9
SITE ENVIRONMENTAL AUDIT
Site
Inspection
9.1
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.
9.2
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. 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).
9.3
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:
- The EIA and
EM&A recommendations on environmental protection and pollution control
mitigation measures;
- Ongoing
results of the EMA& programme;
- Works
progress and programme;
- Individual
works methodology proposals (which shall include proposal on associated
pollution control measures);
- Contract
specifications on environmental protection;
- Relevant
environmental protection and pollution control laws; and
- Previous
site inspection results undertaken by the ET and others.
9.4
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 for reference and for taking immediate action. 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.
9.5
The ET shall also carry out ad hoc site inspections 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.
Compliance
with Legal and Contractual Requirements
9.6
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.
9.7
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.
9.8
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.
9.9
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.
9.10
After reviewing the documentation, 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.
9.11
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.
Environmental
Complaints
9.12
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.