E.Audit Kenya

Environmental Audit for Malindi Laboratory
ENVIRONMENTAL AUDIT REPORT FOR EAST AFRICA PUBLIC

HEALTH LABORATORY NETWORKING PROJECT, MALINDI-
KILIFI COUNTY
NOVEMBER,2018
i
PREPARED BY;
ENG. JAMES MAINA KIAMBIGI
LEAD EXPERT, NEMA REGISTRATION NO. 0307
P.O. BOX 24866-00100 NAIROBI
TEL: 0722789750, 0724250556
Email: mkiambigi@pleng.net
Signature ____________________________ Date ________________________________
On Behalf of;
National Public Health Laboratory Services

East Africa Public Health Laboratory Networking Project
P.O BOX 20750-00202, Nairobi
Nairobi, Kenya
ii
EXECUTIVE SUMMARY
Malindi Level II Laboratory was constructed and is being operationalized under the East Africa
Public Health Networking Project. This project is funded by worldbank and is being
implemented by the ministry of health. The main obective of the project is to to establish a
network of efficient, high quality, accessible public health laboratories for the diagnosis and
surveillance of communicable and non-communicable diseases. Other beneficiary countries
are Tanzania, Burundi, Rwanda, and Uganda.
This project triggered OP/BP4.01 (Environmental Assessment) during the construction and
operations of the laboratory, which were deemed to impact on both the biophysical and socio-
economic environments, including occupational health and safety issues and generation of
medical waste.As such, ESMF, ESIA reports were prepared to mitigate any potential effect on
the health, safety and the environment in the area of influence. The ESIA was prepared in 2012
and the laboratory licensed on 29th May 2013.
Similarly, world bank policy on indigenous people (OP/BP4.10) was triggered. This is due to
the fact that there is a Vulnerable and Marginalized Group locally known as “Wasanya”living
in Malindi sub-county where the lab is located. The “Wasanya” and “Wapemba” are also
found in Ganze and Bahari in the larger Kilifi County. The main economic activity of these
groups is hunting and gathering.
OP 4.10 safeguard seeks to ensure that the development process fully respects the dignity,
human rights, economies, and cultures of Indigenous Peoples. It aims to meet the following
objectives; a) avoid adverse impacts on vulnerable and marginalised groups b) secure broad
community support for the project and c) to provide Vulnerable and Marginalized Groups
(VMGs) with culturally appropriate benefits (Ministry of Health, 2016). In this respect,
avulnerable and marginalized group planning framework (VMGPF) was prepared and
disclosed in March, 2016. This framework outlines among other key issues; the projects likely
to be proposed for financing, potential positive and adverse effects of the project on VMGs, a
plan for carrying out the social assessment, a framework for ensuring free, prior, and informed
consultation with the affected VMGs at each stage of project preparation and
implementation.This referral lab however does not adversely affect the VMGs who are not
present in the hospital vicinity. Thus, there was no need to prepare a vulnerable and
marginalized group plan.
iii
This Environmental and Social Audit Report is prepared in accordance with the requirements
of Part VII of the Environmental Management and Coordination Act 1999, EMCA
(ammendment) 2015 and the Environmental Impact Assessment and Audit Regulations of
2003. Its main objectives are to 1) Ensure compliance with the Environmental Management
and Coordination Act (EMCA), EIA and Audit Regulations; World Bank’s Environmental and
Social Safeguards requirements; 2) Assess whether there are any new significant
environmental and social impacts associated with the running of the lab and its facilities and
3) To explore improvement opportunities.
This report serves as a monitoring tool for the operations of the Malindi East Africa Public
Health Level II Laboratory with respect to Occupational Health and Safety procedures as well
as compliance with National Environmental Management Authority(NEMA)guidelines and
World Bank Safeguard policies.
This Environmental Audit was conducted using a combination of methods including the use of
checklists, observations, site surveys, photographs, interviews and literature reviews of
documented information.
Socio economic, Environmental, and Health and Safety Issues

In auditing the facility and its operations, the following benefits and negative impacts were
gathered;
Socioeconomic aspects
This facility has ensured improvement of medical services as well as standards of living of
people of Malindi and beyond. This facility has also employed the community in many
different ways including cooks, cleaners, suppliers etc.
Environmental Quality
 Loss of Biodiversity
The lawns around the facility are not well maintained making the place not appealing to the
eye. The vegetation is also destroyed through creation of diversionary and short routes. The
removal and destruction of vegetation has led to formation of loose soils which are prone to
erosion thereby affecting the general quality of air in the area. This has also affected the
microorganisms living within the soils.
iv
Waste management
 Solid waste management
Solid waste management in the area is generally good. Waste is segregated with color coded
bins into Highly-infectious (red), Infectious (Yellow) and Non-infectious (Black). With time,
the available incinerator may not be able to meet the facility’s needs due to increased waste
generated from increased population to the facility. Ash from incinerated waste is normally
dumped in an ash pit adjacent to the facility.
 Liquid waste management

Liquid waste from the facility is treated to acceptable quality standards before being released to
septic tank or soak pit for disposal.
Occupational health and safety aspects

 Office equipment
The office equipment was inadequate as some, like benches, taps, shelves were broken.
 Fire safety and preparedness

Fire extinguishers and fire reels have been placed at strategic locations within the facility.
However, prevention and control of fires is currently not adequately addressed by the
laboratory management.
 Water quantity and quality

The facility is connected and obtains its tap water from MalindiWater and Sewerage Company
Ltd (MAWASCO). Although tap water was found to be chemically suitable for domestic use,
water supply to the facility is inadequate.
 Noise levels
The noise levels were established to be 38db which is within recommended limits.
 Occupational Safety
There is extensive use of PPEs by staff within the facility. However, there lacks signs for
prevention of slipping on the floor and various measures required for emergency
preparedness.
Energy Conservation
Electricity is the principal source of lighting within the facility. There is a backup generator in
case of power outages in the area. There was however no evidence of integration of green
energy in the area.
v
Stakeholder consultation and grievance redress mechanism

Stakeholders are normally engaged through three different types of meetings;
▪ County meetings that are held between members of the hospital board and county
officers. These meetings are conducted thrice in a year. The main agenda of such
meetings are supervision and handling of complaints.
▪ The help management committee meetings focus on handling departmental issues. They
are conducted every Monday with departmental heads.
▪ Laboratory county coordinators meeting that is held among ministers, chiefs e.t.c. is
mainly focused on supervision and is normally conducted after every four months.
The laboratory does not have a lab line where patients can forward their complaints. There is
however a suggestion box that is used for complaints and comments. Delays in service delivery
is the most common complain among the patients. The lab manager, deputy lab manager and
the quality officer form the grievance redress committee. This committee reviews complaints
raised once a month. The complaints are safely stored in a complaints file for future reference.
Feedback is normally done through notices that are pinned on the notice boards.
Total Cost
The total cost for implementation of the plan for Malindi is Kshs. 13,720,000. The ESMP will
cost Kshs. 13,720,000. The cost will be met by the County Government of Machakos. Facility
improvement funds disbursed to the site by the EAPHLN project will also cater for some
individual budgets such as Infrastructure upgrade; repair of broken seats/benches,
replacement of broken tiles within the facility and installation of air conditioning system in the
some rooms
vi
Detailed Overview of Issues, Recommended Solution and Institutional Responsibility

Issue/Problem Recommended Solution Responsibility Time Monitoring Indicators Budget
frame (Kshs)
Air Pollution -Air quality monitoring should frequently be done Medical 1 Month -Improved air quality 1,500,000
-Installation of a filter in the chimney at the smoke exit
Superintendent
points
-Noise levels should frequently be monitored to ensure
compliance
Removal of - Plan and provide pedestrian walkways. Medical Regularly -Improved aesthetics of the area
-Re-vegetation of degraded sites to improve landscaping of
vegetation Superintendent -Manicured and maintained 1,000,000
the site
cover - Monitoring of revegetation activities; regular pruning lawns
Solid Waste Management

Solid waste -Construction of an incinerator with a bigger capacity 1 Month -Reduced accumulated waste 1,000,000
management -Liners bins should be strategically located within the around the facility
laboratory to enhance waste segregation and hence proper -Reduced health hazards
waste management Medical Always -Number of complaints against 3,000,000
-Regular removal and proper disposal of solid waste should Superintendent poor waste management
be continued.
-Employ 3Rs (Reduce, Recycle, Reuse)
Liquid waste - The septic tank should be emptied regularly by registered Medical Always -Frequency of water related 2,000,000
management exhauster company. Superintendent diseases
-Comments from surrounding
local community
Occupational health and safety
vii
Office -Regular inspection for malfunctioning systems and Medical Always -Comments from surrounding 1,000,000
equipment structures, and their immediate repair superintendent local community
Fire safety and -Awareness creation Medical Always -Improved fire safety 200,000
preparedness -Conduct drills regularly to ensure preparedness of staff superintendent preparedness
-Provision of information, instruction, training and -Increased awareness on fire
supervision necessary to improve on Fire safety and safety and prevention
preparedness -Number and frequency of fire
-Improve on fire safety preparedness; install smoke related incidences
detectors and fire alarm systems.
-Regular servicing of fire safety equipment
Water quantity -The water should be tested regularly to ensure it maintains Medical Always -Water conservation practices 2,000,000
and quality the recommended WHO guidelines for portable water in superintendent -Incidences of water shortages
regards to bacteriological, physical and chemical properties
before it is used for human consumption. -Comments from the general
-Water harvesting measures should be put in place. public
- Connect water into the washrooms and other parts of the
facility to ensure visitors have access to running water
Noise levels -Continuous noise monitoring should be done to be within Medical Always -Comments from surrounding 100,000
allowable levels by NEMA regulations(60-dB) superintendent local community
Occupational -Monitoring of environmental and health and safety issues -Increased awareness on 200,000
Safety -Provision of information, instruction, training and environmental and safety issues
supervision necessary to improve on fire safety and
preparedness -improved capacity of waiting
- Put biometrics access control in all entrance ways bays
-Increase the size of waiting bays -improved knowledge on PPEs
-The personal protective equipment should be frequently
by staff
replaced and training provided in using the equipment.
Medical Always
viii
- Infrastructure upgrade; superintendent

• Repair all broken seats/benches -Improved lab furniture
• Replace all broken tiles within the facility. -Improved ventilation within
• Install air conditioning system in the rooms
the rooms
without
-Increased light penetration in 500,000
Medical 5 Months the rooms
superintendent -Incidences of roof leaks
Energy Conservation
Unsustainable -Employ 3Rs Medical 12 -Reduced waste generation 1,200,000
energy -Alternative green sources of energy; biogas, solar energy superintendent Months -Improved air quality
consumption
Grievance redress mechanism and stakeholder consultation

