Sound Chemicals Management Mainstreaming and UPOPs reduction in Kenya

Report Cover Image
Evaluation Plan:
2018-2022, Kenya
Evaluation Type:
Mid Term Project
Planned End Date:
12/2019
Completion Date:
12/2019
Status:
Completed
Management Response:
Yes
Evaluation Budget(US $):
30,000

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Title Sound Chemicals Management Mainstreaming and UPOPs reduction in Kenya
Atlas Project Number: 00095750
Evaluation Plan: 2018-2022, Kenya
Evaluation Type: Mid Term Project
Status: Completed
Completion Date: 12/2019
Planned End Date: 12/2019
Management Response: Yes
UNDP Signature Solution:
  • 1. Poverty
Corporate Outcome and Output (UNDP Strategic Plan 2018-2021)
  • 1. Output 1.1.2 Marginalised groups, particularly the poor, women, people with disabilities and displaced are empowered to gain universal access to basic services and financial and non-financial assets to build productive capacities and benefit from sustainable livelihoods and jobs
SDG Goal
  • Goal 10. Reduce inequality within and among countries
SDG Target
  • 10.1 By 2030, progressively achieve and sustain income growth of the bottom 40 per cent of the population at a rate higher than the national average
Evaluation Budget(US $): 30,000
Source of Funding: GEF
Evaluation Expenditure(US $): 21,000
Joint Programme: No
Joint Evaluation: Yes
  • Joint with Government
Evaluation Team members:
Name Title Email Nationality
Dinesh Aggarwal Mr dinesh.a@rediffmail.com INDIA
GEF Evaluation: Yes
GEF Project Title: Sound Chemicals Management Mainstreaming and UPOPs reduction in Kenya
Evaluation Type: Mid-term Review
Focal Area: Persistent Organic Pollutants
Project Type: FSP
GEF Phase: GEF-5
GEF Project ID: 5689
PIMS Number: 5361
Key Stakeholders: Ministry of Environment
Countries: KENYA
Lessons
Findings
1.

PROJECT STRATEGY

Project Design

Problem being addressed

The project is aimed at protecting the human health and the environment by managing the risks posed by production, use, import and export of chemicals and mitigating the release of UPOPs and other toxicants originating due to waste management in HCFs and the MSW in the urban areas. Management of HCW management and MSW management are the two priorities identified in the NIP for SC in Kenya. Kenya, needs to address the issues related to the harmful impacts of chemicals, but there are a number of barriers towards implementation of the initiatives towards doing so. The GEF project has following four components; Component 1: Implementation of the ‘Sound Chemicals Management Program’ Component 2: Introduction of environmentally sound management practices for health care waste Component 3: Demonstration of sound healthcare waste disposal technologies Component 4: Reduction in the release of UPOPs due to dumping of MSW


Tag: Environmental impact assessment Waste management Relevance Global Environment Facility fund Health Sector Technology

2.

Project Strategy

For the ‘Sound Management of Chemicals’ part of the project, the strategy is centred around the effective ways towards implementation of the plans envisaged by the Stockholm National Implementation Plan (NIP) and the SAICM Implementation Plan (SIP). This part of the project is focused on the activities which have synergies with the other two components of the project (emission of UPOPs due to burning of HCW and emissions of UPOPs due to dumping of SW). Accordingly, the strategy for this part of the project comprises of the following • Increase awareness among the industry and civil society on cleaner production, and on alternatives to POPs • Increase in analytical service and the establishment of more sustainable laboratory services • Improvement of regulatory texts and their enforcement towards the implementation of a sound management of chemicals.

For the Components of the project pertaining to addressing the emissions of UPOPs due to HCW management, the project strategy addresses the two key issues of ‘poor segregation’ and ‘poor choice of technology for treatment and disposal of waste’. Thus, the strategy comprises of the following; • Building capacity at national, county and HCF level for the introduction of ‘Best Available Technologies (BAT)’ and ‘Best Environmental Practices (BEP)’ • Drafting and disseminating technical guidance on HCWM, officially endorsed by the government • Strengthening the legislative and policy framework governing HCWM and Mercury at national and county level • Improving HCWM awareness and education • Increase segregation and minimisation of waste. This is to be done mostly by establishing and enforcing HCW management units in the HCFs and providing on-site continuous training and technical assistance to the personnel of the HCFs. In addition, key waste management equipment (bags, bins, cart, sharp boxes) are to be provided to the project HCFs. • Improvement of HCW disposal technology and increased centralisation of waste disposal.


Tag: Waste management Effectiveness Global Environment Facility fund Rule of law Health Sector Programme/Project Design Awareness raising Capacity Building

3.

Relevance and country drivenness

Kenya is a party to the SC, having ratified the Convention in September 2004. It subsequently developed its National Implementation Plan (NIP) in 2007. Kenya completed the process of updating the NIP in line with Article 7 of the Convention. Thus, the country developed and amended the priority policy and regulatory reforms as well as capacity building needs and required investment programs for POPs. In addition to SC Kenya has ratified a number of other chemicals related MEA. One of the aims of the project is to improve Kenya’s compliance with the SC on POPs, particularly with regard to dioxins and furans. This addresses the priorities identified in the NIP for SC. The Kenya government, by reviewing and updating its NIP and by approving its SAICM implementation plan, has already established strong pillars toward the sound management of chemicals. There is now the need to start an effective way to implement the plans envisaged by both the Stockholm National Implementation Plan (NIP) and the SAICM Implementation Plan (SIP).


Tag: Waste management Relevance National Rule of law Health Sector Institutional Strengthening

4.

