5|Page THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBILE ENTITY/AUTHORITY Thereafter ensure that the contractors and supervising implementation. firms comply with the ESHS specifications of their respective contracts. f. Update environmental and social management plans or f. Throughout project other instruments based on updated guidance by WHO on implementation COVID19. g. Project Implementation Manual: Include the ES requirements into the Project Implementation Manual. At the minimum, the Manual will describe: • The roles of Environment and Social (ES) officers • Requirements to ensure universal access for health facilities to be refurbished. • The minimum ES clauses to be included in the Terms of reference and tender documents • Incorporation of ES indicators into Monitoring and Evaluation system • Completion timeline The project will not include vaccine purchase and deployment / distribution but will support Ghana’s preparedness for the vaccine deployment. Since vaccines are potentially polluting, as part of the preparedness, the project will support the development of environmentally and socially sound management procedures of vaccines which will include safe storage, collection, transport, and end use or disposal of unused or waste to protect public health and the environment. 6|Page THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBILE ENTITY/AUTHORITY 1.4 MANAGEMENT OF CONTRACTORS Ministry of Health, Ghana/ Ghana Health Service The MoH/GHS shall manage contractors and subcontractors through inclusion of ESHS specification into procurement Prior to issuing of procurement documents and contracts and thereafter, supervise compliance. documents These shall include but not limited to: Supervise contractors throughout • Incorporating the relevant aspects of the ESCP, including Project implementation the relevant E&S documents and/or plans, and the Labor Management Procedures, into the ESHS specifications of the procurement documents for contractors. Thereafter ensure that the contractors comply with the ESHS specifications of their respective contracts. • Codes of conduct are required of contractors and subcontractors and their workers to prohibit sexual harassment and exploitation and training of workers on their obligations under the Code of conduct • Ensure contractor ESMP (C-ESMP) is costed, with sufficient budget to mitigate E&S risks • Monitor Contractor commitment and compliance • Ensure contractors provide details on contractor’s oversight on environmental, social, health and safety (ESHS) performance • Contractor to develop a grievance redress mechanism to handle concerns of their employees. 7|Page THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBILE ENTITY/AUTHORITY 1.5 EXCLUSIONS: Exclude the following type of activities as ineligible for financing under the Project: • Activities that may cause long term, permanent and/or irreversible (e.g. loss of major natural habitat) adverse impacts • Activities that may have significant adverse social impacts and may give rise to significant social conflict • Activities that may have adverse impacts on cultural heritage 1.6 MONITORING AND REPORTING : Part of the project progress reporting Ministry of Health, Ghana/ The MoH/GHS PIU shall monitor the implementation of requirement Ghana Health Service /PIU E&S environment and social instruments to address environmental Specialists and social risks and impacts of the Project. ESS 2: LABOR AND WORKING CONDITIONS 8|Page THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBILE ENTITY/AUTHORITY 2.1 LABOR MANAGEMENT PROCEDURES Labor Management Plan will be part of Ministry of Health, Ghana/ specific ESMP/ESIA that will be Ghana Health Service Labor Management Procedures (LMP) will be elaborated in the prepared and submitted to the World ESMF, disclosed, adopted, and implemented consistent with ESS Bank for approval. 2. Prior to the preparation of The LMP shall set out the way in which project workers will be procurement documents. managed, in accordance with the requirements of Ghana national laws and ESS 2. The LMP will address the way in which ESS2 will These procedures must be maintained apply to different categories of project workers including, inter throughout Project implementation. alia, implementing adequate occupational health and safety, setting out grievance arrangements for project workers and requirements for third parties to manage their workers. The LMP will be referenced in the ESHS specifications of the procurement documents with requirements for contractors to update into a Plan during implementation and comply with its requirement. 2.2 GRIEVANCE MECHANISM FOR PROJECT WORKERS Grievance mechanism operational prior Ministry of Health, Ghana/ to recruitment of workers and Ghana Health Service/PIU E&S The contractor shall establish, maintain, and operate a GRM for implemented throughout Project Specialists staff, as described in the LMP and consistent with ESS2. This shall implementation. be approved by the PIU and the Bank. 9|Page THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBILE ENTITY/AUTHORITY 2.3 OCCUPATIONAL HEALTH AND SAFETY (OHS) MEASURES Prior to initiating Ministry of Health, Ghana/ construction/refurbishment activities Ghana Health Service MOH shall prepare, adopt, and implement occupational, health and implemented throughout the and safety (OHS) measures specified in the ESMF already Project life. It must follow the same mentioned above. Contractors