USAID GLOBAL HEAL TH SUPPLY CHAIN PRO GRAM PROCUREMENT AND SUPPLY MANAGEMENT

EN.VIRONMENTAL COMPLIANCE FRAMEWORK ENVIRONMENTAL MITIGATION AND MONITORING PLAN (EMMP)

FROM THE AMEl\ICAN PEOPLE U.S P1 c~idcnt'.s Malaria l11i1i,1t1vc:

ENVIRONMENTAL COMPLIANCE FRAMEWORK ENVIRONMENTAL MITIGATION AND MONITORING PLAN (EMMP)

USAID Contract No. AID-OAA-1-15-00004, GHSC-PSM Reference Number Task Orders 1,2,3,4 Authors: Scott Ackerson, Shelby Hockaday, Rebecca Logan, Casey Murphy, Joseph Paquette, Lauren Paragglo, and Viktor Raykin

ENVIRONMENTAL COMPLIANCE FRAMEWORK GHSC·PSM: ENVIRONMENTAL MITIGATION AND MONITORING PLAN (EMMP) I I

CONTENTS

I. GHSC-PSM ENVIRONMENT COMPLIANCE FRAMEWORK INTRODUCTION ........................................ 3

I. I PROJECT DESCRIPTION ......................................................................................................................................... 3

2. ENVIRONMENTAL & MITIGATION AND MONITORING PLAN (EMMP) ................................................. ..4

2.1 PART I: ENVIRONMENTAL SCREENING FORM: ........................................................................................... 4

GLOBAL HEAL TH SUPPLY CHAIN - PROCUREMENT AND SUPPLY MANAGEMENT (GHSC-PSM)4

Indicate which activities your organization Is Implementing . ............................................................................. 5

Description of activities: ............................................................................... , .............................................................. 6

2.2 PART 2: Environmental Mitigation and Monitoring Plan Global Health Supply Chain-Procurement and Supply Management (GHSC-PSM) ........................................................................................................... ............. ............. 7

ENVIRONMENTAL COMPLIANCE FRAMEWORK APPROVAL.. .................................................................. 29

2.3 PART 3: Environmental Mitigation and Monitoring Report Global Health Supply Chain-Procurement and Supply Management (GHSC-PSM) ............................................................................................ 30

ACRONYMS

BEO CFR COR EA EMMP EU GH GHSC-PSM

IEE IP LDC LLINS MEO MSDS PE PF AR PMI PPE PQM PSM QA QC RDC REA SBCC SCMS SIAPS SIEE SOP SoW TO USAID US EPA USG WHO WMP WO

Bureau Environmental Officer(s) Code of Federal Regulations Contract Officer Representative Environmental Assessment Environmental Mitigation and Monitoring Plan Europe Union Global Health Global Health Supply Chain - Procurement and Supply Management Initial Environmental Examination lmplementlng Partner Local Distribution Center Long-lasting Treated Nets Mission Environmental Officer Materials Safety Data Sheet President's Emergency Plan for AID's Rcllef Presidential Malaria Initiative Personal Protective Equipment Promoting the Quality of Medicines Procurement and Supply Management Quality Assurance Quality Control Regional Distribution Center Regional Envlronmental Advisor Social and Behavior Change Communication Supply Chain Management System System for Improved Access to Pharmaceuticals Supplemental IEE Standard Operating Procedure Scope of Work Task Order United States Agency of International Development United State Environmental Protection Agency United States Government World Health Organization Waste Management Plan Work Order

ENVIRONMENTAL COMPLIANCE FRAMEWORK GHSC-PSM: ENVIRONMENTAL MITIGATION AND MONITORING PLAN (EMMP) I ii

I . GHSC-PSM ENVIRONMENT COMPLIANCE FRAMEWORK INTRODUCTIO N

I. I PROJECT DESCRIPTION

Successful implementat ion of USAID's Global Heal th (GH) Sector programs depends considerably on the consistent supply of quality health commodities, as well as supply chain assistance to health systems that manage these commodities. An uninterrupted supply of heaidl products to health facilities and patients worldwide is extremely challenging to achieve for various reasons, such as the difficulty of excluding ineffective and substandard medications Into the supply chain. Further, highly specialized procurement and logistics expertise Is required to oversee and manage the delivery, storage, distribution, and disposal of health commodities.

For these reasons, GH's portfolio includes programs focused on providing an uninterrupted supply of quality­assured health products to health facllities and patients worldwide. These products include, among others, a wide variety of pharmaceuticals, vaccines, nutritional supplements, contraceptives products, consumable medical supplies, test kits, laboratory supplies, and medical and laboratory equipment.

USAID has reorganized Its commodity supply chain program framework Into the new Global Health Supply Chain (GHSC) Program to achieve t he following:

• Maintaining continuity of operations to ensure no interruption of supplies; • Ensuring technical and program soundness through a collaborative process; • Ensuring flexibility to meet different program (health element) requirements as well as future needs; • Minimizing management burden for activities In the field; • Promoting r isk mitigation by collaborative strategies in quantification/forecasting, market dynamics, and

freight forwarding/warehousing and delivery; • Incorporating the principles of the USAID Global Health Initiative, USAID Forward and Implementation

and Procurement Reform; and • Maintaining program oversight and accountability by the different health e lements as needed to meet

disease-speclflc requirements.

ENVIRONMENTAL COMPLIANCE FRAMEWORK GHSC-PSM: ENVIRONMENTAL MITIGATION AND MONITORING PLAN (EMMP) 3

2. ENVIRONMENTAL & MITIGATION AND MONITORING PLAN (EMMP)

2.1 PART I: ENVIRONMENTAL SCREENING FORM:

GLOBAL HEALTH SUPPLY CHAIN - PROCUREMENT AND SUPPLY MANAGEMENT (GHSC-PSM)

Project Name: Original IEE File #DCN:

Global Health Supply Chain - Procurement and Supply Management (GHSC-PSM) AID-OAA-1-15-00004/ GI:!· I Z-Q IQ Name of Prime Implementing Organization: Date of Screening

Chemonlcs International, Inc. March 14, 2017 Name of Sub-awardees Organizations (If this EMMT Is Funding Period for this award: for a sub)

None FY 2016- FY 2021 Geographic location of USAID-funded activities Current FY Resource Levels: (Country, Province, and/or District,)

Global I bllllon USO over S years

Currently active in: Angola, Botswana, Burkina Faso, Burma, Burundi, Cambodia, Cameroon, Caribbean, Central America, Ethiopia, Ghana, Guinea, Guyana, Haiti, Indonesia, Lesotho, Liberia, Madagascar, Malawi, Mall, Mozambique, Namibia. Nepal, Nigeria, Pakistan, ROMA, Rwanda, Senegal, South Sudan, Uganda, Vietnam, Zambia, and Zimbabwe This report was prepared by: Date of Previous EMMT for this organization (in any)

Scott Ackerson, Shelby Hockaday. Rebecca Logan, NIA Casey Murphy. Joseph Paquette, Lauren Paraggio, and Vlktor Raykin

Date: April 7, 2017

ENVIRONMENTAL COMPLIANCE FRAMEWORK GHSC-PSM: ENVIRONMENTAL MITIGATION AND MONITORING PLAN (EMMP)

"

Indicate which activities your organization is implement ing.

Key Elements of Prngram/Activitics Implemented Ye~ No

I Education, Technical Assistance, or Training x

Includes: strategic planning, data analysis, technical consultation, surveys, knowledge and information transfer, meetings, technical material development, outreach programs, and training services.

2 Research and Development x

Includes: health-related research and development activities aimed at advancing knowledge and technology, Including research and evaluation, monitoring and surveillance programs, pilot studies, case studies, and assessments.

3 Public Health Commodities x

Includes: procurement, storage, t ransportation, distribution, and disposal of public health commodities, including pharmaceuticals, nutritional supplements, chemicals (e.g., disinfectants, solvents, laboratory reagents, etc.), medical supplies, and family planning commodities (e.g., contraceptives, condoms, etc.).

4 Small-Scale Construction or Rehabilitation x

Includes: hospitals, clinics, laboratories, voluntary and counseling testing centers, or tralnlng centers. Total surface area of the disturbed environment is under I 0,000 square feet and less than $200,000 total cost.

s Small-Scale Water and Sanitation x

Includes: pond and spring improvements and Installation of hand-dug wells, Individual or community latrines, hand-washing stations, and small-scale septic and leach field systems.

6 Nutrition x

Includes: small-scale food production, procurement and distribution of supplements, preventing undernutritlon, providing nutritional care and support, and Improving nutritional outcomes in programs.

7 Vector Control x

Includes: procurement, distribution, or use of pesticide products such as insecticide-treated bcdnets, larviclding agents, and fumigants.

NO TE: USAID uses USEPA's definition of pesticides, which includes "any substance intended for: preventing, destroying, repelling, or mitigating any pest. This includes herbicides, fungicides, plant regulators, and desiccants."

