Enviromental Impact Assesment

SDF Secretariat
Masala Area, Next to Mercy Corps Guest House

Hargeysa, Somaliland
Tel: +252 (0) 633464207
Email info@sdf-secretariat.org
Ministry of Health
ESIA for Rehabilitation of

Las
Anod
and
Erigavo
Hospitals
November the 21st, 2015
Consultant
Nelson Omagor: Short Term

ESIA Expert
Tel: +256772458903
Email:
nelsonomagor@gmail.com
Somaliland Development Fund-SDF
ESIA for Rehabilitation of Las Anod and Erigavo

Hospitals, MoH
Somaliland Development Fund

Secretariat
Issue and revision record
Revision
Date
Originator
Checker
0 Draft
November 18th
2015
Nelson Omagor
Rup Chapagai
Narayan
1st Draft
November 22nd
2015
Nelson Omagor
Rup Chapagai
Narayan
Approver
Description
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Table of Contents
Chapter title Page

Issue and revision record
Table of Contents
List of abbreviations
Executive Summary
1.
INTRODUCTION
10
1.1.
Background
1.2.
Project Description
10
1.2.1.
Project objective
10
1.2.2.
Project location 10
1.2.3.
Project Alternatives
2.
POLICY, LEGAL AND INSTITUTIONAL FRAMEWORK 12
2.1.
Policy frameworks
2.1.1.
National Environment Policy, 2011
2.1.2.
The National Development Plan 2011-2016
2.1.3.
The Somaliland Vision 2030
2.2.
Legal Frameworks
2.2.1.
The Constitution of the Republic of Somaliland, 2010
2.2.2.
Environment Conservation Act and Proclamation, 1998 12
2.2.3.
Somaliland Health Regulatory Act 19/2001
2.3.
Institutional Framework 12
2.3.1.
The Ministry of Health
2.3.2.
Ministry of Environment and Rural Development 13
2.3.3.
Somaliland Development Fund 13
2.3.4.
Community Health Board
3.
BASELINE ENVIRONMENT AND SOCIAL SETTINGS
3.1.
Population
3.2.
Poverty levels 14
3.3.
High mortality rates
3.4.
High regional risky deliveries
3.5.
Common diseases in Sool and Sanaag regions 15
3.6.
Status of hospital infrastructure 15
10
10
12
12
12
12
12
12
12
13
13
14
14
14
14
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3.6.1.
Dilapidated old hospital infrastructures
15
3.6.2.
Existence of some hazardous infrastructures
3.6.3.
Inadequate facilities
3.6.4.
Improper medical waste management
3.6.5.
Inappropriate location of some infrastructures
3.6.6.
Water supply
17
3.7.
Vegetation
17
4.
ENVIRONMENTAL SCREENING AND STUDY OF THE SUB-PROJECTS
4.1.
Environmental Study Approach 18
4.2.
ESAF screening and categorization of the two hospital sub-projects
18
4.3.
Approach in the preparation of the ESIA for the hospitals sub-projects
18
4.3.1.
Briefing meeting by SDF Programme Team Leader
4.3.2.
Desk review
4.3.3.
Identification of stakeholders
4.3.4.
Consultative meetings in the project areas
5.
PROJECT IMPACTS
20
5.1.
Impacts during works
20
5.2.
Negative impacts during hospitals operations
5.3.
Environmental monitoring
5.3.1.
Monitoring indicators
21
5.3.2.
Proposed BoQs Items
22
5.4.
Conclusion and Recommendations
5.4.1.
Conclusion
5.5.
Recommendations
6.
REFERENCES 23
7.
APPENDICES 24
7.1.
Appendix 1: Disposal of Asbestos Water Pipes in Las Anood Hospital, Sool Region
7.2.
Appendix 2: Environmental and Social Management Plan
7.3.
Appendix 3: WHO medical waste coding 32
7.4.
Appendix 4: Environmental and Social Screening Datasheet (Adapted from SDF ESAF 2014)
7.5.
Appendix 05: Anticipated rehabilitation works in Erigavo Hospital 39
7.6.
Appendix 06: Project rehabilitation works for Las Anood Hospital 40
15
16
16
16
18
18
18
19
19
21
21
22
22
22
24
29
33
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List of abbreviations
CHW
Community Health Workers
DFID
Department for International Development
DG
Director General
ESA
Environmental and Social Assessment
ESAF
Environmental and Social Assessment Framework
ESIA
Environmental and Social Impact Assessment
FGM
Female Genital Mutilation
GBP
Great Britain Pound
GoSL
Government of Somaliland
ICU
Intensive Care Unit
IFI
International Financial Institutions
HC
Health Centres
HGH
Hargeisa Group Hospital
HMIS
Health Management Information System
HSSP
Health Sector Strategic Plan
MCH
Maternal Child Health Centre
MICS
Multiple Indicator Cluster Survey
MoH
Ministry of Health
NDP
National Development Plan
NTC
National Technical Committee
NGOs
Non-Government Organizations
OCVP
Observatory of Conflict and Violence
OPD
Out Patient Department
OT
Operating Theatre
PHU
Primary Health Units
PMT
Project Management Team
PPE
Personal Protective Equipment
RHC
Referral Health Centres
RMO
Regional Medical Officer
SDF
TBA
Traditional Birth Attendants
THET
Tropical Health and Education Trust

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UN
United Nations
USD
United States Dollar
WHO
World Health Organization
CHW
Community Health Workers
DFID
Department for International Development
DG
Director General
ESA
Environmental and Social Assessment
ESAF
Environmental and Social Assessment Framework
ESIA
Environmental and Social Impact Assessment
FGM
Female Genital Mutilation
GBP
Great Britain Pound
GoSL
Government of Somaliland
ICU
Intensive Care Unit
CBO
Community Based Organization
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Executive Summary
Project Background
The two hospitals of Las Anood and Erigavo that are to be rehabilitated are in the regional capitals of Sool
and Sanaag respectively in the remote east part of Somaliland. Overall, the project is expected to contribute
to reduced poverty levels in Sool and Sanaag regions through the delivery of quality secondary health care
services, resulting in lower morbidity and mortality, and higher productivity. This is hoped to lead to increased
equitable access to quality secondary health care in Sool and Sanaag regions through the re-activation of
the two regional hospitals facilities. The two hospitals are existing and operational and within the
municipalities of Erigavo and Las Anood. The hospitals are not within or close to protected areas, any in
culturally sensitive settings or near wetlands. Their rehabilitation will not have any significant adverse
negative impacts nor will there be displacement, or land up take except short-term internal re-organization of
its facilities to accommodate works and allow delivery of services alongside ongoing works.
Project Environmental and Social impacts

Positive impacts
These include:
1. Safe removal and disposal of hazardous asbestos water pipes in Las Anood hospital by excavating,
sealing and safe dispose of the asbestos pipes which reduces its health risk impact on the hospital
community;
2. Once rehabilitated the hospitals will offer improved maternal and child health care services hence,
improve the health status of the mothers and child survival;
3. Gender empowerment in that, well-functioning obstetric units in the hospitals will promote
reproductive rights also, women are more in the administration and service delivery in health units;
4. Through the planned re-modelling and re-equipping of the hospitals, their functionalities will be
improved hence, improvement in service delivery;
5. There will be short-term employment opportunities during rehabilitation works thereby giving a
source of livelihood for the youth and their households;
6. The project will re-organize and appropriately place hospital infrastructures taking into account,
social and psycho-social considerations. For instance, the mortuaries will be relocated to fairly
secluded corners in both hospitals;
7. Rehabilitation and construction of incinerators and their ash pits, placenta pits as well acquisition of
waste management facilities (autoclaves) will improve management of hazardous wastes; and
8. The project will improve water supply systems in both hospitals which will enhance cleanliness and
improve their operations.
Project negative impacts and their mitigation measures

1. Safe and secure disposal of asbestos water pipes in Las Anood hospital will reduce health risks to
which the public is currently exposed to in the hospital;
2. Problems associated with dust and excavation soils during rehabilitation works will be addressed
through hoarding, levelling and compacting the sites;
3. Evident social and tribal sentiments in the project areas which can cause problems of misprocurements are to be mitigated through sensitization and providing to the public with information
on procurements laws and outcomes of the bidding process as much as possible;
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4. Disruption of hospital services during their rehabilitation can be mitigated through joint planning of
work program by the contractors and hospital management to ensure the hospital continue delivering
services during works;
5. The hospitals will remain open for use during their rehabilitation works therefore the safety of the
public has to be guaranteed through hoarding (screening) of the work sites and displaying warning
signs both in English and Somali for the public;
6. Occupational health safety (OHS) risks for workers is to be mitigated through availing Personal
Protective Equipments (PPEs) to the workers, having 1 st Aid kit in place and displaying clear safety
direction guides on the sites;
7. Management of construction waste from demolition debris to be mitigated through routine
transporting and dumping in approved dump sites and possible re-use of some salvageable
materials;
8. Generation of noise and vibrations arising from works and workers is to be checked by keeping to 8
hour work schedule, briefing of workers and ensuring construction trucks observe set speed limits of
15km/hr inside hospitals and no hooting by trucks; and
9. Potential loss of trees in the two hospitals is to be managed by keeping works outside stands of
isolated trees in the compounds.
Negative impacts during operations