working on the Project shall abide timeframe as for the implementation by the approved occupational, health and safety (OHS) of the ESMP plan/measures. The OHS plan shall include guidelines provided in WHO country and technical guidance – coronavirus disease (COVID-19) documents for the prevention of the transmission of the COVID 19 infection. The contractor shall conduct their activities in observance of Government directive and policy on COVID 19. Contractor’s Health and safety officer and MOH E&S officer shall train/orient employees of Project Contractors on various aspects of OHS relevant to the project. ESS 3: RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT 3.1 RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND Throughout Project implementation. Ministry of Health, Ghana/ MANAGEMENT Ghana Health Service Relevant aspects of this standard shall be considered, as needed, under action 1.3 above, including, inter alia, measures to: manage health care wastes, and other types of hazardous and non-hazardous wastes. Use of resources (water, air, etc.) should follow relevant WHO environmental infections control guidelines standards for medical facilities. Each beneficiary medical facility/lab will implement the National Health Care Waste Management Policy and a National Guideline for Health Care Waste Management, the ESMF, WHO COVID-19 guidance documents, and other best international practices, to prevent or minimize such adverse impacts. ESS 4: COMMUNITY HEALTH AND SAFETY 10 | P a g e THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): 4.1 TRAFFIC AND ROAD SAFETY: Throughout Project implementation. Ministry of Health, Ghana/ Ghana Health Service/PIU E&S Project Contractors shall be required to develop and implement Specialists measures and actions in the sub project ESMPs to assess and manage traffic and road safety risks as required in the ESMPs to be developed under action 1.3 above. 4.2 COMMUNITY HEALTH AND SAFETY: Maintained throughout Project Ministry of Health, Ghana/ The Project ESMF and ESMP shall guide the contractors to develop implementation. Ghana Health Service /PIU E&S and implement adequate measures and actions to assess and Specialists manage specific risks and impacts to the community and beneficiary arising from project activities. These will include, inter alia, measures to: minimize the potential for community exposure to the COVID-19 disease, accidents and pollution; ill-behavior of project workers, risks of labor influx, response to emergency situations in case of laboratory accidents/ emergencies, e.g., a fire response or natural phenomena event, prevent and respond to sexual exploitation and abuse, and sexual harassment; and protection of individuals or groups who, because of their particular circumstances, may be disadvantaged or vulnerable, have access to the development benefits resulting from the Project. Contractors measures, and work methods shall be validated by the local authorities and approved by the PIU. 4.3 GBV AND SEA RISKS: Maintained throughout Project Ministry of Health, Ghana/ implementation. Ghana Health Service The Project will ensure the avoidance of any form of Sexual Exploitation and Abuse and Sexual Harassment by relying on the Health Professions Regulatory Bodies Act, 2013 (Act 857) and WHO Code of Ethics and Professional conduct for all workers in the quarantine facilities as well as the provision of gender- sensitive infrastructure such as segregated toilets and adequate lighting in quarantine and isolation centers. 11 | P a g e THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): 4.4 GBV AND SEA RISKS DURING PROJECT IMPLEMENTATION: Throughout project implementation Ministry of Health, Ghana/ SEA/SH prevention plan will be required by the contractor as part Ghana Health Service of C-ESMP with adequate funding for implementation. The contractor shall ensure workers strictly abide by the measures and workers code of conduct . 4.4 SECURITY PERSONNEL: Throughout Project implementation. Ministry of Health, Ghana/ The project does not envisage the use of security personnel. Ghana Health Service ESS 5: LAND ACQUISITION, RESTRICTIONS ON LAND USE AND INVOLUNTARY RESETTLEMENT 5.1 RESETTLEMENT PLANS: RPF and RAPs submitted for the Bank’s Ministry of Health, Ghana/ No land acquisition is envisaged under this project since works approval and, once approved, Ghana Health Service will be conducted within existing government health facilities. implemented prior to commencing civil The government will conduct screening at these facilities using work activities that involve land the environment and social screening tool in the ESMF to ensure acquisition and resettlement. that the proposed facilities do not have encumbrances. In case permanent land acquisition would be necessary during implementation, a Resettlement Framework and Resettlement Action Plans or Abbreviated Resettlement Action Plans would be developed based on Bank’s ESF principles prior to commencement of any land acquisition. Relevant aspects of this standard shall be considered, as needed, under action 1.3 above. 5.2 GRIEVANCE MECHANISM Prior to commencement of Ministry of Health/ Ghana Health The grievance mechanism (GM) to address resettlement related resettlement activities and maintained Service complaints shall be described in the RPF and RAPs and will be throughout implementation completed before commencement of civil works. The GRM will incorporate existing GRM systems in place at the MoH/GHS and the local level. 