ENVIRONMENTAL COMPUANCE FRAMEWORK GHSC-PSM: ENVIRONMENTAL MITIGATION AND MONITORING Pl.AN {EMMP) s

•

Emergency Response x 8

Includes: coordination with outside organizations and technical experts, deployment of • resources and response teams, and development of technlcal materials.

Description of activities:

GHSC-PSM will procure and manage a wide range of health commodities, supplies, and equipment essential for management of malaria, HIV/AIDs, family planning and maternal and child health. An inherent part of this support will require treatment and disposal of nonhazardous and hazardous materials, including unusable medical products and commodities.

GHSC-PSM also provides technical assistance, quality assurance, capacity building, and procurement support to strengthen all elements of host country health commodity supply chains, Including but not limited to, Improved strategic planning, strengthening In-country logistics, effective transfer of skills and knowledge, and strengthening the enabling policy and Institutional environment. Through marketing, advocacy, research, and innovation, the program strategically engages stakeholders for improved long-term supply of commodities (for additional Information on the project see section I} .

•

• ••

ENVIRONMENTAL COMPLIANCE FRAMEWORK GHSC·PSM: ENVIRONMENTAL MITIGATION AND MONITORING PLAN (EMMP) 6

2.2 PART 2: ENVIRONMENTAL MITIGATION AND MONITORING PLAN GLOBAL HEALTH SUPPLY CHAIN-PROCUREMENT AND SUPPLY MANAGEMENT (GHSC-PSM)

Category of

Actl'w tt't ''"Orr"

5ect1or 2 e ~f GHSC-~SM le!:

De:sc-i't·e ~~ec:fic eivvon"l"'t9'n[;d rhr-:-,)_b .: •

y().J~ "."•r~r17.)t:1:in·~

'?.C'tl"t":1~-< .~.);)::-::: :r

,r dt"·> 1n S::c.(10r1 2.5 .:;f

the GHSC-PSM IEE)

I. Education. T echhiol Assistance.Training

Intervention • Activities In this Category 2. category have Awareness negligible foreseeable building and direct adverse advocacy: impacts on the enabling environment. environment • However, activities strengthening aimed at increasing (e.g •. pollcy access to and use of advocacy) healthcare supplies

will rerult in increased generation of medical waste. the environmental threats of which are described under Category 3. Pubr" Healrh Commodities.

Intervention • Activities in this Category 4, category have Capacity negligible foreseeable building for direct impacts on the hos~-country environment. health supply • However. activities chains aimed at

strengthening host-country capacity and

Des·:r"·p~··:'"' of M1t ~at1on M-e.25un:.:) to· rr-:e~~

.)([1,,1:1~; 35 ··.:qu1r·:·:l r S:::-.::r Jr 2 6 ._:..! GHSC.t=S~

1::

I. Awareness and policy activities must address. wherever appropriate. healthcare waste

management at both local and national li:vels.

2. Training. supervision. and curricula development must be consistent with good waste management practices

I. All technical assistance to strengthen health commodity rupply chains must, wherever relev;int, address. advocate for and take all practicable efforts to assure that adequate facilities, procedures and c;ipacities are in place to properly manage expired. used. obsolete or surplus commodities and/or that plans and svareg)es incorporate and provide for such management. TA on healthcare waste

l/>Jh,) 1• •..;.-;,po..,:;:1J1 ..

:CH ·':'°",(_' •1rc1r ng·

Responsible: ActMty Designee. Healthcare Waste Manag!ment Specialist, Environmental Specialist

Approve: Country Director. &Jor Managing Director. or Unit Manager

Responsible: Country Director

Approve: Healthcare Waste Management Specialist.

f'-'lol"" :.v··"r~ I,.. .j1('."l:t.V•

I. Number and % of healthcare facilities and poftcy makers at both local and national levels provided with public awareness materials (i.e .. pamphlets ;nd/or posters) promoting good waste management pr;i.ctices for medical waste disposal

2. Number and % of trainings at both local and national revels addressing good waste management practices and number of staff tr2ined

I. Number and % of healthcare facilities and policy makers at both loal and national levels comp6:ant with good waste management practices

l. Number and% of trainings delivered that incorporated

Mcn1tor•ng M<:!:.,,~,:j

I. Review disseminated public awareness materials

2. Inspect r ecords of trainings and interview training participants

I. Review TA-related materials and information

2. Inspect records of crainlngs and post assessment test

ENVIRONMENTAL COMPLIANCE FRAMEWORK GHSC-PSM: ENVIRONMENTAL MITIGATION AND MONIT ORING Pl.AN (EMMP) I 7

=rE.-qut<n(y .:f

M::-1tcr1n.; ~

I. Annually

2. Basic cr.iinings: Roll-out. Refresher trainings: As designated in workplan

I. Annually

2. Basic trainings: Roll-out. Refresher tr.linings: As designated in workplan

C>regory of A.:.t1v1ty frcrn s~Cl1or 2 6 of

GHSC-PSM IEE

Det;(r1bc- ~ i:ec i fic

c:rnnr 0rn1c:ncal chrens o'

your org.a.rn~t1on ~

acov1: c~ t baJc~ :.r an31ys1~ 1- Scct.o~ 2 S ·~f

cne GHSC-PSM IEE1 supply chains will result in increased procurement. use and disposal of healthcare commodities and supplies, the environmental threats of which are described under 3. Public Health Commodities.

2. Research and Development

NIA I NIA

3. Public Health Commodities

Intervention ~ Testing often Category 3. r equires disposal of Quality the sample. reagents, Assurance (QA) and other supplies. and Quality Recalls require Control (QC) disposal of affected activities THAT commodities. result in • Environmental commodities for threats du~ to poor disposal ( e.: .. disposal practic~ sampling and include public health testing and impaets (e.g.. direct recall activities) exposure through

needle-stick Injur ies. ~ pathogen release) and inti:N,m isza soll and water ~-~~LQn'_gJ)_d.

O~~cnp: cri of M1::1g~t1 ,Jr M€':}.r:ure~ tor rriese

1C(l'.ilt•-:::·:: JS requ1r =·~ 1r. St:1:t1c.r1 2 6 (..of GHSC-PSM IEE

management must be consistent wlth inumational standards (i.e. W HO) and host country requirements.

2.. Training. supervision. curricula development and other supply ®in capacity building must be consistent with conditions established in uch relevant section.

NIA

Dispos al of sample testi ng w aste a nd recalled commodities un de r GHSC-PSM's direct c on trol: I. Implement GHSC-PSM's approved W aste

Management Plan (WM P) that includes procedures for properly handfing. t reating, and disposing c f nonhazardous (general waste) and hazardous wastes in accordance to international best practices (i.e. WHO) and host countJ)' requirements. W aste plan must be appropriate for the location and w-..ste stream.

2. Provide training on the approved WMP developed for properly handfing and disposing of wanes. GHSC-PSM must advise all consignees regarding the hierarchy of disponl for phannac.euticals wd chemicals if or when

Wr1n 10:, r-::~~·ons1b!o:

r<.,r 1r.i:. n1tor 1ng'

Strengthening Director

Concur: Environmental Comp Hance Spcdafist

N/A

QA/QC T ask O rder 2 pro ducts:

RClponslble: Task Order 2 QA/QC

Approve: Quafity Assurance Manager

Disposal of QA/QC retention stock at testing fac.ilities:

MQn•:or rig lrd1cator

environmental audits and wane management; and number of staff trained

NJA •

la. Approved WMP implemented

r b. Number and % of reported incidents of handling, treatmen t. and disposal of nonhazardous and hazardous wastes

2a. N umber and % of trainings and advising consignees on theWMP

2b. Number and % of consignees not advised on

Mo.,1tor-1n3 Mt-rhod

NIA

la. RevlewWMPs to ensure It Is appropriate

I b. Conduct site visits and inspect storage records for conformity and non-conformity. Include date of visits. findings and any non-compliance issues in the annual EMMR

the hierarchy of disposal for I la. Inspect cn'ning Pharrn.l_C~_Sals. genera materials and

ENVIRONMENTAL COMPUANCE FRAMEWORK GHSC.PSM: ENVIRONMENTAL MITIGATION AND MONITOP.!NG PLAN (EMMP) I 8

•

Frequ::ric1 vf Monitor r.g

NIA

I. Quarterly

2. Quarterly

3. As 1·cquired by activity

4a. As required by activity

4b, Quarterly

re lat~ contamination at disposal is required due to expiration, failure to medical supplies, and records and mitigation and disposal site. maintain appropriate norage conditions, or for Responsible: commodities, and intervie'.Y m2aitszrin£: any other r0.1son: Subcontractor, equipment consignees measures o re Healthcare W aste onlx aAAlicabli: 3. Provision of reverse logistics. GHSC-PSM must. Management 3. Number and % of incidents 2b. Inspect records of !2.IQl upoo request. provide tak~c.k services from Specialin when waste drive(s) were disposal of

consignees for all unused commodlties supplied not In comprrance. pharmaceutiols. Upon take-bac:k, commodities come under the Approve: specifically instances related general medical concrol cf the GHSC-PSM project. and subject to Quality Assurance co take-back services from supplies and all relevant requirements under the WMP, Manager, consignees for all unused commodities. and including with respect co QAJQC and disposal. Environmental commodities suppHed equipment