PROGRESS TOWARDS RESULTS

Progress towards attainment of outcomes

This section of the report provides an overview of the progress towards results of different Outcomes of the project. In the Tables below, the column with ‘Level at PIR’ is based on the second PIR (draft PIR for the year 2019). Although, the Guidance for Conducting Mid-term Reviews of UNDP-Supported, GEF-Financed Projects specifies that the level at first PIR be reported, in the present case values of the second PIR has been used. This is considering that there was not much progress at the time of preparation of first PIR (for the year 2018) due to delayed start of the project implementation. As the ‘results framework’ of the project has not provided the indicators at the level of Outcomes, the progress towards achievement of results has been assessed for different Outcomes in terms of the indictors and the targets for the set of outputs. It is important to note that in the present case the set of targets provided for the Outputs are in the form of activities, thus, the achievement of the targets for the Outcomes would not necessarily represent the achievement of the given Outcome of the project.


Tag: Effectiveness Project and Programme management Results-Based Management

5.

PROGRESS TOWARDS RESULTS

Progress towards attainment of outcomes

This section of the report provides an overview of the progress towards results of different Outcomes of the project. In the Tables below, the column with ‘Level at PIR’ is based on the second PIR (draft PIR for the year 2019). Although, the Guidance for Conducting Mid-term Reviews of UNDP-Supported, GEF-Financed Projects specifies that the level at first PIR be reported, in the present case values of the second PIR has been used. This is considering that there was not much progress at the time of preparation of first PIR (for the year 2018) due to delayed start of the project implementation. As the ‘results framework’ of the project has not provided the indicators at the level of Outcomes, the progress towards achievement of results has been assessed for different Outcomes in terms of the indictors and the targets for the set of outputs. It is important to note that in the present case the set of targets provided for the Outputs are in the form of activities, thus, the achievement of the targets for the Outcomes would not necessarily represent the achievement of the given Outcome of the project.


Tag: Emission Reduction Waste management Effectiveness Rule of law Health Sector Project and Programme management Results-Based Management Awareness raising Capacity Building

6.

Global environmental and other impacts

At the time of its design, the project had projected significant global environmental benefits due to reduction in the release UPOPs, due to treatment/disposal of SW and the HCW. While the project is expected to effectively remove the institutional, regulatory and policy related barriers towards achieving this global environmental benefit, some of the barriers are still likely to remain (unless addressed specifically). These barriers would hamper the reduction in the release of UPOPs by the project. Some of the major remaining barriers towards achievement of the reduction in the release of UPOPs are;

• Lack of understanding regarding the need to dispose of the treated HCW (using non-burn technologies), either by recycling or by permanent storage. Related to this is the barrier regarding the understanding of the need to segregate the waste in term of type of waste (not in terms of the category of hazard of the waste, but in terms of plastics, paper etc.). One of the related aspects is the need to separate the sharps (e.g. needle from the syringes etc.) at the point of generation of waste. Despite the training of the government officials from the health care sector and health care providers, this important requirement for using effectively using the non-burn technologies for waste treatment did not became part of the common knowledge. It is important to note that some of the HCW treatment facilities based on non-burn technologies were created in some of the hospitals (as a part of the project which was implemented just before the present GEF project), still there is a lack of understanding on these aspects. MTR is recommending specific action points to remove these barriers (please see recommendation 5)

• Lack of financial resources to carry out the emergency measures at the dumpsites to reduce the release of UPOPs due to SW. There is no possibility of addressing this barrier during the implementation timelines of the project. Particularly considering that the implementation of the emergency measures would require a recurring expense, sustainability of such efforts is also doubtful.

• Lack of knowledge regarding the suitable PPP models for treatment of SW by the private sector. Particularly the models that would be best suited, given the situation of Kenya. The MTR has recommended dedicated efforts for removal of this barrier (please see recommendation 8).


Tag: Environmental impact assessment Waste management Impact Sustainability Rule of law Health Sector Human and Financial resources Sustainability Technology

7.

PROJECT IMPLEMENTATION AND ADAPTIVE MANAGEMENT

Management

The project design has provided for a structured management arrangement. UNDP has the responsibility of the Implementing Agency (IA) under the NIM modality. The project is being executed by the Ministry of Environment and Forestry (MEF), which has the overall responsibility for the achievement of project results as UNDP’s Implementing Partner (IP). The IP is subject to the micro assessment and subsequent quality assurance activities by UNDP. UNDP provides overall management and guidance from its Country Office in Nairobi and the Regional Hub in Istanbul, and is also responsible for monitoring and evaluation of the project as per GEF and UNDP requirements. On its part UNDP provides the required support to the IP and the project team. The support is provided by way of inputs provided during the SC meetings and wherever required, offering the solutions to the problems faced by the project implementation team, e.g. it is helping with the procurement process due to the procedural issues related to the transfer of cash to the government account. UNDP also supports the process of preparation of the annual workplans (and the corresponding budget) and its approval by the steering committee. UNDP in its role as the GEF Implementing Agency, is focused towards the achievement of the results of the project. The PIR for the project are being prepared regularly by the project team. UNDP provides its inputs to the PIRs on a regular and timely manner. The rating provided by UNDP for progress towards achievement of results for the project objectives and the project outcomes, has been in line with the ratings provided by the project team. It is to be noted that the in many cases situation at the time of MTR regarding the progress towards achievement of targets (for indicators), outcomes and objectives doesn’t match with what has been reported in the PIR.


