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Annex 9 to Maharashtra Tertiary Care and Medical Education Sector Development Program
(RRP IND 56343-001)
Environmental Assessment and Review Framework
Document Stage: Draft for consultation

Project Number: 56343 - 001
September 2023
India: Maharashtra Tertiary Care and Medical Education

Sector Development Program
Prepared by: Medical Education and Drugs Department, Government of Maharashtra for the
Asian Development Bank.
This Environmental Assessment and Review Framework is a document of the borrower. The
views expressed herein do not necessarily represent those of ADB's Board of Directors,
Management, or staff, and may be preliminary in nature. Your attention is directed to the “terms
of use” section on ADB’s website.
In preparing any country program or strategy, financing any project, or by making any designation
of or reference to a particular territory or geographic area in this document, the Asian
Development Bank does not intend to make any judgments as to the legal or other status of any
territory or area.
ABBREVIATIONS
ADB Asian Development Bank

ASI Archaeological Survey of India
BMW bio-medical waste
BMWM bio-medical waste management
BUA built-up area
CBWTDF waste treatment and disposal facility
CPCB Central Pollution Control Board
CRZ coastal regulation zone
CTE consent to establish
CTO consent to operate
DG diesel generator
EA executing agency
EARF Environmental Assessment and Review Framework
EC environmental clearance
EIA Environmental Impact Assessment
EMoP Environmental Monitoring Program
EMP Environment Management Plan
ESZs eco-sensitive zones
GMC government medical college
HCF health care facility
IA implementing agency
IEE Initial Environmental Examination
IP indigenous peoples
IR involuntary resettlement
MEDD Medical Education and Drugs Department
MoEFCC Ministry of Environment, Forest, and Climate Change
NoC No Objection Certificate
PUC Pollution under Control Certificate
REA Rapid Environmental Assessment
SDP sector development program
SPCB State Pollution Control Board
Notes
(i) The fiscal year (FY) of the Government of India ends on 31 March. “FY” before a calendar
year denotes the year in which the fiscal year ends, e.g., FY2023 ends on 31 March 2023.
(ii) In this report, "$" refers to United States dollars.

CONTENTS
I. INTRODUCTION 1
A. Overview 1
B. Program Components 2
C. Purpose of the EARF 3
II. ASSESSMENT OF REGULATORY FRAMEWORK 4
A. National Regulatory Framework 4
B. International Environmental Agreements 13
C. ADB Environmental Safeguards 16
D. Compatibility between Country’s and ADB Safeguard Policy 19
III. ANTICIPATED ENVIRONMENTAL IMPACTS 24
A. Preconstruction Phase 24
B. Construction Phase 25
C. Operation Phase 28
IV. PROCESS TO BE FOLLOWED (ENVIRONMENTAL ASSESSMENT) FOR
SUBPROJECTS 30
A. Environment Category 30
B. Environmental Guidelines and Criteria for Subproject Selection 30
C. Screening and Categorization 32
D. Preparation of Environmental Assessments Reports 32
E. Environmental Management Plan 33
F. Review of Environmental Assessment Reports and EMPs 33
V. CONSULTATION, INFORMATION DISCLOSURE 34
VI. GRIEVANCE REDRESSAL MECHANISM 40
VII. INSTITUTIONAL ARRANGEMENT AND RESPONSIBILITIES 47
VIII. MONITORING AND REPORTING 54
APPENDIXES
1. ADB Prohibited Investment Activities List 60

2. Safeguards requirements 1: Environment 61
3. Rapid Environmental Assessment Checklist 75
4. Checklist for Conducting Audit/Assessment of Existing Facility (indicative and will be
revised as per site conditions, if required) 85
5. Generic Environment Management Plan 88
(Indicative and sub project specific EMPs will incorporate the details of various
provisions mentioned in the generic EMP) 88
6. Format for Semi Annual Monitoring Report 119
List of Figures
Figure 1: Stakeholder Influence-Interest Analysis Matrix ...........................................................36
Figure 2: Grievance Redress Mechanism .................................................................................42
Figure 3: Institutional Arrangement for Environmental Safeguard Implementation ....................49
List of Tables
Table 1: Indicative Financing Plan............................................................................................. 2

Table 2: National Laws, regulations, and policies relevant under the Program ........................... 4
Table 3: International treaties, conventions and declarations for nature conservation ...............13
Table 4: International treaties, conventions and declarations for management of hazardous
material .....................................................................................................................................14
Table 5: International treaties, conventions and declarations for atmospheric emissions ..........15
Table 6: International treaties, conventions and declarations for marine environment ...............15
Table 7: International treaties, convention for labour health and safety .....................................16
Table 8: Comparative analysis of ADB SPS and Regulatory Framework of Government of India
.................................................................................................................................................20
Table 9: Types of Biomedical Waste envisaged due to the proposed project ............................28
Table 10: Proposed Public Consultation Activities....................................................................35
Table 11: Potential Stakeholders with influence-interest matrix .................................................37
Table 12: Structure and functions of GRCs (Proposed).............................................................42
Table 13: Indicative Implementation Arrangements ...................................................................47
Table 14: Indicative Responsibilities - Environmental Safeguard Implementation .....................51
Table 15: Environmental Monitoring Plan ..................................................................................54
Table 16: Budget for EARF Implementation ..............................................................................58
I. INTRODUCTION
A. Overview
1. The proposed Maharashtra Tertiary Care and Medical Education Sector Development
Program aims to support the state Maharashtra in a holistic development of tertiary care and
medical education using the sector development program (SDP) modality. Under the program,
the policy actions will create a robust framework for enabling existing and new medical colleges
and hospitals to attract and retain well-trained doctors and allied health staff, as well as provide
quality health care services. These policy actions will enhance the value from new medical
colleges and hospitals by improving quality, availability of medicines, and human resources. On
the other hand, under the investment component, four medical colleges and tertiary hospitals in
underserved districts shall be constructed. Underserved districts include Ambernath, Amravati,
Osmanabad, Palghar, Raigarh, Ratnagiri, and Sindhudurg in the state of Maharashtra, which do
not have state Government Medical Colleges (GMCs) or other funding opportunities for new
GMCs.
2. The program will be aligned with the following impact: modern medical service to all strata
of citizens of the state provided1. The outcome will be access to improved quality and affordable
tertiary health care and medical education in the state of Maharashtra. The program will facilitate
the achievement of above outcome through following three outputs, which will be supported by
the policy and investment components.
3. Output 1: Medical education and tertiary care facilities and systems enhanced. The
program will help the state transform the quality of and access to tertiary health care and medical
education. Policy actions under this output will include (i) introducing performance-based
incentives to GMC staff from health insurance payments to encourage them to prioritize poor
patients covered by insurance schemes; (ii) operationalizing a policy for climate-resilient asset
planning, management, and sustainability for medical colleges and tertiary hospitals to improve
quality, sustainability, climate and disaster resilience, and accountability; and (iii) establishing a
robust, digitally enabled performance management system to improve the quality of health
delivery and medical education covering all medical colleges. In addition, the program will build
new tertiary health care hospitals or upgrade district hospitals to teaching hospitals in underserved
districts2, incorporating climate and disaster resilience and gender equality and social inclusion.
It will also increase the number of beds to treat patients in government tertiary care hospitals, as
well as improve the capacity of staff and introduce protocols for providing appropriate treatment.
4. Output 2: Availability of quality and gender-equitable medical human resources

increased. To improve the availability of health human resources, especially doctors in rural
areas, the program will support the state in taking policy actions on a comprehensive new “hire to
retire” talent management policy, including improved recruitment rules and recruitment through a
dedicated unit at the state Public Service Commission. The program component will support (i)
building new medical colleges to increase the supply of doctors in the state, especially in
underserved districts; and (iii) medical education reform by engaging with the National Medical
Commission on assessing, updating, and revising the curriculum (by including the latest
developments in digital health and climate change) and pedagogic practices.3
1 Government of Maharashtra, Department of Medical Education and Medicines. Objectives and Goals.
2 Underserved districts: Ambernath, Amravati, Osmanabad, Palghar, Raigarh, Ratnagiri, and Sindhudurg in the state
of Maharashtra.
3 The pandemic necessitated review of the curriculum, which the project will support. Medical Council of India. 2018.
Revised curriculum. New Delhi.

2
5. Output 3: State system to deliver quality and affordable tertiary care and medical
education strengthened. This output will help improve the state’s capacity to deliver quality and
affordable tertiary health care and medical education. The policy actions will include (i) setting up
a dedicated agency for the procurement of medicines and equipment to support timely availability
of quality drugs; (ii) establishing India's first state-led quality health care and medical education
network of Centre of Excellences under the Maharashtra University of Health Sciences as a not-
for-profit company networked with other institutes; and (iii) implementing a comprehensive digital
health policy, integrating fragmented systems and linking with the national digital health system.
The Centre of Excellence will institutionalize the quality of health in medical colleges (linking with
national quality standards), develop and implement a learning agenda for gender-responsive and
socially inclusive medical education and tertiary care, develop enabling conditions for leveraging
the private sector, and identify research priorities and conduct research based on state needs.
6. ADB’s value addition and strategic alignment. Since 2013, ADB has supported the
Government of India in urban primary health care; the proposed SDP will deepen this engagement
by targeting medical education and tertiary and secondary care. The program—with a mix of
policy actions and construction of medical colleges and teaching hospitals—can be replicated in
other states, as India aims to expand access to medical education.4 ADB and government
identified seven policy actions based on the sector assessment, consultations, and policy
dialogues. These aim to (i) remove human resource bottlenecks and improve the availability of
quality drugs through reforms; (ii) expand access to secondary and tertiary care by the poor; and
(iii) ensure the sustainability of investments to achieve continual improvement. ADB is working
with the Medical Education and Drugs Department (MEDD) for private sector engagement by
outsourcing auxiliary services. The program will support digitalization for tertiary care and medical
education management by bringing together fragmented information technology systems. The
program is aligned with pillar 35 of ADB’s country partnership strategy for India, 2023–2027 and
Strategy 2030 operational priorities 1, 2, 3, and 6.6
B. Program Components
7. The program has two components (i) Investment Component ($ 500 million; accounting
77% share)7 and (ii) Policy Component ($ 150 million; accounting 23 % share). Of the $500 million
proposed ADB loan, $350 million will be for investment lending to build four Government Medical
Colleges (GMCs), including medical equipment. The remaining $150 million will be for policy-
based lending and will be disbursed after the state undertakes essential policy reforms. Climate
mitigation and adaptation costs will be about 14.5% of the program cost. The Indicative Financing
Plan is in Table 1.
Table 1: Indicative Financing Plan
4 Ministry of Health and Family Welfare. 2022. Health Ministry Reviews Progress of Centrally Sponsored Scheme to
Operationalize New Medical Colleges. New Delhi. Press Information Bureau.
5 ADB India country partnership strategy (2023-2027), Pillar 3: Deepen social and economic inclusiveness.
6 ADB. 2018. Strategy 2030: Achieving a Prosperous, Inclusive, Resilient and Sustainable Asia and the Pacific. Manila.
7 Including Government counterpart funds related to investment component.
3
Amount Share of
Source
($ million) Total (%)
Asian Development Bank 350.0 54.0
Ordinary capital resources (regular loan) for investment component
Ordinary capital resources (regular loan) for policy component 150.0 23.0
Government for investment component 150.0 23.0
Total 650.0 100.0
Note: Government counterpart funds are related only to the investment component.
8. The Executing Agency (EA) and Implementing Agency (IA) for this program will be Medical
Education and Drugs Department (MEDD), Government of Maharashtra.
9. The program is categorized as B for environment (C for both involuntary resettlement and
indigenous peoples). For the investment component, the subproject selection criteria will exclude
subprojects located within environmentally sensitive areas.8 The selection criteria and screening
process (pertaining to safeguards) for the program components are given in this EARF. Potential
environmental impacts and risks will be limited to the sub-project footprint area and to confirm for
any public or state-owned land, that no persons are living on or using the land informally; and that
there are no outstanding complaints with regards to the land. The construction of new medical
colleges will be on government land.
10. For the policy-based component, no environmental, IR and IP impacts are anticipated. In
case of any change in scope or identification of unanticipated impacts during implementation,
environmental due diligence will be done to ascertain the associated impacts and proposed
mitigations measures. This will also be ascertained while sub-projects specific IEE reports are be
undertaken. The REA Checklist for Governance and Finance and Environment and Social impact
assessment matrix for overall policy-based component is provided in Appendix 3.
C. Purpose of the EARF
11. In consideration of ADB’s Safeguard Policy Statement 2009 and national regulatory
framework for environmental safeguard, this environmental assessment and review framework
(EARF) document has been developed for Maharashtra Tertiary Care and Medical Education
Sector Development Program where under the investment component, development of four
medical colleges and tertiary hospitals are proposed. It is intended that the EARF will serve as
guide to the Executing Agency (EA) and Implementing Agency (IA) in selection, screening and
categorization, environmental assessment, and preparation and implementation of safeguard
plans (i.e., environmental management plan i.e EMP) for the proposed hospitals and medical
colleges in the state of Maharashtra.
8 Source: Concept Paper; Project Number: 56343-001, August 2023.

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II. ASSESSMENT OF REGULATORY FRAMEWORK
A. National Regulatory Framework
12. The Government of India have established regulations to manage the environmental
condition, biomedical waste and other waste, which will be directly relevant to sub-projects under
the Program. In addition, there are relevant legal provisions to ensure the pollution prevention,
protection of workers and labor and provisions to ensure adequate management of environmental
risks and impacts during the sub-projects’ planning and implementation stage. This section
outlines the laws, regulations and policies (Table 2) potentially relevant to sub-projects under the
Program.
Table 2: National Laws, regulations, and policies relevant under the Program
S. Key Regulations Relevance to Program Requirement

No.
Environmental Management
1. Environment This is an umbrella act under which several The act to be followed to
(Protection) Act, applicable statutes/regulations have been ensure environmental
1986 and framed. This Act provides general guidelines for protection, compliance
Environmental prevention of pollution. Under this Act, rules have towards emissions,
Protection Rules been specified for discharge/ emission of waste discharge, water
1986 and effluents and different standards for quality, air quality, noise
subsequent environmental quality. These include ambient level standards etc.
amendments noise standard, general effluent standards,
thereon. emission standards etc.
2. EIA Notification, The EIA notification list out type of projects that If the proposed facilities
2006 and requires EIA and/or environmental clearance exceed Built-Up Area
subsequent (EC) from the Expert Appraisal Committee of (BUA) of 20,000m2,
amendments Ministry of Environment, Forest and climate Environment Clearance
change, State/District Environment Impact (EC) from concerned
Assessment Authority body prior to authority will be obtained
commencement of any developmental work or prior to commencement
project expansion. of construction works
and the conditions
As specified in the notification, the projects are stipulated in EC letter will
classified into Category A and B based on the be complied during
type of development/sector and potential design (pre-
impacts. The Category B projects can be further construction),
classified into either Category B1 or Category B2. construction, and
operation stage of sub-
projects under the
Program.
EC will also be required
for the sources of
construction materials
such as stone quarries,
sand mines etc.
3. Water (Prevention The Act prohibits discharge of pollutants into The Healthcare
and Control of water bodies beyond a given standard and lays establishment (falls in
Pollution) Act, down penalties for non-compliance with its red category9, if
1974 and provisions. wastewater generation is
9 https://cpcb.nic.in/openpdffile.php?id=TGF0ZXN0RmlsZS9MYXRlc3RfMTE4X0ZpbmFsX0RpcmVjdGlvbnMucGRm
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subsequent > 100 KLD or incinerator
amendments This act will be applicable for segregation of liquid is present) and DG Set
chemical waste at source and ensuring pre- are required to obtain the
treatment or neutralization prior to mixing with Consent to establish
other effluents generated from healthcare (CTE) and Consent to
facilities and standard disposal. The Central and Operate (CTO) from
State Pollution Control Boards are the statutory State Pollution Control
authorities. Board (SPCB) prior to
4. The Air The purpose of this Act is to prevent, and control commencement of
(Prevention and air pollution and preserve air quality. This Act construction and
Control of empowers Central and State Pollution Control operation respectively.
Pollution) Act. Boards for managing air quality and emission
1981 and standards, as well as monitoring air quality, 13. CTE, and CTO would
subsequent prosecuting offenders and issuing licenses for also be required during
amendments construction and operation of any facility. This Act construction phase for
has notified National Ambient Air Quality construction equipment/
Standard for different land uses. machineries as per the
industrial categorization
of the SPCB such as
batching plant, DG sets,
crusher etc.
5. Noise (Regulation The Rules require activity/ processes generating The noise levels during
and Control) noise to ensure that the ambient noise standards construction period will
Rules 2000 are within the prescribed Standards. The be attenuated to meet
amended in 2010 proposed sub-projects will result in generation of the levels stipulated for
noise during construction phase and will require the land uses adjacent
to follow the noise standards as prescribed under (within 100 m) to the sub-
the rules. projects under the
Program.
During operations stage
the noise levels for
silence zone needs to be
achieved as per the
standards, i.e., 50 dB(A)
during the day and 40
dB(A) during the night.
6. National NEP is a comprehensive guiding document in The MEDD should
Environment India for all environmental conservation adhere to NEP principle
Policy (NEP), programs and legislations by central, state and of “enhancing and
2006 local government. The dominant theme of this conservation of
policy is to promote betterment of livelihoods environmental resources
without compromising or degrading the and abatement of
environmental resources. The policy also pollution”.
advocates collaboration method of different
stakeholders to harness potential resources and
strengthen environmental management.
7. Guidelines/Criteri These guidelines specify the provisions to be Permission from
a for evaluation of followed for obtaining permission towards competent authority
proposals/ abstraction of ground water in Notified/Non- needs to be obtained
requests for Notified areas. prior to extraction of
ground water The requisite permission needs to be obtained ground water, if borewell
abstraction (With from the Central Ground Water Authority etc are proposed.
effect from (CGWA)/ Department of Water Resources,
6

No.
16.11.2015) and Government of Maharashtra if groundwater is
subsequent abstracted for sub-projects under the Program.
amendments
8. The Wildlife The Wildlife Protection Act, 1972 has allowed the The sub-projects
(Protection) Act, government to establish a number of National selection criteria
1972 amended Parks and Sanctuaries and, to protect and excludes the activities to
1993 and Rules conserve the flora and fauna and their habitat. be located within the
1995; Wildlife Prior Wildlife clearance is required to be obtained WLS under the Program.
(Protection) if any works are to be carried out within the
Amendment Act, boundary of WLS.
2002 and
subsequent
amendments
9. Forest This Act provides for the conservation of forests The sub-projects
(Conservation) and regulating the diversion of forest lands to selection criteria
Act, 1980 and non-forestry purpose. Any project falling under excludes program
subsequent the forest area is required to obtain prior activities to be located
amendments; clearance from the relevant authorities under within Reserve Forest or
Forest (Conservation) Act 1980. Protected Forest land.
Forest clearance or NOC
will be required if any
program activities are
located in any other type
of forest land subject to
fulfilling the selection
criteria.
10. Ancient According to this Act, areas within the radii of The program selection
Monuments and 100m and 300m from the “protected property” are criteria excludes sub-
Archaeological designated as “prohibited areas” and “regulated project activities to be
Sites and areas” respectively. No development activity is located within the
Remains Act permitted in the “prohibited areas”. Development prohibited and regulated
1958 and activities are not permitted in the “regulated areas of ASI protected
subsequent areas” without prior permission from the monuments and
amendments Archaeological Survey of India (ASI) if the controlled areas as
site/remains/ monuments are protected by ASI or defined for state
The Maharashtra the State Directorate of Archaeology. protected monuments/
Ancient sites.
Monuments and
Archaeological
Sites and
Remains Act,
1960, 2016
11. Coastal This notification for the purpose of conserving The program selection
Regulation Zone and protecting the coastal areas and marine criteria exclude sub-
(CRZ) waters, the CRZ area has been classified as CRZ projects activities to be
Notification, 2019 I (further classified as IA and IB), CRZ II, CRZ III located within CRZ.
and subsequent (further classified as IIIA and IIIB) and CRZ IV
amendments (further classified as IVA and IVB) based on
ecological sensitivity and zonation.
Section 4 and 5 of the Act clarifies prohibited
activities and Regulation of permissible activities
within CRZ limit. Section 6 of the Act defines the
procedure of securing CRZ clearance for
permissible and regulated activities.
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No.
Projects falling in CRZ needs prior clearance
from the State or National coastal zone
management authority as per applicability.
12. Wetlands These rules are enacted for the protection of Permission from
(Conservation wetlands and restriction of certain activities within concerned authority to be
and wetlands by providing a regulatory mechanism. taken if any impact is
Management) These rules apply to protected wetlands notified envisaged on any such
Rules, 2017 and under the rules (which include Ramsar sites; feature. The program
subsequent wetlands in Eco-Sensitive Zones (ESZs) /United selection criteria exclude
amendments Nations Educational, Scientific and Cultural sub-projects activities to
Organization (UNESCO) sites, high altitudes, be located in notified
etc.). Section 4 of the rule elaborates Restrictions wetlands or reclaimed
of activities in wetlands. land from wetland.
13. Notification of Eco ESZs are area of significant ecological The program selection
Sensitive Zones importance. The ESZs notification are to criteria exclude sub-
(ESZs) and conserve and protect the natural resources and projects activities to be
subsequent living being. Several zones are declared in the located in ESZ.
amendments country as eco sensitive zones by notifications.
Any project activity located in ESZs will require
prior permission from ESZ monitoring committee.
14. The Maharashtra For conservation of trees and restoration of felled Permission from
Felling of Trees trees. concerned authority prior
(Regulation) Act, to tree felling to be
1964 secured. Compensatory
plantation10 activities to
be taken up as stipulated
by the State Forest
department or rules.
15. The National NGT provides an effective and expeditious Stakeholders / affected
Green Tribunal disposal of cases relating to environmental persons may approach
(NGT) Act, 2010 protection and conservation of forests and other NGT to resolve sub-
natural resources including enforcement of any project/s induced
legal right relating to environment and giving environmental issues
relief and compensation for damages to persons
and property and for matters connected
therewith. NGT has jurisdiction over matters
related to Water Act, 1974; Water Cess Act,
1977; Forest (Conservation) Act, 1980; Air Act,
1981; Environment (Protection) Act, 1986; Public
Liability Insurance Act, 1991; and Biodiversity
Act, 2002. Consequently, no other court will have
jurisdiction over the matters related to
environment falling under the above referred
Acts. Being a dedicated tribunal for
environmental matters with the necessary
expertise to handle environmental disputes, NGT
provides speedy justice (within 6 months).
Chennai is one of the five places of sitting of the
Tribunal (Southern Zonal Bench is located in
Chennai). If not satisfied with the NGT decision,
10Based on discussion with Forest Department-Alibag, the department usually recommends for plantation of 10 trees
due to felling of 1 non forest tree. However, this ratio may vary depending on scale of impact and regional
considerations.
8

No.
aggrieved party can approach the Supreme Court
within the specified period of time. Matters
relating to the Wildlife (Protection) Act, 1972 do
not fall under the jurisdiction of NGT.
16. The Motor Vehicle The Act regulates all aspects of road transport The law mandates
Act, 1988 and vehicles. It details legislative provisions regarding requirement of valid
Motor Vehicles licensing of drivers/conductors, registration of pollution under control
Rules, 1989 and motor vehicles, control of motor vehicles through certificate (PUC) of
subsequent permits, traffic regulation, insurance, liability, vehicles.
amendments offences and penalties, etc.
This Act will be applicable for all machinery

including vehicles/machineries deployed/used by
contractor and/or hospital authority.
17. Bio-Medical Facility should have authorization under BMWM The Healthcare
Waste Rule, 2016. BMWM Rules, 2016 is the key establishment need to
Management legislation governing the management of secure Authorization
(BMWM) Rules, biomedical waste in India. These guidelines from SPCB under these
2016 and provide the necessary compliance requirements rules. The Rule
subsequent for BMW generation, storage, transportation, mandates Management,
amendments disinfection, treatment and disposal. monitoring, and record
keeping of BMW
In addition, these guidelines also outline the management processes
provisions for obtaining authorization for alongside submission of
management of biomedical waste as well as annual reports to
monitoring and reporting requirements for concerned authority. The
healthcare facilities involved in biomedical waste rule also mandates the
generation and management. healthcare facility to have
a formal tie-up with
SPCB approved
Common Biomedical
Waste Treatment and
Disposal Facility
(CBWTDF)
18. Solid Waste These guidelines will be applicable for disposal of The hospital authority is
Management solid waste generated from construction camp required to engage a
(SWM) Rules, and Health Care Facility (HCF) which may licensed waste disposal
2016 include packaging material of hospital supplies, company to collect and
food waste, and other general waste. handle the
nonhazardous solid
All bio-degradable, non-biodegradable and waste and/or
domestic hazardous wastes generated in the arrangement with
hospital premise needs to be managed by the municipal authority/Local
hospital authorities in accordance with the Authority for collection
relevant provision of this Rule. and disposal of
nonhazardous solid
waste.
19. Hazardous and These rules ensure the protection to the public For handling and
Other Wastes against improper handling and disposal of disposal of hazardous
(Management hazardous wastes. These rules will be applicable waste, authorization
and for hazardous material and waste storage and under this rule to be
Transboundary handling. ensured for the sub-
Movement) project/s. The rule also
Rules, 2016 mandates the healthcare
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No.
The waste generated from HCFs may be facility to have a formal
hazardous in nature depending on the toxic, tie-up with SPCB
corrosive, flammable, reactive, and genotoxic approved authorized
properties. Such as broken thermometers, blood vendor for collection and
pressure gauges, or waste containing mercury disposal of Hazardous
and cadmium content etc. In addition to that, Waste.
Effluent Treatment Plant Sludge and used oil
generated from Generator Sets are also
considered as Hazardous waste.
20. Construction and The rules apply to every waste resulting from The proposed program
Demolition Waste construction, re-modelling, repair and demolition which will generate
Management of any civil structure of individual or organization construction and
Rules, 2016 or authority who generates construction and demolition (C&D) waste
demolition waste such as building materials, during the construction
debris, rubble. stage would require to
manage the C&D waste
To promote the management of construction and in line with the CPCB
demolition waste in an environmentally friendly guidelines.
manner and reduce the environmental impacts
throughout the duration of the project; CPCB has
developed guidelines on Environmental
Management of C&D Waste Management in
India (2017) in accordance with the Rule 10 sub-
rule 1(a) of C & D Waste Management Rules,
2016.
21. E-Waste Provides for the collection, dismantling, recycling, Applicable as electrical
(Management transport, disposal, and overall handling of e- and electronics as listed
and Handling) waste. in the Schedule I of the
Rules, 2022 E-waste means waste electrical and electronic aforesaid rules will be
(Electrical and equipment, whole or in part, or rejects from used and will require
electronic waste) manufacturing and repair process which are replacement within the
intended to be discarded. lifecycle of the sub-
projects as well during
decommissioning. As per
the provision of these
rules, the disposal of E-
wastes to be done at the
specified collection
centres and needs to be
reported annually.
22. Plastic Waste The Act regulates the responsibilities of The hospital authority is
Management producers and generators, for effective required to engage a
Rules, 2016 and segregation, management and recycling of licensed recycler to
amendments plastic waste. collect and handle the
The health care facilities/ hospitals are specified recyclable plastic waste
as institutional waste generator in the said rules. generated from facility.
All institutional generators of plastic waste are
required to segregate and store the plastic waste
in accordance with the Municipal Solid Waste
(Management and Handling) Rules and
handover the segregated wastes to authorized
waste processing or disposal facilities or
deposition centres either on its own or through
the authorized waste collection agency.
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No.
23. National Building The primary requirement of the Code is the The proposed program
Code (NBC), Safety of the Occupants, the safe exit of will have to comply with
2016 Occupants, restricting fire to a part of the building fire and life safety
and the suppression of fire through automatic or considerations (as
manual means. applicable to) under the
NBC.
24. The Maharashtra The law mandates inclusion of fire safety Fire NoC from State
Fire Prevention measures/infrastructures in buildings. Fires Department is to be
and Life Safety secured by the facilities.
Measures Act,
2006 and
Maharashtra Fire
Prevention and
Life Safety
Measures Rules,
2009
25. National Disaster Provides for the timely and effective response to Applicable in case any
Management Act disaster. It lays down guidelines to be followed by disaster situation arises.
2005 the State Authorities in drawing up the State The program will have
Plans. both onsite and offsite
This Act is applicable if the project encounters emergency response
natural disaster during the construction of plan prepared for the
operation stage. construction and
operations period.
26. Regulation of Use of Polychlorinated Biphenyls (PCBs) by Applicable in case of
Polychlorinated project will be prohibited as per the provisions of transformers / sub
Biphenyls Order, the order, old transformers, if any, will be handled stations to be installed for
2016 as per the provisions of the Act, and all existing power supply
transformers to be PCB free by 2025.
Disposal of PCB containing equipment must be
done as per Hazardous and Other Wastes
(Management, & Trans-boundary Movement)
Rules
27. Ozone Depleting Use of ozone depleting substances by project will Applicable as
Substances be prohibited as per the provisions of the Act. Any refrigerators, air
(Regulation) equipment, using such substances will be conditioners, fire
Rules, 2000 as hermetically sealed extinguishers will be
amended in 2005 used. It needs to be
ensured that no ozone
depleting substances are
used such appliances
Other Guidelines for Handling of Biomedical Waste
28. Guidelines on These guidelines provide directions for stepwise These guidelines will be
management of management of bio-medical waste generated applicable for waste
bio-medical waste from the Universal Immunization Program, generated from the
under Universal including provisions for training of health care various vaccination
Immunization workers, segregation, labelling, record-keeping, program in conjugation
Program (initially transportation, packaging, treatment and with BMW Rules 2016.
released in 2004, disposal of biomedical and solid waste generated
revised in 2016, from vaccination programs.
2017, 2018, 2021)
29. Guidelines for Bar The bar code system was designed to ensure The hospital authority
Code System for effective monitoring of biomedical waste from the should ensure the
11