-Delays in -Expedite services Medical Througho -Comments from the public -
service delivery -Employ more staff superintendent ut the
project
cycle
-Lack of a lab -Install a lab line Medical 1month -Comments from the public 20,000
line -Ensure easy access to the lab line superintendent
-Provide a mechanism of safe storage of complaints sent
through the lab line
Delay in -Ensure address of complains as urgently as possible Medical Througho -Comments from the public -
addressing superintendent ut the -Frequency of repeated
complaints project complaints
cycle
ix
-Inefficiency in -Ensure involvement of aggrieved persons and the party Medical Througho -Comments from the public -
provision of that caused the grievance superintendent ut the
-Ensure involvement of both parties in decision making
feedback to where possible project
complaints cycle
raised
Total Cost 13,720,000
x
Table of Contents
EXECUTIVE SUMMARY ........................................................................................................................... iii
List of Maps ......................................................................................................................................... xiv
List of Plates ......................................................................................................................................... xiv
List of Tables ........................................................................................................................................ xiv
ACRONYMS.......................................................................................................................................... xv
CHAPTER ONE........................................................................................................................................ 1
1.0 INTRODUCTION ............................................................................................................................. 1
1.2 Audit Objectives, Scope and Methodology .............................................................................. 2
1.2.1 Audit Objectives .................................................................................................................. 2
1.2.2 Audit Scope .......................................................................................................................... 3
1.2.3 Methodology ........................................................................................................................ 4
CHAPTER TWO ...................................................................................................................................... 5
2.0 LEGAL, POLICY & INSTITUTIONAL FRAMEWORK ..................................................................... 5
2.1 Overview ..................................................................................................................................... 5
2.2 International Safeguards ....................................................................................................... 5
2.2.3 World Bank Environmental and Social Safeguard Policies ............................................ 5
2.3 Legal Framework ........................................................................................................................ 6
2.3.1 The constitution of Kenya, 2010 ....................................................................................... 6
2.3.2 The Environmental Management and Co-ordination Act Amendment (EMCA), 2015
......................................................................................................................................................... 6
2.3.3 Public Health Act Cap. 242, 2012 .................................................................................... 7
2.3.4 The Occupational Safety and Health Act, 2007 .............................................................. 7
2.3.5 Water Act, 2016.................................................................................................................. 8
2.3.6 Radiation Protection Act, Cap 243 2014 ......................................................................... 8
2.3.7 National Construction Authority Act, 2011..................................................................... 8
2.4 Policy framework........................................................................................................................ 8
2.4.1 The National Health Care Waste Management Plan 2016-2021 ................................. 8
2.4.2 Kenya National Guidelines on Safe Disposal of Pharmaceutical Waste, 2001 ............ 9
2.4.3 National Policy on Injection Safety and Medical Waste Management ......................... 9
2.4.4 National Environmental Policy 2013 ............................................................................. 10
2.5 Environmental Regulations...................................................................................................... 10
2.5.1 Waste Management Regulations, 2006 ......................................................................... 10
2.5.2 Noise and Excessive Vibration Pollution control regulations, 2009 ........................... 10
xi
2.5.3 Environmental Management and Coordination Act (Air Quality) regulations, 2009
....................................................................................................................................................... 11
2.5.4 Environmental Management and Coordination Act (Water Quality) regulations,
2006 ............................................................................................................................................. 12
CHAPTER THREE .................................................................................................................................. 13
3.0 BASELINE INFORMATION ........................................................................................................... 13
3.1 Locational Context .................................................................................................................... 13
3.2 Physiographic and Natural Conditions .................................................................................. 14
3.2.1 Weather and Climate........................................................................................................ 14
3.2.2 Topography and drainage................................................................................................ 14
3.2.3 Geology and soils .............................................................................................................. 14
3.2.4 Vegetation .......................................................................................................................... 15
3.3 Population and Demography .................................................................................................. 15
3.3.1 Population Size and Composition .................................................................................... 15
3.3.2 Vulnerable and Marginalized Groups (VMG) ............................................................... 16
CHAPTER FOUR ................................................................................................................................... 17
4.0 AUDIT AREAS ................................................................................................................................ 17
4.1 The Laboratory Design Provisions .......................................................................................... 17
4.1.1 Laboratory Worktops........................................................................................................ 18
4.1.2 Lab Shelves......................................................................................................................... 18
4.1.3 Emergency shower and Eyewash. ....................................................................................... 18
4.1.4 Floor finishes. ...................................................................................................................... 19
4.1.5 Heating, Ventilation and Air-conditioning ........................................................................... 19
..................................................................................................................................................... 19
4.1.6 Hand-washing Sinks ............................................................................................................ 19
4.2 Water Supply, Quality and Conservation .............................................................................. 19
4.3 Waste Management.................................................................................................................. 20
4.3.1 Solid waste management .................................................................................................. 20
4.3.2 Liquid waste management ............................................................................................... 20
4.4 Health and safety ...................................................................................................................... 20
4.4.1 Fire safety and Preparedness ............................................................................................ 20
4.4.2 Use of PPEs ......................................................................................................................... 21
4.5 Environmental Conservation activities and awareness ........................................................ 21
CHAPTER FIVE ...................................................................................................................................... 22
5.0 AUDIT FINDINGS.......................................................................................................................... 22
xii
5.1 Scope of the Environmental Audit .......................................................................................... 22

5.2 Social and Environmental Findings ........................................................................................ 23
5.2.1 Social, environmental and economic benefits of the facility ....................................... 23
5.2.2 Laboratory Design............................................................................................................. 24
5.2.3 Water Supply Quality and Conservation ................................................................... 24
5.2.4 Waste Disposal and Management................................................................................... 24
5.2.5 Health and Safety .............................................................................................................. 25
5.2.6 Environmental Conservation and awareness................................................................. 27
5.2.7 Energy utilization and Conservation .............................................................................. 27
5.2.8 Stakeholder consultation and Grievance Redress mechanism ..................................... 28
CHAPTER SIX ........................................................................................................................................ 29
6.0 PUBLIC PARTICIPATION AND CONSULTATION ...................................................................... 29
6.1 Introduction .............................................................................................................................. 29
6.2. Stakeholder Engagement......................................................................................................... 29
6.2.1 Vulnerable and Marginalized Group Planning Framework ........................................ 31
CHAPTER SEVEN .................................................................................................................................. 32
7.0 MANAGEMENT AND MONITORING ACTION PLAN ............................................................... 32
CHAPTER EIGHT .................................................................................................................................. 37
8.0 CONCLUSION AND RECOMMENDATIONS.............................................................................. 37
8.1 Conclusion................................................................................................................................. 37
8.2 Recommendations..................................................................................................................... 37
Annexes................................................................................................................................................. 38
xiii
List of Maps
Map 1: Location of Malindi level 2 lab ............................................................................................. 13
List of Plates
Plate 1: Geology and soils ................................................................................................................... 14
Plate 2: Malindi Level 2 Laboratory Facility ..................................................................................... 17
Plate 3: Waiting Bay within the facility ............................................................................................ 17
Plate 4: Laboratory Worktop .............................................................................................................. 18
Plate 5: Lab Shelves.............................................................................................................................. 18
Plate 6: Emergency Shower Eyewash ................................................................................................ 18
Plate 7: Ventilation within the facility............................................................................................... 19
Plate 8: Hand washing sink ................................................................................................................ 19
Plate 9: Facility’s Incinerator .............................................................................................................. 20
Plate 10: Fire Horse reel and Portable Fire Extinguishers ............................................................... 20
Plate 11: Laboratory Design ............................................................................................................... 24
Plate 12: Autoclaving of solid waste .................................................................................................. 24
Plate 13:Liquid Waste Disposal.......................................................................................................... 25
Plate 14: Occupational Safety Strategies ........................................................................................... 25
Plate 15: Fire Safety Strategies ............................................................................................................ 26
Plate 16: Biohazard Spill Kit ............................................................................................................... 26
Plate 17: Vegetation Cover ................................................................................................................. 27
Plate 18: Locked-off Generator Room ............................................................................................... 27
List of Tables
Table 1: International Safe Guards ...................................................................................................... 6
Table 2: Ambient Air Quality Standards ........................................................................................... 11
Table 3: Water Quality Standards ..................................................................................................... 12
Table 4: Water Quality Compliance .................................................................................................. 12
Table 6: Mean Annual Temperature ................................................................................................. 14
Table 7: Population of Kilifi County .................................................................................................. 15
Table 8: Environmental Management Action Plan .......................................................................... 36
xiv
ACRONYMS
EA EnvironmentalAudit
EMCA Environmental Management and Coordination Act
EAPHLNP East Africa Public Health Laboratory Networking Project
NEMA National Environment Management Authority
ESIA Environmental and Social Impact Assessment
ESMF Environmental and Social Management Framework
ESMP Environmental and Social Management Plan
MWMP Medical Waste Management Plan
IPPF Indigenous Peoples Policy Framework
KEMRI Kenya Medical Research Institute
EBM Evidence-Based Medicine
HI Highly Infectious
AF Additional Funding
SLIPTA Stepwise Laboratory Improvement Process Towards Accreditation
KQM Kenya Quality Model
ECDC Early Childhood Development Centers
EPZ Economic Processing Zones
LIMS Laboratory Information Management Systems
KMTC Kenya Medical Training Institute
KEMRI Kenya Medical Research Institute
HH House Hold
xv
CHAPTER ONE
1.0 INTRODUCTION
The East Africa Public Health Laboratory Networking Project main development objective is
to establish a network of efficient, high quality, accessible public health laboratories for the
diagnosis and surveillance of tuberculosis and other communicable diseases. The World
Bank’s additional funding (AF) for Rwanda, Burundi, Uganda and Kenya specifically was to
assist in scaling up additional facilities in cross-border areas, further expanding
geographical coverage as well as broaden and deepen the range of interventions to be
funded i.e., establishment of isolation units; strengthening community surveillance
activities; and supporting joint training in line with the one health approach to enhance
effectiveness and the impacts of health systems in terms of management and containment of
communicable diseases. The additional funding is envisaged to widely boost the
revitalization of disease surveillance, prevention and preparedness capacities.
It is worth noting that certain measures, like development of a laboratory when

implemented will help protect and promote health through development of efficient,
effective and equity-oriented health system. Laboratories form an essential and critical part
of this system as they support clinical diagnosis of public health emergencies.The
establishment of a one-stop-shop at Malindi level 4hospital works well for both providers
and patients, as results are delivered faster. This means required courses of treatment can
start more quickly, leading to better patient outcomes overall. The integration of a level 2
lab with Malindi District Hospital was essential as it continues to increase the catchment
population of the facility.
According toOP/BP4.01, the construction, operation and decommissioning of the Lab

