Environmental and Social Audit Report For Wajir Regional Referral Laboratory 1

Public Disclosure Authorized
East African Public Health Laboratory Networking Project (EAPHLNP)
Environmental & Social

Audit Report
Bonventure Naphtali Okanga

P.O. BOX 53317 – 00200
Tel No. +254 723 494820
NEMA Reg. No. 5067
December 2018
Wajir Regional Referral Laboratory – Environmental & Social Audit Report. Page 1 of 63
DOCUMENT AUTHENTICATION
This report has been prepared by a registered and licensed EIA/EA Expert.
I, the undersigned, certify that the particulars in this report are correct and righteous to the
best of my knowledge.
NEMA EIA/EA EXPERT:
Mr. Bonventure Naphtali Okanga. EIA/EA Expert (Reg. No. 5067)
Signature………………………………………………………………………..
Date……………………………………………………………………………..
NATIONAL PUBLIC HEALTH LABORATORY SERVICES (NPHLS) REPRESENTATIVE
Name……………………………………………………………………………..
Designation……..………………………………………………………………..
Signature………………………………………………………………………....
Date……..………………………………………………………………………..
ACRONYMS AND ABBREVIATIONS

DOSH Directorate of Occupational Safety and Health
EA Environmental Assessment
EIA Environmental Impact Assessment
EAC East African Community
EAPHLN East Africa Public Health Laboratory Network Project
ESMF Environmental and Social Management Framework
ESMP Environmental and Social Management Plan
EMMP Environmental Monitoring & Mitigation Plan
HAIs Healthcare Associated Infections
HCWH Healthcare Waste Handler
HCWMP Healthcare Waste Management Plan
IPP Indigenous Peoples Plan
IPPF Indigenous Peoples Planning Framework
LIMS Laboratory Information Management System
POPs Persistent Organic Pollutants
NEMA National Environment Management Authority
NGO Non Governmental Organizations
OP Operational Policy
SPIU Single Project Implementation Unit
WHD Wajir District Hospital
WHO World Health Organization
WRRL Wajir Regional Referral Laboratory
TABLE OF CONTENTS
DOCUMENT AUTHENTICATION ...................................... 2
EXECUTIVE SUMMARY.............................................. 6
CHAPTER ONE: INTRODUCTION AND BACKGROUND....................... 8
1.1. Introduction ............................................ 8
1.2 Project description and design ........................... 8
1.2.1 Introduction ......................................... 8
1.2.2 The Project Design ................................... 9
1.2 Objective of the Consultancy ............................ 10
1.3 Project Justification ................................... 10
1.4. Scope of the ESA and Specific Tasks for the Consultancy 11
1.5 Methodology and Approach ................................ 11
CHAPTER TWO: ENVIRONMENTAL AND SOCIAL BASELINE INFORMATION.... 13
2.0 Introduction ............................................ 13
2.1 The Project site ........................................ 13
2.1.1 The laboratory Infrastructure ....................... 13
2.1.2 Water and Power Supply .............................. 13
2.1.3 Laboratory Safety and Sanitation .................... 14
2.1.4 Waste Management .................................... 14
2.2 Wajir County profile .................................... 15
2.2.1 Administrative ...................................... 15
2.2.2 Topography .......................................... 16
2.2.3 Climate ............................................. 16
CHAPTER THREE: POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK..... 17
3.0 Introduction ............................................ 17
3.1 Kenya Constitution 2010 ................................. 17
3.2 Environment Management and Coordination (Amendment) Act,
2015 ........................................................ 18
3.2.1 The EMCA (Waste Management) Regulations 2006 ........ 19
3.2.2 The EMCA (Water Quality) Regulations 2006 ........... 20
3.2.3 The EMCA (Air Quality) Regulations 2014 ............. 21
3.3 Radiation Protection Act, Cap 243 ....................... 22
3.4 Public Health Act Cap. 242 .............................. 22
3.5 Occupational Safety and Health Act, 2007 ................ 22
3.6 Guidelines, Plans and Policy framework ................. 22
3.6.1 Sessional Paper No. 6 of 1999 on Environment and
Development ............................................... 22
3.6.2 The National Environmental policy of 2012 ........... 23
3.6.3 World Bank Safeguards and Disclosure Policies ....... 23
3.6.4 The Kenya Health Policy 2012 to 2030 ................ 24
3.6.5 Injection Safety and Medical Waste Management Policy
2007 ...................................................... 24
3.6.6 National IPC Policy ................................. 25
3.6.7 Health Care Waste Management Strategic Plan 2015-2020 25
3.6.8 National Infection Prevention and Control Guidelines

for Health Care Services in Kenya, 2010 ................... 26
3.6.9 Kenya National Guidelines on Safe Disposal of
Pharmaceutical Waste ...................................... 26
3.7 International Agreements ................................ 26
CHAPTER FOUR: PUBLIC PARTICIPATION & CONSULTATIONS............ 27
4.0 Introduction ............................................ 27
4.1 Methodology ............................................. 27
4.2 Findings ................................................ 28
CHAPTER FIVE: AUDIT FINDINGS.................................. 30
5.0 Introduction ............................................ 30
5.1 Legal and regulatory review ............................. 30
5.1.1 Findings ............................................ 30
5.1.2 Actions required .................................... 30
5.2 Construction phase review ............................... 31
5.2.1 Findings ............................................ 31
5.2.2 Gaps identified ..................................... 31
5.2.3 Conclusion .......................................... 32
5.3 Operation and Maintenance Phase Review .................. 32
5.3.1 Findings ............................................ 32
5.3.2 Gaps identified ..................................... 34
5.3.3 Conclusion and Actions required ..................... 39
CHAPTER SIX: CONCLUSION AND RECOMMENDATIONS................... 43
CHAPTER SEVEN: REFERENCES..................................... 46
CHAPTER EIGHT: APPENDICES..................................... 47
APPENDIX 1: HCWM ASSESSMENT SURVEY TOOL. .................... 47
APPENDIX 2: QUESTIONNAIRE FOR STAKEHOLDER CONSULTATIONS ..... 50
APPENDIX 3: OPERATIONAL PHASE ESMP .......................... 51
APPENDIX 4: MINUTES TO THE STAKEHOLDERS MEETING ............. 54
APPENDIX 5: STAKEHOLDERS MEETING PARTICIPANTS ............... 58
APPENDIX 6: CONSTRUCTION PHASE ESMP. ........................ 59
APPENDIX 7: CONSULTANTS 2017 PRACTICING LICENSE. ............ 63
LIST OF FIGURES
Figure 1: showing the ‘local incinerator’ 35
Figure 2: Showing the open pit burning site................... 35
Figure 3: Showing the malfunctioned incinerator (green roof) &
the new modern incinerator under construction................. 36
Figure 4: Showing animals scavenging waste at the burning site
taking note of the neighboring staff quarters and the large
quantities of plastics........................................ 37
Figure 5: Showing scattered broken sharps at the ‘local
incinerator’.................................................. 39
EXECUTIVE SUMMARY
The WRRL, constructed and operationalized in 2015 is one of the five beneficiary satellite
laboratories in Kenya under the EAPHLNP funding from the International Development
Agency/the World Bank through the Ministry of Health.
The EAPHLN Project in Kenya included the rehabilitation/construction and equipping of 5

satellite laboratories (Nairobi, Machakos, Kitale, Busia and Wajir) as well as national
reference laboratories. An Environmental Management Plan for Wajir was prepared and
approved by NEMA in June 2012 and the construction completed in 2014.
The development objective of the regional project was to establish a network of efficient,
high quality, accessible public health laboratories for the diagnosis and surveillance of
communicable and non-communicable diseases in the five East African Community (EAC)
member states (Burundi, Kenya, Rwanda, Tanzania and Uganda).
This environmental and social audit seeks to ascertain compliance of the activities
implemented under the project, the existing facilities and operations with national
environmental laws and regulations as well as World Bank safeguard requirements and
standards and to plan for the management of potential risks and impacts likely to result from
implementation of subsequent activities related to operation of these laboratory facilities.
This auditing exercise on environmental and social management aspects of the construction
and operation phases of WRRL revealed no major non-compliance issues at the construction
phase. Several commendable compliance areas of the operation phase were established
during the audit; availability of updated safety manuals, waste segregation at source, lockable
and well labelled waste storage area, good laboratory infrastructure and structural integrity,
availability of waste management records, proper chemical management and proper handling
and disposal of sharps.
However, the assessment identified healthcare waste management to be the main challenge
of the WRRL operation highlighting several deficiencies: shallow, unlined and overfilled
burning pit; unrestricted access to the burning site; Burning of waste containing plastics and
proximity of the disposal site to the staff quarters and scattered broken sharps at the ‘local
incinerator’. Besides, a legal and regulatory non-compliance was identified in the failure to
prepare an EIA for the proposed modern incinerator currently under construction against
the provisions of Section 45 of the Waste Management Regulations, 2006.
For the purposes of continuous improvement and compliance, the following

recommendations were formulated;
▪ Improve the on-site burning of waste. The on-site burning can be further improved
by digging an open pit but above the water table or lined with clay or plastic, and
protected by a fence or other effective barrier (e.g., rows of thorny brush).
▪ Increased agency monitoring. The EAPHLNP Project Management Unit should

initiate collaboration with NEMA in enforcement, supervision and monitoring of
waste management in the facility.
▪ With the eminent completion of the modern incinerator, proper incinerator

management measures (use of a well trained operator) need to be put in place to avert
its immature/untimely malfunction.
▪ Acquisition of adequate and dedicated number of transport bins and trolleys with
separate ones for infectious waste to be drawn on paved surfaces to the waste
treatment site.
In general, the compliance of the project activities with existing facilities and operating
procedures were found satisfactory.
CHAPTER ONE: INTRODUCTION AND BACKGROUND
1.1. Introduction
The WRRL, constructed and operationalized in 2015 is one of the five beneficiary satellite
laboratories in Kenya under the EAPHLNP funding from the International Development
Agency/the World Bank through the Ministry of Health.
The EAPHLN Project in Kenya included the rehabilitation/construction and equipping of 5

satellite laboratories (Nairobi, Machakos, Kitale, Busia and Wajir) as well as national
reference laboratories. An Environmental Management Plan for Wajir was prepared and
approved by NEMA in June 2012 and the construction completed in 2014. The project was
operationalized in January 2015.
Environmental and Social Management Framework (ESMF) was prepared in 2012 to ensure
proper assessment and mitigation of potential adverse environmental and social impacts. The
ESMF outlined the steps in the environmental and social screening process, and included
Environmental Guidelines for Contractors, a summary of the Bank’s safeguard policies, an
Environmental and Social Checklist, generic Environmental Assessment (EA) terms of
reference to be applied in the event that the screening results indicate the need for a separate
EA report, and an Environmental and Social Management Plan (ESMP).
The Environmental & Social Impact Assessment (ESIA) Environmental Management Plan
(EMP) were prepared and approved by NEMA in June 2012 and a licence thereto issued. It
was established that the construction and operation phases of the project adhered with the
conditions outlined in the licence.
1.2 Project description and design

1.2.1 Introduction
The development objective of the regional project was to establish a network of efficient,
high quality, accessible public health laboratories for the diagnosis and surveillance of
communicable and non-communicable diseases in the five East African Community (EAC)
member states (Burundi, Kenya, Rwanda, Tanzania and Uganda).
The project included three mutually reinforcing components which aimed to assist EAC
member states to diagnose communicable diseases of public health importance and to share
information about those diseases to mount an effective regional response as described below;
1. Component #1 - Regional Diagnostic and Surveillance Capacity provided support to

create and render functional a regional laboratory network which aims to enhance
access to diagnostic services for vulnerable groups; improved capacity to provide
specialized diagnostic services and conduct drug resistance monitoring; and
strengthened laboratory based disease surveillance to provide early warning of public
health events.
2. Component #2 - Joint Training and Capacity Building aimed to support training and
capacity building for laboratory personnel, in order to increase the pool of experts in
the sub-region and to improve the effectiveness of public health laboratories.
3. Component #3 - Joint Operational Research and Knowledge Sharing/Regional

