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E4122
MINISTRY OF HEALTH
NORTH EAST AND RED RIVER DELTA REGIONS HEALTH SUPPORT PROJECT
ENVIRONMENTAL AND SOCIAL
MANAGEMENT FRAMEWORK
Vietnam, January, 2012
TABLE OF CONTENT
I.
INTRODUCTION ...................................................................................................... 4
II. PROJECT DESCRIPTION ....................................................................................... 4
2.1
Project design .................................................................................................... 4
2.2
Project Area ....................................................................................................... 8
2.3
Types of potential sub-projects .......................................................................... 8
2.4
Project management and personnel .................................................................. 9
III.
ENVIRONMENTAL POLICIES APPLICABLE TO THE PROJECT ....................... 9
3.1
Vietnamese Environmental policies ................................................................... 9
3.2
World Bank environmental safeguard policies ................................................. 11
IV.
Institutional arrangement ..................................................................................... 11
4.1
Project hospitals ............................................................................................... 11
4.2
Provincial Project Management Units (PPMUs) ............................................... 12
4.3
Central Project Management Unit .................................................................... 12
4.4
Provincial People Committees (PPCs) ............................................................. 13
4.5
The World Bank ............................................................................................... 13
4.6
Contractor and equipment suppliers ................................................................ 13
4.7
Institutional Capacity ........................................................................................ 13
V. POTENTIAL ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES ........ 14
5.1
Project Environmental Category....................................................................... 14
5.2
Potential Socio - Environmental Impacts .......................................................... 14
5.2.1
Potential impacts during implementation phase ........................................ 14
5.2.2
Potential impacts in operation phase ......................................................... 15
5.3
VI.
Typical Mitigation Measures ............................................................................. 17
ENVIRONMENTAL MANAGEMENT PROCEDURES ......................................... 30
6.1
Documentation requirements ........................................................................... 30
6.2
Project Environmental Management Procedures ............................................. 30
6.2.1
Environmental Screening for eligibility ....................................................... 34
6.2.2
Impact identification ................................................................................... 34
6.2.3
Drafting Subproject Safeguard Document ................................................. 34
6.2.4
Public Consultation and information disclosure ......................................... 35
6.2.5
EMP review and Approval ......................................................................... 36
6.2.6
Licenses and Permits ................................................................................ 36
6.2.7
Supervision and environmental monitoring ................................................ 36
6.2.8
Documentation and record keeping ........................................................... 37
6.3
Capacity building/Training plan ........................................................................ 37
6.4
Cost for safeguard implementation .................................................................. 37
ANNEX
Annex 1: Environmental Eligibility Screen Form
Annex 2: Environmental Impact Screening Form
Annex 3: Recommended Format of EMP for each sub-project
Annex 4: Record of Public Consultation
Annex 5: Technical specifications of facilities and equipment for HCWM
Annex 6: Vietnam Hospital Wastewater Discharge Standard
Annex 7: Vietnam Health Care Solid Waste Incinerator Emission Standard
Annex 8: Cost estimation for technical assistance and capacity building
I.
INTRODUCTION
The Northern East and Red River Delta Region Health Support Project
(NORRED) herein referred to as the FIRST Project or the Project is executed by the
Ministry of Health (MOH) with the funding from the International Development
Association (IDA) under the World Bank.
The NORRED will comply with the World Bank Safeguard Policies and
Vietnamese environmental regulations to avoid or minimize impacts to humans and the
environment during the implementation. Under component 1, the project will finance the
activities of medical equipment purchase and minor civil work for provincial level
hospitals and 50 district hospitals. These activities may cause some environmental
issues relating dust, noise generation and waste management, safety issue during
Project implementation and operation. These impacts are expected to be localized,
mitigable and manageable through good design and appropriate mitigation measures.
Therefore, the project has been categorized as Environmental Category B by the World
Bank classification. As most of investment details under NORRED’s component 1 will
not be known by Appraisal, during preparation an Environmental and Social
Management Framework (ESMF) is prepared by MOH to ensure that the Project
activities will be implemented in an environmentally and socially sustainable manner.
This EMSF lays down the principles and guidelines for addressing environmental
and social impacts due to the implementation of the NORRED. It identifies the range of
policies that the PPMUs should consider in project development. It will also outline the
roles and responsibilities of the investors and project developers, the MOH’s PMU,
PPMU, and the World Bank at each stage of the project cycle. The environmental and
social safeguard policies shall be applied to all financed subprojects under NORRED.
Adoption of ESMF shall ensure that the subprojects meet Vietnam environmental and
social policies and are also consistent with the applicable safeguard policies and
provisions of the World Bank.
The ESMF will be incorporated into the Project Operation Manual to ensure that
environmental and social issues will be considered together with other requirements
during project implementation.
II.
PROJECT DESCRIPTION
2.1
Project design
The Project Development Objective
The Project Development Objective (PDO) is to increase the utilization of patients to
local health services in selected provinces of the North East and Red River Delta
regions by strengthening the capacity of selected provincial and district hospitals to
deliver more and better quality health services and reducing the financial barrier for
accessing care of the economically vulnerable.
The project comprises 3 components.
1. Component One: Strengthening the capacity of lower level health services to
deliver quality services ($115 million): Component One aims to increase the
capacity of the Provinces to provide more and better quality health services. It would
consist of two subcomponents.
Subcomponent 1a - Provincial Subprojects for the Development of Medical
Services and Quality Improvement about 111.5 million). This subcomponent would
provide technical and financial support directly to the Provinces to increase their
capacity to deliver quality health services at their general provincial hospitals or
specialized pediatric or obstetrics and gynecology hospitals as well as at least three
district hospitals per province. This subcomponent would be implemented as a virtual
“Fund”. It would operate as a Fund because no amount of the Credit would be explicitly
allocated to provinces. Provinces would apply to receive these funds to support their
“sub-project” through the development of a Provincial proposal. The proposal would
include the results of a needs analysis and confirm that the request is not a duplication
of other activities supported by other sources of funds such as state bonds or small
donor projects. It would define exactly which services the hospitals would be able to
perform after the assistance provided by the Project. The proposals would cover five
specialty areas (obstetrics/gynecology, pediatrics, cardiology, oncology, and trauma) at
the provincial hospital level and three specialty areas at the district hospital level
(obstetrics/gynecology, pediatrics, and trauma) as well as the auxiliary services at the
hospitals (laboratory, intensive care). The exact services would be in accordance with
the needs of the population, the inability to provide the required service currently (or
provide it with sufficient quantity) and would be in accordance with the MoH guidelines
(Decision 23) as updated on the services to be provided according to the hospital
technical level (Level I being a tertiary facility, Level II being a secondary facility and
usually denoted as a Provincial Hospital, and Level III being a basic secondary facility
with a more limited scope of services and usually denoted as a District Hospital).
Additionally, the proposals would define specific measurements of quality or
management improvement that would be implemented in certain defined areas (at least
5% of the IDA investment in the subproject cost). Three measures of quality and
management improvement would be required: (i) measuring patient satisfaction; (ii)
initiating a Continuous Quality Improvement process; and (iii) development a planning
and budgeting process for facility maintenance. Additionally, the Provinces shall
choose among the topics to implement at least one other measure. The sub-projects
would be implemented through the Provincial Departments of Health (DoH) and their
Provincial Project Management Units (PPMU). The implementation plans for the
subprojects would be consolidated as part of the Annual Workplan of the Project. In the
event of poor implementation by Provinces (including poor management practices and
delays), the sub-project scope can be reduced or cancelled in order to reallocate the
funds to better performing provinces. Under Component 1b, the Ministry of Health will
have technical support available to the provinces to help with the planning and
implementation of the sub-projects which will, in particular, be targeted to the Provinces
with less capacity.
Subcomponent 1b – Training and Technical Transfer for Reducing Hospital
Overcrowding and Quality Improvement (US$3.5 million). This subcomponent would
support the Ministry of Health and the other national level stakeholders to provide
quality technical support to the Provinces to achieve the Components goals. This
component would be implemented by the Ministry of Health and its Central Project
Management Unit (CPMU). This would include two Technical Advisory Groups (TAGs)
(teams of national experts, including from national institutions and hospitals). The first
group would support the Provinces in the preparation and implementation of the plan for
the technical transfer of the “know-how” for certain medical services and procedures;
the second Technical Advisory Group would support the Provinces in the preparation
and implementation of a hospital quality and management improvement plan.
Particularly in the area of quality improvement and management, technical support will
be provided to build the capacity of national counterparts. The component would also
support the Ministry of Health in defining national level strategies and policies for
implementation in the hospitals, research on the hospital overcrowding issue, such as in
developing the guidelines for piloting the provision of radiation therapy treatment as
primarily an outpatient treatment. The subcomponent would also include direct support
to the central hospitals in development of their training capacity and the training
programs in support of the technical transfer.
2.
Component Two:
Reducing the financial barriers to access by the
economically Vulnerable (US$29.0 million). Component 2 aims at reducing the
financial barriers by (i) expanding access to health insurance for a specific vulnerable
group largely not covered by the current insurance system; (ii) providing direct access
to certain high cost services support under Component 1; and (iii) increasing the
general awareness of the rights of individuals and/or households under the insurance
system. It would achieve this through three subcomponents:
Subcomponent 2a - Direct subsidy to support the purchase of a health insurance
card by the near poor (US$23.0 million): Building on the similar and successful
examples under the Mekong and Central North Regional Health System Support
Projects, this subcomponent would support an additional subsidy of 20% of health
insurance premiums (on top of the 70% subsidized by the state) for the Near Poor
household members, conditional upon whole family enrollment.
Those who enroll
individually would not receive any support from the project. The support to household
enrollment will help to increase the coverage more quickly than individual enrollment,
improve risk sharing and reduce adverse selection, the core principles of social health
insurance. The support will provide good experience and lesson learnt for the Ministry of
Health to later expand it as a national policy. The Government has a policy for
expanding health insurance coverage particularly for the vulnerable groups. Based on
the Government’s Universal Health Coverage Roadmap, it is expected that the
Government will extend the state support to this group within the project lifetime. The
Project would provide an opportunity to advance this support in a large geographical
region and for the Government to learn from the policy of requiring family as opposed to
individual enrollment as they are considering this policy change.
Subcomponent 2b - Supporting catastrophic health care expenditure at provincial
hospitals (US$2.0 million). This subcomponent would provide seed funds to the
Provinces in the re-establishment of the Health Care Funds for the poor in accordance
with Government policy. The Government issued Decision 14 revising the Decree 139
re-establishing health care funds for the poor; however, the guiding circular for
implementation is still under development. Among other things, Decision 14 identified
the Government support to vulnerable groups, including the poor, ethnic minorities,
social assistance beneficiaries, and patients with cancer, dialysis, heart operation and
other high cost treatment without ability to pay. Each province has to establish the fund
with Government budget and possible mobilization of funds from other sources.
However, in poor provinces with a large number of beneficiaries, financial resources are
limited. The available resources will spur the issuance of the Guidelines and help set
up the funds in the participating project provinces.
Sub-component 2c - Information, Education and Communication support to
inform the insured and uninsured about the benefits under the national health insurance
system (US$4.0 million). This sub-component will promote awareness of and enrolment
in health insurance by the near poor by improving IEC activities in provinces. It would
also target the currently enrolled to improve the understanding and awareness of the
benefits available. It would also target the providers to reduce institutional barriers of
access for insured, such as how insured patients are received, medical staff attitudes,
etc... Innovative IEC measures are encouraged to effectively target beneficiaries,
particularly ethnic minority population.
3.
Component Three: Technical Support, Managerial Capacity Building and
Project management, monitoring and evaluation (US$6.00 million): The aim of
this component is to ensure adequate management structure, processes and human
resource capacities for the project, and to setup mechanisms for effective monitoring of
activities and evaluation of results. Under this component, the project would fund the
operation of project management units at the central and provincial levels. To the
extent possible, existing health information systems and data collection mechanisms in
the MoH and in provinces will be relied upon. However, for certain information, it will
be necessary to design specific data collection instruments and conduct independent
data collection and auditing (e.g. small scale household surveys, patient exit
interviews, hospital surveys). M&E will consist of two components: (i) monitoring of the
project’s implementation progress, and (ii) monitoring of the project’s results indicators.
Where the project support pilot initiatives, the project may fund specific evaluations of
the pilots.
2.2
Project Area
The proposed NORRED project will be implemented in 7 provinces in North East
Region (Tuyen Quang, Yen Bai, Thai Nguyen, Lang Son, Bac Giang, Phu Tho, Hoa
Binh) and 6 provinces in Red River Delta (Hai Duong, Hung Yen, Thai Binh, Ha Nam,
Nam Dinh, Ninh Binh). Under component 1, the project will provide province level
hospitals and 50 district hospitals with equipment, education, short-term training and the
supervision support. Under component 2, the project will expand access to health
insurance for near poor households and to improve the system’s capacity to manage
health insurance. All project interventions will be taken place within existing hospitals
which are located in urban areas or in densely populated rural areas. No environmental
protection area or physical cultural resource will be affected.
2.3
Types of potential sub-projects
During implementation, the participating Provinces will submit a proposal for a
“sub-project” to be financed that would indicate explicitly: (a) the Provincial hospital
which would be the ‘investment owner’; (b) services that they want to develop at that
Provincial Hospital (which is on the long-list of eligible services and within their current
technical level); (c) the central level hospital from which they would seek ‘sponsorship’;
(c) the investment needs for those services (within the definition of eligible investments);
(d) the selection of at least 3 district hospitals in rural areas to be supported and for
which the Provincial hospital offers its sponsorship; (d) the identification of services to
be developed in those district hospitals (which is on the long-list of eligible services and
within their current technical level); and (e) the investment needs for the district
hospitals (in accordance with the list of eligible investments).
The project will (i) improve the capacity of province level hospitals to provide
curative health services in five priority service areas (obstetrics/gynecology, pediatrics,
traumatology/orthopedics, cardiology, and oncology); and (ii) strengthen the capacity of
district hospitals to provide curative health services in 3 priority service areas
(obstetrics/gynecology, pediatrics, traumatology). This will be done through provision of
medical equipment and telecommunications equipment, education, short-term training
and the supervision support of the sponsored hospitals via an integrated satellite
program. In addition, the project may provide technical support (technical assistance,
training and study tours) for the establishment of an alternative service delivery model
for services to be provided on an outpatient as opposed to an inpatient basis.
The Province and District hospitals would have to indicate that they have the
necessary minimum conditions for receipt of the services and investments including the
staff with the necessary basic qualifications and the hospital infrastructure. The project
will focus on rehabilitation rather than major construction. Any need for significant
additional staffing or major infrastructure investments would indicate that the hospital
was not ready for investments in those services.
2.4
Project management and personnel
Name of Project: Northern East and Red River Delta Region Health Support Project
Name of Donor: The World Bank (WB) / International Development Agency (IDA)
Line Agency: Ministry of Health (MOH)
a) Contact Address: 138 A Giang Vo Street, Ba Dinh, Hanoi
b) Phone: +84-4-62732273
Fax: + 84-4-: 38464051/84-4-62732266
Email: [email protected]
Project owner: Ministry of Health
The project owner will establish a Central Project Management Unit (CPMU) as
Implementing Agency, to act on behalf of the project owner to organize and manage the
project during the implementation.
Project duration: 5 years: 2013-2018
Total Project Budget: USD $ 157.5 million, of which:
a) ODA Funds: USD $ 150.0 million
b) Counterpart Funds: USD $ 5 million
Type of ODA: ODA concessional loan - IDA Credit
III.
ENVIRONMENTAL POLICIES APPLICABLE TO THE PROJECT
3.1
Vietnamese Environmental policies