facility is under Category B (construction of health facilities), as the project has less adverse
environmental impacts. The Bank’s Safeguard Policy on Indigenous Peoples (OP/BP4.10)
was also triggered. This is due to the fact that there is a Vulnerable and Marginalized Group
locally known as “Wasanya” living in Malindi sub-county where the lab is located. The
“Wasanya” and “Wapemba” are also found in Ganze and Bahari in the larger Kilifi County.
The main economic activity of these groups is hunting and gathering.
The OP/BP4.10seeks to ensure that the development process fully respects the dignity,
human rights, economies, and cultures of indigenous peoples. It aims to meet the following
objectives; a) avoid adverse impacts on vulnerable and marginalised groups b) secure broad
1
community support for the project and c) to provide vulnerable and marginalized groups
(VMGs) with culturally appropriate benefits (Ministry of Health, 2016).
As a result, a VMGPF was prepared and disclosed in March, 2016. It outlines the processes
and principles of: (a) screening to determine if a proposed sub-project investment will be
undertaken in the vicinity of vulnerable and marginalized communities; and (b) the
preparation of a vulnerable and marginalized groups plan (VMGP), including the social
assessment process, consultation and stakeholder engagement, disclosure procedures,
communication and grievances redress mechanism (Ministry of Health, 2016). This
referral lab however does not adversely affect the VMGs who are not present in the hospital
vicinity. Thus, there was no need to prepare a vulnerable and marginalized group plan.
Malindi Level 2 Laboratory consists of a two-floored building. The facility can be accessed
from within the hospital or from the main road. The ground floor comprise a waiting area,
reception area, specimen reception area, reports release desk, cashier office, records room,
patients toilets, phlebotomy room, donor room, washing area, counseling room, blood
donor room, restroom, blood bank, pathologists office, server room, staff lounge, office for
in-charge, office for County laboratory technician, utility room, cold room, training room;
video conferencing, suppliers store and staff toilets.
The first floor houses a blood transfusion laboratory, Serology laboratory, chemistry
laboratory, hematology laboratory, parasitology laboratory, histology laboratory,
microscopy, freezer room, media prep room, specimen museum, quality control laboratory,
molecular laboratory, virology laboratory, microbiology laboratory, TB laboratory,
decontamination room, glassware washing, store and staff toilets.
1.2 Audit Objectives, Scope and Methodology

1.2.1 Audit Objectives
The primary objective of the consultancy is to undertake an Environmental Audit (EA) of
the projects in Kenya under the EAPHLNP in order to ensure compliance with:
I. EMCA, Cap 387 and Environmental (Impact Assessment and Audit Regulations),
2003
II. World Bank’s Environmental and Social Safeguards requirements
2
1.2.2 Audit Scope

In accordance with the provision of the Environmental (Impact Assessment and Audit)
Regulations 2003, the report covers the following aspects:
 Review the environmental legal and regulatory requirements applicable to the
laboratory project.
 Verify levels of compliance by the project during construction and operation and
with the requirements of the ESMF, ESIA, ESMPand identify gaps if any.
 Establish environmental management practices being implemented both from
the point of view of adequacy as well as effectiveness, and identify gaps if any.
 Determine the magnitude of the predicted impacts of the projects on various
physical and social parameters at the project sites and compliance monitoring.
 Determine the extent to which expected benefits of the project have been
realized for the stakeholders, community, and the environmental components.
 To review the environmental monitoring to ensure the necessary verification of
the effectiveness of implementation, and identify gaps if any.
 To review the staff/human and other resources capacity available to implement
environmental management practices, and identify gaps if any.
 To review the earlier stakeholder/public consultations done in order to
determine the issues relevant to the Environmental Audit.
 To consult key stakeholders – hospital and laboratory officials, contractors and
consultants, immediate neighboring communities – during the conduct of the
review.
 Assess the major environmental non-compliance issues and challenges.
3
1.2.3 Methodology
The methodology of the environmental audit was achieved through the following approach:
 Review of relevant documents (ESMF, ESMP, ESIA, etc. prepared for the project) and
existing environmental and occupational health and safety legislations and
standards, environmental safeguard policies and guidelines of the World Bank and
Kenya Government;
 Preparation of an audit framework, criteria and checklist;
 Site visit to the East Africa Public Health Laboratory for Malindi Level 4 Hospital for
the physical inspection of the facilities, carrying out interviews and discussions
with management and staff and consultations with key stakeholders.
 Verification of procedures, instructions and equipment in place designed to help
the facilities apply and adhere to: existing environmental laws, regulations, and
World Bank standards, occupational health and safety standards, good
environmental and safety management practices, facilities own environmental and
social management plans
 Evaluation of findings, developing a prioritized list of concerns related to past and
ongoing activities at the facilities.
 Making recommendations including the auditor’s opinion of the facilities’ overall
environmental performance with respect to regulatory framework, World Bank
corporate environmental requirements, NEMA environmental management best
practices and cost estimates for the implementation of remedial action plan
 Review of all safeguard instruments including the ESMP and ESIAs for the safe and
effective management of the public health facility by incorporating appropriate
remedial measures.
 Compiling the findings and finalizing the report writing
 Preparation of an Environmental Management Plan
4
CHAPTER TWO
2.0 LEGAL, POLICY &INSTITUTIONAL FRAMEWORK
2.1 Overview
The consultant reviewed all the policies and legislations that relate to an environmental
audit of a health facility. Emphasis was laid on World Bank Environmental and Social
Safeguard policies as well as the Kenyan policies and legislation.
2.2 International Safeguards

2.2.3 World Bank Environmental and Social Safeguard Policies
The World Bank Environmental and Social Safeguards Policies include key Operational
policies (OP) designed to ensure that potentially adverse environmental and social
consequences are identified, minimized, and mitigated. The EAPHNLP level 2 laboratory
broadly triggered World Bank Policies OP 4.01(Environmental Assessment) and OP/BP
4.10 (Indigenous People) based on the envisaged activities of post-construction.
Policy Objective Trigger for the policy Compliance

OP/BP -To ensure that Bank-financed -The project was -The project requires
4.01 projects are environmentally sound categorized under environmental auditing
Environ and sustainable, and that decision category B and to check for compliance
mental making is improved through required identification with this safeguard and
Assessm appropriate analysis of actions and of and mitigation of any national laws and
ent their likely environmental impacts. adverse environmental internal requirements.
impacts by the project -The project did not
proponent. fully comply with the
- A range of ESIA especially on
instruments were used training and awareness
depending on the of occupation health
project and nature of and safety
impacts: ESIA, ESMF
OP/BP The objective of this policy is to ensure -This policy was -The VMGs are well
4.10 (i) development process fosters full triggered because there represented in decision
Indigeno respect for the dignity, human rights, are indigenous people making and in
us and cultural uniqueness of indigenous in the area of influence grievance redress issues
Peoples peoples; and as such, there
(ii)adverse effects during the dignity, human rights
development process are avoided, or if and cultural uniqueness
not feasible, ensure that these are must be respected.
minimized, mitigated or compensated;
and (iii) indigenous peoples receive
culturally appropriate and gender and
inter-generationally inclusive social
and economic benefits.
5
The WB -To ensure protection of human -These guidelines will -The project did not
Group health and the environment be followed during the fully comply with
Environ The General EHS Guidelines contain preparation of ensuring;
ment, information on cross-cutting mitigation measures. -Energy Conservation
Health environmental, health, and safety -Ambient Water
and issues potentially applicable to all Quality
Safety industry sectors. -Water Conservation
Guidelin -Hazardous Materials
e Management
-Waste Management
-Noise Management
Table 1: International Safe Guards
2.3 Legal Framework

2.3.1 The constitution of Kenya, 2010
This statute stipulates that every citizen in Kenya is entitled to a clean and healthy
environment and has a duty to safeguard it. Article 43 of the Kenya Constitution stipulates
that every person has the right to the highest attainable standard of health, which includes
the right to health care services. The constitution provides that a person may apply to a
court for redress in addition to any other legal remedies that are available in respect to a
violation to a clean and healthy environment.
The CoK, 2010, requires the state to address the needs of vulnerable groups, including
minority or marginalized and particular ethnic, religious or cultural communities. In
article 27(6), this statute calls on the state to undertake, ‘legislative and other measures,
including affirmative action programmes and policies designed to redress any disadvantage
suffered by individuals or groups because of discrimination.
2.3.2 The Environmental Management and Co-ordination Act Amendment (EMCA), 2015
This legal framework on environmental management and conservation provides for the
establishment of an appropriate legal and institutional framework for the management of
the environment in Kenya and for matters connected therewith and incidental hereto. The
act acknowledges the fundamental principle that the environment constitutes the
foundation of our national, economic, social, cultural and spiritual advancement.
Part II of this act provides that every person in Kenya is entitled to a clean and healthy
environment and has the duty to safeguard and enhance the environment. This is in order
to facilitate one’s own as well as another persons’ enjoyment of the clean environment.Part
7 of the EMCA (Sections 68-69) gives NEMA the responsibility of carrying out
environmental audits of all activities that are likely to have significant effect on the
environment. In consultation with lead agencies, the Act also authorizes NEMA to carry out
environmental monitoring of all environmental phenomena and operations of an industry,
projects or activities to determine their impacts.
6
Compliance:This facility’s operations comply to the basic principle of a clean and healthy
environment. There is less noise generated, the air quality is good, water is fit for human
consumption as well.
2.3.3Public Health Act Cap. 242, 2012
This act serves to forbid any accumulation or deposition of refuse or other matter, which is
offensive or injurious or dangerous to health. According to this act, it is an offence to emit
or release any noxious matter or wastewater into any place, land, or watercourse not
approved for the reception of such substances. It also prohibits the release of any gases,
vapors, dust or other impurities generated that are deemed to be injurious or dangerous to
the health of employees. It provides for the prevention of pools of standing water and for
the repair and cleansing of open channels and drains.
Compliance: The safety of disposition of medical wastes within the laboratory has been
upheld. Waste generated within the facility are segregated into highly-infectious, non-
infectious and infectious. These wastes are thereafter disposed into bins that are color coded
for each form of waste; Black for Non-infectious, red for highly infectious, yellow for
infectious and sharps are disposed into safety boxes. The generated wastes are then
transferred to the incineration section for incineration. The ashes from the wastes are then
dumped onto an ash pit adjacent to the incinerator. Waste water on the other bhand is
normally treated before being released to the septic tank.
2.3.4 The Occupational Safety and Health Act, 2007
This Act of Parliament provides for the safety, health and welfare of workers in all
workplaces where whether temporarily or permanently. In this respect, every occupier is
mandated to ensure among other duties, safety and absence of risks to health in connection
with the use, handling, storage and transport of articles and substances; the provision of
such information, instruction, training and supervision as is necessary to ensure the safety
and health at work of every person employed, and the provision and maintenance of means
of access to and egress from it that are safe and without such risks to health.
Appropriate risk assessments in relation to the safety and health of persons employed shall
be carried out and, on the basis of these results, adopt preventive and protective measures
to ensure compliance with the requirements of safety and health provisions of this Act.
Compliance:The facility has shown compliance as health workers and support staff use
protective clothing to avoid contamination and/or injury.Appropriate signages to warn
against danger or any form of risks have also been displayed on strategic locations in the
facility.
7
2.3.5 Water Act, 2016

