7
SITE ENVIRONMENTAL AUDIT
7.1
Site Inspections
7.1.1
Site
inspections provide a direct means to initiate and enforce specified
environmental protection and pollution control measures. These shall be undertaken routinely to
inspect construction activities in order to ensure that appropriate
environmental protection and pollution control mitigation measures are properly
implemented. The site inspection is one
of the most effective tools to enforce the environmental protection requirements
at the works area.
7.1.2
The
ET Leader shall be responsible for formulating the environmental site
inspection, the deficiency and action reporting system, and for carrying out
the site inspection works. Within 21
days of the construction contract commencement, he shall submit a proposal for
site inspection and deficiency and action reporting procedures to the
Contractor for agreement, and to the ER for approval. The ET’s proposal for rectification would be
made known to the IC(E).
7.1.3
Regular
site inspections shall be carried out at least once per week. The inspection shall not be limited to the
environmental situation, pollution control and mitigation measures within the
site; it should also review the environmental situation outside the works area
which is likely to be affected, directly or indirectly, by the site
activities. The ET Leader shall make
reference to the following information in conducting the inspection:
(i) EIA recommendations on environmental
protection and pollution control mitigation measures;
(ii) works progress and programme;
(iii) individual works methodology proposals
(which shall include proposal on associated pollution control measures);
(iv) contract specifications on environmental
protection;
(v) relevant environmental protection and
pollution control laws; and
(vi) previous site inspection results.
7.1.4
The
Contractor shall keep the ET Leader updated with all relevant information on
the construction contract necessary for him to carry out site inspections. Inspection results and associated
recommendations for improvements to the environmental protection and pollution
control works shall be submitted to the IC(E) and the Contractor within 24
hours. The Contractor shall follow the
procedures and time-frame as stipulated in the environmental site inspection,
and the deficiency and action reporting system formulated by the ET Leader, to
report on any remedial measures subsequent to the site inspections.
7.1.5
Ad hoc site inspections shall also be carried out if significant
environmental problems are identified.
Inspections may also be required subsequent to receipt of an
environmental complaint, or as part of the investigation work, as specified in
the Action Plan for environmental monitoring and audit.
7.2
Compliance with Legal and
Contractual Requirements
7.2.1
There
are contractual environmental protection and pollution control requirements as
well as environmental protection and pollution control laws in Hong Kong with
which construction activities must comply.
7.2.2
In
order that the works are in compliance with the contractual requirements, all
works method statements submitted by the Contractor to the ER for approval
shall be sent to the ET Leader for vetting to see whether sufficient
environmental protection and pollution control measures have been
included. The implementation schedule of
mitigation measures is summarised in Appendix A.
7.2.3
The
ET Leader shall also review the progress and programme of the works to check
that relevant environmental laws have not been violated, and that any
foreseeable potential for violating laws can be prevented.
7.2.4
The
Contractor shall regularly copy relevant documents to the ET Leader so that
works checking can be carried out. The
document shall at least include the updated Works Progress Reports, updated
Works Programme, any application letters for different licence / permits under
the environmental protection laws, and copies of all valid licences /
permits. The site diary shall also be
available for the ET Leader's inspection upon his request.
7.2.5
After
reviewing the document, the ET Leader shall advise the IC(E) and Contractor of
any non-compliance with contractual and legislative requirements on
environmental protection and pollution control for them to take follow-up
actions. If the ET Leader's review
concludes that the current status on licence / permit application and any
environmental protection and pollution control preparation works may result in
potential violation of environmental protection and pollution control
requirements, he shall also advise the Contractor and the ER accordingly.
7.2.6
Upon receipt of the advice, the Contractor shall undertake
immediate action to correct the situation.
The ER shall follow up to ensure that appropriate action has been taken
in order to satisfy contractual and legal requirements.
7.3
Environmental Complaints
7.3.1
Complaints
shall be referred to the ET Leader for action.
The ET Leader shall undertake the following procedures upon receipt of
any complaint:
(i) log complaint and date of receipt onto the
complaint database and inform the IC(E) and ER immediately;
(ii)
investigate the complaint to determine
its validity, and assess whether the source of the problem is due to works
activities;
(iii) identify
mitigation measures in consultation with the IC(E) if a complaint is valid and
due to works;
(iv) advise
the Contractor if mitigation measures are required;
(v) review
the Contractor's response to identified mitigation measures, and the updated
situation;
(vi) if the complaint is transferred from the
EPD, submit interim report to the EPD on status of the complaint investigation
and follow-up action within the time frame assigned by the EPD;
(vii) undertake additional monitoring and audit to
verify the situation if necessary, and review the circumstances leading to the
complaint (to ensure that any short comings) do not recur;
(viii) report investigation results and subsequent
actions to complainant (if the source of complaint is EPD, the results should
be reported within the timeframe assigned by the EPD); and
(ix) record the complaint, investigation, the
subsequent actions and the results in the monthly EM&A reports.
7.3.2
During
any complaint investigation work, the Contractor and ER shall co-operate with
the ET Leader in providing all necessary information and assistance for
completion of the investigation. If
mitigation measures are identified as being required in the investigation, the
Contractor shall promptly carry out the mitigation. The ER shall ensure that all necessary
measures have been carried out by the Contractor.