No.
effective source of generation to its ultimate disposal as implementation of Bar
management of per BMW Rules, 2016. Code system for BMW
bio-medical waste management.
These guidelines provide the technical
specifications of a bar code system and guidance
to implement the system.
30. Guidelines for These guidelines provide guidance to healthcare The hospital authority
Handling of facilities as well as to industry/vendors for the should ensure the
Biomedical Waste purpose of management i.e., collection, compliance towards the
for Utilization transportation and disposal of biomedical waste stipulated provisions
to ensure handling of biomedical waste with under these guidelines.
adequate safeguards to protect community
health and the environment.
31. The Epidemic The Act provides for the prevention of the spread The Ordinance has a
Diseases Act of dangerous epidemic diseases. The Ordinance direct applicability to
1897 and The amends the Act to include protections for ensure safety of
Epidemic healthcare personnel combating epidemic communities, workers
Diseases diseases and expands the powers of the central and sub-project/s staff
(Amendment) government to prevent the spread of such working in the hospital
Ordinance, 2020 diseases. facility and residing in the
area surrounding to the
hospital facility in time of
epidemic/pandemic.
32. CPCB “guidelines These guidelines provide guidance on These guidelines are
for Handling, management of waste generated during required to be followed
Treatment and diagnosis and treatment of COVID-19 suspected by all facilities engaged
Disposal of waste / confirmed patients. in COVID-19 waste
generated during management.
Treatment/Diagno
sis/Quarantine of
COVID-19
patients”, 2020
Workers and Labour Welfare
33. The Building and This is a social welfare legislation that aims to This act will have a direct
Other benefit workers engaged in building and applicability to the
Construction construction activities across the country and program as it will involve
Workers regulates the employment and conditions of construction activity for
(Regulation of service of building and other construction workers the proposed hospital
Employment and and to provide for their safety, health and welfare facilities under the
Conditions of measures and for other matters connected Program.
Service) BOCW therewith or incidental thereto.
Act, 1996
34. Workmen’s The Act requires if personal injury is caused to a The provisions of the act
Compensation workman by accident arising out of and in the are to be adhered to by
Act, 1923 and course of his employment, his employer should the contractor, developer
Rules 1924 and be liable to pay compensation in accordance with and hospital
subsequent the provisions of this Act. administration at all times
amendments The provision of this act will be applicable during of sub-project/s
the construction and operation phase construction and
operation. Labour
insurance is required to
be obtained for skilled,
12

No.
semi-skilled and
unskilled workers.
35. The Child Labour This Act prohibits employment of children in The contractor and
(Prohibition and certain occupation and processes (including program authorities need
Regulation) Act, construction and demolition activities) as listed in to ensure that no child
1986 the Act. labour is engaged at site
for construction or
The act also specifies conditions of work for operation works either
children, if permitted to work. The Act also directly or by the
requires maintenance of a register for employed contractors/sub-
children (Section 11). contractors.
36. The Bonded The bonded labour means any labour or service The contractor and
Labour (Abolition) rendered under the bonded labour system. program authorities need
Act 1976 The act states that all forms of bonded labour to ensure that no bonded
stand abolished, and every bonded laborer labour is practiced at site
stands freed and discharged from any obligations for construction or
to render any bonded labor. operation works either
directly or by the
contractors/sub-
contractors.
37. Minimum Wages The Act empowers the Government to fix The program authority
Act, 1948 minimum wages for employees working in needs to ensure the
specified employments. display of wage notice
The Act requires the Government to fix minimum and issue wage slip to
rates of wages and review the rates every 5 workers as prescribed by
years. These are the minimum wages that are to the regulatory body.
be paid to employees (for construction workers).
38. Equal As per the Equal Remuneration Act 1976, it is the The contractor and
Remuneration Act duty of an employer to pay equal remuneration to program authority need
1976 men and women workers for same work or work to ensure the adherence
of a similar nature. to provision with the Act.
This act will be applicable to the proposed project
during construction and operation stage.
39. Inter-state The objective of the act is to regulate the Applicable if more than
Migrant Workers employment of inter-State migrant workmen and five inter-state workers
(ISMW) Act, 1979 to provide for their conditions of service and for are engaged.
and subsequent matters connected therewith.
amendments Every establishment that is recruiting interstate The requisite license
migrant workmen will be required to be registered needs to be obtained
with registering officers and every contractor who from governing authority
employ interstate migrant workmen need to as per the provisions
obtain a licence from the specified authority both stipulated in the act.
of the State i.e., home state (from where belongs)
and the host state (where to be employed).
40. The Contract The Act provides for certain welfare measures to This act will be applicable
Labour be provided by the Contractor to contract labor to all construction works
(Regulation and and in case the Contractor fails to provide, the envisaged to be
Abolition) Rules, same are required to be provided by the Principal employed during the
1971, 1973 and Employer by Law. construction phase of the
subsequent The principal employer is required to take sub-project/s.
amendments. Certificate of Registration and the Contractor is
Contract Labour required to take a License from the designated
(Regulation and Officer.
13

No.
Abolition) The central Act is applicable to the
Maharashtra establishments or Contractor of principal
Amendment Act employer if they engage 20 or more contract
2005, 2017 labour. The Maharashtra Act is applicable if more
than 50 labours are engaged on contract basis.
41. The E.P.F. and This act aims to provide a kind of social security This norm secures well-
Miscellaneous to the employees and workers. being of the employees
Provisions act, and will be followed as
1952 The Act provides retirement or old age benefits, per applicability
such as Provident Fund, Superannuation
Pension, Invalidation Pension, Family Pension
and Deposit-Linked Insurance.
42. Public liability An Act to provide for public liability insurance for The contractor/
insurance act, the purpose of providing immediate relief to the subcontractor needs to
1991 persons affected by accident occurring while obtain insurance policies
handling any hazardous substance and for to cover liabilities from
matters connected therewith or incidental accidents that cause
thereto. harm or injury to the
affected person.
Note: All relevant statutes/ regulations and their amendments of the country/state/local body
related to environmental safeguards and labour standards will be applicable.
B. International Environmental Agreements
14. The list of majors Multilateral Environmental Agreements (MEAs), to which India is a
signatory are listed below:
Nature conservation
Table 3: International treaties, conventions and declarations for nature

conservation
S. No. Nature Conservation
Ramsar Convention on Wetlands: The Convention on Wetlands is an intergovernmental treaty
that provides the framework for national action and international cooperation for the
conservation and wise use of wetlands and their resources. India currently has 49 sites
1
designated as Wetlands of International Importance (Ramsar Sites), with a surface area of
1,093,636 hectares.
Source: https://www.ramsar.org/
CITES (Convention on International Trade in Endangered Species of Fauna and Flora) is an
international agreement between governments. Its aim is to ensure that international trade in
2
specimens of wild animals and plants does not threaten the survival of the species.
Source: https://cites.org/eng
TRAFFIC (The Wildlife Trade Monitoring Network): To ensure the trade in wild plants and
animals is not a threat to the conservation of nature. TRAFFIC is a leading non-governmental
3 organization working globally on trade in wild animals and plants in the context of both
biodiversity conservation and sustainable development.
Source: https://www.traffic.org/about-us/our-mission/
CMS (Convention on the Conservation of Migratory Species): CMS also known as the Bonn
4
Convention, is an environmental treaty of the United Nations that provides a global platform for
14
S. No. Nature Conservation

the conservation and sustainable use of terrestrial, aquatic and avian migratory animals and
their habitats. CMS brings together the States through which migratory animals pass, the Range
States, and lays the legal foundation for internationally coordinated conservation measures
throughout a migratory range.
Source: https://www.cms.int/
CAWT (Coalition Against Wildlife Trafficking): The Coalition Against Wildlife Trafficking (CAWT)
was established in 2005 by the U.S. State Department as a voluntary coalition of governments
and organizations that aims to end the illegal trade of wildlife and wildlife products. CAWT
5
currently includes six governments and thirteen international NGOs.
Source: https://mea.gov.in/bilateral-
documents.htm?dtl/6017/Fact+Sheet+on+Wildlife+Trafficking
CBD (Convention on Biological Diversity): The key objective of CBD includes (a) The
conservation of biological diversity (b) The sustainable use of the components of biological
6 diversity (c) The fair and equitable sharing of the benefits arising out of the utilization of genetic
resources.
Source: https://www.cbd.int/intro/
ITTC (International Tropical Timber Organization): ITTC is intergovernmental organization
promoting the sustainable management and conservation of tropical forests and the expansion
7 and diversification of international trade in tropical timber from sustainably managed and legally
harvested forests.
Source: https://www.itto.int/about_itto/
UNFF (United Nations Forum on Forests): The United Nations Forum on Forests is a high-level
intergovernmental policy forum. The United Nations Strategic Plan for Forests 2017-2030
(UNSPF) provides a global framework for actions at all levels to sustainably manage all types
8 of forests and trees outside forests and halt deforestation and forest degradation. The Strategic
Plan provides a global framework for actions at all levels to sustainably manage all types of
forests and trees outside forests and halt deforestation and forest degradation.
Source: https://www.un.org/esa/forests/index.html
IUCN (International Union for Conservation of Nature and Natural Resources): The IUCN is an
international organization working in the field of nature conservation and sustainable use of
9
natural resources.
Source: https://www.iucn.org/
GTF (Global Tiger Forum): Inter-governmental international body working exclusively for the
10
conservation of Tigers in the wild.
Hazardous material
Table 4: International treaties, conventions and declarations for management of

hazardous material
S.
Hazardous material
No
Cartagena Protocol on Biosafety: The Cartagena Protocol on Biosafety to the Convention on
Biological Diversity is an international agreement which aims to ensure the safe handling,
transport and use of living modified organisms (LMOs) resulting from modern biotechnology that
1
may have adverse effects on biological diversity, taking also into account risks to human health.
It was adopted on 29 January 2000 and entered into force on 11 September 2003.
Source: https://bch.cbd.int/protocol/background/
SAICM (Strategic Approach to International Chemicals Management): The Strategic Approach to
International Chemicals Management (SAICM) is a global multi-sectoral and multi-stakeholder
2 policy framework, whose secretariat is hosted by UN Environment Programme. It offers a forum
to discuss and address the many challenges related to the adoption and implementation of
national policies to safely manage chemicals.
15
S.
Hazardous material
No
Source: https://www.unep.org/resources/factsheet/strategic-approach-international-chemicals-
management-saicm
Stockholm Convention on Persistent Organic Pollutants (POPs): The Stockholm Convention is a
global treaty that aims to protect human health and the environment from the effects of persistent
3
organic pollutants (POPs). The Stockholm Convention, which currently regulates 29 POPs.
Source: http://chm.pops.int/
Basel Convention on the Control of Trans-boundary Movement of Hazardous Waste and Their
Disposal: The overarching objective of the Basel Convention is to protect human health and the
environment against the adverse effects of hazardous wastes. Its scope of application covers a
4 wide range of wastes defined as “hazardous wastes” based on their origin and/or composition
and their characteristics, as well as two types of wastes defined as “other wastes” - household
waste and incinerator ash.
Source: http://www.basel.int/TheConvention/Overview/tabid/1271/Default.aspx
Atmospheric emissions
Table 5: International treaties, conventions and declarations for atmospheric

emissions
S.
Atmospheric emissions
No
UNFCCC (United Nations Framework Convention on Climate Change): The ultimate objective of
all three agreements under the UNFCCC is to stabilize greenhouse gas concentrations in the
1 atmosphere at a level that will prevent dangerous human interference with the climate system, in
a time frame which allows ecosystems to adapt naturally and enables sustainable development.
Source: https://unfccc.int/
Kyoto Protocol: Kyoto Protocol operationalizes the UNFCC by committing industrialized countries
and economies in transition to limit and reduce greenhouse gases (GHG) emissions in accordance
2 with agreed individual targets. The Convention itself only asks those countries to adopt policies
and measures on mitigation and to report periodically.
Source: https://unfccc.int/kyoto_protocol
Montreal Protocol (on Ozone Depleting Substances): The Montreal Protocol on Substances that
Deplete the Ozone Layer (the Montreal Protocol) is an international agreement made in 1987. It
3 was designed to stop the production and import of ozone depleting substances and reduce their
concentration in the atmosphere to help protect the earth's ozone layer.
Source: https://www.unep.org/ozonaction/who-we-are/about-montreal-protocol
Marine environment
Table 6: International treaties, conventions and declarations for marine

environment
S. No Marine environment
IWC (International Whaling Commission): The IWC was established in 1946 as the global
body responsible for management of whaling and conservation of whales. Today the IWC
has 88 member countries. The mandate has not changed but many new conservation
1
concerns exist and the IWC work programme now also includes bycatch and entanglement,
ship strikes, ocean noise, pollution and debris, and sustainable whale watching.
Source: https://iwc.int/en/
16
Occupational Health and Safety
Table 7: International treaties, convention for labour health and safety
S.
N Labor Health and Safety
o
India is a signatory to the International Labour Organization (ILO) Core Labor Standards
with 47 conventions and 1 protocol ratified, this relates to ensuring core labor standards
1 are upheld for construction workers.
https://www.ilo.org/dyn/normlex/en/f?p=NORMLEXPUB:11200:0::NO::p11200_country_id:
102691
C. ADB Environmental Safeguards
15. SPS 200911 provides for the environmental requirements and review procedures of ADB
and applies to all projects/program and grants ADB finances. SPS 2009 comprises three key
safeguard areas: environment, involuntary resettlement, and indigenous peoples; and aims to
avoid adverse project/ program impacts to both the environment and the affected people;
minimize, mitigate and/or compensate for adverse project impacts; and help Borrowers to
strengthen their safeguard systems and to develop their capacity in managing the environmental
and social risks. At the project identification phase, ADB uses a categorization system to indicate
the significance of potential environmental impacts and is determined by the category of its most
environmentally sensitive component, including direct, indirect, cumulative, and induced impacts
within the project's area of influence. The project categorization system is described below.
Category A. A proposed project is classified as category A if it is likely to have significant adverse

environmental impacts that are irreversible, diverse, or unprecedented. These impacts may
affect an area larger than the sites or facilities subject to physical works. An environmental impact
assessment is required.
Category B. A proposed project is classified as category B if its potential adverse environmental

impacts are less adverse than those of category A projects. These impacts are site-specific, few
if any of them are irreversible, and in most cases mitigation measures can be designed more
readily than for category A projects. An initial environmental examination is required.
Category C. A proposed project is classified as category C if it is likely to have minimal or no

adverse environmental impacts. No environmental assessment is required although
environmental implications need to be reviewed.
Category FI. The proposed project involves the investment of ADB funds to, or through, a
financial intermediary.
16. Depending on the significance of project impacts and risks, a full-scale environmental
impact assessment (EIA) will be required for category A projects. An initial environmental
examination (IEE) will be required for category B projects. A desk review is required for Category
C projects. EIA will be a comprehensive assessment while an IEE, with its narrower scope, is
conducted for projects with limited impacts that are few in number, generally site-specific, largely
reversible, and readily addressed through mitigation measures (category B). An EMP, which
addresses the potential impacts and risks identified by the environmental assessment, shall be
11 ADB. 2009. Safeguards Policy Statement. Manila.

17
prepared. The level of detail and complexity of the EMP and the priority of the identified measures
and actions will be commensurate with the project’s impact and risks.
17. Safeguard Policy Statement (SPS): Environmental Safeguard: The objective of this
Policy Statement is to ensure the environmental soundness and sustainability of projects and to
support the integration of environmental considerations into the project decision-making process.
Environmental safeguards are triggered if a project is likely to have potential environmental risks
and impacts. Safeguard Requirements 1: Environment of SPS 2009 is provided as Appendix 2.
Policy Principles:
1. Use a screening process for each proposed project, as early as possible, to determine the
appropriate extent and type of environmental assessment so that appropriate studies are
undertaken commensurate with the significance of potential impacts and risks.
2. Conduct an environmental assessment for each proposed project to identify potential direct,
indirect, cumulative, and induced impacts and risks to physical, biological, socioeconomic
(including impacts on livelihood through environmental media, health and safety, vulnerable
groups, and gender issues), and physical cultural resources in the context of the project’s area
of influence. Assess potential transboundary and global impacts, including climate change. Use
strategic environmental assessment where appropriate.
3. Examine alternatives to the project’s location, design, technology, and components and their
potential environmental and social impacts and document the rationale for selecting the
particular alternative proposed. Also consider the no project alternative.
4. Avoid, and where avoidance is not possible, minimize, mitigate, and/or offset adverse impacts
and enhance positive impacts by means of environmental planning and management. Prepare
an environmental management plan (EMP) that includes the proposed mitigation measures,
environmental monitoring and reporting requirements, related institutional or organizational
arrangements, capacity development and training measures, implementation schedule, cost
estimates, and performance indicators. Key considerations for EMP preparation include
mitigation of potential adverse impacts to the level of no significant harm to third parties, and the
polluter pays principle.
5. Carry out meaningful consultation with affected people and facilitate their informed
participation. Ensure women’s participation in consultation. Involve stakeholders, including
affected people and concerned nongovernment organizations, early in the project preparation
process and ensure that their views and concerns are made known to and understood by
decision makers and taken into account. Continue consultations with stakeholders throughout
project implementation as necessary to address issues related to environmental assessment.
Establish a grievance redress mechanism to receive and facilitate resolution of the affected
people’s concerns and grievances regarding the project’s environmental performance.
6. Disclose a draft environmental assessment (including the EMP) in a timely manner, before
project appraisal, in an accessible place and in a form and language(s) understandable to
affected people and other stakeholders. Disclose the final environmental assessment, and its
updates if any, to affected people and other stakeholders.
7. Implement the EMP and monitor its effectiveness. Document monitoring results, including the
development and implementation of corrective actions, and disclose monitoring reports.
8. Do not implement project activities in areas of critical habitats, unless (i) there are no
measurable adverse impacts on the critical habitat that could impair its ability to function, (ii)
there is no reduction in the population of any recognized endangered or critically endangered
species, and (iii) any lesser impacts are mitigated. If a project is located within a legally protected
area, implement additional programs to promote and enhance the conservation aims of the
18
protected area. In an area of natural habitats, there must be no significant conversion or

degradation, unless (i) alternatives are not available, (ii) the overall benefits from the project
substantially outweigh the environmental costs, and (iii) any conversion or degradation is
appropriately mitigated. Use a precautionary approach to the use, development, and
management of renewable natural resources.
9. Apply pollution prevention and control technologies and practices consistent with international
good practices as reflected in internationally recognized standards such as the World Bank
Group’s Environmental, Health and Safety Guidelines. Adopt cleaner production processes and
good energy efficiency practices. Avoid pollution, or, when avoidance is not possible, minimize
or control the intensity or load of pollutant emissions and discharges, including direct and indirect
greenhouse gases emissions, waste generation, and release of hazardous materials from their
production, transportation, handling, and storage. Avoid the use of hazardous materials subject
to international bans or phaseouts. Purchase, use, and manage pesticides based on integrated
pest management approaches and reduce reliance on synthetic chemical pesticides.
10. Provide workers with safe and healthy working conditions and prevent accidents, injuries,
and disease. Establish preventive and emergency preparedness and response measures to
avoid, and where avoidance is not possible, to minimize, adverse impacts and risks to the health
and safety of local communities.
11. Conserve physical cultural resources and avoid destroying or damaging them by using field-
based surveys that employ qualified and experienced experts during environmental assessment.
Provide for the use of “chance find” procedures that include a pre-approved management and
conservation approach for materials that may be discovered during project implementation.
18. This Program is categorized as B for Environment safeguards. As a sector program, the
MEDD will conduct an environmental screening for all the sub-projects under this program in
accordance with EARF. The screening results will be intimated to ADB for clearance. If the
screening result shows the subproject is Category B for environment, then further assessment in
the form of an IEE report is required in accordance with the EARF before the subproject is
included in the scope of the sector loan, so that the program is in accordance with ADB’s SPS
2009 requirements.
19. SPS 2009 requires information about environmental safeguard issues to be made
available in a timely manner, in an accessible place, and in a form and language(s)
understandable to affected people and to other stakeholders, including the public, so they can
provide meaningful inputs into sub-project/s design and implementation. For illiterate people,
suitable communication methods will be used. This EARF and sample IEE will be disclosed on
ADB’s website and MEDD’s website as well as the site offices. During program implementation,
consistent with SPS 2009, the disclosure of documents submitted by MEDD for this program will
be:
(i) new or updated IEEs, and a corrective action plans, if any, prepared during
project implementation, upon receipt by ADB; and,
(ii) the environmental monitoring reports, upon receipt by ADB.
20. ADB’s Safeguard Policy Statement (2009) requires communities, groups, or people
affected by subprojects, and civil society to be engaged by MEDD through information disclosure,
consultation, and informed participation in a manner commensurate with the risks to and impacts
on affected communities. Meaningful consultation processes are defined as those that, (i)
beginning early in the project preparation stage and being carried out on an ongoing basis
throughout the project cycle, (ii) providing timely disclosure of relevant and adequate information
that is accessible to affected people, (iii) being free of intimidation and coercion, (iv) being gender
19
inclusive and responsive, and (v) enabling the incorporation of all relevant views of affected
people and other stakeholders in decision-making. The consultation process and its results are
to be documented and reflected in an IEE report for category B subprojects.
21. ADB’s SPS 2009 also requires MEDD to set up and maintain a grievance redress
mechanism (GRM) to receive and facilitate resolution of affected peoples’ concerns and
grievances about their environmental performance at program level. It should address affected
people's concerns and complaints promptly, using an understandable and transparent process
that is gender responsive, culturally appropriate, and readily accessible to all segments of the
affected people. Affected people can also take complaints to ADB’s Accountability Mechanism
although they should approach the local GRM in the first instance; but the GRM should not impede
access to the country’s judicial or administrative remedies.
22. International Finance Corporation Environment, Health, and Safety Guidelines:

ADB’s SPS 2009 refers borrowers to the IFC’s General Environment, Health, and Safety (EHS)
Guidelines, 2007 which set out international good practice related to environment, health, and
safety which the program should follow regarding assessment of potential impacts and applicable
standards and management measures, performance indicators, and monitoring guidelines.
D. Compatibility between Country’s and ADB Safeguard Policy
23. The ADB environmental safeguard policy principles are encompassed entirely in its
Safeguards Policy Statement 2009. Government of India has different but robust environmental
legislative framework, embedded in various Acts, Policies, Rules and Regulations. While the ADB
SPS is in line with the multilateral development financing institutions, Government of India policies
are also comparable to international environmental framework including that of ADB. The
government’s environmental regulatory framework derived from Constitutional Provisions; the
National Environmental Policy, 2006 is a comprehensive policy document, addresses all relevant
aspects of environmental protection and conservation, environmental sustainability and
enforcement. The Environmental (Protection) Act, 1986 and its Rules, Notification, Standards,
etc., have created robust regulatory framework. Besides, there are parallel and complementing
legislations dealing with specific aspects like forest, wildlife, pollution control, archeological
conservation, etc.
24. The Government of India’s environmental assessment and clearance process is, in
principle, consistent with ADB’s environmental assessment process and public disclosure
requirements. Environmental impact assessments (EIAs) for development projects under
Category 'A' and 'B1' projects are similar to ADB’s screening, categorization, assessment, and
clearance/approval systems. The difference between both the requirements is that while the ADB
“environmental safeguards are triggered if a project is likely to have potential environmental risks
and impacts”, the Government of India EIA Notification clearly defines the projects/activities and
their environmental categories (A/B1/B2) that require environmental assessment. The
project/activities included are on the nature, scale and location, and cover activities that are likely
to have adverse environmental impacts. The ADB SPS requires the review of environmental
assessment requirement for every project/sub-projects separately and assigns classification
(A/B/C) based on sensitivity of the sub-project.
25. Environmental Guidelines and Criteria for Subproject Selection under this program rules
outs the possibilities of requirement of forest clearance for acquisition of Reserve/protected forest,
wildlife clearance, CRZ clearance, clearance from ASI/State Department of Archaeology;
however, the subjects would /may require Environmental Clearances, green nods from pollution
20
control board, various licenses/NoC (i.e., labour license, Fire NoC, PESO License etc. as detailed
out in ‘National Regulatory Framework’ sections.
26. Subprojects under this program are unlikely to have significant adverse impacts that
irreversible, diverse or unprecedented, and therefore under ADB SPS they are likely to be
categorized as B. Due to construction in urban areas, there may be some adverse impacts during
construction, however, these will be temporary and will likely be restricted with project footfall area
majorly It is therefore required that proposed subprojects are subjected to screening,
categorization, and preparation of IEEs and EMPs. Comparative requirements of Government of
India and ADB for the subprojects under MTCMESDP are presented in below table.
Table 8: Comparative analysis of ADB SPS and Regulatory Framework of Government of

India
Comparison between
Government Regulatory ADB and National
ADB Requirement
Requirement Regulatory
Requirements
EIA Notification SPS 2009 Environmental
If the proposed facilities exceed Built-Up Classify the project using REA Assessment:
Area (BUA) of 20,000m2, environmental checklist. Categorization subprojects under this
Assessment will be mandatory and (A/B/C). Sub-Projects will be program would likely
Environment Clearance (EC) from classified as B. Category A require Environmental
concerned authority will be applicable prior projects will be excluded from Assessment study as per
to commencement of construction works. the program. Government of India
Environmental Assessment and EC will Preparation of IEE will be regulations. Whereas
also be applicable for the sources of needed for the sub-projects. ADB SPS 2009 also
construction materials such as stone Public consultation to be requires the process of
quarries, sand mines etc. carried out in a manner screening,
commensurate with the environmental
However, such type of projects wouldn’t impacts, process and its assessment, public
require Public Hearing or stakeholder results are to be documented consultation, disclosure,
engagement. and reflected in the IEE. etc., for all subprojects.
All necessary government To ensure compliance

approvals/clearances should with ADB, all subprojects
be in place prior to award of should go through the
contracts environmental
assessment process
Mitigation measures specified according to ADB SPS
in IEE are incorporated in 2009 as well as
project design (taking into Environmental
cognizance input from Assessment in
stakeholders); incorporate accordance with the
mitigation and monitoring provisions of EIA
measures (including the EMP) Notification 2006 and it’s
into bid/contract documents. subsequent
amendments (if
applicable).
Environmental Assessment, clearance Disclosure on ADB’s website The program and sub-
conditions are made publicly available on of the final IEE; updated IEEs projects will comply with
MoEFCC portal. and corrective action plans; disclosure requirement
and environmental monitoring as per SPS and national
reports. Public disclosure regulatory requirement.
21
Comparison between
ADB Requirement
Requirements
The report on BMW generation and (complete IEE) in an
disposal are also mandated to be disclosed accessible place and local
by the healthcare facilities in public domain language.
Pollution Prevention Pollution Prevention Projects must comply

with all
Water (Prevention and Control of Pollution) Implementation of EMP; Statutory requirements
Act of 1974, Rules of 1975, and corrective action plans in case as per the regulatory
amendments of non-compliance framework at national,
Air (Prevention and Submission of semi-annual state and local level;
Control of Pollution) Act of 1981, Rules of monitoring report and As per the ADB all
1982 and amendments. mandates CTE and disclosure SPS 2009 covers projects must comply
CTO from all the aspects of pollution with the country
SPCB during construction and operation control environmental
phase of sub-project. SPS also requires that all regulations to be eligible
subprojects should comply for funding.
Hazardous waste rules (construction phase with county safeguard
primarily) and Biomedical Rules (operation Policies.
phase) necessitates Authorization for In project implementation,
SPCB. pollution prevention and
control technologies and
Noise Pollution (Regulation and Control) practices consistent with
Rules, 2000 as amended international good practice, as
reflected in internationally
Rule 3 of the Act specifies ambient air recognized standards such as
quality standards in respect of noise for the World Bank Group’s
different areas/zones. Environment, Health and
Safety Guidelines shall be
Appendix 6 provides applicable noise applied. When Government
standards. regulations differ from these
levels and measures, project
Construction and Demolition Waste shall achieve whichever is
Management Rules, 2016 more stringent. If less
Rule 4 and 5 specifies the duties of waste stringent levels or measures
generator, and duties of service provider are appropriate in view of
and their contractors. These are to be specific project
followed during the construction circumstances, provide full
and detailed justification.
Disposal standards are notified under the

Environment (Protection) Act, 1986 and by
other entities like BIS
Environmental Standards.
Ambient Air Standard:

https://cpcb.nic.in/uploads/National_Ambie
nt_Air_Quality_Standards.pdf
Ambient Noise Standards:
https://cpcb.nic.in/displaypdf.php?id=Tm9p
c2UtU3RhbmRhcmRzL25vaXNlX3J1bGVz
XzIwMDAucGRm
22
Comparison between
ADB Requirement
Requirements
Ground Water Quality Standards:
https://cpcb.nic.in/wqm/BIS_Drinking_Wate
r_Specification.pdf
Surface Water Quality:
https://cpcb.nic.in/wqm/Designated_Best_
Use_Water_Quality_Criteria.pdf
Waste Water Standards:

The Environment (Protection) Rules, 1986:
https://cpcb.nic.in/displaypdf.php?id=R2Vu
ZXJhbFN0YW5kYXJkcy5wZGY=
Standards For Liquid Waste (BMW Rules):
https://cpcb.nic.in/uploads/Projects/Bio-
Medical-Waste/Bio-
medical_Waste_Management_Rules_2016
.pdf
Ancient Monuments and Archaeological SPS 2009 requires that all the Sub-projects will be
Sites and Remains Act 1958 and impacts on archeological, located away from such
subsequent amendments historical and cultural sites in consideration of
resources shall duly be Environmental
The Maharashtra Ancient Monuments and covered in environmental Guidelines and Criteria
Archaeological Sites and Remains Act, assessment for Subproject Selection
1960, 2016
Works within 300 m (up to 100 m)

boundary of the monument can be done
only with prior permission of ASI/state
department of archaeology. Application in
prescribed format to be submitted to ASI
for permission.
Wildlife Protection Act, SPS 2009 requires that all Sub-projects will be
1972 impacts related to located away from such
environmental sensitive areas sites in consideration of
Permission from chief wildlife warden/ State (forest, protected areas etc.,) Environmental
Wildlife Board/ National Board of Wildlife and wildlife are duly being Guidelines and Criteria
necessary if any project is located in such covered in the for Subproject Selection
area environmental assessment
Forest (Conservation) Act, 1980 -Same as above- In consideration of
amendment 1988 and the Environmental
rules/notifications Guidelines and Criteria
for Subproject Selection,
Prior permission/forest clearance to use the sub-projects will not
forest land for non-forest (subproject) be acquiring reserve or
purposes is mandatory protected forest land.
However, forest
clearance to be secured
for any other kind of
forest land.
23
Comparison between
ADB Requirement
Requirements
Labor laws SPS 2009 requires due The program shall
Contractor shall register with the state labor consideration of occupational comply with all labour
department and comply with the provisions, health and safety impacts in laws (central and state),
in terms of minimum wages, equal wages environmental assessment,
for men and women, no child labor, inter- and mitigation measures
state labor, working conditions, amenities to
be provided etc.
24
III. ANTICIPATED ENVIRONMENTAL IMPACTS
27. Depending on the proposal for the sub-project (i.e., whether Greenfield or Brownfield), the
nature of impact on surrounding environment may vary to some extent. Therefore, impact
identification and corresponding mitigation measure should be framed in consideration of specific
sub-project concerned. In subsequent sections the potential impacts as envisaged at different
phases of proposed development i.e., Preconstruction, Construction and Operation Phases are
discussed.
A. Preconstruction Phase
28. Activities during pre-construction include site selection, preparation and approval of
design, and onboarding of contractors. During this phase, the potential environmental impacts are
mostly associated with the design and location of the proposed facilities. The program is
categorized as B for environment and the sub-project selection criteria will exclude subprojects
located within environmentally sensitive areas12. Thus, the environmental impacts during this
phase are not expected to be significant for the proposed sites.
29. Regulatory requirements: Necessary consent/permission (like Environmental

