World Bank Document

SFG1006 REV

Rwanda

Great Lakes Emergency Sexual and Gender Based Violence and Women’s Health Project

Public Disclosure Authorized Environmental and Social Management Approach, including Environmental Management Plan and Medical Waste Management Plan

Executive Summary and Conclusions The Environmental and Social Management Approach (ESMA) provides general policies, guidelines, codes of practice and procedures to mainstream environmental and social (E&S) due diligence during the implementation of the World Bank supported Great Lakes Emergency Sexual and Gender Based Violence and Women’s Health Project. The objective of the abbreviated ESMA is to help ensure that activities will be in compliance with the national legislations of Rwanda and the World Bank’s E&S safeguards policies.

Public Disclosure Authorized The document is the main due diligence instrument required by the World Bank as financer, and additionally covers and goes beyond the Rwandan national regulatory requirements for project- level environmental assessment and management. The Environmental and Social Management Plan (ESMP) will be the main resource for environmental management and monitoring for the Client and set the standards and practices that will guide environmental and social project performance. It will become part of the tender package and environmental management and compliance will constitute a subsection of line items in the bill of quantities (BoQ). The selected bidders will be required to accept E&S conditions and tasks upon contract signature, and the implementation of the ESMP will be an integral part of the construction contracts. The monitoring of E&S performance will, much as other quality criteria, be tied to contractual penalties and damage restoration requirements via appropriate contractual clauses.

Public Disclosure Authorized The project has been designed to cause minimal environmental or social adverse impacts; those which are expected are temporary, minor, confined to locations within already existing structures, compounds and built up areas, and are mitigable with standard, readily available measures. Due to the need to manage the limited, site-specific environmental and social impacts caused by activities supported by the proposed operation, the World Bank’s Safeguards policy on environmental assessment (OP 4.01) was triggered. The following two safeguards instruments are anticipated to fully manage and mitigate the potential adverse social and environmental impacts of activities: (i) an Environmental Management Plan, and (ii) a Medical Waste Management Plan.

Project Description

The Great Lakes Emergency Sexual and Gender Based Violence and Women’s Health Project

Public Disclosure Authorized includes Burundi, the Democratic Republic of Congo, Rwanda and the International Conference on the Great Lakes Region (ICGLR). The Project Development Objectives (PDO) of the regional project are to (i) expand the provision of services to mitigate the short and medium term impact of SGBV, and (ii) to expand utilization of a package of health and nutrition interventions targeted to poor and vulnerable females. The Rwanda project will contribute to the first objective

1 of the regional project. Direct project beneficiaries include male, female and child survivors of SGBV. In addition, the project will provide selected support to families of survivors as well as support at the community level.

The project will support the following components: (i) Holistic support to survivors of SGBV and violence prevention, and (ii) Regional and National Knowledge Sharing, Research and Capacity Building.

Component 1: Holistic Support to Survivors of Sexual and Gender Based Violence and Violence Prevention

This component will support delivering an integrated package of short and medium term assistance to survivors of SGBV at both community and health facility levels through scaling-up the ISANGE OSCs while promoting gender equality, behavioral change and violence prevention in the intervention zones. The holistic approach aims to support survivors’ physical, mental, social and economic well-being, taking into account the multiple needs, causes and consequences of SGBV. A holistic response will contribute to preventing or decreasing different consequences related to SGBV and breaking the cycle of violence. Specifically, this component will support: (i) Integrated Support for Survivors of SGBV and Prevention of Violence at Community Levels; and (ii) Integrated Support for Survivors of SGBV at Health Facility level.

Sub-component 1A: Integrated Support for Survivors of SGBV and Prevention of Violence at Community Levels. This sub-component will include activities to support long-term behavioral and social norm changes to promote gender equality and reduce levels of violence, including SGBV through: (i) launching sensitization and advocacy activities to promote gender equality through public awareness campaigns (including radio, theater and television shows) at the national and community level including on existing laws, policies and services as well as the development of educational/informative modules designed to examine a range of issues directly or indirectly related to SGBV; and (ii) promoting behavioral change through the scaling-up of effective models for working with women, men, boys and girls at the community level to change behaviors and reduce violence in cooperation with other development partners. In addition, this sub-component will provide support to (iii) ensuring follow-up at the community level through social services and referrals to existing social protection programs for the economically vulnerable survivors of SGBV to promote their economic empowerment; and (iv) supporting safe houses to help survivors of SGBV to benefit from temporary safe housing before returning to their communities of origin.

Sub-component 1B: Integrated Support for Survivors of SGBV at Health Facility level. This sub- component would support needs of survivors through scaling-up the ISANGE OSCs at the district level, using the established Multidisciplinary Investigation and Intervention Team Model (MDIIT). The ISANGE OSCs will be established in 17 existing hospitals which would be rehabilitated and modernized to accommodate the OCSs in line with the National Strategy to ensure multidisciplinary services and protection of survivors, 4 of which will focus on providing services to refugee SGBV survivors.1 In addition, during the fourth year of the project, 6

1 The project selected hospitals to set up and upgrade ISANGE OSC s include: (i) Kigali Province: Kigali district Masaka, Muhima and Kibagabaga hospital; (ii) Western province: Karongi district Kilinda and Mugonero hospital, Nyamasheke district Kibogora hospital, Ngororero district Kabaya hospital, Rutsiro district Murunda hospital; (iii) Southern province: Ruhangodistrict Gitwe hospital, Gisagara district Kibilizihospital, Nyamagabe district Kaduha hospital; (iv) Northern province: Rulindo district Rutongo hospital, Gakenke district Nemba hospital and Ruli 2 additional ISANGE OSCs close to refugee camps and boarder areas currently supported by the Government of the Netherlands will be supported. The services are available free of charge, 24 hours per day, 7 days a week. The support provided under this sub-component will complement the recently signed three-year project to support the scaling-up of the ISANGE OSC model with support from the Government of the Netherlands and One-UN. Specifically, this sub-component will include: (i) setting up the ISANGE OSCs in selected hospitals with the necessary facilities, equipment and medical supplies; (ii) supporting clinical care, case management, rapid initial support, and referral depending on the needs of SGBV survivors and based on an individualized and confidential service-delivery plan addressing these needs; (iii) providing PEP emergency kits, medical care services, surgery equipment and medical consumable; (iv) providing medico- legal support through the collection of forensic evidence and the completion of the standard medico-legal form from the national police with the necessary additional equipment and intervention services; (v) providing mental health and psychological support through specialized psychotherapeutic interventions, family mediation, family mental health support, and psychiatric referral, as needed in coordination with social services; and (vi) providing legal aid through police services, legal advice, free legal counseling and representation in court, transport and judicial follow-up, in coordination with social services.