Coordination and Program Management will finance operational research and
knowledge sharing activities, which aim to evaluate the impact of the new TB
diagnostic technologies, assess drug resistance patterns for endemic diseases, and
ascertain feasibility of using mobile phone technologies for surveillance reporting;
and support regional coordination and program management functions.
The laboratory network will facilitate the adoption of harmonized policies, strategies, and
protocols to ensure prompt and high quality results. Priority attention will be given to
networking intermediate or satellite laboratories that serve cross border and migrant populations,
and central public health labs that provide specialized services.
1.2.2 The Project Design

The laboratory is well designed providing adequate space, engineering controls and proper
environmental conditions for storage and analysis of specimen in accordance with good
laboratory practices, laboratory safety requirements and applicable regulations.
The facility meets the required environmental conditions including separation of work areas
to ensure that analyses will not be adversely affected within resources provided (laboratories
are separated according to compatibility of testing activities), bio-safety hoods, adequate air
conditioning, lighting, heating and ventilation are controlled and monitored to the level
needed for each type of test,
The development is a one storey building with the ground floor accommodating the Waiting
area, Specimen reception area, Reception area, Reports release desk, Cashier office, Records
room, Patients WCS, Phlebotomy room, washing area, Counselling room, Blood donor room,
Rest room, Blood bank, Pathologists office, Server room, Staff Lounge, Office for in-charge,
Office for County laboratory Technician, Utility Room, Cold Room, Training Room; video
conferencing, Suppliers store and Staff WCs.
The first floor accommodates the Blood transfusion laboratory, Serology laboratory,
Chemistry laboratory, Hematology laboratory, Parasitology laboratory, Histology laboratory,
Microscopy, Freezer room, Media prep room, Specimen Museum, Quality control laboratory,
Molecular laboratory, Virology laboratory, Microbiology laboratory, TB laboratory,
Decontamination room, Glassware washing, Store and Staff WCS.
1.2 Objective of the Consultancy

This environmental and social audit seeks to ascertain compliance of the activities
implemented under the project, the existing facilities and operations with national
environmental laws and regulations as well as World Bank safeguard requirements and
standards and to plan for the management of potential risks and impacts likely to result from
implementation of subsequent activities related to operation of these laboratory facilities.
The audit is necessary to ensure that the safeguard instruments (ESIAs, ESMPs, MWMP,
IPPFs) have been implemented appropriately, and that relevant mitigation measures have
also been identified and implemented. The audit will be able to identify any
amendments/updates to be effected to the safeguard instruments to improve their
implementation effectiveness.
The key objective of the Environmental Audit is to identify gaps in Environmental

Management measures and to prepare an Action Plan that will be implemented during the
rest of the project period.
1.3 Project Justification

The requirement to conduct an annual Environmental & Social Audit (ESA) is a mandatory
legal obligation, a sound precautionary measure and a proactive strategy in today’s closely
regulated environment. ESA plays a valuable role in encouraging the systematic
incorporation and mainstreaming of environmental and social policies and practices into
many aspects of the WRRL’s overall operations and core values.
Since the ESIAs/ESMPs were prepared in the first year of the project prior to construction,
there was need to carry out an initial Environmental and Social Audit (EA) in order to
ensure that there was due diligence in the application of safeguards during construction
phase and operation phase and to plan for mitigating and/or addressing any potential adverse
risks during the operational phase.
1.4. Scope of the ESA and Specific Tasks for the Consultancy
The scope of the audit is therefore limited to the constructed WRRL under the EAPHLP. The
audit covers two main phases of the project, with specific areas of focus:
- Project construction phase: management of construction materials and waste, air, noise and
wastewater, prevention of soil degradation and forests/critical ecosystems encroachment as
well as occupational health and safety measures set in place by the constructor.
- Project operation and maintenance phase: waste generation, management and disposal from
laboratory operations as well as health and safety of the staff and overall environmental
performance.
1.5 Methodology and Approach

This Environmental & Social Audit (ESA) study was undertaken by employing various
methodologies;
a) A review of the documents (including policies and legislation, World Bank’s
Environmental and Social Safeguards, project documentation, supervision reports).
b) Evaluation of existing internal environmental policies and strategies.
c) Appraisal of work processes and environmental management systems employed
within the WRRL.
d) Site inspections and walk through of sampled facilities based on a detailed
checklist conducted in the week of 5th to 9th June 2017.
e) Evaluation of health and safety policies, strategies and measures in place.
f) HCWM Assessment Survey Tool for data collection (APPENDIX 1: HCWM
ASSESSMENT SURVEY TOOL.)
The Consultant designed and administered the tool generate highly detailed
information at each section so that the HCWM system at the facility could be assessed
and to enable the Consultant to speak fairly to the HCWM “system” at the site. The
HCWM Assessment tool used was designed to highlight observable variables,
registering simple ‘ticks’ of yes/no observables for each variable
The tool laid emphasis on the following five areas:
➢ Presence of sharps in black coded bins

➢ Disposal of waste water into common drain
➢ Provision of waste segregation bins
➢ Provision of respirator to waste handlers
➢ Presence of a working incinerator
g) Interviews and public consultations with key stakeholders (NEMA Wajir County
Environmental officer, public health officials (Wajir District Hospital Health &
Safety Officer), medical and laboratory personnel, community representatives)
and waste handlers. Attention was paid to issues of noise, air quality,
environmental stability as well as the waste disposal regime. A questionnaire
(APPENDIX 2: QUESTIONNAIRE FOR STAKEHOLDER CONSULTATIONS)
was used to guide the consultations, interviews and a meeting with the
stakeholders held on 6th and 7th of July 2017 (APPENDIX 5: STAKEHOLDERS
MEETING PARTICIPANTS).
CHAPTER TWO: ENVIRONMENTAL AND SOCIAL BASELINE

INFORMATION
2.0 Introduction
This chapter provides the main features of the baseline biophysical and socio -economic
information of the project area. Environmental description, also known as baseline
studies, is intended to establish the present state of the environment, taking into
account changes resulting from natural events and from other human activities. If an
environmental description is flawed, this will reduce the accuracy of subsequent
predictions and mitigation measures.
2.1 The Project site

2.1.1 The laboratory Infrastructure
The WRRL building is located within the Wajir District Hospital compound in the
neighborhood of the Wajir County Health building and the Wajir County Mental
Hospital building. The site has an efficient connection of road network
The site is defined by a public access road and it is flat with a number of trees and sandy
soils and is served by electricity from Kenya Power.
The laboratory is well designed to accommodate movement related to patients,

personnel and specimens. The design clearly indicates how specimens move from the
specimen receiving area to the laboratory for test and dispatch of the results to the
patients.
The worktops/workbenches are constructed with a 25mm TRESPA Toplab Plus thick
solid panels which are acid, solvent, stain and scratch resistant with a marine edge top
and applied backsplash to contain spillage.
The laboratory has an elaborate communication system between the various sections
and also LIMS for electronic transfer of information and data from the la boratory area
to other sections or other satellite labs.
2.1.2 Water and Power Supply

Wajir district hospital has a borehole with an elevated pre-stressed steel water tanks
and also ground tank to improve water storage.
The WRRL sources its water for general use from a borehole located at the Wajir
District Hospital.
The hospital has a generator which also supports the new laboratory. There’s need for
the services of an electrical engineer to design for automatic change over switch and
incorporate solar water heating.
2.1.3 Laboratory Safety and Sanitation

The WRRL and the Wajir District Hospital (WHD) have in place a health and safety
committee and the bio-safety committee respectively and the safety management guidelines
such as the Policy and Procedures Manual and Guidelines for chemical safety handling,
incident, injuries and accidents. Safety measures in place were found satisfactory in the
laboratories.
Sanitation measures and facilities at the WRRL were found sufficient and fully operational.
2.1.4 Waste Management

The waste management and disposal at the two facilities (WRRL and WDH) is handled by
the Wajir County Government who have hence contracted the services to Saelf Cleaning
Services Company. The company is responsible for provision of all waste collection materials
as per the different waste categories, provision of PPEs to the waste handlers and also for the
transportation of the waste to the disposal site located behind the laboratory. There was
however no evidence that Saelf Cleaning Services Company was licensed by NEMA to
provide waste handling services as required by Waste Management Regulation, 2006.
2.1.4.1 HCW Segregation
Waste segregation procedures is well known at the WRRL with the waste separated
according to the biohazard risk (colour codes), waste containers clearly labelled and waste
handlers aware of the importance of precaution measures required for the different category
of waste with infectious and non-infectious waste disposed off in separate containers and
sharp instruments and needles discarded in puncture resistant containers. The infectious
waste and sharps are autoclaved before final disposal.
The Health and Safety Officer at the Wajir District Hospital and the Bio-safety Officer at the
Laboratory supervises the waste collection, segregation and transportation to the disposal
site. The HCW disposal through burning is done thrice a week by a County Government
employee (Health Care Waste Handler) using diesel as fuel.
2.1.4.2 HCW Storage Area
The WRRL has a lockable door storage area located on the first floor of the building. The
storage area is well labelled with a weighing scale and the waste records available from
which the quantities of waste generated can be ascertained.
2.1.4.3 HCW Disposal
The common disposal sites are located behind the laboratory: waste dumping site (open
pit) and sharps burning ‘local incinerator’. The waste burning sites are adjacent to the staff
quarters and the smoke emanating from the burning has been a constant menace to the staff
and the general public. There is an on-going project to construct a modern incinerator
with the old incinerator on site having malfunctioned due to a faulty gasket. As at the
time of the audit, it’s worth noting that the construction was stopped by NEMA since
there was no EIA done for the construction of the incinerator as required by the EMCA
(Amendment), 2015.
2.1.4.4 Waste Water Management
The WRRL has a septic tank and a soak pit located behind the laboratory for waste water
management.
2.2 Wajir County profile

Wajir is located in an arid area prone to drought. It sits at a latitude and longitude of
01°45’00”N 40°03’00”E / 1.75°N 40.05°E / 1.75; 40.05.
As with other areas in the former North Eastern Province, Wajir is mainly inhabited by
Somalis, most belonging to the Degodia sub-clan of the Hawiye.
2.2.1 Administrative
Wajir County is the largest County in the former North-Eastern Province and the
second largest in the Republic of Kenya after Turkana. The County borders the
Republic of Somalia to the east, Garissa County to the south, Isiolo County to the south-
west, Marsabit County to the west, Moyale County to the north-west, the Republic of
Ethiopia to the north and Mandera County to the North-East.
The county comprises of six sub-counties namely Wajir East, Wajir West, Wajir North,
Wajir South, Eldas, Tarbaj. The siute is located in Wajir East subcounty, with the
highest population density due to the fact that it’s the County headquarters where
businesses, employment opportunities and informal sector income generating activities

are concentrated.
The County is linked to the rest of the country by STANDARD telephone

communication at Wajir town and Habaswein while manual lines are available in Buna,
Bute, Griftu, and Wajir-Bor. The town is served by Wajir Airport, with flights to
Nairobi, Galkacyo and Mogadishu with three other small airstrips in Bute, Griftu and
Habaswein.
2.2.2 Topography
The County consists largely of a featureless plain, prone to flooding during rainy season,
often making roads impassable. The plain is truncated by dry river beds that fill with
water during the rainy season.
2.2.3 Climate
The County lies within the Sahelian climatic region, which is characterized by long dry
spells and short rainy seasons with an annual average rainfall is between 250mm to
300mm.
Maximum temperatures range between 31°C in July and 36°C in March while minimum
temperatures range between 21°C in July and 24°C in April.
CHAPTER THREE: POLICY, LEGAL AND ADMINISTRATIVE

FRAMEWORK.
3.0 Introduction
Environmental problems are rooted in economic and social policies, they occur at all
levels from local to global, and success requires action by many players over long
periods of time. The Government of Kenya (GoK) is responsible for dealing with these
problems and working towards solutions. Accordingly the government of Kenya has
tried to address this over the years by creating policies, plans and programs enacting
environmental legislation, and through international institutions and treaties, laws and
regulations and expenditures as well as relevant international safeguards such as the
World Bank EHS Guidelines and Safeguard Policies.
The relevant national and international legislations, policies and guidelines are
presented in this section, and the relevant and applicable sections or subsections
identified. This is done to ensure that adequate mitigation measures are put in place to
deal with the negative impacts on the project affected persons, and that all project
related activities are in conformity with the existing laws, and regulations, and
international best practices.
3.1 Kenya Constitution 2010

The promulgation of the Kenya Constitution 2010 marked an important chapter in
Kenya’s environmental policy development. Hailed as a green constitution, it con tains
elaborate provisions with considerable implications for sustainable development. These
range from environmental principles and implications of multilateral environmental
agreements (MEAs) to the right to a clean, healthy environment (article 42), and the
highest attainable standard of health (article 43 (i)) enshrined in the expanded Bill of
Rights, chapter four. It also embodies a host of social and economic rights of an
environmental character, such as the right to water, food, and shelter, among ot hers.
Article 70: (1) If a person alleges that a right to clean and healthy environment
recognized and protected under Article 42 has been, is being or is likely to be, denied,
violated, infringed, or threatened, the per-son may apply to a court for redress in
addition to any other legal remedies that are available in respect to the same matter.
This therefore gives the government the mandate to ensure that the rights of the
Kenyan people are protected and upheld.
3.2 Environment Management and Coordination (Amendment) Act, 2015.

