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. 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 shall 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.
the EIA and EM&A recommendations on
environmental protection and pollution control mitigation measures;
ii.
ongoing results of the EM&A programme;
iii.
works progress and programme;
iv.
individual works methodology proposals (which
shall include proposal on associated pollution control measures);
v.
contract specifications on environmental
protection;
vi.
relevant environmental protection and pollution
control laws; and
vii.
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 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.
9.1.5
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 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
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 shall also
advise the Contractor 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.
9.3.2
A flowchart indicating
the complaint handling procedures is presented in Figure 9.1. A sample of the complaint log sheet is
provided in Appendix E.