Clearance, Forest Clearance,13 tree cutting approval from local authority/forest department if tree
removal required, permission from Central Ground Water Board for water extraction (or any other
concerned authority for abstraction of ground/surface water), labour licenses from Labour
Department and labour insurance etc.) as applicable to the sub-projects prior to site preparation
or construction are required to be secured at this stage. Therefore, MEDD/Contractor will ensure
that all necessary government permits those which are required prior to site preparation or
construction are secured within pre-construction phase. The details of regulatory requirements
are provided in Table 2 of this EARF.
30. Land Asset and Livelihood: The proposed development will be taken up on government
land and no displacement is expected. However, due diligence will be undertaken to confirm for
any public or state-owned land, or no persons are living on or using the land informally; and that
there are no outstanding complaints with regards to the land. Due diligence reports will be
prepared for subprojects with infrastructure with no anticipated impacts.
31. Worker’s Camp Siting: Poor siting and layout of workers camp (if located outside of
proposed area premise) may cause loss of agricultural produce if sited on cultivable land, health
hazard to workers due to poor hygiene condition and nearby community due to improper
management of waste and effluent; contamination to surface and ground water bodies in case
sited near water bodies, local drainage problem, fire, electrical and other safety risks etc. The
location, layout and basic facility provision of each labor camp should be well planned by
contractor and approved by Program authority (Executing/Implementing Agency) prior to
development of camp. The camps will be planned about 500 m (or at a distance as suggested by
concerned authority like forest department, wetland authority etc.) away from water bodies,
residential areas, forest area or any environmentally sensitive areas etc. If the camps are located
within sub-projects premises, they should be adequately barricaded. Contractors will prepare solid
waste and wastewater management plan that includes collection, storage, and disposal subject
to the review and approval of the Program Authority (Executing/Implementing Agency).
12 Source: Concept Paper; Project Number: 56343-001, August 2023

13 For acquisition of forest land other than Reserve or Protected Forest types that are excluded as per selection
criteria.
25
32. Utility Shifting: Unplanned shifting of public utilities due to the proposed interventions
may cause disruption of utility services to local community. All efforts will be made by Program
Authority (Executing/Implementing Agency) to reduce the duration of utility shifting impact (if any).
All utilities should be shifted before start of construction.
33. Plan for continuation of operation of Existing Facility: In case the medical college and
hospital building are planned within existing premise of an ongoing healthcare facility, necessary
plan to be developed by Program Authority (Executing/Implementing Agency) so that no impact
on day-to-day operation of existing healthcare facility is caused due to the construction works and
associated incremental traffic.
34. Heritage and archaeology: If the proposed sub-projects located in the vicinity of any
archaeological/ cultural resources14 then the Program Authority (Executing/Implementing Agency)
will be responsible for siting and designing the project to avoid any significant damage to physical
cultural resources. Such resources likely to be affected by the project will be identified, and
qualified and experienced experts will assess the project’s potential impacts on these resources
(heritage impact assessment) using field-based surveys as an integral part of the environmental
assessment process. Additionally, the contractor should develop a protocol for chance finds
during construction in consideration of Ancient Monuments and Archeological Sites and Remains
Act (1958) and subsequent amendments.
B. Construction Phase
35. Land-use, Topography and Drainage: Since the proposed interventions will not be taken
up in environmentally sensitive areas and expected to be in urban/habitation areas, therefore it
may be anticipated that no significant change in land use would occur. Due to the site preparation
i.e., levelling of land, cutting and filling activities the topography and drainage pattern of the project
footfall area are likely to get affected; however, such impacts are anticipated to be localized.
Provision for managing the excess earth, keeping adequate drainage condition should be
considered in project design to rule out possibility of localized waterlogging by creating unhygienic
condition or flooding by affecting surrounding environment.
36. Air Quality: During construction phase, suspended particulate matter is anticipated to be
key air pollutant, which is likely to be generated during the site development activities such as
levelling of land, cutting and filling activities, transportation of construction material to the project
site from various sources etc. Also, due to the increased construction vehicle movements,
operation of equipment and Generators may result in generation of Gaseous Emissions like NOx,
SO2 and CO. Impacts on sensitive location like school, college, hospital etc. if present in the
proximity (say within 100 m is likely to occur for a temporary period of the construction. These
impacts need to be mitigated by adoption of necessary measures such as maintaining the
machineries and vehicles in good condition complying with the standards/ guidelines of CPCB,
obtaining timely ‘pollution under control (PUC)’ certificates, paving of approach roads under use
onsite and offsite, sprinkling of water etc. As the impacts are likely to be localized in nature, the
areas outside the project boundary might not face any significant adverse impact with respect to
ambient air quality.
14
SPS,2009: Defined as movable or immovable objects, sites, structures, groups of structures, and natural features
and landscapes that have archaeological, paleontological, historical, architectural, religious, aesthetic, or other cultural
significance. Physical cultural resources may be located in urban or rural settings and may be above or below ground
or under water. Their cultural interest may be at the local, provincial, national, or international level.
26
37. Noise generation: The operation of construction machinery such as rock drills, pneumatic
tools, concrete mixers, cranes, generators, pumps, compressors, vibrators, etc., are likely to be
the main sources of noise vibration during the construction phase. Due to the construction
activities, the anticipated noise and vibration generation is envisaged to be mostly confined to the
proposed area premises and not anticipated to have significant adverse impacts on the
surrounding environment. However, generation of noise/vibration could cause considerable
impact in case the proposed development is planned within the premise of any existing healthcare
facility or any other noise sensitive feature like school/college or any other healthcare facility is in
nearby areas (say 100 m). Therefore, adequate measure for managing such impact needs to be
in place such as maintenance of the machineries/ engines, acoustic barrier around the
construction site boundary etc. In addition to noise, in case generation of significant vibration is
perceived (like in case blasting is involved at any site), impact of vibration on nearby buildings
(risk of structural damage) needs to be assessed and mitigation measures needs to be adopted
accordingly. Statutory permissions for blasting need to be obtained from the competent authority
prior to commencement of blasting activities and the conditions stipulated in the permission letter
needs to be complied.
38. Land and Soil: Removal of topsoil is envisaged during construction stage as construction
of new buildings will be involved. In addition to that, impact on topsoil may be caused if workers
camp, stockyards etc. located on fertile land and if haul roads and traffic detours during
construction are routed through agricultural land. In case of vegetation removal, soil erosion due
to surface run off also may increase. However, such types of impacts will be short term and can
effectively be managed by adopting mitigation measures like scrapping the top soil and storing it
in favorable conditions not to lose its fertility, reusing removed topsoil in suitable places, avoiding
agricultural land for material transportation, restoring the compacted soil by loosening them, if
any, taking up plantation activities is incidental areas, judicious siting of workers camp/stock yards
etc.
39. Impact on Water Resource: During construction phase, water will be required for
construction of structures, sprinkling for dust suppression, domestic and non-domestic uses of
the construction workers/camps etc. The abstraction of ground water should be avoided by the
contractor to the extent possible and in case where no alternative option available, permission
from competent authority needs to be obtained prior to extraction of ground water should.
Necessary permission should be secured by contractor in case of abstraction of surface water as
well. During construction phase, deterioration of water quality may occur due to siltation, disposal
of untreated liquid waste, solid waste from the construction sites/ camps, poor handling of material
or construction and demolition (C&D) waste and / or subsequent surface runoffs. Therefore,
proper waste and wastewater management plan should be in place which will be implemented by
the contractor.
40. Construction Debris/Waste: The proposed sub-projects may generate varied quantum
of construction and demolition (C&D) waste during site development and construction work. The
quantum of C&D waste is anticipated to be more in cases where construction of new facilities will
be taken up by demolishing existing structures. The C&D waste may also contain hazardous
material like asbestos. Therefore, proper segregation, temporary storage, handling, transportation
and disposal in conformation with regulatory requirement needs to be ensured by Contractor.
41. Terrestrial Vegetation/Trees: Since the proposed facilities will not be planned in
environmentally sensitive areas, no significant impact on natural habitat or ecologically important
areas are anticipated at this stage. However, due to the proposed development, felling of trees
and vegetation covers are envisaged. Subsequently, impact on associated biodiversity (like small
27
insects, herpetofauna, avifaunal and arboreal species etc.) due to loss of habitat may occur.
Improper management of waste/effluent may also lead to contamination of waterbodies by
causing impact on habitat conditions for aquatic species. However, such impact is expected to be
localised and mitigated by avoiding unnecessary clearance of vegetation / cutting of trees, not
releasing untreated waste into the water bodies, compensatory plantation activities, in the
projects’ nearby areas. The building layout will be superimposed on the plot map to identify the
green areas, if any that can be saved at the design stage itself.
42. Construction Camp: Poor site selection and poor camp management may have several
negative impacts on the environment, including the loss of vegetation due to the use of wood as
a fuel source for cooking, deterioration in the quality of nearby surface water bodies and soil
quality due to improper wastewater and solid waste management, threat of spread of
communicable diseases among the workers and the host communities. The labors need to be
made aware of the ‘dos and don’ts’ to avoid deterioration of surrounding environment, provide
safe cooking fuel / provisions to avoid burning of wood, proper gender segregated sanitation
facilities, provisions for treatment of waste etc.
43. Workers and Community Health and Safety: It is anticipated that there might be,
temporary, localised, and moderate environmental impacts during site preparation, excavation,
material transportation, storage, demolition, and construction works by means of generation of
dust and gaseous pollutants, generation of noise, increase in traffic and associated traffic
congestion, labour influx etc. If adequate mitigation measures are not followed, these activities
might have an impact on the Workers and Community Health and Safety aspects. Impacts on
health and safety can occur due to improper handling of equipment, untrained workers engaged
for critical works like height work, blasting etc., unsupervised work areas/practices and unsafe
working conditions, lack of usage of proper personnel protective equipment, lack of medical
facilities etc. can cause accidents and safety issues. Use of personal protective equipment for
workers, provision of adequate fire-fighting equipment onsite, Preparation and Implementation of
Health Safety and Environment (HSE) procedures as a condition of contract, Implementation of
a Fire Safety Plan prior commencement of any activities at the site, Clear marking of worksite and
hazard recognition, maintenance of a high standard of housekeeping at all times etc. would be
required to mitigate the impacts on occupational health and safety. To avoid community health
safety impacts measures such as preparation and implementation of traffic management plan,
sensitization of workers towards community cultural values etc. will be adopted. Proper site
restoration plan needs to be developed and implemented after completion of construction work to
avoid any potential risk to community and occupational health and safety associated with
improper site condition, contamination, waste dumping etc.
44. Securing necessary Permits at construction stage: Necessary permit as applicable

to the sub-project like (but not limited to) Consent to Establish (CTE), Consent to Operate (CTO),
Hazardous Waste Authorization, Tree felling permission, workman compensation policy, Pollution
Under Control (PUC) certificate for Construction vehicles etc. should be secured by Contractor in
prior as per the provisions of respective regulatory requirements. Contractor to procure
construction materials only from government-approved quarries/vendors. Creation of new borrow
areas, quarries, etc., for the project should be avoided; if unavoidable, contractor to obtain all
necessary clearances and permissions in prior. The conditions precedents as would be stipulated
in the permit/clearance documents should be strictly adhered to.
45. Unanticipated impacts: During implementation there can be impacts that were not
anticipated in the design stage. Such impacts, if identified needs to be assessed and corrective
28
actions need to be taken and the IEE report will need to be updated and submitted to ADB for
clearance and disclosure.
C. Operation Phase
46. Generation of Biomedical Waste and other waste: According to Biomedical

Management (BMW) Rules "bio-medical waste" means any waste, which is generated during the
diagnosis, treatment or immunisation (of human beings or animals) or research activities
pertaining thereto or in the production or testing of biological or in health camps. As per
categorization of BMW Rules, generation of following types of Biomedical Waste envisaged due
to the proposed project15. Please ensure that no activities undertaken or equipment procured are
producing radioactive wastes16. Radioactivity traces can be present in clothing, utensils, syringes,
needles, cotton swabs, vials, gloves and absorbent materials of patients administered high doses
of radioisotopes like I-131 constitute the solid radioactive waste material, x-ray tubes, x-ray plates,
etc.
Table 9: Types of Biomedical Waste envisaged due to the proposed project
Liquid
White
Yellow Red Blue Biomedical
(Translucent)
Waste
• Human, Contaminated Waste sharps Glassware: Chemical
Anatomical Waste including Metals: Broken or Liquid
Waste (Recyclable) Needles, syringes discarded and Waste
• Soiled Waste with fixed contaminated requiring
• Expired or Wastes needles, needles glass including separate
Discarded generated from from needle tip medicine vials collection
Medicines disposable items cutter or burner, and ampoules system
• Chemical such as tubing, scalpels, blades, except those leading
Waste bottles, or any other contaminated to effluent
• discarded intravenous tubes contaminated with cytotoxic treatment
linen, and sets, sharp object that wastes. system
mattresses, catheters, urine may cause
beddings bags, syringes puncture and Metallic Body
contaminated (without needles cuts. This Implants
with blood or and fixed needle includes both
body fluid syringes) and used, discarded
• Microbiology, vaccutainers with and contaminated
biotechnology their needles cut) metal sharps
and other and gloves.
clinical
15 Possibility of Radioactive waste generation is not envisaged in the sub-projects at this stage.
16 The Atomic Energy Regulatory Board (AERB) has been mandated by the Central Government, as the Competent
Authority as per Atomic Energy (safe Disposal of Radioactive Wastes) Rules, 1987 notified under the Atomic Energy
Act 1962. It exercises regulatory control over nuclear installations and the use of radioactive substances and radiation
generating plants outside such installations. As per provisions of Atomic Energy (safe Disposal of Radioactive
Wastes) Rules, 1987, no person shall dispose of radioactive waste (a) unless he has obtained an authorization from
the competent authority under these rules; (b) in any manner other than in accordance with the terms and conditions
specified in the authorization issued under these rules; (c) in any location different from those specified in the
authorization; and (d) in quantities exceeding those specified in the authorization. Health Care Facilities generating
radionuclides waste from treatment of Cancer patients and end-of-life equipment containing radio radionuclides shall
obtain authorization from AERB for its disposal. As per the policy of AERB, radionuclides wastes are required to be
re-exported back to the manufacturer.
29
Liquid
White
Yellow Red Blue Biomedical
(Translucent)
Waste
laboratory
waste
47. Given the hazardous nature of Biomedical Waste, the management of the same (i.e.,
segregation at source, temporary storage in designated colour coded containers in designated
places, transportation, timely handing over to Pollution Control Board (PCB) approved Common
Biomedical Waste Treatment and Disposal Facility (CBWTDF) needs to be ensured by
conforming regulatory requirement as per the provisions of BMW Rules 2016 and its subsequent
amendments. If CBWTDF services are not available in the area where Medical Colleges and
Hospitals will be planned, then in-situ BMW treatment facilities will be required to be established
in accordance with the guidance issued by statutory authorities’ time to time. In case in-situ
facilities are established, the hospital facilities will have proper plan in place to equip the treatment
facilities with adequate pollution abatement features, dedicated trained resource for handling and
managing treatment facilities and wastes likely to be generated from such facilities. The
necessary procedures for mitigating occupational and community health safety risks will be
developed and implemented post incorporation in IEE/ updated IEE and its clearance by ADB.
Beside Biomedical Waste the other kind of solid waste due to hospital operation may include
municipal solid waste, plastic waste, electronic waste, scrap material, hazardous waste (like used
oil from Generator set, sludge generated due to wastewater treatment etc.) also needs to be
ensured as per the provisions of respective regulatory norms.
48. Wastewater Generation: Wastewater generation in form of Sewage and Effluent has
been perceived. In addition to these, surface runoff due to rainfall may also occur. Therefore, the
facility should have proper mechanism for collection and segregation of sewage, effluent, and
stormwater. The effluent and sewage should be treated in wastewater treatment plant (i.e.,
sewage treatment plant and effluent treatment plant) whereas effort should be made for proper
collection and harvesting of rainwater. Quality of treated wastewater from the facility should
conform the discharge standards as stipulated in the Biomedical Management Rules during
facility operation i.e., (a) For discharge into public sewers with terminal facilities, the general
standards as notified under the Environment (Protection) Act, 1986; The Environment (Protection)
Rules, 1986 will be applicable (b) For discharge into public sewers without terminal facilities (or
facilities not connected to public sewers), the standards as stipulated in Biomedical Management
Rules 2016 and subsequent amendments should be followed. Odor and noise generation from
the sewage and effluent treatment plants will also be assessed and appropriate mitigation
measures will be devised.
49. Occupational and Community Health and Safety Risks: Improper management of
waste and wastewater may contaminate (which may include infectious biomedical waste
containing pathogens, chemicals, hazardous material etc.) the surrounding environment of
subproject area. Therefore, effective management (including proper treatment and disposal) of
waste and wastewater including the biomedical waste needs to be ensured. This may increase
Occupational health safety risk and community safety risk as such condition would increases the
risk of exposure of the workers and community to the health care waste and other hazardous
substance. The incremental traffic due to hospital operation may expose the local community to
potential accident risks and may also create traffic congestion at local level. Therefore, traffic
management plan may be developed for subprojects as necessary. In addition, all reasonable
precautions need be taken, and Emergency Preparedness Plan may be developed to mitigate
the potential risk in consideration of emergency situation i.e., fire, inundation, accidental
30
release/spillage of hazardous material etc. The site-specific occupational and community Health
& Safety (H&S) plansneed to be prepared by civil work contractors before commencement of work
and shall be cleared by the Environment and H&S Expert of PMC and thereafter by Environment
Expert under PMU under the Program. During construction stage, the EHS plans need to be
implemented rigorously and may further be updated and cleared by the Environment and H&S
Expert of PMC and thereafter by Environment Expert under PMU, if there is implementation
challenges, which were not covered in the H&S plans under the Program.
50. Securing necessary Permits at construction stage: Necessary permit as applicable

to the sub-project like (but not limited to) Consent to Establish (CTE), Consent to Operate (CTO),
Biomedical Waste Authorization, Permission for Water Abstraction, Pollution Under Control (PUC)
certificate for vehicles, Fire No Objection Certificate (NOC) etc. should be secured by Program
Authority prior to hospital operation and renewed time to time as per the provisions of respective
regulatory requirements. The conditions precedents as would be stipulated in the
permit/clearance documents should be strictly adhered to during implementation (in all stages)
under the Program.
IV. PROCESS TO BE FOLLOWED (ENVIRONMENTAL ASSESSMENT) FOR

SUBPROJECTS
A. Environment Category
51. The scope of MEDD includes construction of four medical colleges and tertiary hospitals
in underserved districts (Ambernath, Amravati, Osmanabad, Palghar, Raigarh, Ratnagiri, and
Sindhudurg) in the state of Maharashtra. As part of the program preparation for medical colleges
and tertiary hospitals, the environmental assessment along with environmental management
plans (EMPs) in accordance with requirements of ADB’s SPS 2009 was carried out for one sample
sub-Project. The IEE concluded that the program will have only small-scale, localized impacts on
the environment. During construction phase, the potential impacts are envisaged to be localized,
and temporary in nature; which can be adequately mitigated by adopting suitable mitigation
measures. However, in the operations phase all hospital facilities would result in generation of
non-hazardous, hazardous and infectious Biomedical waste (including liquid waste) which can
easily be transmitted by direct contact, in the air/water or by vectors, resulting in disease spread/
infections. Thus, having the potential to increase the Occupational Health and safety risk amongst
health workers, patients (including hospital acquired infection) and community. These impacts are
however mitigable through sound and established guidelines and practices. Therefore, sub-
projects under the program of MEDD have been classified as environmental category B.
B. Environmental Guidelines and Criteria for Subproject Selection
52. The MEDD will ensure that all components and subprojects are appraised, selected, and
approved in compliance with ADB’s requirements (as per following selection criteria):
(a) design and selection of subprojects will consider the input from public consultations if
any
(b) All components involving activities included in the ADB Prohibited Investment
Activities List (list provided in Appendix 1) must be excluded from the Program.
(c) All components/activities that trigger environment category A (e.g.
components/activities with significant adverse environmental impacts that are
irreversible, diverse, or unprecedented) must be excluded from the Program
31
(d) Components/activities that result in the significant conversion or degradation of natural

habitat or which are within a critical habitat17 must be excluded from the Program.
(e) no subproject will be located in or encroach upon legally protected areas including
national parks, wildlife sanctuaries, conservation/elephant/tiger reserves, forest land
(reserved and protected forest), ecologically sensitive areas, ecologically sensitive
zones, Coastal Regulation Zones, and Ramsar sites etc;
(f) sub-project components will not be located in forest land (other than reserved and
protected forest) if a significant number of trees are required to be cut or any damage
is envisaged to any rare or endangered species present in the land parcel.
(g) no subproject will be located in or encroach upon areas that have been identified by
MoEFCC or State Government or expert institutions under the GoI /GoM like Wildlife
Institute of India (WII) as potential or priority habitats/clusters for critically endangered
species such as Great Indian Bustard, Lesser Florican etc. unless it has been clearly
demonstrated to ADB through an ecological assessment undertaken by an external
expert, in consultation with relevant biodiversity stakeholders, that the program activity
will not have significant adverse impacts on the ecology of the area.
(h) no sub project will be located in or encroach upon other internationally or nationally
recognized biodiversity sites including key biodiversity areas, important bird areas,
wildlife corridors unless it has been clearly demonstrated to ADB through an ecological
assessment undertaken by an external expert, in consultation with relevant
biodiversity stakeholders, that the Program activity will not have significant adverse
impacts on the ecology of the area.
(i) no subproject will result in significant damage to physical cultural resources or require
any physical cultural resources to be removed from their current location
(j) no subproject will be located in or encroach upon internationally or nationally
recognized cultural, archaeological or heritage sites including ASI and state protected
monuments and their prohibited, regulated or controlled areas as are defined by the
relevant statutes.
(k) environmental screening of the subprojects will be done using the applicable rapid
environmental assessment (REA) checklist (see appendix -3)
(l) subprojects which have been categorized as ‘B’ for environment based on SPS 2009
will not be taken up unless assessed in accordance with Safeguards Requirements 1
(see Appendix 2) and confirmed by ADB following review and clearance of the IEE
report; and
(m) all necessary national and local government approvals and/or clearances (if required)
will have been obtained for the subproject and shared with ADB prior to
implementation.
(n) No sub-projects will be located on flood plains. The sub projects will be located above
the high flood level of that region.
(o) Any sub-project components/ activities will not generate radioactive wastes.
(p) Sub-Projects will not be located in areas of social conflicts
17 As described in ADB’s Safeguard Policy Statement (2009), critical habitat is a subset of both natural and modified
habitat that deserves particular attention. Critical habitat includes areas with high biodiversity value, including habitat
required for the survival of critically endangered or endangered species; areas having special significance for
endemic or restricted-range species; sites that are critical for the survival of migratory species; areas supporting
globally significant concentrations or numbers of individuals of congregatory species; areas with unique assemblages
of species or that are associated with key evolutionary processes or provide key ecosystem services; and areas
having biodiversity of significant social, economic, or cultural importance to local communities. Critical habitats
include those areas either legally protected or officially proposed for protection, such as areas that meet the criteria
of the World Conservation Union classification, the Ramsar List of Wetlands of International Importance, and the
United Nations Educational, Scientific, and Cultural Organization’s world natural heritage sites
32
C. Screening and Categorization
53. The screening using the REA checklist will be conducted to confirm the category of sub-
projects (for environment safeguards) under the Program. REA Checklists are provided in
Appendix 3.
54. The scale and magnitude of impact of the sub-projects on various environmental
components will be determined in consideration of the current land use, prevailing site
surrounding sensitivity, proposed sub-project/s interventions, likelihood of occurrence of impact,
sub-project/s phase for the perceived impact-risk, extent of impact-risk etc. Also, national
regulations as per GOI; and ADB safeguard requirement will be reviewed to determine
categorization of the sub-projects and accordingly, the environmental assessment (including the
EMP) and requisite environmental clearances applicable, if any shall be processed under the
Program.
55. Based on the screening, the environmental category of the sub-project/s will be
ascertained with concurrence of ADB, and the findings leading to the categorization of the sub-
project/s as category B will be documented. Once the Environment safeguards Category is
decided as ‘B’, the Initial Environmental Examination (IEE) Report for the sub-project will have to
be prepared as per the SPS,2009 requirements. The IEE report will be reviewed, cleared by ADB
and then disclosed in both ADB and MEDD websites prior to commencement of the construction
works.
D. Preparation of Environmental Assessments Reports
56. Initial Environmental Examination (IEE) Report. For B category (Environmental

Category) sub-projects, as per ADB SPS 2009, an Initial Environmental Examination (IEE) report
is required. IEE describes the studies conducted to identify the potential environmental impacts
of the proposed development and is prepared when impacts are unlikely to be highly significant
and can be mitigated relatively easily18. The IEE reports will be prepared as per the SPS
requirements and complied by implementing agency and executing agency i.e., Medical
Education and Drugs Department (MEDD), Government of Maharashtra. ADB SPS requirements
for environment safeguards and an outline and content of an IEE Report is given in Appendix 2.
57. In order to prepare IEE Reports for the sub-projects, pertinent baseline information with
respect to Physical-Biological-Social components will be gathered for the sub- Projects’ Area of
Influence19. During the process of collection of Baseline Information, meaningful consultations
with concerned stakeholder will be carried out in form of Key Informant Interview (KII) or Focussed
Group Discussion (FGD). In consideration of proposed interventions pertaining to the sub-
projects, the IEE study will identify the sub-project specific potential impacts on environmental
18 While both the EIA and IEE fulfill the same purpose, EIA prepared (for Category A projects) is a more detailed study
and comprehensive document, because of greater severity of potential impacts
19 ‘Area of Influence encompasses (i) the primary project site(s) and related facilities that the borrower/client (including
its contractors) develops or controls, such as power transmission corridors, pipelines, canals, tunnels, access roads,
borrow pits and disposal areas, and construction camps; (ii) associated facilities that are not funded as part of the
project (funding may be provided separately by the borrower/client or by third parties), and whose viability and
existence depend exclusively on the project and whose goods or services are essential for successful operation of
the project; (iii) areas and communities potentially affected by cumulative impacts from further planned development
of the project, other sources of similar impacts in the geographical area, any existing project or condition, and other
project-related developments that are realistically defined at the time the assessment is undertaken; and (iv) areas
and communities potentially affected by impacts from unplanned but predictable developments caused by the project
that may occur later or at a different location.’- ADB SPS 2009
33
parameters (as discussed under Section III: Anticipated Environmental Impacts, but not limited
to) to formulate necessary mitigation measures. IEE will also keep adequate provisions for
meaningful consultation and disclosure process throughout the sub-project lifecycle along with a
provision of grievance redress mechanism. In case of involvement of any existing facility in the
proposed sub-projects or an activity that can be defined as associated facility (see footnote 19),
an audit/assessment will be carried out to identify gaps in environmental safeguards compliances,
if any with respect to the requirements of GoI regulations and ADB, SPS,2009. Further a
corrective action plan (CAP) will be prepared to ensure compliances. The audit and CAP will be
made part of the IEE reports. The indicative checklist for conducting audit/assessment of existing
facility is provided in Appendix 4.
E. Environmental Management Plan
58. As per the requirement of ADB SPS 2009, an Environmental Management Plan (EMP) is
mandated as part of the IEE. EMP outlines the environmental management practices that should
be followed to reduce temporary impacts associated with any sub-projects and to enhance
positive impact on the environment while a program will be implemented. The EMP also
establishes the requirement of environmental monitoring which would be carried out to evaluate
the adequacy of EMP and adopt corrective actions, if any required. Specific mitigation strategies,
environmental monitoring requirements, and relevant institutional structures, including budgetary
provisions for EMP implementation will be delineated in EMPs. Where impacts and risks cannot
be avoided or prevented, mitigation measures would be identified to ensure that the sub-project/s
is implemented by Contractor and Program Authority (Executing/Implementing Agency) in
conformance with applicable regulatory requirements pertaining to the Sub-Projects. An indicative
generic EMP is attached as Appendix 5 for reference. The generic EMP will be updated further to
ensure site specific mitigation measures for a particular sub-project and provisions provided
herein will be detailed out based on detailed design.
F. Review of Environmental Assessment Reports and EMPs
59. IEEs (including EMPs) for the subprojects will be approved by ADB prior to
commencement of construction works. If required, the EMP should be further updated by the
MEDD during the construction phase, consider the change of location/design/scope, which were
not envisaged during the environmental assessment for different sub-projects under the program.
60. In case the subproject requires Environmental impact assessment (EIA) report (including
EMP) and Environment Clearance as per EIA Notification 2006 and its subsequent amendments,
the MEDD need to engage an accredited EIA Consultant organization for above assignment
under the Program. The commencement of civil works shall only be taken up by respective civil
works contractors upon receipt of requisite EC under the Program.
61. IEE reports including EMPs, prepared/updated by consultants/contractors, will be

reviewed, and approved by MEDD and ADB. Approval of safeguard documents of respective
subproject is pre-requisite to initiate the bidding process. The ADB cleared EMP will be made part
of the bid and contract documents prior to commencement of construction works.
62. Executing agency is primarily responsible for identifying, prioritizing, formulating,

appraising, approving, and implementing subprojects in accordance with technical, financial, and
economic appraisal criteria, including social and environmental criteria, mutually agreed upon
between ADB and the borrower/executing agency. PMU will submit all IEEs to ADB for review
and disclosure.
34
V. CONSULTATION, INFORMATION DISCLOSURE
63. ADB’s SPS (2009) requires sub-projects to carry out meaningful public consultation on an
ongoing basis. All sub-projects will need to be community involved, and as such consultation
should be built into and central to the sub-project design process from initiation onwards.
However, meaningful consultation per ADB SPS 2009 requirements is also mandatory for those
subprojects which are Category ‘B’ and will need to be documented in the IEE report. Public
consultation for these subprojects will: (i) begin early and carry on throughout the project cycle;
(ii) provide timely disclosure of relevant information, understandable and accessible to people;
(iii) ensure a free and un-intimidated atmosphere without coercion; (iv) ensure gender
inclusiveness tailored to the needs of disadvantaged and vulnerable groups; and (v) enable the
incorporation of all relevant views of affected people, and stakeholders into process of decision
making, mitigation measures, the sharing of development benefits and opportunities and
implementation issues. It will then need to continue throughout the sub-project implementation.
MEDD will ensure that the communications strategies and consultations plan will refer to the
requirements of ADB’s SPS 2009 as follows:
(i) Disclosure of relevant information that is understandable and accessible to affected

people.
(ii) Consultation undertaken in an atmosphere free of intimidation or coercion.
(iii) Process of consultation that is gender inclusive and responsive, fit to the needs of
disadvantaged and vulnerability groups.
64. For Category ‘B’ subprojects consultations at different stages may take the form of public
meetings in villages, focus groups e.g., for women, or one-on-one consultations with landowners,
adjacent residents etc. Consultations for each subproject must ensure a representative
percentage of the local community are consulted, as well as gender balance and representation
of vulnerable groups. If that is not possible at a public consultation a separate gender focus group
must be held to ensure the concerns of women and other identified vulnerable groups (e.g., below
poverty line) are heard. Meaningful consultations will inform participants of details of the
subproject and the possible environmental and social impacts, collect views and opinions from
affected persons, and ensure the subproject responds to them. The dates, attendees,
male/female split, details of any participants vulnerabilities, topics covered, and views and
opinions raised should be recorded and included in the IEE report, along with details of how
MEDD /the subproject has responded to them.
65. The key stakeholders to be consulted during sub-project preparation and implementation
include:
• Sub-project beneficiaries, and project affected persons;
• elected representatives, community leaders, and representatives of
community-based organizations; business and industrial associations, etc.;
• relevant local nongovernment organizations (NGOs);
• local government and relevant government agencies, including the
authorities responsible for land acquisition, protection and conservation of
forests and environment, archaeological sites, religious sites, and other
relevant government departments (regulatory, administration and
infrastructure services related);
• residents, shopkeepers, business people, farmers, fisheries (owners and
workers) who live and work near sites where facilities will be built;
custodians, and users of socially and culturally important buildings; and
35
• Vulnerable groups, women groups.
66. A variety of approaches can be adopted, and stakeholders should be consulted throughout
the program implementation. At minimum the following consultation activities (Table 10) should
be conducted. This is indicative and sub-project/program agencies can also adopt more effective
methods and approaches, which are locally appropriate. Consultations shall be conducted in an
atmosphere which is conducive to the development of the subprojects and beneficial to the
affected persons and other stakeholders. The implementing agency will ensure that the
consultations are free of coercion and intimidation, gender-inclusive, and tailored to the needs of
disadvantaged and vulnerable groups. All the consultation events shall be documented, including
gender segregated participants list, and record findings. The IEEs should reflect the feedback and
concerns of consultations.
Table 10: Proposed Public Consultation Activities

