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ESMS for CHNP i
Environmental and Social Management System (ESMS)
Community-Based Health and Nutrition to Reduce Stunting Project
Millennium Challenge Account – Indonesia (MCA-Indonesia)
March 2016
ESMS for CHNP ii
ESMS for CHNP iii
Table of Contents
1. INTRODUCTION ................................................................................................. 1
2. BACKGROUND .................................................................................................. 2
2.1 Overview of the MCA Indonesia ESMS Policy Statement ............................... 2
2.2 Environmental and Social Safeguards and the ESMS ....................................... 3
2.2.1 MCA-Indonesia’s ESMS Framework ........................................................................................ 3
2.2.2 IFC Performance Standards .................................................................................................... 4
2.2.3 ESMS Framework ......................................................................................................................... 5
3. OVERVIEW OF THE COMMUNITY-BASED HEALTH AND NUTRITION TO REDUCE STUNTING PROJECT ............................................................................................ 7
3.1 Project Activities and Implementation Structure.................................................... 7
3.2 Tier-2 ESMS for the Community Based Health and Nutrition Project .......... 13
3.2.1 Environmental and Social Legal Framework for CHNP ................................................. 14
3.2.2 Prohibited Activities .................................................................................................................. 16
3.2.3 Screening Checklist ................................................................................................................... 16
3.2.4 Identification of Environmental and Social Impacts and Risks .................................. 18
4. ACTIVITY 1: COMMUNITY PROJECT ACTIVITY AS DEMAND SIDE .......... 23
4.1 Implementation of Activity 1 ........................................................................................23
4.2 Sharing of Information with Activities 2 and 3 .....................................................23
5. ACTIVITY 2: SUPPLY SIDE ACTIVITY ........................................................... 25
5.1 Implementation of Activity 2 ........................................................................................25
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5.2 Training health service providers and facilitators ................................................25
5.2.1 Environmental and Social Management ............................................................................. 25
5.2.2 Stakeholder Engagement and Social Inclusion............................................................... 26
5.2.3 Grievance Mechanism .............................................................................................................. 26
5.2.4 Environmental and Social Reporting ................................................................................. 26
5.3 Micronutrient Provision ................................................................................................. 27
5.3.1 Environmental and Social Management ............................................................................. 28
5.3.2 Social Inclusion and Stakeholder Engagement .............................................................. 29
5.3.3 Grievance Mechanism .............................................................................................................. 29
5.3.4 Environmental and Social Reporting ................................................................................. 30
5.4 Sanitation and Hygiene ................................................................................................ 30
5.4.1 Environmental and Social Management ............................................................................ 30
5.4.2 Stakeholder Engagement and Social Inclusion ............................................................... 31
5.4.3 Grievance Mechanism.............................................................................................................. 32
5.4.4 Environmental and Social Reporting ................................................................................. 32
6. ACTIVITY 3: COMMUNICATIONS, MANAGEMENT AND EVALUATION ... 33
6.1 Environmental and Social Management .................................................................. 33
6.2 Stakeholder Engagement and Social Inclusion ................................................... 33
6.3 Grievance Mechanism ................................................................................................... 34
6.4 Environmental and Social Reporting ...................................................................... 34
7. CHNP-WIDE ENVIRONMENTAL AND SOCIAL ACTION PLAN .................. 35
7.1 Social and Gender Integration Plan .......................................................................... 38
7.2 Grievance Mechanism ................................................................................................... 38
7.3 Occupational Health and Safety ............................................................................... 39
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7.4 Land Acquisition and Resettlement ........................................................................ 39
7.5 Indigenous People .......................................................................................................... 40
8. INSTITUTIONALIZATION OF THE CHNP ESMS............................................ 41
8.1 Implementation and Management of CHNP ........................................................... 41
8.2 Roles and Responsibilities for the CHNP ESMS ................................................... 43
8.3 CHNP Internal Capacity Assurance .......................................................................... 43
8.4 Budget Requirements for Effective CHNP ESMS Implementation ............... 44
8.5 Capacity Development and ESMS Roll-Out .......................................................... 44
8.6 Compliance and Environmental Audit .................................................................... 45
8.7 Reporting of Environmental and Social Performance ....................................... 45
8.8 Review and Revision of ESMS for CHNP ................................................................ 45
APPENDIX
A. Multiple Micronutrient Product (MMNP) Traceability Guidance ...................... 47
B. Indigenous Peoples Plan Framework (IPPF) .......................................................... 50
C. Example of Statement Letter for Land Donation ................................................. 55
D. List of Available Operational Guidelines for the CHNP ...................................... 56
ESMS for CHNP vi
Abbreviations
BPOM : Badan Pengawasan Obat dan Makanan (Food and Drugs Authority)
CHNP : The Community-Based Health and Nutrition to Reduce Stunting
ECOPs : Environmental and Social Code of Practices
ESMS : Environmental and Social Management System
ESP : Environmental and Social Performance
ESAP : Environmental and Social Action Plan
ESMP : Environmental and Social Management Plan
GOI : Government of Indonesia
GSC : Generasi Sehat dan Cerdas (Health and Smart Generation)
IFC – PS : International Finance Corporation Performance Standards
IPPF : Indigenous Peoples Planning Framework
IPP : Indigenous Peoples Plan
ISO : International Organization for Standarization
MCA-Indonesia: Millennium Challenge Account Indonesia
MCC : Millennium Challenge Corporation
M&E : Monitoring and Evaluation
PNPM : Program Nasional Pemberdayaan Masyarakat (The National Program
for Community Empowerment).
PS : Performance Standard
PSF : PNPM Support Facility
PTO : Petunjuk Teknis Operational (Technical Operational Manual)
QA&QC : Quality Assurance and Quality Control
SNI : Standar Nasional Indonesia (National Indonesia Standard)
STBM : Sanitasi Total Berbasis Masyarakat (Community LedTotal Sanitation)
TTD : Tablet Tambah Darah (Iron Pills)
WHO : World Health Organization
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1. Introduction
The Community-based Health and Nutrition to Reduce Stunting Project or “CHNP” is
one of three main projects under the Indonesia Compact funded by the Millennium
Challenge Corporation (MCC) and implemented by the Millennium Challenge Account
Indonesia (MCA-Indonesia). CHNP is subject to comply with environmental and social
safeguards described in the MCC Environmental Guidelines. To achieve this, MCA-
Indonesia has developed the MCA-Indonesia Environmental and Social Management
System (ESMS) Framework as the main reference for environmental and social
management in MCA-Indonesia and to act as the Tier-1 main policy and
implementation framework for the tiered approach ESMS in the Indonesia Compact.
The Tier-1 ESMS served as the basis for development of ESMS’ for the three compact
projects, referred to as Tier-2 ESMS or Project-level ESMS. For CHNP, the Project ESMS
is described in this document. The CHNP ESMS describes the commitment of the
Project, and describes how the activities under the Project will conform to
environmental and social performance requirements of the Compact. This ESMS has
been tailor-made to the nature and scale of CHNP. This draft also acknowledges the
project design decisions and tools developed by CHNP initiated as a result of previous
drafts of the ESMS and discussions between the Project team and ESP.
The ESMS applies to all three core activities1 of the CHNP, namely: (i). Community
Project Activity as the Demand Side; (ii). Supply Side Activity, and (iii).
Communications, Management and Evaluation; as well as to all parties involved in
implementation of the activities.
Where applicable, the CHNP ESMS document shall be supplemented by a series of
guidelines, manuals and tools to provide clear operational guidance for all parties. This
document may be modified from time to time with the mutual agreement of the MCC
and MCA-Indonesia and will be available in the MCA-Indonesia website (www.mca-
indonesia.go.id) for public access.
For the Community Project Activity component, besides this ESMS, the project
activities will also adhere to the Technical Guideline for Environmental and Social
Safeguards Policy of the Generasi Sehat dan Cerdas (GSC). The guideline is attached
in the GSC Technical Operational Manual or Petunjuk Teknis Operasional (PTO) 2016.2
The guidelines will be available on the GSC website3.
1 Described in the “Gambaran Umum PKGBM (Proyek Kesehatan dan Gizi Berbasis Masyarakat)”, Millennium Challenge Account Indonesia, December 2013. 2 When this ESMS developed, the GSC Technical Operation Manual or Petunjuk Teknis Operasional (PTO) have obtained approval or no objection from the World Bank and has been socialized to the Provincial and District levels. Currently, the Safeguards Guideline is available only in Bahasa Indonesia version. 3 The GSC website still under construction when this ESMS developed.
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2. Background The Millennium Challenge Corporation (MCC) has entered into a Compact with the
Government of Indonesia (GoI) to support the Government’s development objectives
in three important areas: green growth, health and nutrition, and procurement. The
Compact is managed as three separate projects, namely the Green Prosperity Project
(GP Project), the Community-based Health and Nutrition to Reduce Stunting Project
(CHNP) and the Procurement Modernization Project (PM Project). GoI established a
trust institution – the Millennium Challenge Account Indonesia (MCA-Indonesia) – to
manage and implement the Compact and its three projects on behalf of the GoI. The
Compact entered into force on April 2, 2013 and its five-year timeline will conclude on
April 1, 2018.
2.1 Overview of the MCA Indonesia ESMS Policy Statement MCA-Indonesia has established an Environment and Social Management System
(ESMS) for the overall Compact, called the MCA-Indonesia ESMS Framework (Tier 1
ESMS Framework). The Tier 1 ESMS Framework sets the tone and spirit for MCA-
Indonesia’s programs, and is intended to ensure that all operations and investments of
MCA-Indonesia comply with the relevant laws and regulations of the Government of
Indonesia, MCC Environmental Guidelines, and the MCC Gender Policy, and are
consistent with the International Finance Corporation (IFC) Performance Standards
(PS)4.
The objectives of the ESMS Framework are as follows:
1. To ensure all activities and actors anticipate and take action to avoid adverse impacts or risks to communities and the environment;
2. To identify and evaluate environmental and social risks and impacts of the project;
3. To adopt a mitigation hierarchy to anticipate and avoid, or where avoidance is not possible, minimize, and, where residual impacts remain, compensate/offset for risks and impacts to workers, affected communities, and the environment;
4. To promote improved environmental and social performance of all actors and activities through the effective use of management systems;
5. To ensure that grievances from affected communities and external communications from other stakeholders are responded to and managed appropriately;
6. To promote and provide means for adequate engagement with affected communities throughout the project cycle on issues that could potentially affect them and to ensure that relevant environmental and social information is disclosed and disseminated;
7. To ensure all activities and actors consciously foster positive environmental and social impacts and benefits through proactive planning and project design.5
4As described in the Millennium Challenge Compact between the United States of America, acting through the Millennium Challenge Corporation, and the Republic of Indonesia, Annex 1. 5 MCA-Indonesia, Environmental and Social Management System Framework, Tier 1, February 2013.
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Based on the Tier 1 ESMS Framework, a second tier ESMS developed for each of the
three projects, including for CHNP. This CHNP ESMS was prepared through desk
review of relevant materials (developed by MCC, MCA-Indonesia and consultants, as
well as relevant with Program Nasional Pemberdayaan Masyarakat (PNPM) Generasi
and PNPM Rural documents), review of Indonesian regulations and references from
the International Finance Corporation Performance Standards, discussions with MCA-
Indonesia and consultants, as well as participation in site visits.
To ensure that the ESMS Framework is well established and integrated into MCA-
Indonesia operations, MCA-Indonesia has tasked the Environmental and Social
Performance (ESP) unit in MCA-Indonesia (led by the ESP Director) to provide overall
oversight and support to MCA-Indonesia and each of the three main Project. The ESP
Unit will also provide technical inputs and reviews to project activities, serve as cross-
cutting expert on ESP management and act as representative and primary point of
contact with regards to environmental and social safeguards of the Compact.
The MCA-Indonesia Environmental and Social Performance (ESP) Director will be
responsible for ensuring that all investments and operations comply with the ESMS
Framework, while the MCA-Indonesia Executive Director (Chief Executive Officer) is
ultimately held accountable for upholding the environmental and social policy.
2.2 Environmental and Social Safeguards and the ESMS
2.2.1 MCA-Indonesia’s ESMS Framework
The first tier ESMS developed for the overall compact is called the MCA-Indonesia
ESMS Framework and acts to guide environmental and social performance for MCA-
Indonesia. The MCA-Indonesia ESMS Framework presents a policy statement from
MCA-Indonesia on environmental and social performance and sets the tone and spirit
for environmental and social management in MCA-Indonesia projects and activities,
and is intended to ensure that all operations and investments of MCA-Indonesia
comply with the relevant laws and regulations of the Government of Indonesia, MCC
Environmental Guidelines and MCC Gender Policy, and are consistent with the
International Finance Corporation Performance Standards (IFC Performance
Standards).6
MCA-Indonesia ESMS Framework Policy Statement
MCA-Indonesia investments and operations aim to maximize environmental and social benefits for the people of Indonesia (including women and marginalized groups), and minimize the adverse impacts to the environment and society. As such, all MCA-Indonesia investments and operations shall comply with the ESMS Framework, which is based on laws and regulations of the Government of Indonesia, MCC Environmental Guidelines and Gender Policy, and the IFC Performance Standards on Environmental and Social Sustainability.
6As described in the Millennium Challenge Compact between the United States of America, acting through the Millennium Challenge Corporation, and the Republic of Indonesia.
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The Tier 1 ESMS Framework has established six elements required of all MCA-Indonesia
investments, projects and operations. The six elements intended to guide the design
of the project and the institutional arrangement at the Project level. The six
environmental and social safeguard elements in the MCA-Indonesia ESMS are shown
in Figure 1 below.
Figure1: The six elements of MCA-Indonesia’s ESMS Framework
The principle elements will be addressed in this CHNP ESMS. It is worth noting that the
early drafts of the CHNP ESMS had informed the design of the CHNP activities, and
influenced the development of documents and operational tools for the CHNP
activities. Therefore, element E1 will not be further elaborated in this document.