Component 2: Regional and National Knowledge Sharing, Research and Capacity Building.

The second component will support: (i) Regional and National Learning and Capacity Building; (ii) Research and Surveys; and (iii) Project Management. Under (i) two pre-identified buildings will be upgraded to function as a Center of Excellence on Sexual and Gender Based Violence.

Environmental Baseline Data The environmental baseline of all potential project locations is characterized by a pre-existing use as medical facilities, usually within larger villages or cities, within urbanized areas, compounds designated as hospitals for several years already, and entirely within existing structures. The medical facilities within which the ISANGE OSCs would be established are currently well managed, especially in terms of medical waste generation, which is treated in modern incinerators that are installed in about 90 percent of the 42 current district hospitals. Some incinerators are shared by several clinics, and all clinics and hospitals have access to incinerators to dispose their medical waste.

Regulatory oversight over waste management and general environmental impacts are shared by the Rwanda Environmental Management Authority (REMA) and MoH’s Department for Environmental Health (DEH), and is exercised in a diligent, professional and comprehensive manner.

Environmental and Social Impacts The project is expected to increase social cohesion at the family and community level by specifically addressing issues of stigmatization and rejection of survivors of SGBV, as well as activities to promote gender equality and change negative attitudes and norms towards women hospital; and (v) Eastern province: Bugesera district Nyamata hospital, Kayonza district Gahini hospital, and Gatsibo district Kiziguro hospital. Among these ISANGE OSC s, Kilinda, Mugonero, Kiziguro, and Kibilizi hospitals are close to borders and will focus on providing services to refugees.

3 and girls. In addition, the project support will provide targeted communities with better access to basic health service. Project investments may strengthen sound environmental and social practices around health facilities.

The project is not expected to have large scale, significant, or irreversible environmental or social impacts. Project activities are focused on delivery of an integrated package of short and medium term assistance to survivors of SGBV at both the community and health facility level, as well as providing high impact maternal and reproductive health and nutrition services or vulnerable and poor women. To ensure survivors of SGBV will be received in an adequate environment, the project will support setting up in existing health centers special rooms and upgrade existing ones.

Three types of activities have a potential to cause minor adverse impacts that will need to be minimized, mitigated and managed:

(i) The civil works related to the small construction or rehabilitation activities at the 17 identified ISANGE OSCs, which may cause noise, vibrations and emissions from vehicles and machinery, generate construction waste and involve potential risks regarding workplace and community health and safety. (ii) The same type of impacts, but possibly on a slightly larger scale for the rehabilitation of two pre-identified buildings, dedicated to become the SGBV Center of Excellence. (iii) The generation of additional quantities of medical waste during the operation of the health facilities. The planned construction activities under (i) and (ii), and subsequent operation of the ISANGE OSCs and rehabilitation for the Center of Excellence represent a minor scale and are following well established approaches and plans with little scope for variation. The expected impacts will be on a very small scale and widely dispersed and so may induce marginal adverse environmental impacts, significant or cumulative effects are not expected. The anticipated adverse impacts are not expected to go beyond the scope, intensity, and duration that would be generated by similar projects using Best Available Techniques (BAT). In addition, the scaling-up of the ISANGE OSCs follows the National Strategy for Scaling-up ISANGE OSCs (2013) issued by the GoR outlines in detail the models for ISANGE OSCs and need to be followed for all ISANGE OSCs across the country. The generation of medical waste is an unavoidable feature of operating clinics.

Compliance with World Bank and national safeguards policies The activities supported by the proposed operation are expected to have minor environmental and (to even lesser extent) social risks, that could manifest into negative impacts, if not properly managed.; therefore, the World Bank’s Safeguards policy on Environmental Assessment (OP4.01) is triggered.

Overall, the current project design will cause minimal environmental or social adverse impacts, all of which are temporary, minor, confined to locations within already existing structures, compounds and built up areas, and mitigable with standard, readily available measures. In activities (i) and (ii) (see section above) the expected impacts are those of any small scale construction site (noise, dust, exhaust gases, waste generation, workplace and community health and safety). The main anticipated adverse potential impact could occur during the operation of

4 the health facilities, where the planned medical care services will produce medical waste, that – classifiable as hazardous – will need to be managed appropriately. The generation of medical waste is an unavoidable feature of operating clinics. In activities (i) and (ii) the expected impacts will be on a very small scale and widely dispersed and so may induce marginal adverse environmental impacts, significant or cumulative effects are not expected.

The type, magnitude, duration and scope of impacts are currently well understood. The sites for the upgrading of ISANGE OSCs have been identified and the works are planned and designed with a high degree of certainty. The site for the center of excellence has been identified, consisting of 3 existing buildings which will be upgraded. No detailed ESIAs are required to determine the environmental and social impacts, which will be of a standard nature to be expected from all minor construction activities.

The current system of medical waste management in Rwanda is well organized and is fully understood by the project team. A system of incinerators, transport arrangements and treatment and disposal procedures exists, which the project will largely utilize, albeit with potential scale- up and upgrading activities. In addition, the MoH will use and follow the Ministerial Guidelines on Sorting, Transportation, Treatment and Final Disposal of Medical Waste from Site of Generation to Site of Final Disposal.

An environmental impact assessment will not be required for any of the sites, as both the project activities and the resulting impacts are clearly delineated and do not require additional investigations or assessments to be sufficiently understood to produce ESMPs for project implementation.

Regulatory Framework

Rwanda is just revising and enacting new institutional, policy and legislative framework in all its sectors and sub sectors after operating with colonial framework until after 1994. Most of the government ministries have already developed the respective sector policies and strategic plans most of which are based on poverty reduction strategy.

The constitution of the Republic of Rwanda

Adopted by the Rwandans during the Referendum of 26th March, 2003, it stipulates through different wordings of law the following message: ‐ Article 49: Each citizen has the right to healthy and satisfying environment. Each person has the right to protect to conserve and promote the environment. The government will take care of the environment protection. An Act defines the procedures of protecting, conserving and promoting environment.