Compliance Due diligence of testing services providers Spedalist, 4a. N umber and% of SOPs, 3. Inspect records of 4. In selecting QAJQC testing services providers, Risk Management reference letters, incidents when

GHSC-PSM projects mun undertake reasonable Manager insuuction lettel"S, and wane drive(s) were efforts to ascertain that the providers are other documentation for not in compliance compliant with host counuy environmental, testing services providers health. and safety re!jlllrements. and employ 4a. Inspect testing respons:ible practices for the disposal or waste 4b. Basic parameters used by records and other resulting from the tening process. QAJQC i:esting services documentatlon

provider.; (e.g., reference letters) for testil\g services providers

4b. lnsJ>ect QNQC documentation :enerated by testing servicu providers

Intervention Procurement: I. Conduct quantification al\Qlysis and develop a I. Responsible: I. Quantification analysis and a I. Review I L Quarterly Category 5. • Def&tive, expired. or supply plan to meet current needs and minimize Counuy Dlrecwr , supply plan developed and quantification Procurement. counterfeit t he oversupply of healtn commodities Ministry or Health. implemented analysis report 2. Quarterly storage. commodities may be or and/or the supply

ENVIRONMENTAL COMPLIANCE FRAHEWORK GHSC-PSM; ENVIRONMENTAL MITIGATION ANO MONITORING PLAN (EMMP) J 9

distribution, and disposal of pharmaceuticals. general medical supplies and commodities, and equipment, including disposal of nonhazardous or general waste and hazardous materials

ineffective. • Excess procurement

increases the chance of produru expiring on the shelf and requiring disposal.

• Commodities containing mercury and other heavy metals and cont<lminants may become a disposal hazard to staff and the surrounding community.

2. Procure commodities diat comply with international and hon country retluirements

3. Maint2in copies of procurement records on file

4. No mercury-containing medical equipment (e.g.. thermometers. sphygmomanometers) or commodities (e.g., dental amalgam) may be procured or managed under GHSC-PSM, nor may such equipment or commoditle~ be recommended for use. except that the IP may manage disposal of s1Jch equipment or commodities as a commissioned activity. Disposal is subject w the host-country requirements and requirements below.

Review for Compliance: Director of Forecasting and Supply Planning

2-4. Responsible: Sourcing Manager, Supplier Manager

Approve: Risk Management Manager Environmental Management Specialist

Concur: Global Supply Chain Director

3. Procurement records maint<1ined

4. Number and % of incidents of non-compliance with "no m,;,rcury-containing medical equipment" procurement requirements

plan and document in t he annual EMMR

2. Review prnduct specifications to

ensure they comply with international and host country requirements and document in the annual EMMR

3. Verify that procurement records are properly maintained and document verification in the annual EMMR

4. Inspect procurement records and interview beneficiaries to verify compliance with "no mercury­containing medical equipment" procurement requirements

ENVIRONMENTAL COMPLIANCE FRAMEWORK GHSC-PSM: ENVIRONMENTAL MITIGATION AND MONITORING Pl.AN (EMMP) I 10

4. Q uarterly

I. Storage and man;igement of pharmaceuticals. o Poor warehousing general medical suppr.es and commodities. and Senior. ensure they are

practices can lead to equipment must be in conformity with approved Procurement I b. Number and % of reported appropriate I 2. Si-annually inventory loss and SOPs. This includes subcomracted warehousing Manager incidents of storage and spoilage operations. management of I b. Conduct site visits

• Occupational safety Approve: pharmaceuticals, general and inspect storage and heaitl'I risks to 2. Training and advising consignees on the SOPs Team Manager medical supplies and records for workers. such as developed for the safe and effective storage of commodities. and conrormity and injuries from dropped commodities. GHSC-PSM muse 11dvise Concur: equipment non-conformity. loads and toxic consi~s to store produces per the Risk Management Include date of hazards from deaning manufaCOJrer's Materials Safety Data Sheet Manager, 2. Number and % of trainings visits. findings and chemicals. (MSDS) I and train in best practices in Healthcare Waste. and advising consignees for any non-compliance

• Accidents or spills warehousing. Management the safe and effective issues ln the a!'lnual

due to improper Specialist storage of commodities EMMR

maintenance of equipmt!nt used to 12. Inspect training operate f.lcilities. materials and

records and Interview cons! nees

Distri byti2n; I. Transport of phlrmaceuticals. general medical Responsible: i a SOPs Implemented la. Review SOPs to I. Bi-annually • Improper distribution supplies and commoditit!S, and equipment must Plan Supervisor, ensure they are

may de.crease quality bt! in conformity with approved SOPs. DellvcrfRerurn I b. Number and % of reported appropriate 2. As required or rt!Sult in damaged Manager incidents of transported by activity or defective supplies 2. Distribution of products that may generate highly pharmaceuticals. general I b. Conduct site visits that are unsafe toxic waste can only be co those consignees that Approve: medical supplies and and inspect 3. Bi-annually and/or Ineffective. can be reasonably expected to handle such Country Director commodities. and transportation

commodities safely in storage. use. and diq>osal equipment records for conformity and

1 MSDS sheets are supplied by the manufacturer. They are also available on the internet using the active ingredient and MSDS as search terms.

ENVlP.ONMENTAL COMPLIANCE FRAMEWORK GHSC.PSM: ENVIRONMENTAL MmGATION AND H ONITOPJNG PLAN (EMH ?) I 11

• Environmenal impacts may occur from the use or vehicles to transport suppties (e.g., fuel operation, mainten4nee, spills, etc.) or if an accident or spm occurs during distribution that releases commodities to the environment.

Disposal: • Poor disposal

practices can lead to public health impaa:s (e.g .. direct exposure through neerlle-stick injuries, pathogen release) and soil and water contamination at disposal site.

(i.e. in a mann~ generally equivalent to IP's own waste management plan)

3. Training and advising consignees on the SOPs developed for the safe and effective tnnsport of commod"rties. GHSC-PSM must advise consig-iees to uansport productS per the manufacturer's MSDS and train in best pnetices in transpon:ation.

I. Implement GHSC-PSM's approved WMP that includes procedur es for properly handling, treating. and disposing of nonhazardous (general waste) and hazardous wastes in accordance to international best practices (i.e. WHO) and host country requirements. Waste plan must be appropriate for the location and waste stream.

2. Provide training on the approved WMP developed for properly handling and d"isposing of wastes. GHSC-PSM must advise all consignees

Regional Distribution Center (RDC): Responsible: Deliver/Rewrn Manager, Healthcare Waste Man;i:ement Spedalist

Approve:

2. List of consignees capable of handr.ng products that may gene1"2te highly toxic waste

3. Number and % of trainings and advising consign~ for the safe and effective o-<.11sporation of commodities

la. Approved WMP implemented

I b. Number and % of reported incidents of handling. treatment, and disposal or nonhazardous and hazardous wasi:es

non-conformfty. Include date of visits, findings and any non-compliance issues in the annual EMMR.

2. lncerview consignees and conduct site visits co confirm that consignees are able to properly handle producu that may generate highly toxic waste

3. lnspeet training materials and records and interview consignees

la. Review WMP to ensure it Is appropriate

I b. Conduct site visits and inspect sterage records for conformity and non-conformity. Include date of visits. findings and

ENVIRONMENTAL COMPLIANCE FRAMEWORK GHSC.PSM: ENVIRONMENTAL MmGA TION AND MONITORING P1..AN (EMMP) I I l

I. Bl-annually

2. Bi-annua lly

3. As required by actMty

C.:eg::>r) ri'

Activity frc,M

S=ctro~ 2 6 of GHSC-PSM IEE

related miti~otion on!;! monitoriae: mc o.sure-s g:rc only_ 01!~lis;11:fzlr: to T02

Intervention Category S. Procurement. storage.

OQs::r:be s~:::cif1c t"Ov1r c.,.nm~nt~' :r rezts ot

your .~rga!"l1Z:at1on ~

act vttie5 ~:based i::ar anJh·s1~ 1r1 Se:-:ior. ~ 5 .:)•

:~t GHSC-PSM IEE)

contamination at disposal site.

Pro!;!,! rement • Defective, expired. or

counterfeit commodities rriay be

D~scr1pt101-, ;.;' M1:1gcit10""'I 0"'l":l!:Sure-s ~v, t~,._:.~t

.~ctr"n:ie~ 35 r t:Cu r ~d 11"'1 5ecc.iori 2 6 of GHSC-PSM IEE

disposal is required due to expiration, fallure to maintain appropriate storage conditions. or for ;my other re.son:

3. Provision of reverse logistics. G HSC-PSM must, upon request. provide take-back services from consignees for all unused commodities supplied. Upon take-back, commodities come under the contTol of the GHSC-PSM project, and subject co all r elevant requirements under the WMP, including with respect to QNQC and disposal.