Program Stage Consultation Activities Remarks
Subproject • Household level consultations through sample Initial stages of sub-
preparation questionnaire surveys on needs, priorities for sub- project’s preparation
project preparation. under the program.
• Document events, including male and female
participation, record findings in IEE along with how
the subproject responds to them.
• Focus group discussions with people During the visits to sub-
residing/working near the sub-project sites. project sites
Program Stage • A subproject level consultation workshop with all Once the draft IEE
key stakeholders (at site level) report is prepared
• Consultations with Affected persons: Affected At various stages,
persons shall be consulted to ensure: especially during, the
• incorporate their views/concerns on preparation and
compensation/resettlement assistance inclusion of implementation
vulnerable groups in sub-project benefits;
• identify assistance required by affected persons
during rehabilitation, if any; and
• Avoid potential conflicts for smooth sub-project
implementation. It will also provide adequate
opportunities for consultation and participation to
all stakeholders and inclusion of the poor,
vulnerable, marginalized, and affected persons in
the sub-project process
• Affected persons will also include persons who are
affected by environmental disturbance etc.
Consultation will also be needed with such affected
persons.
Subproject • Continue consultations with stakeholders During the EMP
Implementation throughout sub-project implementation as monitoring at work sites
required.
• Following processes may be considered:
• Focus group discussions with the people
• residing/working near the sub-project sites
• Focus group discussions with the construction
workers and construction supervision
• staff (contractor, consultants and PIU)
36
Program Stage Consultation Activities Remarks

• Focus discussions with commuters and general
public along the roads where works are
implemented
• Consultations shall be documented appropriately
(photographs, feedback etc.,) and reported via
Environmental Monitoring Reports
67. A Stakeholder is anyone who can be affected by implementation of any sub-projects under
the Program. They can be internal or external stakeholders in consideration of the sub-projects.
So, the process of systematically gathering and analyzing qualitative information to determine
whose interest should be taken into account in the planning stage of the program is called
stakeholder analysis. The analysis focuses on the stakeholder characteristics as knowledge of
sub-project, interest related to sub-project, position for or against to sub-project, potential
alliances with other stakeholders and ability to affect the sub-project initiation or execution.
Stakeholder analysis assists in this prioritization by assessing the significance of the sub-project
to each stakeholder group from their perspective, and vice versa.
Figure 1: Stakeholder Influence-Interest Analysis Matrix
68. Key potential stakeholders as identified during preparation of the EARF are listed below.
Any others stakeholder if identified during development of IEE for Sub-Projects or implementation
should be brought into the process in the future. Primary stakeholders include:
37
Table 11: Potential Stakeholders with influence-interest matrix
Potential
Level of
impact of
influence of
this
stakeholder
Program on
on this
S.I. stakeholder
Stakeholder Phase Interest program
No (negligible,
(negligible,
minor,
minor,
moderate,
moderate,
high)
high) Power
Interest
Local Government
Sub-Project
As the Executing
preparatory
agency and key
phase, pre-
Medical Implementing
construction
Education and Agency, all the Sub-
phase,
i. Drugs Projects development High High
construction
Department and operation are of a
phase, operation
(MEDD), direct concern for
phase, (defined in
MEDD.
this table as “all
phases”)
Regulator for green
permits for
establishing the sub-
project, pollution
Pollution Control prevention,
ii. All phases Moderate High
Board safeguard
implementation,
biomedical waste
management,
pollution control etc.
Permission for felling
Preconstruction of trees
Department of
iii. and Construction Selection of species Minor High
Forest
Phase for green area
development
Such entities will be
potentially
responsible for the
Urban Local
supply of water
Bodies (Zila
resources for the
iv. Parishad, All Phases Moderate High
proposed sub-
Municipal
project, drainage
Corporation etc.)
connectivity, permits
for the building layout
and safety plans, etc.
In case the treated
Terminal wastewater
wastewater discharged in the
v. Operations phase Moderate Moderate
treatment facility public drainage which
(as applicable) is connected to
terminal wastewater
38
Potential
Level of
impact of
influence of
this
stakeholder
Program on
on this
S.I. stakeholder
No (negligible,
(negligible,
minor,
minor,
moderate,
moderate,
high)
high) Power
Interest
treatment facility for
final treatment.
Water supply and
Groundwater permits for
authority/ Water Construction and abstraction of water
vi. High High
resource operations for construction
department works as well as
during operations.
Maharashtra
State Electricity
Board (MSEB) or
vii. All Phases Supply of electricity Moderate High
other entity
supplying
electricity
Responsible for
firefighting and fire
State fire prevention in the
viii. department/Fire Operations phase building and issuing High High
brigade inspection certificate
after conducting fire
audits.
Fair compensation,
Department of Construction working hours,
ix. High High
labor welfare Phase prohibition of
child/forced labor
Facilitating
discussion with
affected Potential
sub-Project Affected
Preconstruction Peoples;
Revenue
x. and Construction dissemination of Moderate High
Department
Phase information about the
sub-project at local
level; fixation of
entitlement for
compensation
Private sector
On-time payment for
equipment
Equipment
xi. Operation installation, High Minor
suppliers
maintenance of
equipment
Fair wage, safe and
Construction
xii. Construction healthy working High High
contractors
environment
39
Potential
Level of
impact of
influence of
this
stakeholder
Program on
on this
S.I. stakeholder
No (negligible,
(negligible,
minor,
minor,
moderate,
moderate,
high)
high) Power
Interest
Common Bio- On time collection of
medical Waste Biomedical Waste as
xiii. Operations Phase High High
Treatment well as payment for
Facility (CBWTF) services rendered
Contracted
Workers
Fair wage, safe and
(Cleaning staff,
xiv. Operations Phase healthy working High Minor
security,
environment
maintenance,
etc.)
Employee
Fair compensation,
work-life balance,
social
Hospital security/benefits,
xv. Operations High High
Employees adequate provisions
for mitigation of
Occupational
Hazards
Fair compensation,
temporary facilities to
reside, acceptable
Construction
xvi. Construction hygiene in workplace, High High
workers
access to basic
amenities during
construction phase
Community
Loss of
assets/livelihood,
Nuisance from
Patients/ pollution (Air
Residential areas Construction, pollution, traffic
xvii. Moderate Moderate
near proposed Operation phase congestion, noise
facility pollution, threat from
improper
management of
waste and effluent)
Press/social
media and Civil Identify interest,
xviii. Society All phases express and share Moderate Moderate
Organizations/ opinions
Worker’s Unions
69. The stakeholder engagement and communication about the proposed sub-projects should
ensure continuous communication and coordination with the government departments, utility
40
service providers, workers, community etc. throughout the sub-project lifecycle. Stakeholder
engagement is an ongoing process and to be scaled to the sub-project risk and phase. It also
includes disclosure and dissemination of information and participation of those interested or/and
affected by the sub-project, grievance redress mechanism, and ongoing reporting to concerned
public and communities.
70. In case of situations like COVID-19 pandemic, in undertaking any face to face
consultations it will need to be ensured that national COVID-19 requirements and WHO meeting
and hygiene guidelines are followed, including awareness raising activities for those undertaking
consultations, minimizing travel requirements, undertaking screening health checks to confirm
those going in the field are not symptomatic, providing them with adequate supplies of personal
hand sanitizer and masks, ensuring social distancing of at least 1m, that masks are worn at all
times during consultations, and that a register of all contacts is maintained. If public meetings are
not possible to convene due to COVID-19 restrictions, then the same representation should be
achieved through door-to-door consultations within communities. Consultations should also
convey how MEDD will ensure community health and safety during construction.
71. Aside from ADB’s SPS 2009, MEDD will also ensure that the relevant national
requirements in the Right to Information Act 2005 will be complied with. MEDD will ensure to
make a list of the participants of the consultation process including the summary of the concerns/
issues they raised and suggestions on sub-project design, mitigation measures and monitoring,
employment opportunities, and other relevant issues on implementation. Participation of women,
if any, will be highlighted as well as the date and location of the consultations.
VI. GRIEVANCE REDRESSAL MECHANISM
72. ADB’s SPS (2009) requires the establishment of a responsive, readily accessible, and
culturally appropriate grievance redressal mechanism (GRM) capable of receiving and facilitating
the resolution of affected persons’ concerns and grievances about the physical, social, and
economic impacts of the program.
73. Currently there is no program specific Grievance Redress mechanism in place with
respect to environmental safeguards20. At facility level, aggrieved person may reach out to Dean
to inform about any concern with respect to environmental safeguards; however, no formal
platform for registering any grievances is in place currently.
74. A Grievance Redress Mechanism (GRM) will be in place to redress environmental related
grievances during implementation of the program. This GRM will be used for managing
grievances related to environmental safeguards, and occupational health & safety during the
construction and operation phases of the program.
75. Principles of GRM: The GRM is based on the following principles and the same will be
used to assess the GRM performance:
a) Accessibility
• The GRM will be accessible to all people residing in the sub-project area. It will be
available and provide assistance to all project affected people irrespective of language,
20 Government of India’s Centralized Public Grievance Redress and Monitoring System (CPGRAMS) and Government
of Maharashtra’s Grievance Portal (https://grievances.maharashtra.gov.in/en) has platform for registering all types
of grievances.
41
literacy level, or cost. Project affected people will access the GRM without fear of reprisal.
Information on the GRM will be disseminated using various means to ensure people know
about GRC, its members and procedures.
b) Predictability
• The GRM will offer clear procedures with time frames for each stage and clarity on the
type of results it can and cannot deliver.
c) Transparency
• The GRM will operate in such a way that it is easy for others to see what actions are being
performed. This will be undertaken through disclosure of all information to the public and
affected people.
d) Credibility
• The performance of the GRM will enable affected people to accept and believe that the
mechanism works, delivers results and is trustworthy.
e) Fairness
• The GRM procedures will be perceived as fair, especially in terms of access to information,
and opportunities for meaningful participation in the final decision. Its outcome should be
consistent with applicable national standards and should not restrict access to other
redress mechanisms.
f) Feedback
• The GRM will serve as a means to channel citizen feedback to improve program outcomes
for the people.
• It is difficult to avoid Grievances totally but much can be done to minimize and manage
complaints in order to reduce impacts
76. Grievance Redressal Structure and Function: The GRM is intended as the tool by
which a stakeholder (e.g., workers, patients and their kin, local communities) may formally have
a platform to register any grievance. A three-tier grievance redress mechanism is being
proposed: 1st level of Grievance Redresses Cells (GRCs) will be set up at the Site/Facility level;
2nd and 3rd Level GRCs will be at IA/PMU and State/EA Level Committees respectively as
furnished in below figure.
42
Figure 2: Grievance Redress Mechanism
77. The structure (indicative and can be further strengthened to add members) considered for
different level of GRC for managing Environmental Safeguard related grievances are presented
below.
Table 12: Structure and functions of GRCs (Proposed)
Grievance Function
Redresses Levels GRC Members
Cells (GRCs)
First level of Facility/Site • Chaired by Dean • Registration of Grievances
GRC Level • Medical Superintendent • Forwarding Grievances to concerned
• Office Superintendent person or authorities
(Focal Point) • Communicating with complainant
• PMC (Qualified Env regarding receipt and resolution of
Expert at site) complaints
• Contractor (Qualified • Resolution of complaints raised within
Env Expert at site) five days of receipt
• Local body • Feedback to the complainant on
representative action completed against registered
complaint and seeking complainant
feedback on level of satisfaction.
• Closure of grievance
• If not resolved, then forwarding the
complaint to second level of GRC
43
Grievance Function
Cells (GRCs)
Second level IA/ PMU Level • Commissioner- DMER • Registration of complaint
of GRC (DMER) (Project Director- • Eligibility assessment of grievances
Chairperson) by GRC chair person
• Nodal officer (of Joint • Information to the complainant about
Director or Assistant eligibility of the complaint;
Director rank), • Grievance Redress Committee
• Public Grievance meetings to discuss grievances and
Officer (Focal Point) action required;
• Qualified Environmental • Ensuring collection of detailed
Expert information about the eligible
• Qualified Social Expert complaint;
• Assessment of complaint, draw
conclusion from discussions and
make recommendations;
• Develop action plan outlining
activities required to implement the
recommendations;
• Ensuring implementation of
recommendations by stakeholders or
concerned authorities;
• Monitoring actions of the
recommendations in view of timeline;
• Feedback to the complainant on
action completed against registered
complaint and seeking complainant
feedback on level of satisfaction
• Closure of grievances or forwarding
of complaint to the third level of GRC
if not resolved within 10 days
Third level of State/ EA • Chaired by Secretary, • Registration of complaints received
GRC Level (MEDD) MEDD , • Information to the complainant about
• Deputy Secretary- eligibility of the complaint;
MEDD or as designated • Eligibility assessment of grievances
by Secretary MEDD by the GRC chairperson
(Focal Point) • Ensuring collection of required
• Additional members as information about the eligible
nominated by Secretary complaint;
from within or outside • Assessment of complaint to draw
the organisation conclusion from discussions and
make recommendations;
44
Grievance Function
Cells (GRCs)
• Develop action plan outlining
activities required to implement the
recommendations;
• Ensuring implementation of
recommendations by stakeholders or
concerned authorities;
• Monitoring actions of the
recommendations in view of timeline;
• Closing complaint after all actions
taken as per recommendations and
feedback to the complainant.
• Advise to complainants about
approach /appeal to the concerned
department in case the complainant
is not satisfied or complaint is beyond
the scope of the GRC
78. Aggrieved persons will have the flexibility of conveying grievances/suggestions by

dropping grievance redress/suggestion in complaints/suggestion boxes or through telephone, by
email, by post, CPGRAMs and GoM’s grievance portal or by writing in complaints register in
Facility/Site offices. The Office Superintendent at First Level GRC will be the Focal Point for facility
level grievance redressal and will have the responsibility for registering the grievances,
maintaining records. During construction phase, the Office Superintendent will be supported by
Contractor’s EHS expert/s to receive and document the records pertaining to grievances with
respect to environmental underperformance or other issues and subsequent actions. At facility
level, adequate modes (like drop box, common email address, common phone numbers) for
registering grievance will be maintained. The Public Grievance officer will be the focal contact
point at the second level GRC. The contact details (weblinks, contact numbers, email-ids) will be
displayed at construction sites at places accessible to the public and on the website of MEDD and
Facility. The EA will issue office orders nominating the members of GRCs. The GRM will be
gender responsive and ensure adequate gender representation as required. To ensure that the
GRCs remain functional, the GRCs will meet at least once in six months even if there are no
grievances received by the GRCs or all have been resolved at site level itself without referring the
grievances to the GRCs.
79. The First level of GRC at facility/site level will have the responsibility for timely grievance
redress on environmental safeguards related concerns and for registration of grievances, related
disclosure, and communication with the aggrieved party. Depending on the type of the grievance,
the First Level GRC will investigate the grievance and attempt to resolve it within 5 days of
registration of grievance. If the grievance is not resolved at this level, the concern will be
escalated to the next level i.e., Second Level. If the grievance is still unresolved at this stage
(within 10 Days of registration of grievance), the grievance would be escalated to the Third level.
At this level, the timeline for resolving the grievance will be within 15 Days after received by the
GRC. The document trail will be maintained throughout the process of grievance redressal and
45
will be reported thorough Semi Annual Monitoring Reports. The provision for registering
anonymous grievances will also be ensured in case the aggrieved person intends for the same.
80. Affected people can also take complaints to ADB’s Accountability Mechanism although
they should approach the local GRM in the first instance; but the GRM should not impede access
to the country’s judicial or administrative remedies.
81. Process of Grievance Redress Mechanism: The following process shall be adopted for
receiving complaints and addressing received complaints:
Step 1: Receiving Grievances/ Complaints and its Registration at Site Level
• All grievances, complaints, concerns will be submitted verbally or in writing through

drop box placed at accessible location, post, common email id or phone number
• Received complaints will be recorded, compiled and Registered (Grievance
Number) in a register (database) placed at the site/ Dean’s Office with support of
the contractor’s focal person on a daily basis (24 hours). Each grievance shall be
given a number to track status
Step 2: Review of Grievances, Sorting, Information and Forwarding (24 hours)
• Registered grievances will be reviewed by the focal person with support of the
PMC’s Environment Expert and contractor’s EHS.
• Based on type of grievances, the focal person will sort out grievances with support
of PMC’s Environment Expert and contractor’s EHS.
• The focal person will inform the GRC Chairperson about all grievances in writing.
At that time, the focal person may suggest grievances that can be managed by the
site engineer (contractor) to the GRC Chairperson;
• GRC Chairperson will determine eligibility of the complaints. Inconveniences
caused by minor construction related issues shall be referred to the site engineer
to resolve immediately or within 24 hours. Site engineer will be responsible to
respond to the complaints immediately. On the other hand, issues which cannot
be resolved by the site engineer and if it is complex in nature shall be referred to
GRC.
• The focal person will receive acknowledgement from concerned authorities (site
engineer) on receipt of the grievances shared with them. The focal person shall
inform complainants regarding eligibility of their complaint and action to be taken
by the concerned authority (site engineer/ GRC) within (24-72 hours). If the
grievance is ineligible, complainants should be informed of the reasons.
Step 3: Eligibility and Preparation for GRC meeting (2 days)

• GRC Chairperson will receive eligible complaints (copy of written complaint
document or verbally recorded messages) from the focal person and review
details; GRC Chairperson may ask to collect baseline information about the
grievances registered, if required.
• GRC Chairperson will share list of documents with the GRC Secretary to collect
baseline information on selected grievances to be addressed.
46
• The GRC Secretary will arrange all documents with the help of PMC’s Environment
Expert and contractor’s EHS Expert/s etc. in a proper way to present in front of
GRC.
• GRC Chairperson will call a meeting as per convenient date and time of the
committee members.
Step 4: Assessment of the Grievance, Meeting and Plan of Action (3 days)
• If necessary, the GRC will consult and seek relevant information about complaint
from the concerned parties.
• On basis of the collected evidence, GRC shall draw conclusions and make
recommendations for a solution.
• GRC Secretary will keep record of the proceedings and decisions taken by GRC
members to further track the status as per decided timeline.
• The GRC will agree on the action plan required to be implemented according to
the recommendations made. The action plan shall include detailed activities along
with timeline.
• GRC Secretary will inform to the complainant about the decisions taken by the
committee members and expected date of resolution of the grievance.
• If the complaint is complex, the GRC may request for additional time and resolution
after proper assessment or refer the complaint to the GRC-second Level.
Step 5: Implementation of Action (30 days)
• The concerned parties will be responsible to implement action plan according to
recommendations of the GRC.
• The GRC members may arrange field trip and interact with the concerned persons,
if needed before reaching the conclusion.
Step 6: Monitoring and Reporting (Monthly)
• The focal person shall be responsible to track and record status of all complaints -
whether forwarded to site engineer or GRC in the database as follows – Grievance
registered, Grievance in process to be resolved, Grievance addressed and closed,
and Grievance forwarded to concerned authorities.
• The focal persons shall be responsible to report/inform status of the complaints
(received, addressed and forwarded) to the contractor for further reporting.
• Overall GRC chairperson shall be responsible for effective management of
complaints at the town level.
Step 7: Closure of the Complaint
• GRC Secretary shall prepare a summary of the findings and share with GRC
members.
• On agreement of all GRC members, GRC Secretary shall provide information to
the complainant about decisions taken in writing/verbal on the registered complaint
and seek feedback of the complainant about the decisions taken. A copy of the
letter shall be kept as record with GRC Secretary and the focal persons.
• Complaint shall be considered closed if all actions have been taken and the
complainant satisfied with the resolution.
47
• GRC Secretary shall prepare a closure report of the grievances handled by GRC
members and the closure shall be documented by the focal person in his register.
Step 8: Appeal to the State level GRC
• In the event that GRC- First and second level cannot make a decision on how to
resolve the complaint, or if a complainant is not satisfied with the actions taken to
resolve the complaint by the lower level GRC, an appeal can be made to third level
GRC either by the GRC Chairperson or complainant directly.
• GRC Chairperson/s of 1st or 2nd level or complainant shall submit an appeal in
writing to the higher level GRC established at third level.
• The third level GRC Secretary shall register the case in consultation with
Chairperson and provide a number of the grievances to be tracked.
• The third level GRC Secretary shall acknowledge the registration of the grievance
to the complainant in writing.
• The Secretary of the GRC shall review the registered grievances and collect
required evidence from relevant parties to present case to the GRC.
• The third level GRC Chairperson shall call a GRC meeting to review the complaint.
GRC members shall get information about the meeting in advance to ensure their
availability in the meeting.
• The third level GRC shall draw conclusions and recommendations based on the
evidence in the meeting. At the same time an action plan shall be developed for
implementation with a timeline.
• The third level GRC Secretary shall communicate decisions of the third level GRC
to the complainant in writing. The copy of the communication shall be kept with the
third level GRC Secretary as record.
• The recommendations shall be implemented immediately.
• Upon completion of the recommended actions, the third level GRC Secretary shall
prepare a report on the closure of the complaint which will be signed by the
complainant and third level GRC Chairperson. A copy of the same shall be kept
for record.
VII. INSTITUTIONAL ARRANGEMENT AND RESPONSIBILITIES
82. The implementation arrangements for the program are summarized in below Table21.
Table 13: Indicative Implementation Arrangements
Aspects Arrangements
November 2023–October 2028 for investment component
Indicative implementation
September 2022–October 2023 for PBL (policy decisions to be taken by
period
MRM)
Indicative completion date July 2029
Management
Existing Institutional Arrangement
21Source: Concept Paper: Proposed Loans India: Maharashtra Tertiary Care and Medical Education Sector
Development Program; Aug-2023
48
A steering committee chaired by chief secretary, Maharashtra government,

with secretary, MEDD, as vice chair. Representatives from Public Health
(i) Oversight body
Department, Planning Department, Finance Department, MEDD
commissioner, and other stakeholders
(ii) Operational Agency Commissioner- DMER (Project Director- MTCMESDP)
Office of Dean assisted by Medical Superintendent and others (like Office
(iii) Facility Level
Superintendent, Sanitary Inspector, Senior Admin Officer)
Proposed Institutional Arrangement for Environmental Safeguard Implementation
- Secretary – MEDD,
(i) Executing agency
- Deputy Secretary-MEDD or as designated by Secretary MEDD
Environmental and Social Safeguard Cell
(ii) Key implementing - Commissioner- DMER (Project Director- MTCMESDP)

agency (IA)/ PMU - Nodal officer (of Joint Director or Assistant Director rank)
- Qualified Environmental Expert
- Qualified Social Expert
Facility Level Environment Unit
- Office of Dean assisted by Medical Superintendent and others (like Office

Superintendent, Sanitary Inspector, Senior Admin Officer assisted by
(iii) Facility Level
Superintendent)
- Qualified Environment Expert, PMC
- Qualified Health and Safety Expert, PMC
- Qualified Environment, Health and Safety Expert, Contractor
MEDD = Medical Education & Drugs Department, MRM = Management Review Meeting, PBL = policy-based lending
Source: Asian Development Bank.
83. For effective implementation of Environmental Safeguard measures in sub-project

lifecycle (i.e., Preconstruction-Construction and Operation Phases) Institutional Setup plays the
pivotal role. Beside implementation of safeguard measures, Institutional Arrangement would also
be necessary to (a) ensure regulatory compliance; (b) ensure supervision and monitoring of
adequacy of safeguard implementation process (c) suggest corrective action (as necessary); (d)
ensure regular reporting to stakeholders including regulators and funding agency; (e) Redressing
Grievances (if any)
84. The existing institutional arrangement is not equipped to ensure environmental safeguard
in Maharashtra Tertiary Care and Medical Education Sector Development Program
(MTCMESDP). The proposed institutional structure for management of environmental safeguards
is provided in Figure 3. The overall responsibility for EMP implementation and compliance with
regulatory requirements would lie with MEDD (Executive Agency). During various phases of sub-
project lifecycle, the other entities like implementing agency (IA)/ PMU, Facility Level
Environmental Unit including Contractor, Project Management Consultant (PMC) will also be
involved in the process of safeguard implementation-supervision-reporting as well as stakeholder
engagement and redressing grievances (as applicable) during the period of their engagement.
49
Figure 3: Institutional Arrangement for Environmental Safeguard Implementation
85. Environmental and Social Safeguard Cell (at IA / PMU): the PMU will form the
Environment and Social Safeguard Cell (ESSC), which will include two ( one qualified
Environment and one qualifies Social officials) experts under the Nodal Officer (of Joint Director
or Assistant Director rank) who will be reporting to Project Director- MTCMESDP (Commissioner-
DMER). The ESSC will be headed by Project Director- MTCMESDP. The qualified environment
expert will have adequate experience in BMWM.
86. Environmental Unit at Facility Level: At facility level, for management of environmental
safeguard measures an Environmental Unit will be formed which will be headed by the Dean of
respective facility. The Medical Superintendent at facility level will be the designated Focal Point
for overall supervision of Environmental Safeguards aspects. One Office Superintendent and
Sanitary inspector will be supporting Medical Superintendent in implementation of EMP on day to
basis. In addition to that, the Environmental Unit will be supported by one Senior Admin Officer
in order to provide secretarial support.
87. Project Management Consultant (PMC), engaged by MEDD will be assisting the
Environmental Unit (at Site/Facility level) in the process of safeguard management till the end of
defect liability period or issuance of project closure report whichever is later.. Qualified
Environment expert with adequate experience in BMWM and Health & Safety (H&S) expert will
be appointed by PMC for each of the facilities for extending handholding support to Environmental
Unit at the facility/site level and to train the Facility Level Environment unit with respect to
safeguard implementation, supervision, and reporting.
50
88. One qualified Environment, One Health and Safety (EHS) experts22 will be appointed at
each site by the Contractors who will be responsible for day-to-day implementation of EMP and
EHS plan.
89. The qualified environmental experts under PMU, Contractor and PMC will be retained till
the end of defect liability period or issuance of project closure report whichever is later..
90. An apex level (state level) committee will be formed for oversighting the safeguard
performance and redressal of grievances if any not resolved at previous levels. The indicative
structure of State Level Committee is provided below
Secretary – MEDD
Deputy Secretary-MEDD or as designated by Secretary MEDD
Additional members as nominated by Secretary – MEDD
91. Indicative Responsibilities of the entities involved in EMP implementation are furnished in
below section.
22
Instead of One Environment Expert and one H&S Expert, an expert with Environment - Health-Safety expertise
may also be considered if the person is qualified enough in terms of qualification and professional experience.
51
Table 14: Indicative Responsibilities - Environmental Safeguard Implementation
Indicative Responsibilities
Medical Superintendent Qualified Environment (with Nodal Officer at State
Qualified Environment (with (Supported by Office adequate experience in Level with overall
adequate experience in BMWM) Superintendent and BMWM) expert in responsibility for
EHS (one at each site),
and H&S expert23 at each Sanitary inspector): Environment Cell, DMER (PD Environmental
Contractor : Full Time
Site/Facility Level: Full Time Full Time involvement24 Office): Full Time Safeguards,
involvement
involvement (PMC) involvement Environment Cell, DMER
(PD Office): Full Time
involvement
• Preparation of site • Facilitate Environmental • Get regular • Assisting the Nodal
• Coordination with
specific Contractor’s Clearance (under purview updates from PMC officer and PD in
Funding Agency
EMP including Health of EIA Notification 2006 and with respect to Environment
and Reporting
and safety (H&S) plan its subsequent status of safeguards related
• Coordination with
• Day to day H&S and amendments) by environment, activities
external regulatory
EMP implementation appointing accredited EIA Health and Safety • Guide the field staff in
authorities
at site during consultant. measures achieving compliance
• Regular
construction stage • Ensuring that the requisites implementation and • Review sub-project
Coordination with
• Securing regulatory clearances for environment regulatory progress reports
Environmental Unit
permits and and labour are at place prior compliance submitted by PMC/
at Facility/Site Level
Maintenance of to commencement of any • Ensuring Contractors/ others
• Allocation of fund
records of regulatory work. compliance to from Environmental
for EMP
permits/approvals prior • Preparation of IEEs for conditions Unit at Facility/Site
implementation
to and during respective sub-projects and precedents Level
• Get regular updates
construction phase updating the IEEs to stipulated by • Final Review of CEMP/
from site level on
• Conduct incorporate EC conditions, regulators as part EHS plans prepared by
of regulatory
Environmental changes in scope or Contractor and first
permits/clearances. compliance and
Monitoring during unanticipated impacts, if review by PMC.
EMP
construction phase any • Ensuring day to • Assist in obtaining and
Implementation
• Provide required • Review of CEMP/ EHS day management renewing statutory
of waste (including • Taking decision on
data/information for plans prepared by permissions that are
corrective
Monitoring Reporting Contractor biomedical waste)
Under PMC, one for each site if different PMC’s are hired
23
24
Post release of PMC and Contractor, the safeguard implementation-supervision-monitoring-reporting work (including biomedical waste, other waste and effluent
management), and compliance to regulatory requirements will be ensured by Medical Superintendent with supported of Office Superintendent and Sanitary inspector.
52
involvement
involvement
to PMC and others in • Day to day Monitoring of and effluent in a required to be taken by measures (if
Environmental Unit at EMP and Health and safety regulatory the DMER required)
Facility Level (H&S) implementation work compliant manner • Preparation of • Ensure formation of
• Submit monthly of contractor and as per the Environmental GRM
progress report to • Provide guidance to the provisions of EMP. Monitoring Report • Ensure functionality
PMC/ others of contractor for achieving • Regular • Participate in GRM of GRM
Environmental Unit at compliances coordination with • Ensure GRM remain • Participate in GRM
Facility Level including • Maintenance of records on PD office towards functional through • Review the semi-
EHS compliances regulatory providing input in implementation period annual EMR and
• Establish and permits/approvals taken by preparation of • Participate in put up for PD’s
participate in GRM contractor during Monitoring Reports Stakeholder approval before
• Participate in construction phase and sharing consultations submission to ADB
Stakeholder • Identify areas where records on • Review of IEE/ updated though MEDD.
Engagement specific mitigation measure regulatory IEEs of each sub-
is needed from safeguard permits/approvals. project and put up to the
point of view (Corrective • Participate in GRM Nodal officer for
Action Plan) during
• Ensure GRM concurrence and further
construction stage due to
underperformance by remain functional submission to ADB
contractor’s EMP, H&S through through the PD for
implementation practice implementation review and clearance.
• EMP implementation, period
Environmental Monitoring • Participate in
and compliance to Stakeholder
regulatory norms during consultations
operation phase
• Provide inputs for
preparation of Semi-
Annual/Annual
53
involvement
involvement
Environmental Monitoring
Report (that will include
H&S components)
• Participate in GRM
• Ensure GRM remain
functional through
implementation period
• Participate in Stakeholder
consultations
• Provide requisite trainings
to facility level staff on
environment safeguards
requirements compliances
for both construction and
operations
54
VIII. MONITORING AND REPORTING
92. An environmental monitoring program (EMoP) will be developed as part of the EMP.
Environmental monitoring during sub-project implementation is required to assess performance
against agreed standards and criteria, identify any environmental harm and non-compliance
issues, provide data to support compliance, and meet government approval and permit conditions
and ADB requirements.
93. As with mitigation measures, the monitoring program needs to be designed for the sub-
projects should be commensurate with the sub-project’s impacts and risks and focus on the
indicators of compliance for significant issues. The design of the monitoring program may start
with the obligations stated in government approval and permit conditions but with additions made
to ensure comprehensiveness. Depending on the sub-project, the monitoring program specifies
the parameters to be measured, monitoring/measurement methods, sampling locations,
frequency of measurements, performance indicators or targets, detection limits, and thresholds
limits that indicate the need for corrective action. Where external laboratories or other analytical
services are required, National Accreditation Board for Testing and Calibration Laboratories
(NABL) accredited or Ministry of Environment, Forest and Climate Change (MoEFCC) recognized
agencies should be contracted to ensure that measurements and data provided are accurate,
reliable, and defensible.
94. Environmental Monitoring Plan (EMoP): It is expected that project authority and other
concerned entities like Contractor, PMC will ensure and demonstrate compliance with the
regulatory requirements and adhere to the measures as suggested in the EMP document. The
environmental monitoring indicators will be formulated to ensure and demonstrate conformance
with EMP. Monitoring of environmental and health - safety parameters and comparing them with
benchmarks set by regulatory authorities will help the project authority to assess the safeguard
performance and identify gaps or non-conformance and ensuring immediate actions. The
following indicators/ parameters as mentioned below will be monitored during various phases of
sub-project life cycle to assess the adequacy of safeguard implementation works and to take
further necessary action in case desired performance is not achieved. Based on site specific
considerations, additional indicators and/or monitoring parameters will further be added based
on findings of site-specific IEE/s. The cost for implementation of EMoP will be budgeted in the
EMP and Bill of Quantities (BOQs).
Table 15: Environmental Monitoring Plan1
Implementation Supervision
Sl. Key Monitoring Period & Sampl responsibili
Responsibility
NO Indicators Parameter Frequency e Size ty
Construction Phase (assuming 2 Years)
Ambient Air Measurement of Once in each 24 nos Contractor PMC,

