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MINISTRY OF HEALTH NORTH EAST AND RED RIVER DELTA REGIONS HEALTH SUPPORT PROJECT ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK E4122

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Page 1: documents.worldbank.orgdocuments.worldbank.org/curated/en/367181468127162058/E... · Web viewThe Northern East and Red River Delta Region Health Support Project (NORRED) herein referred

MINISTRY OF HEALTH

NORTH EAST AND RED RIVER DELTA REGIONS HEALTH SUPPORT PROJECT

ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK

Vietnam, January, 2012

E4122

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TABLE OF CONTENT

I. INTRODUCTION.......................................................................................................4

II. PROJECT DESCRIPTION........................................................................................4

2.1 Project design.....................................................................................................4

2.2 Project Area........................................................................................................8

2.3 Types of potential sub-projects...........................................................................8

2.4 Project management and personnel...................................................................9

III. ENVIRONMENTAL POLICIES APPLICABLE TO THE PROJECT........................9

3.1 Vietnamese Environmental policies....................................................................9

3.2 World Bank environmental safeguard policies..................................................11

IV. Institutional arrangement......................................................................................11

4.1 Project hospitals................................................................................................11

4.2 Provincial Project Management Units (PPMUs)................................................12

4.3 Central Project Management Unit.....................................................................12

4.4 Provincial People Committees (PPCs)..............................................................13

4.5 The World Bank................................................................................................13

4.6 Contractor and equipment suppliers.................................................................13

4.7 Institutional Capacity.........................................................................................13

V. POTENTIAL ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES........14

5.1 Project Environmental Category.......................................................................14

5.2 Potential Socio - Environmental Impacts..........................................................14

5.2.1 Potential impacts during implementation phase.........................................14

5.2.2 Potential impacts in operation phase..........................................................15

5.3 Typical Mitigation Measures..............................................................................17

VI. ENVIRONMENTAL MANAGEMENT PROCEDURES.........................................30

6.1 Documentation requirements............................................................................30

6.2 Project Environmental Management Procedures..............................................30

6.2.1 Environmental Screening for eligibility........................................................34

6.2.2 Impact identification....................................................................................34

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6.2.3 Drafting Subproject Safeguard Document..................................................34

6.2.4 Public Consultation and information disclosure..........................................35

6.2.5 EMP review and Approval..........................................................................36

6.2.6 Licenses and Permits.................................................................................36

6.2.7 Supervision and environmental monitoring................................................36

6.2.8 Documentation and record keeping............................................................37

6.3 Capacity building/Training plan.........................................................................37

6.4 Cost for safeguard implementation...................................................................37

ANNEX

Annex 1: Environmental Eligibility Screen Form

Annex 2: Environmental Impact Screening Form

Annex 3: Recommended Format of EMP for each sub-project

Annex 4: Record of Public Consultation

Annex 5: Technical specifications of facilities and equipment for HCWM

Annex 6: Vietnam Hospital Wastewater Discharge Standard

Annex 7: Vietnam Health Care Solid Waste Incinerator Emission Standard

Annex 8: Cost estimation for technical assistance and capacity building

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I. INTRODUCTION

The Northern East and Red River Delta Region Health Support Project (NORRED) herein referred to as the FIRST Project or the Project is executed by the Ministry of Health (MOH) with the funding from the International Development Association (IDA) under the World Bank.

The NORRED will comply with the World Bank Safeguard Policies and Vietnamese environmental regulations to avoid or minimize impacts to humans and the environment during the implementation. Under component 1, the project will finance the activities of medical equipment purchase and minor civil work for provincial level hospitals and 50 district hospitals. These activities may cause some environmental issues relating dust, noise generation and waste management, safety issue during Project implementation and operation. These impacts are expected to be localized, mitigable and manageable through good design and appropriate mitigation measures. Therefore, the project has been categorized as Environmental Category B by the World Bank classification. As most of investment details under NORRED’s component 1 will not be known by Appraisal, during preparation an Environmental and Social Management Framework (ESMF) is prepared by MOH to ensure that the Project activities will be implemented in an environmentally and socially sustainable manner.

This EMSF lays down the principles and guidelines for addressing environmental and social impacts due to the implementation of the NORRED. It identifies the range of policies that the PPMUs should consider in project development. It will also outline the roles and responsibilities of the investors and project developers, the MOH’s PMU, PPMU, and the World Bank at each stage of the project cycle. The environmental and social safeguard policies shall be applied to all financed subprojects under NORRED. Adoption of ESMF shall ensure that the subprojects meet Vietnam environmental and social policies and are also consistent with the applicable safeguard policies and provisions of the World Bank.

The ESMF will be incorporated into the Project Operation Manual to ensure that environmental and social issues will be considered together with other requirements during project implementation.

II. PROJECT DESCRIPTION

II.1 Project design

The Project Development Objective

The Project Development Objective (PDO) is to increase the utilization of patients to local health services in selected provinces of the North East and Red River Delta

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regions by strengthening the capacity of selected provincial and district hospitals to deliver more and better quality health services and reducing the financial barrier for accessing care of the economically vulnerable.

The project comprises 3 components.

1. Component One: Strengthening the capacity of lower level health services to deliver quality services ($115 million): Component One aims to increase the capacity of the Provinces to provide more and better quality health services. It would consist of two subcomponents.

Subcomponent 1a - Provincial Subprojects for the Development of Medical Services and Quality Improvement about 111.5 million). This subcomponent would provide technical and financial support directly to the Provinces to increase their capacity to deliver quality health services at their general provincial hospitals or specialized pediatric or obstetrics and gynecology hospitals as well as at least three district hospitals per province. This subcomponent would be implemented as a virtual “Fund”. It would operate as a Fund because no amount of the Credit would be explicitly allocated to provinces. Provinces would apply to receive these funds to support their “sub-project” through the development of a Provincial proposal. The proposal would include the results of a needs analysis and confirm that the request is not a duplication of other activities supported by other sources of funds such as state bonds or small donor projects. It would define exactly which services the hospitals would be able to perform after the assistance provided by the Project. The proposals would cover five specialty areas (obstetrics/gynecology, pediatrics, cardiology, oncology, and trauma) at the provincial hospital level and three specialty areas at the district hospital level (obstetrics/gynecology, pediatrics, and trauma) as well as the auxiliary services at the hospitals (laboratory, intensive care). The exact services would be in accordance with the needs of the population, the inability to provide the required service currently (or provide it with sufficient quantity) and would be in accordance with the MoH guidelines (Decision 23) as updated on the services to be provided according to the hospital technical level (Level I being a tertiary facility, Level II being a secondary facility and usually denoted as a Provincial Hospital, and Level III being a basic secondary facility with a more limited scope of services and usually denoted as a District Hospital). Additionally, the proposals would define specific measurements of quality or management improvement that would be implemented in certain defined areas (at least 5% of the IDA investment in the subproject cost). Three measures of quality and management improvement would be required: (i) measuring patient satisfaction; (ii) initiating a Continuous Quality Improvement process; and (iii) development a planning and budgeting process for facility maintenance. Additionally, the Provinces shall choose among the topics to implement at least one other measure. The sub-projects would be implemented through the Provincial Departments of Health (DoH) and their

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Provincial Project Management Units (PPMU). The implementation plans for the subprojects would be consolidated as part of the Annual Workplan of the Project. In the event of poor implementation by Provinces (including poor management practices and delays), the sub-project scope can be reduced or cancelled in order to reallocate the funds to better performing provinces. Under Component 1b, the Ministry of Health will have technical support available to the provinces to help with the planning and implementation of the sub-projects which will, in particular, be targeted to the Provinces with less capacity.

Subcomponent 1b – Training and Technical Transfer for Reducing Hospital Overcrowding and Quality Improvement (US$3.5 million). This subcomponent would support the Ministry of Health and the other national level stakeholders to provide quality technical support to the Provinces to achieve the Components goals. This component would be implemented by the Ministry of Health and its Central Project Management Unit (CPMU). This would include two Technical Advisory Groups (TAGs) (teams of national experts, including from national institutions and hospitals). The first group would support the Provinces in the preparation and implementation of the plan for the technical transfer of the “know-how” for certain medical services and procedures; the second Technical Advisory Group would support the Provinces in the preparation and implementation of a hospital quality and management improvement plan. Particularly in the area of quality improvement and management, technical support will be provided to build the capacity of national counterparts. The component would also support the Ministry of Health in defining national level strategies and policies for implementation in the hospitals, research on the hospital overcrowding issue, such as in developing the guidelines for piloting the provision of radiation therapy treatment as primarily an outpatient treatment. The subcomponent would also include direct support to the central hospitals in development of their training capacity and the training programs in support of the technical transfer.

2. Component Two: Reducing the financial barriers to access by the economically Vulnerable (US$29.0 million). Component 2 aims at reducing the financial barriers by (i) expanding access to health insurance for a specific vulnerable group largely not covered by the current insurance system; (ii) providing direct access to certain high cost services support under Component 1; and (iii) increasing the general awareness of the rights of individuals and/or households under the insurance system. It would achieve this through three subcomponents:

Subcomponent 2a - Direct subsidy to support the purchase of a health insurance card by the near poor (US$23.0 million): Building on the similar and successful examples under the Mekong and Central North Regional Health System Support Projects, this subcomponent would support an additional subsidy of 20% of health

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insurance premiums (on top of the 70% subsidized by the state) for the Near Poor household members, conditional upon whole family enrollment. Those who enroll individually would not receive any support from the project. The support to household enrollment will help to increase the coverage more quickly than individual enrollment, improve risk sharing and reduce adverse selection, the core principles of social health insurance. The support will provide good experience and lesson learnt for the Ministry of Health to later expand it as a national policy. The Government has a policy for expanding health insurance coverage particularly for the vulnerable groups. Based on the Government’s Universal Health Coverage Roadmap, it is expected that the Government will extend the state support to this group within the project lifetime. The Project would provide an opportunity to advance this support in a large geographical region and for the Government to learn from the policy of requiring family as opposed to individual enrollment as they are considering this policy change.

