SFG3246 V8 EA P119063 Box402910B PUBLIC Disclosed 5 23 2017

Public Disclosure Authorized
SFG3246 V8
MINISTRY OF LOCAL GOVERNMENT AND RURAL DEVELOPMENT

(MLGRD)
GREATER ACCRA METROPOLITAN AREA (GAMA) SANITATION AND
WATER PROJECT
ACCRA METROPOLITAN ASSEMBLY

(AMA)
Construction of Institutional
Sanitation Facilities
ENVIRONMENTAL AND SOCIAL

MANAGEMENT PLAN (ESMP)
FINAL ESMP
Prepared by:
SAL Consult Limited, P. O. Box GP20200, Accra, Ghana
May, 2017
SAL Consult Ltd GAMA - AMA
BTABLE OF CONTENT
ESMP PROJECT TEAM.................................................................................. ERROR! BOOKMARK NOT DEFINED.
TABLE OF CONTENT ..........................................................................................................................................I
LIST OF FIGURES..............................................................................................................................................III
LIST OF TABLES ...............................................................................................................................................III
LIST OF PLATES............................................................................................................................................... IV
ACRONYMS AND ABBREVIATIONS .................................................................................................................. V
EXECUTIVE SUMMARY ................................................................................................................................... VI
1.0 INTRODUCTION ................................................................................................................................... 1
1.1 BACKGROUND ........................................................................................................................................... 1

1.2 OBJECTIVES/PURPOSE OF THE ESMP............................................................................................................. 2
1.3 APPROACH AND METHODOLOGY................................................................................................................... 2
1.3.1 Site Inspections ................................................................................................................................. 2
1.3.2 Stakeholder Consultations ................................................................................................................ 3
1.3.3 Review of Available Literature/project documents ........................................................................... 4
1.3.4 Reporting .......................................................................................................................................... 4
2.0 DESCRIPTION OF THE PROPOSED PROJECT .......................................................................................... 6
2.1 NEED FOR THE PROJECT ............................................................................................................................... 6

2.2 BENEFICIARY SCHOOLS IN AMA AND THEIR LOCATIONS ..................................................................................... 6
2.3 DESCRIPTION/STATE OF EXISTING WASH FACILITIES IN THE BENEFICIARY SCHOOLS ................................................ 8
2.4 PROPOSED SANITATION FACILITIES TO BE PROVIDED BY PROJECT ....................................................................... 14
2.5 DESIGN STANDARDS ................................................................................................................................. 19
2.5.1 General ........................................................................................................................................... 19
2.5.2 Lighting ........................................................................................................................................... 19
2.5.3 Materials for Internal Finishes ........................................................................................................ 20
2.5.4 Water Closets (WCs) ....................................................................................................................... 20
2.5.5 Hand Wash Basin ............................................................................................................................ 20
2.5.6 Service Installations ........................................................................................................................ 20
2.6 LABOUR AND RELATED ISSUES .................................................................................................................... 21
3.0 RELEVANT POLICIES, LEGAL AND ADMINISTRATIVE FRAMEWORKS .................................................. 22
3.1 POLICY FRAMEWORK ................................................................................................................................ 22

3.2 NATIONAL REGULATORY FRAMEWORK ......................................................................................................... 22
3.3 INSTITUTIONAL FRAMEWORK ...................................................................................................................... 25
3.4 WORLD BANK SAFEGUARDS POLICIES .......................................................................................................... 28
4.0 BASELINE ENVIRONMENTAL AND SOCIAL CONDITIONS .................................................................... 30
4.1 LOCATION AND SIZE .................................................................................................................................. 30

4.2 PHYSICAL ENVIRONMENT ........................................................................................................................... 32
4.2.1 Climatic Conditions ......................................................................................................................... 32
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4.2.2 Vegetation ...................................................................................................................................... 32

4.2.3 Geology and Soils ............................................................................................................................ 32
4.3 SOCIO-ECONOMIC ENVIRONMENT............................................................................................................... 33
4.3.1 Demographic Characteristics .......................................................................................................... 33
4.3.2 Education and Literacy.................................................................................................................... 33
4.3.3 Employment and Industry ............................................................................................................... 33
4.3.4 Water Supply .................................................................................................................................. 33
4.3.5 Drainage ......................................................................................................................................... 34
4.3.6 Sanitation and Hygiene ................................................................................................................... 34
4.3.7 Waste Management ....................................................................................................................... 37
5.0 STAKEHOLDER CONSULTATIONS ....................................................................................................... 39
5.1 OBJECTIVES OF CONSULTATION ................................................................................................................... 39

5.2 STAKEHOLDER CONSULTATION STRATEGY AND PLAN ....................................................................................... 39
5.3 STAKEHOLDERS CONSULTED ....................................................................................................................... 43
5.4 OUTCOME OF STAKEHOLDER CONSULTATIONS CARRIED OUT DURING ESMP PREPARATION .................................... 43
5.5 KEY ENVIRONMENTAL AND SOCIAL CONCERNS FROM STAKEHOLDER CONSULTATIONS ........................................... 52
6.0 DESCRIPTION OF ENVIRONMENTAL AND SOCIAL IMPACTS ............................................................... 53
6.1 PROJECT AREA OF INFLUENCE ..................................................................................................................... 53

6.1.1 Geographical Area of Influence ...................................................................................................... 53
6.1.2 Physical Environmental Media Influence ........................................................................................ 53
6.1.3 Community Influence and Vulnerable Persons in the Institutions .................................................. 53
6.1.4 Institutional Influence ..................................................................................................................... 54
6.2 PROJECT ACTIVITIES OF ENVIRONMENTAL AND SOCIAL CONCERN ...................................................................... 54
6.2.1 Preparatory Phase Activities ........................................................................................................... 54
6.2.2 Construction Phase Activities .......................................................................................................... 54
6.2.3 Operations and Maintenance Phase Activities ............................................................................... 55
6.2.4 Decommissioning Phase ................................................................................................................. 55
6.3 CRITERIA OF IMPACT EVALUATION ............................................................................................................... 55
6.3.1 Duration of the Impact.................................................................................................................... 55
6.3.2 Extent of the Impact ....................................................................................................................... 55
6.3.3 Intensity of the Impact .................................................................................................................... 55
6.3.4 Impacts Severity .............................................................................................................................. 56
6.4 EVALUATION OF POTENTIAL POSITIVE IMPACTS .............................................................................................. 56
6.5 EVALUATION OF POTENTIAL ADVERSE IMPACTS ASSOCIATED WITH THE PROPOSED PROJECT ................................... 58
6.6 EVALUATION OF RISKS TO SUSTAINABILITY OF PROJECT .................................................................................... 61
7.0 ENVIRONMENTAL AND SOCIAL MITIGATION AND MANAGEMENT PLAN .......................................... 63
7.1 MITIGATION/ACTION PLAN........................................................................................................................ 63

7.2 MITIGATION/ACTION PLAN FOR IDENTIFIED RISKS TO THE SUSTAINABILITY OF THE PROJECT ................................... 70
7.3 ENVIRONMENTAL AND SOCIAL MONITORING PLAN AND REPORTING.................................................................. 72
7.3.1 Environmental and Social Monitoring Plan .................................................................................... 72
7.3.2 Environmental and Social Monitoring Reporting ............................................................................ 77
7.4 GRIEVANCE REDRESS PROCESS.................................................................................................................... 77
7.4.1 Background ..................................................................................................................................... 77
7.4.2 Objectives of the Grievance Redress Mechanism ........................................................................... 77
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7.4.3 Grievance Redress Process .............................................................................................................. 78

7.5 CAPACITY BUILDING AND OTHER REQUIREMENTS FOR IMPLEMENTATION OF ESMP AND PERMIT CONDITIONS ........... 83
7.5.1 Objectives of the training ................................................................................................................ 83
7.5.2 Methodology for the training ......................................................................................................... 83
7.5.1 Output of the training ..................................................................................................................... 84
7.6 ESTIMATED BUDGET FOR ESMP IMPLEMENTATION. ....................................................................................... 84
8.0 CONCLUSION ..................................................................................................................................... 86
9.0 BIBLIOGRAPHY .................................................................................................................................. 87
ANNEXES ....................................................................................................................................................... 88
ANNEX 1 STAKEHOLDER CONSULTATIONS ............................................................................................... 89
ANNEX 2 CODE OF CONDUCT .................................................................................................................. 90
ANNEX 3 TEMPLATE FOR REPORTING ON THE IMPLEMENTATION OF THE ESMP ..................................... 91
ANNEX 4 GRIEVANCE FORM..................................................................................................................... 92
LIST OF FIGURES
FIGURE 1: INSTITUTIONAL STRUCTURE FOR SHEP IMPLEMENTATION AT THE MUNICIPAL ASSEMBLY AND SCHOOL LEVEL ................ 27
FIGURE 2: MAP OF ACCRA METROPOLIS (SOURCE: GHANA STATISTICAL SERVICE, 2014)........................................................ 31
FIGURE 3: AVAILABILITY AND CONDITION OF TOILETS IN SCHOOLS IN AMA (SOURCE: WASTECARE ASSOCIATES, 2016A) .............. 35
FIGURE 4: METHODS OF SOLID WASTE DISPOSAL IN SCHOOLS UNDER AMA (SOURCE: WASTECARE ASSOCIATES, 2016A) ............. 38
FIGURE 5: GRIEVANCE REDRESS PROCESS FOR THE CONSTRUCTIONAL PHASE INSTITUTIONAL SANITATION FACILITIES PROJECT ....... 80
FIGURE 6: GRIEVANCE REDRESS PROCESS FOR OPERATIONAL PHASE FOR THE INSTITUTIONAL SANITATION FACILITIES PROJECT ....... 82
LIST OF TABLES
TABLE 1: DETAILS OF BENEFICIARY SCHOOLS IN AMA ........................................................................................................ 7

TABLE 2: DETAILS OF EXISTING WASH FACILITIES IN SCHOOLS (SOURCE: WASTE CARE ASSOCIATES, 2016A) .............................. 9
TABLE 3: DETAILS OF SANITATION FACILITIES TO BE PROVIDED BY THE PROJECT...................................................................... 15
TABLE 4: SUMMARY OF WORLD BANK SAFEGUARD POLICIES ............................................................................................. 28
TABLE 5: STAKEHOLDER ENGAGEMENT PROGRAMME ....................................................................................................... 40
TABLE 6: DETAILS OF STAKEHOLDER CONSULTATIONS ....................................................................................................... 44
TABLE 7: EVALUATION OF POTENTIAL POSITIVE IMPACTS.................................................................................................... 56
TABLE 8: EVALUATION OF POTENTIAL ADVERSE IMPACTS ................................................................................................... 58
TABLE 9: EVALUATION OF RISKS TO THE SUSTAINABILITY OF THE PROJECT ............................................................................. 61
TABLE 10: MITIGATION MEASURES/ACTIONS FOR POTENTIAL SIGNIFICANT ADVERSE IMPACTS ................................................... 63
TABLE 11: MITIGATION /ACTION PLAN FOR IDENTIFIED RISKS TO THE SUSTAINABILITY OF THE PROJECT ..................................... 70
TABLE 12: ENVIRONMENTAL AND SOCIAL MONITORING PLAN ........................................................................................... 72
TABLE 13: CAPACITY BUILDING PLAN FOR IMPLEMENTATION OF ESMP AND PERMIT CONDITIONS............................................. 83
TABLE 14: ESMP BUDGET. ......................................................................................................................................... 85
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LIST OF PLATES
PLATE 1: SITE INSPECTION AT ABOSSEY OKAI 1&2 BASIC SCHOOL......................................................................................... 3

PLATE 2: WATER STORAGE TANK AT OSU CLUSTER (SOURCE: WASTECARE ASSOCIATES, 2016A) ............................................. 34
PLATE 3: CONDITION OF A URINAL AT AYALOLO CLUSTER OF SCHOOLS (SOURCE: WASTECARE, 2016A) .................................... 36
PLATE 4: COMMON HAND WASH FACILITIES IN SCHOOLS UNDER AMA (SOURCE: WASTECARE ASSOCIATES, 2016A) ................... 37
PLATE 5: CONSULTATION BETWEEN ENVIRONMENTAL CONSULTANT, OFFICIAL OF AMA AND HEAD TEACHER OF KANESHIE WEST
CLUSTER OF SCHOOLS ........................................................................................................................................ 51
PLATE 6: CONSULTATIONS WITH SHEP COORDINATOR, PREFECTS AND HEALTH CLUB MEMBERS OF SOCCO/M1 CLUSTER OF
SCHOOLS ......................................................................................................................................................... 51
PLATE 7: CONSULTATION WITH PREFECTS OF ABOSSEY OKAI R/C SCHOOL ........................................................................... 51
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ACRONYMS AND ABBREVIATIONS
AMA Accra Metropolitan Assembly

BoQ Bill of Quantities
EHSD Environmental Heath and Sanitation Department
EPA Environmental Protection Agency
ESMF Environmental and Social Management Framework
ESMP Environmental and Social Management Plan
FMP Facilities Management Plan
GAMA Greater Accra Metropolitan Area
GES Ghana Education Service
GHS Ghana Health Services
GoG Government of Ghana
GWCL Ghana Water Company Limited
JHS Junior High School
LI Legislative Instrument
MA Municipal Authority
MLGRD Ministry of Local Government and Rural Development
MMA Metropolitan and Municipal Assembly
MMDA Metropolitan, Municipal and District Assembly
OP Operational Procedures
PPE Personal Protective Equipment
SHEP School Health Education Programme
S&W Sanitation and Water
ToR Terms of Reference
WB World Bank
WC Water Closet
WD Works Department
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EXECUTIVE SUMMARY
The Government of Ghana (GoG) has received financing from the World Bank towards the cost of
implementation of the Greater Accra Metropolitan Area (GAMA) Sanitation and Water Project
(GAMA S&W Project). The objective of the Project is to increase access to improved sanitation and
improved water supply in the GAMA, with emphasis on low income communities; and to strengthen
management of environmental sanitation in the GAMA.
The GAMA Project, which has four components, supports eleven (11) Metropolitan and Municipal
Assemblies (MMAs) spread across the Greater Accra Region. Part of the strategies under Component
1 of the Project is the provision of improved sanitation and water supply facilities in schools in each
of the eleven (11) MMAs in GAMA, including hygiene education and campaigns for awareness raising
and behavioural changes in low income communities
Ghana’s Environmental Assessment Regulations, 1999 (LI1652) requires that for any start-up project
which has potential to impact negatively on the environment and people, the undertaking should be
assessed for its environmental and social impacts, and the appropriate mitigation measures
identified prior to the undertaking for implementation. The Project has also triggered one of the
World Bank Safeguards policies: the Environmental Assessment Policy OP4.01. These require that
any potential environmental and social issues arising from the project implementation should be
mitigated.
This ESMP is prepared to guide the construction and operation of the institutional sanitation
facilities under the Accra Metropolitan Assembly (AMA) in accordance with the Environmental
Assessment Regulations (EAR) 1999, LI 1652 and the World Bank’s Safeguards Policy on
Environmental Assessment (OP 4.01).
Stakeholder consultations were carried out with key stakeholders to obtain their comments and
concerns on the proposed project with respect to the potential environmental and socio-economic
issues and impacts that have been addressed in the study. The stakeholders consulted comprise:
Project proponents:
 Ministry of Local Government and Rural Development/ Project Coordinating Unit
- Safeguards Specialist
 AMA
- Director, Drains Maintenance Unit/GAMA SWP Project Coordinator.
Engineering Consultant
 Waste Care Associates
- Chief Executive Officer
Contractor
 Milpar Development Investment
- Managing Director; and
- Foreman
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Beneficiary Schools
 WASH implementers (Head Teachers; SHEP Coordinators; representatives of School
Management Committee and Parent Teacher Association; school prefects and health club
executives) in the following institutions:
- Abossey Okai R/C Junior High School (JHS);
- Abossey Okai 1&2 Basic School;
- Kaneshie West Cluster;
- Socco/M1 Cluster of Schools;
- Dr. F.V. Nanka Bruce JHS;
- Osu Salem 1 Primary School; and
- Osu Salem 5 Primary School.
The following school children were consulted:

 Ishmael Selormey- School prefect Boys, Abossey Okai R/C Junior High School (JHS);
 Yahwe-Yire Djan- School prefect Girls, Abossey Okai R/C Junior High School (JHS);
 Stephen Yeboah-Health club member, Osu Salem 5 Primary;
 Claudia Borketey-Health club member, Osu Salem 5 Primary;
 Amofah Eva-School prefect/health club secretary, Osu Salem 1 Basic School;
 Ninyeh Benjamin –Boys prefect/Health Club Vice president, Osu Salem 1 Basic School;
 Boateng Emmanuel-President Health club, Socco/M1 Cluster of schools; and
 Wiafe Foster-Vice president Health club, Socco/M1 Cluster of schools.
Significant Environmental and Social Impacts
The significant adverse impacts (rated as moderate or major) identified from the analysis and
evaluation of the potential impacts from the proposed project are stated below.
Construction Phase
 Soil impacts and sediment transport;
 Air quality deterioration;
 Vibration and noise nuisance;
 Visual intrusion;
 Destruction of property and obstruction of walkways;
 Generation and disposal of solid waste;
 Occupational health & safety;
 Public safety & Traffic issues; and
 Sanitation and public health.
Operational Phase
 Nuisance from odour;
 Waste generation;
 Sanitation issues and public health impacts; and
 Sustainability of the institutional facilities.
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Decommissioning Phase
 Occupational/public safety and traffic impacts; and
 Waste management.
Mitigation and Monitoring Plan

Mitigation and monitoring measures for the significant adverse impacts and identified risks to the
sustainability of the project are stated below.
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Mitigation and monitoring actions for potential significant adverse impact
No. Environmental/ Social Monitoring Parameters Monitoring Frequency Responsibility