Environmental Protection Law (EPL) No 52/2005/QH11 dated 29/11/2005 and in
effect from 01/7/2006. EPL provides frameworks on the responsibilities of individuals
and organizations in environmental assessment, environmental protection in hospitals
and health facilities, and management of hazardous waste, general waste, wastewater
and gas emission.
Policies relating to environmental assessment:

Decree 29/2011/NĐ-CP dated 18/4/2011 regulating strategic environmental
assessment, environmental impact assessment and environmental protection
commitment;

Circular 26/2011/TT-BTNMT dated 18/7/2011 of Ministry of Natural Resource
and Environment regulating in detailed some clauses of Decree 29/2011/NĐ-CP dated
18/4/2011 regulating strategic environmental assessment, environmental impact
assessment and environmental protection commitment;

Circular 01/2012/TT-BTNMT dated 16/3/2012 regulating preparation, appraisal,
approval, inspection and implementation verification of detailed environmental
protection plan; preparation and registration of simple environmental protection plan;
Policies relating to hazardous waste and healthcare waste management:

Decision 170/ QĐ-TTg dated 8/2/2012 of Prime Minister approving Master
projection for solid hazardous healthcare waste treatment system until 2025;

Decision 2038/QĐ-TTg dated 15/11/2011 of Prime Minister approving Master
plan for healthcare waste treatment in period of 2011-2015 and orientation to 2020;

Decision 43/2007/QĐ-BYT dated 3/12/2007 of Minister of Health promulgating
Regulations on healthcare waste management;

Circular 12/2011/TT-BTNMT dated 14/4/2011 of Minister of Natural Resource
and Environment promulgating Regulations on hazardous waste management;

Circular No 18/2009/TT-BYT dated 14/10/2009 of Ministry of Health promulgating
Guidelines for organizing and implementing infection control in health care facilities;

National technical regulations QCVN 02:2008/BTNTM on Healthcare waste
incinerator’s gas emission quality;

National technical regulations QCVN 28:2010/BTNTM on Healthcare wastewater
effluent quality;
Policies relating to working safety:

Decision No 3079 /QĐ-BYT dated 21/8/2008 of Minister of Health promulgating
Regulations on organization and activities of working safety system in health facilities;

Inter-ministerial circular 2237/1999/TTLT/BKHCNMT-BYT dated 28/12/1999
promulgating Guidelines for implementation of radioactive safety in health sector;

Circular 23/2010/TT-BKHCN dated 29/12/2010 of Ministry of Science and
Technology promulgating Guidelines for assuring radioactive source security;

Circular 08/2010/TT-BKHCN dated 22 July 2010 guiding the declaration,
licensing radiation related activities and working staff;

Vietnam standard TCVN 6869:2001: Radiation safety – Medical exposure –
General provisions

Vietnam standard TCVN 6866:2001: Radiation safety – Dose limits for radiation
workers and public

Vietnam standard TCVN 6561:1999: Radiation protection for medical installations
using X-ray machine
National environmental technical standards

QCVN 05:2009/BTNMT-National technical regulations on ambient air quality;

QCVN 06: 2009/BTNMT: National technical regulation on hazardous substances
ambient air

QCVN 07: 2009/BTNMT: National technical regulation on hazardous waste
thresholds
3.2
World Bank environmental safeguard policies