The enactment of this law aimed at aligning national water management and water services
provision with the requirements of the Constitution of Kenya 2010 particularly on the
clauses devolving water and sanitation services to the county governments. The Act vests
provision of water and sanitation services with the county governments through Water
Services Providers (WSPs) whose operations must be in accordance with a Service
Agreement entered between each WSP and WASREB.
Compliance: The facility is connected to Malindi water and Sewerage Company water
line.This water was found to be chemically fit for human consumption.
2.3.6 Radiation Protection Act, Cap 243 2014

This Act aims to control the import, export, possession and use of radioactive substances
and irradiating apparatus. Section 9 of this Act stipulates that a license from the National
Radiation Protection Board is required to handle any radioactive substances or irradiating
apparatus.
2.3.7 National Construction Authority Act, 2011

This act focal area is in consolidation and creation of a well-regulated construction industry
that will promote sustainable socio-economic development. The Act covers virtually all
construction works in the country including building and civil engineering works;
electrical and mechanical engineering services all defined in the broadest sense. All
contractors have to be registered with the Authority.
Compliance:The compliance works during the construction phase was adhered to and no
major complains were identified during its construction phase.
2.4 Policy framework

2.4.1 The National Health Care Waste Management Plan 2016-2021
This initiative is by the Ministry of Health (MOH), together with its development partners
notably World Bank, World Health Organization (WHO), US Centers for Disease Control
and Prevention (CDC), National Environment Management Authority (NEMA), and other
partners. This plan provides viable technical and management options as well as a roadmap
for the domestication of the National HCWM Strategy in Kenya for the next five years.
This National HCWM plan brings out a deliberate strategy aimed at strengthening the
management of HCWM within both hospitals and community settings in order to improve
and safeguard public health and realize a sustainable safe environment.
This plan aims to prevent, reduce and mitigate the likely risks of transmission of infections
likely to be acquired from unsound HCWM, such as HIV/AIDS, hepatitis B, and other
health care-associated infections (HAIs) as well as safe guard the environment for
8
sustainable development. The plan provides feasible options of applying the best available
technologies (BAT) and best environmental practices (BEP) in HCWM.
Compliance:The facility Health Care Waste Management Plan is effective as waste is
segregated, incinerated and ash dumped into an ashpit. The liquid waste generated is also
treated before being discharged into tanks.
2.4.2 Kenya National Guidelines on Safe Disposal of Pharmaceutical Waste, 2001

The provisions of these guidelines describe a series of steps that need to be followed in order
to dispose unwanted pharmaceuticals. The steps required include; identification of
pharmaceutical waste, sorting of pharmaceutical waste by category, filling the relevant
forms to seek authority from the District Health Management Team and the Chief
Pharmacist among other persons to dispose such waste.
Upon obtaining all the relevant approvals, the disposal of the pharmaceutical waste shall be
operationalized under the supervision of the local pharmaceutical waste disposal team or
the Waste Management Team. The recommended methods for disposing of unwanted
pharmaceuticals include:
1. The use of either medium temperatures incineration at a minimum of 850°C or high
temperature incineration exceeding 1200°C with two chamber incinerators for
solids, semisolids and powders for controlled substances e.g. anti-neoplastic.
2. Engineered sanitary landfill to be used for disposal of expired or unwanted
pharmaceuticals.
3. Sewer disposal for diluted liquids, syrups, intravenous fluids, small quantities of
diluted disinfectants and antiseptics.
2.4.3 National Policy on Injection Safety and Medical Waste Management
This policyseeks to ensure safety of health workers, patients, and the community and to
maintain a safe environment through the promotion of safe injection practices and proper
management of related medical waste. Some of the guiding principles for the
implementation of this policy include:
 Establishment of organizational structures at all levels for all the implementation of
injection safety and related medical waste.
 The policy also addresses the need for environmental protection through
appropriate waste disposal methods.
 Minimization of risks to patients, health workers, communities and the
environment through application of safer injection devices and sharps waste
disposal methods.
 Advocating for the strengthening of the necessary human resource capacity
through training and sensitization for safe waste disposal
9
2.4.4 National Environmental Policy 2013

This Policy seeks to provide the framework for an integrated approach to planning and
sustainable management of natural resources in the country. It recognizes the various
vulnerable ecosystems and proposes various policy measures not only to mainstream sound
environmental management practices in all sectors of society throughout the country but
also recommends strong institutional and governance measures to support the achievement
of the desired objectives and goal.This policy states that the government will;
1. Promote Environmental Health Impact Analysis as a component of EIA for all
development.
2. Enhance provision of occupational health and safety services.
3. Promote capacity building in the field of health impact analysis.
Compliance:No major complains were raised from the neighboring community about the
facility rate of pollution.
2.5 Environmental Regulations

2.5.1 Waste Management Regulations, 2006
According to these regulations, no person should dispose of any waste on a public highway,
street, road, recreational area or in any public place except in a designated waste
receptacle. Any person whose activities generate waste shall collect, segregate and dispose
or cause to be disposed of such waste in the manner provided for under these Regulations.
Any person whose activities generates waste has an obligation to ensure that such waste is
transferred to a person who is licensed to transport and dispose of such waste in a
designated waste disposal facility.
Compliance:The facility segregates its waste and disposes waste into bins depending on
nature of the waste; Highly-infectious (red), Infectious (Yellow) and Non-infectious
(Black). These wastes are then incinerated and ash dumped into an ashpit.
2.5.2 Noise and Excessive Vibration Pollution control regulations, 2009

This policy stipulates the maximum permissible noise levels from a facility or activity to
which a person may be exposed to; provide for the control of noise; and provide for
mitigating measures for the reduction of noise. These regulations apply even to work
places and do not negate the factories and other places of work.
These Regulations prohibit production of any loud, unreasonable, unnecessary or unusual
noise which annoys, disturbs, injures or endangers the comfort, repose, health or safety of
others and the environment. Any person who is likely to be involved in activities that bring
about excess noise or excessive vibrations beyond the permissible levels must obtain a
license or a permit respectively from the authority.
10
Compliance:The facility has shown compliance to noise levels. No complaints were raised
by respondents.
2.5.3 Environmental Management and Coordination Act (Air Quality) regulations, 2009
This main objective of this regulation is to provide for prevention, control and abatement of
air pollution. This is with an aim of ensuring clean and healthy ambient air. It provides for
the establishment of emission standards and emission limits for various sources such as
mobile sources (e.g. motor vehicles) and stationary sources (e.g. industries) as outlined in
the Environmental Management and Coordination Act, 1999.
Compliance: Quality of air is maintained to be good.

Parameter Guide Value (Max allowable)
Sulphur Oxides (SO2) 60 g/m3
Carbon monoxide (CO)/ carbon dioxide 2.0 mg/m3
(CO2)
Nitrogen Dioxide 0.05 ppm
Oxides of Nitrogen (NOX); 60 g/m3
Suspended Particulate 140 g/m3
Lead (Pb) 0.75 g/Nm3
Table 2: Ambient Air Quality Standards
11
2.5.4 Environmental Management and Coordination Act (Water Quality) regulations, 2006
In the prevention of water pollution, no person shall throw or cause to flow into or near a
water resource any liquid, solid or gaseous substance or deposit any such substance in or
near it, as to cause pollution.
Compliance with water quality standards need to be adhered to as all operators and
suppliers of treated water, containerized water and all water vendors shall comply with the
relevant quality standards in force as promulgated by the relevant lead agencies. The
standards for sources of domestic water need to comply with the standards set out in the
first schedule of the regulations.
Parameter Guide Value (Max allowable)

pH 6.5 – 8.5
Suspended solids 30 (mg/L)
Nitrate-NO3 10 (mg/L)
Ammonia –NH3 5 (mg/L)
Total Dissolved Solids 1200 (mg/L)
Fluoride 1.5 (mg/L)
Copper 0.05 (mg/L)
Table 3: Water Quality Standards
Compliance:
Parameter Guide Value (Max allowable) Results

pH 6.5 – 8.5 7.76
Suspended solids 30 (mg/L) -
Nitrate-NO3 10 (mg/L) 3.61
Ammonia –NH3 5 (mg/L) -
Total Dissolved Solids 1200 (mg/L) 600.16
Fluoride 1.5 (mg/L) 1.03
Copper 0.05 (mg/L) -
Total Bacteria Count 100 -
Total Hardness 300 Mg/LCaCo3 162Mg/LCaCo3
Table 4: Water Quality Compliance
12
CHAPTER THREE
3.0 BASELINE INFORMATION
This chapter provides the main features of the biophysical and socio-economic information
of the project area. Environmental description, also known as baseline studies, is intended
to establish the present state of the environment, taking into account changes resulting
from natural events and from other human activities (Glasson, 1994; Canning et al., 2003).
If an environmental description is flawed, this will reduce the accuracy of subsequent
predictions and mitigation measures (Canning et al., 2003).
3.1 Locational Context

Malindiis located within KilifiCountyin the Coast region. The county lies between latitude
20 20‟ and 400‟South and between longitude 390 05‟ and 400 14‟East. It borders Kwale
County to the south-west,
Taita-Taveta County to
the west, Tana River
County to the north,
Mombasa County to the
south and the Indian
Ocean to the east. The
county covers an area of
12,609.7Km2. It has
sevensub-counties
namely; Kilifi South, Kilifi
North, Ganze, Malindi,
Magarini,
Kaloleni,andRabai. The
sub-counties constitute Map 1: Location of Malindi level 2 lab
seven political
constituencies namely Kilifi North, Kilifi South, Ganze, Malindi, Magarini,
Kaloleni,andRabai.
The laboratory site is found within Malindi District hospital located at 30 13’ 35” Southand
400 7’ 30” East. The hospital is located in Malindi town, in Shella ward. Malindi townis the
largest urban center in Kilifi County. The town is situated at the mouth of the Galana River,
lying on the Indian Ocean coast of Kenya. It is 120 kilometers northeast of Mombasa. The
population of Malindi was 207,253 in 2009.
13
3.2 Physiographic and Natural Conditions

3.2.1 Weather and Climate
Malindi has a monsoon type of climate with hot and humid conditions all the year round.
The long rains are experienced in April to July and the short rains in October to November.
The average rainfall of the area is between 900mm and 1,000mm per annum. Hot and dry
periods occur in the months between January to April while a cool period occurs between
June to August.
The mean minimum temperature is 21.5°C experienced in August while a mean maximum
temperature of 32.1°C is experiencedin March. Average annual temperatures range from
24.4°C to 27.4°C. The warm temperatures coupled with beautiful beaches serve as tourist
attractions.
Malindi Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec
Min (°C) 23 24 24 24 23 23 22 22 22 22 23 23
Max (°C) 31 31 32 31 29 28 27 27 28 30 31 31
Table 5: Mean Annual Temperature
3.2.2 Topography and drainage

