Source document: https://docs-lawep.s3.us-east-2.amazonaws.com/1697800545470.pdf (Dominica)
HOW TO IMPLEMENT THE HOUSE-LEVEL ENVIRONMENTAL & SOCIAL MANAGEMENT PLAN?
Dominica Housing Recovery Project Presented by: Environmental Specialist, Project Implementation Unit OUTLINE  Environmental & Social Management Plan (ESMP) Basics  HRP Environmental & Social Operational Policies  Overview of the House-Level ESMP  Major categories  Sub-categories checklist guide  Mitigation Measures to support ESMP Compliance – Examples  ESMP Implementation  Along the Homeowner Journey  The Contractor Journey  Policies & Tools to support ESMP implementation  ESMP Audit Form  ESHS Tips  Challenges on ESMP Implementation  Proposed Solutions  Contractor benefits to implement the ESMP  Next Steps TRUE OR FALSE  Non-compliance with environmental and social safeguards on this project can result in a construction stop order by the Physical Planning Division, HRP-PIU and the World Bank.
TRUE  The HRP safeguards and World Bank safeguards personnel cannot monitor compliance of ESMP at construction sites unless they are on island or on-site.

 Among the first communication received from the World Bank safeguards specialist when construction on the first house commenced was:  Congratulations!

 The contractor is in breach of compliance with the ESMP.
FALSE TRUE TRUE  Mitigation of environmental and social risks associated with workers’ and communities’ health and safety is one of the key areas of interest to the World Bank and HRP Safeguards.

TRUE  Health and safety at construction sites on Dominica is a high priority for the Government of Dominica and World Bank supported projects.

TRUE 3 ESMP BASICS  What is the ESMP?


 ESMP  Environmental and Social Management Plan  A simple checklist-type plan to monitor and address any environmental and social issues relevant to the housing project, including health and safety.

 An ESMP is mandatory for each beneficiary house under the Housing Recovery Project (HRP).

ESMP BASICS  Why is it needed for small residential construction?

 Project risk is rated: ‘substantial’.


 Environmental and social safeguards are part of national and World Bank policies.

 It guards against any potential threats to the integrity of the resilient construction methods, with the intent to avoid, reduce or mitigate environmental, social, health and safety risks.

 It improves decision making; thus promotes efficient and controlled construction cost.

ESMP BASICS  What is the output?


Compliance with the ESMP will:  Protect homeowners, contractors, the workers, the community, the public and the project.

 Pursue a low hazard house construction area for resilience to category 5 hurricanes and seismic activity.

ESMP BASICS  Who implements the individual house-level ESMPs?

 Managed by the contractor/builder and implemented by all construction trade personnel.
 Supervised by the Design & Supervision Firm (DSF), who then reports to the Project Implementation Unit (PIU).

 Overall monitoring is done by the PIU safeguards team with reporting obligations to the World Bank.

 Supported by relevant stakeholders based on the safeguard in question.

ESMP BASICS  When will the inspections take place?

 At all stages of construction, including prior to disbursement of the second, third and fourth payments.
 Spot checks without notice at any given point by the PIU safeguards team.

 Arrangements may be made for specific visits.

ESMP BASICS  Who approves ESMP compliance?

 Physical Planning Division (PPD) and PIU will approve the environmental and social safeguards according to their respective mandates.

 Compliance monitoring of the ESMP is coordinated among the DSF, PPD and PIU.

 Contractors can assess themselves using the ESMP Audit Form available on www.hrp.gov.dm.
Final decision is by the DSF, PIU and PPD.

 Can non-compliance with the ESMP lead to a Construction ‘Stop Order’?
 Yes, there are elements of the ESMP that could trigger a ‘Stop Order’ by the PPD surrounding three major pillars:  Illegal dumping  Environmental degradation  Health and safety (for anyone) ESMP BASICS  Best practice for compliance: communication  Contractors are encouraged to engage communication with key stakeholders to resolve all challenges in the quickest time in order to comply with the ESMP.
Stakeholders may include: beneficiary, construction workers, DSF, PIU, neighbour, national authorities, private entities, statutory bodies, community, public.

ESMP BASICS  Communicate: use signage and other means ESMP BASICS  How will the project handle COVID-19?

 COVID-19 forms a part of the ESMP implementation under the major category: Emergency Protocol.

