9 SITE ENVIRONMENTAL AUDIT.. 2
9.1 Site Inspection. 2
9.2 Compliance with Legal and
Contractual Requirements. 3
9.3 Environmental Complaints. 3
9.1.1
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.
9.1.2
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. Within 21 days of
the construction contract commencement, 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).
9.1.3
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
Leader shall make reference to the following information in conducting the
inspection:
(i) EIA
recommendations on environmental protection and pollution control mitigation
measures;
(ii) works
progress and programme;
(iii) individual
works methodology proposals (which shall include proposal on associated
pollution control measures);
(iv) contract
specifications on environmental protection;
(v) relevant
environmental protection and pollution control laws; and
(vi) previous
site inspection results.
9.1.4
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. 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.
9.1.5
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.
9.2.1
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.
9.2.2
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 summarised in Appendix A.
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 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.
9.2.5
After
reviewing the document, 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.
9.2.6
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.
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 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.