Tag: Waste management Effectiveness Global Environment Facility fund Human and Financial resources Implementation Modality Partnership Procurement Project and Programme management Country Government Technical Support

8.

The implementation of the project on a regular basis is done by the project management unit (PMU). The project has a full-time national project manager (NPM) supported by the project administrative staff and a full time ‘Technical Advisor’. At the county level the implementation of the project is supported by the NEMA county Directors of in each of the four counties and the officials from the Ministry of Health Headquarters and in the four counties, the Greenbelt Movement , university of Nairobi as well as the Kenya Association of Manufacturers which has a dedicated official to the project. As the PMU has a full time ‘Technical Advisor’ there is adequate technical capacity within the project implementation team to guide and evaluate the work carried out by the consultants. Apart from the ‘Technical Advisor’ the technical aspects are also supported by the “Technical Committee (TE)’. The ‘Technical Committee; is comprised of technical experts drawn from the participating institutions. TE drafts the Annual Work Plan and Quarterly Work Plan for the approval by PSC. The members of the technical committee steer the project in their respective institutions.


Tag: Human and Financial resources Implementation Modality Monitoring and Evaluation Partnership Project and Programme management Risk Management Technical Support

9.

Work planning

Work planning is being done as per the provisions in the project design document. Work plan for the first year was finalised subsequent to the project inception meeting. The work plan for the year 2019 is in place and is being followed. In accordance with the requirements, the work plans are prepared by the Project Manager, reviewed by the National Project Director and approved by the Steering Committee after deliberations. Work planning is carried out keeping in mind the log-frame in terms of timelines and the targets. Work planning is rated as Satisfactory.


Tag: Programme/Project Design Project and Programme management

10.

Reporting

A key reporting requirement, the inception report, which documents the agreed work plans and other arrangements, was prepared and shared with the stakeholders during August 2016. The inception report documents the working arrangements and the responsible institutions/ agencies. PIRs for the project was prepared for the years 2018 and 2019 (draft). The project has also prepared the ‘Annual Progress Reports’ for the years 2017 and 2018. The quarterly progress reports are prepared and shared in accordance with UNDP / GEF requirements. The reporting aspect of the project management has been rated as Satisfactory.

Communications

At the time of MTR, the project did not have a website of its own. The project was using the websites of the implementation partners to disseminate the information about the work carried out under the project. The project also has a Twitter account. The website of the UNDP CO, Kenya is also being used to disseminate the information about the activities and the results of the project. The project is regularly disseminating the information about the project and the results through the news channels (both online and print media). Apart from this the project is making the effective use of the capacity building, training, and awareness creation activities for targeted stakeholders, under different components of the project as a means of communication. The project organised a workshop during August 2019, for creation of a project specific website. This will also act as a ‘repository for information on chemicals and waste management in Kenya’ and bridging the information gap among various actors in the chemicals and waste sectors. The project specific website once created would be used for dissemination of the information and for a two-way communication with the stakeholders. The project is in the process of hiring a consultant to work out and implement a communication strategy for the project. More outreach and awareness creation activities are being planned by the project. The communications aspect of the project management has been rated as Satisfactory.


Tag: Waste management Global Environment Facility fund Communication Partnership Awareness raising

11.

M&E systems

In line with the standard practice for GEF projects, provisions were made in the project design for mid-term review and a terminal evaluation. The main M&E activities planned at the design stage meet GEF and UNDP requirements and standard practices. Quarterly progress reports are prepared as per the M&E plan and were made available during the MTR. Financial monitoring and evaluation of the project is being carried out using the ATLAS tool of UNDP, which generates reports such as the CDR to gauge the level of delivery on all the outcomes of the project. The monitoring tools being used provide the required information. The monitoring tools being used are project specific and meets the requirements of the project design. The monitoring systems doesn’t draw upon any of the national systems in Kenya. The tools being used are efficient and cost effective. However, the effectiveness of any monitoring tool depends on the accuracy of the information captured, which in the present case is captured manually in the monitoring tools. The monitoring tools being used is considered adequate. As at the stage of the design of the project, the impacts of the project on men and women were not considered significant, the project design has not provided any specific tools for monitoring of such impacts. The steering committee is being chaired by the National Project Director, and includes the Focal Point from the Ministry of Environment, members from the Ministry of Health. The monitoring and evaluation budget provisions in the project are adequate. The Monitoring and Evaluation aspects of project management are considered Satisfactory.


Tag: Global Environment Facility fund National Monitoring and Evaluation Programme/Project Design Project and Programme management

12.

Stakeholder engagement

The main formal platform for engaging the stakeholders is the Steering Committee (SC). As was mentioned in section 6.1.4 as well, the project in addition to the engagement of the government stakeholders as PSC level managed to bring on-board many other beneficiaries and decision-makers, including local Governments of counties of Nairobi, Mombasa, Nakuru and Kisumu. The project also built ties with the private sector companiesto facilitate recycling of the waste. Strong bridges were built with local NGOs and CBOs to promote collection of waste at the point of generation and recycling and reuse of the collected waste. The PSC has representatives from different concerned ministries and departments The SC does not have members from civil society, NGOs, research institutions, development agencies, trade & industry bodies or academia. PSC meetings are happening regularly. Stakeholder engagement at an aggregate level has been rated as Satisfactory.


Tag: Waste management Civic Engagement Partnership

13.

