Mitigation and monitoring actions for potential significant adverse impact No. Environmental/ Social Component Proposed Mitigation Measures Monitoring Parameters Monitoring Site Frequency Responsibility (Implementation/ Supervision) PREPARATORY Siting of toilet facility For all schools, Engineering Consultant to extensively consult school authorities on the siting of toilet facilities in the school. The selection of sites should be agreed upon with the school authorities. The selection of sites should take into consideration compatibility with adjacent school facilities. The adjacent school facilities should not be at risk from the operation of the proposed toilets. -Evidence of consultation with authorities of beneficiary institution on siting of facilities. -Complaints on siting of facilities -Beneficiary institutions -Prior to construction - Daily -Contractor/ Engineering Consultant CONSTRUCTION Soil impacts and sediment transport Vegetation (grasses and shrubs) should be cleared only when contractor is mobilised for construction. Vegetation clearance necessary) and excavations should be limited to the demarcated construction site. Backfill with excavated soil material where appropriate. Re-vegetate areas around construction sites to restore the landscape. Ensure that heaped sand delivered for construction works is covered with tarpaulin to prevent wind and water transport of soil particles. -Observable change in turbidity of water in drains -Observable oil sheen in drains -Observation of rills/gullies -Construction site -Nearby drains Daily Contractor/ Engineering Consultant Air quality deterioration Deliver construction equipment and materials to the construction sites outside school sessions, such as in the evenings or on weekends. Speed limit for all vehicles and construction equipment should be less than 30km/h within the school environs and less than 50km/h within communities. Provide speed limit signs to guide drivers/operators. Dampen untarred routes of vehicles/trucks to the construction sites. Haulage trucks carrying sand should be covered with tarpaulin. Hydraulic concrete mixing machines should be used as much as possible and regularly service all construction equipment and machinery. -Observation of air borne particulates (dust) and exhaust fumes - Records of dust level measurements (dust concentration should be below 150µg/m3) -Records of dampening of construction sites and routes for vehicles/trucks Construction site -Immediate environs Daily Contractor/ Engineering Consultant
Dispose all construction and domestic waste at AdMA approved dump sites. Occupational health and safety (OHS) issues Engage experienced artisans for construction works. All workers should be proper induction/orientation on safety. The contractors should have a Health & Safety Policy to guide the construction activities. Regularly service all equipment and machinery. Ensure first aid kits on site and a trained person to administer first aid. Provide and enforce the use of appropriate personal protective equipment (PPE) such as safety boots, reflective jackets, hard hats, hand gloves, earplugs, nose masks, etc. for the labour force. Comply with all site and regulations. Apply sanctions where safety procedures are not adhered to. Site meetings should create awareness on OHS. -Workers’ awareness of Contractor’s health and safety policy -Availability and proper use of PPEs -Availability and proper use of warning signs -Availability of first aid kit -Adherence to health and safety procedures -Records on frequency, type and source of illness/accident/injury -Records on non-compliances -Absence of unauthorized persons at active construction Construction site Daily Contractor/ Engineering Consultant Public safety and traffic issues Hoard off the construction sites to prevent access by unauthorised persons. Use caution tapes and warning signs at the construction sites around trenches and excavations. Deliver construction equipment and materials to the construction sites outside school sessions such as in the evening or weekends. Speed limit for all vehicles and construction equipment should be less than 30km/h within the school environs and less than 50km/h within communities. Provide speed limit signs to guide drivers/public. Do not park at unauthorised places to reduce the risk of accidents. -Availability and proper use of warning -Hoarding of site -Use of caution tape around trenches/ excavations -Records on frequency, type and source of illness/accident/injury Construction site Daily Contractor/ Engineering Consultant