EMCA, 1999 (and its 2015 Amendment) provides a legal and institutional framework
for the protection and conservation of the environment (in line with Article 42 of the
constitution).
The EMCA is very clear about the handling of biomedical waste, in particular, EMCA,
Part V stipulates that:
a. No person shall own or operate any institution that generates bio -medical waste
without a valid environmental impact assessment license issued by the authority
under the provisions of the Act.
b. Every waste generator of biomedical waste shall ensure that the generating
facility has been approved by the appropriate lead agency and the relevant local
authority.
c. Every waste generator of biomedical waste shall at the point of generation and at
all stages thereafter segregate the waste in accordance with the categories
specified in the seventh schedule to the EMCA regulations.
d. All biomedical waste shall be securely packaged in biohazard containers which

shall be labeled with the symbols set out in part i and ii in the eighth schedule of
the EMCA regulations
e. Every waste generator shall treat or cause to be treated all biomedical waste in
the manner set out in the ninth schedule to the EMCA regulations, before such
biomedical waste is stored or disposed of.
f. the relevant lead agency shall monitor the treatment of all biomedical waste to
ensure that such waste are treated in a manner that will not adversely affect
public health and the environment.
g. No person shall store biomedical waste at a temperature above 0˚C for more than
seven days without the written approval of the relevant lead agency, provided
that untreated pathological waste shall be disposed of within 48 hours.
h. No person shall transport biomedical waste without a valid permit issued by the
relevant lead agency in consultation with the relevant local authority.
i. No person shall transport or allow to be transported biomedical waste save in a

specially designed vehicles or other means of conveyance so as to prevent
spillage, leakage or scattering of such waste.
3.2.1 The EMCA (Waste Management) Regulations 2006

The Environmental Management and Coordination (Waste Management) Regulations
2006 is the government’s legal instrument that deals with waste management in Kenya.
The waste Management Regulations are meant to streamline the handling,

transportation and disposal of various types of waste to protect human health and the
environment. The regulations place emphasis on waste minimization, cleaner
production and segregation of waste at source. The regulation requires licensing of
transporters of wastes and operators of disposal site (sections 7 and 10 respectively).
Of immediate relevance to proposed development for the purposes of this project study
report is Part II Sections 4(1-2), 5 and 6.
▪ Section 4 (1) states that “No person shall dispose of any waste on a public
highway, street, road, recreational area or any other public place except in a
designated waste receptacle”. Section 4(2) and 6 explain that the waste generator
must collect, segregate (hazardous waste from non-hazardous) and dispose waste
in such a facility that shall be provided by the relevant local authority.
▪ Section 5 provides method of cleaner production (so as to minimize waste

generation) which includes the improvement of production processes through
conserving raw materials and energy.
▪ Section 11 provides that any operator of a disposal site or plant shall apply the
relevant provisions on waste treatment under the local government act and
regulations to ensure that such waste does not present any imminent and
substantial danger to the public health, the environment and natural resources.
▪ Part VI Section 38, 39 and 40 are relevant as far as biomedical waste segregation,
packaging and treatment is concerned.
▪ Section 38 states that any person who generates biomedical waste shall at the
point of generation and at all stages thereafter segregate the waste in accordance
with the categories provided under the Seventh Schedule to these Regulations.
▪ Section 39 states that all biomedical waste shall be securely packaged in

biohazard containers which shall be labeled with the symbols set out in Part I
and II of the Eighth Schedule to these Regulations.
▪ While section 40 states that any person who generates waste shall treat or cause
to be treated all biomedical waste in the manner set out in the Ninth Schedule to
these Regulations, before such biomedical waste is stored or disposed of.
The Proponent is expected to take full responsibility to ensure that solid waste (both
hazardous and non-hazardous) is properly handled, stored, transported and disposed as
per the procedures provided in these regulations, as well as the various documented
management plans and guidelines on health care waste management such as the
National Health Care Waste Management Plan 2015-2020 and the WHO National
Guidelines on Safe Disposal of Pharmaceutical Waste. The waste must be transported by
licensed transporter and disposed in waste treatment facility that is approved by the
authority.
3.2.2 The EMCA (Water Quality) Regulations 2006

These regulations apply to water used for a variety of purposes, including water used for
domestic purposes, industrial, purposes, agricultural purposes etc. They protect lakes,
rivers, streams, springs, wells and other water sources whereby contravening the
regulations is an offence that attracts a fine not exceeding five hundred thousand
shillings.
Of immediate relevance to the proposed project is Part II Sections 4 -6 as well as Part V

Section 24.
▪ Part II Section 4 inhibits acts which directly or indirectly, immediate or

subsequently cause water pollution.
▪ Part II section 6 criminalize discharge of water from sewage treatment works,

industry or other point sources into the aquatic environment without a valid
effluent discharge license.
▪ Part V Section 24 prohibits discharge or application of any poison, toxic, noxious

or obstructing matter, radioactive wastes, or other pollutants, into water meant
for fisheries, wildlife, recreational purposes or any other uses.
All waste water shall therefore be channeled into the sewer line to avoid ground and
surface water pollution, and if a pollution incidence occurs the contractor/proponent
shall notify the authority immediately. The contractor/proponent will handle hazardous
substances in a manner that is not likely to cause water pollution.
3.2.3 The EMCA (Air Quality) Regulations 2014

The Environmental Management and Coordination (Air Quality) Regulations 2014 is
the government’s legal instrument that deals with air quality in Kenya.
The Air Quality Regulations are meant to provide for the prevention, control and
abatement of air pollution to ensure clean and healthy ambient air.
The general prohibitions state that no person shall cause the emission of air pollutants
listed under First Schedule (Priority air pollutants) to exceed the ambient air quality
levels as required stipulated under the provisions of the Seventh Schedule (Emission
limits for controlled and non-controlled facilities) and Second Schedule (Ambient air
quality tolerance limits).
Of immediate relevance to the project are the following sections excerpts;
▪ Section 9 provides that a person, being an owner of premises, who causes or allows
the generation, from any source, of any odour which unreasonably interferes, or is
likely to unreasonably interfere, with any other person’s lawful use or enjoyment of
his property shall ensure that the odour emission limits comply with the ambient
quality limits set out under the First Schedule of these regulations
▪ Section 17 provides that the owner or operator of a controlled facility shall ensure
that exposure of workers to occupational air pollutants is monitored and recorded.
▪ Section 35 states that no person shall cause or allow stockpiling or other storage of
material in a manner likely to cause ambient air quality levels set out under the First
Schedule to be exceeded.
▪ Section 38 states that No person shall cause or allow emissions of priority air
pollutants from the disposal of medical waste, domestic waste, plastics, tyres,
industrial waste or other waste by open burning.
▪ Section 38 states the owner or operator of any controlled facility shall apply to
the Authority for an emission licence within twelve months from the date these
Regulations come into force.
The Proponent is expected to take measures to curb or minimize air emissions in

controlled areas. In case of emissions, the air quality is to be measured and monitored
against the allowable limits.
3.3 Radiation Protection Act, Cap 243

The Radiation Protection Act, Chapter 243, aims to control the import, export,
possession and use of radioactive substances and irradiating apparatus. Under this Act in
section 9, a license is required to handle any radioactive substances or irradiating
apparatus from the National Radiation Protection Board. Handling here includes the
method of disposing of radioactive waste products, transportation of radioactive
materials, storage, use and maximum working hours that employees are expected to
work with radioactive materials. Under this Act also, institutions generating this
category of waste shall be expected to apply for a license from the same board.
The provisions of this act will guide the proponent on the use of radiation and its
control, in the use of X-ray radiation apparatus and related technology.
3.4 Public Health Act Cap. 242

The Act makes provisions for securing and maintaining health. Part IX, section 115, of
the Act prohibits any person or institution from causing nuisance or a condition likely
to cause injury or which might be dangerous to human health.
3.5 Occupational Safety and Health Act, 2007

This Act of Parliament was enacted to provide for the health, safety and welfare of persons
employed in factories and other places of work and for matters incidental thereto and
connected therewith.
This legislation specifically provides for the protection of workers as well as the communities
within the proximity of the places of work.
3.6 Guidelines, Plans and Policy framework

3.6.1 Sessional Paper No. 6 of 1999 on Environment and Development
In 1999, the Government of Kenya produced the Sessional Paper No. 6 on Environment
and Development. The goal of the policy was to integrate environmental concerns into
the national planning and management processes and provide guidelines for
environmentally sustainable development. The policy paper identified areas requiring
action, which included the development of a comprehensive waste management policy,
guidelines, and standards.
3.6.2 The National Environmental policy of 2012

The environment policy of 2012, among other comprehensive legal instruments, gives a
broad statement on a number of key areas that have an impact on human health. In the
policy, issues of health are captured in chapters five and six. Chapter five is concerned
with the issues of environmental stewardship, which include climate change, disasters,
the sustainability of human settlements, waste management including management of
hazardous wastes and radioactive wastes, energy, gender, HIV/AIDS, and youth.
3.6.3 World Bank Safeguards and Disclosure Policies

The World Bank Environmental and Social Safeguards Policies include key Operational
policies (OP) designed to ensure that potentially adverse environmental and social
consequences are identified, minimized, and mitigated. The relevant policies are
summarized below. These policies will be replaced during 2018 with the Environmental
and Social Framework (ESF).
3.6.3.1 OP/BP 4.01 Environmental Assessment
This policy is considered to be the umbrella policy for the Bank's environmental
'safeguard policies'. This policy requires Environmental Assessment of projects proposed
for Bank financing to ensure that such projects are environmentally sound and
sustainable. All projects proposed must be screened by the Bank and put into one of
four categories for Environmental Assessment purpose. If a project falls into categories
A or B, a Comprehensive Environmental Assessment (also known as EIA or SEIA for
Social and Environmental Impact Assessment) must be conducted to respond to Bank
requirements. An EIA must include a comprehensive environmental management plan.
3.6.3.2 OP/BP 4.10 Indigenous Peoples
This policy underscores the need for project proponent and Bank staff to identify
indigenous peoples and to engage in a process of free, prior, and informed consultation.
The policy also aims to ensure that adverse impacts on Indigenous People are avoided,
or where not feasible, minimized or mitigated and that they participate in project and
benefit from it in a culturally appropriate way.
An elaborate Indigenous Peoples Plan (IPP) and Indigenous Peoples Policy Framework
(IPPF) for the project were prepared, consulted upon and disclosed.
3.6.3.3 Environment, Health and Safety Guidelines
The General World Bank Environmental, Health, and Safety (EHS) Guidelines are designed
to be used together with the relevant Industry Sector EHS Guidelines which provide
guidance to users on EHS issues in specific industry sectors.
Application of the EHS guidelines to existing facilities may involve the establishment of site
specific targets, with an appropriate timetable for achieving them. When host country
regulations differ from the levels and measures presented in the EHS guidelines, projects are
expected to achieve whichever is more stringent.
3.6.4 The Kenya Health Policy 2012 to 2030