The ESMS thus also guides CHNP to conform to the Compact-wide systems that exist
or are developed outside of this ESMS. For element E3, Disclosing Information and
Engaging Stakeholders, the CHNP is expected to follow the MCA-Indonesia
Stakeholder Engagement Plan, and the Information Disclosure Policy. For element E5,
the CHNP is expected to utilize the MCA-Indonesia Grievance Mechanism developed
for the entire Compact.
This CHNP ESMS document, will therefore, focus its discussion on the following
elements:
E2: Understanding of Risks and Benefits
E4: Designing and Implementing Environmental and Social Action Plans
E6: Compliance Monitoring, Reporting and Evaluation.
2.2.2 IFC Performance Standards
At the activity-level, IFC Performance Standards (IFC PS) provide more specific
principles to abide by, depending on which performance standards are triggered by
an activity. The IFC Performance Standards are based on the IFC Sustainability
Framework effective 1 January, 2012 and consist of the following:
Environmentally and Socially Sensitive Project Design
Understanding of Risks and Benefits
Disclosing Information and Engaging Stakeholders
Designing and Implementing Environmental and Social Action Plans
Developing and Instituting Grievance Mechanisms
Compliance Monitoring, Reporting and Evaluation
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Performance Standard 1: Assessment and Management of Environmental and
Social Risks and Impacts
Performance Standard 2: Labor and Working Conditions
Performance Standard 3: Resource Efficiency and Pollution Prevention
Performance Standard 4: Community Health, Safety, and Security
Performance Standard 5: Land Acquisition and Involuntary Resettlement
Performance Standard 6: Biodiversity Conservation and Sustainable
Management of Living Natural Resources
Performance Standard 7: Indigenous Peoples
Performance Standard 8: Cultural Heritage
PS1 (Assessment and Management of Environmental and Social Risks and Impacts)
applies to all activities, and overlaps with E2: Understanding of Risks and Benefits, and
will be discussed further in this document. Identification of risks and impacts will
determine which of the other performance standards apply to an activity. Relevance
of PS2 to 8 to an activity is determined at the risk/impact identification process.
Compliance with GoI laws and regulations is part of IFC PS and is also embedded into
this ESMS. A detailed reference to the IFC PS Sustainability Framework, guidance
notes, and handbooks can be obtained through the IFC website at http//www.ifc.org.
2.2.3 ESMS Framework
A typical ESMS will generally consist of the following components: 1) policy statement
and framework; 2) environmental and social analysis and assessment; and 3)
environmental and social management plan as shown in Figure 2 below.
Figure 2: Typical ESMS Components
Policy
Assessment & Analysis
Management Plan
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Policy: The policy, or policy statement, will state the environmental and social
safeguard policies, standards, framework, and/or guidelines that the project adheres
to. The policy must outline policies, guidelines, etc. that are at par or are more stringent
than that stipulated in the MCA-Indonesia ESMS Framework and outlined in previous
sections above.
Assessments and Analysis: Initial or primary due diligence, environmental audits, gap
analysis, screening and/or scoping shall be conducted where applicable to identify and
recommend any required environmental and social assessments, analysis or studies
based on identified risks and impacts, or triggered performance standards. These
assessments, analyses and studies may include the need for a full or partial
Environmental (and potentially Social) Impact Assessments (EIA/ESIA) or a
supplementary EIA/ESIA, and, if needed, specific studies/supplementary studies (e.g.
studies on Indigenous Peoples (IP), Cultural Heritage (CH), land acquisition and
resettlement, audit, etc.).
The above assessments, analysis and studies combined will lead to the development
of a set of environmental and social action plans (ESAP) to mitigate any potential
environmental risks or impacts. Ultimately all the above will also contribute and/or lead
to the requirement to fulfill environmental permits (Ijin Lingkungan). Under Indonesian
law, an environmental permit is prerequisite for applying for other technical permits.
Management Plan: Each level ESMS that results in a set of action plans should be
followed through with the development of an Environmental and Social Management
Plan (ESMP). The ESMP will consist of the comprehensive management of the
implementation and monitoring of all environmental and social risk and impact
mitigation measures, derived from all assessment and study efforts conducted on the
project. This must also include the budgeting of costs to cover mitigation measures,
which will then input into the project costing or feasibility study.
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3. Overview of the Community-based Health and
Nutrition to Reduce Stunting Project
3.1 Project Activities and Implementation Structure The project objective is to reduce and prevent low birth weight, childhood stunting
and malnourishment of children in project areas, and to increase household income
through cost savings, productivity, growth and higher lifetime earnings. The project
has three core components7 that are interlinked, namely: (i). Community Project
Activity as Demand Side; (ii). Supply Side Activity, and (iii). Communications,
Management and Evaluation. The CHNP is implemented through partnerships with the
Ministry of Health and the PNPM Support Facility (PSF). Project activities will be
implemented in 499 sub-districts, spread over 64 districts in 11 provinces, namely West
and East Java, West and East Nusa Tenggara, Gorontalo, Maluku, North and West
Sulawesi, West and Central Kalimantan, and South Sumatra.
Below is an overview of the three activities of the CHNP.
i). Community Project Activity as Demand
Side
The objective of this activity is to develop
sustainable community demand for nutrition
and health services. The activity includes
providing community facilitators,
participatory planning, and community block
grants. This activity is implemented in
partnership with the GOI’s Program called
Program Generasi Sehat dan Cerdas
(hereafter referred to as GSC).
The three sub-activities are complementary.
The participatory planning is aimed to
improve the capacity of communities and
local government officials to plan and manage community-based development
activities. Facilitators are assigned to assist the participatory planning process.
Development activities resulting from the participatory planning will be financed
through community grants delivered through the Community Direct Aid (Bantuan
Langsung Masyarakat).
7 Described in the “Gambaran Umum PKGBM (Proyek Kesehatan dan Gizi Berbasis Masyarakat)”, Millennium Challenge Account Indonesia, December 2013.
Stunting
Community Project
Activity as Demand
Side
Supply Side Activity
Communication, Management
and Evaluation
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ii). Supply Side Activity
The objective of this activity is to strengthen capacities of health providers to be able to provide better quality and coverage of health and nutrition services. Supply Side Activity involves both service providers and the private sector.
The key interventions under the Supply Side activities are described below.
a. Training for health service providers and facilitators 8
Training activities will be held in 11 provinces to improve knowledge and skills of
health service providers and government officials at project locations. The
topics include food for pregnant mothers, infants and toddlers; growth
monitoring, sanitation triggering; and training for facilitators.
To complement the Growth Monitoring Training, the Project will supply
anthropometry Kits to Puskesmas in project locations. The objective is to
support growth monitoring by measuring the length or height of children in the
project locations.
b. Provision of Micronutrients
The project will provide micronutrients to children in selected locations in three
provinces, namely South Sumatra Selatan, West and Central Kalimantan. If
proven successful following a 6 month pilot period, the distribution of
micronutrients may be expanded to other project locations. In addition,
micronutrient supplements will also be provided to pregnant women in 11
provinces.
Micronutrients for children – Micronutrients will be given to children of the age
of 6 to 24 months, following the specifications stated in the Ministry of Health’s
regulation No 41, 2013 on Micronutrient Standards. Micronutrients will be made
available in sachets, and to be given to children in the project locations every
other day. The micronutrients, known by the name Taburia, will be distributed
to the community through the District-level Pharmaceutical Warehouse, the
Puskesmas and Posyandu in three provinces.
Micronutrients for pregnant women – Pregnant women in project locations will
be given iron pills (Tablet Tambah Darah/TTD), containing Iron equivalent to 60
mg of elemental iron, and Folic Acid 400 micrograms (.4 mg), in accordance
with the most recent Government regulation (Permenkes No. 88, 2014). Every
pregnant woman is expected to consume 90 tablets during her pregnancy. The
pills will be distributed to the community through the District-level
Pharmaceutical Warehouse, the Puskesmas and Posyandu in 11 provinces.
c. Sanitation and Hygiene Behavior
MCA-Indonesia plans to support the GOI’s Community Led Total Sanitation
(CLTS)9 program as a means to support anti-stunting initiatives. The project is
collaborating with the Government’s efforts to improve sanitation through the
8 Source: “Gambaran Umum PKGBM (Proyek Kesehatan dan Gizi Berbasis Masyarakat)”, Millennium Challenge Account Indonesia, December 2013. 9 Or known by the Indonesian acronym STBM (Sanitasi Total Berbasis Masyarakat).
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implementation of the Sanitasi Total Berbasis Masyarakat (STBM) approach.
The approach aims at changing community behaviour (e.g. reducing open
defecation) and encouraging them to develop their own facilities. The project
will not provide financial support (subsidy) for physical infrastructure, but will
instead support a range of capacity building activities to be undertaken at the
communities targeted for intervention.
The activities to be conducted are as follows: a) socialization at the Province,
District and Sub-District levels; b) training activities for sanitarians and village
cadres; c) triggering at the village level for interested villages; d) post-triggering
monitoring; e) incentives for health service providers10, f) training and mentoring
of sanitation entrepreneurs.
d. Private Sector Response Activity
This activity will establish areas of collaboration with private sector partners
through the lens of market gaps that have resulted in poor access, affordability
and/or awareness of, sanitation and hygiene. The objective is to catalyse greater
private sector investment and support public-private partnerships that develop
market driven solutions to address community needs for, better hygiene
practices, safe water and sanitation. The activity plans to award grants to
private companies, NGOs and/or trade/industry associations, covering a wide
range of activities, in sanitation and hygiene.
iii). Communications, Management, Monitoring and Evaluation
a. Communications
The project will conduct a public awareness campaign that reaches the national
level and village level, using mixture of media. A formative study has been
conducted and resulted in a National Nutrition Communication Campaign
Strategy (dated April 2015) that is referenced here.
The National Nutrition Communication Campaign (NNCC) Strategy identified
the following target groups:
Primary
target
audience
Young mothers between 18 and 35 years of age with children
under two years of age, living mostly in rural and semi–urban
areas.
Secondary
target
audience
Husbands; predominantly conservative men who still think that
child health care and nutrition is a women's affair
Mothers or mothers in–law of the primary target audience;
generally women in the 50 years range or older. Many are very
traditional and still believe in superstition and myths with regards
to health care, child care and nutrition.11
10 This activity and others might not be included in the final implementation of the project. However, this ESMS is intended to cover the possibility of activities included in the earlier documents on the project design. 11 National Nutrition Communication Campaign Strategy Design, draft March 2015.
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Messages will be delivered through an integrated mix of the following
approaches:
interpersonal and group communication activities, (group meetings,
one–one–one interactions, and advocacy targeting key stakeholders)
using sets of professionally developed communication materials; and
professionally produced electronic mass media (mainly television) for
dissemination via national and regional media outlets, as well as
production of posters and banners;
complemented by the use of web–based platforms (i.e., Facebook,
Twitter, and an NNCC website). Given the high level of cell phone
ownership, the use of SMS will be used as an effective way to push short
messages to specific target groups.
Television placement will have a national reach, while other activities will focus
on three districts, one district in each of the three provinces: West and Central
Kalimantan and South Sumatra.
b. Management
This activity is designed to ensure proper management of the three activities.
More discussion is provided in the text below.
c. Monitoring and Evaluation
Monitoring of project progress and evaluation of project achievements will be
done by the Implementing Entity, MCA-Indonesia and MCC. Indicators will be
developed and agreed upon to ensure consistency and continuity.
Implementation of the CHNP is managed through partnerships with the following:
Community Project Activity, with the Generasi Sehat dan Cerdas program,
coordinated by the PSF and the Ministry of Villages, Disadvantaged Regions
and Transmigration12;
Supply Side Activity, with the Ministry of Health;
Communications, Management, Monitoring and Evaluation, with the Ministry
of Health.
For the latter two activities, MCA-Indonesia and Ministry of Health have signed an
Implementing Entity Agreement with the Ministry of Health (initially signed in October
2013, and amended in March 2015). This Implementing Entity Agreement establishes
MCA-Indonesia as the accountable entity responsible for implementation of the
Compact Program, and describes the division of roles and responsibilities between
MCA-Indonesia and Ministry of Health, as its Partner Agency to implement the CHNP.
Within the MCA-Indonesia organization, the Agreement identifies CNHP as responsible
for the implementation of the Project, with support from other divisions. This
document will make reference to MCA-Indonesia as the entity responsible for
implementation, consistent with the Implementing Entity Agreement.
12 Previously, the key government agency in charge of PNPM was the Ministry of Home Affairs. Since the Joko Widodo Administration and the establishment of the Ministry of Villages, Disadvantaged Regions and Transmigration, PNPM management has been moved to this Ministry and change the program name to Generasi Sehat dan Cerdas (GSC). This document will continue to refer to the GSC name, as it relates to a body of knowledge that uses this name; even if, in the future, there is a change in the name of the program.
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CHNP Locations
CHNP activities will be conducted in a total of 64 districts across 11 provinces. Eight
provinces are existing GSC program locations, while three provinces are new additions
to the GSC. The new provinces are South Sumatera, West Kalimantan and Central
Kalimantan.
Community Project Activities, the training component of the Supply Side Activity and
distribution of iron supplements will cover all 64 districts in 11 provinces, while the
provision of Taburia micronutrients and village-level communications activities will be
concentrated in the 22 districts in the three new provinces.
The table and map below show the districts covered by the CHNP.
Table 1. Location of CHNP Activities
Name of Province
No. of Districts
Name of District Name of Province
No. of Districts
Name of District
South Sumatera
5
Musi Banyuasin Banyuasin Ogan Komering Ilir Empat Lawang Ogan Komering Ulu Selatan
NTB (West Nusa
Tenggara) 8
Lombok Tengah Lombok Timur Lombok Utara Lombok Barat Sumbawa Barat Sumbawa Dompu Bima
West Kalimantan
9
Kapuas Hulu Sintang Melawi Ketapang Sekadau Kayong Utara Kubu Raya Landak Bengkayang
NTT (East Nusa
Tenggara) 9
Manggarai Manggarai Timur Sumba Timur Rote Ndao Kupang Timor Tengah Utara Belu Lembata Flores Timur
Central Kalimantan
8
Kapuas Pulau Pisang Gunung Mas Barito Utara Murung Raya Katingan Seruyan Lamandau
North Sulawesi
3 Kep. Talaud Kep. Sangihe Minahasa Utara
West Java 7
Sukabumi Cianjur Bandung Barat Subang Sumedang Garut Kuningan
Gorontalo 4
Gorontalo Gorontalo Utara Baelemo Pohuwato
West Sulawesi
3 Polewali Mandar Majene Mamuju
East Java 5
Magetan Trenggalek Nganjuk Malang Pamekasan
Maluku 3
Maluku Tenggara Barat Maluku Tenggara Maluku Tengah
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Figure 3. Geographical Scope of CHNP Activities
3.2 Tier-2 ESMS for the Community Based Health and Nutrition
Project This document (the CHNP ESMS) is a Tier-2 ESMS developed specifically for the CHNP
and addresses the environmental and social management requirements of the CHNP.