temporary road signs at junctions to the beneficiary institutions during the delivery of construction equipment and materials. Ensure delivery trucks hired/contracted are in good condition to prevent breakdowns on roads. Remove all construction equipment from the site after completion of work. -Absence of unauthorized persons at active construction Sanitation issues and public health impacts Provide bins on site for temporary storage of domestic waste such as lubricant containers, drinking water sachets and carrier bags/packaging materials. Dispose all construction and domestic waste at AdMA approved dump sites and in the approved manner. Ensure all trenches or excavations made during the construction do not collect stagnant water which could breed mosquitoes. Provide separate temporary toilets (mobile toilets) for use by construction workers. -Availability and use of bins -Records on frequency and location of waste disposal site of domestic and construction waste -Mobile toilet facilities in -Presence of stagnant water in trenches Construction site Daily Contractor/ Engineering Consultant Public Complaints/ Grievances Implement Grievance Redress Mechanism, which will include such elements as: Lodging and registration of PAPs grievance by grievance redress committee; Redress decision, feedback and implementation; Dissatisfaction and alternative action; and Monitoring and evaluation. -Type and nature of complaints and concerns; -Complaint records (Record of grievance and number resolved/unresolved) -Management and Stakeholder Meetings Project community Weekly Grievance Redress Committee OPERATIONAL PHASE Nuisance from odour Comply with provisions in the Facilities Management Plan (FMP). Ensure good housekeeping at toilet facilities. Clean toilet facilities regularly with disinfectants. Empty bins in classrooms/offices/wards regularly. Liaise with AdMA to contract a registered waste management company to regularly collect and dispose refuse waste at AdMA approved dump site. Dislodge septic tanks outside school sessions, such as on weekends. -Smell of pungent odour -Beneficiary institution -Immediate environs Daily Authorities of beneficiary institution/ SHEP Coordinator
Waste generation and disposal Regularly waste bins at the various locations when full. Sensitize pupils/ staff on effective use of bins to avoid indiscriminate disposal of waste. Damaged waste bins should be replaced as appropriate. Liaise with AdMA to contract a registered waste management company to regularly collect and dispose waste at AdMA approved dump site. Inspect septic tanks periodically and dislodge when full. -Waste disposal records -Availability of bins -Litter around waste bin -Records of inspection and dislodging of septic Beneficiary institution -Daily Authorities of beneficiary institution/ SHEP Coordinator Sanitation issues and health impacts Ensure pupils/staff wash their hands under running water and soap after use of toilet facilities. Ensure good housekeeping at toilet facilities. Clean toilet facilities regularly with disinfectants. Ensure bins are properly covered at all Avoid indiscriminate dumping of waste at waste storage and collection shed and always keep the place clean. Provide disposable hand gloves for cleaning of sanitation facilities and emptying of bins. Create awareness on hygiene and sanitation issues, including proper use of sanitation facilities and proper handling and disposal of Comply with provisions in the FMP. -Cleaning roster -Clean environment -Smell of pungent odour Availability of disinfectants -Availability of cleaning PPEs and tools/materials -Availability of functional hand wash facility -Toilet facility -Waste storage and collection sheds -Daily -Week SHEP Coordinator/ Head of Institution Complaints/ Grievances Implement Grievance Redress Mechanism, which will include such elements as: Lodging and registration of PAPs grievance by grievance redress committee; Redress decision, feedback and implementation; Dissatisfaction and alternative action; and Monitoring and evaluation. -Type and nature of complaints and concerns -Complaint records (Record of grievance and number resolved/unresolved) Project community -Weekly Grievance Redress Committee SUSTAINABILITY OF INSTITUTIONAL FACILITIES Flooding As a precautionary measure against flooding, raise the foundation of all toilet facilities to about 1 meter high. Provide adequate drainage around toilet facilities. Provide rain cover over all windows and doors of the toilet facilities. Extent of flooding during Drains of silt Record of of Rain covers Toilet facility During rains Monthly Authorities of Institution/ PTA/ Municipal Assembly
17 Icodehs Islamic Primary School 6 seater – VIP (Shared) 90 Not in use Weak/dilapidated structure with several cracks and breaks in walls and floors 18 Icodehs Islamic JHS School 6 seater – VIP (Shared) 90 Not in use 19 Knowledge and Faith School 3 seater – VIP (Exclusive) 119 In use Weak/dilapidated structure with few cracks in the walls, very poor ventilation and lighting, poor maintenance regime 20 Islamic Primary School 10 seater – type WC (Exclusive) 61 In use Sound structure, broken cisterns, poor ventilation, poor maintenance regime 21 Mercy Islamic JHS School 10 seater – WC (Exclusive) 16 Partial use Weak structures, all WC’s are broken down/malfunction, pipe leakages 22 Nii Sowah Din Memorial '1' Primary School 8 seater – Biofill (Shared) 190 In use Very sound structure, poor maintenance regime observed 23 Nii Sowah Din Memorial '2' Primary School 8 