The National Health Policy 2012 – 2030 has laid emphasis on healthcare waste
management to accelerate prevention and minimization of communicable diseases and
epidemics including HIV/AIDs, Tuberculosis, Hepatitis B and C, as well as other viral
hemorrhagic fevers among others. This policy is in line with the Public Health Act Cap
242 laws of Kenya which also addresses environmental health, water and sanitation
including healthcare waste management.
3.6.5 Injection Safety and Medical Waste Management Policy 2007

The mission statement of this policy is to ensure the safety of health workers, patients,
and the community and to maintain a safe environment through the promotion of safe
injection practices and proper management of related medical waste. This is the first
document of the Ministry that is explicit on the need to address HCWM problems. The
policy objectives spell out the need to advocate for support and implementation of
proper management of medical waste, among others.
Some of the guiding principles for the implementation of the policy include:
• Establishing organizational structures at all levels for the implementation of

injection safety and related medical waste.
• Addressing the need for environmental protection through appropriate waste

disposal methods.
• Minimizing risks to patients, health workers, communities, and the environment

through application of safe injection devices and sharps waste-disposal methods.
• Advocating for the strengthening of necessary human-resource capacity through

training and sensitization for safe waste disposal.
One of the policy’s key strategies is the need for appropriate financial mobilization and
allocation of the components of injection safety and medical waste management for
effective policy implementation. The provision of sustained supplies and equipment for
waste management through a strengthened logistics system addresses the need for
commensurate in-vestment in waste-handling requirements. Another unique strategy
recommended by the policy is the advocacy of best waste-management practices
through behavior change communication as a key element in the strategy.
3.6.6 National IPC Policy

In recognizing the need to redesign and strengthen existing systems and implement
evidence based methods to tackle infectious diseases in health care settings and tackle
the gradual development of drug-resistant infections, the MOH in 2010 developed the
National Infection Prevention Policy. The policy was set with the purpose of
preventing and managing HAIs by:
▪ Setting national standards for minimizing hazards that are associated with
biological agents in health care settings.
▪ Providing guidance to health administrators, health care workers, and all

stakeholders to observe these standards.
The policy was to be operationalized through the development of mid term and short
term IPC implementation plans and the development of IPC guidelines for health care
settings. This strategic plan is thus a key step in the implementation process of the
national IPC policy in health care settings in Kenya.
3.6.7 Health Care Waste Management Strategic Plan 2015-2020

The National Health Care Waste Management Plan of Action is a document intended
for use by health managers and programme officers across the health sector (including
those in the private health sector). The purpose of developing this plan was to provide a
tool that gives health managers guidance in planning, implementing and monitoring the
activities of health care waste management in health facilities.
A holistic approach has been recommended to include, clear delineation of

responsibilities, occupational health and safety programmes, waste minimization and
segregation. This document is designed to provide viable options to address the
challenges encountered in planning for health care waste management in Kenya.
3.6.8 National Infection Prevention and Control Guidelines for Health Care
Services in Kenya, 2010
These guidelines were formulated by the Ministry of Medical Services and Ministry of
Public Health and Sanitation to provide comprehensive and standardized information
regarding the prevention and control of transmissible infections.
These guidelines are intended to act as a central reference for all health care facilities
and healthcare workers.
Additionally, these guidelines are intended to provide administrators and Health Care
Workers with the necessary information and procedures to implement Infection
Prevention Control (IPC) core activities effectively within their work environment in
order to protect themselves and others from the transmission of infections. They
provide information on the following topics:
▪ The infrastructure, equipment, and supplies that are necessary to implement

standard and additional (transmission-based) precautions for IPC
▪ Procedures for cleaning, disinfecting, and reprocessing reusable equipment
▪ Managing health care waste
▪ Protecting health care workers from transmissible infections
▪ IPC practices in special situations
3.6.9 Kenya National Guidelines on Safe Disposal of Pharmaceutical Waste

The Kenya National Guidelines on Safe Disposal of Pharmaceutical Waste provides a
schedule on how unwanted pharmaceutical waste should be disposed.
3.7 International Agreements

Kenya is a signatory to many agreements and conventions on environmental
management. These include support for the provisions of Agenda 21 amongst other
declarations and statements of principle, such as the Rio Declaration in 1992 on
Environment and Development. Kenya is also a party to the Basel Convention on the
Control of Transboundary Movements of Hazardous Wastes and their Disposal 1992 and
the Stockholm Convention for Persistent Organic Pollutants (POP’s) 1972.
CHAPTER FOUR: PUBLIC PARTICIPATION & CONSULTATIONS
4.0 Introduction
The process mainly involved meetings and consultations exercises by use of open ended
questionnaires and interviews with relevant project affected persons/groups/businesses
and concerned government authorities, documenting their concerns, assessing potential
impacts, and exploring improvement actions. The interviews and consultations were
conducted to seek and input into this report the views of the community during the
construction and operation phases.
Some of the key stakeholders conducted include
1. NEMA Wajir County Environmental officer,
2. Public Health Officials (Wajir District Hospital Health & Safety Officer),
3. The WRRL Bio-safety officer,
4. Medical and laboratory personnel,
5. Community representatives and
6. Waste handlers.
4.1 Methodology
The consultant employed interviews, a structured questionnaire (APPENDIX 2:
QUESTIONNAIRE FOR STAKEHOLDER CONSULTATIONS) and a stakeholder meeting
to review and assess the project impact on the indigenous people. The meeting was held
on 6 th June 2017 at the Wajir Guest House and the recorded minutes attached
(APPENDIX 5: STAKEHOLDERS MEETING PARTICIPANTS & APPENDIX 4:
MINUTES TO THE STAKEHOLDERS MEETING).
Attention was paid to issues of noise, air quality, environmental stability as well as the waste
disposal regime.
4.2 Findings
The findings of the public consultation process (interviews, questionnaire and meetings) were found to compliment and are
summarised in Table 1 below;
Table 1: Summary of the Consultations
No. Category Findings
▪ The laboratory testing capacity has greatly increased and patients
can be treated according to the accurate results from the lab.
▪ The access to the lab by patients is much easier and they can be
Usefulness of the Laboratory
1. treated rapidly as the results are rapidly delivered.
▪ The laboratory testing capacity has greatly increased and patients
from all over the region can be rapidly and better treated based on
results generated by the lab.
▪ The WRRL and the WDH regularly receive patients from the neighboring
Any benefit to neighboring counties and sub-counties (Wajir East, Wajir West, Wajir North, Wajir
2.
regions South, Eldas, Tarbaj) to benefit from affordable and reliable
services provided by the lab.
▪ Waste, including excavated soil and debris properly disposed off by
3. Construction waste
backfilling and landscaping.
Noise pollution: use of ▪ Construction noise was limited to official working hours
4.
drilling machines.
▪ Construction workers trained on safe work practices and were wearing
protective clothes, hard caps, boots and masks. The site was fenced
to restrict onlookers/scavengers and a specific access road for
Noticeable Health and safety
trucks was set up.
5. measures during construction
▪ Signages were used to warn staff and/ or visitors that are not
phase
involved in construction activities of areas that pose risk;
▪ Installation of temporary speed bumps for speed control undertaken
within the construction site;
Noticeable public hazards from
6. the construction of the ▪ No hazards identified from construction of laboratory facilities.
facility
▪ The public has been notified of the works through appropriate
Notification and worker notification all over the Hospital
7. safety. ▪ All legally required permits (construction permit land use, re-source
use, dumping, sanitary inspection permit) have been acquired for
construction and/or rehabilitation
▪ Waste management and smoke emanating from the burning of the HCW to
Noticeable public hazards
8. the Staff headquarters. A transfer of the burning site to a distant
since the project is operating
site was recommended.
▪ Men and women managed to get jobs from the construction and the lab
Noticeable improvement of
staff has increased.
9. livelihood (jobs…)
▪ House owners, shop-keepers and other small business owners benefited
from the presence of construction workers.
Overall perception of the ▪ Clients using the service of the lab have substantially increased and
10.
project the Hospital services benefited from the improved quality of results.
▪ All the conditions pursuant to the issuance of the license were
Adherence with the ESIA adhered with.
11.
License conditions ▪ It is worth noting that very few respondents were aware of the
existence of any conditions to the issuance of the licence.
▪ The WRRL constructed within the Wajir District Hospital (WDH)
12. Land acquisition
compound
From the views collected, there was no major environmental or social hazard from the construction of the laboratory. On the
other hand, the whole project was well received by the locals courtesy of the strong sentiments shared.
CHAPTER FIVE: AUDIT FINDINGS
5.0 Introduction
This review and assessment is based on site reconnaissance visit conducted on 23rd to
24th April, 2017 and from the field visits and consultations conducted in the week of 5 th
to 9th June 2017.
The report provides findings, analysis and recommendations from the assessment of the
WRRL at the construction and operation phase besides the legal and regulatory review in
the construction and operation phases of the laboratory.
5.1 Legal and regulatory review

5.1.1 Findings
The assessment noted an on-going project to construct a modern incinerator. As at
the time of the audit, the construction had been stopped by NEMA since there was
no EIA done for the construction of the incinerator as required by the EMCA
(Amendment), 2015.
The original design of the project included the design for the construction of the
laboratory building but did not include the construction of the proposed modern
incinerator. Besides, the scope of the EIA prepared did not cover the proposed modern
incinerator though the assessment had proposed incorporation of a new standard
incinerator for the facility
The EIA waste regulations require that an EIA be done for any waste incinerator and a
licence be issued for its operation.
Section 45 of the Waste Management Regulations, 2006, stipulates that no person shall
own or operate a biomedical waste disposal site or plant without an EIA licence issued by
the Authority under the provisions of the Act and an operating license issued by the
Authority. Within six months after the commencement of these Regulations, operators of
bio-medical waste disposal sites or plants shall submit an Environmental Audit reports
and thereafter annual Audit Reports to the Authority.
5.1.2 Actions required

There was need to construct a well functioning incinerator under clause 7.4 (Operational
Phase EMP) of the prepared ESIA’s (Appendix 3).
As at the time of the audit, the project management had commissioned a consultant who
is assisting to complete the EIA for the modern incinerator as requested by NEMA Wajir
County Office, in order to comply with legal requirements and regulations. It is worth
noting that most of the non-conformities highlighted in the operation of the WRRL are
linked to the lack of a functional modern incinerator. The completion and commissioning
of the new incinerator, therefore, is crucial in the ultimate mitigation of most of the non-
compliance issues as far as HCWM at the facility is concerned.
5.2 Construction phase review

5.2.1 Findings
The construction of the WRRL started in 2012 on a site within the Wajir District Hospital
compound. It was completed and operationalized in 2015.
The project had triggered OP 4.01 and OP 4.10, World Bank safeguard policies on
Environmental Assessment and on the Indigenous people respectively. The audit
therefore sought to address any gaps in the GOK regulations and the safeguards set
to mitigate some of the negative impacts identified at the construction phase besides
ascertaining the impact of the project on the local community.The construction phase
of the WRRL project was completed in 2015.
In the construction of the WRRL, the construction activities did not result in any land
take, no displacement of people or loss of assets, incomes or livelihoods, and no risks to
vulnerable or marginalized groups since the site was within the existing Wajir District
hospital.
From the views collected, there was no major environmental or social

hazard from the construction of the laboratory an indicator of the effective
implementation of the proposed mitigation measures and monitoring as per
the prepared ESMP for the construction phase (
APPENDIX 6: CONSTRUCTION PHASE ESMP.).
Besides, the whole project was well received by the locals courtesy of the strong sentiments
shared as per the attached summary of the consultations (APPENDIX 4: MINUTES TO
THE STAKEHOLDERS MEETING).
5.2.2 Gaps identified