The ESMS shall be aligned with the Social and Gender Integration Plan (SGIP) as well
as the Compact-wide Stakeholder Engagement Plan and Grievance Mechanism.
The CHNP ESMS identifies potential risks and impacts for the overall CHNP and
outlines requirements for mitigation. The ESMS makes reference to guidelines or tools
that will be applied to specific sub-activities, where potential impacts or risks are
anticipated.
The Compact describes the CHNP as Category D (through a financial intermediary).
This particularly applies to the Community Project Activity, whose funding is
channeled directly to the PSF. The two other activities have been categorized in the
MCA-Indonesia Tier-1 ESMS Framework as Category B or C13. Potential impacts/risks
will be discussed in this document.
13 Refer to page 9 of the Tier-1 ESMS Framework.
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3.2.1 Environmental and Social Legal Framework for CHNP
The Community Based Health and Nutrition Project is designed to support the
Government of Indonesia’s commitment to reduce the incidence of childhood stunting
and improve sanitation standards. This aligns with the National Mid-Term Development
Plan that includes programs to reduce stunting prevalence and to achieve open-
defecation free status and improved access to water supply. The GOI policies that
serve as the basis of the CHNP and that address potential impacts are as follows:
CHNP Activities
Relevant GOI regulations/ policies
Community Project Activity as Demand Side
Act No. 6, 2014 on Village
Act No. 2, 2012 on Land Acquisition for Development of Public Interest
Act No. 36, 2009 on Health
Act No. 14, 2008 on Public Information Disclosure
Act No. 32, 2004 on Regional Autonomy
Act No. 39, 1999 on Human Rights
Act No.39, 1999 on Human Rights
Presidential Regulation No. 42 year 2013 on National Movement for Nutrition Improvement
Presidential Decree No. 111/1999 regarding Development of Isolated Traditional Community (KAT)
Social Ministry Decree No. 06/PEGHUK/2002 regarding Implementation Guidelines of Isolated Traditional Community Empowerment
Supply Side Activity
Act No. 36, 2009 on Health
Act No. 32, 2009 on Environmental Protection & Management
Act No. 14, 2008 on Public Information Disclosure
Act No. 39, 1999 on Human Rights
Act No. 32, 2004 on Regional Autonomy
Act No. 8, 1999 on Consumer Protection
Presidential Regulation No. 42 year 2013 on National Movement for Nutrition Improvement
Regulation of the Minister of Health (Permenkes) No. 41, 2013 Revision of Permenkes 028, 2012 and Permenkes No. 2409 of 2011 on the Standar Bubuk Tabur Gizi Regulation of the Minister of Health (Permenkes) No. 88, 2014 on the Standard for Iron Supplement Tablets for Women in Reproductive Age and Pregnant Women
Government Regulation No. 28, 2004 on Food Safety, Quality and Nutrition.
Government Regulation No. 27, 2012 on Environmental Permit
Decree of Ministry of Health No. 852/Menkes/SK/IX/2008 on National Strategy on STBM (Sanitasi Total Berbasis Masyarakat) Government Regulation No. 69, 1996 on Food Labelling and Advertisement
Regulation of the Head of the Food and Drug Supervision Agency (BPOM) No. Hk 03.1.33.12.12.8195 Year 2012 on Technical Guidelines for on Good Manufacturing of Drugs
Regulation of the Head of the Food and Drug Supervision Agency (BPOM), No Hk. 03.1.34.11.12.7542 Year 2012 on Technical Guidelines for Good Distribution of Drugs
Communications, Management and Evaluation
Act No. 36, 2009 on Health
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CHNP Activities
Relevant GOI regulations/ policies
Act No. 14, 2008 on Public Information Disclosure
Besides Government regulations, the CHNP is expected to comply with policies and
guidelines adopted by the various programs it is attached to, as well as those adopted
by the MCC and MCA-Indonesia. This section provides a description of programmatic
policies and guidelines that are relevant for safeguards of the CHNP.
The Category D determination for the Community Project Activity leads to the use of
the intermediary organization’s policies and safeguard requirements. This is described
in the Project Appraisal Document (PAD) dated July 2011. The PAD describes how
Generasi Plus will take advantage of the implementation structures already in place
within PNPM Rural, including the policy, administrative and fiduciary infrastructure14.
This approach applies specifically to the Community Project Activity, which is
implemented through the Generasi Sehat dan Cerdas Program.
Thus, for the Community Project Activity, the following programmatic safeguard
guidelines shall apply:
The GSC Technical Guideline for Environmental and Social Safeguards Policy,
which attached in the Technical Operational Manual or Petunjuk Teknis
Operasional (PTO) 2016, which provides detailed instructions and template
forms for community engagement, gender integration, environmental and social
safeguards, and monitoring15.
The GSC standard procedures for stakeholder engagement and information
disclosure, grievance redress mechanisms.
The GSC safeguard guidelines are based on the World Bank’s policies on
Environmental Assessment and Indigenous Peoples, and demonstrate PNPM’s
extensive experience applying such policies across the country. The environmental
assessment portion of the guidelines might not be as relevant (as the social portion)
to the GSC, since this activity does not involve any construction of village
infrastructure. However, the social portion of the safeguard guidelines is very
applicable to GSC.
The safeguard guidelines include social code of practices that address indigenous
peoples, gender and vulnerable groups in various regions of Indonesia. The guidelines
shows an institutional ability to understand, anticipate and respond to the complexity
of social issues in the country, particularly as it pertains to vulnerable people, gender,
cultural heritage and indigenous people. This institutional infrastructure will enable the
Community Project Activity to comply with the requirements of the MCA-Indonesia
Tier 1 ESMS.
14Paragraph 43, Project Appraisal Document, Generasi Plus Project. “Reducing Stunting Rates among Children in Indonesia through Improved Nutrition, Health, ECD and Hygiene Interventions through the PNPM Generasi Program”. Bappenas – Ministry of Health – MCC – World Bank, July 2011. 15Petunjuk Teknis Operasional, Generasi Sehat dan Cerdas, Kementerian Desa, Pembangunan Daerah Tertinggal dan Transmigrasi, 2016.
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The Supply Side Activity and the Communications, Management and Evaluation
Activity will be implemented by MCA-Indonesia in partnership with the Ministry of
Health. Therefore, the programmatic policies and guidelines that apply will be those
issued and enforced by the Ministry of Health and its partners. These include Ministry
of Health regulations, technical guidelines, operational manuals related to: a)
production, packaging and distribution of drugs and supplements, b) sanitation and
hygiene activities associated with the STBM (Sanitasi Total Berbasis Masyarakat)
program, c) training of health service providers. The CHNP is adopting various
technical manuals (PTO’s or petunjuk teknis operasional) that will guide
implementation of the activities. A list of the operational guidelines available at the
time of preparation of this ESMS is provided in Appendix E.
3.2.2 Prohibited Activities
In line with the MCA-Indonesia Tier-1 ESMS, MCA-Indonesia shall not provide funds or
assistance for any project that is likely to cause signification environmental, health and
safety hazards. An illustrative list of prohibited activities is available in Appendix 3 of
the MCA-Indonesia Tier-1 ESMS Framework.
3.2.3 Screening Checklist
Individual sub-activities shall undergo screening to identify environmental and social
impacts that need to be addressed in the design and implementation. Activities under
Community Project will utilize the GSC safeguard guidelines and tools, including
screening checklist and project categorization. Activities under the other two projects
shall utilize the following checklist:
Yes No IFC-PS
Triggered
ESMS
Guidance
A. Environmental, Health and Safety – Will sub-projects:
1. Create a risk/potential of contamination related to provision
of food, beverage products or supplements?
2. Create a risk/potential of diseases such as diarrhea?
3. Result in the production of solid or liquid waste, or result in
an increase in waste production, during construction or
operation?
4. Create a risk/potential of safety issues?
5. Cause any physical or economic displacement of households
in the community?
If the answer to any of the questions 1-5 is “Yes”, please include an
Environmental and Social Action Plan (ESAP) and/or simple Environmental and
Social Code of Practices (ECOPs) with the sub-project application.
ESAP
and/or
ECOPs
B. Indigenous Peoples:
6. Are there social-cultural groups present in or use the project
area who may be considered as “indigenous
peoples”/”ethnic minorities”/tribal groups” in the project
area?
7. Members of the indigenous groups in the area who could
benefit from the project?
8. Do such groups self-identify as being part of a distinct social
and cultural group?
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9. Do such groups have a close attachment to ancestral
territories and to the natural resources in the project area?
10. Do such groups have customary cultural, economic, social,
or political institutions?
11. Has such groups been historically, socially and economically
marginalized, disempowered, excluded, and/or
discriminated?
If the answer to any of the questions 6 - 11 is “Yes”, please consult the ESMS
and, if needed, prepare an Indigenous Peoples Planning Framework (IPPF)
and/or Indigenous People Plan (IPP) with the activity/sub-project application.
IPPF/IPP
Screening has been conducted for the overall project design, and has resulted in
identification of potential risks and impacts that are addressed in this CHNP ESMS.
The screening tool shall be complemented by the use of Government of Indonesia’s
regulations and technical guidelines on environmental permit and environmental
assessments, to determine whether formal environmental and social assessments are
required. Sub-activities that may require an environmental assessment16 (and thus
environmental permit) are limited to some sub-projects funded by Activity 1’s block
grant (depending on type of activity and location), and possibly communal sanitation
facilities should Activity 2’s sanitation and hygiene lead to community’s decision to
build such a facility.
The screening process shall be done by the CHNP staff and/or project implementers,
with support from the MCA-Indonesia ESP staff. Decisions regarding the need to
prepare an action plans or assessments will be consulted with the MCA-Indonesia ESP
Director.
If a sub-activity or sub-project requires a formal environmental assessment, CHNP shall
ensure that such studies are conducted in accordance with the regulations, and
sufficiently address the issues covered in the IFC-Performance Standards. CHNP shall
also ensure that environmental permits are approved by the appropriate level of
Government, in accordance with pertinent regulations. Issues not covered by the
formal environmental assessments may be supplemented by studies done under the
GSC framework. Identification of gaps shall be done by the CHNP team with assistance
from MCA-Indonesia ESP team.
Any environmental or social risks or impacts identified in the previous screening
process will lead to determination of impact management and mitigation measures
and actions to ensure activities and sub-activities comply with pertinent regulations
and standards. These measures or actions shall be documented to allow
communication to parties involved and stakeholders, as well as to allow consistency in
monitoring. For sub-projects that have an environmental permit, the management/
mitigation measures will be described as part of the environmental management and
monitoring plans attached to the environmental permit. For sub-projects that are not
16 Given the expected size of the community projects, few or none are expected to require an AMDAL study. Some projects may require a UKL-UPL.
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governed by an environmental permit, the CHNP shall develop an environmental and
social action plan17 that defines the specific impact minimization and mitigation
measures, performance indicators, as well as the role and responsibility of relevant
parties associated with each impact or risk.
3.2.4 Identification of Environmental and Social Impacts and Risks
All components of the CHNP are designed to benefit communities in the target
locations. The project activities also follow community-based approaches designed for
both the GSC and the STBM programs, which are founded on principles of full
community participation, social inclusion and stakeholder engagement. Therefore, the
positive impacts of the CHNP to the communities are expected to be significant. The
health and nutritional impacts are expected to be long-term and support broader
educational, economic and social benefits for the communities.
Nonetheless, some of the activities, if not properly managed, have the potential of
causing adverse negative impacts. Potential impacts are identified in the following, and
discussed further in subsequent chapters.
Following the MCC Environmental Guidelines, the CHNP’s impacts are risks that are
likely to fall under Category B and C.18 Where potential adverse impacts are identified,
CHNP must ensure that mitigation measures are incorporated into the design and
implementation of the activities. The table below provides an overview of the potential
environmental and social risks and impacts anticipated for the CHNP.
17 Such an action plan may include an overall Environmental and Social Action Plan necessary for carrying out a suite of mitigation measures or thematic action plans such as resettlement action plan or indigenous people action plan. Action plans may be plans designed to fill in the gaps of existing management programs to ensure consistency with the Performance Standards, or they may be stand-alone plans that specify the project’s mitigation strategy (adapted from IFC Performance Standards on Environmental and Social Sustainability, page 10, footnote 22, 2012). 18 Category B is defined as: if the potential environmental and social impacts are less adverse than those of Category A projects. Typically, these impacts are site-specific, few if any are irreversible, and mitigation measures are more readily available. Category C is defined as: if the project is unlikely to have adverse environmental and social impacts.
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Table 2: Potential Environmental and Social Risks and Impacts associated with the CHNP
Project Activities Description Potential
Environmental & Social Risk and Impact
Mitigation Measures
Community Project Activity as Demand Side
Providing community facilitators that includes equal number of women and men.
Assign trained facilitators to work with communities. Recruitment process of facilitators need to promote gender balance.
Social impacts may be negative, if women and marginalized groups are not recruited as facilitators, who could assist women and vulnerable groups in participatory planning, by raising their concerns. Similarly, language difference may hamper participation of marginalized groups. No environmental risks or impacts expected.
Ensure social inclusion by recruiting women and representatives of marginalized groups. In conservative societies, women of the community may need to have separate meetings initially to raise their concerns. Similarly, facilitators from certain groups can help reduce language and cultural barriers.