 Follow guidelines of the Ministry of Health in all work pertaining to the project.
 Apply World Bank guidelines on construction sites for COVID-19  Handle complaints through the HRP Grievance Redress Mechanism  Monitor compliance.

 Report on compliance to the World Bank.

 Use the Environmental, Social, Health and Safety (ESHS) Tips for a basic guide to implement COVID-19 protocol.

Available on www.hrp.gov.dm.

ESMP BASICS  What guides the ESMP?

 The HRP Environmental and Social Management Framework (ESMF) provides a guideline for the project ESMP.
 The ESMF provides information about the project, its environmental and social context, social and environmental risks and mitigation measures, institutional arrangements, monitoring indicators, and capacity building and training requirements to ensure that the potential negative environmental and social impacts of project activities are minimized or mitigated, and positive impacts are encouraged and enhanced.
HRP ENVIRONMENTAL & SOCIAL OPERATIONAL POLICIES  World Bank Environmental and Social Operational Policies (OP) triggered:  OP4.01 Environmental Assessment  OP4.09 Pest Management  OP4.10 Indigenous Peoples Plan  OP4.11 Physical Cultural Resources  OP10.00 Contingent Emergency Response Component  National legislation, policies, guidelines, plans relevant to HRP safeguards – some include:  Physical Planning Act, Dominica Solid Waste Management Act, Environmental Health Act, Forestry and Wildlife Act, Parks and Protected Areas Act, Kalinago Territory Act, National Policy and Action Plan for Gender Equity and Equality, Guide to Dominica’s Housing Standards, … OVERVIEW OF THE ESMP HRP ESMP Main Categories OVERVIEW OF THE ESMP – SUB-CATEGORIES CHECKLIST No ESMP Main Activity ESMP Sub-Activity Monitored 1.
Site Security Maintain access control Material & equipment storage Worker storage arrangement Secure construction site & equipment 2.

Traffic Management Stakeholder communication Signage Movement control 3.

Chance Find Physical cultural resource Human OVERVIEW OF THE ESMP – SUB-CATEGORIES CHECKLIST No ESMP Main Activity ESMP Sub-Activity Monitored 4.

Site Stabilization, Erosion & Flood Control Site stabilization Erosion control Drainage installed Drainage performance 5.
Air Quality Dust control Pollution control Noise control 6.

Pest Management Control method Authorized personnel/company OVERVIEW OF THE ESMP – SUB-CATEGORIES CHECKLIST No ESMP Main Activity ESMP Sub-Activity Monitored 7.

Hazardous Management Asbestos handling, storage & disposal 8.

Waste Management Waste separation Use & management of hazardous materials, fuels, solvent, paints and petroleum products Secure storage and use on site Transportation of waste Disposal to landfill or authorized location 9.
Wastewater/Sewage Manage standing water Management Manage liquid waste Install septic tank House connection to septic tank & wastewater system OVERVIEW OF THE ESMP – SUB-CATEGORIES CHECKLIST No ESMP Main Activity ESMP Sub-Activity Monitored 10.

Workers’ Code of Conduct Training/orientation of workers Worker sanitation facility Labour & working conditions Occupational health & safety Emergency management 11.
Community Relations / Social Sensitivity Potential conflict with neighbours Community relations GRM activated, conflict resolution plan Communications, Consultations, Awareness 12.

Emergency Protocol Emergency protocol e.g.

COVID-19, weather events 13.

Other Any other activity MITIGATION MEASURES TO SUPPORT ESMP COMPLIANCE - EXAMPLES Awareness Sessions throughout Construction Prior to Construction Contract Award  HRP Contractors’ Workshop – safeguards’ presentations on:  How to implement the ESMP?
 Workers’ Code of Conduct.

 Grievance Redress Mechanism.

Post Construction Contract Award  Contractor - PIU Safeguards Awareness Session on ESMP & ESHS Tips  Discuss and provide hard copy of the ESMP Audit Form & ESHS Tips  Held immediately post signing of the Beneficiary-Contractor Agreement at the PIU Office.

 DSF - Contractor sessions on site, by call, at office.

 Contractor – workers sessions with workers.

 Contractor, workers awareness sessions with national authorities where relevant.
MITIGATION MEASURES TO SUPPORT ESMP COMPLIANCE - EXAMPLES Site Preparation – Earth Works/Excavation Phase  Chance find of human body remains  Construction halt until clearance provided by DSF to continue.

