9.
SITE ENVIRONMENTAL AUDIT
9.1.1
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.
9.1.2
The
Contractor’s 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 endorsed by IEC 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.
9.1.3
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 Contractor’s 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 proposal 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.
9.1.4
The
Contractor shall update the Contractor’s ET leader 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 ER 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 Contractor’s ET leader to report on
any remedial measures subsequent to the site inspections.
9.1.5
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.
9.2
Compliance with Legal and
Contractual Requirements
9.2.1
There
are contractual environmental protection and pollution control requirements as
well as environmental protection and pollution control laws in
9.2.2
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 Contractor’s ET leader for vetting to see whether
sufficient environmental protection and pollution control measures have been
included.
9.2.3
The
Contractor’s 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.
9.2.4
The
Contractor shall regularly copy relevant documents to the Contractor’s 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 Contractor’s ET leader's inspection upon his request.
9.2.5
After
reviewing the document, the Contractor’s 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.
9.2.6
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.
24-hour Dedicated Hotline for Public
Complaints and Enquiries
9.3.1
The Contractor shall set up a
24-hour hotline dedicated to the Project to receive and respond to complaints
or enquiries from the public, the media and community groups throughout the
construction period of the Project. The Contractor shall display conspicuously
the telephone number of the 24-hour hotline on the construction site(s) at all
vehicular site entrances/exits or at a convenient location for public information
at all times.
9.3.2
Complaints
shall be referred to the Contractor’s ET leader for carrying out complaint
investigation procedures. The Contractor’s 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 IEC
immediately via the ER;
(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 EPD, submit interim report to EPD after
endorsement by IEC 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); and
(i)
record
the complaint, investigation, the subsequent actions and the results in the
monthly EM&A reports.
9.3.3
During
the complaint investigation work, the Contractor and ER shall cooperate with
the Contractor’s 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.
9.3.4
A
flow chart of the complaint response procedures is shown in Figure 9.1. A
sample complaint log form is shown in Appendix B.