1.
Quality PM10, PM2.5, season at 4 through NABL DMER,
SO2, NOx, CO locations (except accredited/ MEDD
monsoon) MoEFCC
registered
1 Based on consideration of site specific requirements and/or requirement of regulatory authorities the Key Indicators,
Monitoring Parameters, Period, number of Location and Frequency (subsequently sample size) will further be
strengthened.
55
Responsibility
monitoring
laboratory
Ambient Measurement of Once in each 32 nos. Contractor PMC,
2.
Noise Noise Pressure season at 4 through NABL DMER,
quality Level in dB(A) locations accredited/ MEDD
MoEFCC
registered
monitoring
laboratory
Ground Key Once in each 16 nos. Contractor PMC,
3.
Water Physicochemical season at 2 through NABL DMER,
quality and and biological locations accredited/ MEDD
Drinking parameters as MoEFCC
Water per IS 10500 registered
(2012) monitoring
laboratory
Surface Key Once in each 16 nos. Contractor PMC,
4.
Water Physicochemical season at 2 through NABL DMER,
quality and biological locations accredited/ MEDD
parameters as MoEFCC
per IS: 2296 registered
Specifications monitoring
laboratory
Soil Quality Soil parameters 16 nos. Contractor PMC,
5. Once in each
viz. pH, SAR, through NABL DMER,
season at least
Water holding accredited/ MEDD
at 2 locations
capacity, MoEFCC
(preferably near
Organic matter, registered
the treated
Conductivity, monitoring
effluent
Organic Carbon, laboratory
discharge
Nitrogen,
points)
Phosphorous,
Potassium
Alkalinity,
Acidity, heavy
metals, trace
metals,
Alkalinity,
Acidity.
EHS audit Regulatory 6 Monthly 4 Contractor PMC,

6.
compliances, through external DMER,
performance auditor MEDD
against EMP
56
Responsibility
Trees Record of tree Quarterly 8 times Contractor PMC,

7.
Cutting/ felling (if DMER,
Green Area applicable) and MEDD
developme plantation;
nt plantation within
premise or any
other suitable
areas in
discussion with
concerned
authority.
Species survival
rate
Traffic Traffic Regularly during Continu Contractor PMC,
8.
safety management construction ous DMER,
arrangeme plan, visual phase MEDD
nts observation;
consultation with
contractor
Accidents records of all Regularly during Continu Contractor PMC,
9.
types of construction ous DMER,
accidents, near phase MEDD
miss records
during
construction
period.
Records of All pertinent to Regularly during Continu Contractor PMC,
10.
Grievance EHS construction ous DMER,
underperforman phase MEDD
ce/concerns
Operation Phase (assuming 3 years)
Ambient Air Measurement of Yearly basis at 2 6 Nos PMC, DMER MEDD
11.
Quality PM10, PM2.5, locations near
SOx, NOx, CO facility premises
Ambient Measurement of Six monthly 12 nos. PMC, DMER MEDD
12.
Noise Noise Pressure basis 2 locations
quality Level in dB(A) near facility
premises
Ground Key Six monthly 12 nos. PMC, DMER MEDD
13.
Water Physicochemical basis 2 locations
quality and and biological near facility
Drinking parameters as premises and
Water per IS 10500 nearby village
(2012)
57
Responsibility
Surface Key Once in each 24 Nos PMC, DMER MEDD

14.
Water Physicochemical season at least
quality and biological at 2 locations
(depending parameters as (preferably near
on per IS: 2296 the treated
availability) Specifications effluent
discharge
points)
Soil Quality Soil parameters Once in each 24 Nos PMC, DMER MEDD
15.
viz. pH, SAR, season at least
Water holding at 2 locations
capacity, (preferably near
Organic matter, the treated
Conductivity, effluent
Organic Carbon, discharge
Nitrogen, points)
Phosphorous,
Potassium
Alkalinity,
Acidity, heavy
metals, trace
metals,
Alkalinity,
Acidity.
Treated The parameters Once in each 24 Nos PMC, DMER MEDD

16.
wastewater as suggested season at 2
generated under BMW discharge
from ETPs rules 2016 and locations
cum STPs its subsequent (number to be
amendments increased in
case there are
more discharge
points)
EHS audit Regulatory Half Yearly 6 times PMC, DMER MEDD
17. compliances,
performance
against EMP
Green area Survival of planted Quarterly 12 PMC, DMER MEDD
18. trees
maintenanc times
e
95. Corrective action. If monitoring identifies a non-conformance against sub-project

approval, permit, underperformance with respect to EMoP Indicators or EMP conditions, the
Executing Agency/Implementing Agency or its contractor may need to develop a corrective action
58
plan to ensure compliance. Corrective actions could range from improving the technical aspects
of mitigation measures to enhancing the environmental management capacity. A corrective action
plan generally:
• describes and prioritizes corrective actions to address each non-conformance
• identifies implementation responsibilities for each corrective action
• identifies a timeline for the implementation of each action
• presents a schedule for communicating the results of plan implementation to
affected communities, government authorities and/or ADB
• Each corrective action should be implemented within the specified time frame.
96. Reporting requirements. The reporting of monitoring results to internal (sub-project

management) and external (authorities, local people, ADB) audiences is required to verify
compliance. ADB requires the borrower/client to prepare periodic monitoring reports
commensurate with the sub-project’s potential risks and impacts. Environment monitoring report
for this Program will be required to be submitted semi-annually to ADB for review and disclosure
till issuance of Project Closure Report. Format for semi-annual monitoring report is provided as
Appendix 6.
97. Staffing and Budget: Budget required for implementing the EARF would cover the
following components:
• conducting environmental assessments of subprojects, preparing and submitting

reports, and public consultation and disclosure;
• application for government regulatory consents, approvals;
• implementation of EMP; Corrective Action (if any) and
• capacity building.
98. The PMC will be involved in preparation of IEE and or Environmental assessment towards
securing environmental clearance with help of experienced environmental specialist and
accredited EIA consultant respectively for conducting the following activities: (i) site visit to assess
environmental conditions and potential impacts of the scheme; (ii) liaison with agencies to obtain
any environmental/social data that might be available locally (e.g. population figures, designated
sites, etc.); (iii) consultation with the local community to inform them about the scheme and identify
their views and concerns; (iv) assessment of impacts and development of mitigation; and (v)
baseline data collection, desk study and report preparation. (vi) activities with respect to securing
environmental clearances.
99. The entities like Contractor, PMC, Facility Level Environment Unit, EA and IA will be
involved in the process of safeguard implementation-supervision-reporting, securing regulatory
permits, capacity building throughout the sub-project lifecycle as elaborated under ‘Institutional
Arrangement and Responsibilities’ Chapter.
100. The indicative costs for EARF implementation are furnished in Table 16.
Table 16: Budget for EARF Implementation
Component Description Involvement Indicative Cost Per Unit (₹)

Staffing
59
Component Description Involvement Indicative Cost Per Unit (₹)

Contractor Qualified Fulltime 15,00,000/person/year
Environment, (till the end of defect liability
Health and period or issuance of project
Safety Expert/s, closure report whichever is
later)
PMC Qualified Health Fulltime 15,00,000/person/year
and Safety (till the end of defect liability
Expert/s, period or issuance of project
closure report whichever is
later)
IA/PMU level Qualified Fulltime 24,00,000/person/year
Environmental (till the end of defect liability
Expert period or issuance of project
closure report whichever is
later)
Regulatory
Permits
Environmental For each sub- Throughout the project To be covered under project cost
Clearance, project lifecycle
Tree Felling
Permission,
CTE/CTO,
Authorization,
Fire NoC etc.
Safeguard
Management
EMP (including For each sub- Throughout the project To be covered under project cost
EMoP project lifecycle and shall be budget in IEE-EMP
implementation, and BoQ
management of
waste, effluent
etc.)
Implementation
Implementation For each sub- Throughout the project To be covered under project cost
of Corrective project (if lifecycle
Actions applicable) (as applicable)
Capacity
Building
Capacity For each sub- Throughout the project 10,00,000 per sub-project (lump
development of project lifecycle intermittently sum)
Environmental
Unit at Facility
Level and
Environmental
and Social
Safeguard Cell
(at IA / PMU) in
environmental
safeguards
aspects
through PMC or
external
trainers
60 Appendix 1
ADB Prohibited Investment Activities List
1. The following do not qualify for Asian Development Bank financing:
i Production or activities involving harmful or exploitative forms of forced labor1 or child

labor2;
ii production of or trade in any product or activity deemed illegal under host country laws
or regulations or international conventions and agreements or subject to international
phaseouts or bans, such as (a) pharmaceuticals,3 pesticides, and herbicides4, (b) ozone-
depleting substances,5 (c) polychlorinated biphenyls6 and other hazardous chemicals,7
(d) wildlife or wildlife products regulated under the Convention on International Trade in
Endangered Species of Wild Fauna and Flora,8 and (e) transboundary trade in waste or
waste products9.
iii production of or trade in weapons and munitions, including paramilitary materials;
iv production of or trade in alcoholic beverages, excluding beer and wine;1010
v production of or trade in tobacco;10
vi gambling, casinos, and equivalent enterprises;10
vii production of or trade in radioactive materials,11 including nuclear reactors and
components thereof;
viii production of, trade in, or use of unbonded asbestos fibers;12
ix commercial logging operations or the purchase of logging equipment for use in primary
tropical moist forests or old-growth forests; and
x marine and coastal fishing practices, such as large-scale pelagic drift net fishing and fine
mesh net fishing, harmful to vulnerable and protected species in large numbers and
damaging to marine biodiversity and habitats.
1 Forced labor means all work or services not voluntarily performed, that is, extracted from individuals under threat of
force or penalty.
2Child labor means the employment of children whose age is below the host country’s statutory minimum age of
employment or employment of children in contravention of International Labor Organization Convention No. 138
“Minimum Age Convention” (www.ilo.org).
3 A list of pharmaceutical products subject to phaseouts or bans is available at http://www.who.int.
4 A list of pesticides and herbicides subject to phaseouts or bans is available at http://www.pic.int.
5 A list of the chemical compounds that react with and deplete stratospheric ozone resulting in the widely publicized
ozone holes is listed in the Montreal Protocol, together with target reduction and phaseout dates. Information is
available at http://www.unep.org/ozone/montreal.shtml
6 A group of highly toxic chemicals, polychlorinated biphenyls are likely to be found in oil-filled electrical transformers,
capacitors, and switchgear dating from 1950 to 1985.

7 A list of hazardous chemicals is available at http://www.pic.int.
8 A list is available at http://www.cites.org.
9 As defined by the Basel Convention; see http://www.basel.int.
10 This does not apply to project sponsors who are not substantially involved in these activities. Not substantially
involved means that the activity concerned is ancillary to a project sponsor's primary operations.
11 This does not apply to the purchase of medical equipment, quality control (measurement) equipment, and any
equipment for which ADB considers the radioactive source to be trivial and adequately shielded.
12 This does not apply to the purchase and use of bonded asbestos cement sheeting where the asbestos content is
less than 20%.

Appendix 2 61
SAFEGUARDS REQUIREMENTS 1: ENVIRONMENT
A. Introduction
1. Safeguard Requirements 1 outlines the requirements that borrowers/clients are required
to meet when delivering environmental safeguards for projects supported by the Asian
Development Bank (ADB). It discusses the objectives and scope of application and underscores
the requirements for undertaking the environmental assessment process. These requirements
include assessing impacts, planning and managing impact mitigations, preparing environmental
assessment reports, disclosing information and undertaking consultation, establishing a
grievance mechanism, and monitoring and reporting. The document also includes particular
environmental safeguard requirements pertaining to biodiversity conservation and sustainable
management of natural resources, pollution prevention and abatement, occupational and
community health and safety, and conservation of physical cultural resources. The applicability
of particular requirements is established through the environmental assessment process and
compliance with the requirements is achieved through implementation of environmental
management plans agreed to by ADB and the borrower/client.
B. Objective
2. The objectives are to ensure the environmental soundness and sustainability of projects,
and to support the integration of environmental considerations into the project decision-making
process.
C. Scope of Application
3. The requirements apply to all ADB-financed and/or ADB-administered sovereign and non-
sovereign projects, and their components regardless of the source of financing, including
investment projects funded by a loan; and/or a grant; and/or other means, such as equity and/or
guarantees (hereafter broadly referred to as projects).
D. Requirements
1. Environment Assessment
4. Environmental assessment is a generic term used to describe a process of environmental
analysis and planning to address the environmental impacts and risks associated with a project.
At an early stage of project preparation, the borrower/client will identify potential direct, indirect,
cumulative and induced environmental impacts on and risks to physical, biological,
socioeconomic, and physical cultural resources and determine their significance and scope, in
consultation with stakeholders, including affected people and concerned NGOs. If potentially
adverse environmental impacts and risks are identified, the borrower/client will undertake an
environmental assessment as early as possible in the project cycle. For projects with potentially
significant adverse impacts that are diverse, irreversible, or unprecedented, the borrower/client
will examine alternatives to the project’s location, design, technology, and components that would
avoid, and, if avoidance is not possible, minimize adverse environmental impacts and risks. The
rationale for selecting the particular project location, design, technology, and components will be
properly documented, including, cost-benefit analysis, taking environmental costs and benefits of
the various alternatives considered into account. The "no project" alternative will be also
considered.
62 Appendix 2
5. The assessment process will be based on current information, including an accurate

project description, and appropriate environmental and social baseline data. The environmental
assessment will consider all potential impacts and risks of the project on physical, biological,
socioeconomic (occupational health and safety, community health and safety, vulnerable groups
and gender issues, and impacts on livelihoods through environmental media [Appendix 2, para.
6]) and physical cultural resources in an integrated way. The project’s potential environmental
impacts and risks will be reviewed against the requirements presented in this document and
applicable laws and regulations of the jurisdictions in which the project operates that pertain to
environmental matters, including host country obligations under international law.
6. Impacts and risks will be analyzed in the context of the project’s area of influence. This
area of influence encompasses (i) the primary project site(s) and related facilities that the
borrower/client (including its contractors) develops or controls, such as power transmission
corridors, pipelines, canals, tunnels, access roads, borrow pits and disposal areas, and
construction camps; (ii) associated facilities that are not funded as part of the project (funding may
be provided separately by the borrower/client or by third parties), and whose viability and
existence depend exclusively on the project and whose goods or services are essential for
successful operation of the project; (iii) areas and communities potentially affected by cumulative
impacts from further planned development of the project, other sources of similar impacts in the
geographical area, any existing project or condition, and other project-related developments that
are realistically defined at the time the assessment is undertaken; and (iv) areas and communities
potentially affected by impacts from unplanned but predictable developments caused by the
project that may occur later or at a different location. The area of influence does not include
potential impacts that might occur without the project or independently of the project.
Environmental impacts and risks will also be analyzed for all relevant stages of the project cycle,
including preconstruction, construction, operations, decommissioning, and post closure activities
such as rehabilitation or restoration.
7. The assessment will identify potential transboundary effects, such as air pollution,
increased use or contamination of international waterways, as well as global impacts, such as
emission of greenhouse gases and impacts on endangered species and habitats.
8. The environmental assessment will examine whether particular individuals and groups
may be differentially or disproportionately affected by the project’s potential adverse
environmental impacts because of their disadvantaged or vulnerable status, in particular, the
poor, women and children, and Indigenous Peoples. Where such individuals or groups are
identified, the environmental assessment will recommend targeted and differentiated measures
so that adverse environmental impacts do not fall disproportionately on them.
9. Depending on the significance of project impacts and risks, the assessment may comprise
a full-scale environmental impact assessment (EIA) for category A projects, an initial
environmental examination (IEE) or equivalent process for category B projects, or a desk review.
An EIA report includes the following major elements: (i) executive summary, (ii) description of the
project, (iii) description of the environment (with comprehensive baseline data), (iv) anticipated
environmental impacts and mitigation measures, (v) analysis of alternatives, (vi) environmental
management plan(s), (vii) consultation and information disclosure, and (viii) conclusion and
recommendations. The annex to this appendix provides further details. An IEE, with its narrower
scope, may be conducted for projects with limited impacts that are few in number, generally site-
specific, largely reversible, and readily addressed through mitigation measures.
Appendix 2 63
10. Depending on the significance of project impacts and risks, the assessment may comprise
a full-scale environmental impact assessment (EIA) for category A projects, an initial
environmental examination (IEE) or equivalent process for category B projects, or a desk review.
An EIA report includes the following major elements: (i) executive summary, (ii) description of the
project, (iii) description of the environment (with comprehensive baseline data), (iv) anticipated
environmental impacts and mitigation measures, (v) analysis of alternatives, (vi) environmental
management plan(s), (vii) consultation and information disclosure, and (viii) conclusion and
recommendations. The annex to this appendix provides further details. An IEE, with its narrower
scope, may be conducted for projects with limited impacts that are few in number, generally site-
specific, largely reversible, and readily addressed through mitigation measures.
11. When the project involves the development of or changes to policies, plans, or programs
that are likely to have significant environmental impacts that are regional or sectoral, strategic
environmental assessment will be required. A strategic environmental assessment report will
include (i) an analysis of the scenario, (ii) an assessment of long-term and indirect impacts, (iii) a
description of the consultation process, and (iv) an explanation of option selection.
2. Environmental Planning and Management

12. The borrower/client will prepare an environmental management plan (EMP) that
addresses the potential impacts and risks identified by the environmental assessment. The EMP
will include the proposed mitigation measures, environmental monitoring and reporting
requirements, emergency response procedures, related institutional or organizational
arrangements, capacity development and training measures, implementation schedule, cost
estimates, and performance indicators. Where impacts and risks cannot be avoided or prevented,
mitigation measures and actions will be identified so that the project is designed, constructed, and
operated in compliance with applicable laws and regulations and meets the requirements
specified in this document. The level of detail and complexity of the environmental planning
documents and the priority of the identified measures and actions will be commensurate with the
project’s impacts and risks. Key considerations include mitigation of potential adverse impacts to
the level of “no significant harm to third parties”, the polluter pays principle, the precautionary
approach, and adaptive management.
13. If some residual impacts are likely to remain significant after mitigation, the EMP will also
include appropriate compensatory measures (offset) that aim to ensure that the project does not
cause significant net degradation to the environment. Such measures may relate, for instance, to
conservation of habitat and biodiversity, preservation of ambient conditions, and greenhouse gas
emissions. Monetary compensation in lieu of offset is acceptable in exceptional circumstances,
provided that the compensation is used to provide environmental benefits of the same nature and
is commensurate with the project’s residual impact.
14. The EMP will define expected outcomes as measurable events to the extent possible and
will include performance indicators or targets that can be tracked over defined periods. It will be
responsive to changes in project design, such as a major change in project location or route, or
in technology, unforeseen events, and monitoring results.
15. At times, a third party’s involvement will influence implementation of the EMP. A third party
may be, inter alia, a government agency, a contractor, or an operator of an associated facility.
When the third-party risk is high and the borrower/client has control or influence over the actions
and behavior of the third party, the borrower/client will collaborate with the third party to achieve
64 Appendix 2
the outcome consistent with the requirements for the borrower/client. Specific actions will be
determined on a case-by-case basis.
16. The borrower/client will use qualified and experienced experts to prepare the
environmental assessment and the EMP. For highly complex and sensitive projects, independent
advisory panels of experts not affiliated with the project will be used during project preparation
and implementation.
3. Information Disclosure
17. The borrower/client will submit to ADB the following documents for disclosure on ADB’s
website:
(i) a draft full EIA (including the draft EMP) at least 120 days prior to ADB Board
consideration, and/or environmental assessment and review frameworks before
project appraisal, where applicable;
(ii) the final EIA/IEE;
(iii) a new or updated EIA/IEE and corrective action plan prepared during project
implementation, if any; and
(iv) the environmental monitoring reports.
18. The borrower/client will provide relevant environmental information, including information
from the documents in para. 17 in a timely manner, in an accessible place and in a form and
language(s) understandable to affected people and other stakeholders. For illiterate people, other
suitable communication methods will be used.
4. Consultation and Participation

19. The borrower/client will carry out meaningful consultation with affected people and other
concerned stakeholders, including civil society, and facilitate their informed participation.
Meaningful consultation is a process that (i) begins early in the project preparation stage and is
carried out on an ongoing basis throughout the project cycle;1 (ii) provides timely disclosure of
relevant and adequate information that is understandable and readily accessible to affected
people; (iii) is undertaken in an atmosphere free of intimidation or coercion; (iv) is gender inclusive
and responsive, and tailored to the needs of disadvantaged and vulnerable groups; and (v)
enables the incorporation of all relevant views of affected people and other stakeholders into
decision making, such as project design, mitigation measures, the sharing of development
benefits and opportunities, and implementation issues. Consultation will be carried out in a
manner commensurate with the impacts on affected communities. The consultation process and
its results are to be documented and reflected in the environmental assessment report.
5. Grievance Redress Mechanism

20. The borrower/client will establish a mechanism to receive and facilitate resolution of
affected peoples’ concerns, complaints, and grievances about the project’s environmental
performance. The grievance mechanism should be scaled to the risks and adverse impacts of the
project. It should address affected people's concerns and complaints promptly, using an
understandable and transparent process that is gender responsive, culturally appropriate, and
readily accessible to all segments of the affected people at no costs and without retribution. The
Appendix 2 65
mechanism should not impede access to the country’s judicial or administrative remedies. The
affected people will be appropriately informed about the mechanism.
6. Monitoring and Reporting

21. The borrower/client will monitor and measure the progress of implementation of the EMP.
The extent of monitoring activities will be commensurate with the project’s risks and impacts. In
addition to recording information to track performance, the borrower/client will undertake
inspections to verify compliance with the EMP and progress toward the expected outcomes. For
projects likely to have significant adverse environmental impacts, the borrower/client will retain
qualified and experienced external experts or qualified NGOs to verify its monitoring information.
The borrower/client will document monitoring results, identify the necessary corrective actions,
and reflect them in a corrective action plan. The borrower/client will implement these corrective
actions and follow up on these actions to ensure their effectiveness.
22. The borrower/client will prepare periodic monitoring reports that describe progress with
implementation of the EMP and compliance issues and corrective actions, if any. The
borrower/client will submit at least semiannual monitoring reports during construction for projects
likely to have significant adverse environmental impacts, and quarterly monitoring reports for
highly complex and sensitive projects. For projects likely to have significant adverse
environmental impacts during operation, reporting will continue at the minimum on an annual
basis. Such periodic reports will be posted in a location accessible to the public. Project budgets
will reflect the costs of monitoring and reporting requirements.
7. Unanticipated Environmental Impacts

23. Where unanticipated environmental impacts become apparent during project
implementation, the borrower/client will update the environmental assessment and EMP or
prepare a new environmental assessment and EMP to assess the potential impacts, evaluate the
alternatives, and outline mitigation measures and resources to address those impacts.
8. Biodiversity Conservation and Sustainable Natural Resource Management

24. The borrower/client will assess the significance of project impacts and risks on
biodiversity2 and natural resources as an integral part of the environmental assessment process
specified in paras. 4–10. The assessment will focus on the major threats to biodiversity, which
include destruction of habitat and introduction of invasive alien species, and on the use of natural
resources in an unsustainable manner. The borrower/client will need to identify measures to
avoid, minimize, or mitigate potentially adverse impacts and risks and, as a last resort, propose
compensatory measures, such as biodiversity offsets, to achieve no net loss or a net gain of the
affected biodiversity.
a) Modified Habitats
25. In areas of modified habitat, where the natural habitat has apparently been altered, often
through the introduction of alien species of plants and animals, such as in agricultural areas, the
borrower/client will exercise care to minimize any further conversion or degradation of such
habitat, and will, depending on the nature and scale of the project, identify opportunities to
enhance habitat and protect and conserve biodiversity as part of project operations.
66 Appendix 2
b) Natural Habitats
26. In areas of natural habitat,1 the project will not significantly convert or degrade2 such
habitat, unless the following conditions are met:
(i) No alternatives are available.
(ii) A comprehensive analysis demonstrates that the overall benefits from the
project will substantially outweigh the project costs, including environmental
costs.
(iii) Any conversion or degradation is appropriately mitigated.