Subcomponent 2b - Supporting catastrophic health care expenditure at provincial hospitals (US$2.0 million). This subcomponent would provide seed funds to the Provinces in the re-establishment of the Health Care Funds for the poor in accordance with Government policy. The Government issued Decision 14 revising the Decree 139 re-establishing health care funds for the poor; however, the guiding circular for implementation is still under development. Among other things, Decision 14 identified the Government support to vulnerable groups, including the poor, ethnic minorities, social assistance beneficiaries, and patients with cancer, dialysis, heart operation and other high cost treatment without ability to pay. Each province has to establish the fund with Government budget and possible mobilization of funds from other sources. However, in poor provinces with a large number of beneficiaries, financial resources are limited. The available resources will spur the issuance of the Guidelines and help set up the funds in the participating project provinces.

Sub-component 2c - Information, Education and Communication support to inform the insured and uninsured about the benefits under the national health insurance system (US$4.0 million). This sub-component will promote awareness of and enrolment in health insurance by the near poor by improving IEC activities in provinces. It would also target the currently enrolled to improve the understanding and awareness of the benefits available. It would also target the providers to reduce institutional barriers of access for insured, such as how insured patients are received, medical staff attitudes, etc... Innovative IEC measures are encouraged to effectively target beneficiaries, particularly ethnic minority population.

3. Component Three: Technical Support, Managerial Capacity Building and Project management, monitoring and evaluation (US$6.00 million): The aim of this component is to ensure adequate management structure, processes and human

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resource capacities for the project, and to setup mechanisms for effective monitoring of activities and evaluation of results. Under this component, the project would fund the operation of project management units at the central and provincial levels. To the extent possible, existing health information systems and data collection mechanisms in the MoH and in provinces will be relied upon. However, for certain information, it will be necessary to design specific data collection instruments and conduct independent data collection and auditing (e.g. small scale household surveys, patient exit interviews, hospital surveys). M&E will consist of two components: (i) monitoring of the project’s implementation progress, and (ii) monitoring of the project’s results indicators. Where the project support pilot initiatives, the project may fund specific evaluations of the pilots.

II.2 Project Area

The proposed NORRED project will be implemented in 7 provinces in North East Region (Tuyen Quang, Yen Bai, Thai Nguyen, Lang Son, Bac Giang, Phu Tho, Hoa Binh) and 6 provinces in Red River Delta (Hai Duong, Hung Yen, Thai Binh, Ha Nam, Nam Dinh, Ninh Binh). Under component 1, the project will provide province level hospitals and 50 district hospitals with equipment, education, short-term training and the supervision support. Under component 2, the project will expand access to health insurance for near poor households and to improve the system’s capacity to manage health insurance. All project interventions will be taken place within existing hospitals which are located in urban areas or in densely populated rural areas. No environmental protection area or physical cultural resource will be affected.

II.3 Types of potential sub-projects

During implementation, the participating Provinces will submit a proposal for a “sub-project” to be financed that would indicate explicitly: (a) the Provincial hospital which would be the ‘investment owner’; (b) services that they want to develop at that Provincial Hospital (which is on the long-list of eligible services and within their current technical level); (c) the central level hospital from which they would seek ‘sponsorship’; (c) the investment needs for those services (within the definition of eligible investments); (d) the selection of at least 3 district hospitals in rural areas to be supported and for which the Provincial hospital offers its sponsorship; (d) the identification of services to be developed in those district hospitals (which is on the long-list of eligible services and within their current technical level); and (e) the investment needs for the district hospitals (in accordance with the list of eligible investments).

The project will (i) improve the capacity of province level hospitals to provide curative health services in five priority service areas (obstetrics/gynecology, pediatrics, traumatology/orthopedics, cardiology, and oncology); and (ii) strengthen the capacity of

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district hospitals to provide curative health services in 3 priority service areas (obstetrics/gynecology, pediatrics, traumatology). This will be done through provision of medical equipment and telecommunications equipment, education, short-term training and the supervision support of the sponsored hospitals via an integrated satellite program. In addition, the project may provide technical support (technical assistance, training and study tours) for the establishment of an alternative service delivery model for services to be provided on an outpatient as opposed to an inpatient basis.

The Province and District hospitals would have to indicate that they have the necessary minimum conditions for receipt of the services and investments including the staff with the necessary basic qualifications and the hospital infrastructure. The project will focus on rehabilitation rather than major construction. Any need for significant additional staffing or major infrastructure investments would indicate that the hospital was not ready for investments in those services.

II.4 Project management and personnel

Name of Project: Northern East and Red River Delta Region Health Support ProjectName of Donor: The World Bank (WB) / International Development Agency (IDA)Line Agency: Ministry of Health (MOH) a) Contact Address: 138 A Giang Vo Street, Ba Dinh, Hanoib) Phone: +84-4-62732273 Fax: + 84-4-: 38464051/84-4-62732266Email: [email protected] owner: Ministry of HealthThe project owner will establish a Central Project Management Unit (CPMU) as Implementing Agency, to act on behalf of the project owner to organize and manage the project during the implementation. Project duration: 5 years: 2013-2018Total Project Budget: USD $ 157.5 million, of which:a) ODA Funds: USD $ 150.0 millionb) Counterpart Funds: USD $ 5 millionType of ODA: ODA concessional loan - IDA Credit

III. ENVIRONMENTAL POLICIES APPLICABLE TO THE PROJECT

III.1 Vietnamese Environmental policies

Environmental Protection Law (EPL) No 52/2005/QH11 dated 29/11/2005 and in effect from 01/7/2006. EPL provides frameworks on the responsibilities of individuals and organizations in environmental assessment, environmental protection in hospitals and health facilities, and management of hazardous waste, general waste, wastewater and gas emission.

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Policies relating to environmental assessment: Decree 29/2011/NĐ-CP dated 18/4/2011 regulating strategic environmental assessment, environmental impact assessment and environmental protection commitment; Circular 26/2011/TT-BTNMT dated 18/7/2011 of Ministry of Natural Resource and Environment regulating in detailed some clauses of Decree 29/2011/NĐ-CP dated 18/4/2011 regulating strategic environmental assessment, environmental impact assessment and environmental protection commitment; Circular 01/2012/TT-BTNMT dated 16/3/2012 regulating preparation, appraisal, approval, inspection and implementation verification of detailed environmental protection plan; preparation and registration of simple environmental protection plan;

Policies relating to hazardous waste and healthcare waste management: Decision 170/ QĐ-TTg dated 8/2/2012 of Prime Minister approving Master projection for solid hazardous healthcare waste treatment system until 2025; Decision 2038/QĐ-TTg dated 15/11/2011 of Prime Minister approving Master plan for healthcare waste treatment in period of 2011-2015 and orientation to 2020; Decision 43/2007/QĐ-BYT dated 3/12/2007 of Minister of Health promulgating Regulations on healthcare waste management; Circular 12/2011/TT-BTNMT dated 14/4/2011 of Minister of Natural Resource and Environment promulgating Regulations on hazardous waste management; Circular No 18/2009/TT-BYT dated 14/10/2009 of Ministry of Health promulgating Guidelines for organizing and implementing infection control in health care facilities; National technical regulations QCVN 02:2008/BTNTM on Healthcare waste incinerator’s gas emission quality; National technical regulations QCVN 28:2010/BTNTM on Healthcare wastewater effluent quality;

Policies relating to working safety: Decision No 3079 /QĐ-BYT dated 21/8/2008 of Minister of Health promulgating Regulations on organization and activities of working safety system in health facilities; Inter-ministerial circular 2237/1999/TTLT/BKHCNMT-BYT dated 28/12/1999 promulgating Guidelines for implementation of radioactive safety in health sector; Circular 23/2010/TT-BKHCN dated 29/12/2010 of Ministry of Science and Technology promulgating Guidelines for assuring radioactive source security; Circular 08/2010/TT-BKHCN dated 22 July 2010 guiding the declaration, licensing radiation related activities and working staff; Vietnam standard TCVN 6869:2001: Radiation safety – Medical exposure – General provisions Vietnam standard TCVN 6866:2001: Radiation safety – Dose limits for radiation workers and public

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Vietnam standard TCVN 6561:1999: Radiation protection for medical installations using X-ray machine

National environmental technical standards QCVN 05:2009/BTNMT-National technical regulations on ambient air quality; QCVN 06: 2009/BTNMT: National technical regulation on hazardous substances ambient air QCVN 07: 2009/BTNMT: National technical regulation on hazardous waste thresholds

III.2 World Bank environmental safeguard policies

OP/BP 4.01 Environmental Assessment Public Consultations and Information Disclosure The World Bank Group Environment, Health and Safety (EHS) General

Guidelines

IV. Institutional arrangement

MOH and its corresponding Central Project Management Unit (CPMU) will have the overall responsibility for safeguard implementation. The Provincial Project Management Units (PPMUs) under Provincial Department of Health (DOH) is responsible for ensuring safeguard compliance of its subproject at provincial level. The beneficiary hospitals under each province will be accountable for implementing safeguard requirements of financed activities. The responsibilities of CPMU, PPMUs, participating hospitals as well as other stakeholders are described in details below.

IV.1 Project hospitals

The financed activities for each hospital are a part of each provincial subproject. The hospitals are the on-the-ground project developers. The participating hospitals are responsible for ensuring safeguard compliance during implementation of provincial subproject and operation of the hospital. These include:

- Collecting and recording all licenses/permits necessary- Preparing site-specific environmental safeguard documents based on the

General safeguard document of provincial subproject. The site-specific environmental safeguard documents shall include a hospital waste management plan for the hospital.

- Carrying out mitigation measures to mitigate impacts as specified in the approved site-specific safeguard documents during subproject implementation and hospital operation.

- Internal monitoring the implementation of mitigation measures by contractors- Report on environmental compliance of the hospital to PPMU for review

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IV.2 Provincial Project Management Units (PPMUs)

The PPMUs are responsible for ensuring environmental safeguard compliance of their provincial subprojects. They will assist the project hospitals in all stages of subproject implementation. They will also consolidate reports from project hospitals and prepare external monitoring reports with technical assistance provided by consultants from MOH’s CPMU.