OP/BP 4.01 Environmental Assessment
Public Consultations and Information Disclosure
The World Bank Group Environment, Health and Safety (EHS) General
Guidelines
IV.
Institutional arrangement
MOH and its corresponding Central Project Management Unit (CPMU) will have the
overall responsibility for safeguard implementation. The Provincial Project Management
Units (PPMUs) under Provincial Department of Health (DOH) is responsible for ensuring
safeguard compliance of its subproject at provincial level. The beneficiary hospitals
under each province will be accountable for implementing safeguard requirements of
financed activities. The responsibilities of CPMU, PPMUs, participating hospitals as well
as other stakeholders are described in details below.
4.1
Project hospitals
The financed activities for each hospital are a part of each provincial subproject. The
hospitals are the on-the-ground project developers. The participating hospitals are
responsible for ensuring safeguard compliance during implementation of provincial
subproject and operation of the hospital. These include:
-
-
Collecting and recording all licenses/permits necessary
Preparing site-specific environmental safeguard documents based on the
General safeguard document of provincial subproject.
The site-specific
environmental safeguard documents shall include a hospital waste management
plan for the hospital.
Carrying out mitigation measures to mitigate impacts as specified in the
approved site-specific safeguard documents during subproject implementation
and hospital operation.
4.2
Internal monitoring the implementation of mitigation measures by contractors
Report on environmental compliance of the hospital to PPMU for review
Provincial Project Management Units (PPMUs)
The PPMUs are responsible for ensuring environmental safeguard compliance of
their provincial subprojects. They will assist the project hospitals in all stages of
subproject implementation. They will also consolidate reports from project hospitals and
prepare external monitoring reports with technical assistance provided by consultants
from MOH’s CPMU.
Each PPMU will assign one staff to work on socio-environmental safeguard
aspect. Responsibilities of the socio-environmental staff will include, but not limited to
the followings:
- Screening to determine the eligibility and magnitude of impacts associated with
financed activities of the participating hospital under its province
- Preparing and getting approval of a subproject general safeguard document. The
general safeguard document shall include the health care waste management
plan (HCWM) for the beneficiary hospitals under subproject.
- To ensure that the subproject general safeguard document is disclosed at project
area at timely manner;
- To review to ensure that requirements in subproject general safeguard document
are included in design, bidding document and contracts;
- To provide guidance for participating hospitals to prepare the site-specific
environmental safeguard documents based on the subproject general safeguard
document and specific conditions, focusing on improving management of health
care wastes regarding to current practices at health facilities;
- Reviewing and approving the site-specific safeguard documents prepared by
participating hospitals
- During implementation, periodically supervising the implementation of safeguard
requirements by participating hospitals and contractors.
- Reviewing monitoring reports prepared by participating hospitals. Periodically
report on subproject environmental compliance to CPMU for review.
4.3
To maintain safeguard and other project documents and submit to CPMU
and/or supervision mission when required Central Project Management
Unit
CPMU will coordinate activities to ensure that the provincial subprojects comply
with Vietnamese Environmental management requirements and the Bank’s safeguard
policies. The CPMU will provide support to the PPMUs by appointing environmental
staffs and consultant as necessary to assist the PPMUs to prepare and implement the
project safeguard requirements. The CPMU will also play a key oversight role in
reviewing the safeguard implementation by PPMUs and report to the World Bank on
Project safeguard compliance. Responsibilities of the CPMU will include, but not limited
to the followings:
- Provide training and technical assistance as necessary to strengthen the
capacity of CPMU, PPMUs, hospital staffs on safeguard implementation including
establishment and implementation of healthcare waste management program and
occupational safety;
- Review subproject general safeguard document submitted by each PPMU;
- Supervise safeguard implementation by PPMUs, project hospitals and
contractors in design, and implementation phases;
- Prepare six-monthly environmental report in agreed form and submit to the Bank
prior to its supervision missions;
- Update the ESMF when required, taking into accounts the lessons learnt during
implementation;
- Mobilize resource for HCWM: many of the more costly needed investments will
be outside the scope of the Project. Many technical supports are being prepared and
funding facilities for HCWM improvement are being established under other project of
MOH. These supports will assist the CPMU and PPMUs in participation in and taking
advantages of existing support programs in order to mobilize additional resources for
HCWM in the region as appropriate;
4.4
Provincial People Committees (PPCs)
The Provincial People’s Committee (PPC) shall approve the subproject general
safeguard documents prepared by participating provinces (through provincial
Department of Natural Resources and Environment DONRE). The PPCs shall also
ensure sufficient budget for construction or installation of hospital waste and wastewater
treatment facilities as required.
4.5
The World Bank
During implementation, the WB will provide guidance and technical assistance to
CPMU in project implementation including safeguard execution.
4.6
Contractor and equipment suppliers
To carry out mitigation measures and self-monitoring during implementation of
minor civil work and equipment supply.
4.7
Institutional Capacity
Vietnam government established legal and institutional framework for
environmental protection. Environmental Protection Laws provides the overarching legal
framework; meanwhile, the Regulations on hazardous waste management and
Regulation on healthcare waste management provide health facilities with detailed
guidelines. The Environmental Management Administration under MONRE is
responsible for policy development, registration, authorization and inspection.
Environmental police under Ministry of Public security is responsible for investigating
environmental crimes. The environmental assessment procedures are regulated in
MONRE’s circulars.
Vietnam Health Environment Management Agency under MOH is established to
take responsibilities for environmental protection in health sector. The MOH has carried
out several WB funded project e.g. Mekong Regional Health Support Project, North
Central Regional Health Support Project, Northern Upland Regional Health Support
Project, and therefore has experience of the World Bank’s safeguard policies. In
addition, a major parallel project of the World Bank in “Hospital Waste Management
Support Project” has been implemented and created a wealth of capital, expertise and a
range of guidelines for different kinds of waste and institutions that will be drawn on.
The health sector gets used to environmental procedures of registration,
authorization, monitoring. The challenges for compliance to regulations on healthcare
waste management include (i) limited management capacity, (ii) lacking financial
resource for investment and operation, (iii) improper maintenance. In addition, the staffs
that had experience on safeguard management of these previous projects may not be
available to be assigned as Staff Officer for NORRED project. The current capacity of
CPMU regarding ESMF implementation, therefore, is considered to be limited.
The Project will require the allocation of qualified an environmental
staff/consultant under CPMU to oversee environment and social safeguard issues and
necessary training will be carried out to strengthen capacity of CPMU, PPMU and
hospitals in implementing safeguard requirements.
V.
POTENTIAL ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES
5.1
Project Environmental Category
The NORRED project is classified as Category B according to the World Bank’s
safeguard guidelines.
5.2
Potential Socio - Environmental Impacts
5.2.1 Potential impacts during implementation phase
The project will have some potential negative impacts associated with the
rehabilitation of hospitals during implementation. These include the generation of noise,
dust and vibration, solid waste and waste water and labor safety issues at moderate
level and in short-term period. Construction waste might affect hospital landscape and
environment if they are not collected and disposed properly. Construction workers,
hospital staff, patients and their relatives may risk being fallen down from height or
suffering from falling debris. Because of the small scale of the investments and the
focus on rehabilitation rather than construction, it is unlikely that any investments under
the project will result in impacts on physical cultural resources. However, graves,
cultural or archeological objects may be still exposed during excavation.
5.2.2 Potential impacts in operation phase
a) Increased generation of healthcare waste
The various investments of the project are intended to increase the utilization of
health services and thus it can be expected there will be an increase in volumes of
healthcare waste (HCW) at targeted hospitals. Almost 75-90% of HCW constitutes
general waste and has no higher risk than general municipal solid waste. Hazardous
healthcare waste (HzHCW) which share between 10-25% of total hospital waste by
weight comprise 4 categories: (i) Infectious waste including sharps, non-sharp infectious
waste, pathological waste and highly infectious waste; (ii) Chemical waste including
chemicals commonly used in healthcare, formaldehyde, photochemicals, heavy metals,
pharmaceutical waste and cytotoxic waste; (iii) Radioactive waste; (iv) Pressurized
containers. Healthcare wastes can exist in solid, liquid, gaseous form. Quantity of solid
HzHCW from hospital varies from 0.09 to 0.3 kg/bed/day depending on provision of
medical services and waste management capacity. The hospitals may generate 0.4 –
0.95 m3 of wastewater per bed per day depending on its water supply and use.
Potential health impacts. Exposure to HzHCW can result in health problems. All
individuals exposed to HzHCW are potentially at risk, including those within hospitals
and those outside these sources. The main groups at risk are the following: (i) hospital
staff including doctors, nurses, technicians; (ii) patients visiting the hospitals, patient
relatives and visitors; (iii) workers in support services allied to hospitals such as
laundries, waste handling, and transportation; (iv) workers in waste disposal facilities
(such as landfills or incinerators), including scavengers; (v) community living nearby
hospitals.
Pathogens in infectious waste may enter the human body by a number of routes:
through a puncture, abrasion, or cut in the skin; through the mucous membranes; by
inhalation; by ingestion. Spillage of infectious waste, especially highly infectious waste
can spread pathogens through the hospital, which could result in outbreak of
nosocomial infection among health staff and patients. Sharps may not only cause cuts
and punctures but also infect these wounds if they are contaminated with pathogens.
Sharp injuries are most popular accidents in health facilities. About 80% of occupational
infections of HIV, HBV, and HCV are resulted from injuries by contaminated sharps.
Many of the chemicals and pharmaceuticals used in health-care establishments
are hazardous (e.g. toxic, genotoxic, corrosive, flammable, reactive, explosive, shocksensitive) but commonly present in small quantities. Acute or chronic exposure to
chemical may cause intoxication that can result from absorption of a chemical or
pharmaceutical through the skin or the mucous membranes, or from inhalation or
ingestion. Injuries to the skin, the eyes, or the mucous membranes of the airways can
be caused by contact with flammable, corrosive, or reactive chemicals (e.g.
formaldehyde and other volatile substances).
Cytotoxic waste and radioactive waste are generated from oncology department.
Many cancer treatment drugs are cytotoxic. They may be irritant and have harmful local
effects after direct contact with skin or eyes, and may also cause dizziness, nausea,
headache, or dermatitis. Hospital staff can expose to antineoplasma drugs by are
inhalation of dust or aerosols, absorption through the skin, ingestion of food accidentally
contaminated with cytotoxic drugs. The type of disease caused by radioactive waste is
determined by the type and extent of exposure. It can range from headache, dizziness,
and vomiting to much more serious problems. Because radioactive waste is genotoxic,
it may also affect genetic material.
Wastewater from hospitals is of a similar quality to urban wastewater. The
principal area of concern is high content of enteric pathogens which are easily
transmitted through water. If healthcare waste is not well managed, hospital wastewater
contains significant amount of pharmaceuticals, chemicals, even cytotoxic substances
and radioactive isotopes if oncology services are delivered.
Potential environmental impacts. Unsafe disposal of solid HCW including
incinerator ash and sludge from wastewater treatment plant is very problematic as
pollutants from landfill sites have been known to seep out, polluting soil and local water
sources which have long-term health impacts. Water resources may become
contaminated by certain hazardous materials contained in hospital wastes. They can
contain water-borne transmitted pathogens. They may contain heavy metals, largely
mercury from thermometers and silver from the processing of X-ray films. Certain
pharmaceuticals, if deposited without treatment, may also cause toxic agents to leach
into water supplies. In addition, the leachate generated by the biological degradation of
clinical wastes has the potential to cause water contamination, by reason of its high
BOD. The risk of air pollution arises largely from the fact that most hazardous wastes
are incinerated or burnt. Many existing hospital incinerators do have a potential
pollution. Improper design, poor operation and maintenance of incinerators may result in
the emission of a wide range of pollutants besides dioxins and furans, including include
heavy metals (lead, mercury and cadmium), fine dust particles, hydrogen chloride,
sulphur dioxide, carbon monoxide, and nitrogen oxides.
Public sensitivity. In addition to health and environmental impacts, the general
public is very sensitive about the visual impact of anatomical waste that are
recognizable human body parts including fetuses. In no circumstances is it acceptable
to dispose of anatomical waste inappropriately, such as on a landfill.
b) Exposure to ionizing radiation
Radiation causes ionizations in the molecules of living cells. The ions formed
then can go on to react with other atoms in the cell, causing damage. They may also
affect genetic material. The type of disease caused by ionizing radiation is determined
by the type and extent of exposure. Exposure to ionizing radiation includes medical
exposure, occupational exposure and public exposure. At higher doses (up to 100 rem),
the cells might not be able to repair the damage, and the cells may either be changed
permanently or die. Cells changed permanently may go on to produce abnormal cells
which may become cancerous. This is the origin of increased risk in cancer, as a result
of radiation exposure. At even higher doses (>100 rem to whole body), tissues fail to
function, resulting in "radiation sickness" such as nausea, diarrhea and general
weakness. With higher whole body doses (>300 rem), the body's immune system is
damaged and cannot fight off infection and disease. At whole body doses near 400 rem,
if no medical attention is given, about 50% of the people are expected to die within 60
days of the exposure, due mostly from infections.
5.3
Typical Mitigation Measures
The project potential socio-environmental impacts can be mitigated through the
implementation of standard mitigation measures during design or implementation and
operation phases as described below. The mitigation measures during detail design
shall be carried out by detailed design consultant. During implementation, the mitigation
measures for generic impacts relevant to generation of dust, noise, vibration, solid
waste and labor safety shall be carried out by contractors and included in the
construction contract. The mitigation measures during operation shall be carried out by
beneficiary hospitals.
The Table below lists typical mitigation measures, which was developed with the
aims of supporting PPMU to prepare subproject general environmental safeguard
documents (IESD) which includes the HCWM. Sub-project general environmental
safeguard should include additional mitigation measures (not listed below) as needed
and required.
Table 1: Standard Mitigation measures in sub-project design phase
Socio-environmental
issues
1. Radiation facility
and equipment do not
meet minimum
requirements for
radiation protection
and safety
Mitigation measures