Component Proposed Mitigation Measures Site (Implementation/
Supervision)
PREPARATORY PHASE
1. Approval for  Consult and seek free, prior and informed consent from school authorities -Evidence of consultation and -Beneficiary -Prior to -Contractor/
construction and siting prior to construction work. consent from school institutions construction Engineering
of toilet facility  For Missionary schools, seek free, prior and informed consent of Church
authorities (including Church Consultant
Leadership in addition to Head Teachers.
Leadership of Missionary
 For all schools, Engineering Consultant to extensively consult school
authorities on the siting of toilet facilities in the school. The selection of Schools)
sites should be agreed upon with the school authorities. -Complaints on siting of - Daily
 The selection of sites should take into consideration compatibility with facilities
adjacent school facilities. The adjacent school facilities should not be at Availability of toilets facilities
risk from the operation of the proposed toilets.
for use by students during
 To ensure that students always have access to toilet facilities, the
construction
contractors/consultants are not to demolish existing toilet facilities
until the new toilet facilities are in place. Where the existing toilet
facility is the only toilet for the school but has been earmarked for
rehabilitation and or reconstruction, then alternative toilet facilities
should be provided the school/students during the course of the
rehabilitation/reconstruction of the existing toilet facility . Where
necessary, mobile toilets should be provided..
CONSTRUCTION PHASE
1. Soil impacts and  Vegetation (grasses and shrubs) should be cleared only when contractor -Observable change in turbidity -Construction Daily Contractor/
sediment transport is fully mobilised for construction. of water in drains site Engineering
 Vegetation clearance (where necessary) and excavations should be
-Observable oil sheen in drains
-Nearby Consultant
limited to the demarcated construction site. drains
-Observation of rills/gullies
 Backfill with excavated soil material where appropriate.
 Re-vegetate areas around construction sites to restore the landscape.
 Ensure that heaped sand delivered for construction works is covered with
tarpaulin to prevent wind and water transport of soil particles.
2. Air quality deterioration  Deliver construction equipment and materials to the construction sites -Observation of air borne Construction Daily Contractor/
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Supervision)
outside school sessions, such as in the evenings or on weekends. particulates (dust) and exhaust site Engineering
 Speed limit for all vehicles and construction equipment should be less fumes -Immediate Consultant
than 30km/h within the school environs and less than 50km/h within environs
-Records of dust level
communities. Provide speed limit signs to guide drivers/operators.
measurements (dust
 Dampen untarred routes of vehicles/trucks to the construction sites.
 Haulage trucks carrying sand should be covered with tarpaulin. concentration should be below
 3
Hydraulic concrete mixing machines should be used as much as possible 150 µg/m )-
and regularly service all construction equipment and machinery. -Records of dampening of
construction sites and routes
for vehicles/trucks
3. Vibration and noise  Demolition of old structures should be done outside school sessions, such -complaints on noise nuisance -Construction Daily Contractor/
nuisance as in the evenings or during weekends. site Engineering
 Carpentry works, and other noise generating activities should as much as -Immediate Consultant
possible be carried outside school sessions. environs
 Hydraulic concrete mixing machines should be used as much as possible
and regularly service all construction equipment and machinery.
4. Visual intrusion  The construction sites should be hoarded off from public view. -Hoarding in place -Construction Daily Contractor/
 Ensure good housekeeping at the construction site. -Condition of areas around site Engineering
 Ensure an acceptable post-construction site as per provisions in the construction site -Immediate Consultant
contract. environs
 Remove all construction equipment from the site after completion of
work.
5. Destruction of property  Ensure construction equipment are not parked haphazardly to obstruct -Evidence of consultations with -Construction Daily Contractor/
and obstruction of walkways. affected property owners site Engineering
walkways  As much as possible, do not dump construction materials in walkways. -Record of affected service -immediate Consultant
 Provide safe alternative routes for pedestrians where walkways will be line/property and action taken environs
obstructed. -Complains on affected
 Consult affected property owners/users and seek their consent prior to property and obstruction of
construction works. walkways
 Realign all affected utility service lines.
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Supervision)
 Reinstate any damaged property such as pavements, etc.
6. Generation and  Apply the principles of Reduce, Reuse and Recover for waste -Availability and use of bins Construction Daily Contractor/
disposal of solid waste management. For example: -Records on frequency and site Engineering
o Purchase the right quality and quantity of materials; location of waste disposal site Consultant
o Ensure judicious use of construction materials such as pipes, of domestic and construction
waste
laterites, sand, etc.;
o Reuse excavated soil material for backfilling and levelling if
appropriate.
 Provide bins on site for temporary storage of domestic waste such as
lubricant containers, drinking water sachets and carrier bags/packaging
materials.
 Dispose all construction and domestic waste at AMA approved dump
sites.
7. Occupational health  Engage experienced artisans for construction works. -Workers’ awareness of Construction Daily Contractor/
and safety (OHS) issues  All workers should be given proper induction/orientation on safety. Contractor’s health and safety site Engineering
 The contractors should have a Health & Safety Policy to guide the
policy
Consultant
construction activities. The contractor health and safety policy would
-Availability and proper use of
take into consideration the World Bank EHS guidelines.
 Regularly service all equipment and machinery. PPEs
 Ensure first aid kits on site and a trained person to administer first aid. -Availability and proper use of
 Provide and enforce the use of appropriate personal protective warning signs
equipment (PPE) such as safety boots, reflective jackets, hard hats, hand -Availability of first aid kit
gloves, earplugs, nose masks, etc. for the labour force.
-Adherence to health and
 Comply with all site rules and regulations.
safety procedures
 Apply sanctions where safety procedures are not adhered to.
 Site meetings should create awareness on OHS. -Records on frequency, type
and source of
illness/accident/injury
-Records on non-compliances
-Absence of unauthorized
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Supervision)
persons at active construction
sites
8. Public safety and traffic  Hoard off the construction sites to prevent access by unauthorised -Availability and proper use of Construction Daily Contractor/
issues persons. warning signs site Engineering
 Use caution tapes and warning signs at the construction sites around
-Hoarding of site
Consultant
trenches and excavations.
-Use of caution tape around
 Deliver construction equipment and materials to the construction sites
outside school sessions such as in the evening or weekends. trenches/ excavations
 Speed limit for all vehicles and construction equipment should be less -Records on frequency, type
than 30km/h within the school environs and less than 50km/h within and source of
communities. Provide speed limit signs to guide drivers/public. illness/accident/injury
 Do not park at unauthorised places to reduce the risk of accidents.
-Absence of unauthorized
 Erect temporary road signs at junctions to the beneficiary institutions
persons at active construction
during the delivery of construction equipment and materials.
 Ensure delivery trucks hired/contracted are in good condition to prevent sites
breakdowns on roads.
 Remove all construction equipment from the site after completion of
work.
9. Sanitation issues and  Provide bins on site for temporary storage of domestic waste such as -Availability and use of bins Construction Daily Contractor/
public health impacts lubricant containers, drinking water sachets and carrier bags/packaging -Records on frequency and site Engineering
materials. location of waste disposal site Consultant
 Dispose all construction and domestic waste at AMA approved dump sites of domestic and construction
and in the approved manner. waste
 Ensure all trenches or excavations made during the construction works do -Mobile toilet facilities in place
not collect stagnant water which could breed mosquitoes. for construction workers
 Ensure construction workers do not use existing institutional toilet -Presence of stagnant water in
facilities. Either they identify nearby public toilet facilities for use or are trenches
provided with temporary toilets (mobile toilets) for use.
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Supervision)
10. Public Complaints/  Implement Grievance Redress Mechanism, which will include such -Type and nature of complaints Project Weekly Grievance
Grievances elements as: and concerns; community Redress
-Complaint records (Record of Committee
o Lodging and registration of PAPs grievance by grievance
grievance and number Section 7.4
redress committee;
resolved/unresolved)
o Redress decision, feedback and implementation;
-Management and Stakeholder
oDissatisfaction and alternative action; and Meetings
- Carry out monitoring and evaluation.
OPERATIONAL PHASE
1. Nuisance from odour  Comply with provisions in the Facilities Management Plan (FMP). -Smell of pungent odour -Beneficiary Daily Authorities of
 Ensure good housekeeping at toilet facilities. institution beneficiary
 Clean toilet facilities regularly with disinfectants. -Immediate institution/ SHEP
 Empty bins in classrooms/offices/wards regularly. environs Coordinator
 Liaise with AMA to contract a waste management company to regularly
collect and dispose waste at AMA approved dump site.
 Dislodge septic tanks outside school sessions, such as on weekends.
2. Waste generation  Regularly empty waste bins at the various locations when full. -Waste disposal records Beneficiary -Daily Authorities of
and disposal  Sensitize pupils/ staff on effective use of bins to avoid indiscriminate -Availability of bins institution beneficiary
disposal of waste. institution/ SHEP
-Litter around waste bin
 Damaged waste bins should be replaced as appropriate. Coordinator
-Records of inspection and
 Liaise with AMA to contract a waste management company to regularly
collect and dispose waste at AMA approved dump site. dislodging of septic tanks
 Inspect septic tanks periodically and dislodge when full.
3. Sanitation issues and  Ensure pupils/staff wash their hands under running water and soap after -Cleaning roster -Toilet facility -Daily SHEP
health impacts use of toilet facilities. -Clean environment -Waste -Week Coordinator/
 Ensure good housekeeping at toilet facilities. -Smell of pungent odour storage and
Head of
 Clean toilet facilities regularly with disinfectants. Institution
Availability of disinfectants collection
 Ensure bins are properly covered at all times.
 Avoid indiscriminate dumping of waste at waste storage and collection -Availability of cleaning PPEs sheds
shed and always keep the place clean. and tools/materials
 Provide disposable hand gloves for cleaning of sanitation facilities and -Availability of functional hand
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Supervision)
emptying of bins. wash facility
 Create awareness on hygiene and sanitation issues, including proper use
of sanitation facilities and proper handling and disposal of waste.
 Comply with provisions in the FMP.
4. Complaints/ Grievances  -Implement Grievance Redress Mechanism, which will include such -Type and nature of complaints Project -Weekly Grievance
elements as: and concerns community Redress
Committee
o Lodging and registration of PAPs grievance by grievance -Complaint records (Record of
redress committee; grievance and number
o Redress decision, feedback and implementation; resolved/unresolved)
o Dissatisfaction and alternative action; and
Carry out monitoring and evaluation.
SUSTAINABILITY OF INSTITUTIONAL FACILITIES
1. Flooding  Raise the foundation of toilet facilities to about 1 meter high, especially in - Extent of flooding during Toilet facility During rains Authorities of
flood prone areas. rains Institution/ PTA/
 Provide adequate drainage around toilet facilities. - Drains clear of silt Monthly
Metropolitan
 Provide rain cover over all windows and doors of the toilet facilities. Assembly
- Record of state of Rain
 Beneficiary schools should ensure all broken louvre blades/or windows
are replaced. covers
- Record of state of louvre
blades
2. Security issues  Provide burglar proof at the doors and windows of toilet facilities. - Security measures (locks, Toilet facility Daily Authorities of
 Maintain adequate security in the schools and at the sanitation facilities burglar proof) functional Institution / PTA/
especially. Eg: through hiring a watchman. Metropolitan
 MA should consider fencing of schools in future projects to improve Assembly
- Watchman hired
security.
 Sensitize wider communities not to disturb school sanitation facilities
3. Unavailability of water  Confirm the source and reliability of the water supply prior to the - Confirmation of availability Toilet facility Prior to Authorities of
commencement of construction. of water supply from GWCL commissioni Institution / PTA/
 Ensure that storage tanks are installed for all the facilities to provide
- Storage tanks installed and ng of
Metropolitan
continuous water supply even when GWCL lines are temporarily out of Assembly
Final ESMP _Construction of Institutional Sanitation Facilities. Page xiv

May 2017

Supervision)
order. all connections and project/
 Ensure connection of water and installation of water storage tanks is plumbing functional Weekly
completed and there is regular flow of water at the toilet facilities before
- Leaks from plumbing
commissioning/handing over of the facilities for use.
4. Funding  The Engineering Consultant to include the relevant recommendations in - Receipts of payment of bills Beneficiary Monthly MLGRD-PCU/
the ESMP in the Facilities Management Plan (FMP). - Programme for fund raising institution Metropolitan
 Comply with provisions in the FMP such as:
- Audited accounts
Assembly/
o Replace damaged equipment/materials with durable ones during Consultant/
maintenance and repair works. Authorities of
Beneficiary
o The beneficiary schools should hire cleaners for the sanitation
Institution/PTA
facilities.
o Develop and implement a maintenance regime for the facilities.
o Report major breakdown of facilities to the Metropolitan GES
Director.
o Educate and create awareness on proper use of facilities.
o Ensure all staff are trained in the effective use and management
of the facilities, in collaboration with the Environmental Health
and Sanitation Department.
5. Poor maintenance  School authorities and PTA to discuss funding for water supply, electricity - Record of training and -Beneficiary Monthly Authorities of
culture bills and maintenance of the facilities at PTA Meetings. awareness creation on institution Institution /
 Capacity building of School authorities /PTA for raising, mobilization and
Facilities Management Plan
SHEP
stewardship of fund Coordinators/
- Record of compliance with
 MA level stakeholder engagements to discuss innovations in funding for PTA/
O&M. Facilities Management Plan Metropolitan
 The project should ensure that all outstanding electricity and water debts - Records on major Assembly
of beneficiary institutions are paid and electricity and water connection breakdowns including
restored to disconnected institutions. leakages
 The beneficiary institutions should ensure regular payment of electricity
- Availability of school hygiene
and water bills to ensure continuous supply of water and electricity to the
clubs
Final ESMP _Construction of Institutional Sanitation Facilities. Page xv

May 2017

Supervision)
facility.
6. Lack of awareness of  Stakeholders should be invited to attend monthly progress meetings to be - Monthly progress carried out -Beneficiary Monthly SMC/ PTA/
the project information constantly informed. - Information provided to institution Metropolitan
 Before the project resumes, information of the proposed project
teachers, students and the
SHEP Committee
including its benefits should be explained to teachers, students and the
PTA.
PTA.
DECOMMISSIONING PHASE
1. Occupational/ public  Personal protective gear are provided to workers involved with -Availability and proper use of -Project site -Daily Contractor/
safety and traffic decommissioning of facilities. PPEs Engineering
-Adherence to health and
impacts  Toilet facilities are available throughout the decommissioning period.
safety procedures
Consultant
 Workers still have access to public toilet facilities in the communities or
-Records on frequency, type
can be conveyed to such facilities where needed, if mobile toilet facilities
and source of illness/accident/
have been relocated.
 Final movement of vehicles and equipment comply with approved speed injury
limits within the communities.
 All community complaints are resolved before handing over sanitation
project.
2. Waste management  Ensure that any remaining waste streams (after applying hierarchy waste -Availability and use of bins -Project site -Daily Contractor/
management practices of reduce, reuse and recycle) created during -Records on frequency and Engineering
construction activities and waste generated during decommissioning location of waste disposal site Consultant
activities are collected from the project sites and properly disposed of domestic and construction
before handing over the project
waste
 Inspect the site to ensure that the contractor has properly cleaned up all
construction sites before final payment is made to the contractor.
3. Site Restoration  Re-vegetate areas around construction sites to restore the landscape -cleared areas re vegetated -Project Site -Daily Contractor/
 Reinstate any damaged property such as pavements, etc. -Property re-instatement Engineering
carried out Consultant
Final ESMP _Construction of Institutional Sanitation Facilities. Page xvi

May 2017
Capacity Building and Other Requirements for Implementation of ESMP and Permit Conditions
Capacity building measures and other requirements proposed (See Section 7.5) to ensure effective
implementation of the ESMP and environmental permit conditions are:
 Training workshop and sensitization programmes for the Engineering Consultants, Contractors
and their workers, school authorities, school children, AMA and other key stakeholders on the
ESMP ( including Contractors code of conduct, public health and safety, grievance redress
mechanism) and its implementation, EPA permit schedule and triggered World Bank Safeguards
Policy;
 Induction on environmental, social occupational and public health and safety requirements of
the works;
 Training for use and management of facilities;
 Sensitization and awareness creation on use and management of facilities (interactive activity,
teaching, demonstrative activity for building habits & knowledge testing during classes, worship
time and assembly);
 Site Meetings; and
 Reporting.
Conclusion
AMA and the Project Coordinating Unit of MLGRD are committed to ensuring sustainable
environmental management and safeguarding the health and safety of the construction workers,
pupils/teachers at the beneficiary schools and the general public during the implementation of the
proposed project. AMA is also aware of the provisions in the Environmental Assessment Regulations
1999, LI 1652 and the World Bank Operational Policies.
In keeping with these laws, this ESMP has identified and assessed key environmental and social
impacts and concerns that may arise from the implementation of the proposed project. A
monitoring programme to help detect changes arising from the predicted adverse impacts has also
been presented in this ESMP. The recommendations outlined in the ESMP for the project will ensure
a high level of health, safety and environmental management for the proposed project.
It is estimated that the implementation of the ESMP in the Accra Metropolis will cost about
GH¢408,700.00. However, the proposed project has the potential to provide numerous benefits to
the beneficiary schools and the national economy. These include improved sanitation, hygiene and
waste management in the beneficiary schools, improved access to sanitation facilities for vulnerable
groups and employment opportunities.
Final ESMP _Construction of Institutional Sanitation Facilities. Page xvii

May 2017
1.0 INTRODUCTION
1.1 Background
The Government of Ghana (GoG) has received financing from the World Bank towards the cost of
implementation of the Greater Accra Metropolitan Area (GAMA) Sanitation and Water Project
(GAMA S&W Project).
The objective of the GAMA S&W Project is to increase access to improved sanitation and improved
water supply in the GAMA, with emphasis on low income communities; and to strengthen
management of environmental sanitation in the GAMA.
The GAMA Project supports eleven (11) Metropolitan and Municipal Assemblies (MMAs) spread
across the Greater Accra Region. The project has four components:
 Component 1 – Provision of water and environmental sanitation services to priority low income
areas of GAMA;
 Component 2 – Improvement and expansion of the water distribution network in the GAMA;
 Component 3 – Improvement and expansion of waste water and faecal sludge collection,
transportation and treatment in GAMA; and
 Component 4 – Institutional Strengthening.
Provision of improved sanitation and water supply facilities in schools in each of the eleven (11)
MMAs in GAMA, including hygiene education and campaigns for awareness raising and behavioural
changes in low income communities, is part of the strategies under Component 1 of the Project.
Most schools in GAMA are faced with poor access to quality sanitation. This posed various degrees
of risk to the pupils, teachers and other people within the area. The institutional sanitation
component seeks therefore to scale-up sanitation, hygiene and waste management in the
institutions.
Part of the Bank’s funds is to be used by the Metropolitan and Municipal Assemblies (MMAs) to
undertake construction of improved sanitation and water supply facilities in schools within their
jurisdiction where schools are faced with poor access to quality sanitation issues.
Ghana’s Environmental Assessment Regulations, 1999 (LI1652) requires that for any start-up project
which has potential to impact negatively on the environment and people, the undertaking should be
assessed for its environmental and social impacts, and the appropriate mitigation measures
identified prior to the undertaking for implementation. The Project has also triggered one of the
World Bank Safeguards policies: the Environmental Assessment Policy OP4.01. These require that
any potential environmental and social issues arising from the project implementation should be
mitigated.
The Ministry of Local Government and Rural Development (MLGRD), is committed to undertake the
construction activities in an environmentally and socially friendly manner, and in accordance with
the World Bank’s Policy on Environmental Assessment (OP4.01) and GAMA Sanitation and Water
Final ESMP _Construction of Institutional Sanitation Facilities. Page 1

May 2017
Project Environmental and Social Management Framework (ESMF) guiding the Project as well as the
Environmental laws of Ghana.
MLGRD has therefore contracted Messrs SAL Consult Limited to prepare an Environmental and
Social Management Plan (ESMP) for the implementation of the proposed institutional sanitation
facilities in each of the eleven (11) MMAs.
This ESMP is prepared to guide the construction and operation of the institutional sanitation
facilities under the Accra Metropolitan Assembly (AMA) in accordance with the Environmental
Assessment Regulations (EAR) 1999, LI 1652 and the World Bank’s Safeguards Policy on
Environmental Assessment (OP 4.01).
1.2 Objectives/Purpose of the ESMP
The objective/purpose of this ESMP is to guide the effective mitigation and management of potential
environmental and social issues of the proposed construction and operation of institutional
sanitation facilities in AMA. The specific objectives of the ESMP include the following:
 Identification of possible direct and indirect significant adverse impacts associated with the
proposed interventions implementation in AMA;
 Assessment and evaluation of potential impacts of the proposed project on the biophysical and
human environment;
 Provision of practical, socially acceptable, technically and economically feasible and
environmentally sustainable measures to address the potential adverse impacts; and
 To comply with the World Bank’s Safeguards Policy on Environmental Assessment (OP 4.01).
1.3 Approach and Methodology
The approach and methodology adopted for the study include:

 Site inspections;
 Stakeholder Consultation;
 Review of available literature; and
 Reporting.
1.3.1 Site Inspections
The Consultants visited some beneficiary schools in AMA between November 2016 and February
2017 to confirm the environmental and social issues and conditions to be affected or are likely to
develop from the implementation of the proposed project.
Due to time constraints, all beneficiary schools in AMA could not be visited. The Consultants
however selected a representative sample of schools based on the environmental and social issues
identified from the environmental screening and the extent of construction works. This was done in
collaboration with the project proponents and the engineering consultant. The school visited are
listed in Section 1.3.2.
The inspections covered the following:
 the proposed construction sites and environs;

May 2017
 existing sanitation facilities in the beneficiary schools (toilets, urinals and hand washing
facilities);
 existing waste collection and disposal facilities and water supply facilities; and
 construction works that have been done for schools where construction has started.
For beneficiary schools where some construction works have been done, the inspection also
ascertained the health and safety measures that had been put in place by the contractors, such as
hoarding of the sites and use of cautionary tapes and warning signs around excavations and
trenches. Plates 1 shows site inspection at Abossey Okai 1&2 Basic School.
Plate 1: Site inspection at Abossey Okai 1&2 Basic School
1.3.2 Stakeholder Consultations
Stakeholder consultations were carried out between November 2016 and February 2017 with some
key stakeholders to obtain their comments and concerns on the proposed project with respect to
the potential environmental and socio-economic issues and impacts that have been addressed in the
study. This includes the project proponents, some beneficiary schools, engineering consultant and
some contractors. Details of the stakeholder consultations are presented in Chapter 5. Evidence of
stakeholder consultations are provided in Annex 1.
Stakeholder consultations have been carried out with the following key stakeholders:
Project proponents:
 AMA
 WasteCare Associates

May 2017
Contractor
- Foreman
Beneficiary Schools
Management Committee and Parent Teacher Association; school prefects and school health club
The following school children were consulted:

 Ishmael Selormey- School prefect Boys, Abossey Okai R/C Junior High School (JHS);
 Yahwe-Yire Djan- School prefect Girls, Abossey Okai R/C Junior High School (JHS);
 Stephen Yeboah-Health club member, Osu Salem 5 Primary;
 Claudia Borketey-Health club member, Osu Salem 5 Primary;
 Amofah Eva-School prefect/health club secretary, Osu Salem 1 Basic School;
 Ninyeh Benjamin –Boys prefect/Health Club Vice president, Osu Salem 1 Basic School;
 Boateng Emmanuel-President Health club, Socco/M1 Cluster of schools; and
 Wiafe Foster-Vice president Health club, Socco/M1 Cluster of schools.
1.3.3 Review of Available Literature/project documents
The following project documents prepared by the Engineering Consultant (WasteCare Associates) for
AMA were reviewed:
 Hygiene Education Plan;
 Final Detailed Design Report, which contains
o Baseline Studies;
o Assessment of Existing School Facilities; and
o Engineering Designs.
 Facility Operation and Maintenance Handbook;
 Situational Analysis and WASH in Schools; and
 Environmental permit schedule.
1.3.4 Reporting
The major headings of the report include the following:

a) Executive Summary;

May 2017
b) Introduction;
c) Description of Proposed Project;
d) Relevant Policies, Legal and Administrative Frameworks;
e) Baseline Environmental and Social Conditions;
f) Stakeholder Consultation;
g) Description of Environmental and Social Impacts;
h) Environmental and Social Impact Mitigation and Management Plan;
i) Capacity Building Plan for Implementation of ESMP and Permit Conditions;
j) Conclusions;
k) Bibliography;
l) Annexes.

May 2017
2.0 DESCRIPTION OF THE PROPOSED PROJECT
2.1 Need for the Project
Most schools in GAMA are faced with poor access to quality sanitation. This is as a result of
inadequate toilet facilities to meet the schools’ population needs, poor condition of existing toilet
facilities, waste management challenges, lack of water, etc. This poses various degrees of risk to the
pupils, teachers and other people within the area. There is therefore the need to improve sanitation
facilities within schools.
The institutional sanitation component of the GAMA Project therefore seeks to scale-up sanitation,
hygiene and waste management in the schools. The objective of the GAMA S&W Project is to
increase access to improved sanitation and improved water supply in GAMA, with emphasis on low
income communities and to strengthen management of environmental sanitation in GAMA. Part of
the World Bank’s funds is to be used by the Metropolitan and Municipal Assemblies to undertake
construction of improved sanitation and water supply facilities in schools within their jurisdiction
where the schools are faced with poor access to quality sanitation issues.
2.2 Beneficiary Schools in AMA and their Locations
The beneficiary Metropolitan Assembly is the Accra Metropolitan Assembly (AMA). The project sites
cover the ten (10) sub-metropolitan areas (sub-metro) of AMA with each sub-metro having at least
two (2) schools selected for the project. Thirty (30) schools have been selected in AMA to benefit
from the proposed sanitation facilities under the project. The details of the beneficiary schools in
AMA (including the names of the schools, sub-metro, location, and GPS coordinates) are provided in
Table 1. An area of not more than 1 acre will be utilised for the project in each beneficiary school.