Due diligence of testing services providers 4. In selecting QIVQC tes.ing services providers,

GHSC-PSM projectS must undertake reasonable efforts to asceruin that the providers are compliant w ith h05t country environmental. health. and safety requirements. and employ responsible practices for me disposal of was.e resulting from the testing process.

l. Conduct quantification analysis and develop a supply plan to meet current Meds and minimize the overnipply of health commodities

w~,Q s r~p.jn<' ,bl~

for rroniror1r-,g'

Responsible: Subcontractor. Healthare Wasre Management Specialist

Approve: Quality Assuronce Manager, Environmental Compliance Specialist. Risk Ma112gement Manager

I. Responsible: Country Director, Ministry of Health, or

M,_\1ur-::>r1r.g lr.d1r-~ror Mo"'ll\_C"lr""•!"'>~ Me·h,Xi

medical supplies, and records and commodities. and interview equipment consignees

3. Number and % of incidents 2b. Inspect records of when waste drive(s) were disposal of not in compliance. pharmaceuticals. specifically instances related general medical to take-back services from suppfoes and consignee> for all unused commodicies, and commodities supplied equipment

4a. Number and % of SOi's. 3. Inspect records or reference letters. incidents when instruction letters. and waste drive(s) were other documentation for not in compliance testing services providers

4a. Inspect testing 4b. Basic parameters used by records and other

QNQC teSting services documentation providers (e.g., reference

letters) for testing services providers

4b. Inspect QAJQC documentation g~eratcd by testing services provider1

I. Quantification analysis and a I. Review supply plan developed and quantiflcation implemented analysis repor<

and/or the supply

ENVIRONMENTAL COMPLIANCE FRAMEWORK GHSC-PSM: ENVIRONMENTAL MITIGATION AND MONITORIN G PLAN (EMMP) I 9

Fr~quency -:-'

Mon1toru·.,~

l I. Quarterly

2. Quarterly

distribution, and disposal of phannaceuticals. general medical supplies and commodities, and equipment. induding disposal of nonhazardous or general waste and hazardous mate.rials

unsafe and/or Ineffective.

• Excess procurement ll'lcr eases the chance o f products expiring on the shelf and requiring disposal.

• Commodities containing mercury and other heavy meals and contaminants may become a disposal hazard to naff and the surrounding community.

2. Procure commodities ttiat comply with international and host country requirements

3. Mair.Qin copies of procurement records on Ale

4. No mercury-containing medical equipment (e.g.. thermometers. sphygmomanometers) or commoc:flties (e.g,, dencal amalgam) may be procured o r managed undes- GHSC-PSM. nor may such equipment or commodities be recommended for use. except that the IP may manage dii;posal of such equipment or commodities as a commissioned actlvlty. Disposal is subject: to the host-country requirements and requirements below.

USAID

Review for Compliance: Director o f Forecasting and Supply Planning

2-4. Responsible: Sourcing Manager. Supplier Manager

Approve: Risk Management Manager Environment21 Management Specialist

Concur: G lobal Supply Cnaln Director

2. Commodities in compl'ance with requirements

3. Procurement records maincained

4. Number and % of incidents of non-compliance with "no mercury-containing medical eGUipment" procurement requirements

plan and document I 3. Annual In the annual EMMR

2. Review product specifications to ensure they comply with International and host country requirements and document in che annual EMMR

3. Verify that procurement records arc properly maintained and document verification in the annual EMMR

4. Inspect procurement records and Interview beneAciaries to verify compliance with "no mercury­containing medical equipment'" procurement requirements

4. Q uarterly

ENVIRONMENTAL COMPLIANCE FRAMEWORK GHSC-f'SM: ENVIRONMENTAL HmGATIONANO MONITORING Pl.AN (EMMP) I 10

I. Storage and managemen1: of pharmaceucials. • Poor warehousing general medical suppnes and commoditles. and Senior. ensure they are

pr.ictices can lead to equipment must be in conformity with approved Procurement I b. Number and % of reported appropriate I 2. Bi-annually inventory loss and SOPs. This includes subconuacted warehousing Manager incidents of storage and spoilage operations. management of I b. Conduct site visits

• Occupational safety Approve: pharmaceuticals, general and inspect sco~e and health risks to 2. Training and advising consignees on the SOPs Team Manager medical suppnes and records for workers, such as developed for the safo and effective storage of commccfnies. and conformity ~r.d injuries from dropped commodities. GHSC-PSM rr.ust advise Concur. equipment non-conformity. loads and toxic consigneo..s to store produru per the Risk Management Include date of hazards from cleaning manufacwrer's Materials Safety Daca Sheet Manager. 2. Number and % of tr.1lnings visits, findings and chemicals. (MSDS)I and train in best practices In Healthcare Waste. and advising consignees for any non-compliance

• Accidents or spills warehousing. Management the safe and effective issues In the annual

due to improper Specialist storage of commodities EMMR maintenance of equipment used to I I I 12. Inspect training operate facilities .. materials and

records and Interview consignees

DisQ:il!YtiRMi I. Transport of pharmaceuticals. general medical Responsible: la. SOPs implemented la. Review SOPs co I. Bl-annually • Improper distribution supplies and commodities, and equipment must Plan Supervisor, ensure they are

may decrease quafity be in conformity with approved SOPs. Deliver/Return I b. Number and % of reported approprute 2. As required or result in damaged Manager incldencs of transported by activity or defective supplies 2. DistribJJtion of produns that may generate highly ph<lrrnaceuticals, general I b. Conduct site visits that are unsafe toxic waste can only be to those consignees that Approve: medical supplies and and inspect I 3. Bl-annually and/or ineffective. can be reasonably expected to handle such Country Director commodities. and transportation

commodities safely in storage, use, and disposal equipment records for conformity and

1 MSDS sheets are supplied by the manufacturer. They are also available on the internet using the active ingredient and MSDS as search terms.

ENVIRONMENTAL COMPLIANCE FRAMEWORK GHSC-PSM: ENVIRONMENTALHITIGATION AND MONITORING Pl.AN (EMMP) I 11

• Environmental impacts may occur from the use of vehicles to transport supplies (e.g .. ruel operation. maintenance. spills. etc.) or if an accident or spill occurs during distribution tliat releases commodities to the environment.

Disposal: • Poor cfisposal

practices can lead to pubfic health impacts (e.g .• direct exposure through needle-rock injuries. pathogen ~lease) and soll and water contamination at disposal site.

~.e. in a manner generally equivalent to !P's own waste management plan)

3. Training and advising consignee! on the SOPs developed for the safe and effective transport of commodities. GHSC-PSM must advise consignees to rransport products per the manufacwrer·s MSDS :;nd train in best practices In transportation.

l. Implement GHSC-PSM's approved WMP that includes procedures for propedy handling. treating. and disposing of nonhazardou< (general wasl.e) and haz:n'dous wastes in accordance to inremational best practices (i.e. WHO) and host country requirements. Wasw plan mim: be appropriate for the location and waste stream.

2. Provide training on the approved WMP developed for property handling and disposing of wastes. GHSC-PSM must advise all consignees

Reg/onol Distribution Cemer(RDq: R.esponsible: Deliver/Rcwrn Manager. Healdlare Waste Ma~ement Specialise

Approve:

l. List of consignees capable of handling produces that may generate highly toxic waste

3. Number and% of trainings and advising consignees for the safe and effective transportation of commodities

la. Approved WMP implemented

lb. Number and% of reported incidents of hand6ng. treatment. and disposal of nonhazardous and hazardous wasteS

non<onformity. Include date of visits, findings and any non-compliance Issues in the annual EMMR.

2. Interview consignees and conduct site visits to confirm that consignees are able co properly handle products that may generate highly toxic waste

3. Inspect training materials and records and interview consignel!S __

I ii. Review WMP to ensure it is appropriate

I b. Conduet site visits and inspect storage recol"ds for conformity and non-conformity. lndude date of visits. findings and

ENVIRONMENTAL COMPUANCE FRAMEWORK GHSC-PSM: ENVlRONMENTAL MmGATION ANO MONITOR.ING PlAN (EMMI') I 12

I. Bi-annually

2. Bi-annually

3. As required by activity

C2tegcry -::f Acc1v1:y f--orr

S~ctlC r 2 6 :if GHSC-PSM IEE

Interventio n Category 7. Procurement. Installation.

D~scribP H'e::~:

€'r.~ironm~nr.al tt"-re.'1.t! c'

yo u ~ Qrg<:irn.Lat 1 on·~

1ct1v1: e'ii I b .f')I;~ o r ,

.;<~lys•s .,.., St:c:1on 2.5 :::r

:ne Gt-SC PSI" IEE1

Treatmenc and DispMal Equipment

Dt:~C ... l;tI1()r 01 M1t.gat1'.)r1 Mea!>u .. E:S t:ir ch~<;(

.JctlVttJe> a> 'equired on Secror,r 2 6 o' GHSC PSM IEE

regarding the hieruchy of disposal for pharmaceuticals and chemicals if o r when disposal is required due to expiration, failure to maintain appropriate storage conditions. or for any other ruson.

3. Provision of rev~e logistics. GHSC-F'SM mun. upon request, provide r.o.ke-back services from consignees for all unused commodities supplied. Upon take-back. commodities come under the concrcl of che GHSC-PSM project. and subject to all relevant requirements in the WMP.