5.3 MONITORING AND REPORTING: Part of the project progress reporting Ministry of Health, Ghana/ MoH/GHS shall ensure that monitoring and reporting on land requirement Ghana Health Service /PIU E&S acquisition and resettlement activities are conducted throughout Specialists the project as part of project regular reporting channels and separately as requested by the World Bank. 12 | P a g e THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): ESS 6: BIODIVERSITY CONSERVATION AND SUSTAINABLE MANAGEMENT OF LIVING NATURAL RESOURCES 6.1 Not relevant. Minor construction or rehabilitation activities may Not relevant Not relevant be anticipated in this project and all works will be conducted within existing facilities. Hence, impacts of the project on natural resources and biodiversity are considered unlikely ESS 7: INDIGENOUS PEOPLES/SUB-SAHARAN AFRICAN HISTORICALLY UNDERSERVED TRADITIONAL LOCAL COMMUNITIES 7.1 Not relevant. There are no distinct social and cultural groups in Not relevant Not relevant the project area who exhibit characteristics akin to the criteria for indigenous or traditionally under-served communities as spelled out in the ESS7. ESS 8: CULTURAL HERITAGE 8.1 CHANCE FINDS: Throughout project implementation Ministry of Health/ Ghana Health Relevant aspects of this standard shall be considered, as needed, Service under action 1.2 above. A Chance Find procedure will be part of the ESMF. ESS 9: FINANCIAL INTERMEDIARIES [This standard is only relevant for Projects involving Financial Intermediaries (FIs). See below a couple of examples of actions that should be considered when FIs are involved.] 9.1 Not relevant. Not relevant No financial intermediaries will be used ESS 10: STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE 10.1 STAKEHOLDER ENGAGEMENT PLAN PREPARATION AND The SEP for the parent project has Ministry of Health/ Ghana Health IMPLEMENTATION been updated and will be submitted to Service the World Bank for approval and Update, disclose and adopt a Stakeholder Engagement Plan (SEP) subsequently disclosed. consistent with ESS10, in a manner acceptable to the Association. The updated version of the SEP will include a risk communication and community engagement strategy, to be finalized under the Project in line with WHO guidance on “Risk communication and community engagement (RCCE) readiness and response to the 2019 novel coronavirus (2019-nCoV)� and in a manner consistent with ESS10 and acceptable to the Association. 13 | P a g e THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): 10.2 PROJECT GRIEVANCE MECHANISM: Throughout project implementation Ministry of Health, Ghana/ Ghana Health Service Accessible grievance arrangements shall be made publicly available to receive and facilitate resolution of concerns and grievances in relation to the Project, consistent with ESS10, in a manner acceptable to the Association. 10.3 CITIZENS SURVEY Throughout project implementation Ministry of Health, Ghana/ Conduct periodic citizen’s survey will be conducted to assess Ghana Health Service satisfaction of the COVID-19 response by stakeholders and the general public. 10.4 The MOH/GHS will adhere to the requirements of the Ghana Data Throughout project implementation Ministry of Health, Ghana/ Protection Act 2012 (Act 843) to safeguard the legitimate, Ghana Health Service appropriate and proportionate use and processing of potential large volumes of personal identifiable and sensitive data likely to be collected and used in connection with the management of COVID-19 pandemic and subsequent vaccination programs CAPACITY SUPPORT (TRAINING) 14 | P a g e THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): CS1 Training of personnel involved in project implementation will National and District Health Officers, Ministry of Health, Ghana/ include among others: Environmental Officers, Project Ghana Health Service • Overview of the relevant standards under the ESF (as per Consultants. the Project ESRS) • COVID-19 Infection Prevention and Control Recommendations • Risk communication and community engagement • Grievance redress mechanisms • WHO guidelines • Laboratory biosafety guidance related to the COVID-19 • Specimen collection and shipment • Standard precautions for COVID-19 patients • Subproject Environmental and Social screening • Emergency preparedness and response • Occupational Health and Safety • Training on COVID 19 transmission, prevention, preparedness and response • Community health and safety • Monitoring and Reporting • SEA/SH Risk prevention and mitigation • Disability inclusion training • Waste management (healthcare waste- solid and sewage) • Documentation and reporting • Labor management procedures • WHO and Africa CDC guidelines on quarantine including case management 15 | P a g e THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): CS2 Training for Project workers and community on occupational Project contractors, workers and Ministry of Health, Ghana/ health and safety including on emergency prevention and community Ghana Health Service preparedness and response arrangements to emergency situations. • community health and safety. • Occupational Health and Safety • communicable diseases/HIV-AIDS/STI awareness and prevention • community grievance redress mechanism as described in the Stakeholder Engagement Plan/ ESMF • process for resolving conflicts between workers and community members • SEA/ SH and Child protection. 16 | P a g e