Site
Inspections provide a direct means to trigger and enforce the specified
environmental protection and pollution control measures. They shall be
undertaken routinely and results catalogued in a site diary to facilitate
inspection of 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.
The ET Leader 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.
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 situations outside the site,
which are 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:
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 proposals on
associated pollution control
measures);
d)
the contract specifications on environmental
protection;
e)
the relevant environmental protection and
pollution control laws; and
f)
previous site inspection results.
The ET Leader shall request all information of
the construction contract from the Contractor required for him to carry out the
site inspections. The inspection results and associated recommendations on
improvements to the environmental protection and pollution control works shall
be submitted to the ER and the Contractor within 24 hours, for reference and for taking immediate
action.
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
There are contractual
environmental protection and pollution control requirements as well as
environmental protection and pollution control laws in Hong Kong, to which the
construction activities shall comply with.
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.
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 the laws can be
prevented.
The ET shall regularly request copies of relevant
documents from the Contractor so that the checking work can be carried out. The
documents shall at least include the updated Work Progress Reports, the updated
Works Programme, the application letters for different licenses/permits under
the environmental protection laws, and all the valid licenses/permits. The site
diary shall also be available for the ET Leader’s inspection upon his request.
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 license/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.
Upon receipt of the advice, the ER shall follow
up to ensure that the Contractor hasd taken appropriate action in order
that the environmental protection and pollution control requirements are
fulfilled.
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 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;
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 the EPD,
submit interim report to the EPD on the status of the complaint investigation
and follow-up action within the time frame assigned by the 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 the complainant
(If the source of complaint is the EPD, the results should be reported within
the time frame assigned by the EPD); and
i)
record the complaint, investigation, the
subsequent actions and the results in the
monthly EM&A reports.
During the
complaint investigation work, the Contractor and ER shall co-operate with the ET
Leader 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.