seater – Biofill (Shared) 190 In use 24 Nii Din Memorial '1' JHS School 8 seater – WC (Exclusive) 38 Partial use structure, few broken cisterns, leakage in roof slab, poor maintenance regime 25 Nii Sowah Din Memorial '2' JHS School 6 seater – WC (Exclusive) 43 In use Sound structure, well maintained facility 26 Ogbojo Presby Primary School 7 seater – KVIP (Shared) 156 In use Weak structure, severe cracks in cover slabs, walls and floor, poor maintenance regime 27 Ogbojo Presby JHS School 7 seater – KVIP (Shared) 156 In use 28 Sraha AdMA Primary School 6 seater – WC (Exclusive) 54 In use Fairly sound structure, minor cracks in the walls, poor ventilation and lighting, facilities is obscured & susceptible to community encroachment 29 St. Francis Catholic Basic School 6 seater - VIP 105 Partial use Poor structure with cracks on and floor, poor ventilation and lighting, poor maintenance regime
Proposed Sanitation Facilities to be provided by Project The overview of sanitation facilities to be provided in the selected institutions in AdMA under the proposed project are as follows: Rehabilitation and retrofitting of existing toilet facilities closet and septic tank); Rehabilitation and expansion of existing septic tanks; Demolition of existing defunct toilet facilities; Construction of micro flush water closet (WC) with biofilm digester; Construction of WC and septic tank; Connection of water from GWCL supply lines; Provision of water storage facilities. Details of the specific toilet interventions to be provided the project in each of the beneficiary schools is provided in Table 2-3. The choice of toilet facilities for each school was decided by the beneficiary schools after the design consultants, Colan Consult, had presented the available options as well as their respective advantages and disadvantages with respect to maintenance requirements, water requirements and cost of maintenance among others. The toilet facilities will be equipped with urinals and hand washing facilities, special cubicle for physically challenged pupils and changing room for girls. Two schools – Bethel Presbyterian Primary & JHS and Knowledge and Faith School – will not benefit from the proposed project due to unavailability of land for the toilet facilities (as indicated in Table 2-3). 23: Details of toilet interventions to be provided in the beneficiary schools NO. NAME OF SCHOOL PROPOSED INTERVENTION LOCATION 1 Abubakar Sadiq Islamic School 2-storey 12-seater WC toilet connection and provision of water storage tank Botwe Newtown 2 Adenta Community KG School Rehabilitation and retrofitting of the existing 4-seater toilet with smart flush WC Rehabilitation and expansion of the existing 2-seater toilet to 6-seater smart flush WC. connection and provision of water storage tank Adenta Flats 3 Adenta Community Primary School Rehabilitation of existing toilet facilities Water connection and provision of water storage tank Adenta Flats 4 Adenta Community JHS School 5 Adjiriganor AdMA Primary School 2 No. 10-seater WC toilets Water connection and provision of water storage tank Adjiriganor 6 Adjiriganor AdMA JHS School 7 Amrahia AdMA Primary School 6-seater WC toilet
World Bank Safeguards Policies The World Bank (WB) has published policies/procedures to guide the safe development of projects it is funding. Among the ten (10) WB Safeguards Policies, one (1) – OP 4.01 – is triggered by the proposed project. The WB safeguards policies and a summary of their core requirements are provided in Table 3-1. 31: Summary of World Bank Safeguard Policies No World Bank Safeguard Policy Summary of core requirements Potential for Trigger under proposed project Remarks or recommendation for proposed project 1 OP 4.01 Environmental Assessment Requires environmental assessment (EA) of projects proposed for Bank financing to help ensure that they are environmentally and sustainable, and thus to improve decision making. The EA takes into account the natural environment (air, water, and land); human health and safety; social aspects (involuntary resettlement, indigenous peoples, and physical cultural resources); and trans boundary and global environmental aspects. It categorizes proposed projects into categories A, B, C or FI based on the extent of adverse impacts anticipated from the project. For Category A and B projects, an ESMP is to be prepared to guide the Implementation of mitigation measures for all identified environmental impacts from the proposed project. Triggered The entire GAMA project funded by the WB, including the Construction of Institutional Sanitation Facilities in MAs and Construction of Road Culvert Drains falls under category B, and this ESMP is in line with the requirement of the policy. 2 OP 4.04: Natural Habitats Do not finance projects that degrade or convert critical habitats. Support projects that affect non- critical habitats only if no alternatives are available and if acceptable mitigation measures are in place. The policy Not triggered Project locations and design will not affect any critical habitats.