From the public consultations conducted and the questionnaire administered, it was noted
that no significant nuisances could be reported and safety measures such as fencing, PPE for
construction staff and public notices were set up. Most of the environmental and social
nuisances from the construction phase were limited in time and were of negligible impact.
5.2.3 Conclusion
The procedures required by the ESMF for the construction phase of the WRRL were fully
applied, including the preparation of an Environmental Impact Assessment (EIA) and the
Environmental Management and Monitoring Plan (EMMP) prior to the commencement of
construction activities. No fatal social and environmental flows could be observed due to the
low significance of the project impacts and the existing regulations in place.
5.3 Operation and Maintenance Phase Review

5.3.1 Findings
The World Health Organization Africa has set up the Stepwise Laboratory Quality
Improvement Process towards Accreditation (SLIPTA), a framework for improving quality of
public health laboratories in developing countries to achieve ISO 15189 standards. From the
2017 peer review audit, which had among other objectives to determine scores of WRRL
towards accreditation using the SLIPTA checklist, it was reported that the laboratory has
improved its performance substantially, reaching three stars, and surpassing the project
target of two stars, on a scale of five.
The annual SLIPTA audit assessment and monitoring on four key areas recorded a substantial
improvement in the management of biomedical waste at the site. This is depicted in the
trend in the composite scores table below;
Table 2: SLIPTA Composite Scores
Section Checklist item Max score Score
Is a laboratory safety manual available, accessible, and

12.9 3 3
up-to-date?
Is sufficient waste disposal available and is waste

12.10 2 2
separated into infectious and non-infectious waste, with
infectious waste autoclaved, incinerated, or buried?
Are hazardous chemicals/materials properly handled?
12.11 2 2
Are ‘sharps’ handled and disposed of properly in ‘sharps’

12.12 2 2
containers that are appropriately utilized?
9 9/9
Source: WRRL 2017 SLIPTA Audit Report
During the field assessment several commendable observations were made;

a. Safety manuals are readily available in work areas and the manuals specifically include
guidelines on key topics e.g. blood and body fluid precautions, hazardous waste
disposal, personal protection equipment; post-exposure prophylaxis, fire safety,
electrical safety, etc.
b. Good laboratory infrastructure and structural integrity. The laboratory is well designed
providing adequate space, engineering controls and proper environmental conditions
for storage and analysis of specimen in accordance with good laboratory practices,
laboratory safety requirements and applicable regulations;
▪ Clearly separated rooms (individual laboratories are separated according to
compatibility of testing activities).
▪ Biometric access control, adequate air conditioning, lighting, heating, and
ventilation are controlled and monitored.
▪ The individual laboratories are equipped with bio-safety hoods and chemical
hoods with adequate face velocities and minimal distortion of air movement (cross
drafts) to capture hazardous or odorous materials used or produced in the analyses
and to protect personnel from airborne toxic substances.
c. Waste Segregation at source. Waste is separated according to biohazard risk, with
infectious and non-infectious waste disposed of in separate containers and whether
sharp instruments and needles are discarded in puncture resistant containers.
d. Waste Management Records are well maintained at the Waste Storage Area. The
WRRL has a well labelled and lockable Waste Storage Area on the first floor with up to
date and well maintained waste management records. It’s therefore to ascertain the
quantities of waste generated by the laboratory and whether it has all been disposed of
in the recommended way.
e. Good laboratory safety and sanitation. The laboratory has in place a health and safety
committee and safety management guidelines such as the Policy and Procedures
Manual and Guidelines for chemical safety handling, incident, injuries and accidents.
Safety measures in place were found satisfactory at the WRRL. Sanitation measures
and facilities were found sufficient and fully operational at the laboratory.
f. Fire fighting equipment provided mostly comprised smoke detectors, hose reels and
fire extinguishers. These were located in strategic positions in and within the
laboratory premise. The fire fighting extinguishers were in good conditions as records
showed they were regularly inspected. Information, warning, and direction sign posts
were placed in all strategic areas.
g. Availability of well maintained waste management records at the lockable waste storage area
located on the first floor of the building.
h. Compliance with handling and disposal of sharps (syringes, needles, lancets, and other
bloodletting devices) capable of transmitting infection are used only once and are properly
discarded in puncture resistant containers that are not overfilled.
In conclusion, the assessment and the annual peer review report carried out in March 2017
indicates the general compliance of the WRRL in most of the areas audited.
5.3.2 Gaps identified

From the socioeconomic angle, the project comes with positive impacts. These include
job creation, improvement of the local economy and as a source of revenue to the local
and national governments. However, at this stage of project development, there are a
number of areas that need attention to ensure that the project meets acceptable
environmental and social performance and sustainability.
Like many health facilities in Kenya, the main challenge facing the WRRL operation
continues to be healthcare waste management (HCWM). Areas of particular concern in
HCWM practice involve how waste incineration and wastewater removal are treated, as
both have broader impacts beyond the level of individual facilities.
Waste at the facilities is disposed of by burning in an open pit and the sharps in a ‘local
incinerator’. The County Government incinerator malfunctioned on 20th January 2016
having been commissioned in June 2015. As a result, a ‘local incinerator’ for disposal of
sharps and a shallow burning pit are being used for the disposal of the HCW (Figure 1 &
Figure 2 below).
Figure 1: showing the ‘local incinerator’
Figure 2: Showing the open pit burning site
Figure 3: Showing the new modern incinerator under construction.
Health Care wastes (HCW) include sharps (syringes, disposable scalpels, blades, etc.), non-
sharps (swabs, bandages, disposable medical devices, etc.), blood and anatomic waste (blood
bags, diagnostic samples, body parts, etc.), chemicals (solvents, disinfectants, etc.),
pharmaceuticals, and others, and may be infectious, toxic, create injuries or be radioactive.
The Wajir County Government has contracted the HCWM and general cleanliness at the
facilities to Saelf Cleaning Services Company. During the assessment no complaint was raised
against the service provision of the company. The company is responsible for availing all the
waste collection materials as per the different waste categories and provision of PPEs to the
waste handlers and also for the transportation of the waste to the disposal site located behind
the laboratory.
Saelf Cleaning Services Company however did not have a NEMA license to collect and dispose
of healthcare waste and to manage other types of solid waste at the time of assessment. Thus,
Saelf’s operation was not in compliance with the stipulations of the Environmental Management
and Coordination (Waste Management) Regulations, 2006.
The Health and Safety Officer at the Wajir District Hospital and the Bio-safety Officer at the
Laboratory supervises the waste management at the respective facility.
The assessments held at the facility highlighted various challenges and deficiencies of the
HCWM system:
1. Shallow, unlined and overfilled burning pit.
Transmission of disease through infectious waste is the greatest and most immediate
threat from healthcare waste. If waste is not treated in a way that destroys the pathogenic
organisms, dangerous quantities of microscopic disease causing agents - viruses, bacteria,
parasites or fungi - will be present in the waste. These agents can enter the body through
punctures and other breaks in the skin, mucous membranes in the mouth, by being
inhaled into the lungs, being swallowed, or being transmitted by a vector organism.
Unlined pits can easily contaminate groundwater if the pits have been dug below the
water table. Wajir is known to have a low water table and there’s therefore need to align
the pits with bricks or polythene.
2. Unrestricted access to the burning site.
Open access to disposal area allows insect and animal vectors to spread pathogens
contained in he waste. Wastepickers, health workers and children at play are directly
exposed to infectious agents.
Figure 4: Showing animals scavenging waste at the burning site taking note
of the neighboring staff quarters and the large quantities of plastics.
3. Burning of waste containing plastics and proximity of the disposal site to the staff
quarters.
This is not only a violation of the laws in place but also a threat to the people and the
environment at large. There are no measures for emission control in place, and can
therefore be a source of air pollution, putting the community at risk of diseases like upper
respiratory tract infection.
This is because dioxins and furans are released from incomplete combustion processes
that characterize low temperature burning of hazardous wastes that are known to contain
carcinogenic materials such as various plastics. Thus, persistent organic pollutants (PoPs),
acidic and corrosive fumes are released which are inhaled by adjacent populations to
HCFs, who themselves are unaware of the ill respiratory effects of the smoke plumes.
Additionally, the release of pathogens from incomplete combustion poses other public
health risks
From the interviews conducted, already there are complaints from the staff quarters
concerning the smoke and smell emanating from the onsite waste burning. The quarters
are adjacent to the waste burning site (Figure 4).
4. Scattered broken sharps at the ‘local incinerator’.
Even if disinfected, sharps in ashes still pose physical hazard.
Figure 5: Showing scattered broken sharps at the ‘local incinerator’
5. Manual Waste Transportation
Waste is transported manually to the disposal and burning site, putting the waste
handlers at risk of injuries and infections.
5.3.3 Conclusion and Actions required

The operation and maintenance phase of the laboratory meets the safeguards requirements in
terms of staff health and safety and quality of service. This finding is consistent with the
improved score of the laboratory, as measured through the SLIPTA composite scores. The
laboratory management shall however enforce the existing regulations to ensure that safety
and quality measures are fully applied.
Finally, healthcare waste disposal can be improved at the facilities with the management
setting up sustainable measures for waste management (waste burning) and enforcement of
the existing regulations.
Taking into account the prepared ESMP for the project operation phase, a revised
Environmental and Social Monitoring and Mitigation Plan (ESMMP) (Table 3) has been
developed with regard to the formulated recommendations to assist the proponent in
mitigating the non-compliance issues identified during the audit and for continuous
improvement. It is noteworthy that key factors and processes may change in the course of
the project life and considerable provisions have been factored for dynamism and flexibility
of the ESMMP. As such, the EMMP will be subject to a regular regime of periodic review.
Table 3: Action plan (ESMMP) to address potential adverse effects during the operation phase at the WRRL
Cost
Monitoring Monitoring
Component Action/Mitigation Measures Indicators Evaluation Estimate
Required responsibility
(KShs.)
▪ Consider practices & ▪ Implement & ▪ Efficient solid Reports on ▪ Public
procedures to minimize waste check record waste ▪ Anomalies in Health
generation without sacrificing keeping for management. segregation Officer
patient hygiene and safety temperature, waste ▪ Records/Logs of practices of ▪ Health and
considerations; segregation & solid waste waste arriving Safety
▪ All waste to be handled and quantities of waste quantities. at incinerator; committee
managed in accordance with arriving for ▪ Proper waste ▪ Incinerator ▪ Bio-safety
the Environmental incineration. segregation functioning committee.
Management and Coordination ▪ Increased (upper limit
▪ Waste ▪ EAPHLNP
(Waste Management) monitoring by the temperatures
management project
Regulations of 2006; lead agency, obtained; liner
training programs managemen
▪ Transport waste to storage NEMA. cracking etc.); t unit.
Waste areas on designated trolleys ▪ Assess (c) exhaust
▪ NEMA
Generation which should be cleaned and implementation of venting; (d)
disinfected regularly; revised EMMPs complaints 2M
&
Management ▪ Ensure construction of the new from adjacent
incinerator meets the standards community etc.
specified in the Environmental ▪ Compliance
Management and Coordination with the EMCA
(Waste Management) requirements
Regulations of 2006 and for the annual
applicable international EA report
standards.
▪ Monitor implementation to
ensure proper management of
the incinerator once completed.
County Government of Wajir to ▪ Verification of ▪ Valid NEMA Annual EA report ▪ Bio-safety

