9.1.1
Site
inspection provides a direct means to trigger and enforce specified
environmental protection and pollution control measures. These shall be undertaken regularly and
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.
9.1.2
The
ET Leader shall be responsible for formulating the environmental site
inspection, the deficiency and remedial action reporting system, and for
carrying out the site inspection works.
The ET Leader shall submit a proposal for site inspection and deficiency
and remedial 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 IEC.
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 works 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:
·
the EIA and EM&A recommendations
on environmental protection and pollution control mitigation measures;
·
ongoing results of the EM&A
program;
·
works progress and programme;
·
individual works methodology
proposals (which shall include proposal on associated pollution control
measures);
·
contract specifications on environmental
protection and pollution prevention control;
·
relevant environmental protection
and pollution control laws;
·
previous site inspection results
undertaken by the ET and others.
9.1.4
The
Contractor shall keep the ET Leader updated with all relevant information on
the construction contract necessary for him/her 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 IEC and the Contractor within
24 hours for reference and for taking immediate remedial action. The Contractor shall follow the
procedures and time-frame stipulated in the environmental site inspection, and
the deficiency and remedial action reporting system formulated by the ET
Leader, to report on any remedial measures subsequent to the site inspections.
9.1.5
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 Event and 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
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 summarized in Appendix C.
9.2.3
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.
9.2.4
The
Contractor shall regularly copy relevant documents to the ET Leader so that
works checking could be carried out effectively. 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/her request.
9.2.5
After
reviewing the documentation, the ET Leader shall advise the 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/she shall also advise the Contractor 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 in order to satisfy
contractual and legal requirements.
9.3.1
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 IEC 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 IEC 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 EPD, submit
interim report to EPD on status of the complaint investigation and follow-up
action within the time frame assigned by 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 identified through EPD,
the results should be reported within the timeframe assigned by EPD);
(ix)
record the complaint, investigation, the
subsequent actions and the results in the monthly EM&A reports.
9.3.2
A
flow chart of the complaint response procedures is shown in Figure 9.1.