27. Mitigation measures will be designed to achieve at least no net loss of biodiversity. They
may include a combination of actions, such as post project restoration of habitats, offset of losses
through the creation or effective conservation of ecologically comparable areas that are managed
for biodiversity while respecting the ongoing use of such biodiversity by Indigenous Peoples or
traditional communities, and compensation to direct users of biodiversity.
c) Critical Habitats
28. No project activity will be implemented in areas of critical habitat3 unless the following
requirements are met:
(i) There are no measurable adverse impacts, or likelihood of such, on the critical
habitat which could impair its high biodiversity value or the ability to function.
(ii) The project is not anticipated to lead to a reduction in the population of any
recognized endangered or critically endangered species4 or a loss in area of
the habitat concerned such that the persistence of a viable and representative
host ecosystem be compromised.
(iii) Any lesser impacts are mitigated in accordance with para. 27.
29. When the project involves activities in a critical habitat, the borrower/client will retain
qualified and experienced external experts to assist in conducting the assessment.
1 Land and water areas where the biological communities are formed largely by native plant and animal species, and
where human activity has not essentially modified the area’s primary ecological functions.
2 Significant conversion or degradation is (i) the elimination or severe diminution of the integrity of a habitat caused by
a major, long-term change in land or water use; or (ii) the modification of a habitat that substantially reduces the
habitat’s ability to maintain viable populations of its native species. Significant conversion may include, for example,
land clearing; replacement of natural vegetation (for example, by crops or tree plantations); permanent flooding (by
a reservoir for instance); drainage, dredging, filling, or canalization of wetlands; or surface mining.
3 Critical habitat is a subset of both natural and modified habitat that deserves particular attention. Critical habitat
includes areas with high biodiversity value, including habitat required for the survival of critically endangered or
endangered species; areas having special significance for endemic or restricted-range species; sites that are critical
for the survival of migratory species; areas supporting globally significant concentrations or numbers of individuals
of congregatory species; areas with unique assemblages of species or that are associated with key evolutionary
processes or provide key ecosystem services; and areas having biodiversity of significant social, economic, or
cultural importance to local communities. Critical habitats include those areas either legally protected or officially
proposed for protection, such as areas that meet the criteria of the World Conservation Union classification, the
Ramsar List of Wetlands of International Importance, and the United Nations Educational, Scientific, and Cultural
Organization’s world natural heritage sites.
4 As defined by the Word Conservation Union’s Red List of Threatened Species or as defined in any national legislation.
Appendix 2 67
d) Legally Protected Areas

30. In circumstances where some project activities are located within a legally protected area,
in addition to the requirement specified in para. 28, the borrower/client will meet the following
requirements:
(i) Act in a manner consistent with defined protected area management plans.
(ii) Consult protected area sponsors and managers, local communities, and other
key stakeholders on the proposed project.
(iii) Implement additional programs, as appropriate, to promote and enhance the

conservation aims of the protected area.
e) Invasive Alien Species
31. The borrower/client will not intentionally introduce any new alien species (that is, species
not currently established in the country or region of the project) unless carried out in accordance
with the existing regulatory framework for such introduction, if such a framework is present, or
unless the introduction is subject to a risk assessment (as part of the environmental assessment)
to determine the potential for invasive behavior. Under no circumstances must species known to
be invasive be introduced into new environments. The borrower/client will undertake assessment
of the possibility of accidental or unintended introduction of such invasive alien species and
identify measures to minimize the potential for release.
f) Management and Use of Renewable Natural Resources

32. Renewable natural resources will be managed in a sustainable manner. Sustainable
resource management is management of the use, development, and protection of resources in a
way, or at a rate, that enables people and communities, including Indigenous Peoples, to provide
for their current social, economic, and cultural well-being while also sustaining the potential of
those resources to meet the reasonably foreseeable needs of future generations. This includes
safeguarding the life-supporting capacity of air, water, and soil ecosystems. Where possible, the
borrower/client will demonstrate the sustainable management of resources through an
appropriate system of independent certification.
9. Pollution Prevention and Abatement

33. During the design, construction, and operation of the project the borrower/client will apply
pollution prevention and control technologies and practices consistent with international good
practice, as reflected in internationally recognized standards such as the World Bank Group’s
Environment, Health and Safety Guidelines.5 These standards contain performance levels and
measures that are normally acceptable and applicable to projects. When host country regulations
differ from these levels and measures, the borrower/client will achieve whichever is more
stringent. If less stringent levels or measures are appropriate in view of specific project
circumstances, the borrower/client will provide full and detailed justification for any proposed
alternatives that are consistent with the requirements presented in this document.
a) Pollution Prevention, Resource Conservation, and Energy Efficiency

34. The borrower/client will avoid, or where avoidance is impossible, will minimize or control
the intensity or load of pollutant emission and discharge. In addition the borrower/client will
5 World Bank Group, 2007. Environmental, Health, and Safety General Guidelines. Washington, DC.
68 Appendix 2
examine and incorporate in its operations resource conservation and energy efficiency measures
consistent with the principles of cleaner production. When the project has the potential to
constitute a significant source of emissions in an already degraded area, strategies that help
improve ambient conditions, such as evaluating alternative project locations and considering
emissions offsets, will be introduced.
b) Wastes
35. The borrower/client will avoid, or where avoidance is not possible, will minimize or control
the generation of hazardous and nonhazardous wastes and the release of hazardous materials
resulting from project activities. Where waste cannot be recovered or reused, it will be treated,
destroyed, and disposed of in an environmentally sound manner. If the generated waste is
considered hazardous, the client will explore reasonable alternatives for its environmentally sound
disposal considering the limitations applicable to its transboundary movement.6 When waste
disposal is conducted by third parties, the borrower/client will use contractors that are reputable
and legitimate enterprises licensed by the relevant regulatory agencies.
c) Hazardous Materials
36. The borrower/client will avoid the manufacture, trade, and use of hazardous substances
and materials subject to international bans or phaseouts because of their high toxicity to living
organisms, environmental persistence, potential for bioaccumulation, or potential for depletion of
the ozone layer7 and will consider the use of less hazardous substitutes for such chemicals and
materials.
d) Pesticide Use and Management
37. The environmental assessment will ascertain that any pest and/or vector management
activities related to the project are based on integrated pest management approaches and aim to
reduce reliance on synthetic chemical pesticides in agricultural and public health projects. The
borrower/client’s integrated pest/vector management program will entail coordinated use of pest
and environmental information along with available pest/vector control methods, including cultural
practices, biological, genetic and, as a last resort, chemical means to prevent unacceptable levels
of pest damage. The health and environmental risks associated with pest management should be
minimized with support, as needed, to institutional capacity development, to help regulate and
monitor the distribution and use of pesticides and enhance the application of integrated pest
management.
38. The borrower/client will not use products that fall in World Health Organization
Recommended Classification of Pesticides by Hazard Classes Ia (extremely hazardous) and Ib
(highly hazardous) or Class II (moderately hazardous), if the project host country lacks restrictions
on distribution and use of these chemicals, or if they are likely to be accessible to personnel
without proper training, equipment, and facilities to handle, store, apply and dispose of these
products properly. The borrower/client will handle, store, apply and dispose of pesticides in
accordance with international good practice such as the Food and Agricultural Organization’s
International Code of Conduct on the Distribution and Use of Pesticides.
6 Consistent with the objectives of the Basel Convention on the Control of Transboundary Movements of Hazardous
Wastes.
7 Consistent with the objectives of the Stockholm Convention on Persistent Organic Pollutants and the Montreal
Protocol on Substances that Deplete the Ozone Layer.
Appendix 2 69
e) Greenhouse Gas Emissions

39. The borrower/client will promote the reduction of project-related anthropogenic
greenhouse gas emissions in a manner appropriate to the nature and scale of project operations
and impacts. During the development or operation of projects that are expected to or currently
produce significant quantities of greenhouse gases,8 the borrower/client will quantify direct
emissions from the facilities within the physical project boundary and indirect emissions
associated with the off-site production of power used by the project. The borrower/client will
conduct quantification and monitoring of greenhouse gas emissions annually in accordance with
internationally recognized methodologies.9 In addition, the borrower/client will evaluate technically
and financially feasible and cost-effective options to reduce or offset project-related greenhouse
gas emissions during project design and operation and pursue appropriate options.
10. Health and Safety

a) Occupational Health and Safety
40. The borrower/client will provide workers10 with a safe and healthy working environment,
taking into account risks inherent to the particular sector and specific classes of hazards in the
borrower’s/client’s work areas, including physical, chemical, biological, and radiological hazards.
The borrower/client will take steps to prevent accidents, injury, and disease arising from,
associated with, or occurring during the course of work by (i) identifying and minimizing, so far as
reasonably practicable, the causes of potential hazards to workers; (ii) providing preventive and
protective measures, including modification, substitution, or elimination of hazardous conditions
or substances; (iii) providing appropriate equipment to minimize risks and requiring and enforcing
its use; (iv) training workers and providing them with appropriate incentives to use and comply
with health and safety procedures and protective equipment; (v) documenting and reporting
occupational accidents, diseases, and incidents; and (vi) having emergency prevention,
preparedness, and response arrangements in place.
41. The borrower/client will apply preventive and protective measures consistent with
international good practice, as reflected in internationally recognized standards such as the World
Bank Group’s Environment, Health and Safety Guidelines (footnote 7).
b) Community Health and Safety

42. The borrower/client will identify and assess the risks to, and potential impacts on, the
safety of affected communities during the design, construction, operation, and decommissioning
of the project, and will establish preventive measures and plans to address them in a manner
commensurate with the identified risks and impacts. These measures will favor the prevention or
avoidance of risks and impacts over their minimization and reduction. Consideration will be given
to potential exposure to both accidental and natural hazards, especially where the structural
elements of the project are accessible to members of the affected community or where their failure
could result in injury to the community. The borrower/client will avoid or minimize the exacerbation
8 Even though the significance of a project’s contribution to greenhouse gas emissions varies between industry sectors,
the significance threshold to be considered for these requirements is generally 100,000 tons of carbon dioxide
equivalent per year for the aggregate emissions of direct sources and indirect sources associated with electricity
purchased for own consumption.
9 Estimation methodologies are provided by the Intergovernmental Panel on Climate Change (IPCC), various
international organizations, and relevant host country agencies.

10 Including nonemployee workers engaged by the borrower/client through contractors or other intermediaries to work
on project sites or perform work directly related to the project’s core functions.
70 Appendix 2
of impacts caused by natural hazards, such as landslides or floods, that could result from land
use changes due to project activities.
43. The borrower/client will inform affected communities of significant potential hazards in a
culturally appropriate manner. The borrower/client will be prepared to respond to accidental and
emergency situations. This preparation will include response planning document(s) that
addresses the training, resources, responsibilities, communications, procedures, and other
aspects required to respond effectively to emergencies associated with project hazards.
Appropriate information about emergency preparedness and response activities, resources, and
responsibilities will be disclosed to affected communities.
44. When structural elements or components, such as dams, tailings dams, or ash ponds, are
situated in high-risk locations and their failure or malfunction may threaten the safety of
communities, the borrower/client will engage qualified and experienced experts, separate from
those responsible for project design and construction, to conduct a review as early as possible in
project development and throughout project design, construction, and commissioning.
11. Physical Cultural Resources

45. The borrower/client is responsible for siting and designing the project to avoid significant
damage to physical cultural resources.11 Such resources likely to be affected by the project will
be identified, and qualified and experienced experts will assess the project’s potential impacts on
these resources using field-based surveys as an integral part of the environmental assessment
process specified in paras. 4–10.
46. When a project may affect physical cultural resources, the borrower/client will consult with
affected communities who use, or have used them within living memory, for long-standing cultural
purposes to identify physical cultural resources of importance and to incorporate the views of the
affected communities on such resources into the borrower’s/client’s decision-making process.
Consultation will also involve relevant national or local regulatory agencies that are entrusted with
protecting physical cultural resources. The findings are disclosed as part of, and in the same
manner as, the environmental assessment report, except when such disclosure would
compromise or jeopardize the safety or integrity of the physical cultural resources.
47. When the project is likely to have adverse impacts on physical cultural resources, the
borrower/client will identify appropriate measures for avoiding or mitigating these impacts as part
of the environmental planning process specified in paras. 12–16. These measures may range
from avoidance to full site protection to selective mitigation, including salvage and documentation,
in cases where a portion or all of the physical cultural resources may be lost.
48. When the proposed location of a project is in areas where physical cultural resources are
expected to be found as determined during the environmental assessment process, chance finds
procedures will be included in the EMP. Chance finds will not be disturbed until an assessment
by a competent specialist is made and actions consistent with these requirements are identified.
49. The project will not remove any physical cultural resources unless the following conditions
are met:
11 Defined as movable or immovable objects, sites, structures, groups of structures, and natural features and
landscapes that have archaeological, paleontological, historical, architectural, religious, aesthetic, or other cultural
significance. Physical cultural resources may be located in urban or rural settings and may be above or below ground
or under water. Their cultural interest may be at the local, provincial, national, or international level.
Appendix 2 71
(iv) No alternatives to removal are available.
(v) The overall benefits of the project substantially outweigh the anticipated
cultural heritage loss from removal.
(vi) Any removal is conducted in accordance with relevant provisions of national

and/or local laws, regulations, and protected area management plans and
national obligations under international laws and employs the best available
techniques.
72 Appendix 2
OUTLINE OF AN ENVIRONMENTAL IMPACT ASSESSMENT REPORT
1. This outline is part of the Safeguard Requirements 1. An environmental assessment

report is required for all environment category A and B projects. Its level of detail and
comprehensiveness is commensurate with the significance of potential environmental impacts
and risks. A typical EIA report contains the following major elements, and an IEE may have a
narrower scope depending on the nature of the project. The substantive aspects of this outline
will guide the preparation of environmental impact assessment reports, although not necessarily
in the order shown.
A. Environment Assessment
2. This section describes concisely the critical facts, significant findings, and recommended
actions.
B. Policy, Legal, and Administrative Framework

3. This section discusses the national and local legal and institutional framework within which
the environmental assessment is carried out. It also identifies project-relevant international
environmental agreements to which the country is a party.
C. Description of the Project

4. This section describes the proposed project; its major components; and its geographic,
ecological, social, and temporal context, including any associated facility required by and for the
project (for example, access roads, power plants, water supply, quarries and borrow pits, and
spoil disposal). It normally includes drawings and maps showing the project’s layout and
components, the project site, and the project's area of influence.
D. Description of the Environment (Baseline Data)

5. This section describes relevant physical, biological, and socioeconomic conditions within
the study area. It also looks at current and proposed development activities within the project's
area of influence, including those not directly connected to the project. It indicates the accuracy,
reliability, and sources of the data.
E. Anticipated Environmental Impacts and Mitigation Measures

6. This section predicts and assesses the project's likely positive and negative direct and
indirect impacts to physical, biological, socioeconomic (including occupational health and safety,
community health and safety, vulnerable groups and gender issues, and impacts on livelihoods
through environmental media [Appendix 2, para. 6]), and physical cultural resources in the
project's area of influence, in quantitative terms to the extent possible; identifies mitigation
measures and any residual negative impacts that cannot be mitigated; explores opportunities for
enhancement; identifies and estimates the extent and quality of available data, key data gaps,
and uncertainties associated with predictions and specifies topics that do not require further
attention; and examines global, transboundary, and cumulative impacts as appropriate.
F. Analysis of Alternatives
7. This section examines alternatives to the proposed project site, technology, design, and
operation—including the no project alternative—in terms of their potential environmental impacts;
Appendix 2 73
the feasibility of mitigating these impacts; their capital and recurrent costs; their suitability under
local conditions; and their institutional, training, and monitoring requirements. It also states the
basis for selecting the particular project design proposed and, justifies recommended emission
levels and approaches to pollution prevention and abatement.
G. Information Disclosure, Consultation, and Participation

8. This section:
(i) describes the process undertaken during project design and preparation for engaging
stakeholders, including information disclosure and consultation with affected people
and other stakeholders;
(ii) summarizes comments and concerns received from affected people and other
stakeholders and how these comments have been addressed in project design and
mitigation measures, with special attention paid to the needs and concerns of
vulnerable groups, including women, the poor, and Indigenous Peoples; and
(iii) describes the planned information disclosure measures (including the type of
information to be disseminated and the method of dissemination) and the process for
carrying out consultation with affected people and facilitating their participation during
project implementation.
H. Grievance Redress Mechanism

9. This section describes the grievance redress framework (both informal and formal
channels), setting out the time frame and mechanisms for resolving complaints about
environmental performance.
I. Environmental Management Plan

10. This section deals with the set of mitigation and management measures to be taken during
project implementation to avoid, reduce, mitigate, or compensate for adverse environmental
impacts (in that order of priority). It may include multiple management plans and actions. It
includes the following key components (with the level of detail commensurate with the project’s
impacts and risks):
(i) Mitigation:
a. identifies and summarizes anticipated significant adverse environmental
impacts and risks;
b. describes each mitigation measure with technical details, including the type
of impact to which it relates and the conditions under which it is required (for
instance, continuously or in the event of contingencies), together with designs,
equipment descriptions, and operating procedures, as appropriate; and
c. provides links to any other mitigation plans (for example, for involuntary
resettlement, Indigenous Peoples, or emergency response) required for the
project.
(ii) Monitoring:
a. describes monitoring measures with technical details, including parameters to
be measured, methods to be used, sampling locations, frequency of
measurements, detection limits and definition of thresholds that will signal the
need for corrective actions; and
74 Appendix 2
b. describes monitoring and reporting procedures to ensure early detection of

conditions that necessitate particular mitigation measures and document the
progress and results of mitigation.
(iii) Implementation arrangements:
c. specifies the implementation schedule showing phasing and coordination with
overall project implementation;
d. describes institutional or organizational arrangements, namely, who is
responsible for carrying out the mitigation and monitoring measures, which
may include one or more of the following additional topics to strengthen
environmental management capability: technical assistance programs,
training programs, procurement of equipment and supplies related to
environmental management and monitoring, and organizational changes; and
e. estimates capital and recurrent costs and describes sources of funds for
implementing the environmental management plan.
(iv) Performance indicators: describes the desired outcomes as measurable events to the
extent possible, such as performance indicators, targets, or acceptance criteria that
can be tracked over defined time periods.
J. Conclusion and Recommendation

11. This section provides the conclusions drawn from the assessment and provides
recommendations.
Appendix 4 75
RAPID ENVIRONMENTAL ASSESSMENT CHECKLIST
3.1 Rapid Environmental Assessment (REA) Checklist: General
Instructions:
(i) The project team completes this checklist to support the environmental classification of a project. It is
to be attached to the environmental categorization form and submitted to the Safeguards Division
(SDSS), for endorsement by Director, SDSS and for approval by the Chief Compliance Officer.
(ii) This checklist focuses on environmental issues and concerns and includes an Asbestos Screening
Tool. To ensure that social dimensions are adequately considered, refer also to ADB's: (a) checklists on
involuntary resettlement and Indigenous Peoples; (b) poverty reduction handbook; (c) staff guide to
consultation and participation; and (d) gender checklists.
(iii) Answer the questions assuming the “without mitigation” case. The purpose is to identify potential
impacts. Use the “remarks” section to discuss any anticipated mitigation measures.
Country/Project Title:
Sector Division:
Screening Questions Yes No Remarks

A. Project Siting
Is the Project area adjacent to or
within any of the following
environmentally sensitive areas?
• Cultural heritage site
▪ Legally protected Area (core zone

or buffer zone)
▪ Wetland
▪ CRZ/Mangrove
▪ Estuarine
▪ Special area for protecting
biodiversity (IBA/KBA/potential
habitats)
B. Potential Environmental
Impacts
Will the Project cause…
impairment of historical/cultural areas;

disfiguration of landscape or potential
loss/damage to physical cultural
resources?
disturbance to precious ecology (e.g.
sensitive or protected areas)?
76 Appendix 4

alteration of surface water hydrology of
waterways resulting in increased sediment
in streams affected by increased soil
erosion at construction site ?
deterioration of surface water quality due
to silt runoff and sanitary wastes from
worker-based camps and chemicals used
in construction?
increased air pollution due to project
construction and operation?
noise and vibration due to project
construction or operation?
involuntary resettlement of people?
(physical displacement and/or economic
displacement)
disproportionate impacts on the poor,
women and children, Indigenous Peoples
or other vulnerable groups?
poor sanitation and solid waste disposal in
construction camps and work sites, and
possible transmission of communicable
diseases (such as STIs and HIV/AIDS)
from workers to local populations?
creation of temporary breeding habitats for
diseases such as those transmitted by
mosquitoes and rodents?
social conflicts if workers from other
regions or countries are hired?
large population influx during project
construction and operation that causes
increased burden on social infrastructure
and services (such as water supply and
sanitation systems)?
risks and vulnerabilities related to
occupational health and safety due to
physical, chemical, biological, and
radiological hazards and biomedical waste
disposal during project construction and
operation?
risks to community health and safety due
to the transport, storage, and use and/or
disposal of materials such as explosives,
fuel and other chemicals during
construction and operation?
community safety risks due to both
accidental and natural causes, especially
where the structural elements or
components of the project are accessible
to members of the affected community or
where their failure could result in injury to
the community throughout project
construction, operation and
decommissioning?
Appendix 4 77

generation of solid waste, hazardous
waste and biomedical waste?
use of chemicals?
generation of wastewater during
construction or operation?
78 Appendix 4
ASBESTOS SCREENING TOOL

Remarks
*For those with answers of YES
Yes Maybe
Screening Questions No and MAYBE, document the
* *
potential likelihood of asbestos
being encountered.
Does the proposed project involve, or
potentially involve, any of the following
activities that are commonly associated with
asbestos use:
• Construction/commissioning of a new asset?
• Refurbishment / demolition of an existing
asset?
• Post-disaster response, involving
reconstruction, repair, or removal of
damaged asset?
• Maritime activities?
• Water supply, water sanitation, wastewater,
sewerage, or water hygiene initiatives?
• Earthworks, remedial activities, or solid waste
management?
• Power, telecommunications, or energy supply
infrastructure?
• Maintenance, demolition, transportation, or
disposal of wastes associated with the
above activities?
Note: If you answered YES or MAYBE to the above questions, assume that the project is
likely to encounter asbestos as a direct or indirect result of project-related activities and
proceed to the TOOLKIT FOR SCREENING
ASBESTOS RISKS IN NEW ADB-SUPPORTED PROJECTS PART B – SCREENING TOOLS
AND CHECKLISTS
Appendix 4 79
A Checklist for Preliminary Climate Risk Screening
Country/Project Title:
Sector :
Subsector:
Division/Department:
Screening Questions Score Remarks1

Location Is siting and/or routing of the project (or its components) likely to
and be affected by climate conditions including extreme weather-
Design of related events such as floods, droughts, storms, landslides?
project Would the project design (e.g., the clearance for bridges) need to
consider any hydro-meteorological parameters (e.g., sea-level,
peak river flow, reliable water level, peak wind speed etc.)?
Materials Would weather, current and likely future climate conditions (e.g.,
and prevailing humidity level, temperature contrast between hot
Maintena summer days and cold winter days, exposure to wind and
nce humidity hydro-meteorological parameters likely affect the
selection of project inputs over the life of project outputs (e.g.,
construction material)?
Would weather, current and likely future climate conditions, and
related extreme events likely affect the maintenance (scheduling
and cost) of project output(s)?
Performa Would weather/climate conditions, and related extreme events
nce of likely affect the performance (e.g., annual power production) of
project project output(s) (e.g., hydro-power generation facilities)
outputs throughout their design lifetime?
Options for answers and corresponding score are provided below:
Response Score
Not Likely 0
Likely 1
Very Likely 2
Responses when added that provide a score of 0 will be considered low risk project. If adding all
responses will result to a score of 1-4 and that no score of 2 was given to any single response, the project
will be assigned a medium risk category. A total score of 5 or more (which include providing a score of 1
in all responses) or a 2 in any single response, will be categorized as high-risk project.
Result of Initial Screening (Low, Medium, High):___________
Other
Comments:__________________________________________________________________________
Prepared by: ________________
1 If possible, provide details on the sensitivity of project components to climate conditions, such as how climate parameters are
considered in design standards for infrastructure components, how changes in key climate parameters and sea level might affect the
siting/routing of project, the selection of construction material and/or scheduling, performances and/or the maintenance cost/scheduling
of project outputs.
80 Appendix 4
3.2 Rapid Environmental Assessment (REA) Checklist: GOVERNANCE AND FINANCE
Instructions:
(i) The project team completes this checklist to support the environmental classification of a project.
It is to be attached to the environmental categorization form and submitted to the Safeguards
Division (SDSS) for endorsement by Director, SDSS and for approval by the Chief Compliance
Officer.
(ii) This checklist focuses on environmental issues and concerns. To ensure that social dimensions
are adequately considered, refer also to ADB's: (a) involuntary resettlement and Indigenous
Peoples checklists; (b) poverty reduction handbook; (c) staff guide to consultation and
participation; and (d) gender checklists.
(iii) Answer the questions assuming the “without mitigation” case. The purpose is to identify potential
impacts. Use the “remarks” section to discuss any anticipated mitigation measures.
Country/Project Title: Policy Based component
Sector Division:

A. Does the Project involve a Program √ The project is part of Maharashtra Tertiary Care
Loan or Sector Development and Medical Education Sector Development
Program Loan with Policy Program. The program has two components
Conditions i.e., (a) Investment Component and (b) Policy
Component
Will the policy reforms lead to:
▪ reductions in government expenditure √ No such scenario envisaged for this project as

that will adversely affect the delivery of the program aims to support the state
public services for environmental Maharashtra in a holistic development of
protection, social programs, drought tertiary care and medical education.
relief, food aid, or agricultural extension
services
▪ alterations in the pattern of land use or √ No such changes are envisaged due to the
land use conflicts policy components.
▪ impacts on the environment through √ No such concern envisaged.

increased exploitation of natural
resources (e.g. forests, fisheries,
minerals)
▪ impacts on the environment through √ It is envisaged that the proposed project will not
changes in agricultural inputs (e.g. land, cause any changes in agricultural
water, energy, fertilizer, pesticides, practice/input.
biotechnology, mechanization)
Appendix 4 81

▪ reduced incentive, capability, or √ Not applicable. The project is pertaining to
resources for small and medium size development of greenfield government medical
enterprises (SMEs) to comply with college and hospital to enhance tertiary care
environmental protection laws and and medical education. Therefore, no reduced
regulations incentive, capability, or resources for SMEs to
comply with environmental protection
regulation is envisaged.
▪ dismantling of environmental √ Not applicable. The project is envisaged to be
regulations or changes in the regulatory implemented in compliance to national
framework for environmental regulatory and ADB safeguard requirements.
management
▪ any other policy outcomes that might √ For the policy-based component, no
have major environmental implications environmental impacts are anticipated
B. Does the Project involve a financial √ Not applicable

intermediation component?
Will the project involve:

▪ credit lines through a financial N/A (Not applicable)
intermediary, including micro-finance,
that will finance sub-projects that include
major infrastructure development, be
located at or near an environmentally
sensitive area, alter the pattern of land
use or cause land use conflicts, lead to
the generation of hazardous waste, or
generate significant air or water pollution
▪ equity investments N/A (Not applicable)
C. Does the Project include an investment √ Under the Maharashtra Tertiary Care and
component? Medical Education Sector Development
Program, out of the total ADB contribution of $
500 million, $ 350 million will be for investment
lending and will be used for building or
refurbishing four Government Medical Colleges
(GMCs), Hospital and associated medical
equipment.
▪ Project loan N/A (Not applicable)
▪ Sector loan √ The proposed program aims to support the

state in a holistic development of tertiary care
and medical education using the sector
development program (SDP) modality.
▪ Guarantee N/A (Not applicable)
▪ Equity N/A (Not applicable)
Will the project:

82 Appendix 4

▪ include major infrastructure √ The project proposes building or refurbishing
development? four Government Medical Colleges (GMCs),
Hospital and associated medical equipment
that are covered under the investment
component.
▪ be located at or near an environmentally √ The EARF selection criteria excludes sub-
sensitive area? project activities if any located in
environmentally/ archaeologically sensitive
areas.
▪ alter the pattern of land use or cause √ Land use pattern is envisaged to change only
land use conflicts? due to the investment component and not the
policy component. The change is however not
anticipated to be significant as environmentally
sensitive areas are excluded.
▪ lead to the generation of hazardous √ Not anticipated as part of the policy component
waste?
▪ generate significant air or water √ Not anticipated as part of the policy component
pollution?
▪ cause a large population influx during √ Not anticipated as part of the policy component
project construction and operation that
causes increased burden on social
infrastructure and services (such as
water supply and sanitation systems)?
▪ add infrastructure that can harm √ Not anticipated as part of the policy component
community health and safety when it is
accessed or when it fails?
▪ dislocation or involuntary resettlement of √ Not anticipated as part of the policy component
people?
▪ disproportionate impacts on the poor, √ Not perceived such kind of impact.
women and children, Indigenous
Peoples or other vulnerable groups?
3.3 Environmental and Social Assessment Matrix of Policy based components.
Environmental Social
Mitigating
SI. No. Policy Actions Safeguards Safeguards
Measure/Remarks
Impacts Impacts
1 Introducing performance- No potential No potential This policy action will not
based incentives to GMC environmental impact on IR trigger ADB SPS 2009.
staff from health insurance impact. and IPs. Mitigation measure is
payments to encourage not required.
them to prioritize poor
patients covered by
insurance schemes.
2 Operationalizing a policy for No potential No potential This policy action will not
climate-resilient asset environmental impact on IR trigger ADB SPS 2009.
planning, management, impact. Policy and IPs. Mitigation measure is
and sustainability for action will help to not required.
medical colleges and improve climate
teaching hospitals to and disaster
Appendix 4 83
Mitigating
Measure/Remarks
Impacts Impacts
improve quality, resilience in
sustainability, climate and medical college
disaster resilience, and and tertiary
accountability. hospital
buildings
3 Establishing a robust, No potential No potential This policy action will not
digitally enabled environmental impact on IR trigger ADB SPS 2009.
performance management impact. and IPs. Mitigation measure is
system (with gender- not required.
disaggregated data) to
improve the quality of
health delivery and medical
education covering all
medical colleges.
4 Adopting a comprehensive No potential No potential This investment
new “hire to retire” talent environmental impact on IR component will support
management policy, impact. and IPs. building new medical
including improved colleges to increase the
recruitment rules and supply of doctors in the
recruitment through a state, especially in
dedicated unit at the state underserved districts.
Public Service The government has
Commission. identified four districts to
construct the medical
colleges. There will be
no land acquisition that
will result to physical or
economic displacement.
The construction of new
medical colleges will be
on government land and
no IR impact is
expected. Project
components that would
trigger ADB SPS on IR
are not eligible for
funding under the
program.
5 Setting up a dedicated No potential No potential This policy action will not
agency for the efficient environmental impact on IR trigger ADB SPS 2009.
procurement of medicines impact and IPs. Mitigation measure is
and equipment to support not required.
timely availability of quality
drugs.
6 Establishment of India's No potential No potential This policy action will not
first state-led quality environmental impact on IR trigger ADB SPS 2009.
healthcare and medical impact and IPs. Mitigation measure is
education network of not required.
Centres of Excellence
(COE) under the
Maharashtra University of
Health Sciences as a not-
for-profit company
84 Appendix 4
Mitigating
Measure/Remarks
Impacts Impacts
networked with other public
and private institutes.
7 Implementing a No potential No potential This policy action will not
comprehensive digital environmental impact on IR trigger ADB SPS 2009.
medical education and impact and IPs. Mitigation measure is
health policy, integrating not required.
fragmented systems and
linking with the national Although the program
digital health system. has a statewide scope, it
does not specifically
target IP groups.
Nevertheless, individual
IPs may choose to
access and benefit from
the program's digital
medical education and
health policies
voluntarily.
Conclusion: Based on assessment of policy actions, it observed that the policy-based

components are likely not to cause and adverse impact on the environment. Therefore, the
Environmental category of the program is determined as C for policy-based components.
Appendix 4 85
CHECKLIST FOR CONDUCTING AUDIT/ASSESSMENT OF EXISTING FACILITY

(INDICATIVE AND WILL BE REVISED AS PER SITE CONDITIONS, IF REQUIRED)
Existing status of
S. compliance Details,
Particulars
No. if any
Yes No
A Regulatory Permits/License (as per applicability)
a. Environmental Clearance
1. b. Environment Assessment report prepared for the
Facility as required for obtaining EC
Authorization from State Pollution control Board for

handling of BMW waste as per biomedical waste
management rules (BMWM Rules), 2016 procured
2. by
• Hospital Facility
• Common Biomedical Waste Treatment
Facility (CBWTF)
Documentation and reporting of record of waste