Table 51: Stakeholder Engagement Programme No. Activity Identified Stakeholders Focus of Consultation/ Engagement Timelines/ Frequency Forms of communication Facilitator Preparation of ESMP/ Project design Ministry of Local Government and Rural Development/ Project Coordinating Unit, Colan Consult, GWCL AdMA (SHEP Coordinator/SHEP Committee), Head Teachers, student representatives, School Management Committee, staff in schools Challenges with WASH implementation in schools, Potential environmental and social issues of concern from the proposed project’s implementation Compliance with World Bank and EPA requirements for GAMA S&W Project Strategies for mitigating the potential impacts and successful maintenance of the proposed facility during their operation Public and occupational health and safety at construction sites Scope of interventions of proposed works for institutional facilities construction and adequacy of sanitation facilities Throughout the ESMP period One on one Interviews Field visitation Sharing and review of relevant reports Email and phone calls SAL Consult Limited Site preparation prior to construction School authorities Students Community/ Assembly member Colan Consult/ Contractor Information on schedule of preparation and construction Awareness creation on the potential impacts and remedial measures to students and community Integration of the ESMP into planning for construction (impacts and mitigation measures) Grievance redress procedures Capacity building for stakeholders for the implementation of the ESMP Two weeks prior to construction General stakeholder meeting for school authorities, Consultant, and contractor Announcement at School Assembly Utilisation of WASH Notice “Talk” boards for students/staff and notice board at site including safety signs Community notifications. Consult/ AdMA Works Department/ Head teacher/ School based Health Coordinator Start of construction School authorities Students Community/ Assembly member Colan Consult/ Contractor Information on Schedule of construction works, activities and progress of construction Awareness creation on the potential impacts and remedial measures to students and community Training Throughout the construction period General stakeholder meeting for school authorities, Consultant, and contractor Announcement at School Assembly Utilisation of WASH Notice “Talk” boards for students/staff Colan Consult / AdMA Works Department/ Head teacher/ School based teaching
ESMP Implementation (impacts and mitigation measures) Code of Conduct Grievance redress mechanism and notice board at site including safety signs Community notification. Health Coordinator End of construction / Decommissioning of construction equipment and machinery School authorities Students Community/ Assembly member Consult/ Contractor Information on Schedule of decommissioning works, activities and progress of decommissioning Awareness creation on the potential impacts and remedial measures to students and community Training ESMP Implementation (impacts and mitigation measures) Code of Conduct Grievance redress mechanism Decommissioning phase General stakeholder meeting for school authorities, Consultant, and contractor Announcement at School Assembly Utilisation of WASH Notice “Talk” boards for students/staff and notice board at site including safety signs Community notification. Colan Consult / AdMA Works Department/ Head teacher/ School based Health Coordinator Commissioning and handing over of Institutional sanitation facility School Management Committee (SMC) Parents Teacher Association (PTA) School based Health Coordinator (SBHC) School Health Club (SHC) Operation and Maintenance (O&M) requirements of the toilets Roles and responsibilities in the O&M Training on the Facilities Management Plan Prior to operation of the facility General stakeholder meeting for school authorities, Consultant, and contractor Announcement at School Assembly and Utilisation of WASH Notice “Talk” boards for students/staff Colan Consult/ Municipal SHEP Committee and Coordinator/ Head teacher/ School based Health Coordinator Operation and maintenance of facility School Management Committee/ Parents Teacher Association School based Health Coordinator Teachers/staff School Health Club Students Hygiene education Operation and Maintenance (O&M) requirements of the toilets Roles and responsibilities in the O&M Training on the Facilities Management Plan Review of grievance During operation and maintenance period General stakeholder meeting Training workshops Consult/ Municipal SHEP Committee and Coordinator / Municipal SHEP Coordinator Students Interactive activity and testing knowledge Demonstration activity for building habits 3 a week Classroom activity Class Teacher