Organic Law on Environment Protection and Management Article 67 of the organic law No 04/2005 of 08/04/2005 determining the modalities of protection, conservation and promotion of environment in Rwanda stipulates that every project shall be subjected to environmental impact assessment before obtaining authorization for its implementation. This applies to programmes and policies that may affect the environment.

Furthermore, the ministerial order No 003/2008 of 15/08/2008 gives the requirements and procedure for environment impact assessment and the ministerial order No 004/2008 of 15/08/2008 establishes the list of works, activities and projects that have to undertake an environment impact assessment highlights some projects including construction and repair of international and national roads, large bridges, industries, factories, hydro‐dams and electrical lines, public dams for water conservation, rain water harvesting for agricultural activities and artificial lakes, large hotels public building which accommodate more than one hundred daily, extraction of mines and public land fills among others. No public institution shall take a decision ,to warrant a certificate, approve or authorize the commencement of the project mentioned in annex of this order without prior environment impact assessment .Notwithstanding what is provided in this paragraph, Rwanda Development Board(RDB) May grant permission for a project to commence without carrying out environmental impact assessment .In addition ,when it is necessary and evident that the project might have a negative impact on the environment, RDB shall have the power to request the project ‘s owner to conduct an environmental impact assessment even if it is no listed in the annex.

Mitigation Measures: For the upgrading of health facilities: Environmental Management Plan (EMP) using the “checklist format” has been developed for this activity due to the small scale, routine manner of interventions, and the expected minor, temporary and localized nature of the potential impacts (see Annex 1.). The objective of the Environmental Management Plan (EMP) is to provide clearly structured guidance how to mitigate negative impacts and to enhance positive impacts resulting from the investment project. The EMP includes check-list format for constructions to be rehabilitated and Mitigation Plan and a Monitoring Plan. The checklist-format EMP will be customized to specific construction projects and become part of the tender and contract documents. The EMP will be produced, reviewed by the Bank, disclosed, consulted on and finalized before any disbursement on physical works of this type of activity may be undertaken. For rehabilitation of buildings for the Center of Excellence: While the expected impacts are analogous to those of the clinic rehabilitation works, they are expected to be slightly larger in scale. Thus the Checklist EMP may be too rudimentary an instrument and will be expanded with a more detailed narrative on site conditions, and more detailed provisions for E&S management, especially dust and noise control as well as traffic and pedestrian safety (due to nearby residential areas), and construction waste management. Also a building survey will be conducted to check for hazardous materials, especially asbestos. While Rwandan environmental regulations do not require separate management instruments for construction of the envisioned small scale, the approach proposed for the Bank-financed activities was fully endorsed by REMA. Medical care: A Medical Waste Management Plan has been produced for the generation and disposal of medical waste from the health facilities, which covers (a) anticipated waste composition and quantity; (b) existing medical waste management system, including free capacity, deviations from, and gaps to BAT, (c) existing regulatory framework and supervision / monitoring arrangements; (c) plan for using the existing medical waste management system, including any measures to upgrade or remedy identified gaps and deviations; and (d) additional arrangements for supervision and monitoring of medical waste management. (Annex 2) Overview roles and responsibilities

The project will be coordinated by Technical Committee chaired by MIGEPROF. The Technical Committee will be responsible to supervise and monitor the progress of the project by activities, identify potential challenges and develop mitigation measures to address these constraints as needed.

The Single Project Implementation Unit (SPIU) in MIGEPROF will be responsible for the production of the EMP and MWMP during the project’s initial preparation period, including (if required) the production of TOR, the management of the consultancy contracts (if required), the review and quality control of deliverables, the driving of the disclosure and consultation process, and the inclusion of the safeguards instruments into tender and contract documents, as well as operational procedures for ISANGE OSCs. The Technical Committee of the project, chaired by MIGEPROF, and comprising of MoH, RNP, MINALOC and MINIJUST will review and approve the EMP and MWMP. In addition, the Technical Committee will draw on additional resources and expertise from REMA and MOH-EHD, as these agencies are currently jointly mandated with the regulatory supervision of the health sector.

The SPIU within MIGEPROF will be responsible for the day-to-day follow up and supervision of the works implementation for the upgrading of the Center of Excellence with support of the Engineer from the RNP, including compliance with environmental and social due diligence provisions, and monitoring and supervision of EMP implementation during construction and operation. The SPIU within the MoH will be responsible for the day-to-day follow up and supervision of the implementation of the EMP for the upgrading of the ISANGE OSCs as well as the MWMP.

The World Bank Task Team will be responsible for ensuring the timely commencement of the preparation of EMP and MWMP, will ensure that no contracts for works that have a physical impact are signed, or construction, or operation of ISANGE OSCs starts without the required safeguards instruments in place. The Task Team will review ToRs (if required) as well as EMP and MWMP and ensure their scope and quality is satisfactory to the Bank, will review tender documents and construction contracts regarding due consideration of the safeguards instruments, and the inclusion of effective and enforceable contractual clauses. The task team will also follow up on the EMP and MWMP implementation through regular supervision missions (which will include an environmental specialist) during which document reviews, site visits and spot-checks will be conducted.

Capacity development

Trainings related to regulatory framework (existing laws and policies related to environment) are highly needed from REMA .This institution has also to provide trainings on environment mainstreaming in plans and policies of different institutions at centralized as well as decentralized level. Though World bank have provided introductory training on safeguard instruments, additional trainings are necessary for deep understanding of World Bank procedures regarding environment.

Annex 1. Rwanda Great Lakes Emergency Sexual and Gender Based Violence Project

Environmental and Social Management Plan (ESMP) Checklist for Civil Works

General Guidelines for use of ESMP checklist:

For construction projects that have low and clearly defined environmental and social risks, such as the small construction or rehabilitation activities at the 17 identified ISANGE OSCs and the rehabilitation of two pre-identified buildings dedicated to become the SGBV Center of Excellence, a streamlined approach is applied to mainstream the World Bank’s environmental safeguards requirements, as well as general good international practice into projects.

The ESMP checklist-type format covers typical key mitigation measures to civil works contracts with small, localized impacts or of a simple, low risk nature. This format provides the key elements of an Environmental Management Plan (EMP) to meet the minimum World Bank Environmental Assessment requirements for Category B projects under OP 4.01. The intention of this checklist is that it offers practical, concrete and implementable guidance to Contractors and supervising Engineers for simple civil works contracts. This checklist constitute an integral part of the bidding documents and eventually the works contracts.

