E476
Vol. 1
Female Secondary School Assistance Project-1I
(P044876)
Environmental Analysis
I.   Project Description:
The project development objective is to improve quality of, and girls access to, secondary
education in rural areas of Bangladesh. The proposed project is a sequel to the IDA
financed Female Secondary School Assistance Project (FSSAP) (1993-2001), and
responds to the Government request for IDA assistance to build upon the success of that
project. The FSSAP II project sustains improved gender equity, and adds activities and
incentives to increase the quality of education in participating schools and to improve
both the management capacity of the Ministry of Education and monitoring and
accountably mechanisms at the community level. The project will address institutions in
119 Upazillas throughout Bangladesh distributed as follows: 12 Upazillas in Barisal
Division; 15 Upazillas in Chittagong Division; 32 Upazillas in Dhaka Division; 19
Upazillas in Khulna Division; 32 Upazillas in Rajshahi Division and 8 Upazillas in
Sylhet Division
II.  Key Environmental Issues:
The principal environmental concerns regarding FSSAP II relate to the need to ensure the
provision of safe drinking water, and the provision and maintenance of adequate
sanitation.
1.   Ensuring the Provision of Safe Drinking Water
After contamination of tubewells with naturally occurring arsenic was identified as a
national problem, testing was initiated of tubewells installed under FSSAP I. To date,
approximately 60% of the tubewells installed under FSSAP I have been tested, of which
some 14% have been found contaminated with arsenic at concentrations above the
national standard for drinking water.
Actions have been designed under FSSAP II to address the following aspects of this
environmnental challenge:
*  Provision of safe drinking water at schools without tubewells;
*  Testing of tubewells for arsenic contamination; and,
* Provision of alternative safe drinking water at schools with arsenic contaminated
tubewells.
2.   Provision and Maintenance of Sanitation
The provision of safe sanitation is a first step towards creating a healthy physical learning
environment. Experience demonstrates, however, that to derive the full health benefits,
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latrines must be appropriately designed, in a good functional state, used by all students
and teaching staff, and the users need to practice adequate hygiene behavior.
Guidelines for the Improvement of School Sanitation have been developed, and should
inform the design, maintenance and use of latrines under FSSAP II.
III. Proposed Mitigation Plans:
Ensuring the Provision of Safe Drinking Water
1.   Provision of safe drinking water at schools without tubewells
Nationally, it is estimated that approximately 30% of Shallow Tubewells (STWs) are
arsenic contaminated, compared with only 1-2% of Deep Tubewells (DTWs). To
minimize the risk of arsenic contamination, FSSAP II will not support the installation of
any further STWs, but will provide DTWs for schools that do not have any safe drinking
water.
DTWs will be installed by the Local Government Engineering Department (LGED),
following the guidelines for installation of DTWs to be developed by the Local
Government Division (LGD) as part of the national arsenic mitigation program. In all
cases, newly installed DTWs will be tested for arsenic contamination as indicated below.
2.   Testing of tubewells for arsenic contamination
All tubewells (STW or DTW) installed under FSSAP I and II must be tested for arsenic
contamination on installation, and given that groundwater conditions may change, they
should be retested six months later, and annually thereafter.
If required, FSSAP II will provide retroactive funding to complete the initial testing of
tubewells installed under FSSAP I. This testing will be conducted at either private or
Department of Public Health Engineering (DPHE) laboratories. These services will be
selected on a competitive basis from among those laboratories that performed
satisfactorily in the Inter-Laboratory Comparison conducted in 2001 by IAEA and WHO.
The Directorate of Secondary and Higher Education (DSHE) will be responsible for
contracting these services, and Upazila Project Officers (UPOs) will be responsible for
coordinating the collection of samples, recording results and informing School
Management Committees (SMCs). SMCs will ensure that all arsenic contaminated
tubewells are painted red, following national practice, and will instruct pupils and staff
not to use water from these tubewells for drinking or cooking.
Installation of new DTWs under FSSAP II will only be approved if arsenic testing
immediately on installation can be guaranteed. SMCs, with the assistance of UPOs, may
either contract this testing from a laboratory approved by the DSHE, or may seek the
commitment of the ward-level arsenic mitigation committee, to be established under the
national arsenic mitigation program, to test their DTW using field test kits.