May 2017
Table 1: Details of Beneficiary Schools in AMA
No. Name of School Sub-Metro Location GPS Coordinates
1 Abossey Okai 1&2 Cluster Ablekuma Abossey Okai N5.334272°; W0.141365°

2 Kaneshie West 1&2 Cluster Central Kaneshie N5.334120°; W0.141365°
3 Mataheko R/C Cluster Mataheko N5.335546°; W0.142623°

Kaneshie
4 Korle Gonno R/C Boys Ablekuma Korle Gonno N5.315225°; W0.132239°
5 Owusu Mills Primary/JHS South Korle Gonno N5.322735°; W0.142865°
6 Socco/M1 Cluster of Schools Korle Gonno -
7 Sempe 8/12 JHS Korle Gonno -
8 Dr F.V. Nanka Bruce JHS Korle Gonno N5.314014°; W0.135547°
9 ANT 4&11 Primary Ayawaso Accra Newtown N5.345948°; W0.124867°

10 ANT 6&8 Primary Central Accra Newtown N5.345988°; W0.124872°
11 Kwame Nkrumah JHS Accra Newtown N5.350086°; W0.124637°
12 Ayalolo Cluster of Schools Ashiedu Keteke Ayalolo N5.324331°; W0.130859°

13 Independence 1&2 Cluster Accra N5.324713°; W0.121574°
14 Osu Presby Cluster Osu Klottey Osu N5.331806°; W0.110100°

15 Farisco Cluster of Schools Osu N5.332118°; W0.124453°
16 Osu St. Barnabas Anglican Schools Osu N5.325863°; W0.111269°
17 Osu Salem 1 Primary School Osu N5.332230°; W0.110925°
18 Osu Salem 5 Primary School Osu N5.332062°; W0.110522°
19 Unity Cluster Ayawaso East Kanda N5.352548°; W0.120484°

20 Kanda Cluster Schools Kanda N5.343115°; W0.114604°
21 Anumle Cluster of Schools Okaikoi North Anumle N5.375848°; W0.125098°

22 Shiayennor 1&2 Primary Shiayennor N5.363710°; W0.135089°
23 Shiayennor A&B JHS Shiayennor N5.363183°; W0.134865°
24 Kaneshie 6 Primary /Kaneshie Kingsway 1 JHS A&B Okaikoi South Kaneshie N5.342213°; W0.135775°
25 Kaneshie 8 Primary /Kaneshie Kingsway 2 JHS A&B
26 La Bawaleshie Presby Cluster Ayawso West La Bawaleshie N5.383510°; W0.100502°

27 Maamobi Prisons Cluster Maamobi N5.361359°; W0.112090°
28 Dzorwulu JHS Dzorwulu N5.365125°; W0.121347°
29 Kwashieman Cluster Ablekuma Kwashieman N5.352276°; W0.160734°

30 Darkuman 1 JHS North Darkuman N5.353688°; W0.150946°

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2.3 Description/State of Existing WASH Facilities in the Beneficiary Schools
The current state/description of the existing WASH facilities in the beneficiary schools; including the
facilities available, population dependent on the facilities (pupils and teachers), waste disposal and
remarks from assessment made by the Supervising Consultant (WasteCare Associates) are presented
in Table 2.

May 2017
Table 2: Details of Existing WASH Facilities in Schools (Source: Waste Care Associates, 2016a)
Cluster School Enrollment Staff Assessments of WASH facilities
Boy Girl Total Male Female Total Toilet Urinal Water Waste HWF Comments
(No. of availability disposal
cubicles)
Abossey Abossey Okai 111 125 236 5 9 14 10 0 x burn 3 WC closed down due to lack of
Okai 1&2 2 Basic water. Unable to pay for refuse
Cluster Abossey Okai 179 223 402 5 15 20 0 x burn pick up service
Cluster 1 JHS
Kaneshie Kaneshie 177 193 370 3 14 20 12 0 √ burn 5 4 cubicles damaged
West West 2 JHS &
1&2 Cann B
Cluster Primary
Kaneshie 231 277 508 5 14 22 10 0 √ burn 7 2 cubicles damaged
West 1 Basic
Mataheko 586 627 1213 11 29 40 14 1 x burn Urinal not segregated, tap not
R/C Cluster flowing, refuse dump
occasionally maintained at a
fee by zoomlion. Toilet is
hazardous
Korle Gonno 424 424 8 9 17 9 3 √ burn
R/C Boys
Owusu Mills 150 129 279 4 13 17 0 0 x burn x Toilet and urinal broken down,
Primary/JHS water bought from neighbour,
hand washing done in bowls
Socco/M Mamprobi 319 309 628 3 19 22 0 3 x 2 bins 5 Waste bins in poor condition.
1 Cluster of Socco HH
Schools Mamprobi 159 172 331 2 9 11 10 0 √ 3 bins 1 Use toilet for urinating
South 6
Sempe 8 146 145 291 5 13 18 0 0 x burn 0 Pupils practice open
Basic defecation. Teachers have one
toilet. 1 bin

May 2017
cubicles)
Dr F.V. Nanka 172 154 326 6 6 12 4 2 √ burn
Bruce JHS
ANT 4&11 111 104 215 1 8 9 1 0 √ burn 2 HWF in poor condition
Primary
ANT 6&8 93 100 193 2 8 10 4 0 √ burn/bury 4 A separate toilet cubicle for
Primary teachers
Kwame 170 5 7 12 2 3 √ burn/bury 2

Nkrumah
Memory
Ayalolo Ayalolo 1 106 114 2205 3 13 16 20 0 √ pick 1 Toilet is used for urinating. 2
Cluster of &2JHS 0 5 up/burn bins
Schools Ayalolo 1 &2 0 √ pick 2 Tri-cycle service expensive
KG /Primary up/burn hence mainly burn. Irregular
flow of water. 2 bins
Independence Independenc 500 0 3 √ dump 2 1 urinal for teachers. Pupils
1&2 e Avenue 1 carry refuse to public dump.
Cluster JHS HWF used by primary only
Osu Osu Pesby 1 197 197 5 7 12 5 3 √ burn 3 Water not regular. Teachers
Presby JHS(Girls) use one toilet cubicle
Cluster Osu Presby 350 350 1 7 8 5 0 √ burn 6 Some HWF in poor condition
Boys primary
Farisco Liberty 147 143 290 12 5 6 √ Public 1 Water not connected to toilet.
Cluster of Avenue JHS dump Only toilet paper is burnt
Schools Liberty 142 148 290 1 7 8 5 3 √ burn 1 5 Refuse bins were donated by
Avenue 1&4 FunMilk Ghana
Primary

May 2017
cubicles)
Osu St. 242 285 527 7 12 19 10 2 √ burn Urinal has no doors and
Barnabas structure is weak. Only 4
Anglican toilets is functional and
Schools conditions is unhygienic.
Osu Salem 1 151 205 356 3 12 15 12 0 x pick up 9 HWF is available for each class
Primary /burn but most are in poor condition.
School 16 seater but only 12 are
functional. Noble house
restaurant pay for refuse
collection. 4 bins
Osu Salem 5 300 0 11 11 6 0 √ pick up 5 refuse collected 2x a month at
Primary /burn a fee, hence occasionally burn
School
Unity Ayebeng 380 4 9 13 0 0 x 2 6 1 toilet for teachers. Pupils use
Cluster Memorial bins/burn public toilet and open defecations
A&B Primary
Unity JHS 275 5 8 13 0 1 x public 1
dump
Kanda Kanda 1 91 104 195 2 8 10 20 0 √ pick up 10 seater toilet available but
Cluster of /burn not in use yet. Pay for weekly
Schools refuse collection.
Ring Road 129 139 268 5 13 18 √ pick up 3 refuse picked up every 2 weeks
East 2 47 45 92 √ service/ at a fee and occasionally burnt.
Primary& burn Pupils use public toilet
Kanda 1 JHS and little ones squat on drains
behind school.
Ring Road 16 0 √ burn 1
East 1 Basic

May 2017
cubicles)
Anumle 705 776 1481 27 52 79 20 12 √ burn Another 2No. 6-seater
Cluster of Uncompleted. 2No. 8-seater
Schools for staff. Water not always
available
Shiayennor 209 237 446 0 17 17 20 0 √ burn 8 toilet facility shared with other
1&2 Primary schools on compound
Shiayennor 137 140 277 5 8 13 0 4 x burn 4
A&B JHS
Kaneshie 6 Primary 181 194 375 6 14 20 20 2 √ burn √ Pupils use running water from
/Kaneshie Kingsway 1 JHS A&B tap for handwashing.
Kaneshie 8 Primary 134 176 328 5 17 22 0 √ burn √ Use nearby house for urinating
/Kaneshie Kingsway 2 JHS A&B
La La 272 273 545 1 6 1 10 2 √ open 2 irregular flow of water to

Bawaleshie Bawleshie dump existing 10 seater toilet, pupils
Presby Primary B have to carry water to flush
Cluster La 163 165 328 9 7 16 √ open after use. KGs practice open
Bawleshie dump defecations on public dump.
JHS New 20 seater has no water
connected yet. Not in use.
Maamobi Maamobi 40 43 83 6 3 9 2 0 √ burn 2 Water flows 3 times a week.
Prisons Prisons 2 Additional 1 toilet for teachers.
Cluster JHS
Maamobi 161 179 340 2 16 18 20 1 √ pick up 3 Refuse are burnt when pick up
Prisons 1 service service is not regular
Primary

May 2017
cubicles)
Dzorwulu 200 220 420 7 15 22 11 2 √ burn 3 Condition of toilet very poor
JHS
Kwashieman 122 138 2612 25 92 117 12 7 √ pick up An additional 6 for KG, Nursery
Cluster 9 3 service (4) and teachers (2) with
bathroom built by mission.
Darkuman 170 7 6 13 3 3 x pick up 2 1 toilet used by teachers
JHs service

May 2017
2.4 Proposed Sanitation Facilities to be provided by Project
The overview of sanitation facilities to be provided in the selected schools in AMA under the
proposed project are as follows:
 Construction of new water closet (WC) and septic tank facilities with internal urinal;
 Rehabilitation of existing WC toilets;
 Fixing of poly tanks overhead and underground for water supply to the toilet facility;
 Construction of refuse/solid waste holding bay;
 Construction of U450 perimeter drain;
 Laying of pavement around toilet facilities; and
 Laying of 3-inch diameter water supply pipeline from GWCL to toilet facility.
The construction of furnace fitted with smoke stack will no longer be carried out in all the schools
due to air pollution concerns as provided in Annex 5. Construction works are expected to be carried
out over a period of 12 months. The specific sanitation facilities to be provided under the project in
each of the beneficiary schools are provided in Table 3.

May 2017
Table 3: Details of Sanitation Facilities to be provided by the Project

Lot Name of School Description of Works
Abossey Okai 1& 2 Completion of new 16-seater 2-storey toilet with septic tank
Cluster Rehabilitation of 10-seater WC with septic tank
Connection of water from GWCL and provision of 2No. Rambo 2000 and 1No.
Ram 500
Provision of a 32.84 m2 refuse holding bay and 4No. 240L bins
Provision of 68m length U-drain
Paving 236.42 m2 of the site
1 2
Kaneshie West 1&2 Provision of 0.91m
Rehabilitation furnace fitted
and remodeling of with smoke
existing stack to 20-seater to meet GES
16-seater
Cluster standards.
Provision of new 3-seater and 10-seater WC with septic tank
Rambo 500
Provision of a 32.84m2 refuse holding bay and 4No. 240L bins
Provision of 74m length U-drain
Mataheko R/C Cluster Rehabilitation and 2remodeling
Provision of 0.91m furnace fitted with smoke
of 24-seater WCstack
with septic tank
Rambo 1000
2
Provision of 60 m length U-drain
2
Paving 188.88m of the site.
Osu Presby Cluster Provision
Rehabilitation and2remodeling
of 0.91m furnace fitted with smoke
of existing stack WC to meet GES standards.
20-seater
Connection of water from GWCL and provision of 2 No Rambo 2000.
Provision of 32.84 m2 refuse holding bay and 4No. 240L bins.
3
Provision of 28m length of U-drain.
Paving 188.88m2 of the site.
Osu Salem 1 Primary Rehabilitation and remodeling of existing 8-seater WC with septic tank
Schools Connection of water from GWCL and provision of 1 No Rambo 1000 and 1No.
Rambo 500.
Provision of 20 m length of U-drain.
Paving 75.04 m2 of the site.
4
Osu Salem 5 Primary Rehabilitation and remodeling of 10-seater WC with septic tank.
School Connection of water from GWCL and provision of 1 No Rambo 2000.
Farisco Cluster of Rehabilitation and remodeling of existing 20-seater facility to meet GES
Schools standards.
Connection of water from GWCL and provision of 1 No Rambo 2000 and 1 No
5 Rambo 1000.
Provision of 24.75 m2 refuse holding bay and 3No. 240L bins

May 2017

Osu St. Barnabas Rehabilitation and remodelling of existing 10-seater WC facility to 14-seater
Anglican Schools WC.
Connection of water from GWCL and provision of 1 No Rambo 2000 and 1
No Rambo 500.
6 2
Provision of 24.75 m refuse holding bay and 3No. 240L bins.
Independence 1&2 Provision of new 10-seater WC with septic tank.

Cluster Connection of water from GWCL and provision of 3 No Rambo 2000.
7
Ayalolo Cluster of Rehabilitation and remodelling of the existing 3 facilities (8, 12 and 20- seater
Schools WCs toilets) to meet GES standards.
8 Provision of 32.84 m2 refuse holding bay and 4No. 240L bins.
Korle Gonno R/C Boys Provision of new 14-seater WC with septic tank
Connection of water from GWCL supply line.
Provision of 1No. Rambo 2000
Provision of a 78 m length of U-drain
9
Dr F.V. Nanka Bruce JHS Provision of new 10-seater WC with septic tank.
Connection of water from GWCL and provision of 1No. Rambo 2000
Socco/M1 Cluster of Provision of new 10-seater WC with septic tank.

Schools Provision Connection of water from GWCL and provision of 1No. Rambo 1000
and 1No. Rambo 500
10
Provision of 68 m length of U-drain
Paving 231.02m2 of the site.
2
Sempe 8/12 JHS Provision of 0.91m
and remodeling with smoke
of existing stackWC to 12-seater WC.
16-seater
Connection of water from GWCL and provision of 1No. Rambo 1000.
2
Paving 90.86 m2 of site.
11
Owusu Mills Primary/ Rehabilitation and remodeling of existing 16-seater WC facility to 12-seater WC
JHS with septic tank.
Connection of water from GWCL and provision of 1No. Rambo 1000.
Provision of 0.91m2 furnace fitted with smoke stack

May 2017

Accra Newtown 6&8 Rehabilitation and remodelling of 8-seater WC with septic tank.
12
Primary Classroom Block Provision of new 10-seater WC with septic tank.
Accra Newtown 4&11 Connection of water from GWCL and provision of 1No. Rambo 1000 and 2No.
Primary Classroom Block Rambo 500.
Provision of 2No 24.75 m2 refuse holding bay and 3No. 240L bins.
Provision of 54 m length of U-drain
Kwame Nkrumah JHS Rehabilitation of existing bio-fill toilet

Connection of water from GWCL and provision of 2 No. Rambo 500.
Unity Cluster Provision of new 10 and 20-seater WC with septic tanks.
Connection of water from GWCL and provision of 2 No Rambo 2000, 1
Rambo 1000 and 1 No Rambo 500.
2
Rehabilitation and remodelling of existing 20-seater to 24-seater WC with septic

tank.
Connection of water from GWCL and provision of 2 No Rambo 2000, 1 Rambo
1000 and 1
13 Kanda Cluster
No Rambo 500.
2
2
Provision of 0.91m
and remodelling ofwith smoke stack
20-seater WC and 2No 10-seater WC and
provision of a new 3-seater WC.
Anumle Cluster of Rambo 500.
14 2
Schools Provision of 32.84 m refuse holding bay and 4No. 240L bins.
Rehabilitation and remodelling of existing 10-seater WC with septic tank.

2
Shiayennor 1&2 Primary
Paving of 86.34 m2 of the site.
15 Rehabilitation and remodelling of 10-seater with septic tank.

Rambo 500.
Shiayennor A&B JHS Provision of 24.75 m2 refuse holding bay and 3No. 240L bins.
2
Paving 86.34 m of the site.

May 2017

Rehabilitation and remodelling of 20, 10 and 12-seater WC with septic tank.
Kaneshie 6 Primary/ Connection of water from GWCL and provision of 2 No Rambo 1000, 1 No
Kaneshie Kingsway 1 Rambo 2000 and
JHS A&B and Kaneshie 8 1No Rambo 100.
16
Primary/ Provision of 48m length of U-drain and 20m length of U-drain
Kaneshie Kingsway 2 Provision of 2 No 24.75 m2 refuse holding bay and 3No. 240L bins.
JHS A&B Paving of 372.86 m2 of the site.
17 La Bawaleshie Presby Rehabilitation and remodelling of existing 10-seater facility with septic tank.
Cluster Connection of water from GWCL supply line.
Provision of 2 No Rambo 2000.
2
Paving 86.34 m of the site.
Rehabilitation and remodelling of existing 10-seater facility and provision of

ancillary facilities to meet GES standards.
Connection of water from GWCL supply line.
2
Maamobi Prisons Cluster
2
Paving of 86.34 m of the site.
Rehabilitation and remodelling of 2 No 10-seater WC with septic tanks.

18 Dzorwulu JHS
Rehabilitation and remodelling of existing 20-seater WC to 24-seater WC with

septic tank.
Rehabilitation of existing 12-seater WC facility to meet GES standards.
Provision of new 24-seater WC with septic tank.
Kwashieman Cluster Connection of water from GWCL and provision of 6 No Rambo 2000
19 Paving 540.34 m2 of the site.
Provision of new 10-seater WC with septic tank.

Darkuman 1 JHS
Paving of 86.34 m2 of the site.

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2.5 Design Standards
2.5.1 General
Good engineering designs of WC toilets and ancillary facilities must incorporate sound design
principles. The following general and specific standards of WC toilet designs have been adopted for
use and incorporated in the production of architectural/structural designs and working drawings.
a) Designs are cost effective. This means that the schools should be able to bear the maintenance
cost of the facility to ensure sustainability.
b) Designs are technically sound and therefore meet the technical criteria below:
 Privy rooms are adequately sized, well ventilated and have squatting/sitting arrangements
selected according to the school’s preference.
 Locally available building materials will be used during construction of the facilities.
 Designs are simple and easy to construct and therefore local persons/artisans in the project
area with no special skills would be engage in the construction as a means of job creation.
 Designs are simple therefore will be easy to use and maintain.
 Designs have adequately sized and functionally well designed septic tanks to efficiently
handle wastewater hence prevent environmental pollution and associated health problems.
c) Designs are “child-friendly”, gender sensitive and safe for use. Toilet seats have been carefully
selected to offer the desired convenience to both male and female pupils. Additional
devices/fixtures are fitted to ensure that smaller children are comfortable and feel safe in the
use of facilities. Ramps and sizes of cubicles are designed to provide access to disabled pupils.
d) Installations that ensure good hygiene have been considered. The facilities prevent contact
with faeces, by humans and flies.
e) Designs are environmentally friendly. The operation and use of the recommended sanitation
facilities will not create any adverse effect on the natural environment (i.e. air, surface water
and ground water pollution).
2.5.2 Lighting
Thoughtful selection of fixtures and lamps coupled with careful replacements is very crucial in
lighting design. The following are the lighting design standards adopted:
 Energy saving bulbs will be used

 The minimum general lighting level is 300 lux
 Warm-colour lighting will be used in the general lighting scheme because it creates better
ambience in the toilets, which in turn encourages more care and responsibility from the users
 Adequate number of windows with a good spread around the building will be incorporated to:
o Provide maximum daylight effect, and
o help create a softer and friendlier environment.

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2.5.3 Materials for Internal Finishes
Materials that will be used for internal walls, floors and ceiling finishes will be durable and resistant
to vandalism and neglect. The following are the good examples of finishes that have been adopted:
 Floors of the toilet rooms will be tiled with non-slip ceramic tiles. Non-slip floor tiles have been
selected because they are durable and relatively easy to clean and maintain as well as friendly
 Internal walls of toilets will be ceramic wall tiled
 The minimum size of tile will be (100mm x 200mm)
Ceiling works should be made with the following materials depending on their availability on the
market, cost and ease of maintenance:
 Mineral fibre board,

 Fibrous plaster board,
 ½ “ plywood boards
 Aluminium panels or strips
The Consultant has opted for the use of ½ inch plywood boards based on availability and cost of
materials on the local market. Ceilings will be painted white to brighten the toilet rooms, create the
interest and produce conducive environment during use.
2.5.4 Water Closets (WCs)
1. All WC cisterns will be wall hung and robustly fitted against the cubicle wall
2. All plumbing fixtures connecting the WC suites will be concealed for easy maintenance and to
deter vandalism.
2.5.5 Hand Wash Basin
1. Minimum size of handwash basins will be 500mm length x 400mm width.

2. Minimum spacing between any two (2) wash hand basins will be 800mm.
3. Minimum space between center of the basin and any end wall will be 500mm.
4. Minimum room dimension for hand-washing area with one wash hand basin will be
1800mm length X 1000mm width.
5. Water pressure and tap/wash basin will be positioned such that water splash is avoided.
2.5.6 Service Installations
1. All pipe works will be concealed, except for final connections to fixtures.
2. All electrical cables will be fully concealed
3. Coved tiles or PVC strips should be provided along edges as far as possible
4. Panels to pipe ducts will be located as far as possible in inconspicuous areas

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2.6 Labour and Related Issues
There are thirty (30) construction sites under AMA and these are expected to be handled by six (6)
different contractors. It is envisaged that each contractor would require up to a maximum of ten (10)
workers per site. The contractors are expected to ensure that the number of workers engaged per
site are in proportion to the project work load and contract duration Workers will be employed from
among artisans in the local community and will return to their homes after completion of their daily
assignments.
The conduct of workers on site will be guided by the model code of ethics provided in Annex 2 to be
adopted by the contractor. The working hours will as much as possible be limited to non-school
periods to minimize the interaction between students and construction workers and will therefore
avoid exposure of students to any indecent behavior that may be exhibited by the workers.