These will likely include:
1. The revitalization of the two hospitals will translate to improved service delivery which will trigger
additional generation of medical waste which is to managed through aggregation of medical waste
into designated and separate waste bins and use of incinerators as well as providing PPEs to the
workers handling medical waste;
2. Impacts relating to human anatomical waste, diseased and incised limbs, removed organs, and birth
placentas are to be managed by keeping such waste in appropriate bags, incineration and disposing
incinerator ash in incinerator pits while placentas are to be disposed in placenta pits;
3. Potential risk of fire outbreaks during hospital operations will be mitigated through use of emergency
exits, fire extinguishers and posting warning signs such as No Smoking in strategic locations in
the hospitals;
4. Potential accumulation of obsolete equipment in the hospitals is to be mitigated through collection,
re-assessing to salvage re-usable ones for use in lower heath units and transporting junk ones to the
National Scrap Yard in Berbera for sale under GoSL Assets and Disposal laws;
5. Community apathy to access health services will be addressed by MoH through media campaigns to
be championed by the Regional Health Offices and community leaderships; and
6. Risks of failure to maintain rehabilitated hospital facilities as well as keep compliance with standard
medical waste management practices are not anticipated to arise because MoH is annually
increasing its allocations to the hospitals for their operations and the hospital management boards
are being revived to oversee resource mobilization at local levels for continued and effective
operations of the hospitals.
Monitoring program
The overall responsibility for the environmental monitoring of the project will lie with the PMT of MoH with
support from SDF M&E Team. Some of the key monitoring indicators will include:
a. Evidence of proper excavation, sealing and safe disposal of asbestos;
b. Asbestos removal site fenced off with warning signs;
c. Implementation of dust suppression and soil control measures;
d. Construction areas fully hoarded in the hospitals for public safety;
e. Traffic signs in place to direct the public and guide traffic in hospitals during works;
f. The underground water tank where asbestos water pipes drain into sealed off with clear warning
signs both in English and Somali;
g. Monitoring of medical waste management measures will focus on the following indicators;
separate medical waste bins in place and clearly labeled,
incinerators in place and working,
incinerator ash pits in place and under use,
placenta pits in place,
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h. PPEs for workers in place and in use;

i. Greenery belts of 10x30m in each hospital in place; and
j. Atleast 20 trees planted and caged in each of the hospitals.
Proposed BoQs Items

The project contracts should have some clauses addressing environmental and social aspects as follows in
the BoQs:
Removal and disposal of asbestos should include the following in the BoQs;
1. Asbestos removal and disposal procedures;
a. Provide for enclosing asbestos work areas and with warning notices,
b. Provide for excavation, building and cementing asbestos disposal pit of suggested size of
2x3x4m,
c. Provide for tones of concrete, sand and cement for burying asbestos pipes,
d. Provide for polythene sheets of 1500g for sealing of asbestos,
e. Provide for tapes for sealing asbestos pipes,
f. Provide for PPEs and tools for daily works on asbestos,
g. Provide for a Video Recording of the asbestos removal and disposal process,
h. Provide for input for an Occupational Safety and Health Specialist to oversee and report on
asbestos removal and disposal process,
i. Provide 1.25m chain link with steel iron bars around asbestos dump site,
j. Well labelled asbestos hazardous warning signs in place on the disposal site.
2. Provide resources for continued and targeted sensitization campaigns in the two areas to provide
information on the procurement requirements to avert mis-procurement risks arising from tribal and
social sentiments in the areas;
3. Provide for hoarding of the sites for public safety public during rehabilitation works;
4. Provide Personal Protective Equipment (PPEs) for workers, overall, gloves and boots (general
workers, not only asbestos working group);
5. Provide for demolition of inappropriately sited pit latrines in Erigavo hospital;
6. Plant at least 20 trees in each of the hospitals for greening and climate change mitigation; and
7. Establishment of green belts of grass in the hospitals of 10x30m; and
8. Provide resources for acquisition of autoclave machines to improve medical waste management.
Conclusion
The following conclusions have been drawn on the project:
1. The environmental and social impacts arising from the planned rehabilitation of the two hospitals will
be of small-scale, localized and of short-term nature. The projects will not impact on protected
ecosystems or forests and there will be no land uptake or displacement of people hence, no
compensation will arise in the projects;
2. The asbestos water pipes for rainwater harvesting in Las Anod hospital will be removed, sealed and
disposed off into a securely prepared and cemented pit inside the hospital premises. This process
should be overseen by an Occupational Safety and Health Specialist and the engineers with video
recording of the process; and
3. The project impacts are of their low grade in nature and can be addressed through good engineering
and construction practices without necessarily calling for standalone environmental based costs and
therefore, a need for proper oversight by the supervising engineer, SDF engineers and the PMT.
Recommendations
The ESIA recommendations are:
1. There is need to explain to the communities in the project areas aspects basics of the procurement
process in the projects because of a feeling that, the contracts should be awarded to local based
contractors in disregard of the procurement law which can make the projects end up in possible misprocurement scenarios;
2. Works should not commence on any of the hospitals until contractors have put in place, appropriate
signs and barricades for purposes of public safety and continued hospital functioning during works.
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INTRODUCTION
1.1.
Background

Secretariat
The GoSL is credited for effective delivery of basic security and stability, especially compared to the regions
in Southern Somalia. This has created an enabling environment for the delivery of public goods. Current
priority activities for improvement of the governments service delivery across all sectors are: improved
regulatory oversight, quality assurance, improved coordination between different government levels and nongovernment actors, costing the sectors and improved Public Financial Management systems. For the
immediate future the GoSL places a high value on the visibly delivery of health services by the state as a
means of enhancing the legitimacy of the state. The GoSL is committed to reactivate its government
managed hospitals that guarantee equitable access to health to all its citizens. Somaliland is amongst
countries with the worst maternal mortality ratios in the world, estimated to be between 1400 and 1000 per
100,000 live births with infant mortality rate at 90/1000 while the under-five mortality is about 145/1000. Life
expectancy at birth is between 47 and 57 years.
1.2.
Project Description
Based on the above, it is evident that, both the public and private hospital establishments in the Eastern
Regions of Somaliland could be considered almost non-functional. Health care is grossly insufficient in the
eastern regions of Sool and Sanaag and therefore, the urgent need for intervention as planned in this
project.
Project objective
The project is expected to contribute to reduced poverty levels in Sool and Sanaag regions through the
delivery of quality secondary health care services, resulting in lower morbidity and mortality, and higher
productivity. This is to be achieved through increased access to quality secondary health care in Sool and
Sanaag regions through the rehabilitation of the two hospitals facilities.
Project location
The two hospitals of Las Anood and Erigavo that are to be rehabilitated are in the regional capitals of Sool
and Sanaag respectively in the remote east of Somaliland (Figure 1).
Project Alternatives
The project Alternatives considered in this ESIA include:

1.2.3.1.
No Project Scenario
The No project scenario means that the proposed rehabilitation of the two hospitals would not be
implemented and could be based an assumption that, the existing facilities would still effectively deliver the
required medical services without any improvements. However, this Alternative is not sustainable
considering that, the areas of Sanaag and Sool would continue to lag behind with regard to access to
improved medical services in terms of immunization, maternal and child mortality, and general dilapidation
of hospital infrastructures. In addition, Las Anood hospital still use asbestos pipes in its rain water
harvesting. If this option was pursued other potential benefits associated this intervention would all be
missed.
1.2.3.2.
Renovating current hospital infrastructures
The Action Scenario means the proposed project will be implemented as planned. The major benefits of
the proposed project are improving availability and access to modern medical services currently not
available due to dilapidated infrastructure and lack of equipment and facilities at the two hospitals. The
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option is to involve limited internal modifications, strengthening weakened sections, re-roofing some units
and painting of the built environment hence entailing demolition, remodeling and reconstruction of walls
and it is the one being pursued.
1.2.3.3.
Construction of new facilities
The option of constructing new medical facilities would maximize the wider desired development goals in line
with GoSL aspirations on universal access to affordable and standard medical services. However, this Option
would require a longer period of time to accomplish and a lot more resources. This will also require a larger
budget than what is currently availed under this intervention by SDF. In view of these, the preferred option at
hand bearing in mind available resources is taken as partial rehabilitation of hospitals infrastructure which is
believed can deliver the objectives of the Project.
Figure 1: Las Anood and Erigavo hospitals shown in purple dots
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POLICY, LEGAL AND INSTITUTIONAL