For incinerators w ith capacities :s; 200 lbs/hour a n d $ 2000 lbsJweekl a nd in-ground disposal facilities $ I 00m1 capacity ( Note that multiple installations servint a facility that in

VYr.(; ;~ ~o:":.sp·::ir"".s1t :c

fo' .,, '."''~ r 0nngi

Environmental Compliance Speciatost. Risk Management

!DC and COUIY!ly

own~d produa: Responsible: C ountry Director, Healthcare Waste Management Specialist

Approve: Environmental Compliance Speciatist. Risk Ma~ement Manager

I. Responsible: Country Director, Engineering Consultant

Mo'l roring Ind ::;-tor

la. Number and% of trainings and advising consignees on ttleWMP

lb. Number and % of consignees not advised on die hierarchy of disposal for pharmaceuticals. general medical supplies, and commodities. and equipment

3. Number and % of incidents when wasce drive(s) were not in compliance. specifically instances related to take-back sCf'Vices from consignees for all unused commodities supplied

I. Incinerator specifications

2. Treatment and disposal ret:ords mai ntained

1'-''k·"'•tcnng M..:tt.::>d

any non-compliance Issues in the annual EMMR

2a. Inspect training materials and records and interview consignees

2b. lnspea: records of dispO!:al of pharmat:euticals. general medical supplies and commodities. and equipment

3. Inspect r ecords of incidents when waste drive(s) were not In compliance

I. Rl!View incineration specifications and dot:ument in die annual EMMR

H-e: c.e' :: >f '10~ 11'~·,ring

L Review incinerator specifications prior to

1 Size definition for incine rators is based o n US C lean Air Act Section 129(a) (2) implementing regulations ("Hospital Medical Infectious W aste Incineration (HMIW l) Regulation"). and con.servatively combines the "very small" weekly limit and the ''small" pounds/hr. limit. See e.g.. hgp://www,combustioneortil.orglhmiwi.html. This is also in line with USAID's PATH Incinerator Guidebook (bttps:f/www.path.ofi/publicat1onsfflles/TS mmis incin guide.pdO

ENVIRONMENTAL COMPLIANCE FRAMEWORK GHSC-PSM: EN\llRONMENTAL Mm GATION AND MONITORING PLAN (EMMP) ( 13

commissioning, management and maintenance of hazardous waste treatment equipment, EXCEPT construction related to installation or hazardous waste

treatment equipment

• Worker exposure to pathogens in waste handling and treatment

• Community exposure to pathogens when infectious waste treatment is not effective.

• Toxic air emissions and toxic ash from inclnention

total exceed these thresholds receive a positive determination; see #2 below)

I. Wastes wiU only be disposed in lncinentors that comply with USAID ;md international standards Q.e. WHO and FAO guidelines).

2. Collect and maintain treatment and disposal records on file

3. The USAID operating unit financing the activity must prepare a SIEE pertaining to the~ site and circumstance in question as part of ttie decision to procure or manage an incinerator. The GH COR must approve the amended SIEE with concurrence by the GH BEO prior to

detailed design, procurement or operation. If the SIEE results in a positive threshold determinatio n. the operating unit must prepare a scoping statement and, as necessary, an EA. See below for scoping requirements pertaining to incinerators.

For incinerators > 200 lbs./ho ur or 2000 lbs.lweek and in-ground disposal facilit ies > I 00 m l capacity"

I. The USAJD operating unit financing t he activity must prepare a Scoping Statement and, as necessary, an EA. to be approved by the GH BEO.

Healthcare Waste Management Specialist. Sourcing Mana.;er

2. Approve: Risk Management Environmental Management Specialist

I. P.esponsible: Country Director, Engineering Consultant Healthcare Waste Management Speciafist, Sourcing Manager

2.Approve:

3. Approval of the SIEJ: with information on the procurement and use of incinerators

I. Approval of Scoping Statement and, as necessary, an EA

2 Review treatment and disposal records

3. Submit SIEE with documenllltion from USAID related to the procurement and use of incinerators for review by the GH CORandGH BEO. Document approval in the annual EMMP..

I. Submit Scoping St:itement and, as necessary. an EA for review by the GHCOR and GH BEO. Document approval In the annual EHMIL

ENVIRONME"-'TAL COH?UANCE FRAMEWOPJ< GHSC.PSM: ENVIRONMENTAL MITlGATION AND HONITOP.ING PtAN (EMHP) I 14

disposal arrangement

2. Annual review of disposal records

3. As required by activity

I. As required by activity

For hazardous waste treatment equipment 2nd installations other than incinerators and in-ground facilities I. The work order fY'/O) and other planning

information needed to ensure adequate environmental compliance must be completed for each specific instance cf procurement. installation or opention of such equipment and installations. and must be approved by the GH COR and GH SEO before IP may proceed with the activity. If the result of the screening and review process defined by the form 15 that an SIEE or scoping study is required. the IP may not proceed until diese analyses are completed and approved.

2. The IP will prepare SOPs that will address procurement and mat'lagement of hazardous waste treatment other than inc.ineramrs and in­ground facilities and submit the SOPs to the GH COR and GH SEO for review and concurrence. The SOPs shall identlfy characteristics and conteXt of the equipment/installation and w;.ste. The GH COR in consultation with the GH BEO wiR advise the IP of the requirements for any additional environmental review.

Management Specialist I. Responsible: Country Directer, Engineering Consultant Healthcare Wasre Management Specialist. Sourcing Manager

Approve: Environmental Compliance Specialist. Risk Management Manager

2. Responsible: Engineering Consultant. Health C?re Waste Management Specialist

Approve: System Strengdiening Director, Risk Management Environmental

I. WO approved and implemented

2. SOPs approved and implemented

I a. Review WO to ensure it is appropriate and has been approved

I b. Conduct site visits and inspect records ror conformity and non-conformity. Include date of visits, findings and any non-compliance issues in the annual EMMR.

la. Review SOPs to eMure they are appropriate and have been approved

2b. Conduct site visits and inspect records for conformity and non-<:<>nformity. Include date of visits, findings and any non-compliance issues in the annual

ENVIRONMENTAL COMPUANCE FRAMEWORK GHSC-PSM: ENVlRONMENTAl MITIGATION AND MONITORING PLAN (EMMP) I IS

I. As required by activity

2. As required by activity

4. Small-Scale Construction

Intervention Category 8. Construction and rehabilitation of infrastructure and facilities

AND

lnr.ervention Category 7. I nmllation of hazardous waste treatment equipment THAT requires construction

Planning and Pesim: Diswrbance to existing landscape/habitat. including drairuige

• Unmanaged extraction of timber. fill. sand and gravel. and brick can lead to sedimentation of surface water bodies, landscape/habitat dinurbance. deforestiltion, borrow piu

• Occupation~! and community health and safety risks. Including exposure to toxic materials such as asbestos, lead paint. formaldehyde (sometimes used in products like particle board, plywood, and insulation)

For "SMAL.L..SCALE'' activities in this category, dl!fined as those involving a total disturbed area equal to or less than 1,000 m 1

I. Conformity with the "Small-Scale" site and facirtty restrictions must be documented

2. Develop a site plan that includes the use or appropriate building materials and complies with lncernational b~ management practices and host country laws and r~lations. The use of materials known to cause health impacts. including asbestos-containing mai:erials. lead­based paint, and mai:erials that off-gas unsafe levels of formaldehyde are not permitted.

• Asbestos. If the presence of asbestos is suspected in a facility to be renovated, the facility must be tested for asbestos before rehabir.tation works begin. Should asbestos be presenc. then the work must be carried out in conformity with host country requirements. (if any) and in conformity wim guidance to be provided by the health team. in consult:atfon with the MEO and REA The IP will be responsible for providing PPE to workers. All results of the testing for asbesros shall be communicated to the COR.

Responsible: Country Director, Manage'Tlent Director, Engineering Consultant. Healthc;ire Waste Management Spcclallst

Approves: Environmental Compliance Specialist. Risk Management Manager

I. AcovJties meet the ~Small­Small-Scale" definition for construction and/or rehabilh:adon actMties

la. Design plan develo?ed and implemented

2b. Number and% of incidents of compliance or non­compliance with asbestos and lead-based requirements

I. Review I. Prior to construction and/or construction rehabirnation or infonnation to rehabilitation confinn proposed at:dvities site meets the "Small-Scale" 2. Prior to definition and construction document in the or annual EM MR rehabilitation

2a. Verify that a design plan was developed and document in the annual EMMR

2b. Conduct site visit to evaluate If design and const:ructlon specifications were properly implemented and review records lab testing resu lts for asbestos or lead­based paint

activities

ENVIRONMENTAL COMPLIANCE FRAMEWORK GHSC-PSM: ENVIRONMENTAL MITIGATION AND MONrTORlNG Pl.AN (EMMI') J 16

Construction: • Construction and/or

rehabilitation activities may lead to adverse health and environmental impactS if not properly managed and secured.