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3.0 RELEVANT POLICIES, LEGAL AND ADMINISTRATIVE FRAMEWORKS
The relevant national and sector policies and plans, national legal and institutional frameworks and
World Bank safeguards policies to guide the proposed construction of institutional sanitation
facilities in Metropolitan and Municipal assemblies to ensure sustainable development and
compliance with national and international regulations are briefly described below.
3.1 Policy Framework
The National Environment Policy (2013)

The Ghana National Environmental Policy was formulated in 1995 and revised in 2013. The ultimate
aim of the National Environmental Policy of Ghana is to improve the surroundings, living conditions
and the quality of life of the entire citizenry, both present and future. It seeks to promote
sustainable development through ensuring a balance between economic development and natural
resource conservation. The policy thus makes a high quality environment a key element supporting
the country’s economic and social development.
The National Environmental Sanitation Policy dated April 2010

The revised environmental sanitation policy seeks to refocus the priorities of the sector, so it is
forward looking and effectively embraces the challenges of changing life-styles associated with
modernization and improving wealth status. The policy lays the basis for developing a systematic
approach and framework for identifying and harnessing resources for value-for-money (economy,
effectiveness and efficiency) services to all.
The Community Water Supply and Sanitation Programme (1994)

The Government has adopted a national water supply and sanitation programme to rationalize the
water sector to promote and improve the delivery of water services in terms of economy, efficiency,
effectiveness and satisfaction. The long term goals of the programme are generally directed at
covering the entire country with potable water and adequate sewage disposal system by the year
2020 with emphasis on payment of adequate tariffs by consumers to ensure full cost recovery and to
provide revenue for operations and maintenance and replacement of systems.
National Health Policy (2007)

The National Health Policy document which aims at creating wealth through health, among other
things places emphasis on improvements in personal hygiene, immunisation of mothers and
children. The National Health Policy also argues that a healthy population could only be achieved if
there were improvements in environmental hygiene and sanitation, proper housing and town
planning, provision of safe water, safe food and nutrition and encouragement of regular physical
exercise.
3.2 National Regulatory Framework
The Constitution of the Republic of Ghana (1992)

The Constitution includes some provisions to protect the right of individuals to private property, and
also sets principles under which citizens may be deprived of their property in the public interest
(described in Articles 18 and 20). Article 18 provides that “…Every person has the right to own
property either alone or in association with others.”

May 2017
In Article 20, the Constitution describes the circumstances under which compulsory acquisition of
immovable properties in the public interest can be done:
“No property of any description, or interest in, or right over any property shall be compulsorily taken
possession of or acquired by the State unless the following conditions are satisfied:
 The taking of possession or acquisition is necessary in the interest of defence, public safety,
public order, public morality, public health, town and country planning or the development
or utilization of property in such a manner as to promote the public benefit; and
 The necessity for the acquisition is clearly stated and is such as to provide reasonable
justification for causing any hardship that may result to any person who has an interest in or
right over the property.”
Article 20 of the Constitution provides further conditions under which compulsory acquisition may
take place: no property “shall be compulsorily taken possession of or acquired by the State” unless it
is, amongst other purposes, “to promote the public benefit (Clause 1).
Ghana Investment Promotion Centre Act 1994, Act 478

The Ghana Investment Promotion Centre Act 1994 (Act 478) requires that every investor wishing to
invest in the country must in its appraisal of proposed investment projects or enterprises, “…have
regard to any effect the enterprise is likely to have on the environment and measures proposed for
the prevention and control of any harmful effects to the environment...”.
Environmental Protection Agency Act 1994, Act 490

The Environmental Protection Agency Act 1994 (Act 490) gave mandate to the Agency to ensure
compliance of all investments and undertakings with laid down Environmental Assessment (EA)
procedures in the planning and execution of development projects, including compliance in respect
of existing ones.
Environmental Assessment Regulations 1999, LI 1652

The Environmental Assessment Regulations 1999 (LI 1652) enjoins any proponent or person to
register an undertaking with the Agency and obtain an Environmental Permit prior to
commencement of the project.
Fees and Charges (Amendment) Instrument 2015 (LI 2228)

The Fees and Charges (Amendment) Instrument 2015 (L.I. 2228) replaces the Fees and Charges
(Amendment) Instrument, 2014 (LI 2216), and gives regulation to the fees and charges
(Miscellaneous Provision) Act 2009, Act 793. The law provides a comprehensive rates, fees and
charges collectable by Ministries, Department and Agencies (MDAs) for goods and services delivered
to the public.
Water Resources Commission Act 1996, Act 522

The Water Resources Commission Act 1996 (Act 522) establishes and mandates the Water Resources
Commission as the sole agent responsible for the regulation and management and the utilisation of
water resources and for the co-ordination of any policy in relation to them. Section 13 prohibits the
use of water (divert, dam, store, abstract or use water resources or construct or maintain any works
for the use of water resources) without authority. The Act states under Section 24 that any person

May 2017
who pollutes or fouls a water resource beyond the level that the EPA may pre-scribe, commits an
offence and is liable on conviction to a fine or a term of imprisonment or both.
GWCL Act/Statutory Corporations (Conversion to Companies) Act 461 of 1993 (as amended by LI
1648)
The Statutory Corporations (Conversion to Companies) Act 461 of 1993 as amended by LI 1648, on
1st July 1999, transformed Ghana Water and Sewage Corporation into a 100% state owned limited
liability, Ghana Water Company Limited (GWCL), with the responsibility for urban water supply only.
The mandate of GWCL is to provide, distribute and conserve the supply of water in Ghana for public,
domestic and industrial purposes in urban communities. GWCL may, after giving notice to the owner
or occupier of any land or premises, enter on that land or premises and dig trenches, lay pipes and
do any other acts reasonably necessary for the carrying out its functions.
Local Government Act, 1993 Act 462

This Act establishes and regulates the local government system and gives authority to the Regional
Coordinating Council (RCC) and the District Assembly to exercise political and administrative power
in the Regions and District, provide guidance, give direction to, and supervise all other administrative
authorities in the regions and district respectively. The Assembly is mandated to initiate programmes
for the development of basic infrastructure and provide municipal works and services as well as
being responsible for the development, improvement and management of human settlements and
the environment in the district.
Lands (Statutory Wayleaves) Act, 1963 (Act 186)

The Lands (Statutory Wayleaves) Act, 1963 (Act 186) details the process involved in the occupation
of land for the purpose of the construction, installation and maintenance of works of public utility,
and for the creation of rights of way for such works. Further to this act, the statutory wayleave
registration 1964 provides procedural details and grievance redress mechanism.
The State Lands Act, 1963 (Act 125)

The Act 125 vests the authority to acquire land for the public interest in the President of the
Republic. It also gives responsibility for registering a claim on the affected person or group of
persons, and provides details of the procedure to do this. The State Lands Act, 1962 provides some
details to be taken into consideration when calculating compensation such as definitions for (1) cost
of disturbance, (2) market value, (3) replacement value, and so on.
Lands Commission Act, 2008 (Act 767)

This Act provides for the management of public lands and other lands and for related matters. The
Commission manages public lands and any other lands vested in the President by the Constitution or
by any other enactment or the lands vested in the Commission. The Act advises the Government,
local authorities and traditional authorities on the policy framework for the development of
particular areas to ensure that the development of individual pieces of land is coordinated with the
relevant development plan for the area concerned.
The Minister may, with the approval of the President, give general directions in writing to the
Commission on matters of policy in respect of the management of public lands. The Commission has
the following divisions:

May 2017
 Survey and Mapping;

 Land Registration;
 Land Valuation; and
 Public and Vested Lands Management.
The Labour Act, 2003 (Act 651)

Section 118(1) of the Labour Act 2003 (Act 651) stipulates that it is the duty of an employer to
ensure that every worker employed works under satisfactory, safe and healthy conditions. Act 651
contains a number of specific provisions relating to an employer’s duty to its workers. These include
providing and maintaining “at the workplace, plant and system of work that are safe and without risk
to health” and taking “steps to prevent contamination of the workplaces by, and protect the workers
from, toxic gases, noxious substances, vapours, dust, fumes, mists and other substances or materials
likely to cause risk to safety or health”. A worker is required to report situations that he believes
may pose “an imminent and serious danger to his or her life, safety or health”.
Workmen’s Compensation Law, 1987, PNDCL 187

It is to provide for the payment of compensation to workmen for personal injuries caused by
accidents arising out and in the course of their employment. The tenets of the law places a large
share of the burden of supporting workers injured at the workplace on the shoulders of the
employers.
3.3 Institutional Framework
Ministry of Local Government and Rural Development

The Ministry of Local Government and Rural Development (MLGRD) exists to promote the
establishment and development of a vibrant and well-resourced decentralized system of local
government for the people of Ghana to ensure good governance and balanced rural based
development. The Environmental Health and Sanitation Directorate (EHSD) of MLGRD has oversight
responsibility for sanitation. The Ministry has developed and is currently implementing a National
Environmental Sanitation Policy and an accompanying plan, the National Environmental Sanitation
Strategy and Action Plan (NESSAP) and Strategic Environmental Sanitation Investment Plan (SESIP).
The Ministry has a Project Coordinating Unit (PCU) which is coordinating the GAMA project. There is
a safeguard specialist and a social safeguards specialist at the PCU to ensure that environmental and
social issues are addressed during project implementation.
Metropolitan, Municipal and District Assemblies

Metropolitan, Municipal and District Assemblies (MMDAs) are responsible for the provision of water
and sanitation services within their respective areas of jurisdiction, including the planning and
implementation of projects where necessary. They serve as the planning authority responsible for
the overall development of their areas of jurisdiction. The proposed construction of institutional
sanitation facilities is being carried out by 11 MMDAs in the Greater Accra Metropolitan Area
(GAMA).
There is a GAMA Project Coordinator at AMA to coordinate the activities at the local level and to
provide feedback and progress on implantation to the PCU. The GAMA project coordinator is not a

May 2017
safeguard specialists and would require some training/capacity building for the ESMP
implementation.
Environmental Protection Agency

The Environmental Protection Agency is the body responsible for regulating the environment and
ensuring the implementation of government policies on the environment. The functions of the
Agency include:
 ensuring compliance with any laid down environmental impact assessment procedures in the
planning and execution of development projects, including compliance in the respect of existing
projects;
 promoting effective planning in the management of the environment;
 imposing and collecting environmental protection levies in accordance with the Environmental
Protection Agency Act 1994, Act 490 or regulations made under the Act; and
 acting in liaison and co-operation with government agencies, District Assemblies and other
bodies and institutions to control pollution and generally protect the environment.
The EPA has the capacity and will corporate with the municipal Assembly (i.e. the GAMA project
coordinator) to ensure the protection of the environment during project implementation.
Ministry Of Education/ Ghana Education Service (GES)

The Ministry of Education/Ghana Education Service provides oversight responsibility for basic,
secondary and tertiary education in Ghana. The School Health Education Program (SHEP) Unit under
the Ghana Education Service is responsible for health promotion in schools up-to pre-tertiary level.
The SHEP Unit facilitates the effective mobilization and deployment of available human, material
and financial resources to equip school children with basic life skills for healthy living through skills-
based health education, promoting good health and preventing diseases among the school
population. There are SHEP Coordinators at the Metropolitan and Municipal levels and also at the
school level. In the schools, the SHEP Coordinators are responsible for coordinating water, sanitation
and hygiene (WASH) issues.
The institutional arrangements for SHEP implementation at the Municipal level is illustrated in Figure
1 as follows:
 Municipal SHEP Committee (at the apex): They are mandated by the SHEP Policy to amongst
other things mobilize schools and communities for SHEP action and mobilize funds for SHEP
implementation activities.
 The School Management Committee is (SMC) is a community level stakeholder grouping that
fosters community participation in educational development. The SMC plays a major role in the
management of the school. Their establishment mandate includes roles in ensuring that the
school premises are in a sanitary and structurally safe condition and to ensure that facilities are
generally in a good state of repair.
 The School-based Health Coordinator is a teacher on roll who is assigned the role of coordinating
all school health related activities
 School Health Club is a vehicle to activate pupils’ participation in school health activities.

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Municipal SHEP
Committee
School Management
Head Teacher
Committee
School based Health

Coordinator
School Health Club
Figure 1: Institutional structure for SHEP implementation at the Municipal Assembly and School level
The SHEP coordinator is not a safeguards specialist and would require some training/capacity
building in the implementation of the ESMP.
Ghana Health Service

The Ghana Health Service (GHS) is the public service body responsible for implementation of
national policies under the control of the Minister for Health through its governing Council - the
Ghana Health Service Council. The mandate of GHS is to provide and prudently manage
comprehensive and accessible health service with special emphasis on primary health care at
regional, district and sub-district levels in accordance with approved national policies. The functions
of GHS include to:
 undertake management and administration of the overall health resources within the service;
 Promote healthy mode of living and good health habits by people;
 establish effective mechanism for disease surveillance, prevention and control; and
 perform any other functions relevant to the promotion, protection and restoration of health.
The School Health Education Programme is a joint mandate of the Ministries of Health and
Education.
Ghana Water Company Limited (GWCL)

GWCL is the state utility company responsible for portable water supply to all urban communities in
Ghana. The mandate of GWCL is to provide, distribute and conserve the supply of water in Ghana for
public, domestic and industrial purposes in urban communities. The connection of water supply to
the toilet facilities under the project will mainly be from GWCL supply lines.
Community Water and Sanitation Agency

Community Water and Sanitation Agency (CWSA) facilitate water supply and sanitation delivery for
rural communities and small towns. CWSA plays a facilitative role in providing technical assistance
for the planning and implementation of water and sanitation facilities in the districts.

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3.4 World Bank Safeguards Policies
The World Bank (WB) has published policies/procedures to guide the safe development of projects it
is funding. Among the ten (10) WB Safeguards Policies, one (1) – OP 4.01 – is triggered by the
proposed project. The WB safeguards policies and a summary of their core requirements are
provided in Table 4.
Table 4: Summary of World Bank Safeguard Policies
No World Bank Summary of core requirements Potential for Remarks or

Safeguard Trigger under recommendation for
Policy proposed project proposed project
1 OP 4.01 Requires environmental assessment (EA) of Triggered The entire GAMA
Environmental projects proposed for Bank financing to help project being funded by
Assessment
ensure that they are environmentally sound and the WB, including the
sustainable, and thus to improve decision Construction of
making. The EA takes into account the natural Institutional Sanitation
environment (air, water, and land); human Facilities in MAs and
health and safety; social aspects (involuntary Construction of Road
resettlement, indigenous peoples, and physical Culvert Drains falls
cultural resources); and trans boundary and under category B, and
global environmental aspects. It categorizes this EMP is in line with
proposed projects into categories A, B, C or FI the requirement of the
based on the extent of adverse impacts policy.
anticipated from the project.
For Category A and B projects, an ESMP is to be

prepared to guide the Implementation of
mitigation measures for all identified
environmental impacts from the proposed
project.
2 OP 4.04: Do not finance projects that degrade or convert Not triggered Project locations and
Natural critical habitats. Support projects that affect design will not affect
Habitats non- critical habitats only if no alternatives are any critical habitats.
available and if acceptable mitigation measures
are in place. The policy strictly limits the
circumstances under which any Bank-supported
project can damage natural habitats (land and
water areas where most of the native plant and
animal species are still present).
3 OP 4.09: Pest Support integrated approaches to pest Not triggered The project will not
Management management, identify pesticides that may be involve the use of
financed under the project and develop pesticides.
appropriate pest management plan to address
this.
4 OP 4.36: Aim is to reduce deforestation, enhance the Not triggered Project location and
Forest environmental contribution of forested areas, design will not affect
promote afforestation, reduce poverty, and any critical forests.
encourage economic development.

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No World Bank Summary of core requirements Potential for Remarks or

Safeguard Trigger under recommendation for
Policy proposed project proposed project
Support sustainable and conservation oriented
forestry. Do not finance projects that involve
significant conversion or degradation of critical
forest areas.
5 OP 4.11: Investigate and inventorise cultural resources Not triggered No culturally sensitive
Physical potentially affected. Include mitigation sites identified.
Cultural measures when there are adverse impacts on
Resources physical cultural resources or avoid if possible
6 OP 4.12: Assist displaced persons in their effort to Not triggered The study did not find
Involuntary improve or at least restore their standards of any evidence of
Resettlement living. Avoid resettlement where feasible or existence or occurrence
minimise. Displaced persons should share in of Involuntary
project profits. Resettlement.
The policy aims to avoid involuntary
resettlement to the extent feasible, or to
minimize and mitigate its adverse social and
economic impacts.
The policy prescribes compensation and other
resettlement measures to achieve its objectives
and requires that borrowers prepare adequate
resettlement planning instruments prior to Bank
appraisal of proposed projects.
7 OP 4.10: Screen to determine presence of indigenous Not triggered No indigenous groups
Indigenous peoples in project area. Policy triggered were identified.
Peoples whether potential impacts are positive or
negative. Design mitigation measures and
benefits that reflect indigenous peoples’ cultural
preferences.
8 OP 4.37: Requires that experienced and competent Not triggered The proposed project
Safety of professionals design and supervise construction, does not involve the
Dams and that the borrower adopts and implements construction of dams.
dam safety measures through the project cycle.
The policy distinguishes between small and large
dams by defining small dams as those normally
less than 15 meters in height. Large dams are
15 meters or more in height.
9 OP 7.50: Ascertain whether riparian agreements are in Not triggered The proposed project
Projects on place, and ensure that riparian states are does not involve
International informed of and do not object to project international waters.
Waterways interventions.
10 OP 7.60: Ensure that claimants to disputed areas have no Not triggered No issues of land
Projects in objection to proposed project. dispute were identified.
Disputed
Areas

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4.0 BASELINE ENVIRONMENTAL AND SOCIAL CONDITIONS
Baseline conditions give the existing status of the environment in the area before the
commencement of the proposed project. The information serves the purpose of a base reference
against which the changes due to the implementation of the project are measured. The ensuing
therefore constitutes the baseline conditions of the proposed project area, which includes the
existing physical and socioeconomic environment.
4.1 Location and Size
The proposed project district is the Accra Metropolitan Assembly (AMA), which is one of the sixteen
(16) Metropolitan, Municipal and District Assemblies (MMDAs) in the Greater Accra Region of
Ghana. AMA has a total land area of 139.674 square kilometres and shares boundaries with the Ga
South Municipal to the West, La Dadekotopon Municipal to the East and Ga West Municipal to the
North. The Gulf of Guinea is on the South of the Metropolis (See Figure 2).

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Figure 2: Map of Accra Metropolis (Source: Ghana Statistical Service, 2014)

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4.2 Physical Environment
4.2.1 Climatic Conditions
The Accra Metropolitan Area lies in the dry equatorial climatic zone. It experiences two rainy
seasons: May to mid-July and mid- August to October. It has an average annual rainfall of about
730mm. There is very little variation in temperature throughout the year. The mean monthly
temperature ranges from 24.7°C in August (the coolest) to 33°C in March (the hottest) with annual
average of 26.8°C. As the area is close to the equator, the daylight hours are practically uniform
throughout the year. Relative humidity is generally high varying from 65% in the mid-afternoon to
95% at night (Ghana Statistical Service, 2014).
4.2.2 Vegetation
There are three broad vegetation zones in the Accra Metropolitan area: shrub land, grassland and
coastal lands. The shrub land occurs more commonly in the western outskirts and in the north towards
the Aburi Hills. It consists of dense clusters of small trees and shrubs, which grow, to an average height
of about five metres. The grasses are mixture of species found in the undergrowth of forests. They are
short and rarely grow beyond one metre. Ground herbs are found on the edge of the shrub. They
include species which normally flourish after fire (Ghana Statistical Service, 2014).
The coastal zone comprises of two vegetation types, wetland and dunes. Mangroves, comprising of two
dominant species, are found in the tidal zone of all estuaries sand lagoons. Salt tolerant grass species
cover substantial low-lying areas surrounding the lagoons. There are a number of wetlands and water
bodies which create micro climates in some parts of the Metropolitan Area. However, the original
vegetation of the Metropolitan Area has been altered in the more recent past century by climatic and
human factors (Ghana Statistical Service, 2014).
The proposed project sites are within schools and are close to existing sanitation facilities. The
vegetation at the project sites, if any, are common grasses and shrubs found in other areas of the
schools and in the Metropolis. Trees are generally not expected to be affected from the project
construction.
4.2.3 Geology and Soils
The geology of AMA consists of Precambrian Dahomeyan Schists, Granodiorites, Granites Gneiss
and Amphibolites to late Precambrian Togo Series comprising mainly Quartzite, Phillites, Phylitones
and Quartz Breccias. Other formations found in the Metropolis are the Palaeozoic Accraian
Sediments - Sandstone, Shales and Interbedded Sandstone-Shale with Gypsum Lenses. The coastline
of the Metropolis has a series of resistant rock outcrops and platforms and sandy beaches near the
mouth of the lagoons. The coastline is exposed and because of the close proximity of the continental
shelf, a strong coastal and wind action, it is subject to severe erosion.
The soils in the Metropolitan area can be divided into four main groups:
i. drift materials resulting from deposits by windblown erosion;
ii. alluvial and marine motted clays of comparatively recent origin derived from underlying shales;

May 2017
iii. residual clays and gravels derived from weathered quartzites, gneiss and schist rocks; and
iv. lateritic sandy clay soils derived from weathered Accraian sandstone bedrock formations.
In many low lying poorly drained areas, pockets of alluvial ‘black cotton’ soils are found
4.3 Socio-Economic Environment
The socioeconomic characteristics AMA are presented below.
4.3.1 Demographic Characteristics
The population of Accra Metropolitan Assembly AMA, according to the 2010 Population and Housing
Census, is 1,665,086 representing 42% of the region’s total population. Males constitute 48.1% and
females represent 51.9%. The Metropolis is entirely urban. It has a sex ratio of 93 and youthful
population (children under 15 years) (42.6%) depicting a broad base population pyramid which
tapers off with a small number of elderly persons (60+ years) constituting 5.9 percent. The total age
dependency ratio is 48.5%, the child dependency ratio is higher (42.6%) than that of old age
dependency ratio (5.9) (Ghana Statistical Service, 2014).
4.3.2 Education and Literacy
For the population 3 years and older in the Metropolis, Out of the 533,291 persons enumerated as
being in school, 38.4% were at the primary level, 18.2% were at the JSS/JHS level while 12.8% were
at the Senior High School level. More females (26.1%) than males (23.2%) ended their education at
the JHS/JSS levels while more males (14.3%) than females (8.2%) completed tertiary education in the
Accra Metropolis. Of the population 11 years and above, 89% are literate and 11% are non-literate.
The number of non-literate females (98,439) was more than twice that of males (39,567) (Ghana
Statistical Service, 2014).
4.3.3 Employment and Industry
About 70.1% of the population aged 15 years and older are economically active while 29.9% are
economically not active. The economically active population, 93% are employed while 7.0% are
unemployed.
More than a third (35.2%) of the total population who worked were in the wholesale and retail,
repair of motor vehicles and motor cycles category. Of this number, females constituted the highest
proportion (41.2%), indicating that females prefer working in those industries. More males (8.3%)
worked in the construction industry compared to females (0.3%). In general, informal sector
employment is predominant in the Metropolis. The private informal sector employs about 74% of
the population (Ghana Statistical Service, 2014).
4.3.4 Water Supply
Of the 30 beneficiary schools, 26% do not have water available and 74% have water. This is because
either they did not have a GWCL piped water connecting to the school at all or they had been cut

May 2017
due to accumulated and non-payment of bills. The measures used by these schools to meet their
water needs include pupils fetching water from outside the school compound as a form of
punishment, fetching of water by pupils as a school activity on the daily duty roaster and asking
pupils to bring water to school (WasteCare Associates, 2016a).
The 74% who had water also had some challenges with the service. Some of the schools complain
that the water supply service which is usually GWCL water service is sporadic with frequent cut in
the service. Some additionally complained that bills continued to pile up and they did not have any
means of paying these bills and feared that service will be cut in the near future. Those schools who
share compounds with the mission (church) depended on them for water. However some of the
head-teachers reported that they had been threatened to pay up their share of the bills or risk being
cut off (WasteCare Associates, 2016a).
Water tanks and other means of water storage are used by most of the schools to store water. These
water tanks are sometimes vandalized or even stolen by unscrupulous characters in the community.
Plate 2 shows a water storage tank at Osu Presby Cluster.
Plate 2: Water storage tank at Osu Cluster (Source: WasteCare Associates, 2016a)
4.3.5 Drainage
Drains on school compounds are mostly non-existent. The common practice in many schools for
liquid waste disposal is the throwing of waste water on the compound. This is also employed as
a means to reduce dust as many of the school compounds are not cemented.
4.3.6 Sanitation and Hygiene
Toilets
Out of the 30 schools and clusters visited 32% of them have no toilets at all 7% have their toilets
closed down for a number of reasons, 51% are in very poor conditions and remaining 10% are in
relatively good condition (Figure 3).