FRAMEWORK
Some of the salient policy instruments relating to environment include:
2.1.
Policy frameworks
National Environment Policy, 2011
The overall vision of the National Policy on Environment is to provide a framework management guide for the
management of Somalilands environment and natural resources so as to ensure that they are managed on
sustainable basis and retain their integrity to support the needs of the current and future generations.
The National Development Plan 2011-2016
The NDP aims at creating an enabling environment that is conducive to employment generation especially
among the youth, human resource development, technological advancement, effective and efficient
governance, increasing competitiveness and rising income levels.
The Somaliland Vision 2030
The Vision outlines five pillars which are critical in turning around and rewriting the Somaliland development
narrative. The pillars are economic development; infrastructure development; governance and rule of law;
social development and environmental protection. The Vision enshrines environmental sustainability in
its aspirations and therefore, development projects ought to be hinged on the NDP Pillars and are to
be implemented in a sustainable manner.
2.2.
Legal Frameworks
The Constitution of the Republic of Somaliland, 2010
Article 18 of the Constitution affirms that, the State shall give a special priority to the protection and
safeguarding of the environment, which is essential for the well-being of the society, and to the care of the
natural resources. In this regard, development projects have to comply with the Constitutional which
obliges them to ensure a clean and healthy environment.
Environment Conservation Act and Proclamation, 1998
The Act provides for the management and protection of trees and general management forest reserves. In
all, project activities have to be compliant with the Act.
Somaliland Health Regulatory Act 19/2001
The Somaliland Health Policy explicitly recognizes the central role of the regional hospitals and Regional
Health Offices and its crucial importance in pastoral areas such as Sool and Sanaag.
2.3.
Institutional Framework
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The Ministry of Health
The key role of the Ministry of Health is policy formulation, advocacy, external relations and serve as the
bridge between the people of Somaliland and the Government. The Ministry of Health has made
commitments to ensure effective and efficient operations of the hospitals of Erigavo and Los Anod after
rehabilitation works.
Ministry of Environment and Rural Development
The mandate of the Ministry of Environment & Rural Development is to develop the pastoral sector, protect,
conserve and manage environment through sustainable development aimed at eradication of poverty,
improving living standards and ensuring that a protected and conserved environment is available. This
gives MoERD mandate technical oversight over the compliance of projects in the country.
The Somaliland Development Fund (SDF) is a 4-year fund designed to support GoSL by supporting projects
that are fully aligned to the NDP. The Sool and Sanaag health sub-projects proposed by the Ministry of
Health are being financed under the SDF framework.
Community Health Board
Community Health Boards (CHBs) are already existing in both hospitals and they represent the voice of the
community. In Las Anood they have been involved in raising funds from local businesses to support the
hospitals. The CHBs have a fair representation of stakeholders, though pastoralists are missing. Experience
in other regions has shown that such a link greatly facilitates the organization and financing the
transportation of seriously ill people from the countryside to the hospitals.
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BASELINE
ENVIRONMENT
SOCIAL SETTINGS
AND
There is no available reference information gives specific baseline information on environmental and social
settings for the two hospitals. What is presented here is a synopsis of such information based on broader
aspects for the wider areas and, some information documented during the field visit to the two sites and is
summarized herein.
3.1.
Population
The Eastern Regions of Sool and Sanaag cover over half of the surface area of Somaliland, but contain only
23% of the population. It has an arid climate (semi arid in the North) and the main livelihood is pastoralism
(Table 1).
Table 1: Population details in Sool and Sanaag Regions
Region
Urban
Rural
Sool
120,993 (37%)
13,983 (2%)
Sanaag
39,717 (12%)
30,802 (7%)
Total
180,710 (23%)
22,787 (6%)
(Source: Population Estimation Survey 2013)
3.2.
Nomads
IDP
Total
187,632 (37%)
332,692 (79%)
320,322 (70%)
2,820
910
3,730
327,228
222,123
771,331
Poverty levels
The poverty levels in the two regions is very high and is attributed to the combined effects of (past) conflict,
the 2001-2009 livestock export ban to Saudi Arabia and environmental degradation. Unfortunately, the two
regional public hospitals have not received adequate government interventions in terms of rehabilitation and
maintenance; they are in dilapidated states and poorly staffed and equipped to deliver any meaningful
medical services amidst high and impoverished population.
3.3.
High mortality rates
Indicators of the availability of healthcare are key determinants for morbidity and mortality and suggests that,
the situation in the Eastern Regions of Sool and Sanaag could be considerably worse than for Somaliland as
a whole. Children under five years in Sanaag visit a health facility on average only 0.46 times a year, or just
over under once every two years, against a recommendation of the World Health Organization of 2 visits per
year. People over 5 visit a public health facility about once every six years.
3.4.
High regional risky deliveries
For Somaliland as a whole, the MICS (Multiple Indicator Cluster Survey) 2011 report indicates that, 18.8% of
all deliveries take place in a public health facility, against 12.4% in Sanaag and 5.2% in Sool. Analysis of the
Health Management Information System (HMIS) for the first nine months of 2014 shows that Sanaag had
only 6.6% in-facility delivery. This is clear evidence that the Eastern regions are considerably disadvantaged
and the mothers are at high risks of death during delivery.
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3.5.

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Common diseases in Sool and Sanaag regions
Though the medical records on disease incidence in the regions is scanty, records from Erigavo Hospital the
following main disease burden in the areas include; diarrhoea, injuries, pneumonia, suspected tuberculosis,
hypertension and STDs (Figure 2). These diseases relate to the life styles and the general living conditions in
the areas i.e. mainly pastoral lives where there is reliance on un boiled milk and unsafe water and sanitation
at household levels.
Figure 2: Reported common diseases treated in Erigavo Hospital

(Source Erigavo Hospital records, 2013-2014).
3.6.
Status of hospital infrastructure
Dilapidated old hospital infrastructures
The two hospitals were built by the colonial administration in 1946-47 and for years, there has been limited
maintenance and repairs to keep the structural integrity of the infrastructures. Some walls in the hospital
infrastructures have developed gaping cracks (Figure 3) which compromises their structural integrity.
Figure 3: Typical scenes in various infrastructures in the two hospitals
Existence of some hazardous infrastructures
Some utilities in the hospitals are of hazardous materials which the hospitals have continued to rely on
despite such them being of high health risk especially asbestos water pipes in Las Anood hospital (Figures
4&5) whose usage has long been outlawed by WHO yet are still part of water supply in the hospital to date.
The asbestos water pipes are exposed and cracked which put lives of the people are risks. These pipes are
earmarked in the project for immediate and safe disposal.
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Figure 4: Exposed and cracked asbestos water harvesting

pipes.

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Figure 5: Crack on upper part of underground

water tank with an asbestos over-flow pipe.
Inadequate facilities
The hospitals were built in 1946-47 and by then the population and demand for medical services was fairly
low. However, over years, the population and the demand for the services has since grown and this has
forced the hospitals to conduct some of their services in small and shared work areas despite the sensitivity
of some of diagnosis especially in laboratory facilities.
Improper medical waste management
The hospitals have challenges of medical waste management though the situation is slightly better in Erigavo
hospital through assistance from Medicines San Frontiers which constructed an incinerator and its pit and a
placenta pit each 7m deep plus other pits not in use for now. In Las Anood the incinerator is not of standard
type and even its ash is improperly disposed thereby putting additional health risk to the hospital community
and, adjacent public. Sometimes expired drugs are improperly disposed (Figure 6).
Figure 6: Expired drugs disposed in a corner of Las

Anood hospital
Figure 7: Mixed medical waste in one

container in Las Anood hospital
Inappropriate location of some infrastructures
From consultations during this ESIA, stakeholders observed that, from a socio-cultural and psycho-social
perception, having mortuaries directly opposite the wards and in front of busy circulation areas in health
facilities is traumatizing both to the patients and the attendants which is the case in both hospitals where the
mortuaries are located directly in front of children and male wards respectively. Patients interviewed showed
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uneasiness with the presence of a morgue directly opposite their wards; instead, the morgues ought to be
located in fairly secluded sites in the hospital establishment.
Water supply
The two hospitals have varying degrees of reliable water supply which affects their normal operations in one
way or the other. For Las Anood, the hospital water is from rainwater harvesting eventually drained to
underground tank through its asbestos water and sometimes water is bought from private water dealers at
an average monthly fee of USD 200. A part from economic cost associated with buying the water, the source,
cleanness of such water cannot be guaranteed. For Erigavo, the hospital has fairly reliable water supply from
municipal water supply system and the project plans to improve the reservoir. For Las Anood the project will
connect the hospital from SDF funded water supply project for the town.
3.7.
Vegetation
There are no wild life sanctuaries or protected areas within the 2 km radius of the project sites i.e. in Erigavo
and Las Anood. Neither are there any rare, endangered or endemic species recorded. These hospitals are
existing and not new or green projects but infrastructure for rehabilitation. Therefore, there will be
no adverse negative impacts on flora and fauna.
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ENVIRONMENTAL SCREENING AND