SMCs will also be responsible for ensuring that the ward-level arsenic mitigation
committee conducts follow-up testing of FSSAP I and II tubewells, six months after
installation and annually thereafter. The UPO will maintain records of tubewell testing
and status, which will be compiled nationally by DPHE.
3.  Provision of alternative safe drinking water at schools
with arsenic contaminated tubewells
In cases where FSSAP I or II tubewells are found to be arsenic-contaminated, FSSAP II
will support the provision of alternative safe drinking water. In cases where STWs are
found to be contaminated, LGED will be contracted to install a DTW, following the
national guidelines to be developed by LGD, and provided that according to these
guidelines, local conditions are considered appropriate.
In the few cases that DTWs are not considered appropriate, or are found to be arsenic
contaminated, alternative options will be considered by the SMC in consultation with the
ward-level arsenic mitigation committee. The options to be considered should be those
validated by the Government under the national arsenic mitigation program, and may
include arsenic removal technologies, or alternative sources such as rain-water
harvesting, dug-wells or pond-sand filters.
Provision and Maintenance of Sanitation
The Guidelines for Improvement of School Sanitation, deVeloped in June 2001 by the
International Training Network at the Bangladesh University of Engineering and
Technology, together with the International Water and Sanitation Centre, should be used
to help guide the design, maintenance and use of latrines supported by FSSAP II. The
Guidelines are attached as Annex 1.
The Guidelines, and accompanying fact sheets which describe different types of latrines,
will help SMCs to determine what improvements in school sanitation are needed, and
which technical options will be most suitable considering local environmental and social
conditions, and the capacity of the school to operate and maintain them. Dissemination
of these guidelines will be built into the training to be provided to the UPOs and SMCs.
IV. Institutional Arrangements
The project will be implemented over a five year period (2001-2006) in 119 rural
Upazillas. The DSHE will be the lead agency for the project. As under the current
FSSAP, an Inter-Ministerial Steering Committee, chaired by the Secretary MoE, will
facilitate project implementation, and provide policy and decision making guidance.
Implementation of the current FSSAP is managed by a PIU and the local Upazilla Project
Offices (UPO) with Steering Committee Oversight provided by MoE/DSHE. The
responsibility of implementation for FSSAP II has been shifted to the Program
Management Unit (PMU) which is to be established within the MoE/ DSHE.



With the guidance of UPOs, SMCs will be responsible for ensuring that school tubewells
are tested for arsenic. SMCs may either contract this testing from a laboratory approved
by the DSHE, or may obtain testing using field test kits from the ward-level arsenic
mitigation committee, to be established under the national arsenic mitigation program.
SMCs will also be responsible for ensuring that the ward-level arsenic mitigation
committee conducts follow-up testing of tubewells, six months after installation and
annually thereafter. The UPO will maintain records of tubewell testing and status, which
will be compiled nationally by DPHE.
DSHE will ensure that the Guidelines for Improvement of School Sanitation are
disseminated through the UPOs to the SMCs. The design and maintenance of latrines,
and requirements for arsenic testing of tubewells, will be incorporated into the training to
be provided to UPOs and SMCs. Selection of latrine design, as well as construction and
maintenance will be the responsibility of SMCs, with clearance to be provided by UPOs.
V.  Monitoring and Evaluation
Monitoring and Evaluation activities for FSSAP II will be built into the current DSHE
program, with the goal of ensuring accountability and monitoring of development
objectives.
On the basis of reports submitted by SMCs, UPOs will be responsible for recording the
installation of tubewells, the dates and outcomes of arsenic testing, the construction of
latrines, and their operating and hygienic condition. UPO records will be compiled by
DSHE, who will also contract annual audits of arsenic testing by an independent
institution, which will retest a representative sample of the tubewells installed under
FSSAP I and II. The records compiled by DSHE and the independent verification of
arsenic testing will be submitted for review by IDA during supervision missions.



With the guidance of UPOs, SMCs will be responsible for ensuring that school tubewells
are tested for arsenic. SMCs may either contract this testing from a laboratory approved
by the DSHE, or may obtain testing using field test kits from the ward-level arsenic
mitigation committee, to be established under the national arsenic mitigation program.
SMCs will also be responsible for ensuring that the ward-level arsenic mitigation
committee conducts follow-up testing of tubewells, six months after installation and
annually thereafter. The UPO will maintain records of tubewell testing and status, which
will be compiled nationally by DPHE.
DSHE will ensure that the Guidelines for Improvement of School Sanitation are
disseminated through the UPOs to the SMCs. The design and maintenance of latrines,
and requirements for arsenic testing of tubewells, will be incorporated into the training to
be provided to UPOs and SMCs. Selection of latrine design, as well as construction and
maintenance will be the responsibility of SMCs, with clearance to be provided by UPOs.
V.  Monitoring and Evaluation
Monitoring and Evaluation activities for FSSAP II will be built into the current DSHE
program, with the goal of ensuring accountability and monitoring of development
objectives.
On the basis of reports submitted by SMCs, UPOs will be responsible for recording the
installation of tubewells, the dates and outcomes of arsenic testing, the construction of
latrines, and their operating and hygienic condition. UPO records will be compiled by
DSHE, who will also contract annual audits of arsenic testing by an independent
institution, which will retest a representative sample of the tubewells installed under
FSSAP I and II. The records compiled by DSHE and the independent verification of
arsenic testing will be submitted for review by IDA during supervision missions.
Annex 1
Guidelines for Improvement of School Sanitation
(will be included)