May 2017
Figure 3: Availability and condition of toilets in schools in AMA (Source: WasteCare Associates, 2016a)
Of the 7% of toilets that were closed at the time of assessment, the common reasons were the lack
of water for the effective operation of the toilet. Other reasons given were damaged septic systems
and blocked toilets due to vandalism and improper use of the facility. A number of reasons
accounted for the 51% toilets in poor condition. Some of the facilities are not being operated at
their full capacity. It was common to see that, for example, a 20 seater toilet facility may be
operating only at half capacity due to some broken fixtures or blocked toilets (drop holes). The few
functional ones were under pressure. Again, due to the lack of water or irregular water supply,
pupils or cleaners are unable to properly use and clean the facility. In most of the cases cleaning of
the facility is left to pupils or in some cases those under punishment. There is usually very little or no
supervision from teachers and hence the condition of the facility keep deteriorating.
Children in schools without toilets resorted to the use of public toilets and/or engaged in open
defecation. Open defecation is particularly common among the smaller children who are unable to
go by themselves to public toilets, or do not have money for the fees, and are unable to hold an
urgent need to defecate. They squat around the school compound, or use poly bags, open spaces or
refuse dumps around the school and other open drains. In some cases teachers or attendants
superintend over such acts because they have no other options.
For the 10% toilets that are relatively in good condition, there is a designated cleaner who is paid,
regular flow of water and in some cases the facility is relatively new and not under pressure. Of the
30 schools assessed, only 30% of schools that have toilet facilities met the Ghana Education Service
(GES) minimum standard of 50 pupils per drop hole. A third of these facilities still presented poor
condition due to irregular flow of water, absence of a designated full time cleaner and in some cases
broken fixtures linked to improper use (WasteCare Associates, 2016a).
Though it is mandated by law for schools to have disability friendly facilities, none of the schools
assessed had disability friendly facilities (WasteCare Associates, 2016a).

May 2017
Urinals
About half (51%) of the 30 beneficiary schools have no urinals. Where toilets are available, pupils
used them for that purpose. Where there are no toilets to be used as urinals, pupils urinate around
the school compound. Where urinals are available, they are usually in poor condition and poorly
managed. In some cases doors to the urinals are damaged, compromising security and privacy. Out
of the 49% who have urinals, half are segregated for boys and girls. But for the remaining half both
boys and girls have to share a cubicle. In about 90% of the school both male and female teachers
have to share a single urinal (WasteCare Associates, 2016a). Plate 3 shows a dilapidated urinal in use
at Ayalolo Cluster of Schools.
Plate 3: Condition of a urinal at Ayalolo Cluster of Schools (Source: WasteCare, 2016a)
Hand wash
The common hand wash facilities currently used in most schools are Veronica buckets or any bucket,
barrel, gallon or jerry can fitted with a tap to facilitate hand washing under running water. Some
challenges experienced by schools include irregular water supply, un-sustained supply of soap and
frequent breakdown of the hand wash facilities. Due to the frequent breakdown of hand wash
facilities, most schools did not have hand wash facilities at the required designated areas and in
some cases a whole school resorts to sharing one hand wash facility. In some schools, toilets did not
have hand wash facilities and pupils have to use hand wash facilities provided in front of classrooms.
Schools which had regular supply of water in some cases did not have hand wash facilities at all
because pupils could easily walk to the tap to wash their hands (WasteCare Associates, 2016a). Plate
4 shows common hand wash facilities in schools under AMA.

May 2017
Plate 4: Common hand wash facilities in schools under AMA (Source: WasteCare Associates, 2016a)
4.3.7 Waste Management
The most widely used methods of solid waste disposal in the Accra Metropolis is collected from
home (57.4%) and by public dump (container) accounting for 32.9%. Liquid waste is mostly disposed
into gutters (48.0%), through a drainage system into a gutter (26.6%) and through a sewerage
system (7.8 %) (Ghana Statistical Service, 2014).
Generally all the beneficiary schools have some form of waste receptacles before refuse are finally
disposed, though they are inadequate. Burning is the most common practice of waste disposal. This
accounted for 60% of schools followed by the use of communal or public dump. A number of the
schools use a combination of methods. Figure 4 shows the methods of waste disposal in schools
under AMA.

May 2017
Figure 4: Methods of solid waste disposal in schools under AMA (Source: WasteCare Associates, 2016a)
Most schools resorted to burning as they were not in the position to pay the monthly service fee of
Gh₵25 - Gh₵30 charged by the waste management companies. In other cases the waste collection
service is unreliable and irregular that some schools had to burn what can easily be burnt on regular
bases and leave the rest to be collected by waste management companies. The pick-up time is
ideally once a week but usually done twice in a month.
Burning is usually done daily in the morning or after school or weekly on Fridays or as and when
needed. Some school heads indicated that neighbouring community members complain about the
smoke whenever they burn, but do not have any other option available to them.
Some of the schools practiced waste separation for plastics. They collected all plastics and sell to
individuals who collect these plastics or to venders who buy these plastics. Some of the schools
claimed though they were separating in the past, they had stopped due to the irregular pick up by
venders and the lack of space to store plastics for long periods. Others do not separate at all because
it was considered a laborious exercise. Many of the schools did not consider waste separation as a
means to reduce waste and generate some income (WasteCare Associates, 2016a).

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5.0 STAKEHOLDER CONSULTATIONS
Stakeholder participation during project planning, design and implementation is widely recognized
as an integral part of environmental and social management for projects. It is a two-way flow of
information and dialogue between project proponents and stakeholders, which is specifically aimed
at developing ideas that can help shape project design, resolve conflicts at an early stage, assist in
implementing solutions and monitor ongoing activities.
Key project stakeholders were identified for consultations and these included AMA, the beneficiary
institutions, local communities, and their representatives and local government institutions.
5.1 Objectives of Consultation
The main objective of the consultations with stakeholders is to discuss the proposed project’s
environmental and social implications and to identify alternatives for consideration. Specifically, the
consultations seek to achieve the following objectives:
 To provide some information about the proposed project;
 To provide opportunities for stakeholders to discuss their concerns and offer
recommendations;
 To gain insight on the role of each stakeholder in the implementation of the environmental and
social safeguards as well as structures in place for the management of the proposed facilities;
 To provide and discuss with stakeholders the alternatives considered to reduce anticipated
impacts;
 To identify and verify significance of environmental, social and health impacts; and
 To inform the process of developing appropriate mitigation and management options.
5.2 Stakeholder Consultation Strategy and Plan
Stakeholder consultation is a process and would continue through the ESMP study stages through to
its implementation. Table 5 summarizes the proposed approach for stakeholder engagement.

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Table 5: Stakeholder Engagement Programme
No. Activity Identified Stakeholders Focus of Consultation/ Engagement Timelines/ Forms of communication Facilitator
Frequency
1. Preparation of  Ministry of Local Government and  Challenges with WASH implementation Throughout the  One on one Interviews SAL Consult
Rural Development/ Project in schools,  Field visitation
ESMP/ Project design  Potential environmental and social issues ESMP study Limited
Coordinating Unit,  Sharing and review of relevant
 WasteCare Associates, of concern from the proposed project’s period reports
 GWCL implementation  Email and phone calls
 AMA (SHEP Coordinator/SHEP  Compliance with World Bank and EPA
Committee), requirements for GAMA S&W Project
 Head Teachers, student  Strategies for mitigating the potential
representatives, School impacts and successful maintenance of
Management Committee, non- the proposed facility during their
teaching staff in schools operation
 Public and occupational health and safety
at construction sites
 Scope of interventions of proposed
works for institutional facilities
construction and adequacy of sanitation
facilities
2. Site preparation prior  School authorities  Information on schedule of preparation Two weeks prior  General stakeholder meeting WasteCare
 Students and construction for school authorities,
to construction  Awareness creation on the potential to construction Associates/ AMA
 Community/ Assembly member Consultant, and contractor
 WasteCare Associates/ Contractor impacts and remedial measures to  Announcement at School Works
students and community Assembly Department/
 Integration of the ESMP into planning for  Utilisation of WASH Notice
construction (impacts and mitigation Head teacher/
“Talk” boards for students/staff
measures) and notice board at site School based
 Grievance redress procedures including safety signs Health
 Capacity building for stakeholders for the  Community notifications.
implementation of the ESMP Coordinator
3. Start of construction  School authorities  Information on Schedule of construction Throughout the  General stakeholder meeting WasteCare
 Students works, activities and progress of for school authorities,
construction construction Associates / AMA
 WasteCare Associates / Contractor  Awareness creation on the potential period  Announcement at School Works
impacts and remedial measures to Assembly Department/
students and community  Utilisation of WASH Notice
 Training Head teacher/

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Frequency
o ESMP Implementation (impacts and “Talk” boards for students/staff School based
mitigation measures) and notice board at site
o Code of Conduct including safety signs Health
 Grievance redress mechanism  Community notification. Coordinator
4. End of construction /  School authorities  Information on Schedule of Decommissioning  General stakeholder meeting WasteCare
 Students decommissioning works, activities and for school authorities,
Decommissioning of progress of decommissioning phase Associates /AMA
construction  WasteCare Associates/ Contractor  Awareness creation on the potential  Announcement at School Works
equipment and impacts and remedial measures to Assembly Department/
students and community  Utilisation of WASH Notice
machinery  Training Head teacher/
o ESMP Implementation (impacts and and notice board at site School based
mitigation measures) including safety signs Health
o Code of Conduct  Community notification.
 Grievance redress mechanism Coordinator
5. Commissioning and  School Management Committee  Operation and Maintenance (O&M) Prior to operation  General stakeholder meeting WasteCare
(SMC) requirements of the toilets for school authorities,
handing over of  Roles and responsibilities in the O&M of the facility Associates /
 Parents Teacher Association (PTA) Consultant, and contractor
Institutional  School based Health Coordinator  Training on the Facilities Management  Announcement at School Metropolitan
sanitation facility (SBHC) Plan Assembly and SHEP Committee
 School Health Club (SHC)  Utilisation of WASH Notice and Coordinator/
Head teacher/
School based
Health
Coordinator
6. Operation and  School Management Committee/  Hygiene education During operation  General stakeholder meeting WasteCare
Parents Teacher Association  Operation and Maintenance (O&M)  Training workshops
maintenance of requirements of the toilets and maintenance Associates /
 School based Health Coordinator
facility  Teachers/staff  Roles and responsibilities in the O&M period Metropolitan
 School Health Club  Training on the Facilities Management SHEP Committee
 Students Plan
and Coordinator /
 Review of grievance
Metropolitan
SHEP Coordinator

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Frequency
 Students  Interactive activity teaching and testing 3 times a week  Classroom activity Class Teacher
knowledge
 Demonstration activity for building habits
 Entire School  Teaching knowledge and motivating Fortnightly  Main school lesson during School health
pupils for change of habits worship time club and SBHC.
 Reinforcing/repeating key messages from 3 times a week  Morning Assembly School health
Worship Time Sessions
club and SBHC.
 Reinforcing/repeating key messages from 3 times a week  WASH Notice “Talk” boards School health
Worship Time Sessions
club and SBHC.
 All classes and all schools in  Activities focusing on testing knowledge Once a term  Competitions and SBHCs/
Metropolis dissemination to the entire school and demonstrative activities
indirectly parents and communities Metropolitan
SHEP Coordinator
 Parents and Teachers  Support to activities/actions as well as Once a term  WASH Session during PTA  PTA
reports on progress meeting for schools
 Funding for the O&M of facilities
 School Management Committee  Support to activities/actions as well as Once a term  WASH Session during SMC SMC
(SMC) reports on progress. Meeting
 support to School Health Club activities
as well as individual support as club
patrons
 Support to SBHC

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5.3 Stakeholders Consulted
Key stakeholders to the proposed Institutional Sanitation Facilities in the Accra Metropolitan Area
have been identified and sampled for consultation. The Consultation of the stakeholders was carried
out from November 2016 to February 2017 to gather information, comments and concerns on the
proposed project with respect to the potential environmental and social issues and impacts.
The approach adopted for the stakeholder consultations involved one-on-one interviews and focus
group discussions. The stakeholders consulted during the ESMP study are listed below.
Project proponents:
 AMA
 WasteCare Associates
Contractor
- Foreman
Beneficiary Schools
Management Committee and Parent Teacher Association; school prefects and health club
5.4 Outcome of Stakeholder Consultations carried out during ESMP Preparation
A summary of the outcome of the stakeholder consultations is provided in Table 6. Further evidence
of stakeholder consultations with the various stakeholders/institutions have been provided as Annex
1.

May 2017
Table 6: Details of Stakeholder Consultations
Stakeholder Contact Person Role Contact Date Concerns raised / information Received
number
PROJECT PROPONENTS/CONSULTANT/CONTRACTOR
Ministry of Local George Awudi Safeguard Specialist 0506152780 Ongoing  Provided relevant information and documents on project implementation and
Government and environmental and social concerns
 Provided input on requirements for compliance with World Bank safeguards
Rural
 The ESMP must ensure it incorporates the provision of constant water supply to the
Development/
sanitation facilities
Project
Coordinating
Accra Graham O. Sarbah Director, Drains Maintenance 0243235530/ Nov. – Dec.  Provided relevant information and documents on project implementation and
Metropolitan Unit/ GAMA SWP Project 0202019170 2016 environmental and social concerns including project description, screening reports,
Facilities Management Plan, Baseline studies and other relevant reports of studies
Assembly Coordinator (AMA).
carried out.
 Also served as liaison between the Environmental Consultant and the beneficiary
institutions, as well as the Engineering Consultants.
Engineering Lukeman Salifu CEO 0302786072 Nov.- Dec.  Provided a description of the proposed project scope and schedule for construction
Consultant 2016  Provided information on environmental and safety measures to be put in place during
(WasteCare construction works.
Associates)
Contractors
-Milpar Christian Managing Director 0244377744 28/11/2016  Provided details of project and information on safety measures to be put in place at
Development Hammond project sites.
Investment
Paul Danquah Foreman 0244605312 28/11/2016
HEADS OF INSTITUTIONS/SHEP COORDINATORS/ PAROCHIAL CHURCH COUNCIL (PCC)/ PARENT TEACHER ASSOCIATION (PTA)
Dr. F.V. Nanka Rita Allotey Addo 0244121456 28/02/2017 Current Practices/ Challenges
SHEP Coordinator
Bruce JHS  The existing facility is a compositing toilet. Students pour about a handful of sawdust
into the toilet after using it.

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number
Cherie Sam Teacher 0244786401  A philanthropist built the existing facility but it is inadequate to accommodate the
entire school population.
 The students come along with toiletries for their personal use in school.
 Some students sometimes go home to use toilet facilities due to pressure on the
existing facility
Water availability
 There is no water supply in the school. The GWCL lines have been disconnected due
to the fact that accumulated utility bills have not been paid.
Security
 The people from the community come to use the existing facility as well and break
the padlock when the door is locked, especially outside school sessions.
 The school has written formally to the Assembly for the provision of a security person
to help improve security in the school.
Socco/ M1 Mercy Kusi- Circuit Supervisor 0208291439 28/02/2017 Current Practices/Challenges
Cluster of Schools Appiah  There is also no toilet facility in the school currently. The students pay to use a public
toilet opposite the school.
Vincentia S. Banim Head Teacher 0244582671  The female students do not come to school during their menstrual period because
there are no changing rooms available.
 There is only one dustbin for the cluster.
Theresa Owusu SHEP Coordinator 0243138281
 Rubbish is sometimes dumped at a public dumpsite at Chorkor which is cheaper, but
very far from the school.
Daniel Acquah PTA Chairman 0241138538
 There is a borehole but no GWCL connections in the school.
 There are only few veronica buckets in the school.
 The students are asked to bring soap and other toiletries to school at the beginning of
the term sometimes.
 Most of the classrooms are temporal structures made of wood.
 The churches that use the classrooms for service pay the electricity bills sometimes.
 There is a dilapidated structure where the new facility is to be sited.
 Students are educated about sanitation issues and how to practice personal hygiene.

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number
 The school conducts inspection once every week as part of its role to promote
personal hygiene.
Management of new facilities
 Part of the capitation grant given to the school by the government could be used as
funds to maintain the new facility.
 The P.T.A would also help with the provision of funds to maintain the new facility
Osu Salem 1 Basic Akuaku Joe Bright Head Teacher 0243312253 28/02/2017 Current Practices/Challenges
School  The existing facility was being rehabilitated by Football for WASH (an NGO) but the
project has been stalled due to inadequate funds rendering only two out of ten toilet
Okyere Monica SHEP Coordinator/ Teacher 0203001192 facilities to be used by both pupils and teachers. This has led to pressure on the toilet
facilities because of the large school population.
 There is no changing rooms for the girls.
 There is no water supply currently although there is a poly tank that was donated by
the NGO.
 Most of the waste bins are broken hence it becomes difficult to dispose rubbish when
the bins are full
 The utility bills are paid with monies collected from churches and individuals who use
the classrooms as places of worship.
Comment on GAMA Project
 School will like the Contractor to provide more details on the project to the school
authorities.
Osu Salem 5 Mrs. Salamatu 0244597126 28/02/2017 Current Practices/Challenges
Primary Abdul-Karim  The existing 10-seater toilet facility which serves two schools (5no. each) was built by
Head teacher
Pronet (an NGO) is not adequate for the two schools.
Miss. Matilda 0261696078  The source of water supply is a well but it is not sufficient especially in the dry season.
 The people from the community come and use the existing facility during weekends
Lokko SHEP Coordinator/ Teacher
and on holidays.
 The school caters for the utility bills using internally generated funds.
Role of Health Club

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number
 The health club is responsible for educating the students on hygiene.
Comments/Recommendations for GAMA Project
 Noise was generated during construction activities, so it would be expedient if
construction is done on weekends.
 Water connection to the new facility can be tapped from the Osu Presby Cluster
which is not far from the school.
Kaneshie West Emelia Ohemeng Head Teacher 0244360212 28/11/2017 Challenges
Cluster of Schools (See Plate 5)  The water bills are very huge.
 There is currently a borehole in the school but it is salty hence it needs to be treated
to enable the school use it instead of the water provided by GWCL.
 There are no waste bins in the school so rubbish is burnt which causes a lot of health
problems.
Abossey Okai R/C Marian H. Head Teacher 0244607528 28/11/2016 Current Practices/ Challenges
JHS Commeh  The existing toilet facility is a 12- seater KVIP which serves over 1000 students, hence
putting pressure on the facility.
 The louvre blades of the existing toilet have been removed, so when it rains it gets
inside the toilet.
 The school pays Zoomlion (a waste management company) to collect and dispose
their solid waste.
 There is water supply in the school currently but the water ceases to flow during the
dry season.
 A cleaner is paid by the school to clean the existing facility although the students also
clean the place occasionally. This procedure will continue if the new facility is built.
Comments on New Toilet
 The school authorities have not been briefed on the project that the construction of
the new facility

May 2017
number
Abossey Okai R/C Eunice S. Asante SHEP Coordinator 0243831883 28/02/2017 Current Practices/ Challenges
 There is strong odour from the existing toilet facility.
Pascal Mensah PCC Member 0260755521  The entire school population is about 2000.
 The existing facility is not enough to accommodate the number of pupils hence there
is pressure on it.
 The female pupils are prone to infectious diseases due to the bad hygienic conditions
of the existing toilets.
 There is an existing borehole in the school which serves as a source of water supply.
 The students pay levy and the church also supports with the payment of utility bills.
 The teachers’ staff common room is very small and not convenient.
 Recommendations/Suggestions for GAMA Project
 The school would prefer a pour flush toilet facility as to water closets to help in easy
maintenance of the new facility
PREFECTS/HEALTH CLUB
Socco/ M1 Boateng President (Health Club) - 28/02/2017 Current Practices/ Challenges

Cluster of Schools Emmanuel  The students defecate in the nearby houses or community public toilets when they
have stomach upset. They are charged 50pesewas when they go to the public toilets.
Wiafe Foster Vice President (Health Club)  The students fetch water from nearby taps outside the school. A gallon costs
Gh₵1.00.
 The school has limited hand wash facilities (veronica buckets).
Pappoe Juliet Secretary (Health Club)
 The female students are inconvenienced during their menstrual period because there
are no changing rooms for them.
Osei Benjamin Organizer (Health Club)
 Students go and fetch water during class hours for use sometimes due to the
unavailability of water in the school.
Antwi Naomi Treasurer (Health Club)
Role of Health Club
 There would be sensitization of students on how to use the new facility and also how
-Members (Health Club) to properly dispose rubbish.
(See Plate 6) Suggestions/Recommendations for Project
 The students would be glad if the project provides them with toiletries even though

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number
they suggested that each of them could pay Gh₵1.00.to be used to purchase the
toiletries.
Osu Salem 1 Basic Amofah Eva School Prefect/ Health Club - 28/02/2017 Current Practices/ Challenges
School Secretary  The existing toilet facility is not adequate to accommodate the school population.
 There is no supply of water and hand washing facilities (veronica buckets) in the
Ninyeh Benjamin Boys’ Prefect/ Health Club Vice school.
 The girls have to change themselves in the latrines during their menstrual period, due
President
to no changing rooms.
Role of Health Club in Sanitation and Hygiene Management
 The Health Club Executives of the school organize fellow students to clean up the
toilet facilities.
 The health club organizes a programme to educate all students on the importance of
good hygiene practice once in a month.
Osu Salem 5 Joshua Bonsu Asst. Porter (Health Club) - 28/02/2017 Current Practices/ Challenges
Primary  The toilet seats and handles of most of the existing water closets are spoilt, hence
Stephen Yeboah Member (Health Club) needs to be rehabilitated
 There are no changing rooms for the girls.
 The Sanitation Prefects are to ensure the existing facility is kept clean.
Claudia Borketey Member (Health Club)
 The existing facility is cleaned both in the mornings and in the afternoons.
 There is water available to be used to maintain the new facility.
 Existing hand washing facilities (Veronica buckets) are inadequate and in a bad
condition.
 The school has inadequate dustbins.
Role of Health Club in Managing New Facilities
 The sanitation prefect and the health club executives will ensure that the new facility
is kept clean and also ensure students do not squat on the water closets.