STUDY OF THE SUB-PROJECTS
4.1.
Environmental Study Approach
In the absence of Somaliland policies and legislation on environmental and social assessment for
development projects, guidance on environmental and social implications of SDF project interventions is
currently based on the SDF Environmental and Social Assessment Framework (ESAF) document 2014
which has guided the screening and categorization of this project as well as the ESIA process.
4.2.
ESAF screening and categorization of the two hospital

sub-projects
As per DFIDs Environment Guide 2003, all SDF interventions (sub-projects) with a value of GBP 1 million or
more where environmental or social impacts are expected, including jointly funded initiatives where DFIDs
contribution is over this threshold, should be screened. On this project, the Environmental Screening was
conducted using SDF Environmental Assessment Framework (ESAF) which is a guiding tool for identification
of potential adverse impacts associated with the interventions as well as project categorization. Since there
is no national framework for streamlined environmental management framework, the ESAF is used alongside
other environmental guidelines for other countries or International Financial Institutions (IFI) to further verify
and authenticate the screening and the categorize the sub-projects.
In these sub-projects, the World Bank Safeguards Guidelines were also referred in the categorization of Las
Anood and Erigavo hospitals projects. Based on these, the rehabilitation of Las Anood and Erigavo hospitals
projects were placed as Category B Type i.e. projects with less adverse environmental and social impacts,
their impacts are site-specific; few; and their mitigation measures can be addressed more readily by
conducting a low scale Environmental and Social Impact Assessment as in this case.
4.3. Approach in the preparation of the ESIA for the hospitals

sub-projects
The preparation of this ESIA was accomplished through a combination of approaches which included:
Briefing meeting by SDF Programme Team Leader
A briefing meeting was held between the consultant and the SDF Programme Team Leader which was aimed
at putting the consultant into perspective with the scope and setup of the project as well as the need for to
work closely with the MoH who are key in identifying and placing appointments with stakeholders to be
consulted. Of key importance in the meeting was concern on how to manage and safely dispose asbestos
rainwater pipes in Las Anood hospital since these are hazardous waste with health risks to humans. ESIA
has from the onset be clear on how such materials are to be disposed off without putting the public at risk.
Desk review
At the start of the assignment, the consultant spent time collecting line information relevant to the study. SDF
secretariat and MoH references were useful sources of baseline information for the study. Sectoral policy
documents and SDF project proposal for MoH alongside SDF ESAF amongst others provided useful base
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information on this study. The consultant also reviewed previous ESIA documents for projects funded by
SDF.
Identification of stakeholders
In consultation with the MoH technical staff, the consultant identified project stakeholders and agreed on how
to hold consultations with the stakeholders on thematic issues of the project as well as giving an informed
view on the project. A planning meeting was held to agree on how to conduct the consultative meetings and
field visits to the sub-project sites in Erigavo and Las Anood. This involved meeting the Deputy Team Leader
and the Project Engineer as well as Conflict Analyst of SDF. There were also meetings with MoH Technical
Advisor and the Project Manager to further discuss aspects of the study as well as field work details.
A provisional list of primary stakeholders was drawn as follows:
a. Director General Ministry of Health
b. Meeting the Regional Governors and mayors in the two regions of Erigavo and Sool
c. Regional Health Officer for Ministry of Health in Erigavo and Las Anood, the Directors of two
hospitals
d. Workers in the hospitals and patients
e. People residing in the vicinity of the hospitals
f. Those doing businesses e.g. kiosks attendants in the hospitals
g. Non-Government Organizations (NGOs)
i.
Tropical Health Education and Training (THET)
ii.
Candlelight for Health, Education and Environment
iii.
Unicef WASH Specialist
h. Some elders in the areas of the hospitals
Consultative meetings in the project areas
The Consultant undertook a 10 day field visit to the project sites with the objective of getting on the site
status of issues in the project, meeting and consulting with the key stakeholders which included meetings
with; the Regional Governors of Sool and Sanaag regions to brief them on the study and its relevance in the
project as well as meetings with the Regional Medical Officers who were met alongside the Medical Directors
of the two hospitals., the consultant inspected the hospital infrastructures and continued discussions with
some senior staff of the hospitals on a number of aspects which included waste management during
hospitals operations as well as environmental and related aspects during their operations.
Meeting at Las Anood compound
Meeting with the RMO
Figure 8: Sections of field discussions
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PROJECT IMPACTS
5.1.
1. Management of asbestos water pipes: the rainwater harvesting in Las Anood has asbestos water
pipes in its rainwater harvesting in since hospital construction in 1946-47. There are plans in the project
for safe removal and disposal of these pipes as detailed under Appendix 1.
2. Dust and excavation soils concerns will be addressed through leveling and compacting the sites;
3. Contracting challenges: through consultations it appears there can be contracting challenges on the
projects based on inherent social, political and tribal sentiments in the project areas. Therefore, the
process of procurement for works needs to be transparent to the detail giving the public access to
information as much as possible.
4. Disruption in the delivery of hospital services during rehabilitation to be mitigated through proper
planning of construction activities, re-arrangements of rooms and equipments to enable hospitals
continue to function;
5. Safety of the public, the hospitals will remain open for use during their rehabilitation works, safety of
the public will be important through hoarding (screening) of the work sites and displaying warning signs
both in English and Somali to for the public (Figure 9b)
Screening or hoarding of the site with CGI

sheets
Site warning signs
Figure 9: Typical hoarding and warning signs in construction site
6. Management of construction waste, which largely consist of demolition debris including timber,
metal cuttings, excavated materials, paper/cement bags, empty paint and solvent containers, broken
glass among others. To be mitigated through transporting it to approved dump sites by the engineer
and re-use of some that is salvageable.
7. Occupational health safety (OHS) risks for workers is to be mitigated through providing PPEs to
the workers, having 1st Aid kit in place and clear safety guides on the site (Figure 10).
8. Generation of noise and vibrations arising mainly from workers is to be addressed through keep
working 8 hour work schedule, briefing of workers and ensuring construction truck observe speed
limits of 15km/hr inside hospitals and no hooting by trucks (Figure 11).
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9. Potential loss of trees, the two hospitals have some isolated trees on their compounds. It is
important rehabilitation works do not cut down the existing indigenous trees. In addition, the project
to plant at least 20 trees in the compounds of the hospitals to mitigate climate change (Figure 12).
5.2.
Negative impacts during hospitals operations
These will likely include:

1. Potential improper management of medical waste arising from improvements and re-equipping of
the hospitals there is likely to be an increase in the services delivered and attendant increased volumes
of hazardous medical waste generated. This will be mitigated through aggregation and disposal of
medical waste into designated and separate medical waste bins and incinerators. Providing PPEs to
workers handling medical waste.
2. Management of human anatomical waste arising from surgeries yielding diseased human parts such
as limbs, removed organs, and incised body parts and after birth placentas all constitute what is
generally termed human anatomical waste. These will be managed by keeping such waste in
appropriate containers or bags as soon as possible at the theater and incineration and the incinerator
ash be disposed in incinerator ash pit close to an incinerator.
3. Potential risks of fire outbreaks during hospital operations will be mitigated through use of emergency
4.
5.
6.
7.
8.
9.
exits, water reels, fire extinguishers and posting warning signs No Smoking be posted in strategic
sections in the hospitals (Figure 13).
Security measures, all persons entering the hospital premises to be subjected to security checks in a
gender and Islam sensitive manner as well as installing security lights in strategic locations in the
hospitals.
Accumulation of obsolete equipment (Figure 14) to be mitigated through collection, re-assessing to
pick re-usable ones for supply to lower heath units while junk will be transported to the National Scrap
Yard in Berbera for sale to scrap dealers under Assets Disposal laws and money remitted to National
Treasury of Somaliland.
Community apathy to accessing health services will be addressed by MoH through use of the
media, campaigns by the Regional Health Offices and Hospital Boards campaigns;
Misuse, abuse or inability to use installed equipment will be addressed through in-service training of
healthcare staffs and skilling on use and operations of installed equipment.
Risks of failure to maintain rehabilitated hospital facilities as well keep compliance with standard
medical waste management will not arise because MoH is annually increasing allocations to the
hospitals for their operations. The Hospital Management boards are to be revived and these will
oversee resource mobilization for continued and effective operations of the facilities.
Impact of establishing a temporary workers camp site for purposes of managing construction
logistical needs, the contractor will require a temporary campsite inside the hospital premises to
house equipment and general administration of the project. This can cause public health issues
regarding management of human waste amongst others. The contractor will put and routinely
ensure clean maintenance of public utilities and later, demolish and fully landscape the site.
5.3.
Environmental monitoring
Monitoring indicators
The overall responsibility for the environmental monitoring of the project will lie with the PMT of MoH with
support from SDF M&E Team and some key monitoring indicators will include:
a. Evidence of proper excavation, sealing and safe disposal of asbestos;
b. Asbestos site fenced off with warning signs;
c. Implementation of dust suppression and soil control measures;
d. Construction areas fully hoarded in the hospitals;
e. Traffic signs in place to direct the public and guide traffic in hospitals;
f. The underground water tank where asbestos water pipes drain into sealed off with clear warning
signs both in English and Somali;
g. Medical waste management measures;
i.
separate medical waste bins clearly labeled,
ii.
incinerators in place and working,
iii.
incinerator ash pits in place
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iv.
placenta pits in place,
h. PPEs for workers in place and in use;
i. Greenery belts of 10x30m in each hospital in place; and
j. 20 trees planted and caged in each of the hospitals.
Proposed BoQs Items
The project contracts should have deliberate clauses addressing environmental and social aspects to the
address the following into their BoQs:
Removal and disposal of asbestos should include the following in the BoQs;
a. Asbestos removal and disposal procedures;
i. Provide for enclosing asbestos work areas and with warning notices,
ii. Provide for excavation, building and cementing asbestos disposal pit of 2x3x4m,
iii. Provide for tones of concrete, sand and cement for burying asbestos pipes,
iv. Provide for polythene sheets of 1500g for sealing of asbestos,
v. Provide for tapes for sealing asbestos pipes,
vi.
Provide for PPEs and tools for daily works on asbestos,
vii. Provide for a Video Recording of the asbestos removal and disposal process,
viii.
Provide for input for an Occupational Safety and Health Specialist to oversee and report on
asbestos removal and disposal process,
ix.
Provide 1.25m chain link with steel iron bars around asbestos dump site,
x.
Well labelled asbestos hazardous warning signs in place on the site.
b. Provide resources for continued and targeted sensitization campaigns in the two areas to provide
information on the procurement requirements to avert mis-procurement risks arising from tribal and
social sentiments in the areas;
c. Provide for hoarding of the sites for public safety public during rehabilitation works;
d. Provide Personal Protective Equipment (PPEs) for workers, overall, gloves and boots;
e. Provide for demolition of inappropriately sited pit latrines in Erigavo hospital;
f. Plant at least 20 trees in each of the hospitals for greening and climate change mitigation; and
g. Establishment of green belts of grass in the hospitals of 10x30m; and
h. Acquisition of autoclave machines to improve medical waste management.
5.4.
Conclusion and Recommendations