• Use of heavy equipment (e.g. graders. scrapers, bulldo?ers, large trucks. etc.) can result in envlronmental impacts including air degradation from air emissions, soil or surface wata­contamination from fuel and oil releases,

• Pa int. No lead·based paint shall be used Paint wlll be srored property so u to avoid accidental spills or consumption by children; empty cans will be disposed of in an environmentally safe manner away from areas where contamination of water sources might occur. ;;nd the empty cans will be broken or punctured so ttlat they cannot be reused as drinking or food containers.

I. Develop or implement existing SOPs for construction activities. Construction and rehabilitation will be undertaken in a manner generally consistent with international and USAID best management practices per the "Sm211 Scale Construction" chapter of the USAID Seaor Environmentol Gui<tefines. (www.usaidgems org/sectorGuidelines.htm). Considerations include, but are not limited to: control measures to minimize soil erosion, standing water. and storm water runoff. water

source protection, vegetation and tree preservation and transplanting. wildHfe habitat protection, site security, relevant occupational health and safety concerns. etc.

2. Provide training to workers on the SOPs developed for construction activities

Responsible: Country Director, Management Director. Engineering Consultant. Healthcare Waste Management Speclallst

Approves: Environmental Compfiance SpedaHst. Risk Management Manager

I. SOPs implemented

2. Training of staff in activities related to SOPs

la. Review SOPs to ensure they are appropriate

I b. Conduct site visits to confirm that SOPs are being effectlvely Implemented and that workers are reporting any incidents. lndude date of visits, findings, and any non-compliance issues In the annual EMMR

2. Review training materials and logs to verify trainings were conducted

EN\lli!.ONMENTAL COMPLIANCE FRAMEWORK GHSC-PSM; ENVIRONMENTAL MmGATION ANO MONITORING Pl.AN (EMMP) I 17

I a. 8-annualty

l b. At least once during construction or rehabilitation activities

2. Annually

and soil and surface water impacts from physial disturbances In areas of heavy traffic.

Standing water an become breeding habitat for disease vectors

Disposal; • Construction

activities may generate debris and wanes that contain both non-hazardous and hazardous materials and require proper disposal. This 1 ncludes chemicals, solvents, and any materials containing toxics such as asbestos, lead-based paint and formaldehyde.

• Workers and other nandling construction debris and wastes may be exposed to nazardous materials if the appropriate PPE is not used.

I. Develop or implement an ~isting WMP that indudes procedures for properly disposing of non-hazardous and hazardous matenals in accordance with international best management practices and nost country requirements. Considerations include. but are not limited to: proper handling and starage of wane. safe disposal practices and accepcal:lle disposal loc2tions, and use of appropriate PPE.

2. Provide training to workers an tile WMP developed for handling waste during connructlon activities

Responsible: Country Director, Management Director, Engineering Consultant. Healtncare Waste Management Specialist

Approves: Environmental Compliance Specialist. Risk Management Manager

I. WMP implemented

2. Training of staff in activities related to the WMP

la. Review WMP to

ensure it is appropriate

I b. Conduct site visits to confirm that WMP is being effectlvely implemented and that workers are reporting any Incidents. Include date of vlsits, findings. and any non-compliance issues In the annual EMMR

2. Review trainina: materials and logs to verify trainings were conducted

ENVlRONMENTALCOMPUANCE FRAMEWORK GHSC-?SM: ENVIRONMENTAL MmGATION ANO MONITORING PlAN (EMMP) I 18

I. Quanerly

lb. At least once during constrUctlon or rehabllitation activities

2. Annua!ly

manage wute streams anticipated in operation (e.g., gray water , latrine discharge. solid waste) can a:>ntiminate ground and surface wner, create breeding habitat for dlsease vectors. and lead to erosion and soil and water contllmination.

I. Provide guidance maxerials and training to host country organization on the proper use. operation, and maintenance of the facility prior to transferring it at compl&ion of the project

For " MEDIUM- TO LARGE-SCALE" activities in this category, defined as those involving a t o tal disturbed area greater than l ,OO Om l on a given site

I. The USAID operating unit financing the activity must prepare a Scoping Statement and, as necessary, an EA, to be approved by the GH BEO.

Responsible: Country Director. Management Director, Engineering Consu ltant. Healthcare Waste Management Specialist

Approves: Environment:al Compliance Specialist. Risk Management Mam.g-cr

Responsible: Country Dire<:tor, Engineering Consultant. Healthcare Waste Management Specialist

Approves; Environmental Compliance Speciahst. Risk Mana.srement

I. Guidance materials developed and training provided

I. Approval of Scoping Statement and. as necessary. an EA

training procedures to ensure they are appropriate

2. Conduct site visits to confirm that guidance materials were provided and facility was successfully transferred to the host country organ izadon. Include date of visits. finding5, and any non-compliance issues in t he annual EMMR.

1. Submlt Scoping Statement and. as necessary, an EA for review by the GH COR and GH BEO. Document approval in the annual EMMR.

ENVIRONMENTAL COMPUANCT FRAMEWORK GHSC·PSM: ENVIRONMENTAL MITIGATION A ND MONITORING PLAN (EMMP) I 19

prior to tnnsferring faclllty at completion of tne project

2. At least once prior to transferring facility at completion of the project

I. As required by activity

c~cegory of Act1 .11ty : .. arr.

Sec ~n 2 6 of G-iSCPSM IEF

Descri~~ specific ~""1\ll'Or,rrH!'r'l(."ll thre.a~5 :,,(

vot.r org1n1z1t•On ~

~c·h1t"1cs tba~ec ·,:,r.

~··:11)""~ n ~·~·ct10.-- 2 ~ 0(

:~:· GHSC-PSM IEE.1

S. Small-Scale Wattr and Sanitation

NIA

6.. NutriUon

NIA

7. Vector Cornrol

LONG­LASTING INSECTICIDAL NETS fLLINsl

lr1tervention Category 6. Procurement. storage. distribution, use, management. disposal of pesticides

NIA

NIA

Procyrement: • If non-approved

LLI Ns are used, exposure may lead to adverse health and environmental impacts due to unknown Msks to health. land, water. and sensitive ecosystems.

• Procurement of non­app1·oved LllNs or over-supply can result in the generation or potentially hanrdous waste that must be property disposed.

De~cnpt1or. of M1t1€;:it1cn Me.:i.!.u""e~ fa ... rh~~~

.,:t1v1t1es ,E i-e.:wred n Se:C"'.'1or 2 6 of -:;HSC-PSM IEE

N/A

NIA

I. Proo.irement of insecocide-treated nets is limited to WHO-recommended brands of LUNs that meet PMJ's technical criteria per the PHI guidance. 22 CFR 21 IU.b analyses for lLINs is satisfied by t he MVC PEA The IP should also refer to the NM PEA for guidance for the procurement or LLINS as well as the WHO recommendations for pacbging LUNs.

2. Procurl'!menc records are maintained

3. WN tllke-back. GHSC-PSM projects must. upon request. provide take-back from consignees for all unused LLINs. It is not feasible to collect used WNs once distributed to end user. However, if requested co do so. the WHO has published recommendations for the safe use and disposal of expired LUNs (WHO 2014).

Wl'io 1 ~ ··1:--;por.-,1t1L:

lo·· mor1'"or r.g' Mon1to~1ng lnd1cat:.r

Manager I I

NIA

NJA

1-2. Responsible; Country Director, War eh oust'! Speci.tl:sr. Distribution Specialist

Approves: Environmental Compliance Specialist. Risk Management Manager, Task Order Director

3. Responsib le: Country Direcror, Warehouse Speciafist. Healthcare Wastt Management Spedafist

Approves:

NIA

NJA

I. Conformity with LUN procurement requirements

2. Procurement records maintained

3. Number and % of incidents of compliance or non­compliance with the LLINs take-back requirements, if applicable

Mor, lo .. 1ng Mi!":riod

NIA

NIA

I. Verify that LUNs ire approved for use in the PMI guidance and meet nost country requirements

2. Verify that procurement records are malncained and document verification in the annual EMMP.

3. Inspect LUNs take­back records and other applicable documents

ENVIP.ONHENTAL COMPUANO: FRAMEWOJ>.K GHSC-PSM: ENVIRONMENTAL MlllGATION ANO MONITORING Pl.AN IEMMP) J 20

fr-foqu~"'\C~ Jf M0"1to· 1ng

N/A

NIA

I. Prior to

procurement activities

2. Monthly

3. As required by activity

Storage and Distribution; • Inadequate quality

control of LUNs during storage and distribution activities may lead to adverse impacts to land, water. and sensitive ecosystems if improperly handled and released to the environment. W orkers and oth~ handling equipment. pesticides, and suppfies may be in direct contact with hazardous materials during these activities, which may lead co health Impacts. Nearby residents may be exposed to pesticides if LUNs are not securely sr.ored to

prevent theft and misuse incidents.