Budget and co-financing

As is evident there is significant planned co-financing for all the Outcomes of the project. The implementation is the project is being supported by the government counterparts as per the plans, thereby signifying the inkind contribution details of which have been provided in Table 18. Cumulative disbursement till June 2019 is about 1.8 million USD which is much short of the budget provisions in the project document. The cumulative General Ledger (GL) as on June 2019 is about 40% (as per PIR for the year 2019). The cumulative GL delivery is also significantly short (at 56.28%) of the expected delivery. One of the reasons for lower achievement of the budget utilisation is that the activities pertaining to procurement of equipment for HCFs for disposal of HCW in an ESM are yet to start. This budget item alone accounts for about 30% of the overall planned GEF funding (please see recommendation 7 as well). Going forward once the activities pertaining to procurement of the equipment will start, the situation of budget utilisation would improve.

One of the issues at the time of MTR is the effectiveness of the project in terms of its global environment benefits (reduction in the release of UPOPs). As was mentioned earlier (please see section 5.2), with the present situation the project would hardly lead to the reduction in the release of UPOPs. However, with the provision of waste treatment equipment to the HCF and with the implementation of some of the MTR recommendations, the situation will improve significantly. Financial Audit of the project is carried out as per the requirements. As the budget utilisation of the project is expected to improve during the rest of implementation period. Budget utilisation of the project is rated as Satisfactory. Based on the ratings above for the different aspects, Implementation and Adaptive Management has been rated as Satisfactory.


Tag: Waste management Efficiency Global Environment Facility fund Resource mobilization Human and Financial resources Operational Efficiency Procurement

14.

SUSTAINABILITY

Project risks

At the design stage, a thorough risk analysis was carried out and appropriate risk mitigation strategies were worked out. Annex 1 of the project document gives an overview of risks identified at the time of project design. Most of the risks identified at the time of project design are the ‘Internal Risks’. Internal risks are projectinherent or can be controlled by the project management. Against this the external risks are of policy-economyinternational nature, and no such risks were identified at the project design stage. One of the risks which did not get identified at the time of project design, and which is impacting the results of the project is the effectiveness of the capacity building and technical training of the stakeholders towards removal to facilitate proper implementation of the BAT and BEP for management of the SW and HCW. For example, there is still lack of understanding amongst the stakeholders regarding the need to dispose of the treated HCW (using microwave or autoclave technology) in a manner where it does not gets burned. Also, amongst the national counter parts, there is gap in the understanding regarding the PPP models for effectively managing the SW (please see recommendation 8).


Tag: Waste management Effectiveness Sustainability Health Sector Project and Programme management Risk Management Technology

15.

Financial risks to sustainability

The project has following three parts; Component 1: Implementation of the ‘Sound Chemicals Management Program’ in the country Component 2 and 3: Reduction in the release of UPOPs due to burning of HCW Component 4: Reduction in the release of UPOPs due to dumping of SW (which eventually gets burned) For the ‘Sound Management of Chemicals’ part of the project, the strategy comprises of increase awareness among the industry and civil society on cleaner production, and on alternatives to POPs; increase in analytical service and the establishment of sustainable laboratory services; improvement of regulatory texts. For the laboratory services the project has envisaged creation of a financially sustainable model wherein the users of the laboratory facilities would pay for the services. There are no financial risks to sustainability for Component 1 of the project


Tag: Waste management Global Environment Facility fund Human and Financial resources Risk Management Capacity Building

16.

Socio-economic risk to sustainability

While at the global environmental benefits level the priorities of the project are reduction in the emission of UPOPs, the project has very significant local environmental benefits like reduction in the emission of NOx, SOx, particulate matter, heavy metals etc. There is an existing level of high awareness with in the national counterparts and within the general public, regarding the issues with the high levels of pollution. This awareness would get further enhanced due to the efforts which will be carried out by the project. The there are no risks to the sustainability of the project form the socioeconomic viewpoint and the sustainability is likely.


Tag: Emission Reduction Sustainability Awareness raising

17.

Institutional framework and governance risks to sustainability

The institutional framework for implementation of the project is embedded to the Ministry of Health (for the HCW) and the ‘Ministry of Environment and Forestry’. The local ministry officials at the county level forms the backbone of the institutional framework for the management of the HCW and the SW. This institutional framework and governance structure have been in place much before the project and no additional institutional framework has been created under the project. There are no risks to institutional framework and governance risks to the sustainability of the results of the project. The sustainability of the results of the project from the view point of institutional framework and governance is likely


Tag: Sustainability Rule of law Country Government

18.

Environmental risks to sustainability

As had been mentioned before (please see section 2.3), the project has significant local environmental benefits with practically no negative environmental impacts of the project. There is a remote possibility of some local level issues in case some of the dumpsites are located to other places. However, considering that the emphasis of the project is on 3Rs for SW management and use of BAT and BEP by taking on board the private sector in PPP mode, the likely negative local level impacts are expected to be well taken care. Though, there are minor risk of environment-related issues blocking the newly created SW management facilities from the view point of environmental risk, sustainability of the project is Likely


Tag: Environment Policy Environmental impact assessment Sustainability Local Governance Partnership

Recommendations
1

Review the Targets for reduction in the emission of UPOPs due to Component 3 (Healthcare waste)

The baseline emissions are 19 gTEq/ Yr. The target for emission reduction is also 19 gTEq (Target 48). This is 100% reduction in the emissions. Complete elimination of the emissions of UPOPs from the medical waste is not feasible.