Conclusion
The following conclusions have been drawn on the project:

1. The environmental and social impacts arising from the planned rehabilitation of the two hospitals will
be of small-scale, localized and of short-term nature and not impact on protected ecosystems,
forests and there will be no land uptake or displacement of people hence, no compensation will
arise.
2. The asbestos water pipes for rainwater harvesting will be removed, sealed and disposed off into a
securely prepared and cemented pit inside the hospital premises. This process should be overseen
by an Occupational Safety and Health Specialist and the Engineers with video recording of the
process.
3. The project impacts are of their low grade in nature and can be addressed through good engineering
and construction practices without necessarily calling for standalone environmental based costs.
5.5.
Recommendations
The ESIA recommends as follows:

1. From the consultation, it is likely that, there is likely to be conflict on the procurement processes on
these projects based on tribal and ethnic divides in the project areas which can lead to misprocurement. To avert these, there should be sustained sensitization on the procurement process
through credible information outlets accessible to the public;
2. Works should not commence on any of the hospitals until contractors have put in place, appropriate
signs and barricades public safety for hospital functioning during works; and
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3. After rehabilitation and handover of the facilities to MoH, it is important, the Ministry supervisory staff
as well as management of the two hospitals have the requisite capacity for effective operations and
supervisory oversight on the operations and functions of equipment and facilities as pledged by MoH
senior management during this ESIA study.
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REFERENCES
1. DFID, 2003: Environmental Guide, UK London

2. FAO 2012, Invisible Guardians: Women Manage Livestock Diversity. FAO Animal Production and
Health Paper No. 174.
3. MoH 2006-2016: National Health Policy, Republic of Somaliland
4. National Development Plan, 2011, Ministry of Health
5. National Development Plan (2012-2016), Ministry of National Planning and Development, HargeisaSomaliland.
6. OCVP 2011, Safety and security: District Baseline report, Las Anood.
7. Republic of Somaliland, Food and Water Strategy, 2010. PGGP-EH-SPENV
8. SDF/GoSL Project Proposals for MoH, Feb. 2015, Hargeisa-Somaliland
9. SDF/GoSL Project Proposals for MoE&HS, Feb. 2015, Hargeisa-Somaliland
10. SDF, Final ToRs for ESIA for Health and Education STE EIA assignment, 2015
11. SDF ESIA for MoL, 2014
12. Unicef 2012 Children in Somaliland Report, Hargeisa Field Office
13. USAID/REDSO/ESA: Environmental Review of Djibouti Live Animal Export Facility Development
Project, Nairobi.
14. USAID 2013: Somaliland Livestock End Market Study. AIMSs Consulting Ltd for DAI and CNFA.
15. World Bank 2013, Environmental and Social Sustainability: Project Categorization Modules,
Washington DC.
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APPENDICES
7.1. Appendix 1: Disposal of Asbestos Water Pipes in Las

Anood Hospital, Sool Region
Asbestos health risks
Asbestos-containing materials can release fibers into the surroundings due to wear and tear and
deterioration or when they are disturbed, damaged or broken. These fibers, when inhaled, may lead to
serious lung diseases such as asbestosis (scarring and fibrosis of the lung tissues), mesothelioma (a cancer
of the lining covering the surface of the lung and inside the chest wall) and lung cancer. The symptoms of
these incurable diseases can take up to several years to appear after the first exposure to asbestos dust.
All types of asbestos can be dangerous if disturbed. The danger arises when asbestos fibers become
airborne. They form a very fine dust which is often invisible. Breathing asbestos dust can cause serious
damage to the lungs and cancer. There is no known cure for asbestos-related disease. The more asbestos
dust inhaled, the greater its risk to ones health. Therefore, precautions should always be taken to prevent
exposure or where this is not practicable, to keep it to a minimum.
The greater the fiber release, the greater the risk to health it will generate and the higher the standard of
precautions required when working with that material. Contractors should take all practicable safety
precautions during the three main phases of asbestos removal work, namely when preparing the site,
removing the asbestos and cleaning-up of the site after removal.
In view their health risks, care must be taken when removing, dismantling, demolishing, renovating,
maintaining and altering structures in buildings containing asbestos. Contractors should take all practicable
safety precautions during and when undertaking work involving asbestos. Asbestos removal work should be
carried out and supervised by contractor with the supervision of an Occupational Health and Safety
Specialist or Environmental Specialist of standing experience .
Removal of Asbestos water pipes in Las Anood hospital
It is suggested that, the removal of asbestos water pipes be undertaken as follows:
Preparation at removal site
As part of the preparation for the exercise of removing asbestos, the following have to be undertaken:
a. Notify the hospital staff about the plan to remove and dispose asbestos. It is important all hospital
staff and patients should be made aware of it and be alerted of the plan to dispose the asbestos
pipes;
b. Map out or establish asbestos work area in which, risks of exposure to asbestos fibers once
disturbed in the removal process are feared could reach. Being a hospital set up and aware of space
constraints in the hospital it is a safe zone of 15m from either side from the pipes is to be observed;
c. The site should be secured with galvanized corrugated iron sheets all around with one entrance that
should not face the areas the public frequents;
a. Post notices on the secured site Hazardous Dangerous Waste, keep off. The warning signs posted
in the work area both in English and Somali languages until the work site has been cleaned up and
is certified free of any asbestos materials by a qualified Supervisor/Occupational Health and Safety
Specialist or approved person with expertise;
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d. All workers who will be involved in the removal of the asbestos should be briefed on the nature of
work they are to be involved in, requirements in terms of dressing and general conduct of those
working on the assignment;
b. At the same time the site for disposal of the pipes be secured with CGI and excavation works could
be mounted as well. The pit for the disposal of asbestos pipes has to be excavated measuring
2x3x6m. The wall of the pit will be built of concrete blocks and cemented up to 2m height from
bottom. The remaining 1m height should be topped by soil up ground level. The size of the pit will be
set up depending on the sizes of the asbestos to be excavated;
e. For safety purposes, those sections of the hospitals should be rendered inaccessible for two weeks
to allow removal works and the area to settle after;
c. Shut down any ventilation and door in the nearby buildings close asbestos work area. All the
buildings close by should be vacated for 2 weeks during the removal of the asbestos water pipes;
d. Set up proper and specific changing and washing facilities for the workers within the enclosed site;
Figure 10: Typical barrier sign excluding asbestos removal area
Figure 11: Additional warning sign on health risks from asbestos

During and after asbestos removal
a. Before and during asbestos removal, use low-pressure water sprays to wet all asbestos pipes once they
are exposed during excavations;
b. Immediately wrap up the removed asbestos pipes in impermeable polyethylene sheets while they are
wet. It is best if the sheets are wrapped in a second layer of polyethylene sheets of 1,500g so that, there
is little risk of asbestos debris or dust spillage. The wrapped asbestos waste must be affixed with proper
warning labels;
c. Wet and collect all broken pieces of asbestos pipe debris in suitable impermeable disposal bags with a
double lining. Do not leave them lying around in the work site where they may be further broken or
crushed, thus creating more asbestos dust. These bags should also be properly sealed and affixed with
proper warning labels;
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d. Break up asbestos pipes that are long to fit into the disposal bags and cannot be wrapped properly. This
should be done within the enclosed space work area. Keep the pipes wet throughout the breaking
process and put all in a polythene seals;
e. The breaking/cutting of asbestos be done on a clean canvass sheet which will be wrapped up and
buried alongside asbestos ppies;
f. After a days removal and wrapping of the removed asbestos pipes together with a pack and seal used
coveralls in impermeable bags, which are also affixed with proper labels, at the end of each work shift
and dispose of together with the asbestos waste for the day; and
g. Once dropped in the pit, the asbestos waste will be covered with 10cm of cement concrete.
Figure 12: Sample PPEs worn by an asbestos worker

End of the asbestos removal job
a. All the equipment used in the days removal works, all the equipment and canvass for cutting or breaking
pipes will be buried in the disposal pit alongside the pipes so removed that day;
b. If more pipes remain, they will be removed on subsequent day through the same process as above;
c. Caution must be borne in mind in that, there should be no overfilling of bags and that, and care should
be taken to ensure sharp edges of asbestos do not puncture the plastic bags. Only new bags and
heavy-duty 200m (minimum thickness) polythene sheeting should be used.
d. The polythene sheeting should be of a height of at least 1.5m and completely wrapping the pipesed.
The pack is then sealed with adhesive tape. Packages should be small enough to be handled easily.
The packages are then clearly labelled with the asbestos warning mark. The height of this marking
should be approximately 75 mm x 90 mm.
e. The underground water tank area is to be sealed off to keep away access to it and should be cleared
labelled with warning signs. The fence should be of chain link of 1.25m high all around the tank area.
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Wrapping of asbestos materials after removal

Secretariat
Bag with broken asbestos materials
Figure 13: Possible wrapping of asbestos pipes and sheets after removal
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Page 29 of 42
7.2.
Appendix 2: Environmental and Social Management Plan