Collection, ensure waste handling is done by waste licenses for the committee.
management a company which is duly licensed transportation management of all
▪ EAPHLNP
and disposal by NEMA licenses from types of waste,
project
of NEMA. including for
managemen 0.5M
Healthcare ▪ Verification of healthcare waste.
t unit.
waste and tracking ▪ Waste disposal
▪ NEMA
other solid documents vis-à- records to be
wastes. vis waste monitored
generation records continuously
▪ Development and ▪ Visit sites and ▪ Efficient solid Annually ▪ Health and
implementation of operational use Assessment waste Compliance with Safety
guidelines/directives on health tool in management. the OSHA committee
and safety during the (APPENDIX 1: ▪ Health and safety requirements for ▪ Bio-safety
operations of the lab. HCWM operational the annual audit committee.
▪ Conduct statutory assessments ASSESSMENT guidelines/directiv report. ▪ EAPHLNP
i.e. risk assessments, fire safety SURVEY es are developed Compliance of project
audits and Occupational Safety TOOL.) to assess and implemented. the air managemen
and Health audits annually compliance
▪ Occupational measurements t unit.
through licensed advisors and ▪ Periodic Safety and Health with the
Occupational ▪ NEMA
auditors by the Directorate of inspections by audits permissible levels
health and
Occupational Safety and Health the EAPHLNP under the air 3.5M
safety ▪ Annual Fire risk
Services (DOSHS); management quality regulations
assessments
▪ Conduct basic occupational team 2014.
▪ Bio-safety,
training programs and statutory ▪ Health & safety
occupational
trainings under OSHA, 2007 committee to
safety and health
and Rules under it. i.e. basic inspect the
trainings.
first aid, fire safety training, and available fire
Occupational Safety and Health detection and fire ▪ Safety and Health
committee training through fighting committees.
approved training institutions equipment and ▪ Incidents
by the DOSHS; address their monitoring
▪ Conduct drills at reasonable efficiency and ▪ No Injuries or
intervals to test the disaster adequacy. cross infections.

preparedness level at the ▪ Weekly checks of ▪ Safety and Health
workplace, using the results to PPE use in Year management and
improve the response One. monitoring plan
mechanisms;
▪ Assess ▪ Annual
▪ Ensure proper PPE is implementation documentation of
consistently available to staff of revised PPE checks.
and that this is used. EMMP. ▪ Reduced
▪ Regular training for emergency ▪ Reports on air complaints from
response. measurements the staff quarter
▪ Restriction of access to high from the residents
risk areas to authorized incinerator and
personnel only i.e. radiation open pit burning
rooms, surgery rooms;
▪ Air quality measurements
▪ Implement an appropriate re- ▪ The management ▪ Observation Continuous ▪ WRRL
vegetation programme to should plan for Manageme
restore the site to its original the establishment nt
status. of trees and other
▪ Consider use of indigenous aesthetic plants
Lack of plant species in re-vegetation. within and
enough around the
▪ Trees should be planted at 10,000
facility
vegetation suitable locations so as to
interrupt slight lines (screen per
cover around month
the Health planting), between the adjacent
Care Facility residential area and the
development.
▪ Harvest rainwater from roof
for non-portable uses e.g.
cleaning and watering plants
during the dry season.
CHAPTER SIX: CONCLUSION AND RECOMMENDATIONS

The project can be termed as a success owing to the positive sentiments shared with
regard to the provision of quality health care which is accessible and accommodative to
all Wajir town residents and beyond.
From the socioeconomic angle, the project comes with positive impacts. These include
job creation, improvement of the local economy and as a source of revenue to the local
and national governments. However, at this stage of project development, there are a
number of areas that need attention to ensure that the project will meet acceptable
environmental performance and sustainability. Most of the issues have been discussed
in the earlier sections of this report and should be followed up and implemented.
For the purposes of compliance and continuous improvement, the following

recommendations were formulated;
6.1 Improve the on-site burning of waste
The on-site burning can be further improved by digging another open pit but above the
water table or lined with clay or plastic, and protected by a fence or other effective barrier
(e.g., rows of thorny brush).
Appropriate handling, treatment, and disposal of waste by type can help to reduce costs and
does much to protect public health.
Spattered broken sharps at the burning site pose a health hazard and their frequent collection
will reduce the accidents.
6.2 Waste Transportation
Acquisition of adequate and dedicated number of transport bins and trolleys with separate
ones for infectious waste to be drawn on paved surfaces to the waste treatment site.
6.3 Proper Incinerator Management.
The old incinerator malfunctioned due to non-adherence to the six month maintenance
schedule leading to the gasket failure. With the expected completion of the modern
incinerator, the management should put incinerator management at the pinnacle of the
HCWM program.
Not to be treated cavalierly by being manned by casual labourers (often not well educated)
for proper operation, keeping records on temperature levels attained, weighing and
recording the waste by segregated category (extremely hazardous, hazardous, or general).
This is an important job pivotal to HCWM and it requires dedicated effort of a well trained
professional.
Most of the challenges and deficiencies highlighted earlier can be well addressed with the
completion and proper operation of the modern incinerator.
The need to expedite the completion of the modern incinerator should be addressed through
finalization of the requested EIA to avert further delays and ensure compliance with national
environmental laws and regulations.
6.4 Monitoring
The National Environment Management Authority (NEMA) is a body that was

established by an Act of parliament as the principal agency in charge of coordination,
monitoring and supervision of all environmental management issues in the country.
This it does in coordination with the County Environmental officers resident in every
County in Kenya. Although NEMA largely relies on a system of ‘self compliance’,
improved monitoring will ensure the facility receives technical guidance that would be
derived from the monitoring visits to enable them take corrective or preventative
action where possible.
There is also need to monitor and report on the implementation of environmental

management tools like ESMF, EMP prepared at the beginning of the project so as to keep
historical records and facts. This would help in improving compliance and serve as a written
basis for other environmental initiatives like environmental auditing.
6.5 Initiate Waste Recycling System
Organisations and cities will always have a challenge in the disposal of wastes, the by
products and the residual wastes thereof. With traditional techniques being flawed, the need
for disposal has been made harder because of the legal requirements in all countries, which
require safe disposal.
The need to produce without pollution is the preferred model and the strategy of waste
minimization is seen as the best way forward. This is particularly relevant; where large
quantities of wastes are produced this always pose formidable disposal problems.
Waste minimization usually benefits the waste producer in terms of costs for; the purchase of
goods, waste treatment, and disposal of hazardous waste. It is important to investigate
feasible options for waste minimization / reduction, recycling. The procurement department
and the lab head should be involved in making these important decisions on the choice of
health products or equipment for use.
Significant reduction of waste generated may be encouraged by the implementation of

certain policies and practices such as;
➢ Source reduction: measures such as purchasing restrictions to en-sure the selection of

methods or supplies that are less wasteful or generate less hazardous waste.
➢ Recyclable products: use of materials that may be safely recycled, either on-site or off
site.
➢ Good management and control practices: apply particularly to the purchase and use of
chemicals and pharmaceuticals. i.e. frequent ordering of small quantities of supplies
and using old batches of a product first.
Besides the above recommendations, a comprehensive Environmental and Social

Management and Monitoring Plan (ESMMP) has been formulated and sufficient
mitigation measures for the operational non-compliance have been proposed therein. In
this regard, it’s therefore recommended that the laboratory management fully
implement the ESMMP (Table 3).
CHAPTER SEVEN: REFERENCES
i. Kenya gazette supplement number 56. Environment Impact Assessment and Audit
Regulations 2003. Government printer, Nairobi.
ii. Kenya gazette supplement number 69. Environmental Management and Coordination
(waste Management) Regulations 2006. Government Printer Nairobi.
iii. Kenya gazette supplement number 68. Environmental Management and Coordination
(water quality) Regulations 2006. Government Printer.
iv. Kenya gazette supplement Acts 2000, Environmental Management and Coordination
Act Number 8 of 1999.Government Printers, Nairobi.
v. Operational Policies, The World Bank Operational Manual, Jan 1999.
vi. EIA Project report for the proposed laboratory for Wajir district hospital in Wajir,
2012.
vii. USAID Kenya environmental compliance health care waste management in Kenya,
2012.
viii. Ministry Of Health Kenya, The National Health Care Waste Management Plan 2016 –
2021
ix. Ministry of Health Kenya, 2007, National Policy on Injection Safety and Health Care
Waste Management.
x. Parker MT (1978). Hospital-acquired infections: guidelines to laboratory methods.
Copenhagen, World Health Organization Regional Office for Europe (European
Series, No.4).
xi. Republic of Kenya, Reversing the Trends: The Second National Health Sector
Strategic Plan-Annual Performance Report July 2007–June 2008 (Annual Operational
Plan 3 Report)
xii. WHO, 2005, Decision making Guide, Management of Solid Health Waste at Primary
Health Care Centres.
CHAPTER EIGHT: APPENDICES

APPENDIX 1: HCWM ASSESSMENT SURVEY TOOL.
The following is an example of the 50 samples collected under this HCWM Assessment. The findings reported in the previous
sections reflect the full collection and analysis of the data collected.
OPERATION ITEM
PARAMETER (CHECKLIST ITEMS) COMMENTS
AREA/ACTIVITY No.
Laboratory unit 1 Do you do cultures and sensitivity tests?

1.2 If yes do you autoclave highly infectious waste?
1.21 For waste water disposal in the lab, Ask following questions:
Is Waste water mixed with other waste water into one common drain
Is waste water Pretreated prior to release into to the common drain.
1.3 Is another method used?
1.31 Is a bio-safety hood/cabinet provided?
1.32 Is the hood functioning?
1.33 Are safety boxes provided?
1.34 If yes above were they three quarters full [also above 3/4 full applies]
1.35 Are the bins provided with a foot pedal/ alternative lid technology?
1.4 Where do you dispose the samples in the lab[ blood, urine, sputum etc];
1.41 Red bin
1.42 Yellow bin
1.43 Black bin
1.5 Are the bins labeled correctly as indicated below?
Red (highly infectious waste )
Yellow ( infectious waste )
Black ( general waste )
1.6 Do you see a container with disinfectant
1.61 Do you see Standard Operating procedures for handling blood/waste spillages?
1.62 Do you see segregation posters?
2.7 Does the x ray operator have the radiation monitoring badge?
Health Care Waste 2 For the health care Waste handler working in the incineration unit, is she/he wearing:
Handler 2.1 Boots?
2.2 Helmets?
2.3 Gloves?
2.4 Respirator?
2.5 Industrial Gloves
2.6 Apron/Overall?
Waste treatment 3 Are wastes collected daily?
practices 3.1 Are wastes treated with a frequency appropriate to the climate and season?
3.1.1 Warm season in warm climates within 24 hrs
3.1.2 In the cool season in warm climates within 48 hrs
3.1.3 In the warm season in temperate climates within 48 hrs
3.1.5 In the cool season in temperate climates within 72 hrs
3.2 Are wastes disinfected before disposal?
3.3 Are wastes being burned in the open air, in a drum or brick incinerator, or a single-chamber incinerator?
3.4 If not are they being buried safely (in a pit with an impermeable plastic or clay lining)?
3.5 Is the final disposal site (usually a pit) surrounded by fencing or other materials and in view of the facility
to prevent accidental injury or scavenging of syringes and other medical supplies?
3.6 If the waste is transported off-site, are precautions taken to ensure that it is transported and disposed of
safely?
Health Care Handling & 4 Please observe the presence /absence of the following:
Waste storage Area. 4.1 Are all doors locked?
4.2 Holes in the walls?
4.3 Vents?
4.4 Leakage from roofing?
4.5 Pot holes?
4.6 Tilting floor toward the door?
4.7 Is the designated area labeled:
4.71 Highly infectious Waste?
4.72 Infectious Waste?
4.73 Sharps waste?
4.74 General waste
4.8 Is a record book available?
4.81 Are records for waste received at the storage unit visible for each of the last 7 days?
4.9 Minimization, reuse, and recycling procedures?
Incinerator/Waste 5 Do you see an incinerator?
treatment area 5.1 If no, ask to see records for HCW disposal that is outsourced.
5.2 If outsourced, are there records proving outsourcing at least for the past 4 weeks?
5.3 Do you see an incinerator shed?
5.4 If there is an incinerator, is the incinerator area fenced?