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number
Abossey Okai R/C Ishmeal Selormey School Prefect - 28/02/2017 Current Practices/ Challenges
 The existing facility is a KVIP.
Yahwe- Yire Djan Girls’ Prefect  Existing toilet is inadequate for the school’ population.
 There are no changing rooms for the females.
 The rubbish in the school is burnt and this pollutes the air
Gilbert Jones Sectional Prefect
 There are only few waste bins in the school, this makes waste management a
challenge.
Joyce Brooke Office Girl
 The school has no library and the ICT is very small
 There are holes in some parts of the roofing hence the sun and rains get into the
Josephine Sackey Asst. School Prefect
classrooms.
(See Plate 7) Role of Prefects in Sanitation and Hygiene Management
 Consultant explained to student their role in managing the new facilities and
improving sanitation and hygiene in the school.

May 2017
Plate 5: Consultation between Environmental Consultant, Official of AMA and Head Teacher of Kaneshie West Cluster of
Schools
Plate 6: Consultations with SHEP Coordinator, Prefects and Health Club Members of Socco/M1 Cluster of Schools
Plate 7: Consultation with Prefects of Abossey Okai R/C School

May 2017
5.5 Key Environmental and Social Concerns from Stakeholder Consultations
The main environmental and social concerns raised during the stakeholder consultations are as
follows:
i. Security
Security in all the schools visited (refer to Section 1.3.2) is currently a major challenge. The
schools mostly do not have a fence/wall and security personnel. Members of the neighbouring
communities therefore use the schools’ toilet facilities, especially outside school sessions. This is
more prominent in communities that do not have public toilet facilities. Locks installed by school
authorities at the toilet facilities to keep out the public are usually destroyed. Security needs to
be improved at the schools in general, and the toilet facilities especially to ensure the
sustainability of the facilities.
ii. Payment of utility bills
Some schools complained of hire water bills and their inability to pay the water bills which
results in disconnection of water supply from Ghana Water Company Limited. For example,
water supply to Abossey Okai 1&2 Basic School had been disconnected due to non-payment of
water bills by the school.
iii. Lack of awareness of the project among school authorities and pupils
Majority of the pupils in the various schools and some school authorities had seen the
construction work ongoing and were aware there was a new toilet facility project. However they
were not aware of the projects key components.

May 2017
6.0 DESCRIPTION OF ENVIRONMENTAL AND SOCIAL IMPACTS
Field inspections and observations, concerns arising from stakeholder consultations and project
description and designs formed the basis for the identified potential environmental issues and
impacts likely to be associated with the proposed construction of institutional sanitation facilities in
AMA.
6.1 Project Area of Influence
6.1.1 Geographical Area of Influence
The immediate geographical area of influence for the proposed sanitation facilities is a maximum of
1 acre land in each of the beneficiary schools. The larger geographical area of influence covers the
Accra Metropolis of the Greater Accra Region of Ghana.
6.1.2 Physical Environmental Media Influence
The physical environmental media to be potentially influenced by the activities of the proposed
project are land (landscape), air quality, groundwater and any adjacent drain to any of the project
sites. The landscape features include soil, flora and fauna at the proposed project site which will be
impacted by the project activities. Any adjacent drain to any of the project sites will be the recipient
of runoff water from the project site. Any percolation of fuels during construction works and
leachates from poorly constructed or improperly sited septic tanks through the soil may impact on
groundwater resources. The air quality may also be impacted by dust and gaseous emissions from
construction activities.
6.1.3 Community Influence and Vulnerable Persons in the Institutions
The implementation of the proposed project could have an impact on the economic and socio-
cultural conditions of the various project communities (as indicated in Table 1) and other
neighbouring localities in AMA.
Vulnerable Groups
Vulnerable groups are those at risk of becoming disadvantaged and require special provisions in the
project design. Vulnerable people include, but not limited to:
 Physically challenged (disabled) pupils/teachers;
 Pre-school children; and
 Female pupils/teachers.
The project will not result in the displacement of any person. The construction sites are within and
belong to the beneficiary institutions, and are not inhabited by any persons. The toilet facilities to be
provided are disability friendly, with a special cubicle provided in each toilet for disabled persons
and ramp provided to aid access to the toilet. Adequate segregation and protection have been
provided between toilet facilities for boys and girls to keep girls from aggressive boys (or any other
potential attackers). Special facilities have also been included in the designs for toddlers.

May 2017
6.1.4 Institutional Influence
The major institutions to be influenced or involved in the proposed project include:

 Ministry of Local Government and Rural Development;
 Ministry of Education;
 Ghana Education Service;
 Ministry of Health;
 Ghana Health Services;
 Environmental Protection Agency;
 Accra Metropolitan Assembly;
 WasteCare Associates;
 The various Contractors;
 The various beneficiary schools; and
 Ghana Water Company Limited.
6.2 Project Activities of Environmental and Social Concern
Activities of potential environmental and social impacts identified with the proposed project are
outlined under four (4no.) main phases of the project activities; namely preparatory; construction;
operations and maintenance; and decommissioning phases.
6.2.1 Preparatory Phase Activities

Preparatory phase activities include among others:
 Assessment of existing sanitation facilities, selection of beneficiary schools, field studies and
environmental screening;
 Preparation of environmental and social screening reports;
 Statutory permitting activities from EPA.
The preparatory phase activities had been completed prior to commencement of the preparation of
the ESMP.
6.2.2 Construction Phase Activities

Construction activities include among others:
 Demolition of existing defective septic tanks ;
 Demolition of existing defective WC toilets;
 Site clearing (where applicable) and excavation works;
 Identification of storage area for construction material;
 Transportation and handling of materials and equipment;
 Construction of WC toilet (with internal urinal) and septic tank;
 Construction of U450 perimeter drain;
 Connection of facilities to GWCL main supply lines and Installation of water storage poly
tanks overhead and underground;
 Rehabilitation of existing toilet facilities;
 Laying of pavement around toilet facilities; and
 Construction of refuse/solid waste holding bay.

May 2017
6.2.3 Operations and Maintenance Phase Activities
Operations and maintenance phase activities include:

 Housekeeping;
 Waste management (collection and disposal);
 Maintenance and repair works; and
 Materials management and storage (including disinfectants, cleaning tools, personal
protective equipment, etc.).
6.2.4 Decommissioning Phase
Decommissioning activities after construction works will involve:

 Disposal of construction spoil and waste in general;
 Restoration of landscape around construction site; and
 Removal of construction equipment.
The sanitation facilities to be provided by the project will be utilized by the beneficiary schools as
long as they are well maintained. Decommissioning during the operational phase is therefore
unlikely.
6.3 Criteria of Impact Evaluation
6.3.1 Duration of the Impact
 A temporary impact can last days, weeks or months, but must be associated to the notion of
reversibility.
 A permanent impact is often irreversible. It is observed permanently or may last for a very long
term.
6.3.2 Extent of the Impact
 The extent is regional if an impact on a component is felt over a vast territory or affects a large
portion of its population.
 The extent is local if the impact is felt on a limited portion of the zone of study or by a small
group of its population.
 The extent is site-specific if the impact is felt in a small and well defined space or by only some
individuals.
6.3.3 Intensity of the Impact
 The intensity of an impact is qualified as strong when it is linked to very significant modifications
of a component.
 An impact is considered of average intensity when it generates perceptible disturbance in the
use of a component or of its characteristics, but not in a way to reduce them completely and
irreversible.

May 2017
 A weak intensity is associated with an impact generating only weak modifications to the
component considered, without putting at risk some its utilization or its characteristics.
6.3.4 Impacts Severity
 Major Impact: An impact of major significance is one where an accepted limit or standard may
be exceeded, or large magnitude impacts occur to highly valued/sensitive resource/receptors.
Repercussions on the environment are very strong and cannot easily be reduced.
 Moderate Impact: An impact of moderate significance is within accepted limits and standards.
Moderate impacts may cover a broad range, from a threshold below which the impact is minor,
up to a level that might be just short of breaching an established (legal) limit. Repercussions on
the environment are substantial but can be reduced through specific mitigation measures.
 Minor Impact: An impact of minor significance is one where an effect will be experienced, but
the impact magnitude is sufficiently small and well within accepted standards, and/or the
receptor is of low sensitivity/value. Repercussions on the environment are significant but
subdued and may or may not require the application of mitigation measures.
6.4 Evaluation of Potential Positive Impacts
The potential positive impacts of the proposed construction of institutional sanitation facilities in
AMA are stated and evaluated in Table 7.
Table 7: Evaluation of potential positive impacts.
No. Impact Key receptor(s) Evaluation Significance

1. Improved Students/staff/ The current sanitation infrastructure (toilets, urinals) in the Major
beneficiary schools are inadequate and in a poor state.
hygiene and visitors of
Changing rooms for girls are not available.
sanitation in beneficiary
beneficiary schools The proposed project, through the construction and
schools rehabilitation of toilet facilities, including urinals and hand
washing facilities will improve hygiene and sanitation
infrastructure as well as access in the beneficiary schools.
The provision of changing rooms for girls will improve
privacy for girls especially during their menstrual period and
menstrual hygiene.
The proposed project will therefore lead to a major

improvement in hygiene and sanitation in the beneficiary
schools in AMA.
2. Improved Disabled people The existing sanitation facilities in the beneficiary schools Major
are not disability-friendly, which makes access to the
access to in the
disabled a challenge. The sanitation facilities to be provided
hygiene and beneficiary by the project will have toilets specially made and reserved
sanitation schools for disabled people. Ramps will also be made to ease access
facilities by to the toilet facilities by disabled people on wheel chairs.
disabled people The impact will be major.

May 2017
No. Impact Key receptor(s) Evaluation Significance

3. Improved waste Students/staff/ Waste management is a challenge in many schools due to Major
inadequate bins and lack of proper storage areas of bins
management in visitors of
prior to collection. Some schools resort to dumping of
beneficiary beneficiary refuse in open areas and open burning as a means of waste
schools; schools management due to inadequate or lack waste collection
bins and storage areas. The proposed project will improve
waste storage and disposal through the provision of
refuse/solid waste holding bay.
The impact on waste management in the beneficiary

schools is major.
4. Improved water Beneficiary Water supply for use and cleaning of existing sanitation Major
facilities in the beneficiary schools is unavailable or where
supply in schools
available, is unreliable. This leads to poor hygiene and
beneficiary cleaning in the toilets and urinals which poses health risks
schools to the users.
The proposed project will improve water supply for use in
the sanitation facilities through connection of water and
provision of poly tanks overhead and underground for
water supply to the toilet facilities. The impact will be
major.
5. Employment Community The proposed project will create employment opportunities Major
for skilled and unskilled labour during the construction and
generation members,
operational phases. These include direct employment
people from opportunities such as masons, carpenters and labours to be
other engaged by the contractor during construction works, and
communities indirect employment opportunities such as food vendors,
petty traders and suppliers of raw materials for
construction. During the operational phase, job
opportunities will be created for maintenance workers and
suppliers of disinfectants, waste management companies,
etc.
The project will have a major positive impact on the
socioeconomic conditions of the various project
communities, and AMA a whole through the creation of
permanent and temporary direct jobs, and indirect jobs.
6. Improvement in Neighbouring The creation of direct and indirect job opportunities during Major
the construction and operational phases of the project will
local and communities,
boost the local and national economy. Improved hygiene
national AMA and and access to sanitation facilities, as well as improved waste
economy national management in the beneficiary schools will reduce
economy sanitation and hygiene related diseases and associated cost.
The impact will be major and last throughout the duration
of the project.

May 2017
6.5 Evaluation of Potential Adverse Impacts Associated with the Proposed Project
The adverse environmental and social issues which could potentially arise from the proposed project
activities are stated and evaluated in Table 8.
Table 8: Evaluation of potential adverse impacts
No. Impact Key Evaluation Significance

receptor(s)
Preparatory Phase
1. Approval for Beneficiary Approval must be sort from school authorities in the selection of Major
schools and prior to construction works. Especially for
Construction schools
Missionary Schools, which are owned and managed by Churches,
and Siting of the Church Leadership must be consulted in addition to the Head
toilet facility Teachers for their approval as they will play a key role in the
management of the facilities.
It is important that siting of the proposed sanitation facilities is

compatible with activities in its close proximity. For instance,
where the proposed construction sites are close to canteens, this
may influence the hygienic conditions of food sold at the
canteen.
Construction Phase
1. Loss of Flora, fauna, The construction of the various project facilities will require Minor
limited vegetation clearance at some selected sites. The
vegetation and soil
vegetation to be lost are mainly grasses or shrubs. Individual
impacts on stands of trees occur at very few schools, example Kaneshie
fauna West Cluster of Schools. A tree will be removed only where it is
unavoidable after review by an Environmental Specialist. The
vegetation clearance will therefore not result in the loss of any
species of conservation value. Insects which may inhabit these
vegetation may be disturbed and will escape to adjoining
vegetation. Impact on vegetation is site-specific. The impact on
fauna (insects) is negligible as the project sites are already
disturbed due to ongoing human activities.
2. Soil impacts and Soil, drains Excavation works, vegetation clearance, levelling and other Moderate
ground works will expose and loosen the soil making it
sediment
susceptible to erosion. Transported soil from erosion may end up
transport in nearby drains. Improper handling and storage of fuel at the
construction site could lead to oil/fuel spills which could
contaminate the soil.
The impact is temporary lasting during the construction works.

But can be managed through good construction practices.
3. Air quality Ambient air Loosed and exposed soils from land preparation, dumping of Moderate
sand/laterite for construction works and movement of vehicles
deterioration environment,
delivering construction materials to the sites may release dust in
construction the immediate vicinity of the project. This may temporarily affect
workers, air quality in the schools. Exhaust fumes from vehicles and
pupils and concrete mixing machines may also impact on air quality.
teachers The impact is local and temporary, lasting during the land
preparation and construction phase.
4. Vibration and Air, fauna, The operation of concrete mixing machines, movement of Major
delivery trucks, tooting of horns of delivery trucks and carpentry
noise nuisance workers,
works will generate noise. This will create a nuisance for the
pupils and beneficiary schools, especially when school is in session. The

May 2017

receptor(s)
teachers demolition of old sanitation facilities may also lead to minor
vibrations. The impact is temporary and of local extent.
5. Visual intrusion Landscape, Construction of new sanitation facilities will result in alteration in Moderate
the landscape character and features. Poor housekeeping
pupils and
practices at the site may also reduce the aesthetic value of the
teachers area. The presence of the workers at site and their activities may
attract the attention of the pupils. This impact will be local and
temporary.
6. Destruction of Public, The movement of delivery trucks through the compound of Moderate
beneficiary schools to the construction sites may result in
property and property
destruction of pavements and concreted areas. The dumping of
obstruction of construction materials and waste in pathways may also obstruct
walkways movement of people. Excavations for laying of pipelines for
water connection may also obstruct movement where it crosses
walkways or destroy pavements and concreted areas along the
route. The affected pavements or concreted areas may belong to
individuals where the water connection point is outside the
schools’ compound. The impact, though temporary and lasting
during the construction phase, will create inconvenience for the
pupils/teachers and may result in public complaints.
7. Generation and Soil, water Vegetative material, excavated soil and construction spoils will Major
form the bulk of construction waste generated at the project
disposal of solid bodies,
sites. Construction spoils will mainly consist of demolished
waste school structures, used nails, wood chippings, plastics and pieces of iron
premises rods, etc.
Construction workers may also generate human and domestic
wastes such as used polythene bags, food wastes, used water
sachets and bottles, etc. The impact is of local extent and
temporary, lasting during the construction phase.
8. Occupational Workers Occupational health and safety issues associated with the Major
proposed project construction include:
health & safety
 Exposure of workers to excessive noise, vibrations and dust;
 Accidents in the use and handling of equipment and
machinery;
 Injury to the body during the use and handling of equipment
and machinery; and
 Illness caused by exposure to wastes and odour.
The extent of impact could be temporary or permanent.
9. Public safety & Public, The transportation of construction materials to site and the Major
movement of equipment to and from the project site may pose
Traffic issues school
safety risk to school children especially during break periods
community when school children are playing. The movement of delivery
trucks to the construction sites may also potentially disrupt
traffic especially at junctions leading to the schools.
Unsecured construction sites and excavations may pose safety

risks to school children in particular who may go playing at the
construction sites. The non-removal/abandoning of construction
equipment from sites after completion of construction works
may pose safety risks to pupils/teachers/public. The impact
could be temporary or permanent and could have major safety
consequences.
10. Sanitation and Land, water Key potential sanitation and public health issues that may arise Major
from the proposed project include:

May 2017

receptor(s)
public health bodies,  unsightly conditions of poorly managed construction site and
workers, indiscriminate disposal of waste;
 indiscriminate disposal of human waste could also lead to
public
spread of diseases; and
 open trenches and containers could collect water and breed
mosquitoes.
The duration of the impact is temporary.

Operational Phase
1. Nuisance from Public, pupils Odour may emanate from the toilets and urinals if they are not Moderate
properly and frequently cleaned. Dislodging of septic tanks when
odour and teachers
full will also generate odour which will be a nuisance to nearby
residents and members of the beneficiary schools. Odour may
also emanate from the waste storage and collection sheds if the
bins are not regularly emptied. The odour may be intense within
the vicinity of the facilities.
2. Ground water Ground Poorly constructed septic tanks may result in leakages which Minor
could potentially contaminate ground water, especially in areas
contamination water, public
where the water table is high. This could have serious health
implications for people who depend on ground water as the
leakage may occur for long periods without being detected. This
impact can be prevented/minimized through proper designing
and construction.
No areas with high water table have been identified in the

beneficiary schools. The probability of the impact is therefore
minimal.
3. Waste Land, public, The main solid waste to be generated on a daily basis at the Major
toilet facilities are faecal matter, used tissue paper, toilet roll and
generation school
sanitary pads. These have to be regularly and properly disposed
or could lead to odour, attract flies and have health implications.
Bins at waste storage and collection sheds also have to be
regularly emptied to prevent overflows which will be a nuisance
and have health implications. Septic tanks may also overflow if
they are not emptied when full. Waste generation will be
permanent, lasting throughout the life span of the project.
4. Sanitation Public, Rodents, flies, cockroaches and other insects may transmit Major
diseases to humans from contact with exposed feacal matter and
issues and school
rubbish at waste storage and collection sheds. The impact could
public health occur through the life span of the project.
impacts
Decommissioning Phase
1. Occupational/ Workers, The relocation of all construction facilities and remaining Moderate
public safety pupils, materials including concrete mixer, trucks, water tanks to new
and traffic teachers, sites or contractor’s office could result in accident and injury to
workers. The removal and transport of such equipment and
impacts public
materials could also pose traffic risks and public safety concerns
within the schools and along the routes. The duration of the
impact is temporary and could be local or of regional extent.
2. Waste Workers, The dismantling and removal of equipment and materials at the Moderate
site, as well as landscape restoration works could generate waste
management pupils,
such as scraps metal, wood, concrete debris, vegetative material,
teachers, and garbage (pieces of plastic bags, food wrappers, etc.).

May 2017

receptor(s)
public
The duration of the impact is temporary, the extent local and the
severity minor.
6.6 Evaluation of Risks to Sustainability of Project
The potential risks to the sustainability of the proposed project, as identified by the stakeholder
consultations, review of project documents and field inspections, are evaluated in Table 9.
Table 9: Evaluation of risks to the Sustainability of the Project
No. Risk Key receptor(s) Evaluation Significance

1. Flooding Groundwater, Heavy rains may result in flooding of areas around the toilet Major
facilities which may end up flooding the toilets if adequate
beneficiary
preventive measures are not incorporated into the design.
institution Flooding at toilet facilities may also result from rain water
getting into toilets which do not have proper windows and
adequate drains around the facility. Flood waters may carry
feacal matter which may end up contaminating surface and
ground water bodies and the soil.
2. Security issues Beneficiary Poor security in the institutions could lead to community Major
institution members entering the institutions’ compounds to use the
toilet facilities or break into the toilets to use them. This
could lead to damage to equipment parts such as door
handles or damage to the water closet. Security is currently
a challenge in many schools and the risk is high.
3. Unavailability of Students/staff/ The success of the proposed facilities hinges heavily on the Major
water regular availability of water at the toilets and beneficiary
visitors
institutions. Damage to water supply lines and unavailability
of water/irregular flow of water for flushing and cleaning
may pose serious health risks. Water supply to the
beneficiary institutions is currently unavailable or where
available, is unreliable. The health risk is high.
4. Poor Sanitation The installation of less durable equipment such as water Major
maintenance closets, hand wash basins and their fittings may lead to
facilities,
culture frequent breakdowns or early damage of the equipment.
beneficiary Improper use of the sanitation facilities and poor
institutions maintenance culture by the beneficiary institutions will also
result in frequent damage to parts of the facilities, which
may result in the facilities not functioning properly. This
may also result in high cost of repairs. Maintenance of the
existing toilet facilities is currently a challenge in many
schools.
5. Inadequate Sanitation Funds are required for facility cleaning, provision of Major
supplies, desludging services, maintenance and repairs and
funds facilities,
other related activities. The GES-SHEP Facilities
beneficiary Management Guide indicates the Capitation Grant as the
institutions main source of funds for implementing the school’s facilities
management plan (FMP). This allocation is however
inadequate and must be supplemented to meet the
maintenance needs of the proposed facilities.