Gender and socially inclusive Participatory planning
Conduct participatory planning process to identify development projects to be proposed for community block grant funding. Participatory planning should capture men’s, women’s and vulnerable group’s different concerns and priorities.
Social impacts are positive, as gender and socially inclusive participatory planning expected to result in village project proposals that suit needs and priorities of women, men and marginalized groups. Process must ensure social inclusion.
Ensure gender and social inclusion in participatory planning process, including vulnerable/marginalized groups, gender balance, and indigenous peoples. Adopt stakeholder engagement, grievance mechanism, and indigenous people framework (in relevant locations). Ensure men’s, women’s and other vulnerable group’s concerns and priorities, so that benefits for all, especially for marginalized groups are well captured in planning process, if necessary through separate forums for women and marginalized groups in all community planning activities.
Community block grants
Funding for community projects proposed through gender and socially inclusive participatory planning process.
To be determined for each village project. Projects should have positive social impacts; but may have localized environmental impacts.
Allocate financial resources to address socio-cultural constraints, including gender gaps identified during project assessment. Include activities so that women and vulnerable groups have equal access and able to avail benefits from the block grant provided. Adopt screening process to identify potential environmental risks and impacts of individual projects. And develop ESMP where necessary.
Supply Side Activity
Training for health service providers and facilitators
Implementation of training courses for health service providers and facilitators in 11 provinces. Courses expected to involve up to 6,000 participants.
Health, safety and security of training participants, related to travel to/from training locations as well as venues/facilities.
Adopt health, safety and security policy and procedures that apply to travel of training participants and selection of course venues/facilities. Ensure safe child care facilities for women facilitators with infants.
Provision of micronutrients
Provision of iron folate tablets to pregnant women, and Taburia
Unexpected health impacts of Taburia in areas where malaria,
Guidelines to address coordination with existing malaria, TB, parasite prevention
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supplement to infants in 3 provinces.
parasitic infections and tuberculosis are prevalent.19 Potential risk of micronutrient supplements being damaged during distribution and storage, related to Indonesia’s tropical climate; thus affecting mothers and infants. Potential risk of double dosage from other programs, such as: regular program from national/local government or other institutions Potential risk of pollution from improper disposal of post-consumer packaging.
programs when promoting Taburia in areas where malaria, parasitic infections and tuberculosis are prevalent. Adopt quality assurance and control throughout supply chain. DHO and Puskesmas ensure no duplication in terms of beneficiaries that receive micronutrients Adopt adequate waste management of post-consumer packaging, especially for Taburia sachets.
Sanitation and hygiene behavior
Implementation of CLTS activities in 11 provinces. Includes training, triggering, post triggering monitoring and incentives for health service providers. The CLTS process need to ensure that all social groups, including women, men and marginalized groups can equally participate in CLTS activities.
Social impacts are expected to be positive. However, approach to indigenous people (where present) must be more tailored. Environmental impacts overall expected to be positive. However, if communal sanitation facilities20 are to be constructed, they may require limited land acquisition/ donations. Furthermore, improved sanitation may require more changes in water access/use patterns. Triggering activities that rely on public shame may lead to marginalization of some community members.
Define culturally appropriate approach for indigenous people (where present). Ensure equal opportunity for women, men and marginalized groups in the management and implementation arrangements of CLTS activities. Take into account any adverse impacts or risks that may affect equal access to/participation in/equal benefit from project activities. Properly assess and plan land acquisition/donation for communal facilities. Properly assess water availability and access; and design appropriate sanitation facilities accordingly. Use gender and socially inclusive participatory process and develop and agree on a
19 World Health Organization, e-Library of Evidence for Nutrition Actions, Multiple Micronutrient Powders for Home
Fortification of Foods Consumed by Children 6-23 Months;
http://www.who.int/elena/titles/guidance_summaries/micronutrientpowder_infants/en/
20 There are no plans to construct communal sanitation facilities in the current design of the CHNP Project. However, if local conditions do not allow construction of household toilets, there is a possibility that CHNP may collaborate and enlist the support of other government programs to develop communal facilities. Should this be the case, this ESMS shall be referenced as well.
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social action plan for 100% ODF village Triggering should encourage social integration, and be sensitive to the use of shame in changing behavior.
Entrepreneur training and mentoring
Training and mentoring to selected entrepreneurs at project locations. Promote a socially inclusive process so that all social groups, including women, men and marginalized groups can equally participate in training.
Social impacts may be negative if gender and socially inclusive process is not undertaken for raising awareness and agreement on ODF.
Ensure equal opportunity for women, men and marginalized groups in training, so that communities can work together for ODF.
Private sector response activity
Competitive grant award for interventions in fortification or sanitation, safe water and hygiene
Risks and impacts unknown; depend on the types of activities proposed that includes participatory situational analysis for understanding demand and willingness to pay for such services and selected for grant award.
Properly assess potential risks and impacts at project appraisal and/or selection process.
Communications, Management, Monitoring and Evaluation
National Nutrition Communications Campaign
Communication campaign at the national (electronic media) and local levels.
Positive social and environmental impacts are expected. However, where vulnerable/ marginalized groups and indigenous peoples are present in target locations, communications strategy may need adjustment.
Ensure social inclusion of vulnerable/marginalized groups, gender balance in communications approach. Incorporate messages tailored to local cultural, religious, gender and situational needs. Involve local women and men, leader, elders from the beginning for wider acceptance, use and outreach of the communication campaign.
Monitoring Monitoring of project outputs and outcomes. Gender and socially disaggregated data should be collected. Gender targets and indicators should be developed. Promote community monitoring for local estimation of their progress, especially include women, men, educated youth, and
Without gender and socially disaggregated data, it will be difficult to measure progress by different social groups, and increase support for lagging groups.
Gender and socially disaggregated data should be collected. Promote community monitoring for local estimation of their progress, especially include women, men, educated youth, marginalized groups in monitoring process
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marginalized groups in monitoring process.
Evaluation Evaluation against project objectives. Ensure that all social groups, including women, men and marginalized groups can equally participate in evaluation. The evaluation report should include an assessment of gender equality results and impacts.
Evaluation may not indicate correct impacts if all social groups are not included
Ensure that all social groups, including women, men and marginalized groups can equally participate in evaluation.
More detailed guidance is provided in the subsequent chapters for each activity.
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4. Activity 1: Community Project Activity as Demand Side
4.1 Implementation of Activity 1 This activity is fully implemented by the GSC institutional infrastructure, and expected
to the use of the GSC policies and safeguard requirements and tools. This is described
in the Project Appraisal Document (PAD) dated July 2011, stating that Generasi Plus
(now change to Generasi Sehat dan Cerdas) will take advantage of the implementation
structures, including the policy, administrative and fiduciary infrastructure21.
Screening will use the environmental impact identification process and verification
process of the GSC, as well as other GSC safeguard guidelines and support tools to
ensure village projects do not cause adverse environmental and social impacts.
Reporting and monitoring shall also utilize the mechanisms already developed and
implemented under GSC. MCA-Indonesia shall obtain such reports, and ensure relevant
information in the reports are communicated to the CHNP team, including consultants
and contractors in the field.
4.2. Sharing of Information with Activities 2 and 3 Generasi Sehat dan Cerdas standard operating procedures address stakeholder
engagement, social inclusion, indigenous peoples, and land acquisition/donation. In
many cases, GSC has developed and communicated with village leaders and
communities, the standards, procedures and tools that are used to address the above
matters. Since the target communities in the CHNP Activities 2 and 3 are one and the
same as target communities under Activity 1, assessments and approaches developed
for Activity 1 are highly relevant for Activities 2 and 3. These include the following:
results of social mapping, which identify presence of vulnerable or marginalized
groups, and the poorest members of the community;
results of identifying possible presence of indigenous peoples or adat
communities, which may require specifically targeted consultations and
interventions;
results of gender assessments, which identifies specific gender-related issues
that must be followed up in the activity plans;
results of community health studies, which identify prevalent diseases in the
area (including malaria, HIV, tuberculosis, other parasitic infections) and
nutritional status among children and pregnant mothers;
standard instruments (letters, agreements, etc.) for land donations, involving
heirs of current land owners);
21Paragraph 43, Project Appraisal Document, Generasi Plus Project. “Reducing Stunting Rates among Children in Indonesia through Improved Nutrition, Health, ECD and Hygiene Interventions through the PNPM Generasi Program”. Bappenas – Ministry of Health – MCC – World Bank, July 2011.
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grievance redress mechanism or complaints handling system that allow
community members to voice their dissatisfaction about project activities.
Sharing of information and study results will allow micronutrient provision, sanitation
and hygiene as well as communications activities to adapt activities accordingly (to
suit the socio-cultural conditions of the target communities). Sharing of information is
most efficiently achieved at the district level, where CHNP district consultants, GSC
facilitators and Puskesmas interact. MCA-Indonesia shall promote such communication
and information sharing.
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5. Activity 2: Supply Side Activity
5.1 Implementation of Activity 2 The Supply Side Activity is implemented through partnership with the Ministry of
Health, as described in the Implementing Entity Agreement. A National Secretariat
Team has been established as part of the Project Implementation Unit, with a role to
manage the Project on a daily basis and to coordinate and provide reports to the
Technical Team. Most activities will be conducted using the institutional arrangements
of the Ministry of Health and provincial/district health agencies. The health agencies
at the provincial and district levels will be assisted by consultants, working under the
supervision of the National Secretariat Team.22
Training activities will be conducted by Ministry of Health, through its existing
programs.
Micronutrient supplements will be procured by MCA-Indonesia through competitive
bidding from private sector suppliers. Distribution responsibility will be shared
between the supplier and the health services network. This will be determined in the
TOR for the bid.
Sanitation and hygiene activities will be implemented using the existing STBM network,
involving facilitators and existing pool of health services providers and cadres in each
location. Entrepreneur training and mentoring will involve provision of molds for latrine
construction to participating district governments.
5.2 Training health service providers and facilitators This sub-activity is expected to involve the mobilization of approximately 6,000
individuals (health cadres, sanitarians, health officials, midwives, etc.) to attend
training courses held at the district or provincial level.
5.2.1 Environmental and Social Management
Mobilization of training participants in large numbers poses potential risk of accidents
or incidents that may result in health and safety concerns. Training courses are
expected to be held in remote locations, with limited facilities and some degree of
difficulty in access. Many individuals (training participants and instructors) will require
travel requiring multiple modes of transport, such as boat, motorcycle, bus/car or air
travel.
MCA-Indonesia shall ensure that individuals are covered under a health, safety and
security policy that ensures safe travel and logistics associated with the training
programs. In the absence of an MCA-Indonesia health, safety and security policy23 that
can be applied to these individuals, MCA-Indonesia must ensure that Ministry of Health
has included the training participants in relevant Government programs that provide
22 Source: RFP for Human Resources Management Firm to Recruit and Manage Provincial and District Health Consultants and Training Consultants in the Implementation of Supply Side Activities, MCA- Indonesia, 2015. 23 The MCA-Indonesia health, safety and security policy has not been finalized at the time of preparation of this ESMS document.
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health and safety coverage. The details of how MCA-Indonesia and its Partner Agency
will achieve this shall be described in an Environmental and Social Action Plan (see
Section 7). In addition, an operational guideline for logistics of the training program
shall be developed and communicated to all parties involved in the selection of training
venue/facilities and in the organization of the training courses.24
Delivery of training materials should be sensitive to gender and culture, and thus
ensure materials are delivered without offending any gender or group. Should there
be concerns related to delivery of training materials or demonstrations, such concerns
shall be conveyed to MCA-Indonesia to be addressed for subsequent training sessions.
In addition, there should be a mechanism to ensure equal opportunity for women, men
and other social groups to participate in awareness activity and training.
5.2.2 Stakeholder Engagement and Social Inclusion
The training activities are already designed to engage various health service
stakeholders, and thus not required to conduct further stakeholder engagement.
However, MCA-Indonesia shall ensure that training instructors provide sufficient
guidance to participants about ensuring equitable access to health information and
services to the different social groups present in target areas. MCA-Indonesia shall
ensure that the training instructors are informed of the MCA-Indonesia Stakeholder
Engagement Plan and the social and gender integration plan, as well as results of the
gender assessment entitled “Gender equality as a key dimension for improved
maternal and child nutrition to reduce stunting”. MCA-Indonesia shall also ensure that
training participants are aware of relevant information obtained through GSC studies25,
and that they consider the study results in providing health services to the community.
The details of how MCA-Indonesia and its Partner Agency will achieve this shall be
described in an Environmental and Social Action Plan (see Section 7).
5.2.3 Grievance Mechanism
The training activity shall utilize the MCA-Indonesia Grievance Mechanism to channel
complaints or inquiries related to the implementation of the training courses. Should
complaints regarding this activity be received via the Ministry of Health’s complaint or
whistle-blowing system, such complaints shall be cross-registered in the MCA-
Indonesia Grievance Mechanism. The Environmental and Social Action Plan can
provide more detail on how the grievance mechanism will engage Ministry of Health
and/or the GSC grievance mechanism.
5.2.4 Environmental and Social Reporting
The training activity is not expected to prepare separate environmental and social
reports. However, the National Secretariat Team is encouraged to report any accidents
or incidents related to travel of participants to and from training venues. Such reports
shall be included in the routine quarterly and annual reports submitted to MCA-
Indonesia.
24 The guideline shall address the minimum requirement of training venues and accommodations, and accessibility of location; as well as describe start and finish time of training sessions, and other issues that may affect the health of safety of all personnel expected to be present at the training course. 25 As described in Section 4.2.
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5.3 Micronutrient Provision Multiple Micronutrient (MMN) is a strategy adopted by MCA-Indonesia to combat
stunting among children and anemia in pregnant woman in Indonesia. CHNP plans to
distribute and promote micronutrient sprinkles (known by the local trade name
“Taburia”) to be given to infants aged 6-24 months, and iron folic acid (IFA) tablets to
pregnant women. Provision of both nutritional supplements will be implemented
through the Ministry of Health.