All hospitals receiving support in radiotherapy shall
comply with Vietnamese regulations and international
basic standard for protection against Ionizing radiation;
The sitting, location, design, construction, assembly,
commissioning,
operation,
maintenance
and
decommissioning of source within practices shall be
based on sound engineering which shall take account
of approved codes and standards (TCVN 6561:1999,
TCVN
6869:2001;
Inter
ministerial
circular
2237/1999/TTLT/BKHCNMT-BYT e.g.);
Equipment consisting of radiation generators or
containing the sealed sources needed for medical
exposure shall (i) conform to TCVN 6869:2001 and
applicable standards of the International Electrotechnical Commission (IEC) and the International
Organization for Standardization (ISO); (ii) conform to
performance specifications, including protection and
safety instructions, provided in a major world language
understandable to the users and in compliance with the
relevant IEC or ISO standards with regard to
accompanying documents, and translated into
Vietnamese; personal protective equipment which
meets Vietnam standard TCVN 6561:1999 shall be
included in radiation equipment set.
The occupational exposure of any worker and the
public exposure any member of pubic shall be so
controlled that dose limits in TCVN 6866:2001 be not
exceeded;
Applicable
regulations
Inter-ministerial
circular
2237/1999/TTLT/
BKHCNMT-BYT:
Guidelines for
implementation of
radioactive safety
in health sector;
Circular
23/2010/TTBKHCN:
Guidelines for
assuring
radioactive
source security;
TCVN 6869:2001:
General
regulations on
radioactive safety
in health radiation
TCVN 6561:1999:
Ionizing radiation
safety in X ray
radiology facility
in health facility
Specify in
Sub-project
detailed
design
Applicable
subprojects
Sub-projects
supporting
radiotherapy
(oncology
services) in
provincial
level
hospitals
Table 2: Standard Mitigation measures in sub-project implementation phase (ECOPs)
(Environmental Codes of Practices performed by contractors)
Socio-environmental
issues
2. Dust, noise and
vibration generated
from construction site
and construction
activities
Mitigation measures







The Contractor is responsible for compliance with
relevant Vietnamese legislation with respect to ambient
air quality, noise and vibration.
The Contractor shall ensure that the generation of dust
is minimized and implement a dust control plan to
maintain a safe working environment and minimize
disturbances for patients, staff and surrounding
residential areas.
The Contractor shall implement dust suppression
measures (e.g. water paths, covering of material
stockpiles, etc.) as required. Material loads shall be
covered and secured properly during transportation to
prevent the scattering of soil, sand, materials, or dust.
Exposed soil and material stockpiles shall be protected
against wind erosion and the location of stockpiles shall
take into consideration the prevailing wind directions
and patient wards.
The Contractor shall ensure dust masks be used by
workers where dust levels are excessive.
The Contractor shall implement measures to reduce
noise to acceptable levels including silencers, mufflers,
acoustically dampened panels or placement of noisy
machines in acoustically protected areas.
The Contractor shall avoid or minimize transportation of
materials though and placement of material processing
facilities (cement mixing) in patient crowded areas
The Contractor shall not carry out construction activities
generating high level of noise before 6 am, after 9 pm
and during lunch time.
Applicable
regulations
QCVN
05:2009/BTNMT:
National technical
regulation on
ambient air
quality
QCVN
26:2010/BTNMT:
National technical
regulation on
noise
QCVN
27:2010/BTNMT:
National technical
regulation on
vibration
Specify in
Construction
bidding and
contract
Applicable
subprojects
Sub-projects
supporting
renovation
Socio-environmental
issues
3. Construction waste
generated from
construction activities
Mitigation measures








The Contractor shall develop a solid waste control
procedure (storage, provision of bins, site clean-up
schedule, bin clean-out schedule, etc.) before
construction and strictly comply with developed
procedure during construction activities.
The Contractor shall obtain all necessary waste
disposal permits or licenses before construction.
The Contractor shall provide litter bins, containers and
waste collection facilities at all places of work.
The Contractor store solid waste temporarily on site in
a designated place prior to off-site transportation and
disposal through a licensed waste collector.
The Contractor shall dispose of waste at designated
place identified and approved by the Construction
Supervision Consultant or local authority. Opened burn
or bury of solid waste in hospital shall not be allowed.
Under no circumstances shall the contractor dispose of
any material in environmentally sensitive areas, such
as watercourses
Recyclable materials such as wooden plates for trench
works, steel, scaffolding material, site holding,
packaging material, etc. shall be segregated and
collected on-site from other waste sources for reuse or
recycle (sale).
Maintenance of vehicles and machines that may
generates used oil, lubricants, cleaning materials, etc.
shall be carried out in licensed workshop, not in
hospital. Chemical waste of any kind shall be disposed
of at an approved appropriate landfill site and in
accordance with local legislative requirements.
The removal of asbestos-containing materials or other
toxic substances shall be performed and disposed of by
specially trained and certified workers.
Applicable
regulations
Decree
59/20078/NĐ-CP
on solid waste
management
Specify in
Construction
bidding and
contract
Applicable
subprojects
Sub-projects
supporting
renovation
Socio-environmental
issues
4. Localized flooding
due to wastewater
from construction site
and blocked drainage
Mitigation measures




5. Safety risks to
construction workers,
hospital staff, patients
and their relatives




6. Chance-find
procedures
Applicable
regulations
The Contractor shall follow the detailed drainage
design included in the construction plans, intended to
prevent storm water and waste water from causing
local flooding.
The Contractor shall install drainage lead water from
construction site to water receivers
The Contractor shall ensure drainage system
maintained and cleared of mud and other obstructions.
The Contractor shall install sediment control structures
where needed to slow or redirect runoff and trap
sediment. Sediment control structures could include
windrows of logging slash, rock berms, sediment
catchment basins, straw bales, storm drain inlet
protection systems, or brush fences.
QCVN
08:2008/BTNMT:
National technical
regulation on
quality of surface
water
The Contractor shall comply with all Vietnamese
regulations regarding worker safety.
The Contractor shall prepare and implement action
plan to cope with risk and emergency
The Contractor shall provide workers with training on
occupational safety regulations and personal protective
equipment
The contractor shall provide safety measures as
installation of fences, use of restricted access zones,
warning signs, lighting system to protect workers,
hospital staff and patients against falling debris and
other risks.
Decree No.
22/2010/TT-BXD
on regulation of
construction
safety
If the Contractor discovers archeological sites, historical
sites, remains and objects, including graveyards and/or
individual graves during excavation or construction, the
Contractor shall:
 Stop the construction activities in the area of the
chance find;
Specify in
Applicable
subprojects
Construction
bidding and
contract
Sub-projects
supporting
renovation
Construction
bidding and
contract
Sub-projects
supporting
renovation
Construction
bidding and
contract
Sub-projects
supporting
renovation
Instruction No.
02/2008/CT-BXD
on safety and
sanitation issues
in construction
agencies
Instruction No.
02/2008/CT-BXD
on safety and
sanitation issues
in construction
agencies
Law on Cultural
Heritage (2002)
Law on Cultural
Heritage (2009)
for supplementary
Socio-environmental
issues
Mitigation measures








Delineate the discovered site or area;
Secure the site to prevent any damage or loss of
removable objects.
Notify the Construction Supervision Consultant who in
turn will notify responsible local or national authorities
in charge of the Cultural Property of Viet Nam (within
24 hours or less);
Relevant local or national authorities would be in
charge of protecting and preserving the site before
deciding on subsequent appropriate procedures. This
would require a preliminary evaluation of the findings to
be performed. The significance and importance of the
findings should be assessed according to the various
criteria relevant to cultural heritage; those include the
aesthetic, historic, scientific or research, social and
economic values;
Decisions on how to handle the finding shall be taken
by the responsible authorities. This could include
changes in the layout conservation, preservation,
restoration and salvage;
If the cultural sites and/or relics are of high value and
site preservation is recommended by the professionals
and required by the cultural relics authority, the
Project’s Owner will need to make necessary design
changes to accommodate the request and preserve the
site;
Decisions concerning the management of the finding
shall be communicated in writing by relevant
authorities;
Construction works could resume only after permission
is granted from the responsible local authorities
concerning safeguard of the heritage.
Applicable
regulations
and reformation
Decree No.
98/2010/ND-CP
for supplementary
and reformation
Specify in
Applicable
subprojects
Table 3: Standard Mitigation measures in operation phase
Socio-environmental
issues
7. Solid healthcare
waste generated from
healthcare activities
Mitigation measures