Each PPMU will assign one staff to work on socio-environmental safeguard aspect. Responsibilities of the socio-environmental staff will include, but not limited to the followings:

- Screening to determine the eligibility and magnitude of impacts associated with financed activities of the participating hospital under its province

- Preparing and getting approval of a subproject general safeguard document. The general safeguard document shall include the health care waste management plan (HCWM) for the beneficiary hospitals under subproject.

- To ensure that the subproject general safeguard document is disclosed at project area at timely manner;

- To review to ensure that requirements in subproject general safeguard document are included in design, bidding document and contracts;

- To provide guidance for participating hospitals to prepare the site-specific environmental safeguard documents based on the subproject general safeguard document and specific conditions, focusing on improving management of health care wastes regarding to current practices at health facilities;

- Reviewing and approving the site-specific safeguard documents prepared by participating hospitals

- During implementation, periodically supervising the implementation of safeguard requirements by participating hospitals and contractors.

- Reviewing monitoring reports prepared by participating hospitals. Periodically report on subproject environmental compliance to CPMU for review.

IV.3 To maintain safeguard and other project documents and submit to CPMU and/or supervision mission when required Central Project Management Unit

CPMU will coordinate activities to ensure that the provincial subprojects comply with Vietnamese Environmental management requirements and the Bank’s safeguard policies. The CPMU will provide support to the PPMUs by appointing environmental staffs and consultant as necessary to assist the PPMUs to prepare and implement the project safeguard requirements. The CPMU will also play a key oversight role in reviewing the safeguard implementation by PPMUs and report to the World Bank on

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Project safeguard compliance. Responsibilities of the CPMU will include, but not limited to the followings:

- Provide training and technical assistance as necessary to strengthen the capacity of CPMU, PPMUs, hospital staffs on safeguard implementation including establishment and implementation of healthcare waste management program and occupational safety;

- Review subproject general safeguard document submitted by each PPMU;- Supervise safeguard implementation by PPMUs, project hospitals and

contractors in design, and implementation phases;- Prepare six-monthly environmental report in agreed form and submit to the Bank

prior to its supervision missions;- Update the ESMF when required, taking into accounts the lessons learnt during

implementation;- Mobilize resource for HCWM: many of the more costly needed investments will

be outside the scope of the Project. Many technical supports are being prepared and funding facilities for HCWM improvement are being established under other project of MOH. These supports will assist the CPMU and PPMUs in participation in and taking advantages of existing support programs in order to mobilize additional resources for HCWM in the region as appropriate;

IV.4 Provincial People Committees (PPCs)

The Provincial People’s Committee (PPC) shall approve the subproject general safeguard documents prepared by participating provinces (through provincial Department of Natural Resources and Environment DONRE). The PPCs shall also ensure sufficient budget for construction or installation of hospital waste and wastewater treatment facilities as required.

IV.5 The World Bank

During implementation, the WB will provide guidance and technical assistance to CPMU in project implementation including safeguard execution.

IV.6 Contractor and equipment suppliers

To carry out mitigation measures and self-monitoring during implementation of minor civil work and equipment supply.

IV.7 Institutional Capacity

Vietnam government established legal and institutional framework for environmental protection. Environmental Protection Laws provides the overarching legal framework; meanwhile, the Regulations on hazardous waste management and Regulation on healthcare waste management provide health facilities with detailed

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guidelines. The Environmental Management Administration under MONRE is responsible for policy development, registration, authorization and inspection. Environmental police under Ministry of Public security is responsible for investigating environmental crimes. The environmental assessment procedures are regulated in MONRE’s circulars.

Vietnam Health Environment Management Agency under MOH is established to take responsibilities for environmental protection in health sector. The MOH has carried out several WB funded project e.g. Mekong Regional Health Support Project, North Central Regional Health Support Project, Northern Upland Regional Health Support Project, and therefore has experience of the World Bank’s safeguard policies. In addition, a major parallel project of the World Bank in “Hospital Waste Management Support Project” has been implemented and created a wealth of capital, expertise and a range of guidelines for different kinds of waste and institutions that will be drawn on.

The health sector gets used to environmental procedures of registration, authorization, monitoring. The challenges for compliance to regulations on healthcare waste management include (i) limited management capacity, (ii) lacking financial resource for investment and operation, (iii) improper maintenance. In addition, the staffs that had experience on safeguard management of these previous projects may not be available to be assigned as Staff Officer for NORRED project. The current capacity of CPMU regarding ESMF implementation, therefore, is considered to be limited.

The Project will require the allocation of qualified an environmental staff/consultant under CPMU to oversee environment and social safeguard issues and necessary training will be carried out to strengthen capacity of CPMU, PPMU and hospitals in implementing safeguard requirements.

V. POTENTIAL ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES

V.1 Project Environmental Category

The NORRED project is classified as Category B according to the World Bank’s safeguard guidelines.

V.2 Potential Socio - Environmental Impacts

V.2.1 Potential impacts during implementation phase

The project will have some potential negative impacts associated with the rehabilitation of hospitals during implementation. These include the generation of noise, dust and vibration, solid waste and waste water and labor safety issues at moderate level and in short-term period. Construction waste might affect hospital landscape and environment if they are not collected and disposed properly. Construction workers, hospital staff, patients and their relatives may risk being fallen down from height or

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suffering from falling debris. Because of the small scale of the investments and the focus on rehabilitation rather than construction, it is unlikely that any investments under the project will result in impacts on physical cultural resources. However, graves, cultural or archeological objects may be still exposed during excavation.

V.2.2 Potential impacts in operation phase

a) Increased generation of healthcare waste

The various investments of the project are intended to increase the utilization of health services and thus it can be expected there will be an increase in volumes of healthcare waste (HCW) at targeted hospitals. Almost 75-90% of HCW constitutes general waste and has no higher risk than general municipal solid waste. Hazardous healthcare waste (HzHCW) which share between 10-25% of total hospital waste by weight comprise 4 categories: (i) Infectious waste including sharps, non-sharp infectious waste, pathological waste and highly infectious waste; (ii) Chemical waste including chemicals commonly used in healthcare, formaldehyde, photochemicals, heavy metals, pharmaceutical waste and cytotoxic waste; (iii) Radioactive waste; (iv) Pressurized containers. Healthcare wastes can exist in solid, liquid, gaseous form. Quantity of solid HzHCW from hospital varies from 0.09 to 0.3 kg/bed/day depending on provision of medical services and waste management capacity. The hospitals may generate 0.4 – 0.95 m3 of wastewater per bed per day depending on its water supply and use.

Potential health impacts. Exposure to HzHCW can result in health problems. All individuals exposed to HzHCW are potentially at risk, including those within hospitals and those outside these sources. The main groups at risk are the following: (i) hospital staff including doctors, nurses, technicians; (ii) patients visiting the hospitals, patient relatives and visitors; (iii) workers in support services allied to hospitals such as laundries, waste handling, and transportation; (iv) workers in waste disposal facilities (such as landfills or incinerators), including scavengers; (v) community living nearby hospitals.

Pathogens in infectious waste may enter the human body by a number of routes: through a puncture, abrasion, or cut in the skin; through the mucous membranes; by inhalation; by ingestion. Spillage of infectious waste, especially highly infectious waste can spread pathogens through the hospital, which could result in outbreak of nosocomial infection among health staff and patients. Sharps may not only cause cuts and punctures but also infect these wounds if they are contaminated with pathogens. Sharp injuries are most popular accidents in health facilities. About 80% of occupational infections of HIV, HBV, and HCV are resulted from injuries by contaminated sharps.

Many of the chemicals and pharmaceuticals used in health-care establishments are hazardous (e.g. toxic, genotoxic, corrosive, flammable, reactive, explosive, shock-

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sensitive) but commonly present in small quantities. Acute or chronic exposure to chemical may cause intoxication that can result from absorption of a chemical or pharmaceutical through the skin or the mucous membranes, or from inhalation or ingestion. Injuries to the skin, the eyes, or the mucous membranes of the airways can be caused by contact with flammable, corrosive, or reactive chemicals (e.g. formaldehyde and other volatile substances).

Cytotoxic waste and radioactive waste are generated from oncology department. Many cancer treatment drugs are cytotoxic. They may be irritant and have harmful local effects after direct contact with skin or eyes, and may also cause dizziness, nausea, headache, or dermatitis. Hospital staff can expose to antineoplasma drugs by are inhalation of dust or aerosols, absorption through the skin, ingestion of food accidentally contaminated with cytotoxic drugs. The type of disease caused by radioactive waste is determined by the type and extent of exposure. It can range from headache, dizziness, and vomiting to much more serious problems. Because radioactive waste is genotoxic, it may also affect genetic material.

Wastewater from hospitals is of a similar quality to urban wastewater. The principal area of concern is high content of enteric pathogens which are easily transmitted through water. If healthcare waste is not well managed, hospital wastewater contains significant amount of pharmaceuticals, chemicals, even cytotoxic substances and radioactive isotopes if oncology services are delivered.

Potential environmental impacts. Unsafe disposal of solid HCW including incinerator ash and sludge from wastewater treatment plant is very problematic as pollutants from landfill sites have been known to seep out, polluting soil and local water sources which have long-term health impacts. Water resources may become contaminated by certain hazardous materials contained in hospital wastes. They can contain water-borne transmitted pathogens. They may contain heavy metals, largely mercury from thermometers and silver from the processing of X-ray films. Certain pharmaceuticals, if deposited without treatment, may also cause toxic agents to leach into water supplies. In addition, the leachate generated by the biological degradation of clinical wastes has the potential to cause water contamination, by reason of its high BOD. The risk of air pollution arises largely from the fact that most hazardous wastes are incinerated or burnt. Many existing hospital incinerators do have a potential pollution. Improper design, poor operation and maintenance of incinerators may result in the emission of a wide range of pollutants besides dioxins and furans, including include heavy metals (lead, mercury and cadmium), fine dust particles, hydrogen chloride, sulphur dioxide, carbon monoxide, and nitrogen oxides.