3. generation (especially biomedical waste) as per
BMW rules
4. Permission for Water abstraction/usage
5. Permit of Installation and operation of Incinerator
6. Authorization for storage of Hazardous Waste
Consent to Establish and Consent to Operate from

7.
SPCB under Water and Air Act
8. Permission for discharge of Wastewater/sewage
9. Valid NOC from fire department
Building Stability permit as per National Building

10.
code
Other Regulatory Permits/License (as per

11.
applicability)
Land ownership documents in name of project

12.
authority
B Others
86 Appendix 4
Existing status of
Particulars
No. if any
Yes No
Internal grievance redress mechanism for workers

13.
and community:
Availability of well experienced and trained staffs for

14. Waste (including Biomedical Waste) and wastewater
(sewage and effluent) Management:
Infrastructure availability for

• BMW segregated collection, disinfection,
15. storage, transportation, treatment and final
disposal
• wastewater (sewage and effluent) disinfection
and treatment and final disposal
Mechanism for disposal of other waste (including

16. Hazardous Waste, Plastic, e-waste, municipal solid
waste)
For discharge of wastewater into public sewers

17. confirmation on whether the sewage system is
connected with terminal treatment facilities
Contamination of surrounding environment including

land /water bodies/ groundwater sources/air, if any
18.
due to mis management of any kind of waste
including biomedical wastes?
Any complaints about the site from local community/

patients/staffs or other institutional entities regarding
19.
environmental safeguards (waste management,
spread of infection, spread of diseases etc)?
20. Any case pending in the court of law or arbitration?
Any notice issued (or probes) by the local authority,

21. SPCB, CPCB, Forest Department, or any other
regulatory authority?
Are the conditions stipulated with EC complied by

the facility? Please provide the latest compliance
22.
matrix submitted (uploaded online) to the MoEFCC
as part of regular environmental monitoring.
Appendix 4 87
Existing status of
Particulars
No. if any
Yes No
Monitoring of environment safeguards and waste

23. management done during construction and
operation of such facility
Corrective Action Recommended
Gaps/ Risk/Impact Level Corrective

Timeline for Responsible
Action
Findings (Low/Moderate/High) Recommended closure Entity
88 Appendix 5
GENERIC ENVIRONMENT MANAGEMENT PLAN

(INDICATIVE AND SUB PROJECT SPECIFIC EMPS WILL INCORPORATE THE DETAILS OF VARIOUS PROVISIONS
MENTIONED IN THE GENERIC EMP)
Means of
Timelines/ Responsibility
Potential concerns Mitigation, Management and Verification/ Supervision
Item/ Components Frequency of for
/Impact Enhancement Measures Monitoring Responsibility
Monitoring implementation
Procedure
General (during project lifecycle)
Set-up an integral compliance
Throughout the
management system for ensuring
project lifecycle
Compliance to regulatory regulatory compliance e.g., legal register
Verification of (pre-
requirements, tracking of should be developed for better Contractor,
Legal register Consent /Permit construction, MEDD
compliance to regulatory monitoring of the compliance status of PMC, DMER
documents construction
requirements permits and approvals during pre-
and operational
construction, construction and
phase)
operational phase.
establish a grievance A Grievance Redressal Mechanism
Verification of Before initiation
process for receiving and (GRM) will be developed and
records of registered construction
Grievance Redressal dealing with the concerns implemented to allow the community and Contractor,
grievances and works and MEDD
Mechanism (GRM) and complaints of workers to express their concerns with PMC, DMER
resolution outcomes; throughout
affected public and respect to Environment-Health-Safety
minutes of meetings. project lifecycle
community, if any concerns, if any.
A Stakeholder Engagement Plan (SEP)
may be developed by contractor to
ensure that a consistent, Before initiation
Dissemination of
comprehensive, informed and stakeholder construction
Stakeholder information, engaging Contractor,
coordinated approach is taken up with engagement works and MEDD
Engagement stakeholders in process PMC, DMER
the concerned stakeholders and meetings/workshops. throughout
of decision making
disclosure of information is ensured project lifecycle
throughout the project cycle as and
when required.
Lack of proper planning
- The layout of the facilities will be
may lead to energy
such that the in-patient
inefficiency, cutting of
departments, classrooms and
trees unnecessarily, Compliance with
hostel premises are away from the Before initiation
improper drainage GRIHA, ECBC , NBC
noise generating sources such as construction
system (possibility of criteria and those
Lay out plan and road traffic, pumps, DG sets. works and to Contractor,
runoff being stipulated by EC, MEDD
Building Design - The siting of STP/ETP/ temporary be maintained PMC, DMER
contaminated due to mis Consents,
storage areas of BMW as far as during
management of wastes), authorization letters
possible will be away from the operation stage
lack of water harvesting, etc.
hostel and inpatient departments
contamination of water
and from the residential areas
bodies, emission of odor
around the site.
from treatment plants and
Appendix 5 89
Means of
Procedure
waste storage areas, - Siting of STP/ETP waste storage
disturbance to patients, areas will be avoided in the upwind
students due to noise etc. direction of the hostel, in patient
department and surrounding
residential areas.
- Building layout will be
superimposed on the site features
to avoid clearing trees from the
zones that are not going to be
constructed.
- STP/ETP waste storage areas etc.
will be installed at height above the
high flood level as a precautionary
measure.
- Acoustic building materials for walls,
windows, doors will be propose
based on the assessment of noise
levels, if they are anticipated to be
beyond the standards.
- Acoustic enclosures will be provided
to noise generating sources like DG
sets, pumps etc.
- Roof top rainwater harvesting
structures will be proposed.
- Energy efficiency measures will be
proposed to comply with ECBC.
- Environmental Sustainability
Provisions required for obtaining
GHRIHA rating will be detailed in
the sub-project specific IEE and
EMPs.
- Drainage layout will be well planned
and ensured that it leads the runoff
to a treatment chamber and reused
as much as possible.
Pre-construction phase
o The Contractor to appoint one
Contractor’s Inadequate Safeguard Availability of the before
Environmental expert having relevant
Environment, Health Performance during expert during initiation of site Contractor PMC, MEDD
qualification and adequate
and Safety Expert/s project implementation construction phase; preparation
experience in implementation of
90 Appendix 5
Means of
Procedure
Environmental safeguards in the construction EMP
project till the engagement period of (CEMP), EMP
contractor. Monitoring Report
o The expert to prepare construction
EMP (CEMP) based on ADB cleared
EMP if required to include the site-
specific conditions pertaining to
construction and associated
activities.
o The occupational health and safety
plan for construction site and near by
community will also be prepared in
detail by the Contractor.
o The permits or Certificates from

concerned authorities (i.e.,
Environmental Clearance Tree
Felling Permissions1,, water
abstraction etc.) as applicable prior to
construction
o Consent to Establish and Consent
to Operate (for facilities such as before initiation
Permit document and
Securing applicable crusher, batching plant etc.) should of site
To ensure compliance to integration of related PMC, DMER
Permits/consents from be obtained as appropriate and preparation Contractor
regulatory requirements measures into the /MEDD
concerned authorities terms/conditions mentioned in the and
specific ESMPs
consent must be complied with. construction
o Registration and license to be
obtained as per Contract Labour
(regulation and abolition) Act 1970
or state act and rules
o Registration and license under Inter
State Migrant Worker Act (in case
migrant workers are engaged).
Changed storm water before initiation
Alteration of land o Design of proposed facility
runoff from alterations of Adoption of drainage of site PMC, DMER
contour and drainage components should enable efficient Contractor
the site’s natural plan in project preparation /MEDD
pattern drainage of the sites and maintain
drainage patterns due to and
1 Responsibility of securing Environmental Clearance, tree felling permission, water abstraction permission (if that is to be continued during operation stage) would
lie with Implementation Support Agency hired by DMER
Appendix 5 91
Means of
Procedure
excavation works in the natural drainage patterns to the construction,
sites, construction extent possible. during
o Plan should be in place so that the construction
drainage pattern of surrounding
area is unaffected
o All utilities (including underground
utilities) which are likely to be
affected by the project should be
shifted before start of construction.
o Necessary permission and
before initiation
payments2 should be made to
Disruption of Utility shifting plan, of site
relevant utility service agencies to PMC, DMER
Shifting of Utility utility services to Intimation to local preparation Contractor
allow quick shifting and restoration /MEDD
local community (if any) community and
of utility services
construction
o Local people must be informed in
prior through appropriate means
about the time of shifting of utility
structures and potential disruption
of services if any
before initiation
to ensure Structural Applicable building regulations as per of site
Selection of materials Adoption of Design
stability, visual Maharashtra Regional and Town preparation
and construction Basis Report
aesthetics, ventilation, Planning (MRTP) or other relevant and DMER MEDD
technologies/design developed by the
adequate health and regulation (as per the applicability) construction
project
safety condition should be followed and during
construction
o In case of felling/cutting of any
trees, Permission from competent
authority (Forest Department) Tree Felling
should be obtained. Permission, Green
Monthly Contractor3/ PMC, DMER
Trees Felling of trees (if any) o In consultation with concerned area development
PMC/DMER /MEDD
department compensatory plan, Site Inspection
plantation, green area development
activities should be undertaken
accordingly.
2 Responsibility of making payment to concerned entity would lie with DMER/MEDD

3 In case it is defined so in the Contract document
92 Appendix 5
Means of
Procedure
A rapid response procedure to protect
chance finds while minimizing disruption
to project activities should be in place. It
Before initiation
will include the provisions to:
construction
Accidental discovery of i) consultation with the State
Chance finds works;
Chance find historical and Archaeology Department, PMC, DMER/
procedure, findings Implementation Contractor
procedure archeological ii) demarcation of the discovery site, MEDD
(if any) record throughout the
resource/artefacts iii) chance finds report,
construction
iv) arrival and actions of cultural
period
authority, and
v) suspension/non- suspension/further
suspension of work
o Resettlement Plan/ due diligence
report to be developed as per Resettlement Plan (in
national regulatory requirement and case of physical /
Potential loss of Before initiation
Resettlement and ADB requirements. economic
Livelihood and/or construction PMC/DMER MEDD
Rehabilitation o Compensation and assistance as displacement);
property asset works
per Resettlement Plan/Framework/ disbursement of
ADB SPS, 2009 to be paid, as compensation
applicable
o No works will be initiated by the
contractor until the site induction
training is carried out
Lack of understanding of o Site induction training includes but
potential safeguard not limited to i) discussion and
Site Induction Record of Induction Prior to start of PMC, DMER
concerns and review of EMP detailing specific Contractor
Training Trainings work at site /MEDD
corresponding mitigation environmental risks associated with
measures their Scope of work; how to
manage, requirement of legal
compliances ii) Health and Safety
Awareness
Construction Phase
Conflicts between locals
and labours Contractor to ensure the followings
measures in consideration of the local Visual observation/
Labour Health & Safety and conditions- Site inspection/ PMC, DMER/
Monthly basis Contractor
Camp/Accommodation environmental risks o Construction camps should be consultation with MEDD
related to labour camps established with prior permission labours
leading disruption and from PCB as applicable. Camps will
delay of construction not be established on forest land, low
Appendix 5 93
Means of
Procedure
works and quality of life lying/ flood prone areas and will be
of the labors located as far as possible (say 500 m)
from the habitations, water bodies,
harvesting structures,
environmentally sensitive areas etc.
o Labour camp should comply with ILO
guideline (preferably those ratified by
India).4
o The location, layout and basic facility
of camp will be submitted to and
approved by MEDD/PMC before
establishment.
o Use of fuelwood should be strictly
prohibited at labour
camp/accommodation, Contractor
should ensure supply of alternative
clean fuel such as LPG and common
cooking area with fire safety
provisions in place.
o The building materials used for
camps will be sturdy and safe to
ensure structural safety.
o Provisions of labour camps provided
with individual dwelling units
supported with piped water supply,
o Provision of common toilets/latrines
and bathing facilities duly segregated
for male and female labour
o Provision of First aid facilities, beds,
mosquito repellent/ net, snake
repellent will be made
o Collection of domestic waste and
sewage and proper disposal to be
ensured as per rules
o Labour camp should be developed
outside any forest area. In addition,
living facilities in labour camps are to
be planned to avoid possibility of
4 https://www.ilo.org/wcmsp5/groups/public/---ed_emp/---emp_ent/---multi/documents/publication/wcms_116344.pdf
94 Appendix 5
Means of
Procedure
flooding, any other natural hazards
like forest fire etc.
o Organizing awareness camp on
general health awareness with
medical facility
o Access to complaint register
o Lighting and fencing will be provided.
o Wildlife awareness training should be
provided so that no wildlife in the
region is disturbed.
o Precautions to be taken to protect the
workers from insect/pest to reduce
the risk to health. Use of insecticides
complying with local regulations.
o No liquor or prohibited drugs will be
imported, sold, given to the workers
of host community.
o Awareness raising to immigrant
workers/local community on
communicable and sexually
transmitted diseases such as HIV,
AIDs and others.
o Besides the above, the contractor to
ensure the followings
o Workers will have access to an
adequate and convenient supply of
free potable water that meets
national/local or WHO drinking water
standards,
o All tanks used for the storage of
drinking water should be covered to
prevent water stored therein from
becoming polluted or contaminated,
o Ensure that drinking water quality is
regularly monitored.
Potential Impact on Documentation with
o Strip the top soil and store properly
Sources of natural land Use/ respect to source of
(so that it maintains the organic/ PMC, DMER
construction materials contours, vegetation material; Monthly basis Contractor
inorganic properties of the soil) for /MEDD
clearance, disturbance to permit/clearance
reuse later.
natural drainage documents
Appendix 5 95
Means of
Procedure
patterns, water logging, o Maximize the re-use of earth-cut
and water pollution.) materials, spoils, and construction
debris/wastes.
o Obtain construction materials only
from government-approved
quarries/vendors that are compliance
to the environmental regulations.
o Creation of new borrow areas,
quarries, etc., for the project should
be avoided; if unavoidable, contractor
to obtain all necessary clearances
and permissions in prior
o The contractor to ensure regular
collection and disposal of
construction waste generated
debris, concrete, metal cuttings
waste, waste/used oil etc. through
authorized vendor or by any other
means in compliance with
Demolition and
regulatory requirement.
Waste management
Generation of Contamination of o Collection, storage, handling and
plan, evidence of
Construction and surrounding disposal of Asbestos containing
contracting and PMC, DMER
Demolition Waste and environment, risk to waste/material from the site should Monthly basis Contractor
disposal of C&D /MEDD
disposal of the same community heal and be managed in accordance with rules
waste, record of
(as applicable) safety, poor aesthetics and guidelines on environmental
generation of waste,
management of construction &
visual observation
demolition (C& D) wastes by Central
Pollution Control board (CPCB) and
MoEFCC. Contractor should submit a
demolition plan for the existing
structures/ sheds within the premises
that are likely to demolished for the
proposed development works.
o Obtain details from PHED/ Local
o Onsite
body on location of underground AC
observations &
Health risk due to pipes/ structures.
records As and when PMC, DMER
Asbestos Materials exposure to asbestos o Contractor should conduct a survey Contractor
o Asbestos required /MEDD
materials with the assistance of PHED and /
management
or NP on the presence of existing
Plan
AC pipes/ structures at site.
96 Appendix 5
Means of
Procedure
o If it is found that AC structures are o Reporting of
present during the survey, then the Incidence by
Contractor will prepare a detailed Contractor
SOP for asbestos handling and o Supervision
management. report of
o All AC pipes/ structures will be left in Asbestos
situ and untouched, if possible management in
o In the event, that the asbestos fibers SEMR
from AC structures were
accidentally disturbed/exposed, the
contractor should follow Safe
disposal provisions as per the
USEPA
https://www.epa.gov/asbestos/safe-
work-practices
o Use of AC materials will be strictly
prohibited at site
o The construction site will be
barricaded with temporary dust
capturing and noise attenuating
barriers of adequate height as must
be prescribed in the CTE
o Dust Generation due o Contractor to submit location and
to construction layout plan for storage areas of
activities and construction materials approved by
transport, storage and MEDD/PMC
handling of o Transport, loading and unloading of
construction materials loose and fine materials through
Site Inspection/
o Emission of air covered vehicles. Monthly basis PMC, DMER
Air Quality Document review, Contractor
pollutants (HC, o Provisions for Paved approach /MEDD
monitoring results
SO2,NOX,CO etc.) roads.
from Construction o Storage areas to be located
vehicles and use of downwind of the habitation area.
construction o Water spraying on earthworks,
equipment and unpaved haulage roads and other
machinery dust prone areas.
o Provision of (Personal Protective
Equipment) PPEs to workers.
o Regular maintenance of
machinery and equipment as per
SPCB requirements.
Appendix 5 97
Means of
Procedure
o Batching plants should be located at
downwind ( as far as possible)
direction from the nearest
settlement.
o Batching plants will have dust
screens at the silos, aggregate
batcher, feeder areas of adequate
height.
o Only crushers licensed by the PCB
should be used
o DG sets should be provided with
adequate stack height and use of
low sulphur diesel as fuel.
o LPG should be used as fuel source
in construction camps instead of
wood
o Ambient air quality monitoring
should be taken up at adequate
location on quarterly basis or as per
the recommendation of MPCB or
any other regulatory body
o Contractor to prepare maintain log
book for water sprinkling
o The construction site will be
barricaded with temporary dust
capturing and noise attenuating
barriers of adequate height as must
be prescribed in the CTE
Disturbance to local
o All construction
residents and sensitive
equipment/machineries to be timely
receptors due to
serviced and maintained. Site Inspection,
increased noise and
o Construction equipment and Document review, Monthly basis PMC, DMER
Noise and Vibration vibration from Contractor
machinery to be fitted with silencers Visual observation, /MEDD
construction activities
and maintained properly. monitoring results
and operation of
o Timing of noise generating activities
equipment, machinery
should be restricted during daytime
and construction vehicles
near residential areas
o Noise generating operations may be
taken up intermittently to avoid
exposure to higher noise level for
longer period
98 Appendix 5
Means of
Procedure
o Honking should be restricted near
built-up
o areas
o Provision of PPEs should be kept
for workers
o Noise monitoring should be taken
up at adequate location on quarterly
basis or as per the recommendation
of MPCB or any other regulatory
body
o If blasting is done, prior permission
will be obtained from the competent
authority. Structural assessment of
surrounding building will be done.
Baseline and during blasting
vibration monitoring will be done so
as to ensure no adverse impacts are
there on the surrounding structures/
ground
o Obtain approval/permission from
competent authority if ground water
abstraction through bore well is
carried out or water is sourced from
any other means.
o Stress on water o Permit conditions (if any) should be
resources. made in practice. These should be
o Contamination of included in construction EMP by the
surface and ground contractor.
water with fuel and o To avoid contaminating water, Site Inspection,
Surface and chemical spills; and discharge of hazardous substances, Document review, Monthly PMC, DMER/
Contractor
Groundwater discharge of chemicals, construction material and monitoring results MEDD
wastewater/solid wastes into water courses, drainage
waste from the systems should strictly be prohibited.
construction o Use treated water for water sprinkling
area/construction to optimize usage of water for dust
camps suppression in access/haul roads,
washing of vehicles, concrete mixing,
etc.
o The batching plan will have adequate
capacity sedimentation tank. No
untreated alkaline water from the BP
Appendix 5 99
Means of
Procedure
will be discharged on open and
unlined ground or water bodies.
o Labour engaged in the construction
phase, should be sensitized about
water conservation and encouraged
for optimal use of water
o Maintain water consumption record.
o Collection and disposal of spills
immediately after occurrence of the
event. The oily waste/grease will be
collected and skimmed by oil traps
and handed over to the authorized
agents.
o Contamination of nearby waterbodies
due to surface runoff should be
strictly avoided with the provisions of
necessary measures like silt fencing.
Silt/sediment should be collected and
stockpiled for possible reuse
o Wastes/wastewater generated from
labour camp must be collected at
regular interval and transported to
approved disposal location.
o Provision for water conservation e.g.,
rainwater harvesting at the project
site.
o Monitoring of surface, ground water
quality (also drinking water of
workers) should be taken up at
adequate location on quarterly basis
or as per the recommendation of
MPCB or any other regulatory body.
o Loss of productive o Provision for appropriate storage of
Topsoil due to topsoil pin an appropriate way (to
excavation ensure that the organic / inorganic Site Inspection,
Soil o Soil erosion due to properties of soil are retained) should Document review, Monthly PMC, DMER
Contractor
Construction be made and reused for growing monitoring results /MEDD
activities, earthwork, vegetation.
and cut and fill, o Excavated soil should be reused as
stockpiles etc. much as possible for backfilling,
100 Appendix 5
Means of
Procedure
o Contamination of landscaping and for other project
soil due to leakage/ areas.
spillage of oil, debris o Oil spill kits will be placed at refuelling
generated from areas, DG sets, pump locations etc.
construction o In case of any accidental spill, the soil
activities, poor should be cut and stored securely for
management of disposal with hazardous waste.
effluent and waste o Re-vegetation should be done in the
generated from the area after the completion of
labour camp construction, in order to reduce the
o Compaction of soil risk of soil erosion.
and impact on o As a best practice, site clearance,
access/ haul roads excavation and access road
due to movement of strengthening will not be carried out
vehicles and during the monsoon season to
equipment minimize erosion and run-off.
o Camp site to be restored at the end.
o Storage of hazardous material (like
used oil, oil-soaked cotton/clothes
etc.) in isolated room with impervious
surface must be ensured to avoid
potential soil contamination. The
hazardous waste should be disposed
of through PCB approved Hazardous
Waste Management vendor.
o Construction vehicles, machinery,
and equipment to be stationed in the
designated areas to avoid
compaction
o Approach roads/haulage roads
should be designed along the barren
and hard soil area to reduce the
possibility compaction of fertile soil.
o To avoid soil contamination Oil-
Interceptors will be provided at wash
down and refuelling areas.
o Monitoring of soil quality should be
taken up at adequate location on
quarterly basis or as per the
recommendation of MPCB or any
other regulatory body
Appendix 5 101
Means of
Procedure
o The contractor to ensure daily
collection and regular disposal of
construction waste/ generated debris
etc.
o Segregation of waste should be
ensured by using color coded bin
system for biodegradable and no-
biodegradable waste segregation.
o Employees working at the site should
be provided with training and
awareness on the segregation of
waste at source.
o Collaborate with local authorities to
transport and dispose waste in
accordance with the regulatory
requirements.
o Solid/liquid Waste
o Biodegradable waste will be
will be generated Site Inspection,
preferably composted in -situ that can
Solid/Liquid Waste during construction document Monthly PMC, DMER/
be used as compost for landscaping Contractor
/Hazardous Waste works as well as verification MEDD
o The municipal solid waste should be
from construction
routed through proper collection and
camp.
handover to local body for further
disposal.
o All the construction and demolition
waste should be managed as per
Construction and Demolition Waste
Management Rules, 20165.
o Good housekeeping should be
ensured.
o Waste oils/Greases/ Oil
contaminated cotton waste from
equipment’s should be properly
collected and disposed through PCB
authorized vendors.
o Secured storage of civil construction
materials including paint, thinner, etc.
to be ensured.
5
https://cpcb.nic.in/displaypdf.php?id=d2FzdGUvQyZEX3J1bGVzXzIwMTYucGRm
102 Appendix 5
Means of
Procedure
o Construction vehicles and equipment
should undergo regular maintenance
to avoid any oil leakages.
o Offloading and loading protocols
should be prepared for diesel, oil and
used oil respectively and workers to
be trained to prevent/contain spills
and leaks.
o Burning of any type of waste and
dumping of waste at any unpermitted
area (especially near watercourses)
should be strictly prohibited.
o Hazardous waste should be properly
labelled, stored onsite at a location
provided with impervious surface,
shed and secondary containment
system in accordance with
Hazardous and Other Wastes
(Management and Transboundary
Movement) Rules, 20166
o Hazardous waste will be disposed
routinely through approved vendors
and proper records will be maintained
of the same.
o It is to be ensured that hazardous
waste is not stored for more than 90
days.
o Regular collection and disposal (in
compliance to regulatory
requirement) of domestic waste and
sewage generated from labour camp
to be ensured.
o Possibility of avoidance and
Tree felling
Loss of Vegetation minimization of tree felling should be
plantation, record of
Ecosystem and associated biodiversity thoroughly examined prior to project PMC, DMER/
plantation, survival Monthly Contractor
Biodiversity due to site preparation development. MEDD
rate of planted trees,
and o Vegetation disturbance and
Site Inspection
clearance should be restricted to the
6 https://cpcb.nic.in/displaypdf.php?id=aHdtZC9IV01fUnVsZXNfMjAxNi5wZGY=
Appendix 5 103
Means of
Procedure
construction activities; Project activity area only. Prior to
accidental contamination vegetation clearance and
of habitat condition construction activities, old mature
trees should be identified through a
survey and options of avoidance
should be explored
o Strict prohibition on use of fuel wood
and shrubs from nearby areas as fuel
should be imposed and workers
should strictly be directed not to harm
any wildlife in the area
o Labourers should be provided
training about dos and don’ts when
encountering wildlife
o Proper disposal of solid and liquid
wastes should be ensured to avoid
any kind of contamination of
soil/waterbody which may affect the
dwelling species.
The contractor will require to comply with
the followings.
o An occupational health & safety Plan
will be prepared and implemented by
the contractor including Health &
Safety reporting and
incident/accident reporting
procedure. Accidents will be reported
Material handling and immediately to ADB (within 48
Site inspection,
storage hours). Root cause analysis and
document
Occupational Health Possible injuries corrective actions take to avoid PMC, DMER/
verification, training Monthly basis Contractor
and Safety associated with working further accidents will also be MEDD
records; consultation
conditions and other submitted to ADB (preferably within
with workers
occupational hazards 72 hours).
o Accident register will be maintained
at site and closed monthly by the site
supervisor.
o Provisions of personal protective
equipment’s (PPEs) viz., gloves,
helmets, dust musk, ear plug, safety
belt, etc. for the workers/staff
depending on the type of works
104 Appendix 5
Means of
Procedure
assigned them (e.g., construction,
excavation, welding, painting etc)
o A PPE matrix and its onsite inventory
and deployment should be
maintained.
o Contractors to adopt and maintain
safe working practices.
o Usage of fluorescent and retro
refectory signage, in local language
should be provided at construction
sites
o Training to workers on safety
procedures and precautions.
o Appointment of safety officer should
be ensured.
o All regulations regarding safe
scaffolding, ladders, working
platforms, gangway, stair wells,
excavations, trenches etc should be
complied with.
o Use of hazardous material should be
minimized/restricted to the extent
possible.
o Emergency plan should be prepared
to respond to any accidents or
emergencies. On-site display of
emergency contact numbers of the
city/local fire services, etc. to be
ensured.
o On-site first aid kits and trained First
Aid attendants should be provided.
o Mock drill/Toolbox talks will be
conducted at regular intervals and
training record should be maintained
at site.
o Loading and unloading operation of
equipment should be done under the
supervision of a trained professional.
o All work at height to be undertaken
during daytime with sufficient
sunlight.
Appendix 5 105
Means of
Procedure
o On-site fire extinguishing equipment
should be provided to handle any
possible fire outbreaks. Fire
extinguishers should be regularly
checked and working condition of the
same to be ensured.
o A Grievance Redressal Mechanism
(GRM) will be implemented to allow
the workers/labours to express their
concerns, if any.
o A Grievance register will be
maintained at site and details such as
name of complainant, date and mode
of complaint receipt, details of
complaints, resolution details,
resolution dates, mode of
communication to the complainant
etc. The register will be closed on
monthly basis by the site supervisor
and countersigned by the PMC
Environment expert/ TL.
o Contractor to maintain good
housekeeping to prevent trips, slips
and falls.
o Necessary permits from the
concerned labour department should
be obtained, pertaining records
should be maintained at site with
proper documentation
o The Contractor and project authority
Cultural and Behavioural will ensure decent labour conditions Site inspection/
Labour Rights/ Influx Conflict. for workers and compliance with /document
PMC, DMER
of workforce in the Conflict between applicable law and regulations in verification/Training Monthly basis Contractor
/MEDD
area contractor and labour. India. record/ consultation
o Contractors will ensure that wages with labours
are being paid as per the requirement
of minimum wages act and records
are maintained
o Daily attendance register with name
and signature of labor will be
maintained
106 Appendix 5
Means of
Procedure
o Notice board to display terms of
employment giving details of wage
rates, working hours, criterion for
overtime etc. Payment of wages of
workers (including
subcontracted/casual labours)
should be aligned with the payment of
wages act.
o The contractor to put in place a Code
of Conduct (customized to local
sensitivities and regulations) for
worker-community interaction and
on-site behaviour. Oblige workers to
adhere to code of conduct. The Code
of Conduct should take into
consideration relevant legislation,
safety rules, substance abuse,
environmental sensitivity,
communicable diseases, gender
issues (sexual harassment), respect
for local beliefs and customs,
community interactions etc.
o Local people should be preferred for
employment wherever possible,
especially as construction workers.
o Contractor to ensure non-
engagement of forced and child
labour, gender equity, non-
discrimination on employment and
opportunity and freedom to express
their view in
o GRM will be disclosed to the workers
and made accessible for reporting
o Contractors should ensure access of
necessary basic amenities and
facilities such as drinking water,
kitchen, separate toilet (for male &
female) and crèches for female
worker’s children, if any.
Appendix 5 107
Means of
Procedure
o Contractor to monitor to avoid any
conflict with local community due to
influx of migrated labour.
o The third-party vendors/suppliers
especially associated with transport
of construction materials and site
cleaning should not be allowed to
enter into the premises without valid
ID cards or gate pass.
o The entry and exit inside the site will
be strictly monitored. Unauthorized
entry will be prohibited.
o Excavation for foundations will be
closed as soon as practicable to
o traffic congestion prevent people or animals falling into
o Potential exposure the excavation sites. Traffic management
to o The transport of heavy loads will be plan, Consultation
pollutants/hazardous undertaken out of normal working with contractor and
material hours to the extent possible. local community,
o Threat of emergency o The contractor/project authority will Grievance Register,
Community Health,
situation make reasonable inquiries to ensure visual observation,
Safety, and Security. Weekly site PMC, DMER
o Potential threat from that those providing security are not environmental Contractor
inspection /MEDD
the security implicated in past abuses; will train monitoring reports,
personals to the security staffs adequately in the use Management Plan
local community of force (and where applicable, for Hazardous
(like abuse, firearms), and appropriate conduct material and
unnecessary use of toward workers and local Emergency
force etc.) Communities. Preparedness plan
o Security personnel engaged should
not use force except when used for
preventive and defensive purposes in
consideration to the nature and
extent of threat. For any issue with
the community, take support of local
administration as needed.
o Establish a Code of Conduct for
worker/security persons -community
interaction and on-site behaviour.
Oblige workers/ security persons to
adhere to code of conduct.
108 Appendix 5
Means of
Procedure
o A Grievance Redressal Mechanism
(GRM) will be implemented to allow
the community to express their
concerns, if any.
o All construction sites should be
barricaded to restrict entry of general
public to avoid chance of any
accidents
o At least one traffic marshal/ flagmen
will be deployed in junction/diversion
point (at approach road to the project
area and main road).
o The traffic movement in the project
area should be regulated to ensure
safety measures for pedestrians.
Traffic management plan may be
developed as necessary.
o speed limits for all Project vehicles
will be implemented
o Training will be provided to all the
drivers on safety measures
o Management Plan for Hazardous
material and Emergency
Preparedness plan should be in
place.
o Necessary mitigation measures as
suggested for management of
different environmental components
(Air, Soil, surface water, ground
water, noise, waste/effluent
management etc.) should be
adequately implemented
o Contractor will prepare site
restoration plan which will be
approved by the PMC/MEDD.
Demobilization: Site Potential Community o The clean-up and restoration Completion of
PMC, DMER
restoration and health and safety threat operations are to be implemented Visual observation construction Contractor
/MEDD
rehabilitation post construction by the contractor prior to work
demobilization.
o All construction zones, workers
camps, plant sites, crushers etc. or
Appendix 5 109
Means of
Procedure
any other area used/affected by the
project will be left clean and tidy, to
the satisfaction of the PMC/MEDD.
The restored level of the ground will
be as per the original level and
condition or better.
Operational Phase
o The Hospital Building along with its
allied facilities would be Indian
Integration of energy Green Building Council (IGBC)
Energy O&M agency, if
efficiency and energy Healthcare Platinum certified7. Review of relevant Prior to start of
efficiency and energy applicable/PMC, PMC, MEDD
conservation component o Also, ECBC 2017 (amended as on certifications operation
conservation DMER
in design date) norms would be complied with
and ECBC certification would be
obtained accordingly7
Obtaining permission and ensuring that
they remain valid throughout the
implementation period.
O&M agency, if
Regulatory To ensure compliance to Ensuring compliance with the Verification of
Semi Annually applicable/PMC, MEDD
Compliance regulatory requirements terms/conditions of various permits such documents
DMER
as CTE, CTO, Biomedical waste
authorization, water abstraction permits,
Fire License etc.
o CTO to be renewed in timely
manner from concerned pollution
control board and conditions as
stipulated in CTO should be strictly
Generation of Particulate
adhered to
Matter, Sulphur dioxide
o Inspection and maintenance of Site Inspection,
and Oxides of Nitrogen O&M agency, if
vehicles will be done at regular Document review,
Air Quality due to traffic movement Monthly applicable/PMC, MEDD
intervals/as per manufacturer’s stakeholder
and operation of DG sets DMER
specification and pollution under consultation
(in case of used due to
control certificate should be secured
power shortage).
o Regular maintenance of DG to be
carried out
o Adequate height of stack should be
provided for the DG sets.
7 DBR, Alibag
110 Appendix 5
Means of
Procedure
o Liquid waste treatment plants will be
maintained well so that odor
emitting gases can be prevented/
controlled
o Air quality monitoring should be
taken up
o DG sets and pumps should be
provided with acoustic enclosures.
o If traffic noise is anticipated to be
higher than the permissible limits,
the facility sites will be
encompassed with acoustic
boundaries in combination with
Noise may be generated
green belt with high and dense
due to traffic movement
enough canopy/ building materials O&M agency, if
and operation of DG sets Site Inspection/
Noise (door/window sheets) used will have Monthly applicable/PMC, MEDD
(in case of use due to Document review
acoustic properties and be properly DMER
power shortage)/ pumps
maintained to retain such properties
at STP/ ETPs etc.
(such as repairing gaps, or broken
sheets, replantation of green belt)
o Noise levels would be reduced
using noise absorbing material on
roof walls and floors.
o Noise level monitoring should be
taken up
o As per the provisions of BMW rules,
the facility should be equipped with
proper facility for collection-
disinfection-segregation-temporary
Generation of biomedical storage in line with the requirements
waste which is of BMW Rules-2016 and
Site Inspection,
hazardous in nature that subsequent amendments. O&M agency, if
Document review,
Biomedical Waste might cause spread of o It will be ensured that storage is Monthly applicable/PMC, MEDD
stakeholder
infections/ contamination done in leak proof containers that DMER
consultation
of surrounding should not generate leachate or
environment etc. attract flies/ vectors etc.
o Under the purview of BMW Rules-
2016, the hospital facility should
secure Authorization (or Combined
Consent and Authorization) from
Appendix 5 111
Means of
Procedure
concerned PCB for ensuring
effective handling and management
of biomedical waste
o The hospital facility should have a
formal tie up with PCB approved
Common Biomedical Waste
Treatment and Disposal Facility
(CBWTDF) to ensure regular and
effective collection and disposal of
Biomedical waste
o If no CBWTDF is available, then in-
situ treatment as recommended by
BMW and related rules (and
concerned regulatory authority) will
be done.
o The hospital should comply with the
conditions precedents of
Authorization or Combined Consent
and Authorization (CCA) issued by
PCB and ensure timely renewal of
the same
o Identification and segregation of
Biomedical Waste at point of
generation should be ensured.
o Segregated waste should be placed
in colour coded (as recommended
by BMW rules) containers to avoid
mixing of biomedical waste with
non-biomedical waste and proper
waste handling, storage and
disposal must be ensured
o The Biomedical waste should be
stored in designated impervious
covered area temporarily before
handing over to CBWTF.
o Ensure workers involved in
biomedical waste handling are
having PPEs such as puncture
resistant gloves, masks etc.
o Record for quantum of different
types of generated biomedical
112 Appendix 5
Means of
Procedure
waste and handed over to CBWTF
should be well documented.
o Educate staffs engaged in BMW
management about different
category of infectious waste and
pathogens
o Immunization of staff members as
necessary
o Adequate facilities to be made for
hand washing and to ensure all
staffs should wash their hands
before and after direct patient
contacts and contact with patient
blood/fluid
o Monitoring and observation of
surrounding areas to ensure that no
contamination is taking place due to
BMW mis management.
o Conduct regular consultations with
the surrounding community/ staff
etc to ensure there no spread of any
infections/ disease that can be
attributed to the mis management of
bio medical wastes.
o Proper segregation of different
waste
o The Hospital also needs to have
formal mechanism for collection of
municipal waste, plastic waste,
Hazardous Waste and E-waste for
Generation of other kind sound management of waste Site Inspection,
O&M agency, if
of hazardous and generated from the facility. Document review,
Other Waste Monthly applicable/PMC, MEDD
nonhazardous waste due o Requirement of separate stakeholder
DMER
to hospital operation Authorization for Hazardous waste consultation
(Hazardous Waste Management
Rules) may be checked from
pollution control board time to time.
o No untreated or infected waste will
be disposed into water bodies or
open pits or grounds.
Appendix 5 113
Means of
Procedure
waste mis management.
wastes from the facilities.
o Mechanism for proper segregation
and collection of Effluent and
Sewage should be ensured.
o The hospital should be equipped
with Wastewater Treatment Plant/s
(like Sewage Treatment Plant and
Effluent Treatment Plant).
o The performance and functioning of
wastewater treatment plants should
be monitored closely and in case of
any underperformance, should be
repaired immediately.
o Quality of treated wastewater from
Generation of sewage, the facility should conform the
Site Inspection/
effluent (containing discharge standards as stipulated in O&M agency, if
Wastewater and Document review,
Chemical Liquid the Biomedical Management Rules Monthly applicable/PMC, MEDD
Effluent Management stakeholder
Biomedical Waste) due during facility operation i.e., DMER
consultation
to hospital operation - For discharge into public
sewers with terminal
facilities, the general
standards as notified under
the Environment (Protection)
Act, 1986 (29 of 1986) will be
applicable
- For discharge into public
sewers without terminal
facilities (or facilities not
connected to public sewers),
the standards stipulated in
Biomedical Management
Rules
114 Appendix 5
Means of
Procedure
o Regular monitoring of inlet and
outlet water quality (with respect to
wastewater treatment plants)
should be taken up.
o Backwash water recirculation
system will be there to ensure
recycling of backwash water
o Sludge will be dried and treated to
conform to the standards given in
Solid waste management rules,
2016 or amendments.
o No untreated or infected waste will
be disposed into water bodies or
open pits or grounds.
liquid waste mis management.
liquid wastes from the facilities.
o A contingency plan will be in place
to handle the liquid waste in case of
power/ technical failures.
o Disposal locations for treated water
will be monitored for their water
quality and ensure that the quality
meets the requirement of end us of
the disposed water be it for irrigation
or washing or aquaculture etc.
o The disposal locations will also be
monitored to ensure that there are
no overflow or flooding due to
addition of the treated waste water
from the facilities.
Potential contamination o CTO to be secured and renewed O&M agency, if
Soil and Water Site Inspection,
to surrounding soil and timely from concerned pollution Monthly applicable/PMC, MEDD
Resource Document review,
water environment due control board and conditions as DMER
Appendix 5 115
Means of
Procedure
to improper waste stipulated in CTO should be strictly stakeholder
(including Biomedical adhered to consultation
waste) and effluent o To avoid contamination to
management surrounding environment (soil and
water resource) discharge of
untreated wastewater and
indiscriminate dumbing of
Biomedical waste and other kind of
solid waste should be strictly
prohibited
o Treated water generated from
wastewater treatment plants should
be reused in the facility to the extent
possible (e.g., HVAC and Greenbelt
development etc.) with a target to
achieve zero discharge.
o Provisions for rainwater harvesting
should be made. Periodic cleaning
of rainwater harvesting system to be
carried out. The run-off from the
previous surfaces and built-up
areas of the project site should be
routed through a carefully designed
storm water drainage network
discharging into rainwater
harvesting structures.
o Efficient Water saving devices/
fixtures should be installed in
kitchens and toilets to reduce
avoidable water consumption.
o Water meters may be installed at
the inlet point of water uptake and
the discharge point to monitor the
daily water consumption and
identify any leakage (if any)
o Regular monitoring of Soil and
Water Quality (Ground and Surface
Water) from the project area and/or
vicinity should be carried out.
116 Appendix 5
Means of
Procedure
o OHS management procedures
covering safe working conditions for
employees, including staff training,
job safety instructions and
measures to ensure workplace
safety and mitigate OHS risks
emanating from exposure to
infections and diseases, hazardous
materials / waste should be in place
and implemented.
o A set of procedures defining the
overall waste (bio-medical and
others) management system should
be in place in consideration of scale
and type of activities and identified
hazards. This will include
minimization, an adequate
segregation at point of generation,
safe handling, collection, temporary
Occupational Health and Site Inspection,
storage, marking, decontamination, O&M agency, if
Health and Safety Safety (OHS) risk Document review,
transport, treatment and disposal Monthly applicable/PMC, MEDD
Risk Community Health and stakeholder
procedures; this will be, DMER
Safety risk consultation
accompanied by systematic record
keeping of waste quantity, type and
final disposal/treatment
o Standard operating procedures on
the use, storage and disposal of
hazardous materials should be in
place
o The facilities should have
Emergency, preparedness and
response plan and should be
designed in commensurate with the
requirement of concerned
department (like Fire Department).
Fire NoC should be secured from
Fire Department and renewed in
timely manner.
o Traffic and Parking management
plan may be developed as
necessary.
Appendix 5 117
Means of
Procedure
o Develop and implement a code of
conduct for security personnel to
ensure that security personnel are
screened for implication in past
abuses including Gender Based
Violence (GBV) and adequately
trained in the use of force and
appropriate conduct toward the
public and workers. The code of
conduct will also include procedures
to report incidents, for affected
people to raise related grievances,
for incident investigations. The code
of conduct will also indicate that the
contractor does not sanction use of
force in relation to the project except
preventive and defensive purposes
in proportion to the nature and
extent of the threat.
o Accidents if any will be reported to
the management / SPCB/ ADB
(within 48 hours to ADB) etc in the
form prescribed as per BMW rules.
o Ocular observation will be carried
out for Avian collision. In case any
such collision are reported
adequate mitigation measure will be
o Risk of
taken viz bird deterrence, spacing Visual observation,
electrocutions, Avian
between energized components etc technical
collision,
Transformers, will be taken in consultation with the specification of
o O&M agency, if
Substation & power forest department. (this will be transformers and
o Risk of use of Regularly applicable/PMC, MEDD
lines applicable based on site specific electrical equipment,
Polychlorinated DMER
condition) breakdown of
byphenyls (PCB)
o Sulphur Hexa fluoride (SF6) if used electrical equipment
and Sulpher
will be monitored adequately to etc.
Hexafluoride (SF6)
prevent leakage
o The transformers used will have
PCB free oil as it is banned for use
in India.
118 Appendix 5
Means of
Procedure
Note: Additional measures (including permits/clearances) as mandated by any regulatory bodies (if any) time to time and/or conditions precedents of permits/clearances
should also be implemented by Contractor/PMC during their engagement period and MEDD in addition to mitigation measures as suggested in the EMP.
Appendix 6 119
FORMAT FOR SEMI ANNUAL MONITORING REPORT
Environmental Monitoring Report
Semiannual Report {Insert Number}