The checklist ESMP has the following sections:

Part A includes a descriptive part that characterizes the project, specifies institutional and regulatory aspects, describes technical project content, outlines any potential need for capacity building and briefly characterizes the public consultation process. This section should indicatively be up to two pages long. Attachments for additional information may be supplemented as needed. Part B includes a screening checklist of potential environmental and social impacts, where activities and potential environmental issues can be checked in a simple Yes/No format. If any given activity/issue is triggered by checking “yes”, a reference to the appropriate section in the table in the subsequent Part C can be followed, which contains clearly formulated environmental and social management and mitigation measures. Part C represents the environmental monitoring plan to follow up proper implementation of the measures triggered under Part B. It has the same format as required for the monitoring plans produced under standard safeguards requirements for Category B projects. Part D contains a simple monitoring plan to enable both the Contractor as well as authorities and the World Bank specialists to monitoring due implementation of environmental management and protection measures and detect deviations and shortcomings in a timely manner.

Part B and C have been structured in a way to provide concrete and enforceable environmental and social measures, which are understandable to non specialists (such as Contractor’s site managers) and are easy to check and enforce. The ESMP should be included in the BoQ (bill of quantities) and the implementation priced by the bidders. Part D has also been designed intentionally simple to enable monitoring of key parameters with simple means and non- specialist staff.

CONTENTS

A) General Project and Site Information

B) Safeguards Information

C) Mitigation Measures

D) Monitoring Plan

PART A: GENERAL PROJECT AND SITE INFORMATION

INSTITUTIONAL & ADMINISTRATIVE Country Rwanda Project title Great Lakes Emergency Sexual and Gender Based Violence Project Scope of project and Two of activities have a potential to cause minor adverse impacts that will need to activity be minimized, mitigated and managed: 1) Civil works related to the small construction or rehabilitation activities at the 17 identified ISANGE OSCs ,which may cause noise, vibrations and emissions from vehicles and machinery, generate construction waste and involve potential risks regarding workplace and community health and safety 2) The same types of impacts, but possibly a slightly larger scale for the rehabilitation of two pre-determined buildings, dedicated to become the SGBV Center of Excellence. Institutional WB Project Management, Local Counterpart and/or Recipient arrangements Pia Peeters MOH (Name and contacts) [email protected] Dr.Fidele NGABO [email protected] / [email protected]

Implementation World Bank Safeguards Local Counterpart Local Inspectorate Contactor arrangements Supervision Supervision Supervision

(Name and contacts)

SITE DESCRIPTION Name of site Masaka, Muhima, Kibagabaga, Gitwe, Kilinda, Kibogora, Kibilizi, Rutongo, Ruli, Murunda, Gahini, Kiziguro, Rutongo, Mugonero, Kabaya, Kaduha, Nemba and Nyamata Describe site location The project selected hospitals to set up and Attachment 1: Site Map [ ]Y [ ] N upgrade ISANGE OSC s include: (i) Kigali Province: Kigali district Masaka, Muhima and Kibagabaga hospital; (ii) Western province: Karongi district Kilinda and Mugonero hospital, Nyamasheke district Kibogora hospital, Ngororero district Kabaya hospital, Rutsiro

district Murunda hospital; (iii) Southern province: Ruhangodistrict Gitwe hospital, Gisagara district Kibilizihospital, Nyamagabe district Kaduha hospital; (iv) Northern province: Rulindo district Rutongo hospital, Gakenke district Nemba hospital and Ruli hospital; and (v) Eastern province: Bugesera district Nyamata hospital, Kayonza district Gahini hospital, and Gatsibo district Kiziguro hospital Who owns the land? District Hospitals Description of Most hospitals are located in urban and pre-urban areas of Kigali and secondary geographic, physical, cities. The works will take place within the hospital’s compound perimeters. biological, geological, Generally, hospital’s surroundings are characterized by intense anthropogenic use hydrographic and and landscape/land se almost fully converted from their former states. socio-economic The project areas are expected to be well connected to transport infrastructure and context energy; most will have a functioning wastewater/sewage management system in form of canalization or cesspits. All hospitals have existing waste management arrangements with appropriate service providers. Locations and The locations are generally well connected to transport infrastructure, and distances distance for material are expected to be moderate for construction materials. Water will be on site in all sourcing, especially cases. The amounts of materials to be sourced are to small moderate, as the works aggregates, water, will mainly deal with rehabilitations and no large structural works are anticipated stones? LEGISLATION Identify national & The works will be registered in infrastructure unit of administrative District and local legislation & comply with REMA’s guidance for environmental protection. A separate approval of permits that apply to the works will not be required under Rwandan law, but an agreement was made project activity with REMA to share EMPs and share their informal occurrence.

PUBLIC CONSULTATION Identify when / This ESMP was disclosed at the following locations for period one month and a half where the public since 25th November 2015 ; The notice board of each district hospital where consultation process Isange One Stop Centers will be scaled up and on the notice boards of different took place health centers located in districts where Isange One Stop Centers will scaled up. In addition, meetings were with people in villages were Isange One Stop Centers will be established and comments received during the consultations have been duly considered in this final version of the ESMP.

INSTITUTIONAL CAPACITY BUILDING Will there be any [X ] N x or [ ]Y if Yes, Attachment 2 includes the capacity building program capacity building?

PART A: GENERAL PROJECT AND SITE INFORMATION

INSTITUTIONAL & ADMINISTRATIVE Country Rwanda Project title Great Lakes Emergency Sexual and Gender Based Violence Project Scope of project and activity Rehabilitation of three pre-identified buildings dedicated to become the SGBV Center of Excellence Institutional WB Project Management, Local Counterpart and/or Recipient arrangements Pia Peeters (Name and contacts) [email protected]

Implementation World Bank Safeguards Local Counterpart Local Inspectorate Contactor arrangements Supervision Supervision Supervision

(Name and contacts)

SITE DESCRIPTION Name of site KACYIRU Describe site location Situated at GASABO District, KACYIRU Attachement 1: Site Map [ ]Y [ ] N Sector, KAMUTWA Cell, UMUTEKANO Village Who owns the land? Government of Rwanda Description of geographic, The Site is bordering with Rwanda National Buildings in the North, A tarmac road in the physical, biological, geological, south and east, and Rwanda National Buildings in the West. The Buildings for hydrographic and socio- rehabilitation are archaic and thus need of a facelift to fit the standards of a modern economic context Center of Excellence. Locations and distance for Almost 20 Kms for stones and aggregates source whereas the source of water is a almost material sourcing, especially a Kilometer away from the site. aggregates, water, stones? LEGISLATION Identify national & local Plot No: 1493 at Place 1008 legislation & permits that apply to project activity PUBLIC CONSULTATION Identify when / where the This ESMP was disclosed at the following locations and dates: public consultation process REMA, for a period of one month since 6th October 2014 took place RDB, for a period of one month since 6th October 2014 Consultations with the public took place at the following dates and locations: Gasabo district, Kacyiru sector, Kamutwe cell, umutekano village, on 27th September 2014.Comments received during consultations have been considered in the this final version of ESMP. INSTITUTIONAL CAPACITY BUILDING Will there be any capacity [ ×] No or [ ]Y if Yes, Attachment 2 includes the capacity building program building?