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Public sensitivity. In addition to health and environmental impacts, the general public is very sensitive about the visual impact of anatomical waste that are recognizable human body parts including fetuses. In no circumstances is it acceptable to dispose of anatomical waste inappropriately, such as on a landfill.

b) Exposure to ionizing radiation

Radiation causes ionizations in the molecules of living cells. The ions formed then can go on to react with other atoms in the cell, causing damage. They may also affect genetic material. The type of disease caused by ionizing radiation is determined by the type and extent of exposure. Exposure to ionizing radiation includes medical exposure, occupational exposure and public exposure. At higher doses (up to 100 rem), the cells might not be able to repair the damage, and the cells may either be changed permanently or die. Cells changed permanently may go on to produce abnormal cells which may become cancerous. This is the origin of increased risk in cancer, as a result of radiation exposure. At even higher doses (>100 rem to whole body), tissues fail to function, resulting in "radiation sickness" such as nausea, diarrhea and general weakness. With higher whole body doses (>300 rem), the body's immune system is damaged and cannot fight off infection and disease. At whole body doses near 400 rem, if no medical attention is given, about 50% of the people are expected to die within 60 days of the exposure, due mostly from infections.

V.3 Typical Mitigation Measures

The project potential socio-environmental impacts can be mitigated through the implementation of standard mitigation measures during design or implementation and operation phases as described below. The mitigation measures during detail design shall be carried out by detailed design consultant. During implementation, the mitigation measures for generic impacts relevant to generation of dust, noise, vibration, solid waste and labor safety shall be carried out by contractors and included in the construction contract. The mitigation measures during operation shall be carried out by beneficiary hospitals.

The Table below lists typical mitigation measures, which was developed with the aims of supporting PPMU to prepare subproject general environmental safeguard documents (IESD) which includes the HCWM. Sub-project general environmental safeguard should include additional mitigation measures (not listed below) as needed and required.

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Table 1: Standard Mitigation measures in sub-project design phase

Socio-environmental issues Mitigation measures Applicable

regulations Specify in Applicable subprojects

1. Radiation facility and equipment do not meet minimum requirements for radiation protection and safety

All hospitals receiving support in radiotherapy shall comply with Vietnamese regulations and international basic standard for protection against Ionizing radiation;

The sitting, location, design, construction, assembly, commissioning, operation, maintenance and decommissioning of source within practices shall be based on sound engineering which shall take account of approved codes and standards (TCVN 6561:1999, TCVN 6869:2001; Inter ministerial circular 2237/1999/TTLT/BKHCNMT-BYT e.g.);

Equipment consisting of radiation generators or containing the sealed sources needed for medical exposure shall (i) conform to TCVN 6869:2001 and applicable standards of the International Electro-technical Commission (IEC) and the International Organization for Standardization (ISO); (ii) conform to performance specifications, including protection and safety instructions, provided in a major world language understandable to the users and in compliance with the relevant IEC or ISO standards with regard to accompanying documents, and translated into Vietnamese; personal protective equipment which meets Vietnam standard TCVN 6561:1999 shall be included in radiation equipment set.

The occupational exposure of any worker and the public exposure any member of pubic shall be so controlled that dose limits in TCVN 6866:2001 be not exceeded;

Inter-ministerial circular 2237/1999/TTLT/BKHCNMT-BYT: Guidelines for implementation of radioactive safety in health sector;Circular 23/2010/TT-BKHCN: Guidelines for assuring radioactive source security;TCVN 6869:2001: General regulations on radioactive safety in health radiationTCVN 6561:1999: Ionizing radiation safety in X ray radiology facility in health facility

Sub-project detailed design

Sub-projects supporting radiotherapy (oncology services) in provincial level hospitals

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Table 2: Standard Mitigation measures in sub-project implementation phase (ECOPs)

(Environmental Codes of Practices performed by contractors)

Socio-environmental issues Mitigation measures

Applicable regulations Specify

in

Applicable

subprojects

2. Dust, noise and vibration generated from construction site and construction activities

The Contractor is responsible for compliance with relevant Vietnamese legislation with respect to ambient air quality, noise and vibration.

The Contractor shall ensure that the generation of dust is minimized and implement a dust control plan to maintain a safe working environment and minimize disturbances for patients, staff and surrounding residential areas.

The Contractor shall implement dust suppression measures (e.g. water paths, covering of material stockpiles, etc.) as required. Material loads shall be covered and secured properly during transportation to prevent the scattering of soil, sand, materials, or dust. Exposed soil and material stockpiles shall be protected against wind erosion and the location of stockpiles shall take into consideration the prevailing wind directions and patient wards.

The Contractor shall ensure dust masks be used by workers where dust levels are excessive.

The Contractor shall implement measures to reduce noise to acceptable levels including silencers, mufflers, acoustically dampened panels or placement of noisy machines in acoustically protected areas.

The Contractor shall avoid or minimize transportation of materials though and placement of material processing facilities (cement mixing) in patient crowded areas

The Contractor shall not carry out construction activities generating high level of noise before 6 am, after 9 pm

QCVN 05:2009/BTNMT: National technical regulation on ambient air qualityQCVN 26:2010/BTNMT: National technical regulation on noiseQCVN 27:2010/BTNMT: National technical regulation on vibration

Construction bidding and contract

Sub-projects supporting renovation

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Applicable regulations Specify

in

Applicable

subprojects

and during lunch time.

3. Construction waste generated from construction activities

The Contractor shall develop a solid waste control procedure (storage, provision of bins, site clean-up schedule, bin clean-out schedule, etc.) before construction and strictly comply with developed procedure during construction activities.

The Contractor shall obtain all necessary waste disposal permits or licenses before construction.

The Contractor shall provide litter bins, containers and waste collection facilities at all places of work.

The Contractor store solid waste temporarily on site in a designated place prior to off-site transportation and disposal through a licensed waste collector.

The Contractor shall dispose of waste at designated place identified and approved by the Construction Supervision Consultant or local authority. Opened burn or bury of solid waste in hospital shall not be allowed. Under no circumstances shall the contractor dispose of any material in environmentally sensitive areas, such as watercourses

Recyclable materials such as wooden plates for trench works, steel, scaffolding material, site holding, packaging material, etc. shall be segregated and collected on-site from other waste sources for reuse or recycle (sale).

Maintenance of vehicles and machines that may generates used oil, lubricants, cleaning materials, etc. shall be carried out in licensed workshop, not in hospital. Chemical waste of any kind shall be disposed of at an approved appropriate landfill site and in

Decree 59/20078/NĐ-CP on solid waste management

Construction bidding and contract

Sub-projects supporting renovation

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Applicable regulations Specify

in

Applicable

subprojects

accordance with local legislative requirements. The removal of asbestos-containing materials or other

toxic substances shall be performed and disposed of by specially trained and certified workers.

4. Localized flooding due to wastewater from construction site and blocked drainage

The Contractor shall follow the detailed drainage design included in the construction plans, intended to prevent storm water and waste water from causing local flooding.

The Contractor shall install drainage lead water from construction site to water receivers

The Contractor shall ensure drainage system maintained and cleared of mud and other obstructions.

The Contractor shall install sediment control structures where needed to slow or redirect runoff and trap sediment. Sediment control structures could include windrows of logging slash, rock berms, sediment catchment basins, straw bales, storm drain inlet protection systems, or brush fences.

QCVN 08:2008/BTNMT: National technical regulation on quality of surface waterInstruction No. 02/2008/CT-BXD on safety and sanitation issues in construction agencies

Construction bidding and contract

Sub-projects supporting renovation

5. Safety risks to construction workers, hospital staff, patients and their relatives

The Contractor shall comply with all Vietnamese regulations regarding worker safety.

The Contractor shall prepare and implement action plan to cope with risk and emergency

The Contractor shall provide workers with training on occupational safety regulations and personal protective equipment

The contractor shall provide safety measures as installation of fences, use of restricted access zones, warning signs, lighting system to protect workers, hospital staff and patients against falling debris and other risks.

Decree No. 22/2010/TT-BXD on regulation of construction safetyInstruction No. 02/2008/CT-BXD on safety and sanitation issues in construction agencies

Construction bidding and contract

Sub-projects supporting renovation

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Socio-environmental issues Mitigation measures

Applicable regulations Specify

in

Applicable

subprojects

6. Chance-find procedures

If the Contractor discovers archeological sites, historical sites, remains and objects, including graveyards and/or individual graves during excavation or construction, the Contractor shall: Stop the construction activities in the area of the

chance find; Delineate the discovered site or area; Secure the site to prevent any damage or loss of

removable objects. Notify the Construction Supervision Consultant who in

turn will notify responsible local or national authorities in charge of the Cultural Property of Viet Nam (within 24 hours or less);

Relevant local or national authorities would be in charge of protecting and preserving the site before deciding on subsequent appropriate procedures. This would require a preliminary evaluation of the findings to be performed. The significance and importance of the findings should be assessed according to the various criteria relevant to cultural heritage; those include the aesthetic, historic, scientific or research, social and economic values;

Decisions on how to handle the finding shall be taken by the responsible authorities. This could include changes in the layout conservation, preservation, restoration and salvage;

If the cultural sites and/or relics are of high value and site preservation is recommended by the professionals and required by the cultural relics authority, the Project’s Owner will need to make necessary design changes to accommodate the request and preserve the

Law on Cultural Heritage (2002)Law on Cultural Heritage (2009) for supplementary and reformationDecree No. 98/2010/ND-CP for supplementary and reformation

Construction bidding and contract

Sub-projects supporting renovation

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in

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site; Decisions concerning the management of the finding

shall be communicated in writing by relevant authorities;

Construction works could resume only after permission is granted from the responsible local authorities concerning safeguard of the heritage.