Reporting Period {From Month Year to Month Year}
Date {Month Year}
IND: Title of the Project

{Example: India: Maharashtra Tertiary Care
and Medical Education Sector Development
Program}
Prepared by {Consultant and/or Implementing Agency} for the {Executing Agency} and for the
Asian Development Bank
INTERNAL. This information is accessible to ADB Management and staff. It may be shared outside ADB with appropriate
permission.
120 Appendix 6
Environmental Safeguards Monitoring Report

{Red text serves as guide for report preparation, please delete it when the report is finalized}
TITLE PAGE
LIST OF ABBREVIATIONS {All abbreviations used in the report should be listed here as well
as being spelt out in full the first time they appear in the report}
TABLE OF CONTENTS
EXECUTIVE SUMMARY {Maximum two-page summary following table like the sample below, if
necessary cross reference the relevant section of the main report for details to keep summary
succinct}
Project Name
Executing Agency
Implementing Agency
Environment Safeguards
Categorization
Environment Safeguards EARF/EIA/IEE/Existing Facilities CAP/EMP
Documentation
Project Stage Obtained Design/Pre-Construction/Construction/Commissioning/O&M
Detailed Design Required Post- Yes/No if yes include remarks on status of design progress (%)
Approval and if more than one design package, provide details if any
differences between the status
Contract(s) Awarded Yes/No if more than one contract package, provide details
Bidding Document(s) Include EMP Yes/No if more than one contract package, provide details if any
Cleared by ADB difference between the status
Contract(s) Awarded Include EMP Yes/No if more than one contract package, provide details if any
Cleared by ADB difference between the status
National Environment, Health and Yes/No/NA provide details if any clearances are outstanding or
Safety Clearance(s) Obtained there is any difference between the status of contract packages,
use NA if any clearances not yet required
Contractor(s) Given Access to Site Yes/No if more than one contract package, provide details if any
difference between the status
Construction Progress (%) If more than one contract package, provide details if any difference
between the status
Unanticipated Impacts including Yes/No if yes, provide brief details with how the IEE and EMP
Change of Scope or Design updated as required
Number of Site Inspections and
Audits Undertaken by
Environment Safeguards Staff in
Reporting Period
Corrective Action Required from Yes/No/NA use NA if this is the first project reporting period
Previous Reporting Period
Outstanding Corrective Action this Yes/No/NA if yes, provide bulleted summary of the key actions
Reporting Period still required, use NA if the response to above is No or NA
Non-Compliances Recorded this Yes/No if yes, provide bulleted summary of the key non-
Reporting Period compliances recorded
Corrective Action Required Yes/No if yes, provide bulleted summary of the key actions to be
taken in response to non-compliances including timeline and
budget
permission.
Appendix 6 121
Number of Health and Safety Provide brief details including how they were responded to
Incidents
GRM Functional Yes/No briefly elaborate on set up if differs to description in
IEE/EMP
Number of Unresolved Grievances
from Prior Reporting Period
Number of Grievances Received
in Reporting Period
Number of Grievances Resolved
this Reporting Period
Number of Grievances Still Provide brief details with timeline for resolution
Outstanding
Number of Grievances referred to Provide brief details
Court of Law
Number of Grievances referred to Provide brief details
the Accountability Mechanism
1.0 Introduction
1.1 Brief Project Description
{Maximum two pages to succinctly convey who the executing and implementing agencies are, the
project outputs, construction works involved, details of contract packages, details of construction
camps and other related facilities, national and ADB environmental safeguards project
categorizations, and the environment safeguard documents (dates) applicable to the project}
{Include maps and plans showing the project site locations and project area of influence}
{Include table and/or organogram of environmental safeguards staffing and relationships between
executing and implementing agencies, consultants, contractors, subcontractors, lenders, etc.}
1.2 Project Progress Status and Implementation Schedule
{Describe the implementation stage reached (design, pre-construction, construction,

commissioning or O&M) and the % progress, main project activities and milestonesachieved during
the reporting period, including bidding documents issued and contracts awarded during the
reporting period etc. No need to repeat progress information included in previous monitoring reports
if no change, cross reference the previous monitoring reportsif needed}
{Highlight any unanticipated impacts in relation to change in the project scope, locations of
components, construction methods, and/or implementation schedule during the reporting period, if
none confirm this.}
{Highlight any changes in the project organization and environmental safeguards staffing during
the reporting period, if none confirm this}
{Report on any unanticipated impacts and updates to IEE/EMP that were required during the
reporting period, status of delivery of documents, required amendments, consultation and
disclosure undertaken etc.}
{The project Gantt chart may be included}
permission.
122 Appendix 6
{Include a simplified table like the sample below to report progress}
Project Target Completion Progress Status Percent Remarks

Component/Stage Date {Revised {not yet started; Completed
Target Date, if ongoing;
delayed} completed}
Medical
college Example for reporting period Jul-Dec 2022
Component
(construction
phase)
Contract award 31 Jan 2022 Completed 100% Contract awarded
to XYZ contractor,
copy of EMP
included
31 Mar 2022 Ongoing 85% There was a delay

Construction (site (original target in the delivery of
clearance, completion was 31
earthworks, civil Dec 2018)
works, installation
of
2.0 Compliance to National Regulations and International Agreements
{Status of compliance and further action to ensure ongoing compliance; if there is partial or no
compliance recommendations for corrective action are required. Provide explanations of any
instances where the requirements of regulations or agreements were breached along with detailsof
responses taken to rectify the breach once identified. Include all the applicable National
Regulations and International Agreements following the sample table below}
National Compliance Compliance Status Remarks

Regulation or Requirements under the {complied; partially {provide details (evidence) to
International Regulation or Agreement complied; show how compliance was
Agreement including any not complied; still achieved; or explain the
Environmental ongoing or n/a at corrective action to be taken if
Clearances Required current stage of the there was non-compliance
project} including timeline and budget}
permission.
Appendix 6 123
3.0 Compliance to Environmental Covenants from the ADB Loan Agreement
instances where covenants were breached along with details of responses taken to rectify the
breach once identified. Include all the applicable Loan Agreement covenants on environment
following the sample table below}
Schedule #, Covenant Compliance Status Remarks

Para. # {complied; partially {provide details (evidence) to
complied; show how compliance was
not complied; still achieved; or explain the
ongoing or n/a at corrective action to be taken if
current stage of the there was non-compliance
4.0 Compliance to Environmental Assessment and Review Framework
instances where tasks allocated to the executing or implementing agency and any consultants have
not been undertaken along with details of responses taken to rectify the situation once identified.
Include all applicable organizations with responsibility for environmental safeguards following the
sample table below}
Organization Tasks Compliance Status Remarks

{complied; partially {provide details (evidence) to
complied; show how compliance was
not complied; still achieved; or explain the
ongoing or n/a at corrective action to be taken if
current stage of the there was non-compliance
Executing
Agency
Implementing
Agency
Contractors
5.0 Compliance to Contract
instances where tasks allocated to the contractor have not been undertaken along with details of
responses taken to rectify the situation once identified. Include all contract packages and provisions
relating to environment, health and safety management following the sample table below}
Contract Contract Provisions Compliance Status Remarks {provide sufficient

Package {complied; partially details (evidence) to show how
complied; compliance was achieved; or
permission.
126 Appendix 6
not complied; still explain the corrective action to

ongoing or n/a at be taken if there was non-
current stage of the compliance including timeline
project} and budget}
Package 1 Clause xx: Environment Partially complied Provide details, if given in
Protection EMP compliance table just
refer the table
Package 2 Clause xx EMP Partially complied Provide details, if given in
EMP compliance table just
refer the table
6.0 Compliance to Environmental Management Plan and Corrective Action Plan (if any)
{With reference to the EMP (design, pre-construction, construction or operation as applicable in a particular
reporting period) of the project, include a table following sample table below with the compliancestatus during
the reporting period, with sufficient details (evidence) to show how compliance was achieved, or corrective
action to be taken if there was non-compliance including timeline and budget}
{Flag if previous environmental monitoring report(s) included corrective action plan, if it did details of that
corrective action plan should be incorporated into the EMP table and compliance status reported}
{Provide explanations of any instances where performance standards were temporarily exceeded during the
reporting period, along with details of any response taken to rectify the exceedance once identified, even if
at the end of the reporting period the project is deemed as being compliant}
{Copies of clearances, CEMP, construction method statements, and other documentation produced in
accordance with EMP during the reporting period should be included as an appendix}
Item # Environment Prior Corrective Compliance Remarks {provide sufficient

Management Action, if any Status details (evidence) to show how
Measures {complied; compliance was achieved; or
partially explain thecorrective action to
complied; be taken if there was non-
not complied; still compliance includingtimeline
ongoing or n/a at and budget}
current stage of
the project}
Item # Management Prior Corrective Compliance Remarks {provide sufficient

measures as per CAP Action Status details (evidence) to show
drawn as part of audit {complied; howcompliance was achieved;
of existing facilities, if partially or explain thecorrective action
any complied; to be taken if there was non-
not complied; still compliance including
ongoing or n/a at timeline and budget}
current stage of
the project}
7.0 Environmental Safeguards Capacity Building
{With reference to the EMP capacity development plan summarize trainings for the executing and
implementing agencies, contractors, and subcontractors, and other activities completed. Include
as appendices the training agenda, attendance sheets, andphotos. If no trainings or other activities
in reporting period, please confirm. Copies of training records related to EMP during the reporting
permission.
Appendix 6 127
period should be included as an appendix}
Trainings Number and Position of Location/s and Date/s Remarks

Participant/s
8.0 Environmental Safeguards Inspection and audits

{Site inspections and audits completed summarize the number and type of site visits, persons
involved, the issues covered, and status of compliance with them, the number of non-compliance
notices given out to the contractor as a result of the site visit, and the checklists/reporting format
used (sample of checklists and reports to be included as an appendix)}
Date Type and Location/s EA, IA, Consultant Remarks
Purpose of Visit Visited Staff Participating
9.0 Quantitative Environmental Monitoring
{Environmental monitoring results

quantitative monitoring activities and data obtained in accordance with the Environmental
Monitoring Plan (EMoP) of the project. Provide explanations of any instances where performance
standards were exceeded along with details of responses taken to rectify the exceedance once
identified}
Typically, this section will include the results of: Noise
and vibration surveys

Water quality surveysAir quality surveys
Flora and fauna surveys etc.
{Indicate the monitoring locations using a map or plan, dates, times, duration of samples as
applicable, weather conditions as applicable, parameters measured, equipment used,standards,
tests, and limits used etc.}
{Corrective actions with timeline and budget are required to ensure any exceedances will be
prevented in the future}
{Graphs can be used in this section to show trends; however, large tables of data or multiple graphs
should be attached as an appendix.
{Calibration and QA certifications of monitoring equipment and laboratories analyzing samples

should be included as an appendix}
10.0 Occupational and Community Health and Safety Monitoring
{Health and safety monitoring results activities

and data obtained in accordance with the Environmental Monitoring Plan (EMoP) of the project.
Provide explanations of any instances where performance standards were exceeded along with
details of responses taken to rectify the exceedance once identified}
permission.
126 Appendix 6
{Corrective actions with timeline and budget are required to ensure any exceedances will be
prevented in the future}
{Include the occupational and community trainings/drills/inspections conducted during thereporting

period following the sample table below. Include as appendices the training/drill/inspection agenda,
attendance sheets, and photos. If no trainings/drills/inspections, please confirm}
Trainings/Drills/ Number and Position of Location/s and Date/s Remarks

Inspections Participant/s
Example: 50 Laborers Construction Camp, Participants safely
Fire Drill 15 Aug 2018
{If there was any near-miss or accident, illness, or other occupational or community healthand safety
related incident during the reporting period (or a previously reported incident with ongoing
rectification) report following the sample table below. Include as appendiceswork safety checklists,
incident reports, and other relevant supporting documents. If no incidents, please confirm}
Number and Position Location/s Detailed Description Time-bound

of Person/s and Date/s of of Incident- Attach Corrective Action
Involved Incident root cause analysis
report
Fatality
Non-fatal Injury
(Lost Time)
Non-fatal Injury
(Minor)
Near-miss
Illness
Other Incidents
11.0 Meaningful Consultation and Grievance Redress
{Meaningful consultation report on any ongoing consultation undertaken, and main issues raisedby
consultees; detailed consultation records should be included as an appendix. If no ongoing
consultation, please confirm}
Date Sub Project and Venue
Sl.no Participants Name Occupation Gender Issues Response

raised by Given by
participants EA/PMC/Co
ntractors
{Include a brief description of the GRM, provide a flowchart, list of grievance redress committee
members and any trainings they have received}
{If there was any grievance or complaint, regardless informal or minor, during the reporting period
(or previously reported complaint with ongoing rectification) provide the corrective action taken
following the sample table below. Detailed grievance records and response reports should be
included as an appendix}
permission.
Appendix 6 127
Complainant’s Date/s of mode of Description of Resolution Date of Mode of

name & Complaint communication to Complaint details resoluti communication
contact details EA/ADB on to complainant
12.0 Compliance to recommendations of Previous reporting period EMR

Non- Corrective Action Compliance status Continued noncompliance, if
compliance recommended in any (please add this to the
identified in previous EMR current EMR’s
previous recommendation as continued
EMR NCs)
13.0 Conclusions and Recommendations
previous sections and, if any non-compliance identified, provide detailed recommendations including
responsibilities, timeliness and budget for the preparation and completion of correctiveaction}
{If non-compliance is major or not readily addressed then a separate corrective action plan may
need to be prepared. For minor and readily addressed non-compliances the corrective action plan
can be incorporated into this final section of the environmental monitoring report following the
sample table below}
Non- Corrective Action to be Responsibility Timeline Budget

compliance Taken
APPENDICES
Photographs {Include relevant photographs of the project site and project area of influence taken
during the reporting period to provide evidence of compliance and/or non-compliance. Foreach
photo, provide a caption with description of what it illustrates, accurate location, and date taken}
Supporting Documents
{E.g. Maps and plans, Sample checklists and reports Clearances and documentation Training
records, Detailed monitoring data, laboratory results etc.Calibration and QA certificates,
Consultation records, Meeting agendas and attendance records,Grievance records,
Environment, health and safety reports etc}
permission.

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Annex 9 to Maharashtra Tertiary Care and Medical Education Sector Development Program

(RRP IND 56343-001)

Environmental Assessment and Review Framework

Document Stage: Draft for consultation

India: Maharashtra Tertiary Care and Medical Education

ADB Asian Development Bank

(ii) In this report, "$" refers to United States dollars.

1. ADB Prohibited Investment Activities List 60

Table 1: Indicative Financing Plan............................................................................................. 2

4. Output 2: Availability of quality and gender-equitable medical human resources

Revised curriculum. New Delhi.

C. Purpose of the EARF

8 Source: Concept Paper; Project Number: 56343-001, August 2023.

II. ASSESSMENT OF REGULATORY FRAMEWORK

A. National Regulatory Framework

S. Key Regulations Relevance to Program Requirement

S. Key Regulations Relevance to Program Requirement

S. Key Regulations Relevance to Program Requirement

S. Key Regulations Relevance to Program Requirement

S. Key Regulations Relevance to Program Requirement

This Act will be applicable for all machinery

S. Key Regulations Relevance to Program Requirement

S. Key Regulations Relevance to Program Requirement

S. Key Regulations Relevance to Program Requirement

S. Key Regulations Relevance to Program Requirement

S. Key Regulations Relevance to Program Requirement

B. International Environmental Agreements

Table 3: International treaties, conventions and declarations for nature

S. No. Nature Conservation

Table 4: International treaties, conventions and declarations for management of

Table 5: International treaties, conventions and declarations for atmospheric

Table 6: International treaties, conventions and declarations for marine

Occupational Health and Safety

Table 7: International treaties, convention for labour health and safety

C. ADB Environmental Safeguards

Category A. A proposed project is classified as category A if it is likely to have significant adverse

Category B. A proposed project is classified as category B if its potential adverse environmental

Category C. A proposed project is classified as category C if it is likely to have minimal or no

11 ADB. 2009. Safeguards Policy Statement. Manila.

protected area. In an area of natural habitats, there must be no significant conversion or

22. International Finance Corporation Environment, Health, and Safety Guidelines:

D. Compatibility between Country’s and ADB Safeguard Policy

Table 8: Comparative analysis of ADB SPS and Regulatory Framework of Government of

All necessary government To ensure compliance

Pollution Prevention Pollution Prevention Projects must comply

Disposal standards are notified under the

Ambient Air Standard:

Waste Water Standards:

Works within 300 m (up to 100 m)

III. ANTICIPATED ENVIRONMENTAL IMPACTS

29. Regulatory requirements: Necessary consent/permission (like Environmental

12 Source: Concept Paper; Project Number: 56343-001, August 2023

44. Securing necessary Permits at construction stage: Necessary permit as applicable

46. Generation of Biomedical Waste and other waste: According to Biomedical

Table 9: Types of Biomedical Waste envisaged due to the proposed project

50. Securing necessary Permits at construction stage: Necessary permit as applicable

IV. PROCESS TO BE FOLLOWED (ENVIRONMENTAL ASSESSMENT) FOR

B. Environmental Guidelines and Criteria for Subproject Selection

(d) Components/activities that result in the significant conversion or degradation of natural

C. Screening and Categorization

D. Preparation of Environmental Assessments Reports

56. Initial Environmental Examination (IEE) Report. For B category (Environmental

E. Environmental Management Plan