Mitigation
Measures
No.
Environmental/Social Issue
A.
a.
Construction phase impacts

Potential disruption in delivery of Contractor to
hospital services
prepare
and
agree
with
hospital
management
schedule
of
works;
Shifting
equipment and
services
to
some available
room;
b.
c.
Management of asbestos waste
Safety
of
the
construction works
public
from
Appropriate
notices in both
in English and
Somali pinned
up in strategic
places
regarding
shifted rooms.
Plan for safe
removal,
handling
and
disposal
of
asbestos
detailed in the
Appendix 01.
Hoarding and
sealing of the
work areas;
Contractor
schedule
place;
Plan
shifting
agreed;
Monitoring
Indicators
in
Agency
Responsible for
Monitoring
Contractor and
Hospitals
management
Records
Inspections.
Monitoring
Activities to be
undertaken
Frequency
Monitoring
of
Continuous
Embedded
in
contract for works
sums.
Embedded
in
contract for works
sums.
Within one month
Embedded
in
contract for works
sums.
Embedded
in
contract for works
sums.
Continuous
Embedded
in
contract for works
sums.
Embedded
in
contract for works
sums.
Continuous
Embedded
Embedded
Unit Cost
for
Notices
directing
patients
in
local Somali
and English in
place.
Asbestos
pipes
excavated,
sealed
and
appropriately
buried as in
Appendix 01.
Work
site
hoarded and
with signs in
place.
Contractor,
MoH and SDF.
Records
Inspections
Contractor,
MoH
Records
Inspections
Speed limits for

construction
fleet;
d.
OSH of workers
Signs guiding
the public in
place.
Provide PPEs
PPEs
Contractor,
Records
in
in

Hospitals, MoH
No.
e.
Mitigation
Measures
purchased
PPEs worn by
workers
Traffic accidents

Secretariat
Speed
set; and
limits
Use of traffic
guides.
Speed limits
furniture
in
place
(25km/h)
Monitoring
Indicators
Supervising
Engineer
SDF
Project
Manager
Contractor,
Supervising
Engineer,
Agency
Responsible for
Monitoring
Monitoring
Activities to be
undertaken
of
contract for works

sums.
Unit Cost
contract for works
sums.
Continuous
Embedded
in
contract for works
sums.
Embedded
in
contract for works
sums.
Inspections
Records
Frequency
Monitoring
Inspections
SDF
Project
Manager
f.
Management of construction waste
g.
Dust nuisance
h.
Potential loss of trees
i.
Security management
Routine
removal
of
construction
and demolition
debris; and
Dumper trucks
to
have
tarpaulins
to
cover
the
rubble.
Hoarding of the
sites;
Sprinkling
of
water
on
access routes
in the hospitals.
Deliberate
planting
of
Neem trees 20
per hospital;
Caging
the
trees
Construction of
standard
security gates
as
per
Somaliland
practices
Rubble readily Contractor,

Records
and routinely
transported
Supervising
Inspections
outside
the Engineer
site; and
SDF
Project
Dumper trucks Manager
with tarpaulins
on.
Continuous
Embedded
in
contract for works
sums.
Embedded
in
contract for works
sums.
Sites hoarded
Schedule for
water
sprinkling
in
place.
Contractor,
Records
Supervising
Engineer
Inspections
SDF Project
Manager.
Continuous
Embedded
in
contract for works
sums.
Embedded
in
contract for works
sums.
No. of trees
planted
and
caged
Contractor,
Records
Continuous
Supervising
Engineer
SDF
Project
Manager.
Contractor,
Supervising
Engineer,
SDF
Project
Manager.
Inspections
Embedded
in
contract for works
sums.
Embedded
in
contract for works
sums.
Continuous
Embedded
in
overall budget of the
project
Embedded
in
contract for works
sums.
MoH will guide

on
policy
Modalities for MoH

disposal
of
Annual
Operational costs by
hospitals.
Operational costs
by hospitals.
Designs
of
security gates
in place;
Security gates
in place
Records
Inspections
Operational phase impacts

B.
a.
Accumulation
equipment
of
obsolete
Records
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Hospitals, MoH
No.
b.
c.
d.
e.
Improper management of medical

waste
Management of human anatomical

waste
Air pollution
Potential fire risks
direction
regarding
disposal
of
such to scrap
metal dealers.
Incinerator in
Erigavo to be
repaired and in
Las Anood a
new one is to
be constructed;
Incinerator ash
pit
to
be
constructed;
Other
waste
management
bins in place
Incineration,
burial
by
families
and
placentas to be
disposed
in
placenta pits.
Fully functional
waste
management
system to be
instituted;
Ensure waste
disposal is by
incineration
and
there
should
adequate fuels
for incinerators
operations.
Fire
fighting
equipment
in
place such as
extinguishers,
water
pipes
reels; and
Buildings
to
have adequate
and standard

Secretariat
Mitigation
Measures
obsolete
equipment
place.
Monitoring
Indicators
Agency
Responsible for
Monitoring
Monitoring
Activities to be
undertaken
Frequency
Monitoring
of
Site inspections
Continuous
hospitals.
Operational costs
by hospitals.
Site
inspections
Records
Continuous
hospitals.
Operational costs
by hospitals.
Site
inspections
Records
Continuous
hospitals.
Operational costs
by hospitals.
Continuous
hospitals.
Operational costs
by hospitals.
Unit Cost
in
Waste
MoH
management
equipment
and facilities in
place.
Incinerators in
place and
operational
MoH
Placenta pits
in place.
Waste
MoH
management
equipment
and facilities in
place.
Fire
fighting MoH
equipment
in
place
Records
Inspections
Buildings
designs
with
provisions for
fire
escape
routes.
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Mitigation
Measures
Monitoring
Indicators
Agency
Responsible for
Monitoring
Monitoring
Activities to be
undertaken
Frequency
Monitoring
of
Unit Cost
escape routes.
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7.3.
Appendix 3: WHO medical waste coding
Type of waste
Household refuse
Sharps
Waste description
Black
Recommended types of containers

Plastic bag
Sharps container
Yellow with this sign

Waste entailing
contamination
risk
of
Plastic bag or container

Anatomical waste
Infectious waste

Yellow with marking highly
infectious and with symbol
Chemical and pharmaceutical

waste
Brown, marked with a suitable

symbols labelling of chemicals
(Source: UNEP, 2005)
Plastic bag or container that can be

autoclaved

Hospitals, MoH
7.4.

Secretariat
Appendix 4:
Environmental and Social Screening
Datasheet ( Adapted from SDF ESAF 2014 )
Geographical Location: Sool and Sanaag regions of Eastern Somaliland

Project Name: Rehabilitation of Las Anood and Erigavo Hospitals in Sool and Sanaag Regions in Eastern
Somaliland
Program Location: The two hospitals are located within the Municipalities settings of Las Anood and
Erigavo in the regional headquarters of the two regions of Sool and Sanaag respectively.
Environmental Issues: The project areas present no major environmental and social issues since the
facilities are existing and operational. The planned rehabilitations works will involve demolitions and
rebuilding of hospital facilities and re-equipping of the hospitals. The hospitals operations are hampered by
staffing, and equipment. There are however issues of medical waste management arising from a
combination of inadequate and non-functional facilities in the establishments which makes management of
hospitals to sometimes resort to non-conventional means such as open burning of waste.
However, in Las Anood hospital, its underground water pipes for rainwater harvesting are asbestos and
measures have been planned to excavate, seal them and burry in a cemented pit and cover them with 10cm
of concrete.
Proposed Actions: The project plans to invest in putting in place modern incinerators and, acquiring waste
management.
Justification/Rationale for Environmental Category: the project impacts will be small-scale, localized and
of short-term nature and can be managed by implementing mitigation measures outlined in the ESIA and its
ESMP.
Reporting Schedule: the project reporting schedule will be part of the overall project reporting framework
i.e. monthly environmental and social compliance of the project will form part of the overall monthly project
reporting.
Remarks: The preparation of the ESIA was done consultatively involving meetings with regional medical
officers, senior management of MoH, hospitals management staff, workers and sections of the communities.
SUBPROJECT DESCRIPTION
Description of the project and its major components:
Both hospital buildings are old but in fair shape. A number of buildings have their foundations and walls being
structurally sound throughout, but water and sanitation needs attention. Major equipment is largely in
available but often out-dated, though much minor equipment and furniture is missing. The initial building
assessment was done in October 2014, and noted that the buildings were in relatively good condition, but
that site works required attention, particularly in Las Anood. Building repairs have been listed; drawings and
bills of quantities are being finalized. Site works for water, sanitation, waste management and electricity are
considerable, and require further detailed assessment and design by experts. In all, the rehabilitation will
focus on structural repairs, reconstructions of some facilities and paintings.
1.
SUBPROJECT DESCRIPTION
Description of the project and its major components
The project will largely involve demolitions, excavations, re-building, equipping and painting of some units in
the hospitals. There will be provision of water supply and removal of asbestos water pipes in Las Anood
hospital. The hospitals will each benefit from receive some new buildings to constructed within the hospital
premises either on the very spots where there dilapidated structures or, on new spots within the
establishment.
2.
SUBPROJECT LOCATION
2.1 Site information: The projects are within the Municipalities of Erigavo and Las Anood in Eastern
Regions of Sanaag and Sool respectively.
Name of locality
Erigavo Hospital in Sanaag region and Las Anod Hospital, Sool
Region
Community:
The hospitals are within the municipalities
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Present use and development

Surrounding uses/zoning
Access
Public Services

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The areas are mainly settlements and business areas.