All beneficiary hospitals shall comply with Vietnamese
regulations and World Bank guidelines relating
healthcare waste management (HCWM)
Each beneficiary hospital shall prepare a facilityspecific Environmental Management Plan (EMP)
focusing on healthcare solid waste and wastewater
management;
Each hospital under the project shall form a HCWM
team or Infection Control team responsible for
preparing and implementing EMP, as well as
monitoring and supervising EMP implementation;
A solid HCWM system established and maintained in
each hospital under the project shall include: (i)
segregation of waste at source; (ii) on-site collection,
transportation, storage of waste; (iii) off-site
transportation of waste; (iv) treatment and final disposal
of waste; (v) reduction, reuse and recycle of waste.
Healthcare solid waste shall be segregated into 5
categories: infectious waste (sharp, non-sharp, highly
infectious and anatomical waste), hazardous chemical
waste, radioactive waste, pressurized containers and
general waste. Wastes generators must carry out
segregation at their generation places.
Each category of waste must be contained in bags/bins
with coded color; labeling and technical specifications
in line with the Regulations on HCWM (see Annex 4).
Waste bags shall be tied up and collected when they
are filled to 3/4 of capacity. Assigned hospital orderly or
environmental workers take the responsibility for
collecting waste from generation places to interim
storage in the department. Each department shall
Applicable
regulations
Environmental
Protection Law
2005
Circular No
18/2009/TT-BYT:
Guidelines for
organizing and
implementing
infection control in
health care
facilities
Decision
43/2007/QĐ-BYT:
Regulations on
healthcare waste
management;
Circular
12/2011/TTBTNMT:
Regulations on
hazardous waste
management
Specify in
Environmental
management
plan
Applicable
subprojects
All subprojects
Socio-environmental
issues
Mitigation measures




clearly determine locations for placement of waste bins.
Hazardous waste and general waste shall be
separately transported to waste storage area in hospital
at least once per day and when needed. The hospital
shall stipulate routes and time for the transportation of
waste. Waste bags shall be tied up and transported by
specialized transport devices to avoid leakage or
spillage of waste during transportation.
At storage places, hazardous waste and general waste
shall be kept in separate rooms and in specific
equipment to avoid leakage and spillage into
environment. The maximum duration for storing
healthcare waste in hospital is 48 hours or 72 hours in
cold warehouse/cabinet. If hazardous waste needs to
be stored more than 06 months, hospital shall inform to
and get approval of environmental authority. Storage
house and equipment shall meet technical
specifications described in Regulations on HCWM and
hazardous waste management (see Annex 4)
Hazardous waste can be treated and disposed through
3 models: (i) centralized model; (ii) clustering model;
and (iii) on-site model. According to Government
master projection (Decision 170/QD-TTg), the hospitals
in Red River Delta and North East Regions are planned
to move towards clustering treatment model by 2015
and centralized treatment model by 2025.
In case of off-site treatment, the transfer of the
hazardous waste treatment responsibility between the
generator and the party receiving such responsibility
shall be affected under contracts certified by provincial
environmental protection agencies. The facility
providing healthcare waste treatment services to
healthcare establishments shall have license for
hazardous waste management practice
Applicable
regulations
Decision
170/QĐ-TTg:
Master projection
for solid
hazardous
healthcare waste
treatment system
until 2025
Specify in
Applicable
subprojects
Socio-environmental
issues
Mitigation measures



8. Wastewater
generated from
hospitals




Hazardous healthcare waste shall be treated by
allowed technologies including disinfection by wet
thermal, disinfection by microwave irradiation,
incineration in high-temperature incinerator, hygienic
landfill, concrete bury pit, inertization, return to supplier
and others based on waste hazards and
characteristics. Opened burn and opened bury onsite
are not allowed. Burying in hygienic landfill or concrete
pit is acceptable in rural areas. Once incineration
method is applied, shall meet Vietnam regulations on
design and gas emission, and take measures to control
secondary pollution. Non-burn technologies that are
environmentally sound are encouraged to apply.
The hospitals shall reuse equipment, instruments and
materials following sterilization and disinfection. If
reused, plastic containers of sharp waste shall be
cleaned, disinfected prior reuse.
Waste recycle is encouraged, however, it is only
permitted to recycle non-hazardous healthcare waste
such as plastic bottles, glass bottles, glass jar of
injection medicine, paper, cardboard, metal cans e.g.
Recycling healthcare
waste
contaminated by
hazardous elements shall be prohibited.
Each hospital under the project shall have a
synchronous system of waste water collection and
treatment.
Wastewater collection network of contaminated
wastewater shall be separated from raining water
collection network, underground or covered by caps.
Hospital shall install wastewater treatment plant
meeting Vietnam standard (TCVN 7957:2008) on
design.
The hospital shall operate the wastewater treatment
Applicable
regulations
QCVN
02:2008/BTNTM:
National technical
regulations on
Healthcare waste
incinerator’s gas
emission quality;
Specify in
TCVN 7380:2004:
technical
requirements for
healthcare waste
incinerator
Decision
43/2007/QĐ-BYT:
Regulations on
healthcare waste
management;
TCVN 7957:2008:
wastewater
external network
and facilities –
Environmental
management
plan
Applicable
subprojects
Socio-environmental
issues



9. Risks associated
with exposure to
hazards in hospital
environment
Applicable
regulations
plant daily and maintain it properly according to Design standard
manufacturer’s instruction;
Hospital wastewater effluent shall meet National
technical regulation QCVN 28:2010/BTNMT on QCVN
healthcare wastewater quality. The hospital shall get 28:2010/BTNTM:
DONRE’s license for discharge wastewater into National technical
regulations on
environment.
Sludge shall be considered as hazardous waste and Healthcare
managed according to solid waste management wastewater
effluent quality
regulation.
Hospital shall employ measures to minimize entry of
hazardous solid waste and large quantities of
pharmaceuticals or chemicals into wastewater stream
Mitigation measures





All hospitals under the project shall comply with
Vietnamese regulations on working hygiene, safety and
occupational health
Each hospital under the project shall establish and
maintain a working safety system including working
safety team, working safety network in departments
and occupational health unit in line with Decision
3079/QĐ-BYT
Hospitals under the project shall provide healthcare
professionals and waste workers with sufficient training
on healthcare waste management and occupational
safety regulations
Hospitals under the project shall provide healthcare
professionals and waste workers with appropriate
personal protective equipment.
Interim storage area and treatment facilities of
hazardous healthcare waste in project hospitals shall
be provided with firefighting equipment (extinguisher,
sand e.g.), first aid box, materials and tools for
response to leakage and spillage,
abridged
Specify in
Environmental
management
plan
Decision No
3079/QĐ-BYT:
Regulations on
organization and
activities of
working safety
system in health
facilities
Circular
12/2011/TTBTNMT:
Regulations on
hazardous waste
management
Applicable
subprojects
All subprojects
Socio-environmental
issues
Mitigation measures


10. Risks associated
with exposure to
ionizing radiation




instructions of safe operating procedures and accident
response, regulations on working safety and health
protection.
Hospital under the project shall develop procedures for
response to exposure to blood, body fluid or sharp
injury. Counseling and prophylaxis treatment of
occupational infections such as HIV/AIDS or Hepatitis
B shall be offered to health and waste workers in case
of high risk of acquired infection.
Hospitals under the project shall provide their staff with
annual medical check, regular occupational disease
diagnosis and monitoring; and manage records, report
statistics on occupational health and working accidents
in line with Circular 19/2011/TT-BYT and interministerial Circular 12/2012/TTLT-BLĐTBX-BYT.
All hospitals receiving support in radiotherapy shall
comply with Vietnamese regulations and international
basic standard for protection against Ionizing radiation
and for the safety of radiation sources;
Hospital offering radiotherapy shall notify DOST within
15 days after receipt of radioactive equipment; get
license from DOST prior to commencement of
radiotherapy provision; make inventory and report to
DOST regularly;
Hospital offering radiotherapy shall assign a radiation
protection officer who is trained on radiation safety by
authorized training institution. Responsibilities for
radioactive source security and radiation safety shall be
clearly defined;
All involved staff (radiotherapy practitioners, nurses,
source handlers, patient transporters, maintenance
engineers, waste collectors e.g.) shall be trained and
qualified so that they understand their responsibilities
Applicable
regulations
Specify in
Applicable
subprojects
Circular
19/2011/TT-BYT:
guidelines for
management of
working hygiene,
occupational
health and
disease
Inter-ministerial
circular
2237/1999/TTLT/
BKHCNMT-BYT:
Guidelines for
implementation of
radioactive safety
in health sector;
Circular
23/2010/TTBKHCN:
Guidelines for
assuring
radioactive
source security;
TCVN 6869:2001:
General
Environmental
management
plan
Sub-projects
supporting
radiotherapy
(oncology
services) in
provincial
level
hospitals
Socio-environmental
issues
Applicable
regulations
and perform their duties with appropriate judgment and regulations on
according to defined procedures;
radioactive safety
Radioactive sources shall be kept secure so as to in health radiation
prevent theft or damage in accordance with Circular TCVN 6561:1999:
23/2010/TT-BKHCN;
Ionizing radiation
Equipment consisting of radiation generators or safety in X ray
containing the sealed sources needed for medical radiology facility
exposure shall conform to performance specifications, in health facility
operating and maintenance instructions, including
TCVN 6867-1:
protection and safety instructions;
The commissioning, operation, maintenance and 2001: Radiation
decommissioning of source within practices shall be safety. Safe
based on sound engineering which shall take account transportation of
of approved codes and standards (TCVN 6561:1999, radioactive
TCVN
6869:2001;
Inter
ministerial
circular substances. Part
1: general
2237/1999/TTLT/BKHCNMT-BYT e.g.);
Guidance levels for medical exposure and optimization regulations
of protection for medical exposure which are
established by TCVN 6869:2001 shall be complied;
The occupational exposure of any worker shall be so
controlled that dose limits in TCVN 6866:2001 be not
exceeded;
Workers shall be provided with suitable and adequate
personal protective equipment which meets Vietnam
standard TCVN 6561:1999.
The public exposure any member of pubic Public
exposure shall be so controlled that dose limits in
TCVN 6866:2001 be not exceeded;
Radioactive waste and wastewater shall be stored in
necessary time for them to decay to allowable limit
before discharge into environment. Radioactive
wastewater (including excreta of patients receiving
radioactive medicine) shall be contained in 1 of 2
Mitigation measures