 Work with Central Investigation Department (CID) during investigation.

 Chance find of historical artifacts  Construction halt until clearance provided by DSF to continue.

 Work with Physical Planning Division (PPD) during investigation.

 Cooperate with DSF, CID and PPD where relevant.


MITIGATION MEASURES TO SUPPORT ESMP COMPLIANCE - EXAMPLES Site Preparation & Construction Phases  Community relations/social sensitivity – use appropriate communication with homeowners, neighbours, community, public e.g.

town hall meeting to inform of project; traffic disruption announcement on narrow road; workers briefed on workers’ code of conduct.
 Workers’ health & safety – use of personal protective equipment; safe placement of tools in use; clear pathway; beneficiaries are not allowed on site unless guided by the contractor or supervisor and dressed in proper wear e.g.

no slippers at construction sites; ramps to the house must be secure.

 Site security – restrict access to avoid accidents; secure material to maintain resilient quality; beneficiaries cannot access site anytime desired and without PPE.
MITIGATION MEASURES TO SUPPORT ESMP COMPLIANCE - EXAMPLES Site Preparation & Construction Phases  Air quality – control dust by spraying water on work surface; free area of debris.

 Waste management – separate waste to reduce health hazard; no burning; secure waste on site; cover transported waste; dispose at landfill; secure proof of tipping fee.

 Pest control – control must be performed safely by registered pest control companies.

 COVID-19 transmission – sanitization arrangement/facility.
 Other (e.g.

biodiversity protection) – purchase natural materials from authorized dealers to ensure sustainable use e.g.

high quality timber from Forestry Division; verify that drainage do not affect sensitive area.

MITIGATION MEASURES TO SUPPORT ESMP COMPLIANCE - EXAMPLES Demobilization Phase  Ensure ESMP is in full compliance  Clean the site.

 Resolve any grievances.

 Protect the natural environment  Restore surface and vegetation where it has been significantly disturbed.
ESMP IMPLEMENTATION ALONG THE HOMEOWNER JOURNEY  STAGE 3.

The Design & Supervision Firm documents potential environmental and social safeguards concerns.

This will highlight which of the ESMP categories that require additional attention for contractors/builders to implement.

Contractors must plan accordingly.

 STAGE 4.

Once a beneficiary arrives at stage 4, the contractor/builder will be required to implement the individual house-level ESMP developed by the Design & Supervision Firm.

 STAGES 5-8.
 STAGES 5-8.

Prior to each of stages 5, 6, 7 and 8 during construction, contractors/builders must fulfil obligations of the ESMP at each site.
ESMP IMPLEMENTATION – THE CONTRACTOR JOURNEY ESMP Complete & 1st Orientation DSF develop ESMP per house DSF establish ESMP in the MIS PIU & Contractor introductory consultation, DSF & Contractor consultation post contract award Establish Mitigation Measures & SOPs Adapt to house level prior to construction Implement with respective stakeholders during construction Adjust & implement during construction Awareness, Guidance, Workshops Deliver ESMP orientation sessions on site to workers regularly Communicate mitigation measures, SOPs, ESMP checklist on-site, ESHS Tips using various communication channels Propose & participate at appropriate workshops and sessions with key stakeholders ESMP Monitoring, Evaluation, Reporting Completion Implement during preparation and construction stages with close supervision & inspections to ensure building codes & environmental and social safeguards are adhered to – by Contractor, DSF, PIU, PPD, EHD, Division of Labour DSF reports on ESMP compliance using the MIS Complaints handled via HRP GRM & disputes via contract management Climate Resilient home received by homeowner ESMP Implementation Model – good examples including improvements at all construction stages POLICIES AND TOOLS TO SUPPORT ESMP IMPLEMENTATION  Implementation is guided by the HRP Environmental & Social Management Framework Version 2 (ESMF v2) to guide contractors  HRP Environmental & Social Management Plan (ESMP) Guide – Annex 7  Mitigation Measures - part of the ESMP Guide – Annex 7  World Bank Guidelines
 on Construction Sites for COVID-19 – Annex 7  Project Stakeholders & Roles, and Specific Areas of Cooperation & Processes to Support Environmental & Social Safeguards - Annex 5  Contingent Emergency Response Component (CERC) ESMF – Section 12  The Grievance Redress Mechanism  Tool to handle complaints on ESMP implementation can be logged on Grievance form - HRP website or HRP App  Indigenous Peoples Plan  Strategy applied for the Kalinago homeowners under the HRP POLICIES AND TOOLS TO SUPPORT ESMP IMPLEMENTATION  Ministry of Health & World Bank COVID-19 guidelines  General - Ministry of Health website  Construction works – ESMF v2  HRP Management Information System (MIS)  Database tool to monitor, evaluate and report on contractor ESMP compliance for each house construction  Used by PIU, DSF, as well as PPD  ESMP On-Site Monitoring & Awareness Tools for Contractors, DSF & PIU  Monitoring: Environmental and Social Management Plan (ESMP) Audit Form  Awareness: Environmental, Social, Health and Safety (ESHS) Tips (updated version will be placed on the website)  To reference tools and policy documents, visit:  HRP website: www.hrp.gov.dm  Dominica HRP App - download on Google Play Store ESMP AUDIT FORM  USE: A tool used to assess contractors’ compliance with the ESMP.
 Results are housed in the Management Information System (MIS) of the project.