North:
South:
East:
West: mix of residential and commercial settlements
Name of roadway if direct access, description of easement from
public or private roadway
Water Supply: name of district, or if private, note "private onsite
well" or "shared well"
Sewage: name of district or "septic system"
Other: e.g. school, health clinic
3.
POTENTIALLY SIGNIFICANT ENVIRONMENTAL OR SOCIAL IMPACTS
The following checklist indicates the potential level of impact and is abbreviated as follows:
S
S/M
Significant impacts
Potentially significant impacts but mitigated to less than significant levels.
NS
No significant impacts
3.1
GEOLOGIC PROCESSES
Will the project result in:
Exposure to or production of unstable earth conditions such as landslides, soil
creep, mudslides, ground failure (including expansive, compressible, collapsible
a. soils)
Disruptions, displacements, compaction or over covering of the soil by cuts, fills, or
b. grading?
c. Permanent changes in topography?
The destruction, covering or modification of any unique geologic or physical
d. features?
S/M
NS
X
X
X
X
X
e. Any increase in wind or water erosion of soils, either on or off the site?
Changes in deposition, or erosion or siltation that may modify the channel of a river,
f. or stream, or any water body?
The placement of septic disposal systems in impermeable soils with severe
g. constraints to disposal of liquid effluent?
h. Excessive grading on slopes of over 20%?
i. Sand or gravel removal or loss of topsoil?
Vibrations, from short-term construction or long-term operation, which may affect
j. adjoining areas?
k. Excessive spoils, tailings or over-burden?
X
X
X
X
X
X
Impact discussion: Erosion will likely arise through demolition works in which, loose materials and debris
will be generated and if not well managed, they can be blown away by wind. There will also be excavation for
foundation works for new buildings and the process is likely to generate loose soils that can be eroded if not
properly protected.
Mitigation measures: The contractor will hoard off work sites and loose soils will be sprinkled with water to
reduce friability. Workers will be provided with PPEs for their protection while working on excavations etc.
Trucks transporting construction debris to have tarpaulins to control wind blowing off the loose materials.
3.2 WATER RESOURCES/FLOODING
a.
Changes in the course or direction of water movements?
Changes in percolation rates, drainage patterns or the rate and amount of surface
b.
water runoff?
S/M
NS
X
X
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c.
d.
e.
f.
g.
h.
i.
j.
k.

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Change in the amount of surface water in any water body?

Discharge into surface waters, or alteration of surface water quality, including but
not limited to temperature, dissolved oxygen, turbidity, solids?
Alterations to the course or flow of flood waters, or need for private or public flood
control projects
Exposure of people or property to water related hazards such as flooding, or
accelerated runoff
Alteration of the direction or rate of flow of groundwater?
Change in the quantity of ground waters, either through direct additions or
withdrawals?
Overdraft of any groundwater basin? Or, an increase in the existing overdraft of any
groundwater basin?
The substantial degradation of groundwater quality
Substantial reduction in the amount of water otherwise available for public water
supplies?
X
X
X
X
X
X
X
X
X
Impact discussion: No ground water changes are envisaged because in Las Anood hospital where a
production well is to sunk, detailed assessments will be done to establish baseline information on the
availability and the quality of the water. This will eliminate any possibilities of compromising underground
water quality and quantity in the areas.
Mitigation measures: the water works will be for the needs of the hospital not the wider municipalities
hence, the impacts will of low scale, localized and short-term in nature.
3.3 TRANSPORTATION/CIRCULATION
Generation of substantial additional vehicular movement (daily, peak-hour, etc.) in
a. relation to existing traffic load and capacity of the street system?
b. A need for private or public road maintenance, or need for new road(s)?
c. Effects on existing parking facilities, or demand for new parking?
Substantial impact on alteration of present patterns of circulation or movement of
d. people and/or goods?
Increase in traffic hazards to motor vehicles, bicyclists or pedestrians (including
e. short- term construction and long-term operational)?
S/M
X
NS
X
X
X
X
Impact discussion: There will be entry and exist of heavy trucks mainly dumper trucks ferrying construction
materials as well as construction debris out of the sites to dump areas. These operations will to some extent,
impact on the parking in the hospitals and traffic flow especially with heavy trucks.
Mitigation measures: This will be a short-term negative impact during the construction period and will be
mitigated through instructing drivers to observe speed limits of 25km/h inside the hospital establishments.
There should be guides/flag persons to
3.4 AIR QUALITY
The generation of air pollutants, a contribution to an existing or projected air quality
a. violation or exposure of sensitive receptors to substantial pollutant?
b. The creation of smoke, ash or odors?
c. Dust generation?
S/M
NS
X
X
X
Impact discussion: there will smoke arising from incineration operations and also from demolition of
structures. The burning of medical waste will equally generate the odors and if the waste is not timely
disposed in appropriate manner; there will be odors as well. Once the hospitals are rehabilitated and are fully
operational, its various operations will generate waste that will be a nuisance if not timely and routinely
removed.
Mitigation measures: The project will rebuild state of art incinerators, provide for autoclaves and waste
collection bins for given category of medical waste which will address these impacts.
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3.5
BIOLOGICAL RESOURCES
FLORA
a. Removal or disturbance of natural vegetation?
S/M
NS
X
X
b. A loss or disturbance to a unique, rare or threatened plant community?

A reduction in the numbers or restriction in the range of any unique, rare or
c. threatened species of plants?
A reduction in the extent, diversity, or quality of native vegetation (including bush
d. removal for fire prevention and flood control improvements)?
Introduction of herbicides, pesticides, or other factors that would change or hamper
e. the existing habitat?
FAUNA
f. A reduction in the diversity or numbers of animals onsite?
g. A deterioration of existing fish or wildlife habitat?
X
X
X
X
X
X
h. Introduction of barriers to movement of any resident or migratory wildlife species?.

X
i.
Introduction of any factors (light, fencing, noise, human presence and/or domestic
animals) that could hinder the normal activities of wildlife
Existing plant and animal communities/conditions: There plant and animal communities in the project
areas comprise lawn plants and shade/ornamental trees in the compounds of the hospitals. There are wild
animals or species of conservation concern in the areas. Occasional visitor birds are encountered in the
project areas.
Impact discussion: Since the hospitals plant and animal communities are not rare or threatened from a
conservation perspective, there will be no impacts on these resources arising from planned rehabilitation and
reconstruction works.
Mitigation measures: The mitigation measures will include thorough clearing of the site off all construction
debris and landscaping to allow for vegetation regeneration and greening of the sites.
3.6
ARCHAEOLOGICAL/CULTURAL RESOURCES
Disruption, alteration, destruction, or adverse effect on a recorded historic or
a. archaeological site?
b. Disruption or removal of human remains?
c.
d.
S/M
NS
X
X
X
Increased potential for vandalizing, or sabotaging archaeological resources?

Ground disturbances in an area with potential cultural resource sensitivity based on
the location of known historic sites?
Impact discussion: The hospitals for rehabilitation are existing, there will be no alteration, destruction or
removal of any materials of archaeological importance.
Mitigation measures: Mitigation measures are not envisaged to be necessary because there is no impact
on the archaeological resources.
3.7
HISTORIC AND CULTURAL RESOURCES
Adverse physical or aesthetic impacts on a structure or property at least 50 years
a. old and/or of historic or cultural significance to the community?
Beneficial impacts to a historic resource by providing rehabilitation, protection,
b. conservation, etc.?
S/M
NS
X
X
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Impact discussion: There will be impacts on histo-cultural resources because the hospital structures to be
renovated are existing.
Mitigation measures: No impacts envisaged.
3.8
LAND USE
a. Structures and/or land use incompatible with existing land use?
b. The induction of substantial growth or concentration of population?
The extension of sewer trunk lines or access roads with capacity to serve new
c. development beyond this proposed project?.
d. The conversion of prime agricultural land to non-agricultural?
e. The loss of open space?
f. An economic or social effect that would result in a physical change?
S/M
NS
X
X
X
X
X
X
Impact discussion: The project little land use issues as all works will involve rehabilitation of existing
buildings, rebuilding and paintings works more so, the house structures to be built are of similar heights with
the existing ones. However, some new structures will built in the compound of the existing hospitals thereby
taking up some of the available open spaces.
Mitigation measures: Clearing and cleaning up areas where debris are collected after works. To ensure the
project does not take up all available green areas, infrastructures will be planned bearing in mind he need to
have green belts in the compounds of hospitals.
3.9 PUBLIC FACILITIES
General services:
a. A need for new health care services?
b. Student generation exceeding school capacity and/or facilities?
c. Additional amounts of solid waste and wastewater generation?
d. A need for new or altered sewer system facilities (sewer lines, lift-stations, etc.)?
S/M
NS
X
X
X
X
Impact discussion: There will be no relocations of people hence, no impact on public services such as
water supply, medical services, schools and others. However, during construction there will be construction
waste from demolition works. When fully reconstructed, the hospitals operations will generate increased
amounts of medical waste through increased numbers of patients.
Mitigation measures: The contractors will routinely remove the construction debris and dispose it to
designated sites approved by the supervising engineer. For medical waste, there are plans to put in place
new incinerators, placenta pits and incinerator ash pits alongside training workers on medical waste handling
and disposal.
3.10
ENERGY
Substantial increase in demand, especially during peak periods, upon existing
a. sources of energy?
b. Requirement for the development or extension of sources of energy?
S/M
NS
X
X
Impact discussion: The project works will be driven either manually or by use of electricity already
connected to the hospitals and sometimes, the contractors will have their own generators to drive welding
and associated metals works.
Mitigation measures: The project will not have impacts on energy supply hence, no need for additional
power supply source(s).
3.11
HOUSING
a. Loss of existing dwellings through demolition, conversion, or removal?
b. Displacement of current residents?
S/M
X
X
NS
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Impact discussion: The rehabilitation works will cause demolition, conversions and rebuilding of some
buildings in the hospitals and that will call for relocation and movement of equipment from one place to the
other. That process will affect the functions and delivery of health services.
Mitigation measures: This will be mitigated through contractors working out their work schedules and
discussing them with the hospital management so that, they will plan relocation and transfer of equipment for
smooth delivery of medical services.
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7.5.
Appendix 05: Anticipated