Table 3: Standard Mitigation measures in operation phase

Socio-environmental issues Mitigation measures

Applicable regulations Specify

in

Applicable

subprojects

7. Solid healthcare waste generated from healthcare activities

All beneficiary hospitals shall comply with Vietnamese regulations and World Bank guidelines relating healthcare waste management (HCWM)

Each beneficiary hospital shall prepare a facility-specific Environmental Management Plan (EMP) focusing on healthcare solid waste and wastewater management;

Each hospital under the project shall form a HCWM team or Infection Control team responsible for preparing and implementing EMP, as well as monitoring and supervising EMP implementation;

A solid HCWM system established and maintained in each hospital under the project shall include: (i) segregation of waste at source; (ii) on-site collection, transportation, storage of waste; (iii) off-site transportation of waste; (iv) treatment and final disposal of waste; (v) reduction, reuse and recycle of waste.

Environmental Protection Law 2005

Circular No 18/2009/TT-BYT: Guidelines for organizing and implementing infection control in health care facilities

Decision 43/2007/QĐ-BYT: Regulations on

Environmental management plan

All sub-projects

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Applicable regulations Specify

in

Applicable

subprojects

Healthcare solid waste shall be segregated into 5 categories: infectious waste (sharp, non-sharp, highly infectious and anatomical waste), hazardous chemical waste, radioactive waste, pressurized containers and general waste. Wastes generators must carry out segregation at their generation places.

Each category of waste must be contained in bags/bins with coded color; labeling and technical specifications in line with the Regulations on HCWM (see Annex 4).

Waste bags shall be tied up and collected when they are filled to 3/4 of capacity. Assigned hospital orderly or environmental workers take the responsibility for collecting waste from generation places to interim storage in the department. Each department shall clearly determine locations for placement of waste bins.

Hazardous waste and general waste shall be separately transported to waste storage area in hospital at least once per day and when needed. The hospital shall stipulate routes and time for the transportation of waste. Waste bags shall be tied up and transported by specialized transport devices to avoid leakage or spillage of waste during transportation.

At storage places, hazardous waste and general waste shall be kept in separate rooms and in specific equipment to avoid leakage and spillage into environment. The maximum duration for storing healthcare waste in hospital is 48 hours or 72 hours in cold warehouse/cabinet. If hazardous waste needs to be stored more than 06 months, hospital shall inform to and get approval of environmental authority. Storage house and equipment shall meet technical specifications described in Regulations on HCWM and

healthcare waste management;

Circular 12/2011/TT-BTNMT: Regulations on hazardous waste management

Decision 170/QĐ-TTg: Master projection for solid hazardous healthcare waste treatment system until 2025

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hazardous waste management (see Annex 4) Hazardous waste can be treated and disposed through

3 models: (i) centralized model; (ii) clustering model; and (iii) on-site model. According to Government master projection (Decision 170/QD-TTg), the hospitals in Red River Delta and North East Regions are planned to move towards clustering treatment model by 2015 and centralized treatment model by 2025.

In case of off-site treatment, the transfer of the hazardous waste treatment responsibility between the generator and the party receiving such responsibility shall be affected under contracts certified by provincial environmental protection agencies. The facility providing healthcare waste treatment services to healthcare establishments shall have license for hazardous waste management practice

Hazardous healthcare waste shall be treated by allowed technologies including disinfection by wet thermal, disinfection by microwave irradiation, incineration in high-temperature incinerator, hygienic landfill, concrete bury pit, inertization, return to supplier and others based on waste hazards and characteristics. Opened burn and opened bury onsite are not allowed. Burying in hygienic landfill or concrete pit is acceptable in rural areas. Once incineration method is applied, shall meet Vietnam regulations on design and gas emission, and take measures to control secondary pollution. Non-burn technologies that are environmentally sound are encouraged to apply.

The hospitals shall reuse equipment, instruments and materials following sterilization and disinfection. If reused, plastic containers of sharp waste shall be

QCVN 02:2008/BTNTM: National technical regulations on Healthcare waste incinerator’s gas emission quality;

TCVN 7380:2004: technical requirements for healthcare waste incinerator

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Applicable regulations Specify

in

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cleaned, disinfected prior reuse. Waste recycle is encouraged, however, it is only

permitted to recycle non-hazardous healthcare waste such as plastic bottles, glass bottles, glass jar of injection medicine, paper, cardboard, metal cans e.g. Recycling healthcare waste contaminated by hazardous elements shall be prohibited.

8. Wastewater generated from hospitals

Each hospital under the project shall have a synchronous system of waste water collection and treatment.

Wastewater collection network of contaminated wastewater shall be separated from raining water collection network, underground or covered by caps.

Hospital shall install wastewater treatment plant meeting Vietnam standard (TCVN 7957:2008) on design.

The hospital shall operate the wastewater treatment plant daily and maintain it properly according to manufacturer’s instruction;

Hospital wastewater effluent shall meet National technical regulation QCVN 28:2010/BTNMT on healthcare wastewater quality. The hospital shall get DONRE’s license for discharge wastewater into environment.

Sludge shall be considered as hazardous waste and managed according to solid waste management regulation.

Hospital shall employ measures to minimize entry of hazardous solid waste and large quantities of pharmaceuticals or chemicals into wastewater stream

Decision 43/2007/QĐ-BYT: Regulations on healthcare waste management;TCVN 7957:2008: wastewater external network and facilities – Design standard

QCVN 28:2010/BTNTM: National technical regulations on Healthcare wastewater effluent quality

Environmental management plan

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Applicable regulations Specify

in

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9. Risks associated with exposure to hazards in hospital environment

All hospitals under the project shall comply with Vietnamese regulations on working hygiene, safety and occupational health

Each hospital under the project shall establish and maintain a working safety system including working safety team, working safety network in departments and occupational health unit in line with Decision 3079/QĐ-BYT

Hospitals under the project shall provide healthcare professionals and waste workers with sufficient training on healthcare waste management and occupational safety regulations

Hospitals under the project shall provide healthcare professionals and waste workers with appropriate personal protective equipment.

Interim storage area and treatment facilities of hazardous healthcare waste in project hospitals shall be provided with firefighting equipment (extinguisher, sand e.g.), first aid box, materials and tools for response to leakage and spillage, abridged instructions of safe operating procedures and accident response, regulations on working safety and health protection.

Hospital under the project shall develop procedures for response to exposure to blood, body fluid or sharp injury. Counseling and prophylaxis treatment of occupational infections such as HIV/AIDS or Hepatitis B shall be offered to health and waste workers in case of high risk of acquired infection.

Hospitals under the project shall provide their staff with annual medical check, regular occupational disease diagnosis and monitoring; and manage records, report

Decision No 3079/QĐ-BYT: Regulations on organization and activities of working safety system in health facilities

Circular 12/2011/TT-BTNMT: Regulations on hazardous waste management

Circular 19/2011/TT-BYT: guidelines for management of working hygiene, occupational health and disease

Environmental management plan

All sub-projects

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Applicable regulations Specify

in

Applicable

subprojects

statistics on occupational health and working accidents in line with Circular 19/2011/TT-BYT and inter-ministerial Circular 12/2012/TTLT-BLĐTBX-BYT.

10. Risks associated with exposure to ionizing radiation

All hospitals receiving support in radiotherapy shall comply with Vietnamese regulations and international basic standard for protection against Ionizing radiation and for the safety of radiation sources;

Hospital offering radiotherapy shall notify DOST within 15 days after receipt of radioactive equipment; get license from DOST prior to commencement of radiotherapy provision; make inventory and report to DOST regularly;

Hospital offering radiotherapy shall assign a radiation protection officer who is trained on radiation safety by authorized training institution. Responsibilities for radioactive source security and radiation safety shall be clearly defined;

All involved staff (radiotherapy practitioners, nurses, source handlers, patient transporters, maintenance engineers, waste collectors e.g.) shall be trained and qualified so that they understand their responsibilities and perform their duties with appropriate judgment and according to defined procedures;

Radioactive sources shall be kept secure so as to prevent theft or damage in accordance with Circular 23/2010/TT-BKHCN;

Equipment consisting of radiation generators or containing the sealed sources needed for medical exposure shall conform to performance specifications, operating and maintenance instructions, including protection and safety instructions;

Inter-ministerial circular 2237/1999/TTLT/BKHCNMT-BYT: Guidelines for implementation of radioactive safety in health sector;Circular 23/2010/TT-BKHCN: Guidelines for assuring radioactive source security;TCVN 6869:2001: General regulations on radioactive safety in health radiationTCVN 6561:1999: Ionizing radiation safety in X ray radiology facility in health facilityTCVN 6867-1: 2001: Radiation safety. Safe

Environmental management plan

Sub-projects supporting radiotherapy (oncology services) in provincial level hospitals

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Applicable regulations Specify

in

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subprojects

The commissioning, operation, maintenance and decommissioning of source within practices shall be based on sound engineering which shall take account of approved codes and standards (TCVN 6561:1999, TCVN 6869:2001; Inter ministerial circular 2237/1999/TTLT/BKHCNMT-BYT e.g.);

Guidance levels for medical exposure and optimization of protection for medical exposure which are established by TCVN 6869:2001 shall be complied;

The occupational exposure of any worker shall be so controlled that dose limits in TCVN 6866:2001 be not exceeded;

Workers shall be provided with suitable and adequate personal protective equipment which meets Vietnam standard TCVN 6561:1999.

The public exposure any member of pubic Public exposure shall be so controlled that dose limits in TCVN 6866:2001 be not exceeded;

Radioactive waste and wastewater shall be stored in necessary time for them to decay to allowable limit before discharge into environment. Radioactive wastewater (including excreta of patients receiving radioactive medicine) shall be contained in 1 of 2 separated, radiation resistant underground tanks. One tank receives radioactive wastewater daily; the other tank contains radioactive wastewater until discharge. Radioactive waste is collected in black plastic bags and placed in metal containers. Radioactive waste is collected daily and stored in radiation resistant tanks in necessary time until discharge into environment;

Safety assessment related to protection and safety measures for sources within practices shall be made at

transportation of radioactive substances. Part 1: general regulations

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different stages. Monitoring and measurement shall be conducted of the parameters necessary for verification of compliance with the requirements of the standards;

Records shall be maintained of the results of monitoring and verification of compliance, including records of the tests and calibrations carried out in accordance with standards;

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VI. ENVIRONMENTAL MANAGEMENT PROCEDURES

VI.1 Documentation requirements

The subproject general safeguard documents will prepared, reviewed and approved in accordance with the applicable existing Vietnamese environmental regulations (Decree No29/ND-CP dated 18 April 2011 and Circular No 26/TT-BTNMT dated 29 July 2011).