ENVIRONMENTAL AND SOCIAL MANAGEMNENT PLAN (ESMP) Component/Subcom Parameter(Mitigati Mitigation measures Monitoring Monitoring Responsibility for Monitoring ponent/Activity on aspects) indicators methods monitoring frequency

Responsibility for mitigation Scaling up 17 IOSCs Notification and Notifying local construction and A written notice Field observation Contractor Ongoing during Worker Safety environment inspectorates and to local during the construction communities of upcoming construction and rehabilitation phase activities(Rehabilitating existing environment of existing MoH building in different hospitals inspectorates and buildings where IOSCs will be scaled up local communities

Notifying the public of the works A written notice construction site Contractor Rehabilitation through appropriate notification in the media and inspection during the phase in the media and/or at the public public accessible rehabilitation accessible sites(including the site sites including the phase MoH of works) site of works

Acquiring all legally required MoH permits for construction and/or The permits for rehabilitation construction and rehabilitation in Rehabilitation place Field observation MIGEPROF phase

Ensuring Workers’ PPE comply -Complaints construction site The contractor Ongoing during with international good practice from laborers inspection during the construction (always hardhats, as needed ,occupants rehabilitation phase masks and safety glasses, &community phase MoH harnesses and safety boots). -Incidents /accidents

Putting in place appropriate signposts in place construction site The contractor Ongoing during signposting of the sites will inspection during the construction inform workers of key rules and rehabilitation phase regulations to follow. phase MoH

The Contractor formally agrees The formal Checking the The contractor Ongoing during that all work will be carried out in agreement in terms of during the construction a safe and disciplined manner place (This item contract rehabilitation phase designed to minimize impacts on included in terms phase MoH neighboring residents and of the contract) environment.

Air Quality (e.g. : During excavation works dust Dust clouds construction site The contractor Ongoing during Increase in dust control measures shall be within inspectionIntera during the construction generation dues to employed, e.g. by spraying and construction sites ction with local rehabilitation phase clearing, civil works, moistening the ground, regular and road/path community phase and earth moving watering of unpaved roads, leading to it. activities remove soil/mud from tires of Dust deposition tracks and equipment before on vegetation and MoH leaving the area, covering haling rocks. trucks with canvass or any Complaints from equivalent material, set up local community temporary fence around the construction area

Demolition debris, excavated soil Dust clouds construction site The contractor Ongoing during and aggregates shall be kept in within sites and inspection during the construction controlled area and sprayed with road/path leading rehabilitation phase water mist to reduce debris dust to it. phase

Dust deposition MoH on vegetation and rocks.

Complaints from local communities

During pneumatic drilling or Dust clouds construction site The contractor Ongoing during breaking of pavement and within inspection during the construction foundations dust shall be construction sites rehabilitation phase suppressed by ongoing water and road/path Interaction with phase spraying and/or installing dust leading to it. local community screen enclosures at site. Stockpile the top soil in a safe Dust deposition place and use it as a final grading on vegetation and material or final layer rocks. As soon as possible ,rip-rap or revegatate the construction area Complaints from local community. MoH

The state of construction area after construction (garden or vegetation ).

The surrounding environment Dust clouds construction site The contractor Ongoing during (side walks, roads) shall be kept within sites and inspection during the construction free of soil and debris to road/path leading rehabilitation phase minimize dust to it. Interaction with phase local community Dust deposition MoH on vegetation and rocks

Complaints from local community

There will be no open burning of complaints from construction site Contractor Ongoing during construction / waste material at local community inspection during the construction the site Interaction with rehabilitation phase local community phase MoH

NOISE All machinery will comply with complaints from construction site Contractor Ongoing during Polish emission regulations, shall local community inspectionIntera during the construction well maintained and serviced and ction with local rehabilitation phase there will be no excessive idling community phase of construction vehicles at sites MoH

Construction noise will be Complaints from construction site Contractor On going during limited to restricted times agreed local communities inspection during the construction to in the permit and kept below Vibration due to Interaction with rehabilitation phase limit machinery and local community phase vehicles MoH

During operations, the engine Complaints from construction site Contractor On going during covers of generators, air local inspection during the construction compressors and other powered communities, e.g rehabilitation phase mechanical equipment shall be .(i) Interaction with phase closed, and equipment placed as noise;(ii)vibration local community MoH far away from residential areas as due machinery possible and vehicles

Water Quality slit fences in place construction site Contractor On going during The site will establish appropriate inspection during the construction erosion and sediment control rehabilitation phase measures such as e.g. hay bales Interaction with phase and / or silt fences to prevent local community MoH sediment from moving off site and causing excessive turbidity in canalization and nearby streams and rivers Waste Waste collection and disposal complaints from construction site Contractor On going during management(Const pathways and sites will be local community inspection during the construction ruction phase) identified for all major waste rehabilitation phase types expected from excavation, phase MoH demolition and construction activities.