Taburia Program
CHNP plans to fund the procurement and distribution of nutritional supplement in
the form of sprinkles, known as Taburia. The composition of the supplement follows
the Minister of Health Regulation No. 41, 2013 Revision of Permenkes 028, 2012 and
Permenkes No. 2409 of 2011 on the Standar Bubuk Tabur Gizi. Taburia will be
distributed to selected districts in three provinces, namely South Sumatra, West
and Central Kalimantan. Distribution will be channeled through the District
government’s pharmaceutical warehouse to reach the Puskesmas and Posyandu in
target locations. Mothers are expected to provide Taburia to their infants aged 6-
24 months every two days; requiring distribution of 15 sachets per child per month.
The Taburia program will initially be piloted in selected provinces; and depending
on the results of the pilot, distribution may be extended within the three selected
provinces.
It is noted here that Taburia is a relatively new program for the Government of
Indonesia. Although it has been piloted in a number of districts with a number of
international partners, Taburia distribution has not been adopted as a national
program. Lessons learned from the previous pilots are being considered in the
development of the program and in preparing this ESMS.
Iron Folic Acid Program
CHNP plans to fund the procurement and distribution of nutritional supplement in
the form of iron folic acid (IFA) tablets. The provision of IFA supplementation is
recommended as part of the antenatal care package to reduce the risk of low birth
weight, maternal anemia and iron deficiency. Composition of the IFA tablets will
follow the Minister of Health’s Regulation Permenkes No. 88 by 2014. A total of 90
IFA tablets will be provided to every pregnant woman in project areas. CHNP plans
to procure sufficient tablets for distribution over a two year period, in 11 provinces,
namely West and East Java, West and East Nusa Tenggara, Gorontalo, Maluku,
North and West Sulawesi, West and Central Kalimantan, and South Sumatra. MCA-
Indonesia plans to engage a supplier/manufacturer/distributor that will be
responsible for producing, packaging, distributing and conducting product
traceability and monitoring in project areas.
Distribution of IFA supplementation has been quite widespread in Indonesia.
Experience with production, distribution and consumption of IFA tablets is well
established. However, it is noted that UNICEF has recently updated its Technical
Bulletin on packaging for iron/iron folic acid tablets, aimed at preventing accidental
ESMS for CHNP
28
consumption by children and ensuring better product quality.26 This ESMS
considers past lessons learned gained through discussions in MCA-Indonesia.
5.3.1 Environmental and Social Management
This ESMS focuses on ensuring that Taburia and IFA tablets are safe at the time of
human consumption, which requires adequate control of food safety hazards
throughout the supply chain27. The ESMS also ensures that post-consumption, Taburia
packaging waste does not cause adverse impacts to the environment (soil, waterways)
in and around the areas where Taburia is distributed28.
MCA-Indonesia shall thus develop, adopt and communicate a set of guidelines for
quality assurance and control of the micronutrient supplements. The guidelines shall
be based on good drugs/supplements manufacturing and distribution procedures, as
well as reflect the existing capacity and infrastructure for distribution and storage of
food and drugs.29
The guidelines shall address the following issues: a) shelf-life of the products, b)
packaging, c) distribution and storage criteria, considering Indonesia’s climatic
conditions, d) traceability of poor quality products, e) disposal of post-consumer
packaging, f) reporting of adverse reactions related to the product. The guidelines
shall ensure that duplication of dosage is prevented, recognizing that other programs
in the area may distribute the same or similar supplements; and that supplements are
given with caution in areas with known malaria and other diseases. The guidelines shall
also refer to existing technical guidelines also in use in the health sector, such as the
Cara Pembuatan Obat yang Baik (CPOB) and Cara Distribusi Obat yang Baik (CDOB)30,
international specifications or guidelines31 or other tools commonly used in the food
and drug industry in Indonesia.
Such guidelines shall be communicated through tender documents for and contracts
with third-party suppliers and consultants. The guidelines will apply also to any sub-
contractors that support third-party suppliers/contractors in fulfilling their legal
obligation to MCA-Indonesia.
The guidelines shall also be developed with the Ministry of Health32, and all efforts will
be made to ensure that all parties within the health network are committed to
maintaining the quality of the micronutrient supplements along the supply chain, and
to manage packaging waste appropriately. Therefore, guidelines shall reach health
officials at the District and Sub-District levels, and health service providers at the
26 UNICEF Technical Bulletin No. 20 (March 2015) on “Change of Pack Size for Iron Tablets and Iron and Folic Acid Tablets. This document promotes safety measures in packaging, such as use of blisters or child-proof lock on bottle packs, and smaller number of tablets in each package. 27 This invokes IFC-PS 4 on Community Health, Safety and Security. 28 This invokes IFC-PS 3 on Resource Efficiency and Pollution Prevention. 29 At the time of preparation of this ESMS document, the guidelines are still under preparation. Discussions and visits related to preparation of the guidelines have received significant contributions from the ESP units of MCC and MCA-Indonesia, reflecting on the contents of the previous draft of the CHNP ESMS 30 Both issued by the Indonesian food and drug agency, BPOM. 31 Such as the UNICEF Technical Bulletin No. 20, March 2015. 32 The MOH Implementing Entity Agreement states that MCA-Indonesia will “develop project operations manual, based upon the Operational Technical Guidelines”, developed by the Partner Agency.
ESMS for CHNP
29
Puskesmas and Posyandu level, especially those directly interacting with pregnant
women, infants’ mothers and other caregivers.
Each party involved in the above process shall have clear responsibilities and user-
friendly instruments to fulfill the tasks, such as check-lists, chain-of-custody forms,
informational posters, etc. Responsibility of private sector producers and service
providers (transport, packaging, and disposal) shall be included in bidding documents
and contracts. Contracts shall also define the oversight responsibility of third-party
contractors when/if they involve sub-contractors to fulfill their MCA-Indonesia
obligations.
In addition, MCA-Indonesia shall also ensure that Taburia is not consumed by children
who may have malaria, tuberculosis, HIV and parasitic infection -- following the
guidelines of the World Health Organization.33 In areas where the above diseases are
prevalent, Taburia promotion and distribution should be done with caution, focusing
on areas where prevention/ treatment programs exist and are effective. MCA-
Indonesia shall ensure that project guidelines provide clear approach for Taburia
distribution in areas that are known to have malaria, tuberculosis, HIV and parasitic
infections.
5.3.2 Social Inclusion and Stakeholder Engagement
The CHNP shall refer to and utilize reports/results of GSC social assessments to ensure
all social groups are adequately involved in consultations and decision-making, and
equitably benefit from the provision of micronutrients. The project shall also consult
the list of adat communities under the AMAN (Aliansi Masyarakat Adat Nusantara)
network. District consultants contracted to assist in implementing the CHNP shall have
sufficient understanding of the socio-cultural dimension of the areas they work in, and
implement their activities with appropriate socio-cultural sensitivity. Details on how
the Project will achieve this shall be described in the Environmental and Social Action
Plan for the CHNP.
5.3.3 Grievance Mechanism
The micronutrient provision program shall utilize two grievance redress mechanisms.
At the level of implementation (districts, Puskesmas and Posyandu), the GSC
grievance mechanism shall apply, since community members and health service
providers are most familiar with this system. However, for production and distribution
(up until the district level), the MCA-Indonesia grievance mechanism will likely be
utilized. MCA-Indonesia must ensure that complaints or grievances from both systems
are handled appropriately and feed into decisions of the program. The Environmental
and Social Action Plan can provide more detail on how the grievance mechanism will
engage Ministry of Health and/or the GSC grievance mechanism.
33 World Health Organization, e-Library of Evidence for Nutrition Actions, Multiple Micronutrient Powders for Home Fortification of Foods Consumed by Children 6-23 Months; http://www.who.int/elena/titles/guidance_summaries/micronutrientpowder_infants/en/
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30
5.3.4 Environmental and Social Reporting
The CHNP Director is expected to immediately report to the ESP Director any incident
or complaint related to micronutrient provision, to allow the ESP Director to guide and
monitor any mitigation measures that are put into effect.
In addition, CHNP shall include in its annual report on environmental and social
performance the level of compliance of the micronutrient provision sub-activity with
respect to the requirements laid out in this ESMS and the quality assurance/control
guidelines. The report shall include, but not be limited to, the following:
Incidents of complaints/grievances related to micronutrient provision, and how
they were resolved;
Incidents of batches of Taburia or IFA reported/found to be of poor quality
(sub-standard), including information on batch, location where it was
distributed, source of report, and how situation was handled by the CHNP
infrastructure and/or local health authorities;
Incidents of toxicity or adverse reactions related to Taburia or IFA
administration;
Issues/problems encountered in relation to disposal or destruction of unusable
batches (due to poor quality or expiration) and post-consumer packaging of
Taburia;
Good practices and lessons learned on project outcomes/ outputs or activities
that promote social inclusion and gender equality
Lessons learned from the above.
5.4 Sanitation and Hygiene Sanitation and hygiene activities will be conducted in 11 provinces, covering 64
districts, 1600 villages and 704 Puskesmas. The activities consist of three components,
namely enabling environment, demand creation, and sanitation and hygiene supply.
The first component, enabling environment, is largely an awareness and capacity
building activity, and thus not expected to cause significant adverse environmental or
social impact. The demand creation will involve a series of cascading training events
that precede a village triggering process, and subsequent post-triggering follow-up.
The third component, sanitation and hygiene supply, involves improving the
availability of sanitation products and development of sanitation entrepreneurs. The
latter two components will be discussed further in this ESMS document.
5.4.1 Environmental and Social Management
This sub-activity is not expected to require any formal environmental assessment or
environmental permit. However, if a triggered community decides to construct
communal sanitation facilities, there is a need to conduct screening to determine any
potential adverse impacts. Possible impacts may relate to location of the communal
facility (risk of erosion, flooding, etc.), need to secure land owned by private
individuals, availability of water to support the facility, as well as potential river and
groundwater contamination if septic tanks are not in full operation.
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31
Furthermore, the selection of sanitation technology can minimize environmental and
social impacts, and shall be considered in this sub-activity. Considerations are as
follows:
Plans to use appropriate technology should consider site-specific conditions,
such as:
o Availability of water to support flushing of toilets and clean water for
hand-washing. In some areas in West and East Nusa Tenggara, water may
be very scarce in many months of the year or even throughout the year.
o Design of toilets/latrines in areas where the water table is high. In parts
of West and Central Kalimantan, toilets will have to be designed
appropriately as to not cause more (rather than less) water-borne
diseases related to fecal matter.
o Design of toilets/latrines in areas that are covered by water, such as in
communities living on rivers, tidal flats and/or ocean. In such areas,
latrines must be designed so as to not increase water pollution, yet
ensure safe and comfortable use by individuals.
o Design of toilets/latrines should consider the needs and concerns of
women and people with disabilities.
Should project activities lead to construction of community sanitation facilities,
the project should ensure that land used for the facility does not cause physical
or economic displacement of any person or families. Land donated or purchased
should be documented properly (following the GSC guidelines), and
agreements reached so as not to adversely affect individuals of families in the
area.34
Should activities be conducted in areas where indigenous people are present,
appropriate sanitation technology and/or other culturally-sensitive approaches
shall be selected?
Should project activities lead to the provision of awareness and capacity
building activities, the project should ensure all social groups are adequately
involved in consultations and decision-making, and equitably benefit from the
provision of project activities.
5.4.2 Stakeholder Engagement and Social Inclusion
The demand creation activities shall refer to reports/results of GSC social assessments
to ensure all social groups are adequately involved in consultations and triggering, and
equitably benefit from the sanitation and hygiene activities. The activity shall also
consult the list of adat communities under the AMAN (Aliansi Masyarakat Adat
Nusantara) network. Presence of indigenous communities or adat groups is
particularly likely in Central Kalimantan, West Kalimantan, Central Sulawesi, West Nusa
Tenggara and East Nusa Tenggara.
Facilitators in the field shall have sufficient understanding of the socio-cultural
dimension of the areas they work in, and implement their activities with appropriate
socio-cultural sensitivity. MCA-Indonesia shall ensure that district consultants are well
34 This will prevent application of IFC-PS5 on Land Acquisition and Involuntary Resettlement. Please refer also to Section 8.4 for more discussion on land acquisition and donation.
ESMS for CHNP
32
informed and advised. Details on the project’s approach can be described in the
Environmental and Social Action Plan.
5.4.3 Grievance Mechanism
The sanitation and hygiene sub-activity shall utilize two grievance redress
mechanisms. At the level of implementation (districts, Puskesmas and Posyandu), the
GSC grievance mechanism shall apply, since community members and health service
providers are most familiar with this system. In addition, the MCA-Indonesia grievance
mechanism shall also be available to accommodate grievances and complaints. MCA-
Indonesia shall ensure that complaints or grievances from both systems are handled
appropriately and feed into decisions of the program. The Environmental and Social
Action Plan can provide more detail on how the grievance mechanism will engage
Ministry of Health and/or the GSC grievance mechanism.
5.4.4 Environmental and Social Reporting
CHNP shall include in its annual report on environmental and social performance the
level of compliance of the sanitation and hygiene sub-activity with respect to the
requirements laid out in this ESMS. The CHNP’s approach to monitoring and reporting
shall be elaborated in the ESAP.
The report shall include, but not be limited to, the following:
Sanitation technology selection in areas of scarce water and high water table;
Sanitation technology and triggering approach used for indigenous
communities or adat groups, and in what areas they were applied;
Communal sanitation facilities built (if any), and the environmental/social
assessments conducted and permits obtained, incidents of land
acquisition/donation and handling of approval documentation, sanitation
technology used (including sludge handling);
Any grievances or complaints received in relation to the sanitation and hygiene
sub-activity, including how these complaints were handled by MCA-Indonesia;
Good practices and Lessons learned on project outcomes/ outputs or activities
that promote social inclusion and gender equality.
Lessons learned from the above.
