8.
SITE
ENVIRONMENTAL AUDIT
8.1
Site Inspections
8.1.1
Site inspections provide a direct means to trigger and enforce the
specified environmental protection and pollution control measures. They shall be undertaken routinely to
inspect the construction activities in order to ensure that appropriate
environmental protection and pollution control mitigation measures are properly
implemented. With well defined
pollution control and mitigation specifications and a well established site
inspection, deficiency and action reporting system, the site inspection is one
of the most effective tools to enforce the environmental protection
requirements on the construction site.
8.1.2
The ET is responsible for formulation of the environmental site
inspection, deficiency and action reporting system, and for carrying out the
site inspection works. He shall submit
a proposal on the site inspection, deficiency and action reporting procedures
within 21 days of the construction contract commencement to the Contractor for
agreement and to the ER for approval. The ET’s proposal for rectification would
be made known to the IEC(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 site area which is likely to be affected, directly or indirectly,
by the site activities. The ET shall
make reference to the following information in conducting the inspection:
a)
The EIA
recommendations on environmental protection and pollution control mitigation
measures
b)
Works progress
and programme
c)
Individual works
methodology proposals (which shall include proposal on associated pollution
control measures)
d)
The contract
specifications on environmental protection
e)
The relevant
environmental protection and pollution control laws
f)
Previous site
inspection results.
8.1.4
The Contractor shall update the ET with all relevant information of the
construction contract for him to carry out the site inspections. The inspection results and its associated
recommendations on improvements to the environmental protection and pollution
control works shall be submitted to the IEC(E) and the Contractor within 24
hours, for reference and for taking immediate action. The Contractor shall follow the procedures and time-frame as
stipulated in the environmental site inspection, deficiency and action
reporting system formulated by the ET 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 EM&A.
8.1.6
A mitigation implementation status proforma and a site inspection
proforma are provided in Appendix D1 and D2 respectively.
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 which the construction activities shall comply with.
8.2.2
In order that the works are in compliance with the contractual
requirements, all the 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.
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 the
any foreseeable potential for violating the laws can be prevented.
8.2.4
The Contractor shall regularly copy relevant documents to the ET Leader
so that the checking work can be carried out.
The document shall at least include the updated Work Progress Reports,
the updated Works Programme, the application letters for different
licence/permits under the environmental protection laws, and all the valid
licence/permit. 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 ER and the
Contractor of any non-compliance with the 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 not cope
with the works programme or may result in potential violation of environmental
protection and pollution control requirements by the works in due course, he
shall also advise the Contractor and the ER accordingly. The review
shall be copied to IEC for any follow up action.
8.2.6
Upon receipt of the advice, the Contractor shall undertake immediate
action to remedy the situation. The ER
shall follow up to ensure that appropriate action has been taken by the
Contractor in order that the environmental protection and pollution control
requirements are fulfilled.
8.2.7
A regulatory compliance proforma is presented in Appendix D3.
8.3
Environmental Complaints
8.3.1
Complaints shall be referred to the ET Leader for carrying out
complaint investigation procedures. The
ET Leader shall undertake the following procedures upon receipt of the
complaints:
a)
Log complaint and
date of receipt onto the complaint database and inform the ER and IEC immediately
b)
Investigate the
complaint to determine its validity, and to assess whether the source of the
problem is due to works activities
c)
If a complaint is
valid and due to works, identify mitigation measures in consultation with the IEC(E)
d)
If mitigation
measures are required, advise the Contractor accordingly
e)
Review the
Contractor's response on the identified mitigation measures, and the updated
situation
f)
If the complaint
is transferred from EPD, submit interim report to EPD on status of the
complaint investigation and follow-up action within the time frame assigned by
EPD
g)
Undertake additional
monitoring and audit to verify the situation if necessary, and review that any
valid reason for complaint does not recur
h)
Report the
investigation results and the subsequent actions to the source of complaint for
responding to complainant (If the source of complaint is EPD, the results
should be reported within the time frame assigned by EPD)
i)
Record the
complaint, investigation, the subsequent actions and the results in the monthly
EM&A reports.
8.3.2
During the complaint investigation work undertaken by the ET, the
Contractor and ER shall cooperate with the ET in providing all the necessary
information and assistance for completion of the investigation. If mitigation measures are identified in the
investigation, the Contractor shall promptly carry out the mitigation. The ER shall ensure that the measures have
been carried out by the Contractor.
8.3.3
A complaint log sheet is provided in Appendix D4.
8.3.4
ET should provide a flow chart of the complaint response
procedures. This should address
complaint receiving channels, responsible parties/contacts for
information/action, the investigation processes, procedures for the
implementation of mitigation measures, guidelines for communication and public
relation with the complainant.