I. Implement approved SOPs for the safe storage and distribution of LUNs

2. Distribute WNs to facifities that can handle sudl commodities safely in storage. distribution, and disposal (i.e. in a maMer generally equivalent to Implementing Partner's own SOPsJWMP)

3. Storage facilities and transportation vehicles must be physically secured to prevent theft

4. Storage and distribution records are maintained

S. Train workers and drivers on tlie approved SOPs developed for the safe storage and distribution of LLINs

Environmental Compriance Speciafa. Risk Management Manager Responsible: Country Dire«or, Task Order Director. W arehouse Speciafist. Healthcare Waste Management Speclaflst

Approves: Environmental Compliance Sped a.Ost Risk Management Manager

I. Review and implement approved SOPs

2. Storage facifrties and vehides comply with approved SOPs

3. Storage facilities and tr.lnsportation vehicles are secured and theft Incidents reported

4. Storage and distribution records maintained

5. Training materials and records

I. f\.eview approved SOPs to ensure they are appropriate

2. Inspect storage facilities and transportation vehicles to ensure they are adequate and in compliance with approved SOPl.

3. Conduct inspections during operations and document any non­compriance issues or the~ incidents

4. Inspection of storage and cfastrlbution r~rds.

Storekeeper performance checklists.

ENV!RONMENTAL COMPUANCE FRAMEWORK GHSC-PSM: ENVIRONMENTAL MITTGATION ANO MONITORING Pl.AN (EMMP) I 21

I. Twice a week

1. Twice a week

3. Weekly

4. Weekly

5. Bl-annually. or more frequently as new personnel require training

including the illegal resale of pesticides.

Use and Reuse:

• Improper use of LLINs may lead to adverse health and environmental impacts

• Human health impacts from pesticide exposure include headaches. nausea. severe poisoning, cancer. reproductive harm, endocrine disruption. coma, and death.

• Wildlife can face similar impacts due to pesticide exposure and accumulation in water. air. and soil.

Djsposa): • WHO has developed

recommendations for disposing of used LLINs and USAID conducted a pilot

I. U!Ns have now essentially replaced conventional insecticide-treated nets in Africa. Conventional insecticide-treated nets (ITNs), requiring regular retreatment of insecticide, may still be In use in the Greater Mekong Subregion. No support for net retreatment including procurement will be undertaken before an environmental review is completed which examines the proposed pesticides to be used in the r etreatment programs. Such an analysis would be in the form of a FERSUAP. and should follow guidance in me ITM PEA and IVM PEA on the preparation of activity-level LLIN PERSUAPs.

2. Develop and implement a communication plan that includes a social and behavior change communication (SBCC) strategy to inform users on acceptable and unacceptable repurposing uses for LLINs. The JP !!l!.!Z inscruct recipients that using new LUNs for anything om er than their intended use (e.g., fishing) is prohibited.

I. Resident:s will be advised to continue using nets until a new one ls provided and repurpose non­viable nets for acceptable uses. Refer to the Reuse information above.

Responsible: Country Director. Healthcare Waste Management Specialist

Approves: Environmental Comphance SpeciaRst, Risk Management Manager. Task Order Director

I. Refer to the Reuse information above.

I. USAID approved errvironmental review of the proposed pesticides to be used in the retreatment programs (such as a PERSUAP or other required documentation)

2. Communication plan developed for LUNs that indudes a SBCC strategy (when instructed by USAJD)

I. Refer to the Reuse information above.

S. Review training materials and records to verify trainings were conducted

I. Review documentation from USAID related to the environmental review of the proposed pesticides to be used in the "'treatment programs

2.. Review communication plan for LLINs

I . Refer to the Reuse Information above.

ENVIRONMENTAL COMPLIANCE FRAMEWORK GHSC-PSM: ENVll\ONMENTAL MITIGATION AND MONITORING PLAN (EMMP) I 22.

I. As required by activity

2. SBCC mater ials witti every delivery of LLINs

h Refer to the Reuse information above.

• PERSONAL REPELLANTS

Intervention Category 6. Procurement. storage,

scudy to determine the feasibility of a take-back and r ecyding program that Involve<! the incineration of LLIN.s. However, it was found that die collection and disposal of LLJ Ns were not practical or cost-effective in most setting>. In addition. many residents were reluctant to give up their nets. regardless of the age and condition of the net. As a result, residents should be advised to continue using nets until 2 new one is provided and repurpose non-viable nets for acceptable uses.

Procurement:

• Procurement of non­approved personal repellants may result in adverse health and environmenal impacts due to

I. Procurement ofj)ersonal repellants is limited to EPA-registered or WHO-recommended pesticides. 22 CFR 2163.b analyses for peno~ r epellants is satisfied by the Ziki PERSUAP and host country requirements.

2. Procurement records are maintained

Responsible: Country Direccor. Task Order Director. Warehouse Specialist. Healthcare Waste

I . Conformity With procurement requirements for personal repellanu

2. Procurement records maintained

I . Verify that personal 11. Prior to repenani:s .ore procurement approved for use In aaivities the Zika Programmatic PERSUAP and meet I 2. Monthly host country requirements

ENVIRONMENTAL COMPLIANCE FRAMEWORK GHSC.f'SM: ENV11\0NMENTAL MmGATION ANO MONITORING PLAN (EMMP) I 23

management. disposal of pesticides

and sensitive ecosystems

Storage and Distribution:

Inadequate quaflty control of repeJJ;ncs during sterage and distribution ictivities may lead to adverse impacts co land, water, and sensitive ecosystems if improperly handled and released to t he environment.

• Workers and others ~dling equipment. perocidcs, and suppfles may be in direct contact with h=!rdous materials during these activities, which may lead to

health lmpaas. • Nearby residents may

be exposed to

I. Implement approved SOPs for the safe storage and distribution of personal repellant:s

2. Distribute personal repellant:s to facifitles that can hanc1e such commodities nfely in storage. distribution. and disposal (t.e.. in a manner generally equivalent to Implementing Partner's own SOPslWMP)

3. Storage facilities and transportation vehicles must be physically secured to prevent theft.

4. Storage and distribution records a.re maintained

5. Train workers and drivers on the approved SOPs developed for the safe stof:lge and distribution of personal repellants

Management Specialist

Approves: Environmental Compliance Specialist, Risk Manigement Manager Responsible.: Country Direccor. Taslc Order Director, Warehouse Specialist. Healthcare Waste Management Specialist

Approves: Environmental Compliance Speciartst, Risk Management Manager

I. Review and implement approved SOPs

2. Sto!dge facitrties and vehides comply with approved SOPs

3. Storage facilities and transportation vehicles arc secured and the~ incidents reported

4. Storage and distribution records maintained

5. Training materials and records

2. Verify that procurement r e.cords are maintained and document verification in the annual EMMR

I. Review approved SOPs to ensure they are appropriate for the actiVe ingredient used

2. Inspect storage facilities and transportation vehicles to ensur e they are adequate and in compnance with approved SOPs.

3. Conduct inspections during operations and document any non­compliance issues or theft incidents

ENVIRONMENTAL COMPLIANCE FRAMEWORK GHSC.PSM: ENVIP.ONHENTAL MITIGATION AND MONITORING Pt.AN (EMMP) I 2'4

I. Twice a week

2. Twice a wee.le

3. Weekly

4. Weekly

5. Bi-annually. or more frequently as new personnel require training

pesticides if repellants are not securely stored to prevent theft: and misuse incidents, including the illegal resale of pesticides.

Use: • Improper use of

personal repeUams by consignees ~.e. health providers) and beneficiar ies (e.g .. pregnant women) may lead to adverse health and environmental impacts.

Disposal: • Improper disposal of

general and hazardous wastes (e.g., empty __

I. Tr.iin health providers on the proper procedures for handling and distributing personal repellants at health establishments

2. Implement a communication plan tl\at indudes a SBCC strategy to Inform users on acceptable and unacceptable uses of personal repellants

I. Handfing. treatment. and disposal or nonhazardous (general waste) and hazirdous wastes must be in accordance with the approvt!d WMP. The WMP. which outlines SOPs for

R.esponslble: Country Director, Task Order Directer. W arehouse Specialist. Healthcare Waste Management Specialist

Approves: Environmental Compliance Specialist. Risk Management Mana:er Responsible: Country Director. Task Order Director.

l. Health providers are notified of prnper prcxedures related to personal repellants

2. SBCC materials developed and distributed

I. WMP implemented

2. T ninlng materials and records

4. Inspection of pesticide management records. Storekeeper performance checklists.

5. Review training materials 2nd records t0 verify trainings were conducted

l. Verify health providers· understanding of procedures related to personal repellants

2. Review SBCC materials with all consignees regarding personal repellants and otner rcleva.nt documentation

I a. Review WMP to ensure it is appropriate

ENVIRONMENTAL COMPLIANCE FRAMEWORK GHSC-PSM: ENVlRONMENTAL MITIGATION AND MONITORING PLAN (EMMP) J 25

I. Training to health providers with every derrvery of personal repellants

2. SBCC materials with every delivery of personal repellants

l. Quarterly

lb. At least once during

C"tegc.ry .')f .A ,:vvitv !rc,m

Sec:t1vr. 2.6 •:1t

GHSC-PSM IEE

DE-scrit-P sp"ofoc ~nv1ron-i1tn:al i:hr-2.n':: l;

}"Cur •::,ir-~an:zz: QI;;:

:"ti:'T'••·rt 1 E5 I bd~E-0 ·:.r

;i;r.~11~ <:. •!i 1r. 5ect10~ .:!..5 ,:.f

t~e GH5C-PSM IEE!

pesticide containers. expired repellants. etc.) may lead to

adverse health and environmental impacts

Tr"e~~ntand Ois9o~al .Eg11i11m~nt: . Improper incineration

of pesticide wastes and disposal of residual ash can pose a threat to air quality, soil. and the water supply and result in environmental and public health hazards

Descnp~·0r n1 M1::1g;.innr Mo:.asure~ tor Lh€se

·Kt1'w·rt1·.-~~ _,~ rr;.•qu1~ ~r_:1 1r, St::C:• ~·r1 2 6 r)f 3H5C-P5M IEE

managing waste processes. must be in accordance with PMl's Best Manarement Praqjces CBM~). international best practices O.e. WHO, FAO) and host country requirements.