 USERS:  Contractors ESMP compliance rating is measured by DSF using this form  Contractors encouraged to use it as a guide and to self assess compliance  Contractors may use it for daily worker orientation sessions  AVAILABLE: on www.hrp.gov.dm 29 ESHS TIPS  Disclaimer: DSF provides directives for ESHS and ESMP tips.

The tips are a basic guide.

 Updated versions are available on www.hrp.gov.dm.
 Tips will be discussed during ESMP introductory session with PIU Safeguards Specialist.
 Major areas covered:  General Environmental, Health and Safety  Workers’ Code of Conduct:  Priority Actions  Prohibited Actions  Traffic Management – particularly for construction sites near the road or in a residential area  COVID-19 Guidelines for construction works  PPE Guide  Chance Find Guidelines  Grievances versus Disputes for HRP Contractors 30 TOP CHALLENGES ON ESMP IMPLEMENTATION  Hazard communication that leads to workers’ action to comply  Tool guarding/storage re safety risk for authorized visitors  Unsecure ramp to access the house under construction  PPE use and basic clothing attire  Equipment storage in open space  Beneficiary on site without permission and inappropriate PPE  Litter e.g.
bottle, cement bag (including from beneficiary)31 OTHER CHALLENGES ON ESMP IMPLEMENTATION  No clear pathway  Fall protection e.g.

from roof, ladder  Scaffolding  Voluntary assistance using unsafe practices  Any others anticipated?
32 PROPOSED SOLUTIONS  Daily communication to workers  Frequent monitoring  Engage DSF, PIU on challenges to support contractor efforts  Contractor-Beneficiary Forum  Identify challenges of both stakeholders  Engage key partners  Conclude on approach to solutions  Any others proposed?
33 CONTRACTOR BENEFITS TO IMPLEMENT THE ESMP  Results in a resilient house  Encourages a spirit of cooperation and transparency  Creates a hazard risk managed environment  Controls construction cost  Contractors & Skilled Trade Workers in good standing at National and World Bank levels = better business relations  Happy people  Improved quality of life NEXT STEPS 1.

2.

3.

Beneficiary selects a few pre-qualified contractors; provided to the PIU.
Pre-qualified contractor is invited by the PIU to bid to construct the beneficiary house.

Pre-qualified contractor who wins the bid will receive a letter of award to construct the beneficiary house from the PIU.

4.

On day of signing the beneficiary-construction agreement, the PIU safeguards team conducts the initial environmental and social safeguards introductory awareness session with the awarded contractor and with the beneficiary.
At this session, a hard copy of the HRP ESMP Audit Form and the Environmental, Social, Health and Safety (ESHS) Tips (current version) is provided to the contractor.

LOOKING FOR ESMP IMPLEMENTATION BEST PRACTICE MODELS… …get ready to BE AMONG THE FIRST THANK YOU Project Implementation Unit- Housing Recovery Project (HRP-PIU) CONTACT PIU ESMP Safeguards Team Environmental Specialist: environspecialisthrp@dominica.gov.dm Social Safeguards Specialist: socialsafeguardshrp@dominica.gov.dm