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33
6. Activity 3: Communications, Management and
Evaluation
This ESMS will only discuss the Communications component of Activity 3. The overall
objectives of the national nutrition communication campaign are:
1. Increase awareness and understanding of the causes, symptoms, long–term
implications, and prevention of stunting among parents, community members,
health personnel, government officials, and the general public;
2. Gain commitment from a broad array of stakeholders in the public and private
sectors to tackle the problem of stunting;
3. Foster individual and community behavior change related to health and nutrition
among parents, other caregivers, and MOH personnel who deliver community
health/nutrition services. 35
The main target audience is women of reproductive age, mothers, fathers and other
family members who are involved in child care. On the ground communication
activities will be conducted in three provinces, namely West and Central Kalimantan
and South Sumatra. The use of television will have national reach.
The national communication strategy states that interventions will include an
integrated mix of: a) interpersonal communications through group meetings and one-
on-one interactions; b) use of mass media, mainly television, for national scope; c)
web-based platforms (i.e., Facebook, Twitter, and an NNCC website) and short-
message service (SMS).
6.1 Environmental and Social Management The sub-activity does not require any formal environmental assessments. Adverse
impact on the environment is expected to be minimal, especially as a result of the
heavy reliance on electronic media. Social impacts are expected to be positive and
have long-term benefits for the health and social welfare of the target communities.
To ensure social inclusion, the project activity should confirm all social groups are
adequately involved in consultations and decision-making, and equitably benefit from
the communications approach.
6.2 Stakeholder Engagement and Social Inclusion The national communications campaign shall refer to reports/results of GSC social
assessments to ensure the campaign reaches and benefits all social groups in the
target locations. The campaign shall also consult the list of adat communities under
the AMAN (Aliansi Masyarakat Adat Nusantara) network. Where indigenous
communities or adat groups are present (likely in Central Kalimantan, West
Kalimantan, Central Sulawesi, West Nusa Tenggara and East Nusa Tenggara), the
campaign shall develop culturally appropriate communication messages and delivery
mechanisms.
35 MCA- Indonesia, “National Nutrition Communication Campaign Strategy Design, Draft 1, March 2015
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34
Consultants, facilitators or other parties involved in the communications campaign at
the field level shall ensure that content of messages and conveyance thereof are
appropriate for the socio-cultural setting in the target areas. MCA-Indonesia is
responsible for ensuring these individuals are well informed and advised. Details on
how to achieve this shall be described in the Environmental and Social Action Plan.
6.3 Grievance Mechanism The communications campaign sub-activity shall utilize two grievance redress
mechanisms. At the level of implementation (districts, Puskesmas and Posyandu), the
GSC mechanism shall apply, since community members and health service providers
are most familiar with this system. In addition, the MCA-Indonesia grievance
mechanism shall also be available to accommodate grievances and complaints. MCA-
Indonesia shall ensure that complaints or grievances from both systems are handled
appropriately and feed into decisions of the program. The Environmental and Social
Action Plan can provide more detail on how the grievance mechanism will engage
Ministry of Health and/or the GSC grievance mechanism.
6.4 Environmental and Social Reporting CHNP shall include in its annual report on environmental and social performance the
level of compliance of communications campaign sub-activity with respect to the
requirements laid out in this ESMS. The CHNP’s approach to monitoring and reporting
shall be elaborated in the ESAP.
The report shall include, but not be limited to, the following:
Specialized communications approach to indigenous communities or adat
groups in specific areas, including a description of their response/reaction to
the communications effort;
Good practices and lessons learned on project outcomes/ outputs or activities
that promote social inclusion and gender equality.
Any grievances or complaints received in relation to the communications
campaign, including how these complaints were handled by MCA-Indonesia.
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35
7. CHNP-Wide Environmental and Social Action Plan
CNHP of MCA-Indonesia is responsible for preparing a CHNP-wide Environmental and
Social Action Plan (CHNP ESAP). The ESAP will present the specific mitigation or
management actions that will be taken to comply with the requirements of this CHNP
ESMS. Since earlier drafts of the ESMS have influenced the design of the CHNP
activities, the ESAP shall focus on the implementation phase. This section provides
some guidance on preparation of the ESAP.
At a minimum, the ESAP shall contain the following:
Description of impact mitigation/management actions, including specific
interventions, locations (if not all areas), and timeframe. If CHNP has
developed/issued technical or operational guidelines to address the potential
impacts, these guidelines shall be referred to in the text and attached to the
ESAP;
Parties responsible for each mitigation actions, identifying the particular office
or unit within the CHNP implementation structure;
Description of monitoring efforts to ensure that impact mitigation/management
is effective and to ensure that no unanticipated impacts arise. This should also
describe which parties are responsible for monitoring, and what documentation
and reporting is required, as well as frequency of monitoring and reporting. If
monitoring and reporting utilizes the GSC and/or STBM systems, this should be
stated in the ESAP. Monitoring and reporting outside of the GSC and/or STBM
systems shall also be described.
Specific roles and responsibilities of MCA-Indonesia, consultants, contractors,
and the National Secretariat Team at the Ministry of Health, as well as others
involved to ensure compliance with this ESMS.
Budget line items to be included in annual work plans and budget of the CHNP.
Specific timelines for tasks identified above.
CNHP shall develop the Environmental and Social Action Plan, in consultation with the
ESP team. The format of the ESAP shall be agreed upon between the two teams.
Should it be deemed necessary (to be agreed upon by the ESP Director and CHNP
Director), the ESAP may be supplemented by an annual Environmental Social
Management Plan (ESMP), which will serve as the basis for supervision by the ESP
Director. The ESMPs shall describe in detail the expected management and monitoring
activities, timeframe (schedule), roles and responsibilities, and reporting content and
channels.
To guide the preparation of the ESAP for CHNP, the following table provides a
summary of the risks and impacts that need to be addressed in the ESAP. The relative
magnitude of the risk/impact is indicated in the table, and can be used to identify
appropriate actions and measures.
ESMS for CHNP
36
Table 3. Summary of Anticipated Risks and Impacts of the CHNP
Project
Activities
Potential Risks And
Adverse Impacts
Level Of
Risk/Impact*
Critical Items For ESAP
Preparation
Community Project Activity as Demand Side
Participatory
planning
Social jealousy from
community members not
fully engaged in participatory
planning
Low Ensure equal opportunity for
participation across all
groups, especially the poor,
female headed households
and marginalized groups.
Community
block grants
Localized environmental
impacts from projects
selected by communities
Low to Moderate Community projects with
moderate environmental
impacts may require permits
and/or environmental
management plans.
Allocate financial resources
to address socio-cultural
constraints, including gender
gaps identified during
project assessment.
Supply Side Activity
Training for
health service
providers and
facilitators
Health, safety and security
associated with training
program, especially related
to travel to/from training
locations and venue/facilities
where training is held.
Limited participation of
women and other
marginalized groups to
training activity.
High Guidelines for logistical
arrangement of training
program shall include health
safety and security of
training participants at the
training location,
accommodations and travel
to and from the location.
Ensure safe daycare facilities
for trainees with infants
Delivery of some materials
offend particular gender or
cultural sensitivities.
Low to moderate Ensure delivery of materials
are gender- and culturally-
sensitive.
Provision of
micronutrients
Adverse effects of Taburia
consumed by children with
malaria, HIV, tuberculosis and
parasitic diseases.
Moderate Guidelines must ensure
Taburia distribution in areas
with prevalent malaria, HIV,
tuberculosis and parasitic
diseases is done following
WHO recommendations.
Damaged micronutrient
supplements during
distribution and storage; thus
affecting mothers and
infants.
High Guidelines for quality control
and assurance of
micronutrient supplements
must be strictly followed.
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37
Accidental ingestion of iron
tablets by children
Low to moderate Selection of packaging to
prevent easy access to
children, following UNICEF
technical bulletin (2015)
Double dosage of
supplements given to
beneficiaries.
Low to moderate Ensure local health agencies
are aware of other programs
distributing supplements to
the communities.
Pollution from improper
disposal of post-consumer
packaging
Moderate Guidelines for disposal of
post-consumer packaging
must be strictly followed.
Sanitation and
hygiene
behavior
Sanitation technology used
not suitable for ecological
and social context
Low to moderate Ensure sanitation technology
is suitable for different
ecological features (water
tables and water availability)
and cultural characteristics
Economic or physical
displacement if communal
sanitation facilities (if
applicable) require land
acquisition/ donations
Low GSC guidelines for land
acquisition/donation must
be strictly followed.
Change in water access or
water use patterns with
improved sanitation
Low to moderate
(depending on
location/
community)
Level of risk depends on
existing patterns of water
use and availability and
accessibility of water to the
communities.
Triggering activities that rely on public shame lead to marginalization of some community members.
Low to moderate Guidelines should aim at
social integration and
prevent marginalization of
certain community
members.
Entrepreneur
training and
mentoring
Limited participation of
women and other
marginalized groups to
training activity.
low Ensure equal opportunity for
women, men and
marginalized groups to
participate in training.
Private sector
response
Risks and impacts unknown;
depend on the types of
activities proposed and
selected for grant award
Low to moderate Screening must be done for
proposed or selected
activities.
Communications, Management, Monitoring and Evaluation
National
Nutrition
Communications
Campaign
Vulnerable/ marginalized
groups and indigenous
peoples excluded from
campaign activities, in
locations where they are
present.
Low Social mapping and social
inclusion approaches of GSC
to be utilized.
*Risk level indicated assumes that the basic community-based approaches of GSC and STBM are
already implemented.
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38
The following sub-sections provides further guidance on other elements to be
addressed in the ESAP.
7.1 Social and Gender Integration Plan In defining project beneficiaries and affected communities, CHNP shall consult and
apply the Social and Gender Integration Plan (SGIP) and any gender assessment
conducted for CHNP. This includes consideration of differentiated needs, concerns and
societal and gender norms related to maternal health and child nutrition. Among
others, enhancing the role and responsibility of men in improving maternal and child
health and nutrition shall be considered. 36 The project should collect gender
disaggregated data to track gender equality result and assess gender impacts.
Additionally, the project should also incorporate mechanism of gender balance to
ensure gender balanced representation and participation in project activities and
decision making. In monitoring and evaluation, the project should develop gender
specific targets or performance indicators that track gender equal result and impact
and make sure women, men and vulnerable/marginalized groups are able to
participate in monitoring and evaluation process.
7.2 Grievance Mechanism MCA-Indonesia has developed a formal mechanism for efficiently and effectively
recording and resolving complaints or disputes related to the community-based health
and nutrition project design, implementation and impacts. Such a grievance
mechanism fulfills the ESMS requirement on Developing and Instituting Grievance
Mechanisms (E5). The mechanism can be found online in the MCA Indonesia webpage.
See http://mca-indonesia.go.id/en/mekanisme-pengaduan/.
The MCA-Indonesia grievance mechanism will allow recording of complaints or
grievances related to CHNP, including those submitted to the GSC grievance
mechanism, and even if such grievances are already handled and resolved by the GSC
system. Should follow-up be required by MCA-Indonesia, the grievance mechanism
shall record actions taken and responses provided to the involved parties.
The MCA-Indonesia grievance mechanism shall be widely communicated to the
communities in the districts targeted for CHNP, and shall allow use of the most
prevalent/ accessible communication methods or technologies in these areas. For
example, the grievance mechanism is expected to receive text messages from mobile
phones, or for areas where mobile phone use is low, and post office service is not
available, MCA-Indonesia is expected to ensure the creation of village-level hubs for
information relay to MCA-Indonesia or relevant CHNP staff/consultants at the district
level. Care shall be taken to ensure that the methods or technologies used are sensitive
to the needs and customs of women and marginalized groups, including indigenous or
adat communities.
MCA-Indonesia is expected to assign a person(s) to manage the grievance process,
including:
36 MCA- Indonesia, “Gender Equality as a Key Dimension for Improved Maternal and Child Nutrition to Reduce Stunting”, July 2011.
ESMS for CHNP
39
Relaying grievances to the appropriate organization or unit in MCA-Indonesia;
Where the content of the grievance is unclear, seek more information;
Assigning a timeframe for responding to the grievance, and reminding the
responsible unit when the deadline is near;
Following-up on grievance response, especially for issues that cannot be
resolved immediately (e.g. requiring changes in project activity or coordination
with other stakeholders);
Responding to the source of the grievance. This response is best done in writing
or, at least, recorded in writing. Where necessary and/or appropriate, the
response shall be officially raised with or witnessed by the community or village
leader;
Managing documentation of grievances and grievance responses, as required
by the MCA Indonesia document management system.
Prior to Compact closure, grievance management will be handed over to
appropriate institutions, based on an assessment of capacity and sustainability.
Such hand-over shall be planned from Year 4 of Compact implementation.
7.3 Occupational Health and Safety The CHNP activities may pose health and safety risks to those involved in
implementation. The risks may derive from travel activities, remoteness of activity
locations, and occupational hazards related to construction of village facilities.
To ensure safe and healthy working conditions, all CHNP activities will be required to
follow health and safety guidelines acceptable to MCA-Indonesia, or referring to the
MCA-Indonesia Health and Safety Guidelines. For activities that fall under the GSC
framework, the health and safety guidelines and procedures of GSC shall be applied.
For activities implemented through the Ministry of Health, the MCA-Indonesia Health
and Safety Guidelines shall apply; or relevant Government of Indonesia programs that
provide health and safety coverage. At the very least, training participants should
obtain proper briefing on transportation safety, advised on how to prevent accidents
and respond to emergency situations.
7.4 Land Acquisition and Resettlement CHNP is unlikely to require involuntary resettlement and land acquisition, since none
of its activities require construction of facilities at a significant scale. The only possible
sub-activity where some economic or physical displacement may be encountered is
the sanitation and hygiene (under Supply Side Activity), if a community
decides/wishes to construct communal sanitation facilities. In such cases, there may
be a need to utilize private land for siting of the communal facility.
If land is donated by a family (private owner), the MCA-Indonesia shall ensure that
proper documentation is prepared and signed, following the PTO of GSC for land
donation. A sample of the land donation letter is provided in Appendix D. MCA-
Indonesia shall also ensure that no other community members are adversely impacted
by the use of the land. This is considered sufficient to cover the IFC-PS 5, especially
since decisions on land transfer/use are made collectively, involving the land owner as
ESMS for CHNP
40
member of the community. No further land acquisition and resettlement plans need to
be prepared.
