10.              SITE ENVIRONMENT AUDIT

 

 10.1     Site Inspections 

 

Site inspections provide a direct means to assess and ensure the Contractor’s environmental protection and pollution control measures are in compliance with the contract specifications.  The site inspection will be undertaken routinely by the ET to ensure that appropriate environmental protection and pollution control mitigation measures are properly implemented in accordance with the EIA.  In addition, the ET will be responsible for defining the scope of the inspections, detailing any deficiencies that are identified, and reporting any necessary action or additional mitigation measures that were implemented as a result of the inspection. 

 

Regular site inspections will be carried out twice a month.  The areas of inspection will not be limited to the site area and should also include the environmental conditions outside the site which are likely to be affected, directly or indirectly, by the site activities.  The ET will make reference to the following information while conducting the inspections:

 

·           the EIA and EM&A recommendations on environmental protection and pollution control mitigation measures;

·           ongoing results of the EM&A programme;

·           work progress and programme;

·           individual works methodology proposals;

·           the contract specifications on environmental protection;

·           the relevant environmental protection and pollution control laws; and

·           previous site inspection results.

 

 A monthly waste management audit will be carried out as part of the site audit programme.

 

The Contractor(s) will update the ET with relevant information on the construction works prior to carrying out the site inspections.  The site inspection results will be submitted to the IEC, ER and the Contractor within 24 hours.  Should actions be necessary, the ET will follow up with recommendations on improvements to the environmental protection and pollution control works and will submit these recommendations in a timely manner to the IEC, ER and the Contractor.  They will also be presented, along with the remedial actions taken, in the monthly EM&A report. 

 

The Contractor will follow the procedures and time frame stipulated in the environmental site inspection for the implementation of mitigation proposal and the resolution of deficiencies in the Contractor’ EMS.  An action reporting system will be formulated and implemented to report on any remedial measures implemented subsequent to the site inspections. 

Ad hoc site inspections will also be carried out by the ET and IEC if significant environmental issues 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.

 

10.2              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 with which the construction activities will comply.

 

In order that the works are in compliance with the contractual requirements, the works method statements submitted by the Contractor to CEDD/ER for approval will be sent to the ET for review.

 

The ET will also review the progress and programme of the works to check the regulatory compliance.

 

The Contractor will regularly copy relevant documents to the ET so that the checking and auditing work can be carried out.  The relevant documents are expected to include at a minimum the updated Work Progress Reports, the updated Works Programme, the application letters for different licence/permits under the environmental protection laws and all valid licences/permits.  The site diary will also be available for the ET inspection upon request.

 

After reviewing the document, the ET will advise the IEC, ER and the Contractor of any non-compliance from the contractual and legislative requirements on environmental protection and pollution control for follow-up actions.  The ET will also advise the IEC, the Contractor and ER on the current status on licence/permit applications and any environmental protection and pollution control preparation works that may not be suitable for the works programme or may result in potential nonconformity of environmental protection and pollution control requirements.

 

Upon receipt of the advice, the Contractor will undertake immediate action to remedy the situation.  The ET, IEC and ER will follow up to ensure that appropriate action will be taken by the Contractor in order that the environmental protection and pollution control requirements are fulfilled.

 

10.3              Environmental Complaints

 

The complaints handling procedure will be as follows. The ET will undertake the following procedures upon receipt of a complaint:

 

(i)          log complaint and date of receipt into the complaint database and inform the IEC immediately;

(ii)         investigate the complaint and discuss with the Contractor and ER to determine its validity and to assess whether the source of the issue is due to works activities;

(iii)        if a complaint is considered valid due to the works , the ET will identify mitigation measures in consultation with the Contractor, ER and IEC;

(iv)        if mitigation measures are required, the ET will advise the Contractor accordingly;

(v)         review the Contractor's response on the identified mitigation measures and the updated situation;

(vi)        if the complaint is transferred from EPD, an interim report will be submitted to EPD on the 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 ensure that any valid reason for complaint does not recur;

(viii)      report the investigation results and the subsequent actions on the source of the 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

(ix)              record the complaint, investigation, the subsequent actions and the results in the monthly EM&A reports.

 

During the complaint investigation work, the ET, Contractor and ER will cooperate with the IEC in providing the necessary information and assistance for completion of the investigation.  If mitigation measures are identified in the investigation, the Contractor will promptly carry out the mitigation measures.  ER/CEDD will approve the proposed mitigation measures and the ET and IEC will check that the measures have been carried out by the Contractor.

 

10.4              Log Book

 

The ET Leader will keep a contemporaneous log-book of each and every instance or circumstance or change of circumstances which may affect the environmental impact assessment and every non-compliance from the recommendations of the EIA Reports or the Environmental Permit.  The ET Leader will notify the IEC within one working day of the occurrence of any such instance or circumstance or change of circumstance.  The ET Leader’s log-book will be kept readily available for inspection by persons assisting in supervision of the implementation of the EIA Reports recommendations (such as ER, IEC and Contractor) and the EPs or by EPD or his authorised officers.