Is the incinerator door locked?
Do you see at least 4 temperature readings recorded for the last 6 weeks?
Is there a Standard Operating Procedure document available within the incineration unit?
Is there an incineration log? (Last 4 weeks/at least once per week)
Go to records proceeding the month of January. Do you see entries for incinerator use that week?
Go to the preceding month of June. Do you see at least four entries for incineration?
Is there an ash pit visible in the vicinity?
Do you see a concrete slab covering the ash pit?
Is the distance between the principal incinerator and the community greater than 30 meters?
Is the distance between the principal incinerator and any patient ward greater than 30 meters?
Is there any cropping within 300metres of the incinerator?
Waste Transport Unit 6 Are waste transport trolleys with bins provided?
6.1 Are they color coded? (Red, yellow & black)
6.3 (Ask the person) Is the floor smooth enough to transport the waste from generation to disposal without
spillage?
Is Health Care waste transported by mixing all types of wastes together[red, yellow, black]
Is each type of waste transported separately to the waste storage room
Staff Training, Practices, 7 Staff trained in safe handling, storage, treatment, and disposal.
and Protection 7.1 Do staff exhibit good hygiene, safe sharps handling, proper use of protective clothing, proper
7.2 Packaging and labeling of waste, and safe storage of waste?
7.3 Do staff know the correct responses for spills, injury, and exposure?
7.4 Protective clothing available for workers who move and treat collected infections waste such as surgical
masks and gloves, aprons, and boots.
7.5 Good hygiene practices. Are soap and, ideally, warm water readily available workers to use and can
workers be observed regularly washing.
7.6 Workers vaccinated for against viral hepatitis B, tetanus infections, and other endemic infections for
which vaccines are available.
Written Plans and 8 Written waste management plan Describing all the practices for handling, storing, treating, and disposing
Procedures of hazardous and non-hazardous waste, as well as types of worker training required.
8.1 Internal rules for generation, handling, storage, treatment, and disposal of healthcare waste.
8.2 Clearly assigned staff responsibilities that cover all steps in the waste management process.
8.3 Staff waste handling training curricula or a list of topics covered.
8.4 Waste minimization, reuse, and recycling procedures
APPENDIX 2: QUESTIONNAIRE FOR STAKEHOLDER CONSULTATIONS
APPENDIX 3: OPERATIONAL PHASE ESMP

The necessary objectives, activities, mitigation measures, and allocation of responsibilities pertaining to prevention, minimization and monitoring of
significant negative impacts and maximization of positive impacts associated with the operational phase of proposed Health Care Project are outlined in the
table below.
Table 7: Environmental Management Plan for the operation phase
Environmen Mitigation Responsibility Monitoring means Monitoring Monitoring Duration &
Tal frequency by budget
Concerns
Safety Such holes should be filled with soil or Management Observation One off An EIA Ksh.20,
Likely open covered with a concrete cover should be to ensure that activity Expert and 000
fitted with openable grills. any open pits the
Health and Waste bins should never be placed Management Observation Continuous An EIA Ksh.5,
Safety within the patients’ waiting shades, to ensure that activity Expert and 000 per
For Patients especially those holding medical waste this is the month
and general implemented management
public
Health and All staff within the facility should be in Management Observation to ensure Continuous An EIA Ksh.5,
Safety protective gears at all times that this is activity Expert & the 000
Lack of implemented management
protective
gears
Health and Reporting all incidents and accidents to Management Observation to ensure Continuous An EIA
Safety include details of: -The nature of the that this is activity Expert and
within the accident or incident; implemented the
facility The place and time of the accident or management
incident; The staff who were directly
Accidents involved; Any other relevant
circumstances
Health and -Evacuate the contaminated area; Management Observation Continuous An EIA
Safety Decontaminate the eyes and skin of to ensure that activity Expert and
exposed personnel immediately; Inform this is the
spillages the designated person (usually the implemented management
Waste Management Officer), who
should coordinate the necessary
actions.; Determine the nature of the
spill; Evacuate all the people not

involved in cleaning up if the spillage
involves a particularly hazardous
substance; Provide first aid and medical
care to injured individuals;
Secure the area to prevent exposure of
additional individuals; Provide adequate
protective clothing to personnel
involved in cleaning-up; Limit the
spread of the spill;
Neutralize or disinfect the spilled or
contaminated material if indicated;
Collect all spilled and contaminated
material. [Sharps should never be
picked up by during this process,
because this will spread the
contamination. The decontamination
should be carried out by working from
the least to the most contaminated part,
with a change of cloth at each stage. Dry
cloths should be used in the case of
liquid spillage; for spillages of solids,
cloth impregnated with water (acidic,
basic, or neutral as appropriate) should
be used.
-Rinse the area, and wipe dry with
absorbent cloth.
-Decontaminate or disinfect any tools
that were used.
-Remove protective clothing and
decontaminate or disinfect it if
necessary.
-Seek medical attention if exposure to
hazardous material has occurred during
the operation.
Latrines The walls and floors of the latrines and Management Observation to ensure One off An EIA Ksh.300,
and other walls of public areas should be fitted that this is activity Expert and 000
public with white smooth tiles for easy cleaning implemented the
areas management
Water Initiate roof water harvesting and install Management Observation are fixed One off An EIA Ksh.200,
harvesting water storage tanks activity Expert and 000
and storage the
facilities management
Poor waste -Construct a well functioning Management Observation A continuous An EIA Ksh.500,000
disposal incinerator activity to ensure Expert and
-sort waste at source -connect all that appropriate the
laboratory sink to a functioning solid and liquid management
biomedical liquid waste treatment waste
system. management is
established
Lack of -The management should plan for the Management Observation A continuous An EIA Ksh.10,000
Enough establishment of trees and other activity Expert and
vegetation aesthetic plants within and around the the
cover around facility management
the Health
Care Facility
APPENDIX 4: MINUTES TO THE STAKEHOLDERS MEETING
Minutes of Consultations with
Stakeholders of Wajir Town on the
Environmental & Social Impacts of

the
Constructed Wajir Regional Referral
Laboratory under the World Bank

funded EAPHLN Project.
Introduction
The Consultant engaged the stakeholders to gather knowledge, concerns and their awareness
of the constructed new public health laboratory (Wajir regional referral laboratory) at the
Wajir District Hospital under the East Africa Public Health Networking Project. This was
held on 6th June 2017 at Wajir Guest House in Wajir town and follow-up discussions were
conducted on the 7 th June 2017. The Consultant together with Mr. Abbey (Head of WRRL)
engaged the local community to share their knowledge on any social and environmental
hazards experienced at the construction phase, any benefits and complaints since the
commissioning of the constructed laboratory and the way forward.
Agenda
To engage the community of Wajir county in Wajir town as key stakeholders on the
environmental and social performance of the constructed WRRL.
Minute 1
The meeting started at 10:00 am
The Consultant took the public through the project step by step as follows:
a. Introduction of the project - East Africa Public Health Networking Project (EAPHLN) that
included WRRL as one of the locations to benefit from the establishment of a new public
health laboratory.
b. The objective of the audit ascertain the effectiveness of the safeguard policies put in place
before and during the construction and operation phases.
Participants’ views and concerns about the project During the Construction and operation
phases were sought using simple questions and recordings for those able to read and write.
They were encouraged to freely express their views, and to cite any complaints in the
questionnaire based on the explanations provided by the Consultant. The Consultant engaged
the local community Representatives and officials on one to one basis to gather insight on the
overall performance of the project. All the participants were aware of the project existence
and were enthusiastic about the gains and services, including the increase in the number and
type of laboratory diagnostic tests, leading to better healthcare management and shortening of
the time patients will spend waiting for laboratory results.
The team then explained to participants that there are potential risks associated with the
project during construction and during the operational stages. In view of the project’s
magnitude and activities, it lead to some positive impacts, such as the creation of job
opportunities (both directly and indirectly), and provision of the much-needed hospital
laboratory services for the people of Wajir and its surroundings.
One of the participants narrated the youth (from the surrounding communities) job creation as
one of the most realized impact not to mention that the unemployment was a major concern.
Another talked of the laboratory services having indirectly spruced up the gain of business
opportunities of the local business community courtesy of the increased activity at the district
hospital by the construction.
To minimize public health hazards posed by the project construction, some measures were
taken, including scaffolding/fencing of the site during the construction period, provision of
protective gears to all workers, provision of sanitation facilities to the workforce during the
construction period, provision of first aid kits on site, erection of the appropriate signage to
direct the public and provisions were made in case of fires and emergency exits proposed.
The Consultant engaged the participants on whether the proposed measures were
implemented and effective.
Most of the people acknowledged the fencing off of the construction site and they fully
supported the work since they knew most of the workers employed at the site. They
supported the wearing of uniform protective gear and noted that the hospital had provided
one of the public ablutions for the workers at the site.
At the operationalization of the laboratory they noted quicker delivery of tests (services)
serving the communities in Wajir town and others from within the County, including patients
from different regions coming for services at the facility. The influx has created a bigger
market opportunity for the business community and improved social interactions.
The participants expressed satisfaction of the employment opportunities created for children
and several clinical officers and nurses. One resident reiterated that the support for
tuberculosis testing was very important to him since the disease was a big challenge to the
poor people in the vicinity.
Despite the numerous sentiments shared, the participants raised concerns with the project
operationalization especially with the open pit dumping and burning of the waste collected
from the Laboratory and the Wajir District Hospital. Some of the members complaint of the
smoke and strong stange emanating from the waste burning, regretting the failure of the
County Government incinerator located behind the Laboratory. The participants
(complainants) were later realized to be the staff residing in the staff quarters adjacent to the
poorly fenced dumping and burning site. They talked of the need to dig another pit for
dumping since the current one was filled up causing littering in the area and their desire to
have the site relocated to save them from the persistent toxic fumes. As part of the mitigation,
the Consultant informed the participants that a modern incinerator will be installed and that
all dangerous hospital waste will be disposed off through the incinerator and thereby creating
a clean environment.
The stakeholders included members of the community such as professionals, business people,
travelers and members of Non Governmental Organizations who were willing to contribute to
the consultation at the stakeholder’s forum. Attached please find the list of participants.
Suggestions from participants
▪ The need to dig another pit for dumping since the current one was filled up causing
littering and affecting the aesthetic value of the area;
▪ Proper fencing of the dumping site to prevent access of vectors to the infectious
waste;
▪ Relocation of the burning site (off-site burning of waste) to save them from the
persistent toxic fumes.
▪ Community actors highlighted the need to educate the public about the importance of
seeking health services through educational materials.
▪ Continual monitoring and oversight on the project environmental impact and of other
impacts is important.
▪ Means of evaluating performance should be developed jointly with the local public
health office and the supporting partner, the WB.
CONCLUSION
I take this opportunity to appreciate support from the EAPHLN Project Management Unit
and the WRRL management for this exercise that has definitely had a positive impact on the
community. The implementation of the recommendations will ensure sustainability and
continual improvement of the project.
Report prepared by
Bonventure N. Okanga
Consultant
APPENDIX 5: STAKEHOLDERS MEETING PARTICIPANTS