So far, the details activities of subprojects of participating provinces have not yet been fully identified. Depending on the investment scale, magnitude of impacts, the environmental safeguard requirements may be varied among subprojects. According to the national regulations, some subprojects require an environmental subsection included in the Economic-Technical Report (ETR) or Feasibility Study (FS) Report while for the others, a stand-alone safeguard document e.g. Environmental Protection Commitment (EPC) would be required.

According to the World Bank requirements, the preparation and implementation of an environmental management plan (EMP) which includes an HCWM plan is adequately for addressing potential impact during subproject implementation.

To address inconsistency and to ensure that the subproject implementation will strictly follow national environmental regulations and WB safeguard policies, that under the NORRED project, it is requested the an subproject general safeguard document prepared by PPMUs shall include an Environmental Management Plan (EMP) covering the HWM plan, which is acceptable by the Bank and with format acceptable to Vietnamese local authority. The subproject general safeguard documents can be a stand-alone document or included into the form of environmental section of the ETR/FS.

A template for the EMP to be included in the subproject general Safeguard document is described in Annex 3.

VI.2 Project Environmental Management Procedures

Under the NORRED project, PPMU or its consultant will make sure that environmental section of the ETR/FS or a stand-alone Environmental report of each subproject shall include an Environmental Management Plan (EMP) with contents acceptable to the Bank and with format acceptable to Vietnamese local authority.

The EMP will also be included into design contract, construction bidding and contractual documents, and in construction supervision contract. Project costs will cover the costs for EMP implementation and monitoring.

Table 4 below listed the activities to be undertaken by various project stakeholders at each step of subproject implementation.

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Table 4: Project Environmental Management Procedures

Project cycle Environmental action required

Implemented by Monitored/ checked by

1. Sub-project identification

1.1 Environmental Eligibility Screening:

PPMU Environmental Staff

CPMU

WB check randomly

2. Preparation of Economic – Technical Report or FS

2.1 Environmental Impacts Screening

2.2 Prepare and subproject general safeguard document. The subproject general safeguard documents shall include an EMP/HCWM plan

PPMU / Project Preparation Consultant

CPMU Environmental staff

2.3 Prepare site-specific safeguard documents covering HCWM plan each hospital

Hospital PPMU

2.4 Carry out Public Consultations, prepare meeting minutes and list of participants

2.5 Include solutions to address community concerns into final EMP. Consultation records is filed for submission when required.

PPMU / Project Preparation Consultant

CPMU Environmental staff

2.6 Include requirements in the general safeguard document into relevant project documents to get approval from local authorities, and NOL from WB if required

PPMU Relevant local authority to carry out prior-review

2.7 a. EMP disclosure: A copy of subproject general safeguard document is sent

PPMU CPMU

WB check

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Project cycle Environmental action required

Implemented by Monitored/ checked by

to Project Commune People’s Committee (CPC) for Disclosure at public accessible place. Written confirmation by CPMU is sent to PPMU.

during supervision

2.7 b. Include relevant clauses into Specifications for Engineering Design Bidding documents and contract

Consultant

PPMU Environmental staff

3. Engineering Design

3.1 Incorporate mitigation measures presented in the EMP into design

Design Consultant PPMU Environmental staff

4. Sub-project implementation

4.1 Include relevant EMP requirements into construction/supervision bidding documents and contract

PPMU PPMU Environmental staff

4.2 Implement mitigation measures applicable to construction phase

Contractors Construction Supervisor

PPMU

Hospital

Local community

4.3 Carry out environmental monitoring and supervision

- Self-monitoring by contractor

- Frequent monitoring by construction supervision as necessary

- Internal monitoring by hospital

- Periodic monitoring by PPMU

PPMU

local authority

WB Construction Supervisor

PPMU

Local community

WB random checks

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Project cycle Environmental action required

Implemented by Monitored/ checked by

- Random monitor by CPMU

- Local community monitoring

4.3 Reporting:

Report on implementation of mitigation measures. This report shall be part of contractor progress report

Contractors report to Construction supervisors/PPMU

PPMU

Report on carrying out environmental compliance by contractors

Hospitals, construction supervisors report to PPMU

PPMU

Report on environmental compliance of subproject

PPMU report to CPMU

CPMU

5. Operation 5.1 Implement healthcare waste management plan as specified in the subproject general and site-specific safeguard document

Hospital PPMU during project period

local authority

WB random check

5.2 Carry out environmental monitoring and supervision

Hospital local authority

PPMU during project period

WB random check

5.3 Incorporate healthcare waste management into sub-project progress report

Hospital PPMU during project period

local authority

WB random check

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VI.2.1 Environmental Screening for eligibility

PPMU fill in Environmental Eligibility Screening Form (shown in annex 1) and attach to the list of subprojects sent to CPMU for review. WB will randomly check the screening form and advise CPMU/ PPMU about the list of subprojects that WB requires prior-review, i.e. EMP should be submitted for the Bank to review and no-objection. Remaining subprojects will be subjected to post-review.

Environmentally, a subproject will not be eligible for inclusion in the NORRED if: It is a major hospital infrastructure It cause land acquisition and involuntary resettlement, triggering the Bank’s Policy on Involuntary Resettlement Cause relocation of known cultural heritages such as pagodas, temples, churches, shrines, graves or object of spiritual important to local community, triggering the Bank’s policy on Physical Cultural Resources

At subproject-identification stage, CPMU staff who responsible for environmental safeguard issues will carry out screening to identify environmental eligibility of proposed sub-projects. Only eligible subprojects will be financed under the NORRED project. Guidance on how to carry out environmental screening is described in Section V.

VI.2.2 Impact identification

For each eligible sub-project, PPMU fill will answer the questions provided in Environmental Impacts Screening Form (provided in Annex 2) to determine the impacts potentially occurred during the implementation and operation of a proposed subproject. This is the basis for the preparation of sub-project safeguard document discussed in 5.2.3.

VI.2.3 Drafting Subproject Safeguard Document

PPMU or its consultant will prepare a subproject General Safeguard Document including EMP/HCWM Plan for each subproject. The EMP will include two parts, mitigation program and environmental monitoring. EMP should be presented using the format introduced in Annex 3 of the ESMF.

Before implementation of hospital activity, the participating hospital will prepare a site-specific safeguard documents including HCWMP to address any potential impacts associated with investment activities.

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VI.2.4 Public Consultation and information disclosure

At subproject-level

After the draft General Safeguard document including EMP and HCWM Plan is prepared, related PPMU or its consultants will conduct a consultation meeting with project affected groups. Consultation can be either in the form of questionnaire or community meeting. At the consultation meeting, representatives from affected groups will be informed about the project’s potential environmental impacts and mitigation proposed to mitigate these impacts. Representatives from affected groups will be asked to comment on the impacts/mitigation measures or talk about their socio-environmental concerns related to project activities. The purpose of the consultation is to identify environmental issues of concerns to project affected groups so that they may be included in the subproject general safeguard documents. Community consultation activities will be documented with date and location of consultation meeting, and comments received from affected people. Documentation of the consultation should be included as attachment in safeguard documents. Form of public consultation records is provided in Annex 4 of the ESMF.

For each subproject, the General Safeguard Document including EMP/HCWM Plan will be disclosed at commune level for public access during project preparation stage. A full package including safeguard documents, Environmental Management Plan, environmental certificate, records of public consultations will be sent to the Bank for disclosure at VIDIC prior to appraisal of Economic-Technical Report or Feasibility Study.

At Project level

During preparation of ESMF, meaningful consultations have been conducted with participating provinces, MOH staffs. Thirteen provinces conducted rapid assessment on healthcare waste management in their province based on self-administrated questionnaires. The ESMF was disseminated to relevant agencies within MOH including Vietnam Health Environment Management Agency for review. The concerns from stakeholders have been incorporated into the final ESMF.

At Project level, prior to appraisal, the final draft ESMF has been disclosed locally at the MOH office and Vietnam Development Information Center (VDIC) in Vietnamese language in January 2012. It has been disclosed in WB InfoShop in Washington DC in English language before the departure of appraisal mission.

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VI.2.5 EMP review and Approval

For all subprojects, PPMU do review of environmental documents and relevant local authorities do approval in accordance with existing Vietnamese environmental management regulations. The Bank will do prior review on screening results and up to 20% of general safeguard document prepared for subprojects.

If a stand along safeguard document is required by local authority, the final submission to the Bank for prior-review the CPMU should provide evidence (e.g. copies of the letters of approval, environmental certificate) that all necessary approvals of the EMP has been obtained from the responsible Vietnamese authorities.

VI.2.6 Licenses and Permits

It is the responsibility of PPMU to secure and maintain any necessary licenses or permits which are either issued by or require approval of any Vietnamese environmental authorities during subproject implementation.

All project hospitals shall have registration of hazardous waste generator, license for discharge of wastewater into environment and license for solid waste treatment (if required). Project hospital offering radiation therapy shall obtain notification of radioactive source and apply to Provincial Department Science and Technology for license of radiation therapy.

VI.2.7 Supervision and environmental monitoring

During subproject implementation, the PPMUs or their construction supervision consultants will be responsible for day to day supervision of mitigation compliance and monitoring activities which have been identified in EMP. Local communities are encouraged to undertake monitoring. If there are complaints from local project-affected groups, the PPMU should be prepared to send staff in a timely fashion to assess the validity of complaints and take any necessary actions to remedy the situation. Reporting on the implementation of the EMP should be sent to the Bank as part of the progress reports prior to the Bank’s semi-annual supervision missions. CPMU is responsible to provide technical guidance as needed to PPMUs to enable them fulfill their supervision responsibilities and related reporting and documentation requirements. Hospital will be responsible for supervision the implementation of safeguard compliance of contractor at its area.