May 2017
No. Risk Key receptor(s) Evaluation Significance

Payment of water and electricity bills in most schools is a
challenge. Some schools have accumulated debts which
must be paid to avoid any potential disconnection of
electricity and water to the schools in future.
6. Lack of Beneficiary In order to obtain the full support of the beneficiary Minor
institutions, it is important to ensure they are fully aware of
awareness of institutions
the scope and schedule of the facilities to be provided for
the project each beneficiary institution.
information Consultations indicate that the level of awareness of the
project is mainly limited to the head teachers and SHEP
Coordinators, other staff and students have minimum
knowledge and this may affect the extent to which they
take ownership of the project.

May 2017
7.0 ENVIRONMENTAL AND SOCIAL MITIGATION AND MANAGEMENT PLAN
7.1 Mitigation/Action Plan
Mitigation and management measures for the significant adverse impacts (rated as moderate or major) identified from the analysis and evaluation of the
potential impacts from the proposed project activities are provided in Table 10.
Table 10: Mitigation measures/actions for potential significant adverse impacts
No. Potential Project Activities Proposed Mitigation Measures/Actions Responsibility Cost Estimates per
Environmental and project site (Gh₵)
Social Impacts
PREPARATORY PHASE
1. Approval for  Stakeholder Consultations  Consult and seek free, prior and informed consent from school authorities prior to Contractor/Engineering Already captured
construction and siting  Siting of toilet facilities construction work. Consultant in Bill of Quantities
of toilet facility  For Missionary schools, seek free, prior and informed consent of Church Leadership
(BoQ)
in addition to Head Teachers.
 For all schools, Engineering Consultant to extensively consult school authorities on
the siting of toilet facilities in the school. The selection of sites should be agreed
upon with the school authorities.
 The selection of sites should take into consideration compatibility with adjacent
school facilities. The adjacent school facilities should not be at risk from the
operation of the proposed toilets.
 To ensure that students always have access to toilet facilities, the
contractors/consultants are not to demolish existing toilet facilities until the
new toilet facilities are in place. Where the existing toilet facility is the only
toilet for the school but has been earmarked for rehabilitation and or
reconstruction, then alternative toilet facilities should be provided the
school/students during the rehabilitation/reconstruction of the existing toilet
facility. Where necessary, mobile toilets should be provided. Where necessary,
mobile toilets should be provided.

May 2017
Social Impacts
CONSTRUCTION PHASE
1. Soil impacts and  Site clearing and excavation works  Vegetation (grasses and shrubs) should be cleared only when contractor is fully Contractor/ Already captured
sediment transport  Water connection from GWCL mobilised for construction. Engineering Consultant in Bill of Quantities
supply line.  Vegetation clearance (where necessary) and excavations should be limited to the (BoQ)
demarcated construction site.
 Backfill with excavated soil material where appropriate.
 Re-vegetate areas around construction sites to restore the landscape.
 Ensure that heaped sand delivered for construction works is covered with
tarpaulin to prevent wind and water transport of soil particles.
 Consult affected property owners/users and seek their consent prior to
construction works.
 Realign all affected utility service lines.
 Reinstate any damaged property such as pavements, etc.
2. Air quality deterioration  Site clearing and excavation works  Deliver construction equipment and materials to the construction sites outside Contractor/ Already captured
 Demolition of existing school school sessions, such as in the evenings or on weekends. Engineering Consultant in BoQ
sanitation facilities (where  Speed limit for all vehicles and construction equipment should be less than 30km/h
applicable) within the school environs and less than 50km/h within communities. Provide
 Transportation of materials and speed limit signs to guide drivers/operators.
equipment  Dampen untarred routes of vehicles/trucks to the construction sites.
 Construction of facilities  Haulage trucks carrying sand should be covered with tarpaulin.
 Disposal of construction spoil and  Hydraulic concrete mixing machines should be used as much as possible and
waste in general. regularly service all construction equipment and machinery.
3. Vibration and noise  Demolition of existing school  Demolition of old structures should be done outside school sessions, such as in the Contractor/ Already captured
nuisance sanitation facilities (where evenings or during weekends. Engineering Consultant in BoQ
applicable);  Carpentry works, and other noise generating activities should as much as possible
 Site clearing and excavation be carried outside school sessions.

May 2017
Social Impacts
works;  Hydraulic concrete mixing machines should be used as much as possible and
 Transportation of materials and regularly service all construction equipment and machinery.
equipment;
 Construction of facilities
4. Visual intrusion  All construction phase activities  The construction sites should be hoarded off from public view. Contractor/ Already captured
 Ensure good housekeeping at the construction site. Engineering Consultant in BoQ
 Ensure an acceptable post-construction site as per provisions in the contract.
 Remove all construction equipment from the site after completion of work.
5. Destruction of property  Demolition of existing school  Ensure construction equipment are not parked haphazardly to obstruct walkways. Contractor/ Already captured
and obstruction of sanitation facilities (where  As much as possible, do not dump construction materials in walkways. Engineering Consultant in BoQ
walkways applicable);  Provide safe alternative routes for pedestrians where walkways will be obstructed.
 Site clearing and excavation  Consult affected property owners/users and seek their consent prior to
works; construction works.
 Transportation of materials and  Realign all affected utility service lines.
equipment;  Reinstate any damaged property such as pavements, etc.
 Excavation works;
 Disposal of construction spoil and
waste in general.
6. Generation and disposal  All construction activities  Apply the principles of Reduce, Reuse and Recover for waste management. For Contractor/ Already captured
of solid waste example: Engineering Consultant in BoQ
- Purchase the right quality and quantity of materials;
- Ensure judicious use of construction materials such as pipes, laterites, sand,
etc.;
- Reuse excavated soil material for backfilling and levelling if appropriate.
 Provide bins on site for temporary storage of domestic waste such as lubricant
containers, drinking water sachets and carrier bags/packaging materials.

May 2017
Social Impacts
 Dispose all construction and domestic waste at AMA approved dump sites.
7. Occupational health and  All construction activities  Engage experienced artisans for construction works. Contractor Already captured
safety (OHS) issues  All workers should be given proper induction/orientation on safety. in BoQ
 The contractors should have a Health & Safety Policy to guide the construction
activities. The contractor health and safety policy would take into consideration the
World Bank EHS guidelines
 Regularly service all equipment and machinery.
 Ensure first aid kits on site and a trained person to administer first aid.
 Provide and enforce the use of appropriate personal protective equipment (PPE)
such as safety boots, reflective jackets, hard hats, hand gloves, earplugs, nose
masks, etc. for the labour force.
 Comply with all site rules and regulations. Engineering Consultant
 Apply sanctions where safety procedures are not adhered to.
 Site meetings should create awareness on OHS.
8. Public safety and traffic  Construction activities  Hoard off the construction sites to prevent access by unauthorised persons. Contractor/ Already captured
issues  Transport of equipment and  Use caution tapes and warning signs at the construction sites around trenches and Engineering Consultant in BoQ
materials to and from site excavations.
 Deliver construction equipment and materials to the construction sites outside
school sessions such as in the evening or weekends.
 Speed limit for all vehicles and construction equipment should be less than 30km/h
within the school environs and less than 50km/h within communities. Provide
speed limit signs to guide drivers/public.
 Do not park at unauthorised places to reduce the risk of accidents.
 Erect temporary road signs at junctions to the beneficiary schools during the
delivery of construction equipment and materials.
 Ensure delivery trucks hired/contracted are in good condition to prevent

May 2017
Social Impacts
breakdowns on roads.
 Remove all construction equipment from the site after completion of work.
9. Sanitation issues and  All construction phase activities  Provide bins on site for temporary storage of domestic waste such as lubricant Contractor/ Already captured
public health impacts containers, drinking water sachets and carrier bags/packaging materials. Engineering Consultant in BoQ
 Dispose all construction and domestic waste at AMA approved dump sites and in
the approved manner.
 Ensure all trenches or excavations made during the construction works do not
collect stagnant water which could breed mosquitoes.
 Ensure construction workers do not use existing school’s toilet facilities. Either they
identify nearby public toilet facilities for use or provided with temporary toilets
(mobile toilets) for use.
Public All construction phase  Implement Grievance Redress Mechanism, which will include such elements as: Refer to Redress Refer to Grievance
concerns/Grievance o Lodging and registration of PAPs grievance by grievance redress mechanism Chapter Redress Budget at
redress committee; table 14
o Redress decision, feedback and implementation;
o Dissatisfaction and alternative action; and
 Carry out monitoring and evaluation.
OPERATIONS PHASE
1. Nuisance from odour  Operation of sanitation facilities  Comply with provisions in the Facilities Management Plan (FMP). Authorities of 4,000 (per school
 Ensure good housekeeping at toilet facilities. beneficiary school/ per year)
 Clean toilet facilities regularly with disinfectants. SHEP Coordinator
 Empty bins in classrooms/offices regularly.
 Liaise with AMA to contract a waste management company to regularly collect and
dispose waste at AMA approved dump site.
 Dislodge septic tanks outside school sessions, such as on weekends.
2. Waste generation and  Use of sanitation facilities  Regularly empty waste bins at the various locations when full. Authorities of 4,000 (per school

May 2017
Social Impacts
disposal  Waste management  Sensitize pupils/staff on effective use of bins to avoid indiscriminate disposal of beneficiary school / per year)
 Maintenance and repair works. waste. SHEP Coordinator
 Damaged waste bins should be replaced as appropriate.
 Liaise with AMA to contract a waste management company to regularly collect and
dispose waste at AMA approved dump site.
 Inspect septic tanks periodically and dislodge when full.
3. Sanitation issues and  Use of sanitation facilities  Ensure pupils/staff wash their hands under running water and soap after use of SHEP Coordinator/ 1,000 (per school
health impacts  Waste management (collection toilet facilities. Head of school / per year)
and disposal)  Ensure good housekeeping at toilet facilities. Administrator
 Maintenance and repair works;  Clean toilet facilities regularly with disinfectants.
and  Ensure bins are properly covered at all times.
 Materials management and  Avoid indiscriminate dumping of waste at waste storage and collection shed and
storage (including disinfectants, always keep the place clean.
cleaning tools, personal protective  Provide disposable hand gloves for cleaning of sanitation facilities and emptying of
equipment, etc.). bins.
 Create awareness on hygiene and sanitation issues, including proper use of
sanitation facilities and proper handling and disposal of waste.
 Comply with provisions in the FMP.
DECOMMISSIONING PHASE
1. Occupational/public All decommissioning activities The contractor will be required to ensure that: Contractor/ No additional cost
safety and traffic  personal protective gear are provided to workers involved with decommissioning Engineering Consultant required aside
of facilities.
impacts BoQ
 toilet facilities are available throughout the decommissioning period.
 workers still have access to public toilet facilities in the communities or can be
conveyed to such facilities where needed, if mobile toilet facilities have been
relocated.
 final movement of vehicles and equipment comply with approved speed limits

May 2017
Social Impacts
within the communities.
 all community complaints are resolved before handing over sanitation project.
2. Waste management All decommissioning activities  Ensure that any remaining waste streams created during construction activities and Contractor/ No additional cost
waste generated during decommissioning activities are collected from the project Engineering Consultant required aside
sites properly disposed before handing over the project. BoQ
 Inspect the site to ensure that the contractor has properly cleaned up all
construction sites before final payment is made to the contractor.
3. Site Restoration All decommissioning activities  Re-vegetate areas around construction sites to restore the landscape Contractor/ No additional cost
 Reinstate any damaged property such as pavements, etc. Engineering Consultant required aside
BoQ
Sub-Total: 9,000 (per school
per year)
Grand Total: 270,000 per year
for AMA

May 2017
7.2 Mitigation/Action Plan for Identified Risks to the Sustainability of the Project
Table 11: Mitigation /Action Plan for Identified Risks to the Sustainability of the Project
No. Risk Proposed Mitigation Measures/Actions Implementation Phase Responsibility Cost Estimates per
project site (Gh₵)
1. Flooding  Raise the foundation of toilet facilities to about 1 meter high, especially in  Construction Contractor/ Engineering -Already captured in
flood prone areas. Consultant BoQ / If not revise
 Provide adequate drainage around toilet facilities.  Construction BoQ accordingly
 Provide rain cover over all windows and doors of the toilet facilities.  Construction
 Beneficiary schools should ensure all broken louvre blades/or windows are  Operation -500.00 per school
replaced. per year
2. Security issues  Provide burglar proof at the doors and windows of toilet facilities.  Construction Contractor/ Engineering -Already captured in
 Maintain adequate security in the schools and at the sanitation facilities Consultant/ Metropolitan BoQ/ If not revise
especially. Eg: through hiring a watchman. Assembly/ Authorities of BoQ accordingly
 MA should consider fencing of schools in future projects to improve  Operation Beneficiary Institution -2,400.00 per
security. institution per year
 Sensitize wider communities not to disturb school sanitation facilities -
-
3. Unavailability of  Confirm the source and reliability of the water supply prior to the  Construction Contractor/ Engineering -Already captured in
water commencement of construction. Consultant BoQ/ If not revise
 Ensure that storage tanks are installed for all facilities to provide continuous  Construction BoQ accordingly
water supply even when GWCL lines are temporarily out of order.
 Ensure connection of water and installation of water storage tanks is
completed and there is regular flow of water at the toilet facilities before  Construction -
commissioning/handing over of the facilities for use.
4. Poor  The Engineering Consultant to include the relevant recommendations in the  Construction Contractor/ Engineering -Already captured in
maintenance ESMP in the Facilities Management Plan (FMP). Consultant/SHEP BoQ / If not revise
culture  Comply with provisions in the FMP such as: Coordinators/Heads of BoQ accordingly
o Replace damaged equipment/materials with durable ones during  Operational Institutions -Refer to FMP

May 2017
No. Risk Proposed Mitigation Measures/Actions Implementation Phase Responsibility Cost Estimates per
project site (Gh₵)
maintenance and repair works. Budget
o The beneficiary schools should hire cleaners for the sanitation facilities.  Operational
o Develop and implement a maintenance regime for the facilities.  Operational
o Report major breakdown of facilities to the Metropolitan GES Director.  Operational
o Educate and create awareness on proper use of facilities.  Operational
o Ensure all staff are trained in the effective use and management of the  Operational
facilities, in collaboration with the Environmental Health and Sanitation
Department.
5. Inadequate  School authorities and PTA to discuss funding for water supply, electricity  Operational MLGRD-PCU/ Metropolitan -
funds bills and maintenance of the facilities at PTA Meetings. Assembly/ Consultant/
 Capacity building of School authorities /PTA for raising, mobilization and  Operational Authorities of Beneficiary -Refer to Capacity
stewardship of fund Institution Building Budget
 MA level stakeholder engagements to discuss innovations in funding for  Operational -
O&M.
 The project should ensure that all outstanding electricity and water debts of  Operational -
beneficiary institutions are paid and electricity and water connection
restored to disconnected institutions.
 The beneficiary institutions should ensure regular payment of electricity  Operational -
and water bills to ensure continuous supply of water and electricity to the
facility.
6. Lack of  Stakeholders should be invited to attend monthly progress meetings to be  Operational Consultant -
awareness of the constantly informed.
project  Before the project resumes, information of the proposed project including  Operational
information its benefits should be explained to teachers, students and the PTA.
Sub-Total: 2,900 (per institution
per year)
Grand Total: 87,000 per year for
AMA

May 2017
7.3 Environmental And Social Monitoring Plan and Reporting
7.3.1 Environmental and Social Monitoring Plan
The environmental and social monitoring plan proposed for the Institutional Sanitation Project in AMA is presented in Table 12.
Table 12: Environmental and Social Monitoring Plan
No. Environmental/ Monitoring Parameters Monitoring Site Frequency Responsibility Cost Estimate/ Year
Social Component (Implementation/ (GH)
Supervision)
PREPARATORY PHASE
1. Approval for -Evidence of consultation and consent from school -Beneficiary institutions -Prior to -Contractor/ Engineering No additional cost
construction and authorities (including Church Leadership of Missionary construction Consultant required aside BoQ
siting of toilet Schools)
facility -Complaints on siting of facilities - Daily
-availability of alternative toilets for school/students
during construction
-Availability of toilet facilities for use by construction
workers other than school toilet
CONSTRUCTION PHASE
1. Soil impacts and -Observable change in turbidity of water in drains -Construction site Daily Contractor/ Engineering No additional cost
sediment transport -Observable oil sheen in drains -Nearby drains Consultant required aside BoQ
-Observation of rills/gullies
2. Air quality - Observation of air borne particulates (dust) and exhaust -Construction site Daily Contractor/ Engineering No additional cost
deterioration fumes -Immediate environs Consultant required aside BoQ
3
- dust concentration should be below 150 µg/m
-Records of dampening of construction sites and routes for
vehicles/trucks
3. Vibration and noise -Complaints on noise nuisance Construction site Daily Contractor/ Engineering No additional cost

May 2017
Supervision)
nuisance -Immediate environs Consultant required aside BoQ
4. Visual Intrusion -Hoarding in place Construction site Daily Contractor /Engineering No additional cost
-Condition of areas around construction site -Immediate environs consultant required aside BoQ
5. Destruction of -Evidence of consultations with affected property owners -Construction site Daily Contractor /Engineering No additional cost
property and -Record of affected service line/property and action taken -immediate environs consultant6 required aside BoQ
-Complains on affected property and obstruction of
obstruction of
walkways
walkways
Reinstatement of damaged property and landscape
6. Waste -Availability and use of bins Construction site Monthly Contractor/ Engineering No additional cost
Management -Records on frequency and location of waste disposal site Consultant required aside BoQ
of domestic and construction waste
7. Occupational -Workers’ awareness of Contractor’s health and safety Construction site Daily Contractor/ Engineering No additional cost
Health & Safety policy (The contractor health and safety policy would take Consultant required aside BoQ
into consideration the World Bank EHS guidelines)
-Availability and proper use of PPEs

-Availability and proper use of warning signs
-Availability of first aid kit
-Adherence to health and safety procedures
-Records on frequency, type and source of
-Records on non-compliances
-Absence of unauthorized persons at active construction
sites
8. Public safety and Availability and proper use of warning signs Construction Site Daily Contractor/Engineering No additional cost
traffic issues -Hoarding of site consultant required aside BoQ
-Use of caution tape around trenches/ excavations

May 2017
Supervision)
-Records on frequency, type and source of
-Absence of unauthorized persons at active construction
sites
9. Sanitation issues, -Availability and use of bins Construction site Daily Contractor/ Engineering No additional cost
health and safety -Records on frequency and location of waste disposal site Consultant required aside BoQ
impacts of domestic and construction waste
-Mobile toilet facilities in place for use by contarctor
-Presence of stagnant water in trenches
10. Public Complaints/ -Type and nature of complaints and concerns; Project community Weekly Grievance Redress Refer to Grievance
Grievances Redress -Complaint records (Record of grievance and number Committee Redress Budget in
resolved/unresolved) Table 14
-Management and Stakeholder Meetings
OPERATIONAL PHASE
1. Nuisance from -Smell of pungent odour Beneficiary school Daily School Authorities/SHEP 1500.00
odour -Immediate environs Coordinator
2. Waste -Waste disposal records Beneficiary Institution -Daily SHEP Coordinator/ School 800.00
Management -Availability of bins Heads
-Litter around waste bin
-Records of inspection and dislodging of septic tanks
3. Sanitation, hygiene, -Cleaning roster -Toilet facility -Daily SHEP Coordinator/ School 500.00
health and safety -Clean environment -Waste storage and -Week Heads
-Smell of pungent odour collection sheds
-Availability of disinfectants
-Availability of cleaning PPEs and tools/materials
-Availability of functional hand wash facility
-Payment of utility bills

May 2017
Supervision)
-Records on accidents/injury
4. Complaints/ -Type and nature of complaints and concerns; Beneficiary institution -Weekly Grievance Redress 1000.00
Grievances -Complaint records (Record of grievance and number Committee
resolved/unresolved)
Sustainability of the institutional facilities
1. Flooding - Extent of flooding during rains Toilet facility During rains School Authorities / PTA/ 700.00
- Drains clear of silt Metropolitan Assembly
- Record of state of Rain covers Monthly

- Record of state of louvre blades
2. Security issues - Security measures (locks, burglar proof) functional Toilet facility Daily School Authorities/ PTA/ 1500.00
- Watchman hired Metropolitan Assembly
3. Unavailability of - Confirmation of availability of water supply from GWCL Toilet facility Prior to School Authorities/ PTA/ 1000.00
water - Storage tanks installed and all connections and commissioning of Metropolitan Assembly
plumbing functional project/

- Leaks from plumbing Weekly
4. Funding - Receipts of payment of bills Beneficiary institution Monthly MLGRD-PCU/ Metropolitan 1500.00
- Programme for fund raising Assembly/ Consultant/
School Authorities /PTA
- Audited accounts
5. Poor maintenance - Record of training and awareness creation on Facilities -Beneficiary institution Monthly School Authorities / SHEP 1200.00
culture Management Plan (FMP) Coordinators/ PTA/
Metropolitan Assembly
- Record of compliance with FMP.
- Records on major breakdowns including leakages
- Availability of school hygiene clubs
6. Lack of awareness - Monthly progress carried out -Beneficiary institution Monthly SMC/ PTA/ Metropolitan -
of the project - Information provided to teachers, students & PTA. SHEP Committee
information
DECOMMISSIONING