Elsewhere in the ‘Project Document’ (Page 18) different figure has been provided for the emissions of UPOPs (490.1 gTEq/ yr.). It is recommended that the provisions be reviewed and revised (if required)

2

Identify emergency measures for reduction of UPOPs due to burning of SW and facilitate their implementation

The Outcome 4.2 (Target 73) requires reduction in the emissions of UPOPs of 20 gTEq/yr. by implementing the emergency measures. However, the project design has not provided for identification and implementation of the emergency measures to achieve this Target. Although, the project design has provided for capacity building and awareness creation etc. the emergency measures, there are no provisions in the project budget to support implementation of the emergency measures.

It is recommended that the provisions in the project design be made for identification and facilitating implementation of the emergency measures.

3

Promote alternatives to dumping of Organic Solid Waste

The project is promoting recovery of recyclable materials (metals, plastics, glass, paper) at the source of generation of the ‘solid waste’. In the baseline situation recovery of such inert materials was happening at the dumpsites (except for the paper) for the SW. Thus, in the baseline the inert components of the SW were not leading to emissions of UPOPs.

Recovery of recyclable materials at the point of generation of waste (instead of the dumpsites) is good, however, it is not leading to any reduction in the emissions of UPOPs as there is no reduction in the quantum (except some waste paper) and composition of the material getting burned at the dumpsites. It is recommended that the target (Target 74) for reduction in the emissions of UPOPs due to 3Rs be reviewed and made flexible to include the activities like composting by CBOs at the local level.

The project is already promoting alternate methods for disposal of ‘decay-able organic solid waste’ at the community level by the CBOs using composting/ vermicomposting technologies, but the scale of such activities is very low. It is recommended that the project further promote the composting/vermicomposting at the level of CBOs, to dispose of the organic component of the SW, which doesn’t lead to emission of UPOPs and help to achieve the Target of reduction of 3 gTEq/ Yr. due to waste segregation.

 

 

4

Review of the provisions regarding PRTR

Outcome 1.2: Monitoring activities intensified and strengthened and PRTR database in place, has provided for the laboratory equipment and other such related activities.

However, quantification and monitoring of the emissions of POPs and other hazardous chemicals is mostly done using the emission factors, mass balance methods, engineering calculations and activity rates etc. Thus, although strengthening of the capacity in the country to carry out laboratory operations is good, it is not contributing towards the overall objective of the project.

It is recommended that the provision of Activities/Targets for Outcome 1.2 be reviewed and if required suitably modified.

5

Promote recycling of plastics in HCW

The project is supporting use of non-burn technologies (Autoclave, Microwave) for disposal of HCW. Thus, the project is leading to disposal of HCW in an ESM. However, as the final disposal of the shredded waste out of the autoclave/microwave is still happening by dumping it at the dumpsites (where it eventually gets burned), there is no reduction in the emission of UPOPs. As per the requirements the use of non-burn technologies for HCW, after treatment the waste needs to be disposed of at a secured landfill or may be used for material recovery.

 

It is recommended that such methods and the technologies be promoted, wherein the final disposal is done by recycling of the plastic parts of the HCW. This would require not only segregation of the HCW (in terms of plastic and other wastes) but also the separation of sharps at the source of the waste generation. In case of HCW plastics, further segregation in terms of types (syringes, bottles, transfusion kits, gloves etc.) would be needed. Segregated component of plastics can then be treated separately using non-burn technologies (autoclave, microwave, gas chambers etc.) and sent for material recovery.

 

It is further recommended that the project, facilitate awareness amongst and demonstration to the stakeholders regarding the practice to recycling of the plastic waste out of HCFs. (please see recommendation 8 as well).

6

Extension to Implementation timelines

There was an initial delay in the start of the implementation of the project. Some of the activities involving long procurement processes are presently underway. These activities are important from the viewpoint of the results and effectiveness of the project. The procurement and subsequent implementation of the activities can only be completed if an extension of a year is granted to the project.

 

Further, in the present case there is a need to provide hands-on training to the ground staff (hospital staff) on the procedures (like segregation of waste, separation of sharps, etc.) to be followed with the introduction of the non-burn technologies for the management of HCW. This should include the pilot run of the whole procedure to be followed for a sufficient period of time. Experience from other projects on health care waste management also highlight that this period after the receipt of the equipment in the HCFs is crucial and requires sufficient time to ensure full acceptance and good operation of the equipment.

 

It is recommended that a one year no-cost extension to the implementation timelines request be considered, if put forth by the implementation in the last year.

7

Prioritize the hardware procurement activities

There is a provision of USD 1.3 million (out of total GEF funding of about USD 4.5 million) for procurement of HCW management equipment. Considering the long procurement process, it is recommended to prioritize procurement of these equipment to ensure timely and proper utilization of this provision.

This will also help towards better overall utilization of the budget for the project.

8

Facilitate implementation of measures/ technologies to dispose of SW in ESM and recycling of plastics in HCW by private sector participation.

There is a high level of interest amongst government counter parts to involve private sector for treatment of SW. The counties where the interventions under the project are being carried out has already initiated efforts in this direction. However, in the absence of any past experience and specific knowledge about the suitable PPP models for treatment of SW, the efforts are not focused. It is recommended that the project facilitate uptake of PPP for disposal of SW and for recycling of plastics in the HCW.  In this regard following sequential activities may be undertaken;

a)       Preparation of a report on the best practices and case studies of PPP for SW in other developing countries having similar situation

b)       Based on a) and specific conditions of Kenya, recommendations regarding SW disposal technologies and recycling of plastics in HCW and the corresponding PPP model

c)        Sensitization of the stakeholders (relevant government officials, politicians, representatives of industry etc.) about the findings of a) and b) above

Study tour of the stakeholders to the countries/locations where such PPP initiatives are working successfully

9

More involvement of private sector (e.g. waste recycling firms) in the project activities

The project design has provided for taking on board the private sector (recyclers) to increase the collection of recyclable waste. Somehow, the level of involvement of the private sector in the project is lagging. It is recommended that the level of involvement of the private sector be increased.