The project hospitals are responsible for monitoring healthcare waste and wastewater generation, handling, treatment and disposal. They are also responsible for monitoring impacts of healthcare solid waste, wastewater and gas emission to ambient air and occupational health.

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VI.2.8 Documentation and record keeping

CPMU and the PPMU of related provinces and beneficiary hospitals are responsible to record and keep all safeguard documentation (Environmental screening forms, EMP, consultation records, confirmation on public disclosure, environmental monitoring records etc.) related to subproject investment. Safeguard implementation is a part of progress implementation report that CPMU will submit to the Bank prior to supervision mission.

VI.3 Capacity building/Training plan

Based on actual demands in ESMF implementation, a capacity building and training program for relevant agencies will be established. The content and cost for capacity building program is described in Annex 8.

VI.4 Cost for safeguard implementation

The cost for safeguard implementation is included in the Project cost and is described in Annex 8. The project includes US $ 300,000 for technical assistance and training activities related to safeguard implementation including health care waste management. Financing for healthcare waste management equipment and facilities in the second stage of implementation will be determined based on demand from project hospitals and local authorities in accordance with their needs and priorities.

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Annex 1 – Environmental Eligibility Screen Form

PPMU ………………………………………

Eligibility screening for sub-projectHospital 1…………….

Hospital 2…………….

Hospital 3…………….

Hospital 4…………….

Hospital 5…………….

Hospital 6…………….

I Question Yes No Yes No Yes No Yes No Yes No Yes No

1.1 Is the subproject a major hospital infrastructure?

1.2 Will the subproject cause:

a land acquisition and/or involuntary resettlement?

b relocation of known cultural heritages such as pagodas, temples, churches, shrines or object of spiritual important to local community

II Eligibility:

At least one above answer was “yes”

the subproject is not eligible

All the above answers were “no”

the subproject is eligible

Date: ..../……/……. Screened by Verified by PPMU director

(full-name and signature) (full-name, signature and stamp)

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Annex 2 – Environmental Impact Screening Form

Socio-environmental issuesPotential impact

CommentsYes No

Will the sub-project implementation and associated activities cause:

1. Dust, noise and vibration generated from construction site and construction activities

2. Construction waste generated from construction activities

3. Localized flooding due to wastewater from construction site and blocked drainage

4. Safety risks to construction workers, hospital staff, patients and their relatives

5. Graves, cultural or archeological objects are exposed

6. Other issues (pleased specify)

…………………………………………………..

Will the hospital operation cause:

7. Increased generation of solid healthcare waste from healthcare activities

8. Increased generation of wastewater from hospital

9. Increased risks associated with exposure to hazards in hospital environment

10. Increased risks associated with exposure to ionizing radiation

11. Other issues (please specify)

………………………………………………….

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Annex 3 – Recommended Format of EMP for each sub-project

INTRODUCTION

Legal background for EMP preparation

Information source for EMP preparation

Organization of EMP preparation

PART 1: BASELINE SITUATION

1 Hospital name

2 Hospital director (full name, address, telephone, fax, email)

3 Hospital location, area and catchment area

4 Hospital size (number of beds and number of staff in reality and projection to 2020)

5 Hospital structure

6 Hospital main services and performance

7 Current situation of hospital environmental management

Registration of hazardous waste generation owner

Authorization of hazardous waste treatment and wastewater treatment

Implementation of Healthcare waste management regulation

Environmental inspection and punitive sanction (if available)

Main challenges and difficulties

PART 2: HEALTHCARE WASTE, ENVIRONMENTAL ISSUES AND PROPOSED MITIGATION MEASURES

1 Healthcare solid waste and proposed mitigation measures

1.1 Hazardous healthcare waste management

Quantity of generation by healthcare waste categories

Segregation and color coding

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Collection, on-site transportation, storage

Off-site transportation, treatment and disposal

Reuse and recycle

1.2 General healthcare waste management

Quantity of generation

Segregation and color coding

Collection, on-site transportation, storage

Off-site transportation, treatment and disposal

Reuse and recycle

1. 3 Hospital waste water management

Quantity of generation

Collection network

Treatment facilities

Operation and maintenance (including sludge removal and disposal)

1.4 Gas emission and controlling measures

1.5 Renovation under NORRED project (if available) and mitigation measures

Prevention and control of dust, noise, vibration from construction activities

Management of solid waste from construction activities

Management of wastewater and localized flooding

1.6 Proposed measure for occupational health and safety

Health surveillance, management of occupational exposure and diseases

Radiation protection and safety

Training and communication (key manager, staff, waste collectors and operators, patients)

1.7 Notification, Registration, Authorization

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PART 3: ANNUAL ACTION PLAN

Project phase

Environmental Issues Proposed measures Budget and

source Time Person/ institution in charge

DesignSubstandard facility and equipment for radiation exposure

Renovation

Dust, noise, vibration

Construction waste

Wastewater and blocked drainage

Workers’ safety risks

Chance finding

OperationSolid healthcare waste management

Wastewater collection, treatment

Gas emission controlling

Occupational health and safety

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PART 4: ENVIRONMENTAL MONITORING PROGRAM

Project phase

ContentLocatio

nParameter Frequency Cost

Person in

charge

Design

Renovation

Operation

PART 5: INSTITUTIONAL ARRANGEMENT

1 Healthcare waste management team (or Infection control team)

2 Occupational safety team

PART 6: PUBLIC CONSULTATION AND DISCLOSURE

ANNEX

Annex 1: Hospital layout

Annex 2-1: Decision on Infection control committee establishment

Annex 2-2: Decision on working safety committee establishment

Annex 3: Environmental monitoring and inspection results

Annex 4: Record of Public consultation

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Annex 4 – Record of Public Consultation

Date: Subproject:

Method of consultation Public meeting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Questionnaire circulation: . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . [indicate number sent and number received]

Location(s) consultation(s) was (were) held: [building, commune, district]

Number of attendances from affected group. . . .

Comments and Questions from affected group

………………………………………………………………………………………………….

………………………………………………………………………………………………….

………………………………………………………………………………………………….

………………………………………………………………………………………………….

………………………………………………………………………………………………….

………………………………………………………………………………………………….

………………………………………………………………………………………………….

………………………………………………………………………………………………….

………………………………………………………………………………………………….

………………………………………………………………………………………………….

………………………………………………………………………………………………….

………………………………………………………………………………………………….

Response by Presenters) ………………………………………………………………………………………………….

………………………………………………………………………………………………….

………………………………………………………………………………………………….

………………………………………………………………………………………………….

Meeting Minutes prepared by (name and title)

Representative from affected group (full name, address and signature)

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Annex 5 – Technical specifications of facilities and equipment for HCWM

Waste bag shall meet the following requirements: (i) yellow and black bags must be the PE or PP plastic bags, not be PVC; (ii) bag’s walls must have minimum thickness of 0.1 mm, bag sizes must be appropriate to generated waste quantity, the maximum volume of a bag is 0,1m3; (ii) on the outside of the bag, there must be a horizontal line running at the height of 3/4 of the bag with the inscription "no storing beyond this line"; (iv) waste bags must conform to color coding and be used with right purposes.

Sharp box shall meet the following requirements: Hard wall and bottom are hardly penetrable, leak-proof capacity, suitable size, the lid easy to open/close, the opening is big enough to contain sharp items without propulsive force, marked with the inscription “for sharp items only”, a horizontal line running at the height of 3/4 of the bag with the inscription of "no storing beyond this line", yellow color, with handle or enclosed with fixation system, sharp items inside aren’t dropped out during transportation.

Waste bin shall meet the following requirements: (i) be made of plastic with high density, thick and hard walls or made of metal and with covers opened by foot; (ii) bins of 50 l and larger should have wheels; (iii) yellow bins are used for collection of yellow waste boxes/bags, black bins are used for collection of black waste boxes/bags, radioactive waste must be contained in metal bins, green bins are used for collection of green waste boxes/ bags, white bins are used for collection of white waste boxes/ bags; (iv) The bins’ holding capacities vary from 10 to 250 liters, depending on the generated waste volumes; (v) The bins’ outside must be marked with a line at the level of 3/4 of the bin and the inscription of "not storing beyond this line"; (vi) Waste bins shall be cleaned daily.

Onsite waste transportation devices shall meet standards: having the wall, cover, closed bottom, easy to load and unload the waste, easy to clean, disinfect and dry.

Storages places at healthcare establishments shall meet the following requirements: be far from food-preparing places, patients’ wards, crowded sites and public paths at least 10 m; have ways for waste carriers to come from the outside; have roofs, protection fences, doors and locks to prevent animals, rodents and unassigned persons from freely penetrating therein; the area is suitable to the waste volumes generated from the healthcare establishments; be equipped with facilities for hand-washing, means for protection of personnel, cleansing tools and chemicals; be built with water drainage systems, water -resistant floor and wall, good ventilation; if interim storage is designed as warehouse, it shall meet Vietnam standard TCVN 4317:86 – Warehouse – Basic principle of design or equivalent or higher international standards. Besides, the storage house shall be equipped as follows: manual or physical loading

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and unloading equipment; warning sign correlative to stored hazardous waste category in each cell or unit of storage area and on each storage equipment, warning signs comply with TCVN 6707:2009, have at least 30 cm in each size, color and inscription on warning sign are not faded; abridged instructions of safe operating procedures, accident response, working safety and health protection are in place; convenient to see, easy to read to encourage healthcare establishments to keep waste in cold warehouse/bins.

Hazardous waste storage equipment shall meet the following requirements: shell can resist against corrosion, infiltration or adsorption; be stainless, not react to chemicals inside; be reinforced at connection and charging, discharging points to avoid leakage; structure is firm to stand clash, not to broken, deform during utilization; warning sign in line with TCVN 6707:2009 has at least 30 cm in each size, is clear to read; equipment storing liquid or evaporate hazardous waste shall has closed lid, measure to control evaporation, measure to control overfill; cooling storage equipment is encouraged to be equipped.