Specify in
Applicable
subprojects
Socio-environmental
issues
Mitigation measures


separated, radiation resistant underground tanks. One
tank receives radioactive wastewater daily; the other
tank contains radioactive wastewater until discharge.
Radioactive waste is collected in black plastic bags and
placed in metal containers. Radioactive waste is
collected daily and stored in radiation resistant tanks in
necessary time until discharge into environment;
Safety assessment related to protection and safety
measures for sources within practices shall be made at
different stages. Monitoring and measurement shall be
conducted of the parameters necessary for verification
of compliance with the requirements of the standards;
Records shall be maintained of the results of
monitoring and verification of compliance, including
records of the tests and calibrations carried out in
accordance with standards;
Applicable
regulations
Specify in
Applicable
subprojects
VI.
ENVIRONMENTAL MANAGEMENT PROCEDURES
6.1
Documentation requirements
The subproject general safeguard documents will prepared, reviewed and
approved in accordance with the applicable existing Vietnamese environmental
regulations (Decree No29/ND-CP dated 18 April 2011 and Circular No 26/TT-BTNMT
dated 29 July 2011).
So far, the details activities of subprojects of participating provinces have not yet
been fully identified. Depending on the investment scale, magnitude of impacts, the
environmental safeguard requirements may be varied among subprojects. According to
the national regulations, some subprojects require an environmental subsection
included in the Economic-Technical Report (ETR) or Feasibility Study (FS) Report while
for the others, a stand-alone safeguard document e.g. Environmental Protection
Commitment (EPC) would be required.
According to the World Bank requirements, the preparation and implementation
of an environmental management plan (EMP) which includes an HCWM plan is
adequately for addressing potential impact during subproject implementation.
To address inconsistency and to ensure that the subproject implementation will
strictly follow national environmental regulations and WB safeguard policies, that under
the NORRED project, it is requested the an subproject general safeguard document
prepared by PPMUs shall include an Environmental Management Plan (EMP) covering
the HWM plan, which is acceptable by the Bank and with format acceptable to
Vietnamese local authority. The subproject general safeguard documents can be a
stand-alone document or included into the form of environmental section of the ETR/FS.
A template for the EMP to be included in the subproject general Safeguard
document is described in Annex 3.
6.2
Project Environmental Management Procedures
Under the NORRED project, PPMU or its consultant will make sure that
environmental section of the ETR/FS or a stand-alone Environmental report of each
subproject shall include an Environmental Management Plan (EMP) with contents
acceptable to the Bank and with format acceptable to Vietnamese local authority.
The EMP will also be included into design contract, construction bidding and
contractual documents, and in construction supervision contract. Project costs will cover
the costs for EMP implementation and monitoring.
Table 4 below listed the activities to be undertaken by various project
stakeholders at each step of subproject implementation.
Table 4: Project Environmental Management Procedures
Project cycle
Environmental action
required
Implemented by
Monitored/
checked by
1. Sub-project
identification
1.1 Environmental Eligibility
Screening:
PPMU
Environmental Staff
CPMU
2. Preparation of
Economic –
Technical
Report or FS
2.1 Environmental Impacts
Screening
PPMU / Project
Preparation
Consultant
CPMU
Environmental
staff
2.3 Prepare site-specific
safeguard documents
covering HCWM plan each
hospital
Hospital
PPMU
2.4 Carry out Public
Consultations, prepare
meeting minutes and list of
participants
PPMU / Project
Preparation
Consultant
CPMU
Environmental
staff
2.6 Include requirements in
the general safeguard
document into relevant
project documents to get
approval from local
authorities, and NOL from
WB if required
PPMU
Relevant local
authority to
carry out priorreview
2.7 a. EMP disclosure: A
copy of subproject general
safeguard document is sent
PPMU
CPMU
2.2 Prepare and subproject
general safeguard
document. The subproject
general safeguard
documents shall include an
EMP/HCWM plan
WB check
randomly
2.5 Include solutions to
address community
concerns into final EMP.
Consultation records is filed
for submission when
required.
WB check
Project cycle
Environmental action
required
Implemented by
to Project Commune
People’s Committee (CPC)
for Disclosure at public
accessible place. Written
confirmation by CPMU is
sent to PPMU.
Monitored/
checked by
during
supervision
2.7 b. Include relevant
clauses into Specifications
for Engineering Design
Bidding documents and
contract
Consultant
3. Engineering
Design
3.1 Incorporate mitigation
measures presented in the
EMP into design
Design Consultant
PPMU
Environmental
staff
4. Sub-project
implementation
4.1 Include relevant EMP
requirements into
construction/supervision
bidding documents and
contract
PPMU
PPMU
Environmental
staff
4.2 Implement mitigation
measures applicable to
construction phase
Contractors
Construction
Supervisor
PPMU
Environmental staff
PPMU
Hospital
Local
community
4.3 Carry out environmental
monitoring and supervision
- Self-monitoring by
contractor
- Frequent
monitoring by
construction
supervision as
necessary
- Internal monitoring
by hospital
PPMU
local authority
WB
Construction
Supervisor
PPMU
Local
community
- Periodic monitoring WB random
checks
by PPMU
Project cycle
Environmental action
required
Implemented by
Monitored/
checked by
- Random monitor
by CPMU
- Local community
monitoring
4.3 Reporting:
Report on implementation of
mitigation measures. This
report shall be part of
contractor progress report
5. Operation
Contractors report to
Construction
supervisors/PPMU
PPMU
Report on carrying out
Hospitals,
environmental compliance by construction
contractors
supervisors report to
PPMU
PPMU
Report on environmental
compliance of subproject
PPMU report to
CPMU
CPMU
5.1 Implement healthcare
waste management plan as
specified in the subproject
general and site-specific
safeguard document
Hospital
PPMU during
project period
5.2 Carry out environmental
monitoring and supervision
Hospital
local authority
WB random
check
local authority
PPMU during
project period
WB random
check
5.3 Incorporate healthcare
waste management into subproject progress report
Hospital
PPMU during
project period
local authority
WB random
check
6.2.1 Environmental Screening for eligibility
PPMU fill in Environmental Eligibility Screening Form (shown in annex 1) and
attach to the list of subprojects sent to CPMU for review. WB will randomly check the
screening form and advise CPMU/ PPMU about the list of subprojects that WB requires
prior-review, i.e. EMP should be submitted for the Bank to review and no-objection.
Remaining subprojects will be subjected to post-review.
Environmentally, a subproject will not be eligible for inclusion in the NORRED if:

It is a major hospital infrastructure

It cause land acquisition and involuntary resettlement, triggering the Bank’s
Policy on Involuntary Resettlement