Mineral construction and complaints from construction site Contractor Ongoing during demolition wastes will be local community inspection during the Operational separated from general refuse, Containers in rehabilitation phase organic, liquid and chemical place Interaction with phase wastes by on-site sorting and Existence of local community stored in appropriate containers. containers MoH

Construction waste will be A licensed construction site Contractor Ongoing during collected and disposed properly collector of inspectionIntera during the construction by licensed collectors waste in place ction with local rehabilitation phase and community phase operation phase

MoH

The records of waste disposal Books of records construction site Contractor On going during will be maintained as proof for of waste disposal inspection during the construction proper management as designed. rehabilitation phase and Interaction with phase and operational phase local community District hospitals during MoH operational phase

Operation Phase: waste containers in Construction site District on going during produced to be properly place where inspection hospitals Operational identified and adequately sorted different types of Interaction with during phase ; waste are local community operational storage space be provided. disposed off phase MoH

Solid Waste management(Oper ational phase) Spaces should be designed for Existence of Construction site District Ongoing during ongoing separation of paper, spaces meant for inspection hospitals Operational glass, aluminum, steel and separation of Interaction with during phase plastic. paper,glass,almini local community operational um,steel and phase MoH plastic

Asbestos (a) If asbestos is located on the Marking on Site inspection District On going during management project site, it shall be marked Hazardous Interaction with hospitals construction and clearly as hazardous material (b) materials local community during operational phase When possible the asbestos will containers in operational be appropriately contained and place phase sealed to minimize exposure Existing (c) The asbestos prior to removal mechanisms to (if removal is necessary) will be handle and treated with a wetting agent to dispose of minimize asbestos dust asbestos (D) If asbestos material is be stored temporarily, the wastes MoH should be securely enclosed inside closed containments and marked appropriately. Security measures will be taken against unauthorized removal from the site.

Toxic / hazardous (a) Temporarily storage on site Containers Construction site Contractor on going during waste management of all hazardous or toxic meant for the inspection and during construction and substances will be in safe temporary interaction with construction operation phase containers labeled with details of storage of local community phase and composition, properties and hazardous /toxic district handling information materials hospitals during operation (b) The containers of hazardous Licensed carriers phase substances shall be placed in an in place leak-proof container to prevent spillage wastes to be transported by specially licensed carriers and disposed in a licensed facility MoH

(d) Paints with toxic ingredients or solvents or lead-based paints will not be used

Establish the center Notification and Notifying local construction and A written notice Field observation Contractor Ongoing during of excellence Worker Safety environment inspectorates and to local during the construction communities of upcoming construction and rehabilitation of phase activities(Center of excellence to environment existing MIGEPROF be established) inspectorates buildings and local communities

A written notice construction site Ongoing during in the media and inspection construction public accessible phase Notifying the public of the works sites including MIGEPROF through appropriate notification the site of works contractor in the media and/or at the public during the accessible sites(including the site rehabilitation of works phase Acquiring all legally required The permits for MIGEPROF Ongoing during permits for construction and/or construction and construction rehabilitation rehabilitation in phase place

Field observation MIGEPROF -Complaints construction site The contractor Ongoing during from laborers inspection during the construction ,occupants and rehabilitation phase Ensuring Workers’ PPE comply community phase MIGEPROF with international good practice -Incidents (always hardhats, as needed /accidents masks and safety glasses, occurrence harnesses and safety boots). construction site The contractor Ongoing during inspection during the construction signposts in rehabilitation phase Putting in place appropriate MIGEPROF signposting of the sites will place phase inform workers of key rules and regulations to follow. The contractor formally agrees The contractor Ongoing during that all work will be carried out in The formal during the construction a safe and disciplined manner agreement in rehabilitation phase Checking the designed to minimize impacts on place (This item phase terms of MIGEPROF neighboring residents and included in contract environment. terms of the contract)

Air Quality During excavation works dust Dust from sites construction site contractor Ongoing during control measures shall be and road/path inspection during the construction employed, e.g. by spraying and leading to them. Interaction with rehabilitation phase moistening the ground local community phase Dust deposition on vegetation MIGEPROF and rocks

Complaints from local community

Demolition debris, excavated soil Dust from sites construction site Contractor Ongoing during and aggregates shall be kept in and road/ path inspection during the construction controlled area and sprayed with leading to them; rehabilitation phase water mist to reduce debris dust dust deposition phase on vegetation MIGEPROF and rocks; complaints from local community

During pneumatic drilling or construction site Contractor Ongoing during breaking of pavement and inspectionIntera during the construction Dust from sites foundations dust shall be ction with local rehabilitation phase and road/ path suppressed by ongoing water community phase leading to them; spraying and/or installing dust dust deposition MIGEPROF screen enclosures at site on vegetation and rocks; complaints from local community

Surrounding environment (side construction site Contractor On going during walks, roads) shall be kept free of inspection during the construction soil and debris to minimize dust rehabilitation phase Interaction with phase local community Dust from sites and road/ path MIGEPROF leading to them; dust deposition on vegetation and rocks; complaints from local community

There will be no open burning of complaints from construction site contractor Ongoing during construction / waste material at local community inspection during the construction the site Interaction with rehabilitation phase local community phase

MIGEPROF

NOISE All machinery will comply with Complaints from construction site contractor Ongoing during RW emission regulations(and in local community inspection during the construction their absence with WBG ESH Interaction with rehabilitation phase and guidelines);will be well serviced ; local community phase operation phase there will be no excessive idling of construction vehicles at sites MIGEPROF

Construction noise will be Complaints from construction site The contractor Ongoing during limited to restricted times agreed local inspection during the construction to in the permit communities Interaction with rehabilitation phase about noise and local community phase vibrations due to MIGEPROF machinery and vehicles

During operations the engine construction site contractor Ongoing during covers of generators, air inspectionIntera during the construction compressors and other powered ction with local rehabilitation phase mechanical equipment shall be community phase closed, and equipment placed as Complaints from far away from residential areas as local MIGEPROF possible communities about noise and vibrations due to machinery and vehicles construction site contractor Ongoing during inspection during the construction rehabilitation phase The site will establish appropriate Interaction with phase local community erosion and sediment control slit fences in Water Quality measures such as e.g. hay bales MIGEPROF place and / or silt fences to prevent sediment from moving off site and causing excessive turbidity in canalization and nearby streams and rivers

Waste Waste collection and disposal construction site contractor Ongoing during management pathways and sites will be inspection during the construction identified for all major waste rehabilitation phase types expected from excavation, complaints from phase MIGEPROF demolition and construction local community activities.