Entire School Teaching knowledge and motivating pupils for change of habits Fortnightly Main school lesson during worship time School health club and SBHC. Reinforcing/repeating key messages from Worship Time Sessions 3 times a week Morning Assembly School health club and SBHC. Reinforcing/repeating key messages from Worship Time Sessions 3 times a week WASH Notice “Talk” boards School health club and SBHC. All classes and all schools in Metropolis Activities focusing on testing knowledge dissemination to the entire school and indirectly parents and communities Once a term Competitions and demonstrative activities SBHCs/ Municipal SHEP Coordinator Parents and Teachers Support to activities/actions as well as reports on progress Funding for the O&M of facilities Once a term WASH Session during PTA meeting for schools PTA School Management Committee (SMC) Support to activities/actions as well as reports on progress. support to School Health Club activities as well as individual support as club patrons Support to SBHC Once a term WASH Session during SMC Meeting SMC
Construction of facilities Disposal of construction spoil and waste in general. Speed limit for all vehicles and construction equipment should be less than 30km/h within the school environs and less than 50km/h within communities. Provide speed limit signs to guide drivers/operators. Dampen untarred routes of vehicles/trucks to the construction sites. Haulage trucks carrying sand should be covered with tarpaulin. Hydraulic concrete mixing machines should be used as much as possible and regularly service all construction equipment and machinery. 3. Vibration and nuisance Demolition of existing facilities (where applicable); Site clearing and excavation works; Transportation of materials and equipment; Construction of facilities Demolition of old structures should be done outside school sessions, such as in the evenings or during weekends. Carpentry works, and other noise generating activities should as much as possible be carried outside school sessions. Hydraulic concrete mixing machines should be used as much as possible and regularly service all construction equipment and machinery. Contractor/ Engineering Consultant Already captured in BoQ 4. Visual intrusion All construction phase activities The construction sites should be hoarded off from public view. Ensure good housekeeping at the construction site. Ensure an acceptable post-construction site as per provisions in the contract. Remove all construction equipment from the site after completion of work. Contractor/ Engineering Consultant Already captured in BoQ 5. Destruction of property and obstruction of walkways Demolition of existing sanitation facilities applicable); Site clearing and excavation works; Transportation of materials and equipment; Excavation works; Disposal of construction spoil and waste in general. Ensure construction equipment are not parked haphazardly to obstruct walkways. As much as possible, do not dump construction materials in walkways. Provide safe alternative routes for pedestrians walkways will be obstructed. Consult affected property owners/users and seek their consent prior to construction works. Realign all affected utility service lines. Reinstate any damaged property such as pavements, etc. Contractor/ Engineering Consultant Already captured in BoQ
6. Generation and disposal of solid waste All construction activities the principles of Reduce, Reuse and Recover for waste management. For example: Purchase the right quality and quantity of materials; Ensure judicious use of construction materials such as pipes, laterites, sand, etc.; excavated soil material for backfilling and levelling if appropriate. Provide bins on site for temporary storage of domestic waste such as lubricant containers, drinking water sachets and carrier bags/packaging materials. Dispose all construction and domestic waste at AdMA approved dump sites. Contractor/ Engineering Consultant Already captured in BoQ 7. Occupational health and safety (OHS) issues All construction activities Engage experienced artisans for construction All workers should be given proper induction/orientation on safety. The contractors