Cause relocation of known cultural heritages such as pagodas, temples,
churches, shrines, graves or object of spiritual important to local community, triggering
the Bank’s policy on Physical Cultural Resources
At subproject-identification stage, CPMU staff who responsible for environmental
safeguard issues will carry out screening to identify environmental eligibility of proposed
sub-projects. Only eligible subprojects will be financed under the NORRED project.
Guidance on how to carry out environmental screening is described in Section V.
6.2.2 Impact identification
For each eligible sub-project, PPMU fill will answer the questions provided in
Environmental Impacts Screening Form (provided in Annex 2) to determine the impacts
potentially occurred during the implementation and operation of a proposed subproject.
This is the basis for the preparation of sub-project safeguard document discussed in
5.2.3.
6.2.3 Drafting Subproject Safeguard Document
PPMU or its consultant will prepare a subproject General Safeguard Document
including EMP/HCWM Plan for each subproject. The EMP will include two parts,
mitigation program and environmental monitoring. EMP should be presented using the
format introduced in Annex 3 of the ESMF.
Before implementation of hospital activity, the participating hospital will prepare a
site-specific safeguard documents including HCWMP to address any potential impacts
associated with investment activities.
6.2.4 Public Consultation and information disclosure
At subproject-level
After the draft General Safeguard document including EMP and HCWM Plan is
prepared, related PPMU or its consultants will conduct a consultation meeting with
project affected groups. Consultation can be either in the form of questionnaire or
community meeting. At the consultation meeting, representatives from affected groups
will be informed about the project’s potential environmental impacts and mitigation
proposed to mitigate these impacts. Representatives from affected groups will be asked
to comment on the impacts/mitigation measures or talk about their socio-environmental
concerns related to project activities. The purpose of the consultation is to identify
environmental issues of concerns to project affected groups so that they may be
included in the subproject general safeguard documents. Community consultation
activities will be documented with date and location of consultation meeting, and
comments received from affected people. Documentation of the consultation should be
included as attachment in safeguard documents. Form of public consultation records is
provided in Annex 4 of the ESMF.
For each subproject, the General Safeguard Document including EMP/HCWM
Plan will be disclosed at commune level for public access during project preparation
stage. A full package including safeguard documents, Environmental Management
Plan, environmental certificate, records of public consultations will be sent to the Bank
for disclosure at VIDIC prior to appraisal of Economic-Technical Report or Feasibility
Study.
At Project level
During preparation of ESMF, meaningful consultations have been conducted with
participating provinces, MOH staffs. Thirteen provinces conducted rapid assessment on
healthcare waste management in their province based on self-administrated
questionnaires. The ESMF was disseminated to relevant agencies within MOH including
Vietnam Health Environment Management Agency for review. The concerns from
stakeholders have been incorporated into the final ESMF.
At Project level, prior to appraisal, the final draft ESMF has been disclosed locally
at the MOH office and Vietnam Development Information Center (VDIC) in Vietnamese
language in January 2012. It has been disclosed in WB InfoShop in Washington DC in
English language before the departure of appraisal mission.
6.2.5 EMP review and Approval
For all subprojects, PPMU do review of environmental documents and relevant
local authorities do approval in accordance with existing Vietnamese environmental
management regulations. The Bank will do prior review on screening results and up to
20% of general safeguard document prepared for subprojects.
If a stand along safeguard document is required by local authority, the final
submission to the Bank for prior-review the CPMU should provide evidence (e.g. copies
of the letters of approval, environmental certificate) that all necessary approvals of the
EMP has been obtained from the responsible Vietnamese authorities.
6.2.6 Licenses and Permits
It is the responsibility of PPMU to secure and maintain any necessary licenses or
permits which are either issued by or require approval of any Vietnamese environmental
authorities during subproject implementation.
All project hospitals shall have registration of hazardous waste generator, license
for discharge of wastewater into environment and license for solid waste treatment (if
required). Project hospital offering radiation therapy shall obtain notification of
radioactive source and apply to Provincial Department Science and Technology for
license of radiation therapy.
6.2.7 Supervision and environmental monitoring
During subproject implementation, the PPMUs or their construction supervision
consultants will be responsible for day to day supervision of mitigation compliance and
monitoring activities which have been identified in EMP. Local communities are
encouraged to undertake monitoring. If there are complaints from local project-affected
groups, the PPMU should be prepared to send staff in a timely fashion to assess the
validity of complaints and take any necessary actions to remedy the situation. Reporting
on the implementation of the EMP should be sent to the Bank as part of the progress
reports prior to the Bank’s semi-annual supervision missions. CPMU is responsible to
provide technical guidance as needed to PPMUs to enable them fulfill their supervision
responsibilities and related reporting and documentation requirements. Hospital will be
responsible for supervision the implementation of safeguard compliance of contractor at
its area.
The project hospitals are responsible for monitoring healthcare waste and
wastewater generation, handling, treatment and disposal. They are also responsible for
monitoring impacts of healthcare solid waste, wastewater and gas emission to ambient
air and occupational health.
6.2.8 Documentation and record keeping
CPMU and the PPMU of related provinces and beneficiary hospitals are
responsible to record and keep all safeguard documentation (Environmental screening
forms, EMP, consultation records, confirmation on public disclosure, environmental
monitoring records etc.) related to subproject investment. Safeguard implementation is
a part of progress implementation report that CPMU will submit to the Bank prior to
supervision mission.
6.3
Capacity building/Training plan
Based on actual demands in ESMF implementation, a capacity building and
training program for relevant agencies will be established. The content and cost for
capacity building program is described in Annex 8.
6.4
Cost for safeguard implementation
The cost for safeguard implementation is included in the Project cost and is
described in Annex 8. The project includes US $ 300,000 for technical assistance and
training activities related to safeguard implementation including health care waste
management. Financing for healthcare waste management equipment and facilities in
the second stage of implementation will be determined based on demand from project
hospitals and local authorities in accordance with their needs and priorities.
Annex 1 – Environmental Eligibility Screen Form
PPMU ………………………………………
Hospital 1
Hospital 2
Hospital 3
Hospital 4
Hospital 5
Hospital 6
Eligibility screening for sub-project
…………….
…………….
…………….
…………….
…………….
…………….
I
Yes
Yes
Yes
Yes
Yes
Yes
Question
No
No
No
No
No
1.1 Is the subproject a major hospital
infrastructure?
1.2 Will the subproject cause:
a
land acquisition and/or involuntary
resettlement?
b
relocation of known cultural
heritages such as pagodas, temples,
churches, shrines or object of
spiritual important to local
community
II
Eligibility:
At least one above answer was “yes”
 the subproject is not eligible
All the above answers were “no”
 the subproject is eligible
Date: ..../……/…….
Screened by
(full-name and signature)
Verified by PPMU director
(full-name, signature and stamp)
No
Annex 2 – Environmental Impact Screening Form
Potential impact
Socio-environmental issues
Comments
Yes
Will the sub-project implementation and
associated activities cause:
1. Dust, noise and vibration generated from
construction site and construction activities
2. Construction waste generated from
construction activities
3. Localized flooding due to wastewater
from construction site and blocked drainage
4. Safety risks to construction workers,
hospital staff, patients and their relatives
5. Graves, cultural or archeological objects
are exposed
6. Other issues (pleased specify)
…………………………………………………..
Will the hospital operation cause:
7. Increased generation of solid healthcare
waste from healthcare activities
8. Increased generation of wastewater from
hospital
9. Increased risks associated with exposure
to hazards in hospital environment
10. Increased risks associated with
exposure to ionizing radiation
11. Other issues (please specify)
………………………………………………….
No
Annex 3 – Recommended Format of EMP for each sub-project
INTRODUCTION
Legal background for EMP preparation
Information source for EMP preparation
Organization of EMP preparation
PART 1: BASELINE SITUATION
1
Hospital name
2
Hospital director (full name, address, telephone, fax, email)
3
Hospital location, area and catchment area
4
Hospital size (number of beds and number of staff in reality and projection to 2020)
5
Hospital structure
6
Hospital main services and performance
7
Current situation of hospital environmental management
Registration of hazardous waste generation owner
Authorization of hazardous waste treatment and wastewater treatment
Implementation of Healthcare waste management regulation
Environmental inspection and punitive sanction (if available)
Main challenges and difficulties
PART 2: HEALTHCARE WASTE, ENVIRONMENTAL ISSUES AND PROPOSED
MITIGATION MEASURES
1
Healthcare solid waste and proposed mitigation measures
1.1
Hazardous healthcare waste management
Quantity of generation by healthcare waste categories
Segregation and color coding
Collection, on-site transportation, storage
Off-site transportation, treatment and disposal
Reuse and recycle
1.2
General healthcare waste management
Quantity of generation
Segregation and color coding
Collection, on-site transportation, storage
Off-site transportation, treatment and disposal
Reuse and recycle
1. 3
Hospital waste water management
Quantity of generation
Collection network
Treatment facilities
Operation and maintenance (including sludge removal and disposal)
1.4
Gas emission and controlling measures
1.5
Renovation under NORRED project (if available) and mitigation measures
Prevention and control of dust, noise, vibration from construction activities
Management of solid waste from construction activities
Management of wastewater and localized flooding
1.6
Proposed measure for occupational health and safety
Health surveillance, management of occupational exposure and diseases
Radiation protection and safety
Training and communication (key manager, staff, waste collectors and operators, patients)
1.7
Notification, Registration, Authorization
PART 3: ANNUAL ACTION PLAN
Project
phase
Environmental
Issues
Design
Substandard facility
and equipment for
radiation exposure
Dust, noise, vibration
Construction waste
Renovation
Wastewater and
blocked drainage
Workers’ safety risks
Chance finding
Operation
Solid healthcare
waste management
Wastewater
collection, treatment
Gas emission
controlling
Occupational health
and safety
Proposed measures
Budget and
source
Time
Person/ institution
in charge
PART 4: ENVIRONMENTAL MONITORING PROGRAM
Project
phase
Content
Location Parameter
Frequency
Design
Renovation
Operation
PART 5: INSTITUTIONAL ARRANGEMENT
1
Healthcare waste management team (or Infection control team)
2
Occupational safety team
PART 6: PUBLIC CONSULTATION AND DISCLOSURE
ANNEX
Annex 1: Hospital layout
Annex 2-1: Decision on Infection control committee establishment
Annex 2-2: Decision on working safety committee establishment
Annex 3: Environmental monitoring and inspection results
Annex 4: Record of Public consultation
Cost
Person
in
charge
Annex 4 – Record of Public Consultation
Date:
Subproject:

Method of consultation
Public meeting
...........................................
Questionnaire circulation: . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
[indicate number sent and number received]

Location(s) consultation(s) was (were) held: [building, commune, district]

Number of attendances from affected group. . . .

Comments and Questions from affected group
………………………………………………………………………………………………….
………………………………………………………………………………………………….
………………………………………………………………………………………………….
………………………………………………………………………………………………….
………………………………………………………………………………………………….
………………………………………………………………………………………………….
………………………………………………………………………………………………….
………………………………………………………………………………………………….
………………………………………………………………………………………………….
………………………………………………………………………………………………….
………………………………………………………………………………………………….
………………………………………………………………………………………………….