Erigavo Hospital
Building Name
Physiotherapy
Male medical ward
Unfinished
laboratory
building
UNICEF EPI Store
Old tore
Kitchen
Old laboratory
Female medical ward
Laundry
Maternity ward
OT
Paediatric ward
Male surgical ward
X-Ray building
OPD
Consultation
and
Administration Block
Mechanical workshop
Sanaag
Health
Directorate Office

Secretariat
rehabilitation
works
in
Scope of Work
Closing of the cracks and painting for aesthetic look.
Rehabilitations works are repair of frame, replacement of glass boxes,
and installation of new sanitary facilities.
The construction activity is to complete the building with CGI roof,
windows, doors, sanitary fittings and a new veranda.
Steel doors and windows are in a good shape and will need only minor
fixings/ glazing and mosquito nets
Windows and doors are in a good shape but will need mosquito nets.
Major rehabilitation works for this building are painting of the walls,
maintenance and repair of windows and doors.
Major activities are painting, construction of new floor slab, repair of
windows and doors, installation of new ceiling, floor finishing/tiles.
Major rehabilitation activities are wall painting, repair of wooden doors
and windows, repair metal doors, laying new floor tiles, installation of 3
sanitary facilities.
Major activities are demolishing of old small building and constructing a
new one at identified location in the drawing. Dimension of the new
building is specified in the working drawings.
Major activities are to demolish cracked wall section and reconstruct
new wall, remove the corrugated iron sheet roof and install new one,
replace ceiling board, fixing and repair wooden doors and windows,
repair metal doors, laying floor tiles, and install new 6 sanitary facilities.
Major activities are to repair cracks in the walls, repair wooden windows
and doors, steel doors and painting.
The wall facing the OT has a series of cracks. This portion of the wall
should be demolished and rebuilt connecting it with existing walls with a
ReBar every 500 mm. Washbasins with water supply and drainage is
necessary both in the ward and nurses room. Other construction
activities are to demolish the toilets and reconstruction of new ones as
indicated in the working drawing, repair of cracked walls, painting, repair
of wooden windows and doors, ceiling and sanitary facilities.
The construction is still structurally sound and does not need any major
rehabilitation work. Washbasins with water supply and drainage is
necessary both in the ward and nurses room. Repair activities are to
maintain wooden windows and doors, and sanitary facilities
Major construction activities are to replace the whole roof system, repair
cracked walls..
Major construction activities are some changes with original plan of the
building and increase number of consultation rooms, demolish the walls
with major cracks and reconstruct..
Major construction activities are that many cracks show substantial
structural problems that would require a full rehabilitation.
Demolish cracked walls and reconstruct new wall, replace the roof,
install new ceiling, repair wooden window frame, repair doors, plastering
painting and sanitary.
Construction are to demolish old ministry of health regional directory and
construct a new one with 8 office rooms and toilet will be constructed
(Source: Engineers BoQs for Works, SDF 2015)
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7.6. Appendix 06: Project rehabilitation works for Las Anood

Hospital
Building Name
Asbestos water pipes
Store/Reverse osmosis
Morgue/mortuary
Pediatric ward
Physiotherapy
Maternity
Women washroom
Women ward
Laboratory & store
New OT
Health
Regional
Directorate
OPD & New Admission
New H. Administration
Old H. Administration
Old OT
Kitchen
Generator room
Meeting room
Mental health
Mens ward
Mens toilet
Incinerator
Service Block
Scope of Work
Disposal of asbestos pipes avoiding future manipulation, its advisable to
dispose them inside new directorate building site but not under the building
site, and the disposable landfill will be approved by construction supervisor.
Specification of landfill will be indicated in the Bill of quantity
Store is not currently used; SDF plans to use for reverse water treatment
room.
Demolish the existing for door, supply and fix steel casement with opening
accessories, steel hinges, iron mongery and burglar proof for steel
windows, install door, floor tiles, wall tiles and finally painting of walls
Construction of new morgue/mortuary facility with worktop for dead bodies,
floor tiles, painting and sanitary facilities and fitting with electricity
connections and chilling system.
Rehabilitation of pediatric ward installation of ring beam and new roof
system, ceiling, painting, install new doors, windows, repair old wooden
doors and windows, maintain aluminum windows, install gutter for rain.
Construction of new wash room
Repair doors and windows, repair both metal and wooden frame of doors
and windows, remove old floor screed and construct new floor screed,
sanitary facility, and wall tiles
Rehabilitation of maternity building, painting, repairing and maintenance of
louvered windows, doors, wooden frame windows, metallic doors and
window, provide new gutter with ditto, and sanitary facilities
Demolish the old women toilet and construct new wash room which bigger
and better capacity.
Replacement of corrugated iron sheet including veranda and false ceilings
for women ward.
New ceiling board, paining, maintenance of doors and windows, floor
screed, floor tiles, and roof tiles, and sanitary facility.
Modification of OT building layout , or extension of this building, ceiling,
replacement of windows doors, sanitary facilities.
Construction of new regional Health directorate outside the hospital
premises.
Extension and rehabilitation of the building, installation of new roof system,
repair windows and doors, maintenance of wooden and metallic frames.
This is a new building, which is constructed recently, SDF only provides
water harvesting system Gutter
Provide gutter, repair window frames, door frames, painting, and sanitary
system
Painting, replacement of doors and windows, gutter and sanitary facilities.
Extension of kitchen and rehabilitation painting, repair of windows, doors,
and sanitary system
Construct a new generator room.
Supply water harvesting system
Supply water harvesting system
Installation of new roof, repair windows, maintain door frames, etc
SDF will construct new complete toilet larger than previous.
Demolish old incinerator and construct new include incinerator ash pit.
Construction of new service blocks size of 30mx8m.
(Source: Engineers BoQs for Works, SDF 2015)
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SDF Secretariat

Masala Area, Next to Mercy Corps Guest House

ESIA for Rehabilitation of

Nelson Omagor: Short Term

ESIA for Rehabilitation of Las Anod and Erigavo

Somaliland Development Fund

Issue and revision record

ESIA for Rehabilitation of Las Anod and Erigavo

Somaliland Development Fund

Chapter title Page

POLICY, LEGAL AND INSTITUTIONAL FRAMEWORK 12

National Environment Policy, 2011

The National Development Plan 2011-2016

The Somaliland Vision 2030

The Constitution of the Republic of Somaliland, 2010

Environment Conservation Act and Proclamation, 1998 12

Somaliland Health Regulatory Act 19/2001

The Ministry of Health

Ministry of Environment and Rural Development 13

Somaliland Development Fund 13

Community Health Board

BASELINE ENVIRONMENT AND SOCIAL SETTINGS

High mortality rates

High regional risky deliveries

Common diseases in Sool and Sanaag regions 15

Status of hospital infrastructure 15

ESIA for Rehabilitation of Las Anod and Erigavo

Somaliland Development Fund

Dilapidated old hospital infrastructures

Existence of some hazardous infrastructures

Improper medical waste management

Inappropriate location of some infrastructures

ENVIRONMENTAL SCREENING AND STUDY OF THE SUB-PROJECTS

Environmental Study Approach 18

ESAF screening and categorization of the two hospital sub-projects

Approach in the preparation of the ESIA for the hospitals sub-projects

Briefing meeting by SDF Programme Team Leader

Consultative meetings in the project areas

Impacts during works

Negative impacts during hospitals operations

Proposed BoQs Items

Conclusion and Recommendations

Appendix 2: Environmental and Social Management Plan

Appendix 3: WHO medical waste coding 32

Appendix 05: Anticipated rehabilitation works in Erigavo Hospital 39

Appendix 06: Project rehabilitation works for Las Anood Hospital 40

ESIA for Rehabilitation of Las Anod and Erigavo

Somaliland Development Fund

Community Health Workers

Department for International Development

Environmental and Social Assessment

Environmental and Social Assessment Framework

Environmental and Social Impact Assessment

Female Genital Mutilation

Great Britain Pound

Intensive Care Unit

International Financial Institutions

Hargeisa Group Hospital

Health Management Information System

Health Sector Strategic Plan

Maternal Child Health Centre

Multiple Indicator Cluster Survey

National Development Plan

National Technical Committee