Truck for hazardous waste transportation shall have fixed hermetic body in order to avoid leakage and spillage of hazardous waste into environment. Warning signs which is in line with TCVN 6707:2009 and at least 30 cm in size are marked at two sides of truck; the inscription of “transportation of hazardous waste” together with name, address, telephone are labeled at two sides of truck. On the truck, hazardous healthcare wastes shall be packaged in bins/boxes in order to prevent and control leakage, spillage and environmental incidents caused by hazardous wastes. Hazardous waste containing equipment shall meet the requirements for hazardous waste containers described above.

Healthcare waste incinerator shall meet Vietnam standard TCVN 7380:2004 regulates technical requirements for healthcare waste incinerator as follows: incinerator includes primary chamber and secondary chamber; temperature in primary chamber ≥ 800oC; temperature in secondary chamber ≥ 1200oC; Temperature of emission gas at chimney hole ≤ 250oC; Gas residence time in secondary chamber ≥ 1,5 second; Incinerator must be compulsorily ventilated. Healthcare waste management practitioners shall use incinerator having capacity of at least 100 kg/hour. Vietnam policies and the World Bank’s EHS guidelines require healthcare solid waste incinerator to have measures to control secondary pollution. Secondary air pollution control measures for healthcare solid waste incinerators include the following: (i) The height of chimney must be 3 meters higher than the roof of the highest house within a radius of 40 meters from incinerator location, in case there is no house within that zone, the chimney height must be at least 8 meters from the ground; (ii) Wet scrubber to control acid gas emissions e.g. HCl, SO2 and fluoride compounds; (iii) Cyclones, fabric filters, and/or electrostatic precipitators to control particulate matter; (iv) Fabric filter, electrostatic precipitators, venturi quenches and venturi scrubbers to control volatile

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heavy metals; (v) Flue gas need to be quenched very quickly to avoid formation and reformation of POPs; (vi) Flue gas cleaning devices shall meet international standard; (vii) Gas emission of incinerator shall be monitored regularly with frequency of at least 3 month and meet National technical requirements on gas emission of healthcare waste incinerator (QCVN 02:2008/BTNMT). Bottom ash, fly ash and liquid effluent from flue gas cleaning shall be managed as hazardous waste. According to Stockholm Convention signed by Vietnam, healthcare waste incinerator is considered as a potential releasing source of Dioxin and Furans and priority consideration should be given to alternative technologies that avoid formation of dioxins & furans.

Controlled dump that can be temporarily applied for resource limited healthcare establishments in mountainous area shall be stipulated by local authority and accepted by local environmentally managerial bodies. Controlled dump shall meet requirements: surrounding fence, far from water well, far from housing area at least 100 m, bottom of landfill separated from surface water level by 1.5 m at minimum, opening of the landfill is prominent and temporarily covered to prevent rain water; a soil layer of 10-25 cm is heaped up on the surface of hole in each time of burial; and the thickness of top soil layer is 0.5m. Infectious waste shall not be buried together with general waste. Infectious waste shall be disinfected before burying.

Concrete bury pit includes 3 types: underground pit, sub-underground pit, and surface pit; pit is located at area where groundwater level is suitable; area of bottom of each pit ≤ 100 m2 and the height ≤ 5 m; bottom and wall are made of leak-proof ferro-concrete and located on reinforced ground; wall (underground part) and bottom are enclosed by a leak-proof layer; roof is in place to protect pi’s surface from sun and rain, and measure is in place to protect pit’s content from direct wind; when the pit is full, enclose the pit by leak-proof ferro-concrete cover; the cover must cover all pit’s surface to prevent leakage and endosmosis.

Hazardous waste engineered landfill shall meet Vietnam standard TCXDVN 320:2004 that is applied to design, construct a hazardous waste landfill or renovate or design new cells in existing hazardous waste landfill.

Healthcare wastewater collection and treatment. Each hospital shall have a synchronous system of waste water collection and treatment. Hospital shall have collection network of contaminated wastewater separated from collection network of raining water. Wastewater collection network shall be underground or covered by caps. Design of wastewater collection network and treatment facilities shall meet the National Standard TCVN 7957:2008 on design of wastewater external network and facilities. Hospital waste water treatment technologies shall be appropriate to geographic conditions, investment capital, operational and maintenance expense. Wastewater treatment technologies include source segregation and pretreatment for removal /

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recovery of specific contaminants such as radio isotopes, mercury, etc.; skimmers or oil water separators for separation of floatable solids; filtration for separation of filterable solids; flow and load equalization sedimentation for suspended solids reduction using clarifiers; biological treatment with suspended growth process and/or attached growth process for reduction of soluble organic matter (BOD); biological or chemical nutrient removal for reduction in nitrogen and phosphorus; chlorination of effluent when disinfection is required; dewatering and disposal of residuals as hazardous medical/infectious waste. Hospital wastewater effluent shall meet National technical regulation QCVN 28:2010/BTNMT on healthcare wastewater quality. Sludge shall be considered as hazardous waste and managed according to solid waste management regulation. Additional engineering controls may be required for containment and treatment of volatile constituents and aerosols stripped from various unit operations in the wastewater treatment system. Hospital shall employed measures to minimize entry of hazardous solid waste and large quantities of pharmaceuticals or chemicals into wastewater stream.

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Annex 6. Vietnam Hospital Wastewater Discharge Standard

(QCVN 28:2010/BTNMT)

Parameters Unit Value of C Technical standard referenceA B

1. pH 6,5 - 8,5 6,5 - 8,5

TCVN 6492:1999(ISO 10523:1994)

2. BOD5 mg/l 30 50 TCVN 6001 - 1:2008

3. COD mg/l 50 100TCVN  6491:1999(ISO 6060 : 1989)

4. Total Suspended Solid (TSS) mg/l 50 100 TCVN 6625:2000(ISO 11923:1997)

5. Sulfur (S2-, calculate by H2S) mg/l 1.0 4.0 TCVN 6637:2000(ISO 10530:1992)

6. Ammonium (NH4+, calculate by N) mg/l 5 10 TCVN 5988:1995(ISO 5664:1984)

7. Nitrates (NO3-, calculate by N) mg/l 30 50 TCVN 6180:1996(ISO 7890 - 3 : 1988)

8. Phosphate (PO43-, calculated by P)- mg/l 6 10 TCVN 6494 – 2: 2000(ISO 10304 -2 : 1995)

9. Oil and grease mg/l 10 20 US EPA Method 1664

10. Alpha radioactivity Bq/l 0.1 0.1 TCVN 6053:1995(ISO 9696:1992)

11. Beta radioactivity Bq/l 1.0 1.0 TCVN 6291:1995(ISO 9697:1992)

12. Total coliform MPN/ 100ml 3000 5000

TCVN 6187-1:2009(ISO 9308 - 1:2000)TCVN 6187 - 2:1996(ISO 9308 - 2:1990)

13. Salmonella Bacteria/100 ml KPHD KPHD TCVN 4829:2001

14. Shigella Bacteria/100 ml KPHD KPHD SMEWW 9260

15. Vibrio cholera Bacteria/100 ml KPHD KPHD SMEWW 9260

Note:- KPHD: undetectable;- A category: apply to hospital waste water discharged to water body used for domestic

purposes;- B category: apply to hospital waste water discharged to municipal sewerage and water body

not used for domestic purposes- Allowable threshold (Cmax) = C * K;

K = 1 in case of hospital having ≥ 300 beds, parameters pH, Total coliform, Salmonella, Shigella, Vibrio choleraK = 1.2 in case of hospital having < 300 beds and other health facilities

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Annex 7. Vietnam Health Care Solid Waste Incinerator Emission Standard

(QCVN 02:2008/BTNMT)

No ParameterChemical

formulationUnit Limits

Technical standardreference

1 Dust mg/Nm3 115 TCVN 7241: 2003

2 Hydrofluoric acid HF mg/Nm3 2 TCVN 7243 : 2003

3 Hydrochloric acid HCl mg/Nm3 100 TCVN 7244 : 2003

4 Carbon monoxide CO mg/Nm3 100 TCVN 7242 : 2003

5 Nitrogen oxide NOx mg/Nm3 250 TCVN 7245 : 2003

6 Sulfur dioxide SO2 mg/Nm3 300 TCVN 7246 : 2003

7 Mercury Hg mg/Nm3 0.55 TCVN 7557–2 : 2005

8 Cadmium Cd mg/Nm3 0.16 TCVN 7557–3 : 2005

9 Lead Pb mg/Nm3 1.2 TCVN 7557–3 : 2005

10 Total Dioxin/Furan 2.3 TCVN 7566-1 : 2005

Dioxin C12H8-NClnO2 Ng –

TEQ/Nm3

TCVN 7566-2 : 2005

Furan C12H8-NClnO TCVN 7566-3 : 2005

Note: N: number of Chlo atom; N*: 2 ≤ n ≤ 8 TEQ

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Annex 8. Cost estimation for technical assistance and capacity building

Unit: USD

No Cost items Unit Quantity Cost Total1 Technical assistance 40,4801.1 Update safeguard and HCWM regulations man.day 10 100 1,000

1.2Provide training on development of safeguard documents including HCWM plan man.day 10 100 1,000

1.3Support development of safeguard documents including HCWM plans man.day 78 100 7,800

1.4Take consultation with stakeholders on safeguard documents including HCWM plan man.day 13 100 1,300

1.5Provide training on following up of safeguard and HCWM activities man.day 117 100 11,700

1.6Provide training on operation and maintenance man.day 7.8 100 780

1.7 Monitor and prepare regular reports man.day 130 100 13,000

1.8Midterm review and prepare proposal for procurement man.day 39 100 3,900

2 Training and seminars 202,800

2.1Training on development of safeguard document including HCWM plan trainee 156 150 23,400

2.2 Stakeholder seminars seminar 13 500 6,500

2.3Training on follow up of safeguard and HCWM activities trainee 780 150 117,000

2.4 Training on operation and maintenance trainee 156 150 23,400

3 Other capacity building activities province 13 2500 32,5004 Contingency 24,2205 Total 300,000