May 2017
Supervision)
1. Occupational/publi - Availability and proper use of PPEs -Beneficiary institution -Daily Contractor/WasteCare 500.00
c safety and traffic
- Adherence to health and safety procedures Associates/ AMA
- Records on frequency, type and source of
2. Waste disposal - Availability and use of bins -Beneficiary institution Daily Contractor/ WasteCare 500.00
- Records on frequency and location of waste disposal site Associates/ AMA
of domestic and construction waste
TOTAL: 11,700.00

May 2017
7.3.2 Environmental and Social Monitoring Reporting

Environmental monitoring is an essential component to ensure the successful implementation of the
ESMP. A report on the monitoring programme will provide the contractor and AMA with relevant
data and information to better understand the extent of implementation of the ESMP. All monthly
and progress reports should capture health, safety and environment issues arising from the
implementation of the ESMP. A template for reporting on the implementation of the ESMP is
provided in Annex 3.
The format requires the implementing body to specify evidence of completion for each mitigation
measure (e.g. a document that proves the completion of the measure or a short description of the
expected achievement or pictures). If implementation is ongoing, the status of implementation
should be described. The monitoring report concludes by summarising the main findings and by
indicating the overall status of ESMP implementation using a three-point ranking scale: on track
(green), slightly delayed (yellow) or delayed (red). Opportunity is provided for indicating any
additional environmental or social risks that may have emerged since the project start and the
appropriate mitigation measures taken or planned for any significant new risk.
7.4 Grievance Redress Process
7.4.1 Background
A grievance is any query, call for clarification, problems and concerns raised by individuals or groups
related to activities undertaken or processes applied by the project. Grievances can be an indication
of growing stakeholder concerns and can escalate if not identified and resolved. A Grievance Redress
Mechanism (GRM) is a system by which queries or clarifications about a project are responded to,
problems that arise out of implementation are resolved and grievances are addressed efficiently and
effectively. An effective and efficient GRM should have multiple avenues or channels for lodging
complaints, transparency, promptness and timeliness of responses and clear procedures.
During the planning of the planning stages of the projects in each school, the school authorities, PTA
and the SHEP Coordinators were consulted by the AMA Management, AMA GAMA Project Team and
the Engineering Consultant for AMA (WasteCare Associates). The consultation helped to identify the
plot boundaries of the institutions, the appropriate toilet types for the institutions and the location
of toilets.
Since the entire project implementation programme was carried out with consultation and
participation of the beneficiary institutions and AMA, many grievances are not anticipated to arise
from the project implementation and any unforeseen grievances may be resolved amicably and
easily. Nevertheless, appropriate channels have been provided for expression and resolution of
grievances during the implementation and operation of the project.
7.4.2 Objectives of the Grievance Redress Mechanism
The objectives of the grievance redress mechanism are as follows:

1. To provide affected people and institutions with channels to lodge complaints or resolve any
disputes that may crop up during project implementation;

May 2017
2. Provide a mechanism for stakeholder concerns to be addressed in a mutually acceptable and

timely manner, and by the most appropriate officers;
3. Identify and monitor stakeholder concerns to support effective stakeholder and risk
management;
4. Enhance the reputation of the project implementers as transparent and environmentally
and socially responsible; and,
5. Meet requirements of international best practice.
7.4.3 Grievance Redress Process
The grievance redress process has been discussed below under the construction and operational
phases of the proposed project. Any grievance received from affected stakeholders shall be treated
confidentially and resolved in a transparent and fair manner.
Construction Phase Grievance Redress

Grievance registration
The School based Health Coordinator/SHEP Coordinator of each beneficiary school will be officially
responsible for receiving grievances which may be channeled to them directly through face-to-face
communication, phone calls, letters, e-mail, text messages, etc. Complaints received shall be
forwarded to the grievance redress committee. The members of the committee shall be the Head
Teacher, the School Management Committee and the SHEP Coordinator, who will be secretary to
the grievance redress committee.
All grievances, presented in writing or verbally, will be logged by the Head Teacher by filling a
grievance redress form. The SHEP Coordinator will ensure that each complaint has an individual
reference number, and is appropriately tracked and recorded actions are completed. A sample of a
Grievance Mechanism Form is included in Annex 4. Grievances may also be channeled to the GAMA
Project Coordinator at AMA.
The SHEP Coordinator shall have a log book for keeping records of all grievances received and copies
of the records kept with all the relevant authorities. A review of grievances will be conducted at least
every three months during implementation in order to detect and correct systemic problems.
The log book should take into account the following: date the complaint was reported; date on
which the grievance form was submitted to the grievance committee, date information on proposed
corrective action sent to complainant (if appropriate); the date the complaint was closed out and
date response was sent to complainant.
Redress decision, feedback and implementation

The redress committee will make a decision on all matters received, in consultation with the
complainant, if necessary, in not more than two working days. The agreed redress action should be
implemented within an agreed timeframe of not more than five days, depending on the nature of
the complaint.
If field verification is required, the redress committee, in company with the complainant, will visit
the complaint area to verify satisfactory redress action is carried out. When the complainant is

May 2017
satisfied with the redress action, the complaint will be closed and logged in the grievance log book
and endorsed by the complainant.
Dissatisfaction and alternative action

1. If no understanding or amicable solution is reached, or the affected person does not receive a
response from the redress committee within 5 working days, the affected person can appeal to
the GAMA Project Coordinator, who shall seek to resolve the issue in collaboration with the
Project’s Engineering Consultant and the AMA Works Engineer. It is expected that the
complaint/grievance will be resolved within 5 working days of its filing.
2. If the grievance remains unresolved, the affected person can appeal to the Safeguards Specialist
at the PCU, who in consultation with the GAMA Project Director at the MLGRD, GAMA Project
Coordinator at the PCU and the Chief Director will mediate on the issue within five working days.
3. If a resolution is not reached from the first three steps, the complainant may seek legal action
for redress. However, noting that court cases can be cumbersome and time consuming, it is of
high opinion that Court cases should be the last ‘resort’ and all effort must be made to reach
amicable settlement at the very early stages of complaints by affected persons.
Monitoring and Evaluation

Monitoring and evaluation activities will be conducted by the PCU to ensure complaint and
grievances lodged by the affected persons are followed-up and amicably resolved.
The grievance redress process for the construction phase is illustrated in Figure 5.

May 2017
TIER 1
Grievance received and screened by

SHEP Coordinator
Redress Committee of
meet and take decision
2 wkn TIER 2
days
Complainant not
Feedback to satisfied (Grievance
complainant unresolved
Complainant satisfied Grievance sent to GAMA

with decision Project Coordinator, Project’s
(Grievance resolved) Engineering Consultant and
AMA Works Engineer
5 wkn days
TIER 3
Decision taken
through discussion Complainant not
with beneficiary satisfied (Grievance
institution and unresolved
Complainant
Complainant Grievance sent to Safeguard

satisfied (Grievance Specialist PCU, the GAMA
resolved) Project Director at the
MLGRD, GAMA Project
Coordinator at the PCU and
the Chief Director
5 wkn days TIER 4
Decision taken Complainant not

through discussion satisfied (Grievance
with all parties unresolved
Complainant
Complainant takes
satisfied (Grievance
legal action
resolved)
Law Court Rules
Figure 5: Grievance Redress Process for the Constructional Phase Institutional Sanitation Facilities Project

May 2017
Operational Phase Grievance Redress

The School based Health Coordinator/SHEP Coordinator of each beneficiary school will be officially
responsible for receiving grievances which may be channeled to them directly through face-to-face
communication, phone calls, letters, e-mail, text messages, etc. Complaints received shall be
forwarded to the School Management Committee (SMC) for redress.
All grievances, presented in writing or verbally, will be logged by the SHEP Coordinator by filling a
grievance redress form. The SHEP Coordinator will ensure that each complaint has an individual
reference number, and is appropriately tracked and recorded actions are completed. A sample of a
grievance mechanism form is included in Annex 4.
The SHEP Coordinator shall have a log book for keeping records of all grievances received and copies
of the records kept with all the relevant authorities. A review of grievances will be conducted at least
every three months during implementation in order to detect and correct systemic problems. The
log book should take into account the following: date the complaint was reported; date on which the
grievance form was submitted to the grievance committee, date information on proposed corrective
action sent to complainant (if appropriate); the date the complaint was closed out and date
response was sent to complainant.
Redress decision, feedback and implementation
The SMC will make a decision on all matters received, in consultation with the complainant, if
necessary, in not more than two working days. The agreed redress action should be implemented
within an agreed timeframe of not more than five days, depending on the nature of the complaint.
If field verification is required, the redress committee, in company with the complainant, will visit
the complaint area to verify satisfactory redress action is carried out. When the complainant is
satisfied with the redress action, the complaint will be closed and logged in the grievance log book
and endorsed by the complainant.
Dissatisfaction and alternative action
1. If no understanding or amicable solution is reached, or the affected person does not receive a
response from the redress committee within 5 working days, the affected person may appeal to
the Metropolitan SHEP Committee, through the Metropolitan SHEP Coordinator, who should act
on the complaint/grievance within 5 working days of its filing. Grievances from the school
stakeholders, where necessary, will be resolved in collaboration with the beneficiary institution
and the complainant. Grievances involving the community members will be resolved in
consultation with the community leadership and complainant, as necessary.
2. If the grievance remains unresolved, the affected person can appeal to the Regional SHEP
Coordinator at the Ministry of Education who, in consultation with the Metropolitan SHEP
Committee will mediate on the issue.
3. If a resolution is not reached from the first three steps, the complainant may seek legal action
for redress. However, noting that court cases can be cumbersome and time consuming, it is of
high opinion that Court cases should be the last ‘resort’ and all effort must be made to reach
amicable settlement at the very early stages of complaints by affected persons
Monitoring and Evaluation
Monitoring and evaluation activities will be conducted by the PCU to ensure complaint and
grievances lodged by the affected persons are followed-up and amicably resolved.
The grievance redress process for the operational phase is illustrated in Figure 6.

May 2017
TIER 1
Grievance received and screened by

SHEP Coordinator
School Management
Committee meet and
take decision
TIER 2
2 wkn days
Complainant not
Feedback to satisfied (Grievance
complainant unresolved
Complainant satisfied Grievance sent to Metropolitan

with decision Assembly/GES (Metropolitan
(Grievance resolved) Committee/ Municipal SHEP
Coordinator to receive)
5 wkn days
TIER 3
Decision taken through
discussion with Complainant not
beneficiary institution/ satisfied (Grievance
community leadership unresolved
and Complainant
Complainant Grievance sent to

satisfied (Grievance Regional SHEP
resolved) Coordinator at GES
- TIER 4
Decision taken Complainant not

through discussion satisfied (Grievance
with all parties unresolved
Complainant
Complainant takes
satisfied (Grievance
legal action
resolved)
Law Court Rules
Figure 6: Grievance Redress Process for Operational Phase for the Institutional Sanitation Facilities Project

May 2017
7.5 Capacity Building and other Requirements for Implementation of ESMP and Permit
Conditions
Training Workshop will be organized to guide the implementation of the ESMP, Permit Schedule,
Triggered World Bank Safeguards Policy and environmental management. The training on the ESMP
implementations will include the Code of Conduct for contractor and his/her labour force, public
health and safety issues, Grievance Redress Mechanism for the project, ESMP monitoring and
reporting.
7.5.1 Objectives of the training

The main objective of the capacity building and training activities is to create, enhance and develop
the necessary skills and abilities for successful implementation of the proposed project.
7.5.2 Methodology for the training

The methodology to implement the training will include:
 Workshops and site meetings;
 Sensitization for students during School Assembly, Morning Devotion or in the classrooms;
 Sensitization at PTA meetings.
It is recommended that the site meetings discuss the ESMP issues and any health and safety issues
identified in the course of the month. Non-compliances identified during monitoring should
reviewed and corrective actions taken. A capacity building measure proposed to achieve this is
provided in Table 13.
Table 13: Capacity building plan for implementation of ESMP and Permit Conditions
No. Activity Target Timeline/Duration Proposed Facilitator Estimated

Group/Participants Cost/(Gh₵)
1. Training Engineering Prior to Consultant/Metropolitan 15,000.00
Workshop on Consultant resumption/ Assembly/ Safeguards
ESMP, Permit -Resident Engineer commencement of Specialist/ Consultant
Schedule, -Clerk of Works construction works
Triggered World
-Safeguards Officer
Bank Safeguards
Policy Contractor
-Manager
-Foreman
-Engineer
AMA
-Project Coordinator
Metro Engineer
-Metro
Environmental Health
Officer
Metro SHEP
Coordinator

May 2017
No. Activity Target Timeline/Duration Proposed Facilitator Estimated

Group/Participants Cost/(Gh₵)
2. Induction on All construction workers Prior to Consultant/Lead 10,000.00
occupational and commencement of Contractor/ Engineering
public health and construction works Consultant
safety requirements
of the works and
environmental
management
3. Training for use and -SHEP Coordinators Prior to -Engineering Consultant 10,000.00
management of -Teachers commissioning and -GAMA Coordinator
facilities -SMC handing over of -Metropolitan SHEP
-School Health Club facilities to schools Committee & Coordinator
-school children
4. Sensitization and -Students Throughout -SHEP Coordinators As part of

awareness creation operation of facilities -School Health Club duties of
on use and SHEP
management of Coordinators,
facilities (interactive School and
activity, teaching, School Health
demonstrative Club.
activity for building
habits & knowledge
testing during
classes, worship
time and assembly)
35,000.00
TOTAL COST
7.5.1 Output of the training
Capacity building on the health, safety, environmental and social management measures provided in
this chapter is required to ensure the effective implementation of the ESMP and the permit
conditions. All monthly and progress reports should capture health, safety and environment capacity
building activities carried out.
7.6 Estimated Budget for ESMP Implementation.
It is estimated that an amount of Four Hundred and Eight Thousand, Seven Hundred Ghana Cedis
(GH¢408,700.00) will be required to implement the provisions of the ESMP for all the beneficiary
institutions in AMA as shown in Table 14. This figure is subject to review following confirmation
from cost studies to be carried out after project development phase.

May 2017
The budget for the monitoring activities by the MLGRD-PCU are not captured in the monitoring costs
presented in the Environmental and Social Monitoring Plan and reporting. This is because, the
monitoring roles of the PCU is already included in the GAMA Project cost.
Table 14: ESMP Budget.

No. Programme Cost/year (GH)
1. Mitigation Action for Identified Impacts (Table 10): Operation phase only {GH¢ 9000 270,000.00
per institution/yr} there are 30 schools.
2. Mitigation Action for Identified Risks To The Sustainability of the Project (Table 11) 87,000.00
3. Environmental And Social Monitoring Plan (Table 12) 11,700.00
4. Grievance Redress 5,000.00
5. Capacity Building (Table 13) 35,000.00
Total 408,700.00

May 2017
8.0 CONCLUSION
AMA and the Project Coordinating Unit of MLGRD are committed to ensuring sustainable
environmental management and safeguarding the health and safety of the construction workers,
pupils/teachers at the beneficiary schools and the public during the implementation of the proposed
project. AMA is also aware of the provisions in the Environmental Assessment Regulations 1999, LI
1652 and the World Bank Operational Policies. In keeping with these laws, this ESMP has identified
and assessed key environmental and social impacts and concerns that may arise from the
implementation of the proposed project.
Consultations with stakeholders, review of relevant literature, field inspections and studies
underpinned the identification of the project adverse environmental and social impacts. A
monitoring programme to help detect changes arising from the predicted adverse impacts has also
been presented in this ESMP. The recommendations outlined in the ESMP for the project will ensure
a high level of health, safety and environmental management for the proposed project.
It is estimated that an amount of Four Hundred and Eight Thousand, Seven Hundred Ghana Cedis
(GH¢408,700.00) will be required to implement the provisions of the ESMP for all the beneficiary
institutions in AMA as shown in Table 14. This figure is subject to review following confirmation
from cost studies to be carried out after project development phase. The budget for the monitoring
activities by the MLGRD-PCU are not captured in the monitoring costs presented in the
Environmental and Social Monitoring Plan and reporting. This is because, the monitoring roles of the
PCU is already included in the GAMA Project cost.
The proposed project has the potential to provide numerous benefits to the beneficiary schools and
the national economy. These include improved sanitation, hygiene and waste management in the
beneficiary schools, improved access to sanitation facilities for vulnerable groups and employment
opportunities.

May 2017
9.0 BIBLIOGRAPHY
Ghana Statistical Service (2014) 2010 National Population & Housing Census. District Analytical Report.
Accra Metropolis.
WasteCare Associates (2016a). Situational Analysis and WASH in Schools. Accra Metropolitan
Assembly.
WasteCare Associates (2016). Facility Operation and Maintenance Handbook. Accra Metropolitan
Assembly.
WasteCare Associates (2016). Final Detailed Design Report. Accra Metropolitan Assembly.
WasteCare Associates (2016). Hygiene Education Plan. Accra Metropolitan Assembly.

May 2017
ANNEXES
Annex 1 Stakeholder Consultations

Annex 2 Code of Conduct
Annex 3 Template for reporting on the implementation of the ESMP
Annex 4 Grievance Form
Annex 5 Letter from AMA instructing the removal of furnace/incinerator

May 2017
ANNEX 1 STAKEHOLDER CONSULTATIONS

May 2017
ANNEX 2 CODE OF CONDUCT

May 2017
ANNEX 3 TEMPLATE FOR REPORTING ON THE IMPLEMENTATION OF THE ESMP

May 2017
ANNEX 4 GRIEVANCE FORM

May 2017

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MINISTRY OF LOCAL GOVERNMENT AND RURAL DEVELOPMENT

ACCRA METROPOLITAN ASSEMBLY

ENVIRONMENTAL AND SOCIAL

ESMP PROJECT TEAM.................................................................................. ERROR! BOOKMARK NOT DEFINED.

TABLE OF CONTENT ..........................................................................................................................................I

LIST OF TABLES ...............................................................................................................................................III

ACRONYMS AND ABBREVIATIONS .................................................................................................................. V

EXECUTIVE SUMMARY ................................................................................................................................... VI

1.0 INTRODUCTION ................................................................................................................................... 1

1.1 BACKGROUND ........................................................................................................................................... 1

2.0 DESCRIPTION OF THE PROPOSED PROJECT .......................................................................................... 6

2.1 NEED FOR THE PROJECT ............................................................................................................................... 6

3.0 RELEVANT POLICIES, LEGAL AND ADMINISTRATIVE FRAMEWORKS .................................................. 22

3.1 POLICY FRAMEWORK ................................................................................................................................ 22

4.0 BASELINE ENVIRONMENTAL AND SOCIAL CONDITIONS .................................................................... 30

4.1 LOCATION AND SIZE .................................................................................................................................. 30

Final ESMP _Construction of Institutional Sanitation Facilities. Page i

4.2.2 Vegetation ...................................................................................................................................... 32

5.0 STAKEHOLDER CONSULTATIONS ....................................................................................................... 39

5.1 OBJECTIVES OF CONSULTATION ................................................................................................................... 39

6.0 DESCRIPTION OF ENVIRONMENTAL AND SOCIAL IMPACTS ............................................................... 53

6.1 PROJECT AREA OF INFLUENCE ..................................................................................................................... 53

7.0 ENVIRONMENTAL AND SOCIAL MITIGATION AND MANAGEMENT PLAN .......................................... 63

7.1 MITIGATION/ACTION PLAN........................................................................................................................ 63

Final ESMP _Construction of Institutional Sanitation Facilities. Page ii

7.4.3 Grievance Redress Process .............................................................................................................. 78

8.0 CONCLUSION ..................................................................................................................................... 86

9.0 BIBLIOGRAPHY .................................................................................................................................. 87

ANNEX 1 STAKEHOLDER CONSULTATIONS ............................................................................................... 89

ANNEX 2 CODE OF CONDUCT .................................................................................................................. 90

ANNEX 3 TEMPLATE FOR REPORTING ON THE IMPLEMENTATION OF THE ESMP ..................................... 91

ANNEX 4 GRIEVANCE FORM..................................................................................................................... 92

TABLE 1: DETAILS OF BENEFICIARY SCHOOLS IN AMA ........................................................................................................ 7

Final ESMP _Construction of Institutional Sanitation Facilities. Page iii

PLATE 1: SITE INSPECTION AT ABOSSEY OKAI 1&2 BASIC SCHOOL......................................................................................... 3

Final ESMP _Construction of Institutional Sanitation Facilities. Page iv

ACRONYMS AND ABBREVIATIONS

AMA Accra Metropolitan Assembly

Final ESMP _Construction of Institutional Sanitation Facilities. Page v

Final ESMP _Construction of Institutional Sanitation Facilities. Page vi

The following school children were consulted:

Significant Environmental and Social Impacts

Final ESMP _Construction of Institutional Sanitation Facilities. Page vii

Mitigation and Monitoring Plan

Final ESMP _Construction of Institutional Sanitation Facilities. Page viii

Mitigation and monitoring actions for potential significant adverse impact

No. Environmental/ Social Monitoring Parameters Monitoring Frequency Responsibility

Final ESMP _Construction of Institutional Sanitation Facilities. Page ix

No. Environmental/ Social Monitoring Parameters Monitoring Frequency Responsibility

Final ESMP _Construction of Institutional Sanitation Facilities. Page x

No. Environmental/ Social Monitoring Parameters Monitoring Frequency Responsibility

Final ESMP _Construction of Institutional Sanitation Facilities. Page xi

No. Environmental/ Social Monitoring Parameters Monitoring Frequency Responsibility

Final ESMP _Construction of Institutional Sanitation Facilities. Page xii

No. Environmental/ Social Monitoring Parameters Monitoring Frequency Responsibility

Final ESMP _Construction of Institutional Sanitation Facilities. Page xiii

No. Environmental/ Social Monitoring Parameters Monitoring Frequency Responsibility

Final ESMP _Construction of Institutional Sanitation Facilities. Page xiv

No. Environmental/ Social Monitoring Parameters Monitoring Frequency Responsibility

Final ESMP _Construction of Institutional Sanitation Facilities. Page xv

No. Environmental/ Social Monitoring Parameters Monitoring Frequency Responsibility

Final ESMP _Construction of Institutional Sanitation Facilities. Page xvi