Response by Presenters)
………………………………………………………………………………………………….
………………………………………………………………………………………………….
………………………………………………………………………………………………….
………………………………………………………………………………………………….
Meeting Minutes prepared by (name and title)
Representative from affected group (full name, address and signature)
Annex 5 – Technical specifications of facilities and equipment for HCWM
 Waste bag shall meet the following requirements: (i) yellow and black bags must
be the PE or PP plastic bags, not be PVC; (ii) bag’s walls must have minimum thickness
of 0.1 mm, bag sizes must be appropriate to generated waste quantity, the maximum
volume of a bag is 0,1m3; (ii) on the outside of the bag, there must be a horizontal line
running at the height of 3/4 of the bag with the inscription "no storing beyond this line";
(iv) waste bags must conform to color coding and be used with right purposes.
 Sharp box shall meet the following requirements: Hard wall and bottom are
hardly penetrable, leak-proof capacity, suitable size, the lid easy to open/close, the
opening is big enough to contain sharp items without propulsive force, marked with the
inscription “for sharp items only”, a horizontal line running at the height of 3/4 of the bag
with the inscription of "no storing beyond this line", yellow color, with handle or enclosed
with fixation system, sharp items inside aren’t dropped out during transportation.
 Waste bin shall meet the following requirements: (i) be made of plastic with high
density, thick and hard walls or made of metal and with covers opened by foot; (ii) bins
of 50 l and larger should have wheels; (iii) yellow bins are used for collection of yellow
waste boxes/bags, black bins are used for collection of black waste boxes/bags,
radioactive waste must be contained in metal bins, green bins are used for collection of
green waste boxes/ bags, white bins are used for collection of white waste boxes/ bags;
(iv) The bins’ holding capacities vary from 10 to 250 liters, depending on the generated
waste volumes; (v) The bins’ outside must be marked with a line at the level of 3/4 of
the bin and the inscription of "not storing beyond this line"; (vi) Waste bins shall be
cleaned daily.
 Onsite waste transportation devices shall meet standards: having the wall,
cover, closed bottom, easy to load and unload the waste, easy to clean, disinfect and
dry.
 Storages places at healthcare establishments shall meet the following
requirements: be far from food-preparing places, patients’ wards, crowded sites and
public paths at least 10 m; have ways for waste carriers to come from the outside; have
roofs, protection fences, doors and locks to prevent animals, rodents and unassigned
persons from freely penetrating therein; the area is suitable to the waste volumes
generated from the healthcare establishments; be equipped with facilities for handwashing, means for protection of personnel, cleansing tools and chemicals; be built with
water drainage systems, water -resistant floor and wall, good ventilation; if interim
storage is designed as warehouse, it shall meet Vietnam standard TCVN 4317:86 –
Warehouse – Basic principle of design or equivalent or higher international standards.
Besides, the storage house shall be equipped as follows: manual or physical loading
and unloading equipment; warning sign correlative to stored hazardous waste category
in each cell or unit of storage area and on each storage equipment, warning signs
comply with TCVN 6707:2009, have at least 30 cm in each size, color and inscription on
warning sign are not faded; abridged instructions of safe operating procedures, accident
response, working safety and health protection are in place; convenient to see, easy to
read to encourage healthcare establishments to keep waste in cold warehouse/bins.
 Hazardous waste storage equipment shall meet the following requirements:
shell can resist against corrosion, infiltration or adsorption; be stainless, not react to
chemicals inside; be reinforced at connection and charging, discharging points to avoid
leakage; structure is firm to stand clash, not to broken, deform during utilization; warning
sign in line with TCVN 6707:2009 has at least 30 cm in each size, is clear to read;
equipment storing liquid or evaporate hazardous waste shall has closed lid, measure to
control evaporation, measure to control overfill; cooling storage equipment is
encouraged to be equipped.
 Truck for hazardous waste transportation shall have fixed hermetic body in
order to avoid leakage and spillage of hazardous waste into environment. Warning
signs which is in line with TCVN 6707:2009 and at least 30 cm in size are marked at two
sides of truck; the inscription of “transportation of hazardous waste” together with name,
address, telephone are labeled at two sides of truck. On the truck, hazardous
healthcare wastes shall be packaged in bins/boxes in order to prevent and control
leakage, spillage and environmental incidents caused by hazardous wastes. Hazardous
waste containing equipment shall meet the requirements for hazardous waste
containers described above.
 Healthcare waste incinerator shall meet Vietnam standard TCVN 7380:2004
regulates technical requirements for healthcare waste incinerator as follows: incinerator
includes primary chamber and secondary chamber; temperature in primary chamber ≥
800oC; temperature in secondary chamber ≥ 1200oC; Temperature of emission gas at
chimney hole ≤ 250oC; Gas residence time in secondary chamber ≥ 1,5 second;
Incinerator must be compulsorily ventilated. Healthcare waste management
practitioners shall use incinerator having capacity of at least 100 kg/hour. Vietnam
policies and the World Bank’s EHS guidelines require healthcare solid waste incinerator
to have measures to control secondary pollution. Secondary air pollution control
measures for healthcare solid waste incinerators include the following: (i) The height of
chimney must be 3 meters higher than the roof of the highest house within a radius of
40 meters from incinerator location, in case there is no house within that zone, the
chimney height must be at least 8 meters from the ground; (ii) Wet scrubber to control
acid gas emissions e.g. HCl, SO2 and fluoride compounds; (iii) Cyclones, fabric filters,
and/or electrostatic precipitators to control particulate matter; (iv) Fabric filter,
electrostatic precipitators, venturi quenches and venturi scrubbers to control volatile
heavy metals; (v) Flue gas need to be quenched very quickly to avoid formation and
reformation of POPs; (vi) Flue gas cleaning devices shall meet international standard;
(vii) Gas emission of incinerator shall be monitored regularly with frequency of at least 3
month and meet National technical requirements on gas emission of healthcare waste
incinerator (QCVN 02:2008/BTNMT). Bottom ash, fly ash and liquid effluent from flue
gas cleaning shall be managed as hazardous waste. According to Stockholm
Convention signed by Vietnam, healthcare waste incinerator is considered as a
potential releasing source of Dioxin and Furans and priority consideration should be
given to alternative technologies that avoid formation of dioxins & furans.
 Controlled dump that can be temporarily applied for resource limited healthcare
establishments in mountainous area shall be stipulated by local authority and accepted
by local environmentally managerial bodies. Controlled dump shall meet requirements:
surrounding fence, far from water well, far from housing area at least 100 m, bottom of
landfill separated from surface water level by 1.5 m at minimum, opening of the landfill
is prominent and temporarily covered to prevent rain water; a soil layer of 10-25 cm is
heaped up on the surface of hole in each time of burial; and the thickness of top soil
layer is 0.5m. Infectious waste shall not be buried together with general waste.
Infectious waste shall be disinfected before burying.
 Concrete bury pit includes 3 types: underground pit, sub-underground pit, and
surface pit; pit is located at area where groundwater level is suitable; area of bottom of
each pit ≤ 100 m2 and the height ≤ 5 m; bottom and wall are made of leak-proof ferroconcrete and located on reinforced ground; wall (underground part) and bottom are
enclosed by a leak-proof layer; roof is in place to protect pi’s surface from sun and rain,
and measure is in place to protect pit’s content from direct wind; when the pit is full,
enclose the pit by leak-proof ferro-concrete cover; the cover must cover all pit’s surface
to prevent leakage and endosmosis.
 Hazardous waste engineered landfill shall meet Vietnam standard TCXDVN
320:2004 that is applied to design, construct a hazardous waste landfill or renovate or
design new cells in existing hazardous waste landfill.
 Healthcare wastewater collection and treatment. Each hospital shall have a
synchronous system of waste water collection and treatment. Hospital shall have
collection network of contaminated wastewater separated from collection network of
raining water. Wastewater collection network shall be underground or covered by caps.
Design of wastewater collection network and treatment facilities shall meet the National
Standard TCVN 7957:2008 on design of wastewater external network and facilities.
Hospital waste water treatment technologies shall be appropriate to geographic
conditions, investment capital, operational and maintenance expense. Wastewater
treatment technologies include source segregation and pretreatment for removal /
recovery of specific contaminants such as radio isotopes, mercury, etc.; skimmers or oil
water separators for separation of floatable solids; filtration for separation of filterable
solids; flow and load equalization sedimentation for suspended solids reduction using
clarifiers; biological treatment with suspended growth process and/or attached growth
process for reduction of soluble organic matter (BOD); biological or chemical nutrient
removal for reduction in nitrogen and phosphorus; chlorination of effluent when
disinfection is required; dewatering and disposal of residuals as hazardous
medical/infectious waste. Hospital wastewater effluent shall meet National technical
regulation QCVN 28:2010/BTNMT on healthcare wastewater quality. Sludge shall be
considered as hazardous waste and managed according to solid waste management
regulation. Additional engineering controls may be required for containment and
treatment of volatile constituents and aerosols stripped from various unit operations in
the wastewater treatment system. Hospital shall employed measures to minimize entry
of hazardous solid waste and large quantities of pharmaceuticals or chemicals into
wastewater stream.
Annex 6. Vietnam Hospital Wastewater Discharge Standard
(QCVN 28:2010/BTNMT)
Parameters
Unit
Value of C
A
B
6,5
8,5
1. pH
-
6,5 - 8,5
Technical
standard
reference
TCVN 6492:1999
(ISO 10523:1994)
2. BOD5
mg/l
30
50
3. COD
mg/l
50
100
4. Total Suspended Solid (TSS)
mg/l
50
100
5. Sulfur (S2-, calculate by H2S)
mg/l
1.0
4.0
6. Ammonium (NH4+, calculate by N)
mg/l
5
10
7. Nitrates (NO3-, calculate by N)
mg/l
30
50
8. Phosphate (PO43-, calculated by P)-
mg/l
6
10
9. Oil and grease
mg/l
10
20
10. Alpha radioactivity
Bq/l
0.1
0.1
11. Beta radioactivity
Bq/l
1.0
1.0
12. Total coliform
MPN/
100ml
3000
5000
KPHD
KPHD
TCVN 4829:2001
KPHD
KPHD
SMEWW 9260
KPHD
KPHD
SMEWW 9260
13. Salmonella
14. Shigella
15. Vibrio cholera
Bacteria
/100 ml
Bacteria
/100 ml
Bacteria
/100 ml
TCVN 6001 - 1:2008
TCVN 6491:1999
(ISO 6060 : 1989)
TCVN 6625:2000
(ISO 11923:1997)
TCVN 6637:2000
(ISO 10530:1992)
TCVN 5988:1995
(ISO 5664:1984)
TCVN 6180:1996
(ISO 7890 - 3 : 1988)
TCVN 6494 – 2: 2000
(ISO 10304 -2 : 1995)
US EPA Method 1664
TCVN 6053:1995
(ISO 9696:1992)
TCVN 6291:1995
(ISO 9697:1992)
TCVN 6187-1:2009
(ISO 9308 - 1:2000)
TCVN 6187 - 2:1996
(ISO 9308 - 2:1990)
Note:
- KPHD: undetectable;
- A category: apply to hospital waste water discharged to water body used for domestic
purposes;
- B category: apply to hospital waste water discharged to municipal sewerage and water body
not used for domestic purposes
- Allowable threshold (Cmax) = C * K;
K = 1 in case of hospital having ≥ 300 beds, parameters pH, Total coliform, Salmonella,
Shigella, Vibrio cholera
K = 1.2 in case of hospital having < 300 beds and other health facilities
Annex 7. Vietnam Health Care Solid Waste Incinerator Emission Standard
(QCVN 02:2008/BTNMT)
No Parameter
Chemical
Technical standard
Unit
Limits
mg/Nm3
115
TCVN 7241: 2003
formulation
reference
1
Dust
2
Hydrofluoric acid
HF
mg/Nm3
2
TCVN 7243 : 2003
3
Hydrochloric acid
HCl
mg/Nm3
100
TCVN 7244 : 2003
4
Carbon monoxide
CO
mg/Nm3
100
TCVN 7242 : 2003
5
Nitrogen oxide
NOx
mg/Nm3
250
TCVN 7245 : 2003
6
Sulfur dioxide
SO2
mg/Nm3
300
TCVN 7246 : 2003
7
Mercury
Hg
mg/Nm3
0.55
TCVN 7557–2 : 2005
8
Cadmium
Cd
mg/Nm3
0.16
TCVN 7557–3 : 2005
9
Lead
Pb
mg/Nm3
1.2
TCVN 7557–3 : 2005
10
Total Dioxin/Furan
2.3
TCVN 7566-1 : 2005
Dioxin
C12H8-NClnO2
Ng –
TCVN 7566-2 : 2005
Furan
C12H8-NClnO
TEQ/Nm3
TCVN 7566-3 : 2005
Note: N: number of Chlo atom; N*: 2 ≤ n ≤ 8 TEQ
Annex 8. Cost estimation for technical assistance and capacity building
Unit: USD
No
Cost items
Unit
Quantity Cost
Total
1
Technical assistance
40,480
1.1
Update safeguard and HCWM regulations
man.day
10
100
1,000
1.2
Provide training on development of safeguard
documents including HCWM plan
man.day
10
100
1,000
1.3
Support development of safeguard documents
including HCWM plans
man.day
78
100
7,800
1.4
Take consultation with stakeholders on
safeguard documents including HCWM plan
man.day
13
100
1,300
1.5
Provide training on following up of safeguard
and HCWM activities
man.day
117
100
11,700
1.6
Provide training on operation and
maintenance
man.day
7.8
100
780
1.7
Monitor and prepare regular reports
man.day
130
100
13,000
1.8
Midterm review and prepare proposal for
procurement
man.day
39
100
3,900
2
Training and seminars
2.1
Training on development of safeguard
document including HCWM plan
trainee
156
150
23,400
2.2
Stakeholder seminars
seminar
13
500
6,500
2.3
Training on follow up of safeguard and HCWM
activities
trainee
780
150
117,000
2.4
Training on operation and maintenance
trainee
156
150
23,400
3
Other capacity building activities
province
13
2500
32,500
4
Contingency
5
Total
202,800
24,220
300,000