Malindi has four major topographic features, namely coastal plains, forest plateau, coastal
range and Nyika plateau. These features are closely related to the existing agro-ecological
zones.The region has altitude ranging from 136m to 600m above sea level and slopes
towards the sea.
The drainage pattern for the county is formed by a permanent river (Sabaki) and seasonal
rivers, which drain into the Indian Ocean through the various creeks along the coastline.
River Sabaki, which flows across Malindi, is the principle source of water for the entire
Kilifi County. The Indian Ocean is a major feature in the district with a coastline of about
155km running from Mida to Ungwana and has good beaches for tourism and fishing
activities. The Seasonal rivers are Nzovuni, Rare, Goshi and Kombeni. There are also
streams which include Wimbi, Muhomkulu,andMleji.
3.2.3 Geology and soils

The geology of the area is made up of unconsolidated sediments at the mouths of rivers and
along the coast. The majority of the area is,
however, formed from marine sediments deposited
since the break-up of Pangea (Burgess and Clarke
2000), with younger sediments closer to the
coast.Sandy soils characterize the landscape of the
14
Plate 1: Geology and soils
area enabling good drainage due to their large air spaces.
3.2.4 Vegetation
Most of this area is covered with dense thicket with scattered cultivated plots planted
mainly with cassava, maize and cowpeas. The natural forest remnant is found near Gede
with species like Combretumschumanii, FicusbusseiandGyrocarpusamericanus. Mangroves
and swamps cover only a small portion of Malindi Municipal area mainly on the sides of
the Mida Creek in Watamu.
3.3 Population and Demography
3.3.1 Population Size and Composition
The population of Kilifi County was estimated to be 1,217,892 in 2012 according to the
Kenya Population and Housing Census 2009. This comprised of 587,719 males and
630,172 females. It has a growth rate of 3.05 percent per annum.
Population Composition by Gender
47.5%
52.5%
Male Female
Chart 1: Population Composition by Gender
Table 6: Population of Kilifi County
Males represent 47.5 percent while females represent 52.5. The county’s dependency ratio
stands at 45 percent. The average morbidity rate in the county is 12.9 percent, with females
having higher morbidity rate at 15.4 percent as compared to men at 9.9 percent. The most
common causes of morbidity in the county are alaria/fever, respiratory infections, Stomach
ache, diarrhea and flu.
The major activities undertaken within the area is fishing due to its proximity to the Indian
Ocean. Malindi is also a tourist destination since majority of tourists prefer visiting the
beach to enjoy the serene environment, the warm sun and the water body. 49.6 percent of
the total population in the area form the labor force population, with only 40.5 percent of
15
the labor force engaged in formal employment. Bodabodatransport service

provisionhashelped curb the problem of unemployment to the youth in the area.
3.3.2 Vulnerable and Marginalized Groups (VMG)

Kilifi is home to a number of VMGs. These include the Wasanya and Wapemba, mainly
found in Ganze, Malindi and Bahari constituencies. The main economic activity ofWasanya
is hunting and gathering while that of Wapembais fishing.These two groups have a unique
identity, collective attachments, distinct customary institutions, indigenous language, small
populations, traditional lifestyles and unique cultures.
16
CHAPTER FOUR
4.0 AUDIT AREAS
4.1 The LaboratoryDesign Provisions
The Malindi Laboratory has been constructed to the design that meets the drawings
specification. The laboratory design is lean and optimized to address the movement related
to patients, personnel and specimens. It has met the design of the client since there is a clear
indication
of how
specimens
move from
the
specimen
area to the
labs for
test and
dispatch of
the results
to the Plate 2: Malindi Level 2 Laboratory Facility
patients.
The laboratory is a two floored laboratory with the ground floor having a waiting bay,
specimen reception area, reception area, reports release desk, cashier office, records room,
patients water closets, phlebotomy room, donor room, blood donor room, restroom, blood
bank, pathologists office, server
room, staff lounge among the key
features that were noted.
The first floor of the facility consists
of microbiology room (functional
room), serology laboratory,
chemistry laboratory, hematology
laboratory, parasitology laboratory,
histology laboratory, microscopy,
freezer room; media prep room,
specimen museum, quality control
laboratory, molecular laboratory
and virology laboratory.
Plate 3: Waiting Bay within the facility 17

4.1.1 Laboratory Worktops.

The worktops/workbenches
are constructed in thick solid
panels which are acid,
solvent, stain and scratch
resistant. They are made
with TRESPA Top Plus and
approved with a marine edge
top and applied backsplash
to contain spillage.
4.1.2 Lab Shelves Plate 4: Laboratory Worktop

The laboratory has shelves, lipped at its edges which are complete and secure. They serve
the purpose of storing reagents.
Plate 5: Lab Shelves
4.1.3 Emergency shower and Eyewash.

The facility has an emergency body shower, well mounted with the self-draining head.
There is an emergency wash that is strategically located
for ease of accessibility along the first-floor corridor. It has
no wastewater floor trap and the need to provide one
would be considered necessary to avoid flooding during
showers.
Plate 6: Emergency Shower 18

Eyewash
4.1.4 Floor finishes.

The laboratory floors are well finished with granite tiles thus making cleaning easier.
4.1.5 Heating, Ventilation and Air-conditioning

The facility is well ventilated. There is an air-conditioner that creates safety and comfort to
the staff and guest users.
Plate 7: Ventilation within the facility

4.1.6 Hand-washing Sinks
There are hand washing sinks adjacent to doorways.However, some sinks are not well
maintained and have rust, with no water running on the taps.
Plate 8: Hand washing sink

4.2 Water Supply, Quality and Conservation
Water connection to the facility is from Malindi Water and Sewerage Company main water
line.The facility receives inconsistent water supply. The water quality was tested by Water
Resources Authority and was found to be chemically fit for domestic use.The facility
usesborehole water as an alternative source of water. There are also storage tanks installed
to cater for incidences of water shortages.
19
4.3 Waste Management
4.3.1 Solid waste management

Waste management strategies are captured in the
Laboratory Safety Manual.
The facility handles its wastes through collection
into the respective bins that are color coded with
liners to distinguish them and advise the facility
users. These wastes are segregated into infectious
(yellow bin), highly infectious (red bin), and
non-infectious (black bin). The facility’s
incinerator uses diesel and has two chambers.
The ash from the incinerator is then disposed of
into an ash pit.
Plate 9: Facility’s Incinerator

4.3.2 Liquid waste management
The laboratory has ensured that any wastewateristreated before being released. In addition,
there is a soak pit for waste water collection.
4.4 Health and safety

4.4.1 Fire safety and Preparedness
The Lab has a mounted hose reel and portable fire extinguishers for safety purposes. The
facility currently has seven fire extinguishers. These are located along the corridors and
exit points of ground and first floor. The contents of the extinguishers include water,
powder and carbon dioxide. The facility also has fire signage at the corridors and exit
points. Educational fire pamphlets and fire team among staff are non-existent.
Plate 10: Fire Horse reel and Portable

Fire Extinguishers
20
4.4.2 Use of PPEs

The staff employs extensive use of personal protective clothing while carrying out their day
to day activities. For instance, those who deal with waste management and general
cleanliness of the facility, ensure use of gloves and gum boots every time they handle waste.
In addition, clinicians use gloves and spill kits while working to ensure their safety and that
of the patients.
4.5 Environmental Conservation activities and awareness

The area is landscaped by grass vegetation. However, small paths have been created within
these lawns causing destruction of the vegetation. There are licenses and permits that
demonstrate accreditation of the project. The facility management is working towards
accreditation under ISO 15189 standards.
21
CHAPTER FIVE
5.0 AUDIT FINDINGS
The need to identify the status of the current environmental conditions within the facility is
paramount as required by the Environmental Impact Assessment and Audit Regulations of
2003. The audit was conducted using various methods and sources, including review of
relevant safeguard documents such as the ESMF, ESMP, ESIAs and VMGPF, Aide Memoires,
including the environmental implementation review sections, assessment reports, and the
EAPHLN Project Appraisal Documents project documentation, supervision reports, site
inspections, interviews and public consultations of key stakeholders (public health officials,
medical and laboratory personnel, waste operators, patients, community representatives) .
The audit findings are thus based on field survey and consultations and review of relevant
documents. Compliance documents during its construction phase were not provided
though a general conclusion was made that the facility had been constructed under
generally good terms.
This facility indeed showed compliance with regard to noise generation, safety of workers
and equipment, security, incidents and accidents occurrence, wastewater generation,
energy consumption, dust emissions, solid waste generation, stormwater runoff and soil
erosion, hydrology and water degradation, air pollution and possibility of diseases
exposure. However, it was noted that the facility did not have adequate instructional,
informatory and directional signage within it.
5.1 Scope of the Environmental Audit

After the initial general assessment of all the facilities, installations, activities, the general
environment in and around the laboratory facility and discussion with the relevant
stakeholders, the assessment focused on the following issues: -
 The laboratory design
 Water supply, quality and conservation
 Waste disposal and management
 Health and safety
 Environmental conservation activities and Environmental awareness
 Energy utilization and conservation
22
5.2 Social and Environmental Findings

5.2.1 Social, environmental and economic benefits of the facility
East Africa Public Health Laboratory has shown admirable actions towards compliance with
the NEMA regulations and World’s Bank Safety guidelines while at the same time meeting
the desires of the client. The laboratory testing capacity has greatly improved the services of
the hospital as patients can be treated according to the accurate results from the lab and do
not have to go far and wide to seek assistance.
The staff and the public commend the facility infrastructure stating that it has generated
growth within the area like well-maintained roads, improved security, and job creation and
services being offered within the laboratory. The services offered within this facility are
extending to the neighboring counties-Mombasa, Kwale, Taita-Taveta, Kitui and Tana River
Counties. Notable positive impacts identified were as follows:
 Revenue
The community has appreciated the presence of the facility since more and better services
are provided. This has generated a pool of people visiting the area promoting businesses
hence increased revenue to the county.
 Job Creation
The facility has created jobs for residing community as some people have been employed by
the facility as security guards, cleaners and lab technicians. Other business people like
suppliers also benefit from this facility. Chemists from the locality benefit since patients are
normally referred to obtain drugs from the chemists. This has generated a viable business
growth within the area.
 Improved standards of living
The facility has ensured faster and accurate diagnosis of diseases and subsequent faster
treatment. This has thus improved the health of the people of Malindi county and beyond.
The employment of staff in the facility and creation and expansion of businesses in the area
has also raised the standards of living of the people.
23
5.2.2 Laboratory Design

Malindi level 2 lab constructed under the Regional East Africa Public Health Laboratory
Networking Project has a well-structured facility that meets the standards and expectation
of the designs. The laboratory corridors are wide enough for easy movement of people and
specimen. The floor is furnished with granite tiles. The rooms of the facility are also well
ventilated.
Plate 11: Laboratory Design
5.2.3 Water Supply Quality and Conservation