7.5 Indigenous People The CHNP may support activities across several provinces and districts where
indigenous or adat communities may be present. This includes Central and West
Kalimantan, West Sulawesi, West Nusa Tenggara and East Nusa Tenggara. As the
presence of indigenous people triggers the application of IFC-PS 7; some general
principles and procedures are presented in Appendix C (Indigenous Peoples Plan
Framework).
In principle, MCA-Indonesia shall ensure that indigenous communities are identified,
consulted with, have equal opportunity to benefit from, and are not adversely
impacted by the project. Since all of CHNP locations are also GSC locations, Activities
2 and 3 of CHNP shall build upon the knowledge, information and practices of GSC in
relation to indigenous peoples. Upon commencing activities, GSC’s village facilitators
conduct social mapping/ assessments and identification of indigenous peoples,
marginalized and vulnerable groups. Similar information is usually possessed by health
officer/service providers in Puskesmas. MCA-Indonesia shall ensure that Puskesmas
staff and GSC village facilitators agree on the composition of the local communities
they service, and work from a common list and/or understanding.
CHNP is not expected to prepare a separate indigenous people plan for each locality.
However, it is expected to report activities and locations where indigenous people
have participated in consultations, received micronutrient supplements, took part
triggering and sanitation/hygiene activities. These reports would be incorporated in
the routine project implementation reports submitted by the Puskesmas to CHNP
district consultants and back to MCA-Indonesia.
ESMS for CHNP
41
8. Institutionalization of the CHNP ESMS
8.1 Implementation and Management of CHNP MCA-Indonesia, led by the Executive Director, has two main divisions, i.e. the
Operations Support Division and the Programs Division. Each division is led by a
Deputy Executive Director. The CHNP Director reports to the Deputy Executive
Director for Programs.
CHNP receives operational support from the Operations Support Division (including
Legal, Finance, Procurement, Human Resources, Communications), as well as technical
support and oversight from cross-cutting units under the Program Divisions (i.e.
Environmental and Social Performance, Social and Gender Assessment, and
Monitoring and Evaluation units).
The implementation of CHNP is organized through different institutions, namely the
PNPM Support Facility, the Ministry of Health network, and MCA-Indonesia and its
contractors. The diagram below shows the implementation structure developed for
the CHNP37:
37 Described in the Millennium Challenge Account Indonesia Stakeholder Engagement Plan. This diagram has been updated in accordance with changes in management of Generasi Sehat dan Cerdas Program.
ESMS for CHNP
42
Figure 4. Institutional Set-up of CHNP
As described in the Implementing Entity Agreement (IEA) between MCA-Indonesia
and the Ministry of Health, the Ministry of Health serves as the Partner Agency to
implement CHNP. The Ministry of Health is responsible for establishing and managing
the Project Implementation Unit that consists of a Steering Committee, a Technical
Team and a National Secretariat Team. The latter plays a vital role in the day-to-day
operations of CHNP. The National Secretariat Team will comprise of a team of
consultants assigned to the province and district levels. Implementation of the Supply
Side Activity will involve the district level health agency (Dinas Kesehatan) and the
Puskesmas, Posyandu, as well as health service providers and cadres. Implementation
of the communications campaign will involve a third-party contractor
(communications firm), which will recruit district level coordinators. The coordinators
will support communication cadres identified by the third-party contractor and MCA-
Indonesia.
GSC – National Task Force
Secretariat
GSC OVERSIGHT TEAM (Pokja Pengendali)
GSC – National Coordinator Team
District Coordination Team
Project Manager
(PJOK)
Provincial Coordination Team
Ministry of Villages, Disadvantaged
Region, and Transmigration
ESMS for CHNP
43
At the field level, Puskesmas will serve as the anchor for all three activities of CHNP. It
will be involved in the community-projects, training activities, micronutrient provision,
and (to a lesser extent) the sanitation/hygiene activities. The knowledge and expertise
of the Puskesmas staff, health cadres, sanitarians, and midwives are expected to
ensure the three CHNP activities are synergized and bring benefits to the community.
8.2 Roles and Responsibilities for the CHNP ESMS MCA-Indonesia is responsible for upholding the environmental and social management
requirements as stated in this ESMS. Due to the complexity of the institutional
structure of CHNP, the Health and Nutrition Director will ensure clear assignment of
responsibilities related to execution of this ESMS.
CHNP shall assume the overall responsibility of executing the ESMS at all levels of
project implementation. This includes assigning roles and responsibilities for the
National Secretariat Team and the communications campaign contractor, recruiting
consultants to conduct specific studies or implement specific tasks, and ensuring
constructive information sharing between GSC (Activity 1) and parties involved in
Activities 2 and 3. CHNP is also responsible for communicating the ESMS to all parties
involved in implementing the project. Assistance from the ESP unit can be sought.
Contractor’s roles and responsibilities in relation to this ESMS shall be described in
contracts and other legally binding documents, and will be monitored as part of the
contract performance monitoring. This is particularly crucial for contracts with the
suppliers of the micronutrient supplements and their sub-contractors; as well as for
the third-party contractor assigned to implement the communications campaign.
The ESP Director will maintain oversight responsibility for implementation of the CHNP
ESMS. Where needed, the ESP unit shall provide technical support to CNHP.
8.3 CHNP Internal Capacity Assurance MCA-Indonesia shall ensure there is capacity within the MCA-Indonesia organization
and all third-party organizations38, as well as sufficient resources to implement this
ESMS (described in the ESAP). This includes sufficient resources allocated in MCA-
Indonesia budgets and in contracts with contractors/consulting firms, in other
agreements with other third-party organizations.
Where MCA-Indonesia delegates some of its authority to contractors or other entities,
the agreements or contracts that govern their relationship shall incorporate the
entity’s or contractor’s obligations, roles and responsibilities with regard to
implementation of this ESMS. Where possible, the contracts or agreements shall
contain sanctions for failure in or inadequate performance of said duties.
For the micronutrient provision sub-activity, MCA-Indonesia shall conduct a capacity
assessment as part of the due diligence process prior to finalization of the project
design and bidding documents for micronutrient suppliers. Should severe deficiency
be identified, MCA-Indonesia shall obtain assurances that the organization will enhance
their capacity to ensure conformance with their obligations. Should sub-contractors
38 This includes contractors, consulting firms, Government health agencies and services.
ESMS for CHNP
44
be involved, the main supplier is responsible for ensuring the sub-contractor adheres
to the same quality assurance and control standards utilized by the main supplier, and
agreed to with MCA-Indonesia.
MCA-Indonesia, through the ESP Director and CNHP, shall also ensure that district
government agencies, Puskesmas and Posyandu are prepared to execute their roles
and responsibilities related to this ESMS and detailed in the ESAP. This includes
monitoring and reporting, as well as grievance management. The CHNP team is
responsible for communicating the roles and responsibilities, and integrating them into
the routine workflow of the project.
8.4 Budget Requirements for Effective CHNP ESMS
Implementation MCA-Indonesia shall ensure that sufficient budget is allocated annually and throughout
the entire Compact period to implement and institutionalize the CHNP ESMS, as well
as to conduct evaluation and revision of the requirements, as necessary.
Budgets required for environmental and social performance activities shall be
reflected and secured in the Quarterly Disbursement Request (QDR), disbursement
and procurement plans, and made ready for use in each respective quarter of the
CHNP implementation.
8.5 Capacity Development and ESMS Roll-Out The MCA-Indonesia ESP Director is responsible for ensuring that all relevant parties
are aware of the ESMS and the CHNP ESMS. The ESP Director will work with the Health
and Nutrition Director to develop an ESMS roll-out/communication plan, which is
integrated or dovetailed with the rolling out of the Social and Gender Integration Plan.
This plan shall include:
Development and delivery of workshops/ training sessions for MCA-Indonesia
officers and staff;
Development and delivery of workshops/ training sessions for contractors,
consultants or other entities assigned to implement portions of CHNP;
Development and delivery of workshops/ training sessions for Ministry of
Health, and district health agencies, and Puskesmas;
Assignment of responsibilities in the CHNP Management and ESP Management
of MCA-Indonesia to implement the plan;
Schedule for preparation of tools and commencement of workshops/training
sessions.
Any capacity development activity related to implementation of this ESMS shall also
consider the appropriateness of materials and/or delivery to women and marginalized
target groups.
ESMS for CHNP
45
8.6 Compliance and Environmental Audit MCA-Indonesia and the CHNP may be subject to a technical audit that may include
environmental (and social) audits, as described in the Audit Guidelines. Compliance
shall be verified by means of regular project monitoring or audit. ESMS compliance
shall be a contractual obligation for the suppliers of the micronutrient supplements.
Should MCA-Indonesia (or its contractors) discover ESMS-related violations or non-
compliance, MCA-Indonesia shall issue a warning letter to the parties involved, and
develop plan of action to ensure compliance. As is the case with breaches of other
contracts, sanctions or reprimands for ESMS non-compliance shall be enforced in line
with MCA-Indonesia policies.
8.7 Reporting of Environmental and Social Performance The MCA-Indonesia ESP Director is responsible for reporting environmental and social
performance to the MCA-Indonesia Executive Director on an annual basis. Such a
report shall be prepared jointly with the Social and Gender Director. The environmental
and social performance reports shall be compiled from reports prepared by the three
Compact Projects. The CHNP, reports shall consist of information gathered from
Project’s monitoring and evaluation framework.
On a quarterly basis, the MCA-Indonesia ESP Director (with the Social and Gender
Director) and the CHNP Director shall meet to evaluate the Project’s environmental
and social performance, and identify issues regarding non-compliance, capacity
development needs and progress, and other factors that hinder positive performance.
The ESP Director shall develop environmental and social indicators to be included in
the CHNP’s monitoring and evaluation framework. Such indicators shall be inserted
into the monitoring and reporting obligations of MOH, as the Partner Agency, and as
described in the Implementing Entity Agreement. Where appropriate, the ESP Director
shall also extract information from the GSC’s reporting (and M&E) cycle, minimizing
duplication of data collection, analysis and reporting.
For the micronutrient production, MCA-Indonesia shall ensure that private producer(s)
receiving financial support from MCA-Indonesia complies with reporting requirements
under their environmental permit. As much as possible, the private producer’s
environmental and social monitoring program shall be synchronized with MCA-
Indonesia’s monitoring framework to minimize duplication of data collection, analysis
and reporting. Ministry of Health (as Implementing Entity) is responsible for ensuring
that the private producer is in compliance with GOI regulations.
8.8 Review and Revision of ESMS for CHNP Evaluation of CHNP’s environmental and social performance may lead to findings
regarding weakness of or inappropriate requirements and/or procedures in the ESMS
for CHNP. This may include problems with cumbersome procedures, inappropriate or
ineffective division of roles and responsibilities, and/or requirements that are too
stringent for the scope or level of activities.
ESMS for CHNP
46
Should there be such findings, the ESP Director shall decide whether this ESMS for
CHNP should be modified or revised. In making this decision, the ESP Director shall
consult the Social and Gender Director and the CHNP Director, and will seek advice/
support from MCC.
Revision of the requirements or procedures of this ESMS for CHNP must still comply
with the overall ESMS Framework for MCA-Indonesia and, particularly, must not violate
the Policy Statement in the Tier 1 ESMS Framework or the laws and regulations of the
Government of Indonesia.
ESMS for CHNP
47
Appendix A
A. Multiple Micronutrient Product (MMNP) Traceability
Guidance Community-based Health and Nutrition Project
1. Background
The CHNP will provide micronutrients to children and pregnant women. The
micronutrients will be distributed to the community through the District-level
Pharmaceutical Warehouse, the Puskesmas and Posyandu at project locations. To
anticipate the negative impact of providing micronutrient, it is necessary to build a
traceability system.
Product traceability systems allow for complete and up to date histories of all batches
of micronutrient product from the premix/bulk material to the complete final product.
Identification and status of material is provided by a unique and controlled numbering
system. The system can be interrogated to provide a report/record for an individual
dose to trace its course to its point of origin.
2. Objectives
The objectives of this guidance are:
a. To ensure all multiple micronutrient products will be appropriate identified
during the product’s processing, packaging, storage, distribution and
consumption at the community/users level.
b. To ensure the products can be traceable in cases of adverse events following
their consumption at the community/users level.
3. Authorities and Responsibilities
Indonesia Ministry of Health (MoH) as implementer of the MMNP project will be
responsible for day-to-day implementation of the distribution of MMNP. MCA
Indonesia will hire a consultant for the overall preparing and run the traceability system
for MMNP project. The specific task for the consultant will be provided in the TOR.
4. Control Measures
Premix/bulk production. The multiple micronutrient premix/bulk product should have
a unique batch number given by the producer’s laboratory. The producer’s quality
assurance team (QA team) will maintain the nutrient ingredients in MMN product. Each
ESMS for CHNP
48
ingredient in the premix/bulk product should meet the specification mentioned in the
Indonesia Pharmacopeia and/or US Pharmacopeia or European Union Pharmacopeia,
or if these standards are not available, other recognized international standard. In
preparing the premix/bulk normally an extra proportion of the micronutrient is added
as an ‘overage’ in order to compensate for anticipated losses or degradation during
storage.
Finished Product. The finished product for MMNP should be done under proper Good
Manufacturing Practices (GMP) conditions, such as adequate level of industrial
hygiene, adequate processing conditions in well-maintained and state-of-the-art
equipment, full traceability back to the raw material, Hazard Analysis and Critical
Control Point (HACCP) procedures implemented according to Codex Alimentarius and
ISO 22000.
Certificate of Analysis Testing. The producers of multiple micronutrient premix/bulk
product should obtain a Certificate of Analysis from a certified laboratory, showing the
content of the product. Upon receiving all administrative submission BPOM will
physically inspect the factory using the GMP criteria checklist. License will be obtained
within 3 months process after fulfilling all the BPOM criteria. Beside the license from
BPOM, the producers should also provide the Halal Certificate from the country of
origin or by Majelis Ulama Indonesia (MUI).
MMNP Packaging. The Ministry of Health, through Regulation No.
