8
SITE ENVIRONMENTAL AUDIT
8.1
Site Inspection
8.1.1
Site inspection provides 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.
8.1.2
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).
8.1.3
Regular site inspections shall
be carried out at least once per week.
The areas of 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.
8.1.4
The Contractor shall keep the
ET Leader updated with all relevant information on the construction contract
necessary for him to carry out the 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.
8.1.5
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.
8.2
Compliance with Legal and
Contractual Requirements
8.2.1
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.
8.2.2
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.
8.2.3
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.
8.2.4
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.
8.2.5
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.
8.2.6
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.
8.3
Environmental Complaints
8.3.1
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) 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 that circumstances leading to the complaint
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.