The main water supply provider of the facility is MalindiWater and SewerageCompany. The
facility faces the problem of inadequate water supply as it was observed that there was no
water in the taps. Due to this, the facility stores its water for use during periods of water
shortages.The water from taps was tested by water resources authority and was found fit
for domestic use. The facility is also served by a borehole as an alternative water source.
5.2.4 Waste Disposal and Management
Solid waste management
The facility reuses some equipment like slides and forceps,
thus reducing wastes generated. It however does not recycle
wastes. The waste generated iscollectedin bins which are
appropriately color-codedwith liners. Wastes generated are
segregated into highly-infectious, infectious, non-infectious
and sharps. Infectious waste is burnt using the two-chamber
incinerator. Ash from the incinerator are well maintained by
the provision of a pit where ashes are disposed into. Non-
infectious waste is sterilized through autoclaving and
afterwards released to be collected by the county garbage
Plate 12: Autoclaving of solid waste
collection service providers.
Liquid waste management
24
Waste water from the facility is treated using

phenol or formalin. The laboratory has an
effective septic tank as well as a soak pit in
which treated liquid waste is discharged.
Plate 13:Liquid Waste Disposal
5.2.5 Health and Safety

Occupational safety
Safety of the workers has been upheld. The furniture and other equipment are in good
condition. The facility has a romp access to cater for aceess of the physically disabled Waste
is normally sterilized before being discharged and/or released. Re-usable materials are
normally disinfected
before and after use.
Training to create
awareness on sharps
handling, use of
Plate 14: Occupational Safety Strategies
protective clothing,
waste management
and emergency
response is also
upheld within the facility. there are warning signs on the walls of the corridors and on
some doors that warn against danger and entry restrictions. The facility staff normally uses
whistle to warn against danger.
Most accidents/incidents reported normally occur in the phlebotomy room. Pricking is the
most common incident. The facility has an incident file, whereby all records of injuries, ill-
health or accidental loss are stored.
Employees get involved in improvement of their health and safety through loging their
complains, being involved in providing mitigative measures and monitoring safety and
health improvement activities.
Fire safety and preparedness
25
Fire safety strategies are captured in the Laboratory safety manual. Fire drills and training
on fire safety are conducted once in a year and records of the same safely stored. Ire
assembly points are at reasonable distances and areas that would allow extinguishers work
properly in case of fire. There are indeed evident preventive measures against fire such as
the fire extinguishers, fire horse reels and fire assembly pointsand clear signage pinned on
the walls.Theseequipment were last inspected in March, 2018 and thus inspection needs to
be done to validate their effectiveness.
Plate 15: Fire Safety Strategies
The doors and some walls of the facility are fitted with a vision panel to easily see smoke
and other forms of incidents. The facility does not have smoke detectors and audible alarms
and flashing lights for reinforced fire safety and preparedness. Instead, people whistle in
times of danger.
Personal Protective Equipment (PPE’s)
The cleaners wear protective clothes and
gloves while cleaning the facility.
The hospital’s incinerator operator is highly

trained and adheres to safety measures. They
dress effectively with protective gears like
helmets, boots, protective clothes and masks
covering their mouths and nose.
The technicians use biohazard spill kits and

dispose sharps in a safety box.
Plate 16: Biohazard Spill Kit
26
5.2.6 Environmental Conservation and awareness

Loss of Biodiversity
Vegetation cover has been destroyed as the place is used for movements of persons and
vehicles. The lawns are also un-manicured hence making the compound untidy. This has
destroyed the natural habitat of some insects. There is need for provision of designated
areas for pedestrian walkways and lawns.
Plate 17: Vegetation Cover
5.2.7 Energy utilization and Conservation

The power houses that serve the facility are locked off and only accessed by authorized
personnel. These personnel observe safety
strategies like use of boots and gauntlets. The
electrical equipment, like cable sheaths, plugs
e.t.c are generally in good condition.
Plate 18: Locked-off Generator Room 27

5.2.8 Stakeholder consultation and Grievance Redress mechanism

Patients get to fill forms to assess their accessibility to services and their satisfaction after
every six months. This helps the lab management to gauge the performance of the facility
in terms of service provision. Stakeholders are normally engaged through three different
types of meetings;
▪ County meetings that are held by members of the hospital board and county
officers. These meetings are conducted thrice in a year. The main agenda of such
meetings are supervision and handling of complaints. Concerns of the VMGs are
effectively addressed as the boards have community representatives from these
groups.
▪ The help management committee meetings focus on handling departmental issues.
They are conducted every Monday among departmental heads.
▪ Laboratory county coordinators meeting that is held among ministers, chiefs e.t.c. is
mainly focused on supervision and is normally conducted after every four months.
The facility has a service charter that outlines the services offered, time to be taken and the
cost or each service. The staff are expected to strictly adhere to this charter at all times.
Every client is entitled to a redress in case they feel that their rights are being violated.
The laboratory does not have a lab line where patients can forward their complaints. There
is however a suggestion box that is used for complaints and comments. Delays in service
delivery is the most common complain among the patients. The lab manager, deputy lab
manager and the quality officer form the grievance redress committee. This committee
reviews complaints raised once a month. The complaints are safely stored in a complaints
file for future reference. Feedback is normally done through notices and the respective
representatives in the hospital board.
28
CHAPTER SIX
6.0 PUBLIC PARTICIPATION AND CONSULTATION
6.1 Introduction
Public Participation and Consultation form a vital component for gathering, understanding
and establishing the project target populations’ understanding of the project, perceptions,
expectations, level of involvement and views on its impacts during design, implementation,
and operation. Furthermore, through public participation and consultation, it is possible to
enhance project performance, acceptability, and sustainability.
The Constitution of Kenya,

2010 provides for public
participation and
consultation throughout the
project cycle to enhance
acceptability and
sustainability of the
expected project benefits.
The purpose of public and
Figure 1: Public Participation
stakeholder participation in
the environmental audit of the lab facility in Malindi under the ongoing regional East
Africa Public Health Laboratory Networking Project was to obtain their opinions on the
project and establish how they derived or could derive project benefits and the challenges
they faced or could face due to the project.
6.2. Stakeholder Engagement

Stakeholder engagement is a key principle of the World Banks safeguards policies. This
approach of public participation is informed by the requirements under the World Banks’
Vulnerable and Marginalized Group Planning Framework (VMGPF) which gives guidelines
on the need and approach to ensuring the said populations adequately participate in the
project.
Public consultation as part of the environmental and social impact assessment report was
conducted before the project commenced. This was aimed at obtaining public opinions on
the proposed laboratory project. Among the stakeholders engaged included business
people, patients and the residents of the region. The general conclusion of this exercise was
that all the respondents were in support of the project.
29
The respondents reiterated that the project would bring about job creation, infrastructure
improvement and gains in local and national economy. They however did not fail to
mention negative concerns/ issues associated with the project, such as potential noise
pollution, potential dust emissions, and potential increase in water demand, potential
increased solid and liquid waste generation, risks of accidents and Injuries to workers and
the public among others.
On 30th April, 2015, consultations with the general public were held at Malindi Market.
The overall goal for doing this was to seek for public opinions from professionals, patients,
patients’ relatives, employees among other members of the community. The main agenda
included project’s magnitude, envisaged activities and impacts, safeguard provisions during
construction, mitigation measures during implementation, historical or cultural importance
and suggestions on way forward from the stakeholders.
The participants reported that there were no historic or cultural sites around the project
site. They pointed out positive impacts of the project as creation of job opportunities;
provision of timely services, reduced transportation cost; improved quality of diagnostics
and enhanced ability to conduct disease outbreak investigations. They also described
shortcomings of the project and recommended that the project should initiate outreach
laboratory services, mobile clinics and medical camps for the hard to reach areas, enhance
public participation through regular community engagement and that community
awareness campaigns be conducted to increase utilization of the facility.
Public consultations during this EA were conducted through interviews with the
neighboring household members and discussions with the relevant key stakeholders,
management, staff, affected persons. A sample of thirty questionnaires were administered to
key staff, institutions and the immediate target community members who utilize the
laboratory facility. In-depth discussions in form of focus groups with waste handlers, and
healthcare workers were also done. Other data were collected by use of checklists,
observations, site surveys, photographing, and literature reviews of documented
information.
The participants raised their concerns about the project and provided recommendations as
outlined below;
 The facility should have other equipment to avoid referrals

 Employment of more laboratory staff for efficiency of services
 Establishment of similar labs within Malindi to achieve a wider threshold
30
6.2.1 Vulnerable and Marginalized Group Planning Framework

This framework aimed at ensuring participation of VMGs in the project before and during
project implementation. This is to achieve benefits that are culturally appropriate and
minimize or mitigate negative impacts that may affect these VMGs. Representatives of some
VMGs were involved in preparation of this framework, through consultation and during
disclosure of the framework. A number of anticipated positive and negative effects of the
project were raised and mitigation measures proposed where applicable. It was anticipated
that there will be no significant and/or irreversible adverse environmental and social issues
anticipated from the investments to be financed under the Project.
A number of concerns that arose were social exclusion of VMGs by the elite,environmental
risk due to biomedical waste which may be solid or liquid, weak capacity to implement and
monitor safeguards at the county level, cultural mismatch between the health staff
approach and the VMGs, geographic isolation and socio-cultural issues in some target
communities that may hinder health service uptake. It was proposed that the disclosure
mechanisms be culturally appropriate,social inclusion through good communication and
social awareness andcapacity development of VMGs and stakeholders be enhanced through
financial support.
31
CHAPTER SEVEN
7.0 MANAGEMENT AND MONITORING ACTION PLAN
The role of this EA was to ensure utmost compliance with domestic laws and regulations,
especially with EMCA, (Environmental Impact Assessment and Audit), 2003; EMCA
(Amendment) 2015. The Compliance strategies involve actions to promote and enforce
legal requirements.
The new lab facility in Malindi had shown compliance across different institutional
framework at the National level. However, some areas did not complywith the stated
measures and standards. A matrix of the compliance of the project’s operation phase was
done to evaluate the findings of the audits and propose the intervention measures against
the negative impacts caused by activities of the facility. There is need to put into
consideration the stated interventions to enable attainment of effective operationof the
facility.
32
Detailed Overview of Issues, Recommended Solution and Institutional Responsibility

Issue/Problem Recommended Solution Responsibility Time Monitoring Indicators Budget
frame (Kshs)
Air Pollution -Air quality monitoring should frequently be done Medical 1 Month -Improved air quality 1,500,000
-Installation of a filter in the chimney at the smoke exit
Superintendent
points
-Noise levels should frequently be monitored to ensure
compliance
Removal of - Plan and provide pedestrian walkways. Medical Regularly -Improved aesthetics of the area
-Re-vegetation of degraded sites to improve landscaping of
vegetation Superintendent -Manicured and maintained 1,000,000
the site
cover - Monitoring of revegetation activities; regular pruning lawns
Solid Waste Management