2409/MENKES/PER/2011 on Nutrient Sprinkle Standard (Standar Bubuk Tabur Gizi),
has specified the materials for the packaging of MMNP (Taburia) which has already
proved to be robust packaging. But, from the producers’ point of view, the packing of
every 15 sachets into zip-lock plastic bag is not efficient because it is done manually.
Producers suggest to pack the 15 sachet in common sealed plastic bag and the
producer still will provide separate empty zip-lock for every 15 sachets. Mothers will
use the zip lock to keep the sachets after open the plastic bag. The Ministry of Health
also has specified the standard labeling and expiry date for Taburia that should be
followed by anybody who wish to produce standard Taburia.
Batch Number. Batch numbers should appear on each sachet of MMNP/Taburia. Each
batch number is an eight digit number in the format YYXXZZZZ, starting with the last
two digits of the year, followed by two digits of the month. A consecutive four digits
number is assigned up to 9000 sachet of batches starting from 0001.
Quality spot check. Inspection and spot checks should be done at various levels
(District Warehouse, Puskesmas, Posyandu and Community/users) to verify the
quality of the products.
Storage. The storage data must follow the First In-First Out (FIFO) and First Expires
– First Out (FEFO) principles.
Documentation and Recording. Full traceability is assured through issuing
appropriate documentation and maintaining records that accompany every step in
batch manufacturing...
ESMS for CHNP 49
MMNP supply chain traceability model:
TRACKING
Process Premix
Producer
Packager/
Distributor
District
Warehouse Puskesmas Posyandu
Community/Us
ers
Product
Identificatio
n Method
Premix/Bu
lk batch
number
Proper batch
number on each
sachets and
product ID on each
box (small and big
box)
Proper batch
number on each
sachets and
product ID on
each box (small
and big box)
Proper batch number
on each sachets and
product ID on each
box (small and big
box)
Proper batch
number on
each sachets
Proper batch
number on
each sachets
Traceability
Records
Producer
quality
control
procedure
s and
quality
control
records
Batch number
records
BPOM – Certificate
Analysis Testing
Distribution plan
Distribution form
Distribution
plan
Receipt and
Distribution
form
Distribution plan
Receipt and
Distribution form
Receipt and
Distribution
form
Receipt and
Distribution
form
Users/benefici
aries list
Premix
Producers
Packager/
Distributor
District
Warehouse Puskesmas Posyandu
Community/Us
ers
TRACING
ESMS for CHNP 48
ESMS for CHNP 50
Appendix B
B. Indigenous Peoples Plan Framework (IPPF)
1. Introduction
Since CHNP components may support activities/specific-projects across several
provinces in the country, they are likely to affect Indigenous People (IP) or ethnic
minority in a number of Specific-project areas in participating provinces such as Jawa
Barat, Jawa Timur, Nusa Tenggara Barat, Nusa Tenggara Timur, Gorontalo, Maluku,
Sulawesi Utara, Sulawesi Barat, Kalimantan Barat, Kalimantan Tengah, and Kalimantan
Selatan.
This IPPF is prepared in order to provide some general principles and procedures that
will be applied during Specific-project preparation and implementation, if IP are to be
affected. In the CHNP activities, therefore, the purpose of the framework is for ensuring
consultation, giving IP a voice, and an opportunity to benefit from the program.
Objective
The primary objectives of the IPPF are to ensure that:
such groups are afforded meaningful opportunities to participate in planning
that affects them;
opportunities to provide such groups with culturally appropriate benefits are
considered;
any project impacts that adversely affect them are avoided, to the extent
possible. If unavoidable, mitigation measures should be developed.
This is in line with the national objective in empowering indigenous community
(Komunitas Adat Terpencil - KAT), in which to grant of authority and belief to KAT to
self-determine their own destiny and various development activity programs available
within their location and their necessity through protection, reinforcement,
development, consultancy and advocating to improve their social prosperity level.
2. Definition
The national legislation, Presidential Decree No. 111/1999 sets the criteria as follows: a)
in form of small, closed and homogenous community; b) social infrastructure
supported by familial relationships; c) in general geographically remote and relatively
difficult to reach; d) in general live in subsistence economy; e) its Government of
Indonesia equipment and technology is simple; f) dependency to local environment
and natural resources are relatively high; g) limited access to social, economic, and
political service.
ESMS for CHNP
51
The terms “indigenous people”, “indigenous ethnic minorities” and “tribal groups”,
describe social groups with a social and cultural identity distinct from the dominant
society that makes them vulnerable to being disadvantaged in the development
process. For the purposes here, “indigenous people” is the term that will be used to
refer to these groups.
Indigenous peoples are commonly among the poorest segments of a population.
According to the IFC Performance Standard and World Bank policy, the term
“Indigenous Peoples” is used in generic sense to refer to a distinct, vulnerable, social
and cultural group processing the following characteristics in varying degrees: a) a
close attachment to ancestral territories and to the natural resources in these areas; b)
self-identification and identification by others as members of a distinct cultural group;
c) an indigenous language, often different from the national language; and d) presence
of customary cultural, economic, social or political institutions.
For the purpose of this Framework, the definition of IP will try to follow both the
criteria of the IFC/World Bank and the national legislation.
3. Screening for indigenous people among the affected populations
Initial screening of the potential presence of IP in the specific-projects area will be
conducted by using combination criteria of IFC Performance Standard and World Bank
and national legislation identification. All specific-project areas which have IP
communities will be visited (at the time of first consultation with communities) by a
project implementing unit and relevant local authorities, including personnel with
appropriate social science training or experience. Prior to the visit, respective project
implementing unit will send notice to the communities informing their leaders that they
will be visited for consultation. The notice will request that the communities invite to
the meeting representatives of community livelihood (i.e. farmers, fishermen, etc.),
women associations and village leaders for discussion on the Specific-project. During
the visit, the community leaders and other participants will be consulted and present
their views with regards to the Specific-project.
At this visit, personnel with social science training or experience will undertake a
further screening for IP population with the help of local leaders, local authorities, and
NGO as necessary. The screening will check for the following: (a) names of IP groups
in the affected village; (b) total number of IP in the affected villages; (c) percentage of
IP in affected villages; (d) Number and percentage of indigenous households within a
described zone of influence of the proposed Specific-project.
If the results show that there are IP communities in the zone of influence of the
proposed specific-project, a social assessment will be planned for those areas.
4. Social Assessment (SA) and Consultation
During the preparation of the Specific-project proposal and/or Specific-project
approval, a social assessment process will be undertaken to define the Information
dissemination to all members of the IP community will be conducted specifically
ESMS for CHNP
52
targeting appropriate message routes in accordance with prevailing customs and
traditions, including using the commonly used IP language in every meeting, minutes,
brochures, etc.
5. Indigenous People Plan
Free, prior and informed consultations will be conducted through a series of meetings,
including separate group meetings: indigenous village leaders; indigenous men; and
indigenous women, especially those who live in the zone of influence of the proposed
work under Specific-project. Discussions will focus on Specific-project impacts,
positive and negative; and recommendations for design of Specific-projects. If the SA
indicates that the proposed Specific-project will cause adverse impact or that the IP
community rejects the proposal, the Specific-project will not be approved (and
therefore no further action is needed). If the IP supports the Specific-project
implementation an IPP will be developed to ensure that the IP will receive culturally
appropriate opportunities to benefit from the Specific-project activities.
The IPP is prepared in a flexible and pragmatic manner, and its level of detail varies
depending on the specific project and the nature of effects to be addressed. It will
include the following elements, as needed:
a. A summary of Social Assessment (SA);
b. A summary of results of the free, prior, and informed consultation that was
carried out during Specific-project preparation;
c. A framework for ensuring free, prior, and informed consultation with the
affected indigenous communities during project implementation.
d. An action plan of measures to ensure that the Indigenous Peoples receive social
and economic benefits culturally appropriate;
e. The cost estimates and financing plan for the IPP;
f. Accessible grievance mechanism, which takes into account the availability of
customary mechanism;
g. Monitoring, evaluation and reporting mechanism
The GSC is expected to prepare IPP under the Community Project Activity, and
expected to share the IPP and findings of the social assessment with the Supply Side
Activity and Communications, Monitoring and Evaluation Activity. The Supply Side
Activity and Communications Campaign are expected to report the presence of
indigenous peoples, the project approach taken at the field level and any unexpected
reactions towards project activities. Such a report will be submitted to the CHNP
Director, with copy to the ESP Director and SGA Director on a regular basis.
ESMS for CHNP
53
The IPP should be disclosed publicly so that accessible to the affected indigenous
community.
Upon agreement between the CHNP Director and ESP Director, for the specific-
projects that work utilize community-decision making process, a stand-alone IPP may
not be required. The process to ensure that the IP are included as beneficiaries and
participate in any activities will be incorporated in the specific-project design.
6. Principles if a Specific-project affects indigenous peoples
There are a number of measures to be applied when the IP are presence in the Specific-
project area and are part of the beneficiaries, in relation to the development of
indigenous peoples plan.
Project implementation unit or proponent (PIU) will ensure that free, prior and
informed consultations are undertaken, in a language spoken by, and location
convenient for, potentially affected IP. The views of IP are to be taken into
account during preparation and implementation of any Specific-project, while
respecting their current practices, beliefs and cultural preferences. The outcome
of the consultations will be documented into the Specific-project documents.
If the IP conclude that the Specific-project will be beneficial to them, and that
any minor adverse impacts, if any, can be mitigated, a plan to assist them will
be developed based on consultation with the IP and local representatives. The
community should also be consulted to ensure that their rights and culture are
respected. The assistance may also include institutional strengthening and
capacity building of indigenous villages and community groups working with
the Specific-project.
In the issue of access restriction to the natural resources, the IP will participate
in the zoning and mapping activities in order to fully benefit from the project. In
full consultation with the IP groups, the zoning and mapping activities will define
the areas with customary rights of the local IP and reflect the issues in the IPP
with particular actions to protect or compensate the groups.
Where indigenous people are identified that represent a sufficiently large
interest, efforts will be made to ensure that the group is represented and that
regular and formal communication is established with the group.
Where the indigenous people speak a language different from Bahasa
Indonesia, relevant brochures and documents will be translated in the
appropriate language. Provision has been made in the project budget to allow
for additional translations of relevant project documents as well as preparation
of pictorial materials (brochures, posters, etc.).
These steps will be aimed at ensuring that indigenous peoples participate fully in the
project, are aware of their rights and responsibilities, and are able to voice their needs
during the social/economic preliminary survey/exercise and in the formulation of the
Specific-projects and operational policies. In addition, they will be encouraged to
submit Specific-project proposals that cater to their group's needs, if necessary.
ESMS for CHNP
54
7. Reporting, Monitoring and Documentation
Besides specific attention to IP issues in supervision and monitoring, PIU will include
these matters in their progress reporting. The MCA-I (through CHNP and ESP unit)
supervision missions will periodically pay special attention to ensure that that the
Specific-projects affecting IP afford benefits to them and no adverse impacts on them.
8. Implementation Arrangement
The PIU will be responsible for training the respective project implementing unit or
local authorities to undertake the work of consultation, screening, social assessment,
analyses and preparing IPPs and addressing any grievances.
PIU of individual Specific-projects and local authorities are responsible for
implementing IPP (arrange adequate staff and budget).
ESMS for CHNP
55
Appendix C
C. Example of Statement Letter for Land Donation
I, the undersigned:
Name :
Occupation :
Address :
Herewith declare that I voluntarily donate my land or assets affected for the project /
Specific-project ……………………………………………………………………………………………….. (Write the
name of project / Specific-projects to be constructed)
Location of land :
Size of land :
Current land use :
Status of ownership :
With reasons :
Map/sketch of donated land with borders :
............................................................................................................................. ................................................
....................................................................................................................................................... ......................
.............................................................................
This statement was made in good faith without any coercion.
Place, date of the agreement
Knowing,
Landowner Signature Acknowledgement by Head of Village,
Name: ................................ Name: ................................
Signature of heirs and witnesses:
1. Name: ............................................ Signature:
2. Name: ............................................ Signature:
3. Name: ............................................ Signature:
ESMS for CHNP
56
Appendix D
D. List of Available Operational Guidelines for the
CHNP39
MCA-Indonesia, Technical Operation Manual for Child Growth Monitoring Training,
Community Based Health and Nutrition Program (CHNP), Revised January 2015.
MCA-Indonesia dan Kementerian Kesehatan Republik Indonesia, Pedoman
Pelaksanaan Sanitasi Total Berbasis Masyarakat, Proyek Kesehatan dan Gizi Berbasis
Masyarakat (PKGBM), 2015.
Ministry of Health of The Republic of Indonesia, Directorate General of Nutritional
Health and Mother and Child Health, Technical Operation Manual Training for
Counseling on Infant and Young Child Feeding (IYCF), 2014.
MCA-Indonesia and the Ministry of Health of the Republic of Indonesia, Technical
Operation Manual Community Led Total S
anitation, Community Based Health and Nutrition Project (CHNPP), 2015.
Ministry of Health of The Republic of Indonesia and MCA-Indonesia, Guideline for the Management
Of Distribution And Quality Control of Micronutrient Powder For Children 6-24 Months, 2015
Ministry of Health of The Republic of Indonesia and MCA-Indonesia, Guidelines For Iron And
Folic Acid Supplements Distribution And Quality Control Program For Pregnant Women, 2015.
Guideline for the Management of Distribution and Quality Control of Micronutrient
Powder for Children Age 6-24 Months in Community-based Health and Nutrition
Program Areas, 2016
Guidelines For Iron And Folic Acid Supplements Distribution And Quality Control
Program For Pregnant Women In Community-based Health and Nutrition
Program Areas, 2016
Technical Specifications and Requirements Provision and distribution of Iron Folic Acid
Tablets for pregnant women (undated).
Other Relevant Guidelines
World Health Organization, e-Library of Evidence for Nutrition Actions, Multiple Micronutrient
Powders for Home Fortification of Foods Consumed by Children 6-23 Months;
http://www.who.int/elena/titles/guidance_summaries/micronutrientpowder_infants/
en/
39 List updated in February 18, 2016. Documents subsequently produced/ finalized will require update of this list.