10

Formalize the dropping of the activity to replace mercury devices with non-mercury devices

For the activity of developing the procedure and guidance for the replacement of mercury devices with non-mercury (Target 29). It was found during the survey that the inventory of Thermometers and Sphygmomanometer with mercury is not much at the HCFs. Accordingly, it was decided by the project team that this activity/Target be dropped from the results frame-work of the project. It is recommended to formalize this, through the SC meeting.

11

Hire Technical Advisor for the project

It would help, if the project implementation gets the benefit from the expertise of an international technical expert, hired under a contact for a longer period (part-time) to advise the project team on a regular basis (please see recommendation 11). The project may appoint an international technical expert to help and provide guidance on technical matters.

1. Recommendation:

Review the Targets for reduction in the emission of UPOPs due to Component 3 (Healthcare waste)

The baseline emissions are 19 gTEq/ Yr. The target for emission reduction is also 19 gTEq (Target 48). This is 100% reduction in the emissions. Complete elimination of the emissions of UPOPs from the medical waste is not feasible.

Elsewhere in the ‘Project Document’ (Page 18) different figure has been provided for the emissions of UPOPs (490.1 gTEq/ yr.). It is recommended that the provisions be reviewed and revised (if required)

Management Response: [Added: 2019/12/19] [Last Updated: 2021/01/28]

The 19gTeq was the baseline in 2015 during the PPG stage. It might have increased or decrease. The project team will establish the baseline and revise the target as recommended.

Key Actions:

Key Action Responsible DueDate Status Comments Documents
Revision of the targets for the reduction of UPOPs due to Health care waste
[Added: 2020/01/21]
Project Team, UNDP CO 2020/03 Overdue-Initiated
Communicate the revised target to UNDPRO
[Added: 2020/01/21]
UNDP CO 2020/04 Overdue-Not Initiated
2. Recommendation:

Identify emergency measures for reduction of UPOPs due to burning of SW and facilitate their implementation

The Outcome 4.2 (Target 73) requires reduction in the emissions of UPOPs of 20 gTEq/yr. by implementing the emergency measures. However, the project design has not provided for identification and implementation of the emergency measures to achieve this Target. Although, the project design has provided for capacity building and awareness creation etc. the emergency measures, there are no provisions in the project budget to support implementation of the emergency measures.

It is recommended that the provisions in the project design be made for identification and facilitating implementation of the emergency measures.

Management Response: [Added: 2019/12/19] [Last Updated: 2021/01/28]

The capacity building on measures to reduce open burning is informed by the identification of gaps in the ongoing operations of dumpsites at the counties. Emergencies occurrence of fires when generated deliberately or through methane from organic waste does occur. The emergency measures have not been clearly outlined by the project capacity building plan. Though some elements have been covered in the overall capacity building action. The project team will identify and document the emergency measures to be promoted.

Key Actions:

Key Action Responsible DueDate Status Comments Documents
Definition/identification of emergency measures to address emergency situations at the dumpsites
[Added: 2020/01/21]
Project Team 2020/03 Overdue-Initiated
Emergency measures capacity building plan developed and mainstreamed in project implementation.
[Added: 2020/01/21]
Project Team, UNDP CO 2020/03 Overdue-Initiated
3. Recommendation:

Promote alternatives to dumping of Organic Solid Waste

The project is promoting recovery of recyclable materials (metals, plastics, glass, paper) at the source of generation of the ‘solid waste’. In the baseline situation recovery of such inert materials was happening at the dumpsites (except for the paper) for the SW. Thus, in the baseline the inert components of the SW were not leading to emissions of UPOPs.

Recovery of recyclable materials at the point of generation of waste (instead of the dumpsites) is good, however, it is not leading to any reduction in the emissions of UPOPs as there is no reduction in the quantum (except some waste paper) and composition of the material getting burned at the dumpsites. It is recommended that the target (Target 74) for reduction in the emissions of UPOPs due to 3Rs be reviewed and made flexible to include the activities like composting by CBOs at the local level.

The project is already promoting alternate methods for disposal of ‘decay-able organic solid waste’ at the community level by the CBOs using composting/ vermicomposting technologies, but the scale of such activities is very low. It is recommended that the project further promote the composting/vermicomposting at the level of CBOs, to dispose of the organic component of the SW, which doesn’t lead to emission of UPOPs and help to achieve the Target of reduction of 3 gTEq/ Yr. due to waste segregation.

 

 

Management Response: [Added: 2019/12/19] [Last Updated: 2021/01/28]

The Project partners agree with this finding.  The partners will review actions to take on board recommendations.

Key Actions:

Key Action Responsible DueDate Status Comments Documents
Revision of Target 74 to include composting
[Added: 2020/01/21]
Project Team, UNDP CO 2020/03 Overdue-Initiated History
Revision of the workplan to include the recommended scale-up of composting actions by the community
[Added: 2020/01/21]
Project Team, UNDP CO 2020/03 Overdue-Initiated
4. Recommendation:

Review of the provisions regarding PRTR

Outcome 1.2: Monitoring activities intensified and strengthened and PRTR database in place, has provided for the laboratory equipment and other such related activities.