Solid waste -Construction of an incinerator with a bigger capacity 1 Month -Reduced accumulated waste 1,000,000
management -Liners bins should be strategically located within the around the facility
laboratory to enhance waste segregation and hence proper -Reduced health hazards
waste management Medical Always -Number of complaints against 3,000,000
-Regular removal and proper disposal of solid waste should Superintendent poor waste management
be continued.
-Employ 3Rs (Reduce, Recycle, Reuse)
Liquid waste - The septic tank should be emptied regularly by registered Medical Always -Frequency of water related 2,000,000
management exhauster company. Superintendent diseases
-Commentsfrom surrounding
local community
33
Occupational health and safety

Office -Regular inspection for malfunctioning systems and Medical Always -Comments from surrounding 1,000,000
equipment structures, and their immediate repair superintendent local community
Fire safety and -Awareness creation Medical Always -Improved fire safety 200,000
preparedness -Conduct drills regularly to ensure preparedness of staff superintendent preparedness
-Provision of information, instruction, training and -Increased awareness on fire
supervision necessary to improve on Fire safety and safety and prevention
preparedness -Number and frequency of fire
-Improve on fire safety preparedness; install smoke related incidences
detectors and fire alarm systems.
-Regular servicing of fire safety equipment
Water quantity -The water should be tested regularly to ensure it maintains Medical Always -Water conservation practices 2,000,000
and quality the recommended WHO guidelines for portable water in superintendent -Incidences of water shortages
regards to bacteriological, physical and chemical properties
before it is used for human consumption. -Comments from the general
-Water harvesting measures should be put in place. public
- Connect water into the washrooms and other parts of the
facility to ensure visitors have access to running water
Noise levels -Continuous noise monitoring should be done to be within Medical Always -Comments from surrounding 100,000
allowable levels by NEMA regulations(60-dB) superintendent local community
Occupational -Monitoring of environmental and health and safety issues -Increased awareness on 200,000
Safety -Provision of information, instruction, training and environmental and safety issues
supervision necessary to improve on fire safety and
preparedness -improved capacity of waiting
- Put biometrics access control in all entrance ways bays
-Increase the size of waiting bays -improved knowledge on PPEs
34
-The personal protective equipment should be frequently by staff

replaced and training provided in using the equipment. Medical Always
- Infrastructure upgrade; superintendent

• Repair all broken seats/benches -Improved lab furniture
• Replace all broken tiles within the facility. -Improved ventilation within
• Install air conditioning system in the rooms the rooms
without -Increased light penetration in 500,000
Medical 5 Months the rooms
superintendent -Incidences of roof leaks
Energy Conservation
Unsustainable -Employ 3Rs Medical 12 -Reduced waste generation 1,200,000
energy -Alternative green sources of energy; biogas, solar energy superintendent Months -Improved air quality
consumption
Grievance redress mechanism and stakeholder consultation
Delay in -Expedite services Medical Througho -Comments from the public -
service delivery -Employ more staff superintendent ut the
project
cycle
Lack of a lab -Install a lab line Medical 1month -Comments from the public 20,000
line -Ensure easy access to the lab line superintendent
-Provide a mechanism of safe storage of complaints sent
through the lab line
Delay in -Ensure address of complains as urgently as possible Medical Througho -Comments from the public -
addressing superintendent ut the -Frequency of repeated
complains project complaints
cycle
35
Inefficiency in -Ensure involvement of aggrieved persons and the party Medical Througho -Comments from the public -
provision of that caused the grievance superintendent ut the
-Ensure involvement of both parties in decision making
feedbackto where possible project
complains cycle
raised
Table 7: Environmental Management Action Plan
36
CHAPTER EIGHT
8.0 CONCLUSION AND RECOMMENDATIONS
8.1 Conclusion
The lab facility has been operating on general good practices as they have complied to some
extent with World Bank Safeguards policies, NEMA regulations and requirements of the
Environmental Management and Co-ordination Act (EMCA), 2015 and the Environmental
(Impact Assessment and Audit) Regulations 2003. However, there is need to implement the
stated measures to achieve a friendly environment and a positive social impact on the users
both within and outside of the facility.
8.2 Recommendations
In order to ensure socially inclusive, environmentally friendly and economic benefits of the
project, the stated environmental management mitigation measures should be put to action.
In addition, the project proponent should also;
 Enhance public participation through regular community engagement

 Conduct sensitization campaigns to create awareness on the project implementation
activities and any other cross cutting issues
 Initiate outreach laboratory services, mobile clinics and medical camps for the hard
to reach areas
 Ensure proper capture of VMG concerns through efficient involvement and
consultation with these groups
 Embrace green construction strategies like rain water harvesting, use of renewable
energy sources and landscaping to enhance the environment
 Ensure efficient grievance redress mechanism through provision of a lab line,
involvement of aggrieved parties and the department to which the complain is
raised and addressing of complaints as they occur.
37
Annexes
Annex 1: EA Checklist
Annex 2: Sample Institutional Questionnaire
Annex 3: Sample Stakeholder questionnaires
Annex 4: Water quality Test
Annex 5: Sound calibration
Annex 6: Room Layout
Annex 7: Incinerator and Autoclave
Annex 8: Ground Floor Lab Design
Annex 9: First Floor Lab Design
Annex 10: EA TEAM
Annex 11: Lead Expert Certificate
Annex 12::TOR
38
Annex 1: EA Checklist
39
40
41
42
43
44
45
Annex 2: SampleInstitutional Questionnaire
46
47
48
Annex 3: Sample Stakeholder questionnaires
49
50
51
52
53
54
55
56
57
58
59
60
61
62
63
Annex 4: Water quality Test
64
65
Annex 5: Sound calibration
66
Annex 6: Ground Floor Lab Design
67
Annex 7: First Floor Lab Design
68
Annex 8:Incinerator and Autoclave
Autoclave
69
Annex 9: Room Layout

i. Ground Floor Corridor( Floor, Wall and ceiling)
ii. Reception area ventilation and sitting area
70
iii. Corridoor Upstairs ( Ceiling and floor)
iv. Tuberculosis lab room
71
Annex 10: EA TEAM
EIA Team Qualification

James MainaKiambigi Lead expert
Moses Nyaga Associate expert
Brian Ngunjiri Associate expert
Rossinah Mwau Associate expert
72
Annex 11: Lead Expert Certificate
73
Annex 12: TOR

Terms of Reference
Background Information
The Government of Kenya through the Ministry of Health under the regional East Africa
Public Health Laboratory Networking Project (EAPHLNP) received funding from the
International Development Agency/the World Bank to strengthen laboratories in Kenya.
Other beneficiary countries were Tanzania, Burundi, Rwanda and Uganda. The
development objective of the regional project was to establish a network of efficient, high
quality, accessible public health laboratories for the diagnosis and surveillance of
communicable and non-communicable diseases.
This regional project triggered OP/BP4.01 (Environmental Assessment) due to the

construction of laboratories as well as the potential generation of medical waste at the
completed laboratories. Thus, the project was assigned the Environmental Category B. Also,
the Bank‟s Safeguard Policy on Indigenous Peoples (OP/BP4.10) was triggered (Kenya,
Burundi) premised on the assumption that the projects may affect vulnerable and
marginalized communities. In view of the triggering of these two Safeguard Policies, the
regional EAPHLNP prepared an omnibus Environmental and Social Management
Framework (ESMF) that included an Environmental and Social Management Plan (ESMP)
for all participating countries to ensure proper assessment and mitigation of potential
adverse environmental and social impacts and risks. This ESMF outlined the steps in the
environmental and social screening process, and included Environmental Guidelines for
Contractors, a summary of the Bank‟s Safeguard Policies, an Environmental and Social
Checklist, Generic Environmental Assessment (EA), Terms of Reference to be applied in the
event that the screening results indicate the need for site-specific ESIA reports and
Environmental and Social Management Plans (ESMPs).
Part of the World Bank credit to the Government of Kenya under the EAPHLNP was used to
construct five regional public health laboratories at Wajir, Machakos, Malindi, BusiaKitale
and National Public Health Laboratory (table 1). Other key units participating in and
benefiting from the project include the Disease Surveillance and Response Unit and
Tuberculosis and Malaria Programs. The Kenya Medical Supplies Agency and Kenya
Medical Research Institute are also implementing the supply chain management and
research components respectively.
74
In Kenya, an elaborate Indigenous Peoples Policy Framework (IPPF) was prepared,

consulted upon and disclosed. Also the Kenya project adopted a National Medical Waste
Management Plan (MWMP), and carried out site-specific Environmental and Social Impact
Assessment (ESIA) studies for each of the project sites. These have been consulted upon,
approved by the National Environmental Management Authority (NEMA) and disclosed in-
country and in the World Bank Info shop much later when most of the construction had
either started or completed.
Table 1: Project sites
No. Name Intervention Location

1. Malindi New Construction Kilifi county
2. Machakos New Construction Machakos county
Problem definition
Since the ESIAs/ESMPs were prepared in the first year of the project prior to construction,
there is need for carrying out an environmental and social audit (EA) in order to ensure
that there was due diligence in the application of safeguards during construction and to
plan for mitigating and/or addressing any potential adverse risks during the operational
phase. An EA is required for systematic documentation, and objective determination and
evaluation of the environmental and social liabilities of the laboratory constructions in full
compliance with the World Bank Safeguard policies including the ESMF 1, ESIAs, MWMP,
IPPF that were prepared and recently disclosed in-country and at the World
Bank‟sInfoShop. The EA will also indicate compliance with environmental, health and
safety guidelines with the objective of protecting the health of workers and the general
public living in the area as well as to protect the biophysical environment.
75
Scope of Environmental Audit:
The scope of the EA will cover all the civil works related to public health laboratories that
have been constructed under the East Africa Public Health Laboratory Networking Project
(EAPHLNP)as well as the operationalization of the waste management plan for the health
institutions in Kenya supported at the satellite laboratories by the EAPHLN project.
Overall Objective of the Assignment
The primary objective of the consultancy is to undertake an Environmental Audit (EA) of

the projects in Kenya under the EAPHLNP in order to ensure compliance with:
(i) The National Environmental Management Authority (NEMA) Act and EIA
and Audit Regulations
(ii) World Bank‟s Environmental and Social Safeguards requirements
Thus, the EA will help to determine how far the activities that relate to the construction as
well as operation of the laboratories have complied with the ESIAs, ESMPs, MWMP, IPPFs
and sound environmental health and safety management practices. The audit is necessary
to ensure that the safeguard instruments have been implemented appropriately, and that
relevant mitigation measures have also been identified and implemented. The audit will be
able to
Section 6. Fraud and Corruption
identify any amendments/updates to be effected to the safeguard instruments to improve
their implementation effectiveness. The key objective of the Environmental Audit is to
identify gaps in environmental management measures and to prepare an action plan that
will be implemented during the rest of the project period. Overall Tasks to be Carried Out:
Environmental audit studies to be conducted at each of the sites to assess
whether there are significant environmental and social impacts or sensitive and
fragile habitats at the sites
Prepare environmental audit reports on the potential environmental

consequences of structures on the environment, and socio-economic impact of
the operationalization of the expanded public health laboratories if any.
76
Specific Tasks for the Consultancy:

The following is the scope of work:
A. Review and Gap Analysis

• To review the environmental legal and regulatory requirements applicable to
the laboratory project. To determine on-the-ground compliance to these
requirements, and identify gaps if any.
• Verify the levels of compliance by the project during construction and with
the conditions of the ESMF, ESIA, ESMP, MWMP, IPPF, and identify gaps if any.
• To review the environmental management practices being implemented both
from the point of view of adequacy as well as effectiveness, and identify gaps if any.
• Determine the magnitude of the predicted impacts of the projects on various
physical and social parameters at the project sites and compliance monitoring.
• Determine the extent to which expected benefits of the project has been
realized for the stakeholders, community, and the environmental components.
• To review the environmental monitoring, planned and being done to ensure
the necessary verification of the effectiveness of implementation, and identify gaps if
any.
• To review the staff/human and other resources capacity available to
implement environmental management practices, and identify gaps if any.
• To review the earlier stakeholder/public consultations done in order to
determine the issues relevant to the Environmental Audit.
• To consult key stakeholders – hospital and laboratory officials, contractors
and consultants, immediate neighbouring communities – during the conduct of the
review.
• Assess the major environmental non-compliance issues and challenges.
B. Action plan
Based on the review and gap analysis carried out under A:
• To identify the specific environmental management measures and corrective
actions that are required to be implemented during the rest of the project -
completion of civil works stage and in the operation stage. These management
measures should be either avoidance or mitigation or remedial/compensatory.
• To identify the specific environmental monitoring required during the
implementation of safeguards instruments during the remaining phase of the project.
• To identify how the management and monitoring measures will be addressed
so that contractors implement these measures.
77
• To assess additional capacity and costs or budgetary requirements in order to

conduct the additional management and monitoring measures.
• Discuss findings of the environmental audit exercise with the relevant
project authorities and county officials where the public health laboratories are
located in order to find appropriate solutions locally.
C. Report Preparation
• Prepare site-specific environmental audits and compliance monitoring
reports for the counties, regional ministry of health and MoH.
• To document the findings in a report that will include a summary, audit
findings and an environmental and social action plan for each facility. The structure
of the report will follow the outline indicated in the scope of work.
1. Methodology and Approach:
The environmental auditing will be achieved through the following approach:
• Review of relevant documents (ESMF, ESMP, ESIA, IPPFs, MWMP, etc.
prepared for the project) and existing environmental and occupational health and
safety legislations and standards, environmental safeguard policies and guidelines of
the World Bank and Kenya Government;
• Prepare an audit framework, criteria and checklist;
• Site visits to two project supported sites of Machakos and Malindi. This will
include physical inspection of the facilities, carrying out interviews and discussions
with facility management and staff, and holding meetings and consultations with
key stakeholders and affected communities, if any;
• Verification of procedures, instructions and equipment in place designed to
help the facilities apply and adhere to: existing environmental laws, regulations, and
World Bank standards, occupational health and safety standards, good
environmental and safety management practices, facilities‟ own environmental and
social management plans
• Evaluation of findings, developing a prioritized list of concerns related to
past and ongoing activities at the facilities, making recommendations (including the
auditor‟s opinion of the facilities‟ overall environmental performance with respect
to regulatory, World Bank corporate environmental requirements, main strengths of
NEMA environmental management practices, cost estimates for the implementation
of remediation action plan deemed necessary to comply with World Bank‟s
Safeguard
Policies, etc.);
78
• Reviewall safeguards instruments including the ESMP, ESIAs, MWMP and

IPPF for the safe and effective management of the public health facilities by
incorporating appropriate remediation measures; and
Section 6. Fraud and Corruption
• Compiling the findings and finalizing the report writing
2. Qualification of the Consultant:
An Individual Consultant will be selected on the basis of Quality and Cost Based Selection
procedures in accordance with the policies of the International Development Association
(IDA) detailed Guidelines: Selection and Employment of Consultants by World Bank
Borrowers, published in May 2004, and revised in October 2006 and May 2010. A copy of
the guidelines can be obtained at the following website: www.worldbank.org/procure.
A suitably qualified and experienced lead consultant with a higher degree at masters level,
with excellent professional background and experience in environmental and social
assessment and familiarity with the Kenya Government and World Bank‟s safeguard
policies and procedures will be recruited to conduct the environmental and social audit.
3. Expected Output and Report Format
The main outputs of this assignment will be individual EAs reports for each of the sites,
prepared in accordance with the World Bank Safeguard Policies (especially OP. 4.01) and
the NEMA EIA and Audit Regulations. The reports should ensure that they provide the EA
findings and the recommendations for remedial action required to bring the facilities into
compliance with the World Bank guidelines and other applicable safeguard obligations.
The Consultant shall produce site-specific audit reports that will comprise three chapters,
in addition to an executive summary. Chapter one will provide the introduction to the
project, scope and methodology for conducting the audit. Chapter two will provide
description of the environmental and social footprint of the project (location), relevant
policies and administrative frameworks (including applicable laws, procedures and
guidelines), implementation arrangements, environmental and social safeguards
instruments that were prepared and identified environmental and social impacts. Chapter
three will provide the EA findings and the recommendations for remedial action required to
bring the facilities into compliance with the World Bank guidelines and other applicable
79
safeguard obligations. Also,Chapter three will provide a prioritized list of concerns. The
report will have an executive summary and appendices, and photographs, where
applicable.
Deliverables, Duration and Timing for Study

A detailed and acceptable Inception Report for work on the two locations and incorporating
methodology and timeframe for carrying out the consultancy and the expected outputs
shall be prepared and submitted within the first two (02) weeks of signing the Contract.
The Client shall review the Inception Report and give feedback to the Consultant within one
(01) week. The Consultant will then proceed to conduct the EA study in the field and draft
the individual EA reports within four (4) weeks. These reports will be submitted to Project
Coordinating Unit for review and quality assurance check after seven (7) weeks after
signing the Contract. The Client will review and comment on the submitted reports within
two (02) weeks from the date of reports receipt and thereafter the Consultant will prepare
the final EA reports within the eleventh (11) week after signing the contract. The final
reports shall incorporate comments from the Client and other stakeholders. The EA reports
should meet the requirements of the World Bank and those of the National Regulations on
EIA and Audits. The Consultant will submit to the Client four (4) hard copies as well as two
(2) CDs containing soft/electronic copies (in word document and „pdf‟ format) of the Final
EA reports for each of the sites in English language.
The timeframe of implementation of the assignment and schedule of payments:

No. Item Outputs Vs Payment Duration of
submission by
consultant
1. Upon submission of inception Inception Report (20%) Three (02) weeks
report
2. Review of the inception report Review comments on the One (01) week
by the Client Inception Report
3. Upon submission of draft EA Draft EA report (30% Four (04) weeks
reports payment)
4 Review and quality assurance of Review comments on draft Two (02) weeks
EA reports by the Client EA report
5 Upon submission and approval Final EA report (50% Two (02) weeks
of final EA reports payment)
80
Project Facilitation:
The Consultant will be facilitated from the project side with the following:
Relevant materials which will include the relevant safeguards documents such as the
ESMF, ESMP, ESIAs, IPPF and MWMP, Aide Memoires, project’s progress reports, including
the environmental implementation review sections, assessments reports, and the EAPHLN
Project Appraisal Documents A liaison project staff from the PCU.
Annex 11:Image (i) Copy of WHO SLIPTA Checklist, pg.11
81
82

E.Audit Kenya

Uploaded by

Copyright:

Available Formats

E.Audit Kenya

Uploaded by

Document Information

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

E.Audit Kenya

Uploaded by

Copyright:

Available Formats

Environmental Audit for Malindi Laboratory

ENVIRONMENTAL AUDIT REPORT FOR EAST AFRICA PUBLIC

ENG. JAMES MAINA KIAMBIGI

LEAD EXPERT, NEMA REGISTRATION NO. 0307

P.O. BOX 24866-00100 NAIROBI

TEL: 0722789750, 0724250556

Signature ____________________________ Date ________________________________

National Public Health Laboratory Services

Socio economic, Environmental, and Health and Safety Issues

 Liquid waste management

Occupational health and safety aspects

 Fire safety and preparedness

 Water quantity and quality

Stakeholder consultation and grievance redress mechanism

Detailed Overview of Issues, Recommended Solution and Institutional Responsibility

Solid Waste Management

Occupational health and safety

- Infrastructure upgrade; superintendent

Grievance redress mechanism and stakeholder consultation

5.1 Scope of the Environmental Audit .......................................................................................... 22

EMCA Environmental Management and Coordination Act

EAPHLNP East Africa Public Health Laboratory Networking Project

NEMA National Environment Management Authority

ESIA Environmental and Social Impact Assessment

ESMF Environmental and Social Management Framework

ESMP Environmental and Social Management Plan

MWMP Medical Waste Management Plan

IPPF Indigenous Peoples Policy Framework

KEMRI Kenya Medical Research Institute

EBM Evidence-Based Medicine

SLIPTA Stepwise Laboratory Improvement Process Towards Accreditation

KQM Kenya Quality Model

ECDC Early Childhood Development Centers

EPZ Economic Processing Zones

LIMS Laboratory Information Management Systems

KMTC Kenya Medical Training Institute

KEMRI Kenya Medical Research Institute

It is worth noting that certain measures, like development of a laboratory when

According toOP/BP4.01, the construction, operation and decommissioning of the Lab

1.2 Audit Objectives, Scope and Methodology

1.2.2 Audit Scope

2.0 LEGAL, POLICY &INSTITUTIONAL FRAMEWORK

2.2 International Safeguards

Policy Objective Trigger for the policy Compliance

2.3 Legal Framework

2.3.5 Water Act, 2016

2.3.6 Radiation Protection Act, Cap 243 2014

2.3.7 National Construction Authority Act, 2011

2.4 Policy framework

2.4.2 Kenya National Guidelines on Safe Disposal of Pharmaceutical Waste, 2001

2.4.4 National Environmental Policy 2013

2.5 Environmental Regulations

2.5.2 Noise and Excessive Vibration Pollution control regulations, 2009

Compliance: Quality of air is maintained to be good.

Parameter Guide Value (Max allowable)

Parameter Guide Value (Max allowable) Results

3.1 Locational Context

3.2 Physiographic and Natural Conditions

3.2.2 Topography and drainage

3.2.3 Geology and soils

Signature Date ____