No. Name Designation/profession/jo Email/telephone
b
1. Winfred Jerusha Health Officer – Wajir 0728659634
district hospital
2. Mr. Siachi Head – NEMA Wajir 0720328873
3. Mohamed A. Businessman [email protected]
Muktar
4. Abdirahman M PHO [email protected]
Abdille
5. Farhiya H. Ali Grocery [email protected]
6. Sahara Humey Sub-County Laboratory
7. Abdiaziz Omar Teacher [email protected]
8. Abdullahi Nurse [email protected]
Abdille
9. Mohamed A. Driver
Abdille
10. Fatuma Farah Nurse
11. Muktar Hassan [email protected]
12. Mohamed Hussein Businessman [email protected]
m
13. Osongo Justus Lab Tech
14. David Okoth Head teacher - Faulu Sec 0729273353
15. Chief Ibrahim Wajir Township 0720597941
16. Halima Omar Business lady
17. Haji Rashid Hotel 0722307892
Yakub
18. Ambia Ahmed Student Wajir college
19. Shukri Ali Clinical Officer [email protected]
Mohamed
20. Abdullahi Adow Electronic business 0724421777
Hamza
21. Nasra H. Ali Business lady in Wajir 0723977075
town
22. Josphine PHO [email protected]
23. Elama Abdi Dep Disable 0722179214
24. Mercy Munene Clinical Officer 0720212628
25. Fatuma Sahara Housewife 0727441111
Ahmed
26. Mohamed hasan Driver – golden coach 0720016741
abdi
27. Maryan Ali Grocery 0724810668
28. Hadha Adan Veterinary Officer 0727918843
29. Mzee Abdille Businessman 0724815753
30. Jenniffer Okoth Dental Technician 0711887165
31. Hassan Issack KPLC 0723970185
32. Maalim Imam 0720341514
Abdullahi
APPENDIX 6: CONSTRUCTION PHASE ESMP.
Table 6: Environmental monitoring/Management plans for the construction phase.
Estimated
Expected Recommended Mitigation
Responsible Party Time Frame Cost
Negative Impacts Measures
(Kshs)
1. Source building materials from local suppliers who use Resident Project Manager Throughout
environmentally friendly processes in their operations. & Contractor construction period
2. Ensure accurate budgeting and estimation of actual
Resident Project Manager Throughout
construction material requirements to ensure that the least
& Contractor construction period
amount of material necessary is ordered.
3. Ensure that damage or loss of materials at the construction Resident Project Manager Throughout
Part of the
site is kept minimal through proper storage. & Contractor construction period
main budget
4. Use of some recycled/refurbished or salvaged materials to
reduce the use of raw materials and divert material from
landfills.
High Demand Civil Engineer, Architect
5. Specify locations for trailers and equipment, and areas of the
of Raw materials and Resident Project 1 month
site that should be kept free of traffic, equipment, and storage.
Manager
Civil Engineer, Architect
6. Designate access routes and parking within the site. and Resident Project 1 month
Manager
7. Introduction of vegetation (trees, shrubs and grass) on open Architect, Resident Project
Monthly to
spaces and their maintenance, especially at the front side of the Manager & Landscape 100, 000.00
Annually
development specialist
8. Design and implement and appropriate landscaping During the
Architect & Landscape
programme to help in re-vegetation of part of the project area beginning phase of
specialist
after construction. the project
1. Roof water to be harvested and stored in
underground/ground reservoirs for use in cleaning and in the The Civil Engineer, During the
toilets. To ensure the use of such water for the stated purposes, Mechanical Engineer and beginning 100, 000.00
Increased storm
the building should be fitted with a dual water distribution Resident Project Manager phase of the project
water, runoff and
system.
soil erosion
2. A storm water management plan that minimizes impervious The Civil Engineer,
area infiltration by use of recharge areas and use of detention Mechanical Engineer and 1 month 50, 000.00
and/or retention with graduated outlet control structure will be Resident Project Manager
designed.
The Civil Engineer,
3. Apply soil erosion control measures such as leveling of the
Mechanical Engineer and 1 months
project site to reduce run-off velocity and increase
Resident Project Manager
1. Use of an integrated solid waste management system i.e.
through a hierarchy of options: reduction, sorting, re-use,
recycling and proper disposal
2. Through accurate estimation of the sizes and quantities of
materials required, order materials in the sizes and quantities Resident Project Manager
One off
they will be needed, rather than cutting them to size, or having & Contractor
large quantities of residual materials.
3. Ensure that construction materials left over at the end of
construction will be used in other projects rather than being One off
& Contractor
disposed of. 50,000
4. Ensure that damaged or wasted construction materials
including cabinets, doors, plumbing and lighting fixtures, Resident Project Manager
One off
marbles and glass will be recovered for refurbishing and use in & Contractor
other projects
5. Donate recyclable/reusable or residual materials to local Resident Project Manager
One off
community groups, institutions and individual & Contractor
Increased solid
6. Use of durable, long-lasting materials that will not need to be
Waste generation Resident Project Manager Throughout
replaced as often, thereby reducing the amount of construction
waste
7. Provide facilities for proper handling and storage of
construction materials to reduce the amount of waste caused by One off
& Contractor
damage or exposure.
8. Purchase of perishable construction materials such as paints
should be done incrementally to ensure reduced spoilage of
unused materials
9. Use building materials that have minimal or no packaging to Resident Project Manager Throughout
avoid the generation of excessive packaging waste & Contractor construction period
10. Use construction materials containing recycled content Resident Project Manager Throughout
when possible and in accordance with accepted standards. & Contractor construction period
11. Reuse packaging materials such as cartons, cement bags, Resident Project Manager Throughout
empty metal and plastic containers to reduce waste at the site & Contractor construction period
12. Dispose waste more responsibly by dumping at designated Resident Project Manager Throughout
dumping sites & Contractor construction period
Exhaust Resident Project Manager Throughout
1. Vehicle idling time shall be minimized 50,000
emission & Contractor construction period
2. Alternatively fuelled construction equipment shall be used

where feasible; equipment shall be properly tuned and
maintained
3. Sensitize truck drivers to avoid unnecessary racing of vehicle
engines at loading/offloading points and parking areas, and to
switch off engines at these points
1. Sensitize construction vehicle drivers and machinery
operators to switch off engines of vehicles or machinery not
being used.
2. Sensitize construction drivers to avoid gunning of vehicle
engines or hooting especially when passing through sensitive
areas such as churches, residential areas and hospitals
Noise and 3. Ensure that construction machinery are kept in good Resident Project Manager Throughout
50,000
vibration condition to reduce noise generation & Contractor construction period
4. Ensure that all generators and heavy duty equipment are
insulated or placed in enclosures to minimize ambient noise
levels.
5. The noisy construction works will entirely be planned to be
during day time when most of the neighbors will be away at
work.
1. Ensure electrical equipment, appliances and lights are Resident Project Manager Throughout
switched off when not being used & Contractor construction period
2. Install energy saving fluorescent tubes at all lighting points Resident Project Manager Throughout
instead of bulbs which consume higher electric energy & Contractor construction period
Increased energy Part of the
3. Ensure planning of transportation of materials to ensure that
consumption Resident Project Manager Throughout main budget
fossil fuels (diesel, petrol) are not consumed in excessive
amounts
4. Monitor energy use during construction and set targets for Resident Project Manager Throughout
reduction of energy use. & Contractor construction period
1. Provision of means for handling sewage generated by Mechanical Engineer, Throughout
construction workers proponent and Resident construction period
2. Conduct regular checks for sewage pipe blockages or
Generation of Mechanical Engineer, Part of the
damages since such vices can lead to release of the effluent into One off
wastewater proponent and Resident main budget
the land and water bodies
3. Monitor effluent quality regularly to ensure that the Mechanical Engineer, Throughout
stipulated discharge rules and standards are not violated proponent and Resident construction period
Machinery/ 1. Arrangements must be in place for the medical examination
Resident Project Manager,
equipment of all construction employees before, during and after Continuous 50,000
Developer & Contractor
safety termination of employment
2. Ensure that machinery, equipment, personal protective

equipment, appliances and hand tools used in construction do Resident Project Manager,
One off
comply with the prescribed safety and health standards and be Developer & Contractor
appropriately installed maintained and safeguarded
3. Ensure that equipment and work tasks are adapted to fit
Resident Project Manager,
workers and their ability including protection against mental Continuous
Developer & Contractor
strain
4. All machines and other moving parts of equipment must be
Resident Project Manager One off
enclosed or guarded to protect all workers from injury
5. Arrangements must be in place to train and supervise
inexperienced workers regarding construction machinery use Resident Project Manager Continuous
and other procedures/operations
6. Equipment such as fire extinguishers must be examined by a
government authorized person. The equipment may only be Resident Project Manager Continuous
used if a certificate of examination has been issued
7. Reports of such examinations must be presented in
prescribed forms, signed by the examiner and attached to the Resident Project Manager Continuous
general register
1. Well stocked first aid box which is easily available and Resident Project Manager
One-off
Occupational health accessible should be provided within the premises & Contractor
and safety risks 2. Provision must be made for persons to be trained in first aid, Resident Project Manager
One-off
during construction with a certificate issued by a recognized body. & Contractor 50,000
period and 3. Fire fighting equipment such as fire extinguishers and
occupational phase hydrant systems should be provided at strategic locations such One-off
& Contractor
as stores.
APPENDIX 7: CONSULTANTS 2017 PRACTICING LICENSE.

Environmental and Social Audit Report For Wajir Regional Referral Laboratory 1

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Public Disclosure Authorized

East African Public Health Laboratory Networking Project (EAPHLNP)

Environmental & Social

Bonventure Naphtali Okanga

NEMA EIA/EA EXPERT:

Mr. Bonventure Naphtali Okanga. EIA/EA Expert (Reg. No. 5067)

NATIONAL PUBLIC HEALTH LABORATORY SERVICES (NPHLS) REPRESENTATIVE

ACRONYMS AND ABBREVIATIONS

3.6.8 National Infection Prevention and Control Guidelines

The EAPHLN Project in Kenya included the rehabilitation/construction and equipping of 5

For the purposes of continuous improvement and compliance, the following

▪ Increased agency monitoring. The EAPHLNP Project Management Unit should

▪ With the eminent completion of the modern incinerator, proper incinerator

CHAPTER ONE: INTRODUCTION AND BACKGROUND

The EAPHLN Project in Kenya included the rehabilitation/construction and equipping of 5

1.2 Project description and design

1. Component #1 - Regional Diagnostic and Surveillance Capacity provided support to

3. Component #3 - Joint Operational Research and Knowledge Sharing/Regional

1.2.2 The Project Design

1.2 Objective of the Consultancy

The key objective of the Environmental Audit is to identify gaps in Environmental

1.3 Project Justification

1.5 Methodology and Approach

➢ Presence of sharps in black coded bins

CHAPTER TWO: ENVIRONMENTAL AND SOCIAL BASELINE

2.1 The Project site

The laboratory is well designed to accommodate movement related to patients,

2.1.2 Water and Power Supply

2.1.3 Laboratory Safety and Sanitation

2.1.4 Waste Management

2.1.4.1 HCW Segregation

2.1.4.2 HCW Storage Area

2.1.4.3 HCW Disposal

2.1.4.4 Waste Water Management

2.2 Wajir County profile

businesses, employment opportunities and informal sector income generating activities

The County is linked to the rest of the country by STANDARD telephone

CHAPTER THREE: POLICY, LEGAL AND ADMINISTRATIVE

3.1 Kenya Constitution 2010

3.2 Environment Management and Coordination (Amendment) Act, 2015.

d. All biomedical waste shall be securely packaged in biohazard containers which

i. No person shall transport or allow to be transported biomedical waste save in a

3.2.1 The EMCA (Waste Management) Regulations 2006

The waste Management Regulations are meant to streamline the handling,

▪ Section 5 provides method of cleaner production (so as to minimize waste

▪ Section 39 states that all biomedical waste shall be securely packaged in

3.2.2 The EMCA (Water Quality) Regulations 2006

Of immediate relevance to the proposed project is Part II Sections 4 -6 as well as Part V

▪ Part II Section 4 inhibits acts which directly or indirectly, immediate or

▪ Part II section 6 criminalize discharge of water from sewage treatment works,

▪ Part V Section 24 prohibits discharge or application of any poison, toxic, noxious

3.2.3 The EMCA (Air Quality) Regulations 2014

Of immediate relevance to the project are the following sections excerpts;

The Proponent is expected to take measures to curb or minimize air emissions in

3.3 Radiation Protection Act, Cap 243

3.4 Public Health Act Cap. 242

3.5 Occupational Safety and Health Act, 2007

3.6 Guidelines, Plans and Policy framework

3.6.2 The National Environmental policy of 2012