Mineral construction and construction site contractor Ongoing during demolition wastes will be inspection during the construction separated from general refuse, rehabilitation phase organic, liquid and chemical Interaction with phase complaints from wastes by on-site sorting and local community local community; stored in appropriate containers. MIGEPROF containers in place

Construction waste will be construction site contractor Ongoing during collected and disposed properly inspection during the construction by licensed collectors rehabilitation phase Interaction with phase A licensed local community collector of MIGEPROF waste in place

The records of waste disposal Books of records construction site contractor Ongoing during will be maintained as proof for of waste disposal inspection during the construction proper management as designed. rehabilitation phase and Interaction with phase operation phase local community MIGEPROF

Annex 2. Medical Waste Management Plan Outline

Outline and Context This is the medical waste management plan (MWMP) f or the following facilities, functions and components: : Mugonero Hospital (Karongi District), Kibogora Hospital (Nyamasheke District), Kabaya Hospital (Ngororero District), Kibagabaga Hospital (Gasabo District), Kirinda Hospital (Karongi District), Masaka Hospital (Kicukiro District) , Kiziguro Hospital (Gatsibo District) , Ruli Hospital (Gakenke District), Muhima Hospital (Nyarugenge District), Nemba Hospital Gakenke Hospital,Gahini Hospital (Kayonza Hospital) Murunda Hospital (Rutsiro District), Nyamata Hospital ( Bugesera Hospital, Rutongo Hospital (Ruhango District), Kaduha Hospital ( Nyamagabe District), Kibilizi Hospital (Rusozi District), Gitwe Hospital (Ruhango District). The MWMP describes type of waste generated, their volume, collection method, transport, safe packaging and final disposal. The below MWMP is developed as a template. For each hospital, the template needs to be used for tailored analysis and customized for each One Stop Center.

1. Review of current Waste Management System On project and clinic levels: Review of current medical waste management and disposal procedures and practice; compliance with domestic regulations and international good practice; identification of major gaps and deviations from regulations and good practice. On clinic level: Assessment / estimate of current waste volumes; number of segregated waste streams; inventory of existing equipment and facilities: collection boxes, storage facilities, transport to incinerators, incinerators on site / off site (distance from clinic?); type and condition of incinerators; disposal of ashes, and other non-incinerated waste types (e.g. glass / plastic bottles, sharps, placentas, food waste, non-infectious waste); (see checklist in Annex 1)2

2. Demand and Gap Analysis On project and clinic level: Expected additional volumes for each relevant waste type, resulting from project activities; assessment of available additional capacity for each waste type; identification of capacity constraints and bottlenecks; 3 On clinic level: Quality and compliance assessment of current MWMP: condition, functionality of collection boxes; safety of temporary storage containers / facilities, and transport to incinerators / deposits; completeness of incineration process; odor of flue gases, prevailing wind directions, existence of sensitive receptors? (e.g. gardens, fields, residences, schools, hospital facilities, patients’ wards); quality and dimensions of receptacles for incineration residue (ashes) and non-incinerated medical waste (e.g. placentas); (see checklist Annex 2)

3. Compliance and Operational Management Plan Preparation of a plan for: (i) establishing compliance in current MWM system, including repairs, upgrading, replacement and new construction / procurement of equipment and facilities; (ii) creating and operating system and procedures for handling additional medical waste quantities generated by project activities, (iii) ensuring staff is aware, trained, disciplined and diligent in

2 Suggested to calculate based upon one or two ISANGE OSCs 3 Suggested to calculate based upon estimates for one new ISANGE OSC and extrapolate total for the 17 new ISANGE OSC s based upon estimates of one ISANGE OSC s

29 operating MWMS; (iv) implementing a monitoring plan for the generated quantities of the various waste types, their treatment and final disposal; include basic quality criteria such as: state of repair of system components, cleanliness around MWM facilities, completeness of incineration process, smoke development. In addition, the MoH will use and follow the Ministerial Guidelines on Sorting, Transportation, Treatment and Final Disposal of Medical Waste from Site of Generation to Site of Final Disposal.

Attachment 1: Waste Management System Review

(1) Current waste volumes(Average of three hospitals)

Estd. volume/week Waste type Collection system Transport Final disposal (m3) infectious waste 0.74 Sorting system and Manual transport incineration temporary disposed system in the dust bins with specific color sharps & needles 0.039 Using safety boxes Manual transport incineration and other marked system and secured containers bottles / glass 0.091 Manual transport Multipurpose system separated pits human tissue 0.0267 sorting in the no Manual transport Burying in protected sharp infectious system pit waste bag with Red Colors food waste 0.176 Collected through Manual transport composting bins system other waste 0.450 Piped Piping system soak pits

(2) Incinerators / disposal facilities4:

Auxiliary Weekly capacity fuel / Type Condition Remarks (m3) incineration method Construction materials: Metal and Medical Are used Functional refractor cement, Source of energy: Cumulative capacity wastes are when modern Electricity and fuel. Hourly : 0.630 m3 transferred incinerator is destruction capacity : 50-60 Kg/h Our incinerators to an others not well ,L.C.P. (lower calorific power) of have capacity to Health functioning waste : 4 KW/Kg, Heating power : incinerate Facility in 240 KW/h, Volume of combustion 3 Chamber 1200 L , Temperatures 600dm /h*10hours case of 900°c 1100°c ,Power of burners, of autonomous per breakdown. Power of banner: (Combustion 250 day *7 days=14 KW, Post - combustion 250 KW), m3.The average per Chimney: (Diameter400 mm, High week is 8,00 m ), Size of the loading door ( 14000dm3=14 m3 cm 70x70),Weight : 6 T Power of the adaptable energy recover :250

4 This is based on an example from DRC, please adjust according to Rwanda context

KW/h Construction materials: Metal and The incineration is carried refractor cement, Source of energy: out according to standard Electricity and fuel. Hourly procedures except one case Of Kabaya district hospital destruction capacity : 50-60 Kg/h where there is a difference ,L.C.P. (lower calorific power) of in the level between the waste : 4 KW/Kg, Heating power : hospital buildings and the 240 KW/h, Volume of combustion wood, but site where the incinerator is Chamber 1200 L , Temperatures MW is installed/built. So for other 900°c 1100°c ,Power of burners, usually incinerators there is no

Power of banner: (Combustion 250 doused with problem. KW, Post - combustion 250 KW), gasoline and Chimney: (Diameter400 mm, High set alight 8,00 m ), Size of the loading door ( cm 70x70),Weight : 6 T Power of the adaptable energy recover : 250 KW/h

Placenta pit: 10 m of deep and 2 --- safe m width Ashes disposal pit: 5 dm3 /week In Rwandan Placenta and Functional culture, other human human body body parts parts are not incinerated. The burial method is used

Other remarks: There are existing health and safety policies and guidelines, protocols and procedures and capacity to handle hospital waste. In most of facilities, health care wastes generated are appropriately segregated into sharps, infectious and non-infectious and kept in labeled containers. Highly infectious wastes are first autoclaved before incineration.