However, quantification and monitoring of the emissions of POPs and other hazardous chemicals is mostly done using the emission factors, mass balance methods, engineering calculations and activity rates etc. Thus, although strengthening of the capacity in the country to carry out laboratory operations is good, it is not contributing towards the overall objective of the project.

It is recommended that the provision of Activities/Targets for Outcome 1.2 be reviewed and if required suitably modified.

Management Response: [Added: 2019/12/19] [Last Updated: 2021/01/28]

Management Response:  The project team notes that the actions will not contribute towards the objective. However, the information collected is important documentation of the trends at the hotspots and will enable appropriate deductions on the underlying reasons. In Kenya under the Environment and Management coordination Act physical laboratory assessment are the only methods for indicators currently recognized.  UNEP toolkits are not recognized by policies and regulations so far. The BAT/BEP guidelines on waste that contain POPs also are explicit on sampling and monitoring of POPs and UPOPs

Key Actions:

Key Action Responsible DueDate Status Comments Documents
Development of PRTR to provide empirical information on trends of UPOPs emissions at hotspots in Kenya
[Added: 2020/01/21]
Project Team, UNDP CO 2020/05 Overdue-Initiated
Revise the activities to include quantification of emissions using the UNEP toolkits.
[Added: 2020/01/21]
Project Team, UNDP CO 2020/03 Overdue-Initiated
Revise the activities to include quantification of emissions using the UNEP toolkits.
[Added: 2020/01/21]
Project Team, UNDP CO 2020/03 Overdue-Initiated
5. Recommendation:

Promote recycling of plastics in HCW

The project is supporting use of non-burn technologies (Autoclave, Microwave) for disposal of HCW. Thus, the project is leading to disposal of HCW in an ESM. However, as the final disposal of the shredded waste out of the autoclave/microwave is still happening by dumping it at the dumpsites (where it eventually gets burned), there is no reduction in the emission of UPOPs. As per the requirements the use of non-burn technologies for HCW, after treatment the waste needs to be disposed of at a secured landfill or may be used for material recovery.

 

It is recommended that such methods and the technologies be promoted, wherein the final disposal is done by recycling of the plastic parts of the HCW. This would require not only segregation of the HCW (in terms of plastic and other wastes) but also the separation of sharps at the source of the waste generation. In case of HCW plastics, further segregation in terms of types (syringes, bottles, transfusion kits, gloves etc.) would be needed. Segregated component of plastics can then be treated separately using non-burn technologies (autoclave, microwave, gas chambers etc.) and sent for material recovery.

 

It is further recommended that the project, facilitate awareness amongst and demonstration to the stakeholders regarding the practice to recycling of the plastic waste out of HCFs. (please see recommendation 8 as well).

Management Response: [Added: 2019/12/19] [Last Updated: 2021/01/28]

The PMU and stakeholders agree with this.  The partners are meeting in January to give direction on this.

Key Actions:

Key Action Responsible DueDate Status Comments Documents
Technical Committee meeting develops recycling action plan
[Added: 2020/01/21]
Project Team, UNDP CO 2020/03 Overdue-Initiated
Develop an awareness and demonstration of Health Care Facility plastic waste recycling manual/kit and a dissemination plan of action
[Added: 2020/01/21]
Ministry of Health, Ministry of Environment and Forestry and National Environmental Management Authority 2020/03 Overdue-Initiated
6. Recommendation:

Extension to Implementation timelines

There was an initial delay in the start of the implementation of the project. Some of the activities involving long procurement processes are presently underway. These activities are important from the viewpoint of the results and effectiveness of the project. The procurement and subsequent implementation of the activities can only be completed if an extension of a year is granted to the project.

 

Further, in the present case there is a need to provide hands-on training to the ground staff (hospital staff) on the procedures (like segregation of waste, separation of sharps, etc.) to be followed with the introduction of the non-burn technologies for the management of HCW. This should include the pilot run of the whole procedure to be followed for a sufficient period of time. Experience from other projects on health care waste management also highlight that this period after the receipt of the equipment in the HCFs is crucial and requires sufficient time to ensure full acceptance and good operation of the equipment.

 

It is recommended that a one year no-cost extension to the implementation timelines request be considered, if put forth by the implementation in the last year.

Management Response: [Added: 2019/12/19] [Last Updated: 2021/01/28]

The constraints on procurement occasioned in the initial start have been largely addressed. This will facilitate the attainments of most of the project targets. The PMU team feels that this will be achievable. The project team will endeavor to complete the project as originally planned.

Key Actions:

Key Action Responsible DueDate Status Comments Documents
Multi-year Annual workplans 2020 and 2021 to fully cover the planned activities to project end.
[Added: 2020/01/21]
Project Team, UNDP CO, UNDP RSC 2020/02 Overdue-Initiated
Adaptive management to fast track planned activities for 2020/21
[Added: 2020/01/21]
Project Team, UNDP CO 2020/02 Overdue-Initiated
Seek project extension if key actions for sustainability are yet to be realized and no other solution is identified to complete all activities by the planned completions dates. It is generally not recommended to extend project duration and all other alternate solutions to accelerate delivery and satisfactory completion by the agreed deadline will be preferred
[Added: 2020/01/21]
Implementing Partner, UNDP CO 2020/11 Overdue-Not Initiated
7. Recommendation:

Prioritize the hardware procurement activities

There is a provision of USD 1.3 million (out of total GEF funding of about USD 4.5 million) for procurement of HCW management equipment. Considering the long procurement process, it is recommended to prioritize procurement of these equipment to ensure timely and proper utilization of this provision.

This will also help towards better overall utilization of the budget for the project.