should have a Health & Safety Policy to guide the construction activities. Regularly service all equipment and machinery. Ensure first aid kits on site and a trained person to administer first aid. Provide and enforce the use of appropriate personal protective equipment (PPE) such as safety reflective jackets, hard hats, hand gloves, earplugs, nose masks, etc. for the labour force. Contractor Already captured in BoQ Comply with all site and regulations. Apply sanctions where safety procedures are not adhered to. Site meetings should create awareness on OHS. Engineering Consultant 8. Public safety and traffic issues Construction activities Transport of equipment and materials to and from site Hoard off the construction sites to prevent access by unauthorised persons. Use caution tapes and warning signs at the construction sites around trenches and excavations. Deliver construction equipment and materials to the construction sites outside school sessions such as in the evening or weekends. Speed limit for all vehicles and construction equipment should be less than 30km/h within the school environs and less than 50km/h within communities. Do not park at unauthorised places to reduce the risk of accidents. Contractor/ Engineering Consultant Already captured in BoQ
(Implementation/ Supervision) PREPARATORY PHASE Siting of toilet facility -Evidence of consultation with authorities of beneficiary institution on siting of facilities. -Complaints on siting of facilities -Beneficiary institutions -Prior to construction - -Contractor/ Engineering Consultant No additional cost required aside BoQ CONSTRUCTION Soil impacts and sediment transport -Observable change in turbidity of in drains -Observable oil sheen in drains -Observation of -Construction site -Nearby drains Daily Contractor/ Engineering Consultant No additional cost required aside BoQ Air quality/ Noise - Observation of air borne particulates (dust) and exhaust fumes -Records of dust level measurements (dust concentration should be below 150µg/m3) -Records of dampening of construction and routes for vehicles/trucks -Construction site -Immediate environs Daily Contractor/ Engineering Consultant No additional cost required aside BoQ Vibration and noise nuisance -Complaints on noise nuisance Construction site -Immediate environs Daily Contractor/ Engineering Consultant No additional cost required aside BoQ Visual Intrusion -Hoarding in place -Condition of around construction site Construction site -Immediate environs Daily Contractor /Engineering consultant No additional cost required aside BoQ Destruction of property and obstruction of walkways -Evidence of consultations with affected property owners -Record of affected service line/property and action taken -Complains on affected property and obstruction of walkways Reinstatement of damaged property and landscape -Construction site -immediate environs Daily Contractor /Engineering consultant6 No additional cost required aside BoQ
Electricity availability and functioning light bulbs at toilet facilities Watchman hired 3. Unavailability of water Confirmation of availability of water supply from GWCL Storage installed and all connections and plumbing functional Leaks from plumbing Toilet facility Prior to commissioning of project/ Weekly School Authorities/ PTA/ Municipal Assembly 1000.00 4. Funding Programme for PTA, SMCs, MMAs for fund raising for payment of water supply and electricity bills, and maintenance of the facilities Receipts of payment of bills Audited accounts Beneficiary institution Monthly MLGRD-PCU/ Municipal Assembly/ Consultant/ School Authorities /PTA 1500.00 5. Poor maintenance culture Record of training and awareness creation on Facilities Management Plan Record of compliance with Facilities Management Plan Records on major breakdowns including leakages Availability of school hygiene clubs -Beneficiary institution Monthly School Authorities / SHEP Coordinators/ PTA/ Municipal Assembly 1200.00 6. Lack of awareness of the project information Monthly progress carried out Information provided to teachers, students and the PTA. -Beneficiary institution Monthly SMC/ PTA/ Municipal SHEP Committee 700.00 DECOMMISSIONING 1. Occupational/public safety and traffic Availability and proper use of PPEs Adherence to health and safety procedures Records on frequency, type and source of illness/accident/injury -Beneficiary institution -Daily Contractor/ Consult/ AdMA No additional cost required aside BoQ