Attachment 2: Demand and Gap Analysis

(1) Current waste volumes

Identified Remarks (e.g. time Compliance Rectification Measures and cost Component / Issues Gaps description requirements) condition & Insufficiency of Avail appropriate functionality of appropriate protection collection boxes public bins Avail appropriate public ca. …..weeks bins ca. 1, 000,000RwF safety of temporary Storage container Avail appropriate storage storage containers / not appropriate container ca. ………..weeks facilities ca. 1,500,000 RwF

31 transport to incinerators / In some areas, the Rehabilitation of route to deposits: safety and status of the incinerator functionality of route driveways are Avail adequatte equipment ca..…. weeks and equipment not in a good for transport conditions (wheelbarrow..) ca. 75000 RwF

Incinerators: In some Heath To add the length of Ca……..……weeks completeness of facilities, fumes incinerator chimney (Is a ca 2,500,000 RwF incineration process; should change the option) odor of flue gases, direction prevailing wind depending to the directions, existence of wind directions sensitive receptors? (e.g. and should affect gardens, fields, neighboring residences, schools, residents hospital facilities, patients’ wards) quality and dimensions No gaps Keep up the standards Ca ……………week of receptacles for identified where ca…………… RwF incineration residue modern (ashes), protection incinerator was against rain and leaching installed

quality and dimensions 10 - 6 m3 , Not Suggest to construct a of receptacles for non- appropriate multipurpose separate pit ca……………Weeks incinerated medical (Ash, placenta, bottles..) 10,800,000 RwF waste (e.g. placentas) (Is a proposed option)

Annex 3. Rwanda Ministry of Health: Ministerial Guidelines on Sorting, Transportation, Treatment and Final Disposal of Medical Waste from Site of Generation to Site of Final Disposal

Introduction:

In Rwanda, efforts to improve injection safety and healthcare waste management are remarkable in public health facilities settings and in community. Elaboration of these Guidelines is crucial in sustaining efforts already employed in healthcare waste management and injection safety. Its primary purpose is to provide guidance to health professionals and waste handlers in proper handling of medical waste with particular emphasis on transport of waste in a manner that does not endanger the lives of waste handlers or other human lives along the road where medical waste is transported. The Ministry of Health takes this opportunity to request Districts, District Hospitals and Staff to ensure that these guidelines are thoroughly implemented. By definition, Medical waste is any waste generated from medical activities including preventive, curative and palliative care in the field of human and veterinary medicine. Medical waste can be divided into three major types: Infectious sharp waste, Infectious non sharp waste and Non infectious waste. When Non infectious waste gets into contact with infectious waste, it also becomes infectious.

General provisions

 All equipment used in the country including that in non-governmental sector should meet the recommended standards.  Adequate injection material supplies should be made available at the districts and Health facilities.  Matching quantities of injection safety materials such as syringes and water resistant puncture proof safety boxes are systematically ordered for; for all injections including immunization, curative and reproductive health services.  The different departments and programs should plan and lobby for enough budgetary allocation for injection materials for all programs including immunization, curative and reproductive health services.  Relevant departments and programs should be put in place with effective systems for forecasting, procuring, distributing, monitoring and supervision of the way injection

equipment and supplies are handled.  Solid chemotherapeutic should never be disposed in the regular trash or in biohazard bags.  Liquid waste should be treated before being discharged in appropriate channels  Liquid chemotherapeutic wastes should never be disposed down the drain or sanitary sewer.

Transportation of medical waste

 Transportation of medical waste should be done in covered/sealed trucks & containers to avoid littering. Trucks and containers carrying or containing medical waste should be have warning marks to indicate that they are carrying such type of waste.  Where transportation is contracted, the contractor should be licensed by REMA (Rwanda Environmental Management Authority) or Ministry Of Health and should provide proof that he has necessary expertise in handling medical waste.  Trucks carrying medical waste should avoid highways that are known to harbor heavy traffic or crowded places like markets, churches and other public places.  Transportation of medical waste between the points of generation to site of final disposal should be done during times when less traffic is expected on the road. Slippery roads that may increase likelihood of accidents should be avoided.  Workers who collect, transport and dispose of hazardous waste must be trained on proper work procedure, emergency procedures and the use of appropriate personal protective equipment

Waste treatment

 The practice of waste treatment depends on the type of waste and availability of waste treatment technologies. Alternative treatment technologies that are environmentally friendly and cost-effective should be encouraged.  The following treatments are recommended: Autoclaving for biomedical waste, Liming for pathological waste (embalming is optional), Chemical decontamination for blood/blood containing body fluids- hypo chlorite can be used, Infectious waste and sharps should be incinerated.  In case of the lack of the incinerators, the health facility should transport off site the

contaminated waste  Health facilities should have a protected separated medical waste pits (ash and placenta) with a vial crusher

Final waste disposal

 Waste handlers are strongly required to use heavy duty utility latex gloves and appropriate personal protective equipment when handling waste. They must ensure that containers are decontaminate after use and use heavy duty during waste handling and disposal  Always wash hands after handling contaminated wastes. Handle wastes carefully to avoid spills or splashes  Avoid transferring contaminated waste from one container to another  Incineration is the preferred method for waste disposal, as the heat will generally be sufficient to destroy infectious microorganisms and will also prevent scavenging and reuse of discarded items.  Rinse glass containers thoroughly with water; glass containers may be washed with detergent, rinsed, dried and reuses  For plastic containers that contained toxic substances such as glutaraldehyde, rinse three times with waster and dispose by incineration; these containers may be used for sharp disposal containers, but do not reuse them for any other purpose

Incineration of medical waste

This is a process of converting waste into ash under the high temperature (≥ 850oC). Incineration provides high temperatures and destroys microorganisms; and therefore, is the best method for disposal of contaminated wastes; incineration also reduces the bulk size of wastes to be buried. Simple incinerators like DeMontfort incinerator with double chamber can be built in health centers from locally available materials in refractory bricks. It is important to note that only non carcinogenic agents should be incinerated. Special measures for the handling of Management of chemotherapeutic and other radioactive waste should be taken. These measures can be found at the MoH/Environmental Health Desk. Also, only modern and DeMontfort incinerator with 850oC for combustion and 1100oC for post combustion is acceptable in order to avoid environmental pollution.