Management Response: [Added: 2019/12/19] [Last Updated: 2021/01/28]

The project team agree with the recommendation.  The specifications for hard ware have been agreed with and procurement will proceed as expected. In addition, MEF has required that all procurement plans be shared by Feb 2020

Key Actions:

Key Action Responsible DueDate Status Comments Documents
Identify and provide specification of all the hardware for the Health Care Waste management
[Added: 2020/01/21]
Project Team, UNDP CO 2020/03 Overdue-Initiated
Procurement plan to cover all the hardware for the Health Care Waste management. Procurement to follow as planned
[Added: 2020/01/21]
Project Team, UNDP CO 2020/07 Overdue-Initiated
8. Recommendation:

Facilitate implementation of measures/ technologies to dispose of SW in ESM and recycling of plastics in HCW by private sector participation.

There is a high level of interest amongst government counter parts to involve private sector for treatment of SW. The counties where the interventions under the project are being carried out has already initiated efforts in this direction. However, in the absence of any past experience and specific knowledge about the suitable PPP models for treatment of SW, the efforts are not focused. It is recommended that the project facilitate uptake of PPP for disposal of SW and for recycling of plastics in the HCW.  In this regard following sequential activities may be undertaken;

a)       Preparation of a report on the best practices and case studies of PPP for SW in other developing countries having similar situation

b)       Based on a) and specific conditions of Kenya, recommendations regarding SW disposal technologies and recycling of plastics in HCW and the corresponding PPP model

c)        Sensitization of the stakeholders (relevant government officials, politicians, representatives of industry etc.) about the findings of a) and b) above

Study tour of the stakeholders to the countries/locations where such PPP initiatives are working successfully

Management Response: [Added: 2019/12/19] [Last Updated: 2021/01/28]

The partners concur that SW management at county level requires private sector investment to be sustainable. Kenya as a country is yet to identify disposal technologies that will work for the volumes generated at urban settlements. The recommendations are fully taken.

Key Actions:

Key Action Responsible DueDate Status Comments Documents
Develop a private sector dialogue and engagement framework
[Added: 2020/01/21]
Project Team 2020/03 Overdue-Not Initiated
Preparation of a report on the best practices and case studies of PPP for SW in other developing countries having similar situation
[Added: 2020/01/21]
Project Team 2020/12 Overdue-Not Initiated
Based on a) and specific conditions of Kenya, recommendations regarding SW disposal technologies and recycling of plastics in HCW and the corresponding PPP model
[Added: 2020/01/21]
Project Team 2020/12 Overdue-Not Initiated
Sensitization of the stakeholders (relevant government officials, politicians, representatives of industry etc.) about the findings of a) and b) above
[Added: 2020/01/21]
Project Team 2021/03 Not Initiated
Study tour of the stakeholders to the countries/locations where such PPP initiatives are working successfully
[Added: 2020/01/21]
Project Team, UNDP CO 2021/03 Not Initiated
9. Recommendation:

More involvement of private sector (e.g. waste recycling firms) in the project activities

The project design has provided for taking on board the private sector (recyclers) to increase the collection of recyclable waste. Somehow, the level of involvement of the private sector in the project is lagging. It is recommended that the level of involvement of the private sector be increased.

Management Response: [Added: 2019/12/19] [Last Updated: 2021/01/28]

The roles of private sector players in waste recycling to be identified and linkages with the community collectors facilitated.

Key Actions:

Key Action Responsible DueDate Status Comments Documents
Potential areas for Private Sector engagement in the waste recycling value chain clearly identified for the respective counties
[Added: 2020/01/21]
Project Team 2020/05 Overdue-Not Initiated
MOUs/Supply Contracts signed with the companies that contain targets and the support to attain increase in recycling
[Added: 2020/01/21]
Project Team 2020/09 Overdue-Not Initiated
10. Recommendation:

Formalize the dropping of the activity to replace mercury devices with non-mercury devices

For the activity of developing the procedure and guidance for the replacement of mercury devices with non-mercury (Target 29). It was found during the survey that the inventory of Thermometers and Sphygmomanometer with mercury is not much at the HCFs. Accordingly, it was decided by the project team that this activity/Target be dropped from the results frame-work of the project. It is recommended to formalize this, through the SC meeting.

Management Response: [Added: 2019/12/19] [Last Updated: 2021/01/28]

The partners agree to the recommendation

Key Actions:

Key Action Responsible DueDate Status Comments Documents
Revision of Target 29 through the PSC
[Added: 2020/01/21]
Project Team UNDP CO 2020/03 Overdue-Initiated
Monitoring of the replacement of equipment with mercury to continue but not as part of the project reporting targets
[Added: 2020/01/21]
Project Team 2021/05 Not Initiated
11. Recommendation:

Hire Technical Advisor for the project

It would help, if the project implementation gets the benefit from the expertise of an international technical expert, hired under a contact for a longer period (part-time) to advise the project team on a regular basis (please see recommendation 11). The project may appoint an international technical expert to help and provide guidance on technical matters.

Management Response: [Added: 2020/01/21] [Last Updated: 2021/01/28]

This technical advisor would be valuable in monitoring and evaluation of delivery against the Stockholm Convention requirements

Key Actions:

Key Action Responsible DueDate Status Comments Documents
Review budgets and activities to identify resources for the engagement of technical advisory services
[Added: 2020/01/21]
Project Team, UNDP CO 2020/03 Overdue-Initiated
Engage technical advisor as allowed by resources, as and when required
[Added: 2020/01/21]
Project Team UNDP CO 2021/05 Initiated

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