2. Train workers on the WMP

I. Pestlc1de wastes will only be disposed in incinerators that comply with USAID and international standards (i.e. WHO and FAO guidelines).

2. Collect and maintain treatment and disposal documents and records on file

3, The USAID operating unit financing the activity must prepare an amended SIEE pertaining to the specific site and circumstance in question as part of the decision to procure or manage incineration services. The GH AOR/COR must approve the amended STEE with concurrence by the GH BEO prior to detailed design.

Whc· ' ' r~spo.,51~le

for n-10!1 1rur1n:~'

Warehovse Specialist, Healthcare Waste Management Specialist

Approves: Environmental Compliance Speclalist. Risk Management Manager

Responsible: Country Director, Task Order Director, Warehouse Specialist. Healthcare Waste Management Spec la fist

Approves: Environmental Compfiance Specialist. Risk Management

Mori 'i.~)r :r g l r.d1 .:~co1

L Incinerator specifications

2. Maintenance of treatment and disposal records

3. Approval of amended SIEE

M0n11:.on ng MFrhcd

I b. Conduct site visrts to confirm that WMPisbeing effectiVely implemented and that workers are reporting any incidents. Include date of visits, findings. and any non-compliance issues in the annual EMMR

2. Review training materials and logs to verify tralnlngs were conducted

I. Review incineration records and document in the annual EMMR

2. Treatment and disposal records maintained

3. Submittal of amended SIEE and review byGH COR and GH SEO concurrence. Document approval

ENVIRONMENT AL COMPLIANCE FRAMEWORK GHSC.PSM; ENVIRONMENTAL MITIGATION AND MONITORING PLAN (EMMP) J 26

Fr-=-q.Jency :A Morittn rmg

campaign

2. Bi-annually. or more frequently as new personnel require training

I. Review incinerator specifications prior to disposal arrangement

2. Annual review of disposal records

I 3. As r equired by activity

PEST CONTRO L

Intervention Category 6. Procurement. storage, distribution. use. management. disposal of penicides

STERILANTS ANO OTHER PESTICIDES

Intervention Category 6. ProaJrement. storage, distribution. use, management.

Use and D jsposal: • Pest control in

warehouses and od1er storage facmties will not use phosphine or other forms of fumigation for pest control. Instead, pest control wiU be conduned using contaet or residual pesticide/rodcnticide.

u-.e; • Use and management

of pesticides other than LLINs. personal repellants. or pest control produru, including disinfectants and phannaceuticals classified by US EPA as pesticides ls

procurement. or operation. For incinerators with capacities to bum >I OOkg of wane per hour. t his will result in a Positive Determination and require a scoping study. and potentially, an EA.

I. SOP$ for operation of warehouses and storage faciUties wi11 address the proper appOcation of pestlcideslrodentlcides and disposal of the resulting waste. Pest control produru will be dispose in accordance with the label requirementS.

I. The USAfD operating unit financing the activity must prepare involves a separate evaluzt:ion in the form of a SEA or PERSUAP to address potential health and environmental impacts. The GH COR must approve the environmental evaluation with concurrence by the GH BEO prior use of other pesticides.

Responsible: Country Director, Warehouse Specialist, Healthcare Waste Management Specialist

Approves: Environmental Compliance Specialist. ~sk Management Manager

Responsible: Country Director, Warehouse Specialist. Healthcare Waste Management Specialist

Approves: Environmental

I. SOP> ioclude procedures on the proper appncation of pesticideslrodenticides and disposal of the resulting waste.

2. Incidents records maintained

I. Approval of SEA or PERSUAP

in the annual EMMR.

I. Review SOPs for I. Annually operation of warehouses and 2. Annually or storage facillties as occurs addressing the application of pesticideslrodentici des and disposal of the resulting waste to ensure they are adequate and document review in the annual EMMR

2. Maintain records of any incidents and document in the annual EMMR

I. Submittal and apflroval of SEA or PERSUAP for review by the GH COR and GH BEO. Doaiment approval ln the annual EMMR.

I. As required by activity

ENVIRONMENTAL COMPl.JANCE FAAMEWORK GHSC-PSM: ENVIRONMENTAL HITIGATION ANO MONITORING PlAN (EMMP) I 27

1 disposal of pesticides

permitted under GHSC-PSM only as authorized by and subject to the conditions of Programmatic or Mission documentation satisfying the requirements of 2.2 CFR 2 I 6.3(b).

• This involves a separate E!"r.lluatlon in the form of a SEA or PERSUAP to address potential health and environmental impacts.

8. Eme!'lency Response

NIA I NIA NIA

Compliance Specialist. Risk Management Manager

NIA NfA N/A

ENVIRONMENTAL COMPllANCE FRAME\NOR.I< GHSC-PSM: ENVIRONMENTAL MITIGATION AND MONITORING PLAN (EMMP) I 2B

NIA

ENVIRONMENTAL COMPLIANCE FRAMEWORK APPROVAL

Prepared by:

Internally approved by:

Approved by:

Approved by:

Approved by:

G

• • Date: 115. ~- .I~

~~ t,,,; f'IM-81t- """ 0 £ 2 1.. /1: GH -PSM Representatives

Date: Mc..b u I 2.0 n

Date:~~~~~~~~~ Contracting Officer's Representative

Date: ~ ~ -2£}/ A.._

ENVIRONMENTAL COHPUANCE FRAMEWORK GHSC.PSM: ENVlRONMENTAL MITlGATION AND MONITORING Pl.AN (EMMI') I 29

2.3 PART 3: ENVIRONMENTAL MITIGATION AND MONITORING REPORT GLOBAL HEAL TH SUPPLY CHAIN-PROCUREMENT AND SUPPLY MANAGEMENT (GHSC-PSM)

List each Mitigation Measure fr om column 3 ln the EMMP List any outstanding issues relating to required St<!tus of Mitigation Measures

conditions Remarks

I. Educ:ati~tt. Tech(l!9l! AsSistance, Training

Intervention Category 2. Awareness building and advocacy; enabling environment strengthening (e.g., policy advocacy)

Intervention Category 4. Capacity building for host· country health supply chains

2. Research and Qevelopn:fent_ - °NIA NIA NIA

3. Public Heald\ Commoctn:ies

Intervention Category 3. Quality Assurance (QA) and Quality Control (QC) activities THAT result in commodities for d isposal (e.g .. sampling and testing and recall aCT.ivities) £Only_ Of!.fl.licable to T02

Intervention Category 5. Procurement. storage. distribution. and disposal of pharmaceuticals. general medical supplles and commodieles. and equipment. including disposal of nonhazardous or general wane and hazardous ma'terials

lnrervention Category 7. Procurement. installa tion. commissioning, m2nagement. and maintenance of hazardous waste treatment equipment. EXCEPT construction related to inscallation of hazardous waste • treatment equipment

4. Small-Scale Construction

lnrervention Category 8. Construction and rehabilitation of infrastructure and facilities AND Intervention Category 7. Installation of hazardous waste . treatment equipment T HAT r equires construction

ENVIRONMENTAL COMPLIANCE FRAMEWORK GHSC-PSM: ENVIRONMENTAL MITIGATION AND MONITORING PlAN (EMMP) I 30

•

-5. Small-Sale Wat6 ~d~~ti_on NIA NIA NJA

.6. Nutrition NIA NJA NIA

7. Vecror Control

lnteNention Category 6. Procurement. storage. .disO"lbution. use. minagemen~ disposal of pesticid,es

8. ·emeflency R~p<>nse N/A NIA NIA -

Prepared by: Signature Date:~~~~~~~~-

l'-lame.a_11_d_Thle

ENVIR.ONMENTAL COMPLIANCE FRAMEWORK GHSC-PSM: ENVIRONMENTAL HITIGATION AND MONITORING PLAN (EMMP) I 31

U.S. Agency for International Development 1300 Pennsylvania Avenue, NW Washington, D.C. 20523 Tel.: (202) 712-0000 Fax: (202) 216-3524

www.usaid.gov

~USAID ~ FROM THE AMERICAN PEOPLE