6. environmental auditing
6.1 Site Inspections
6.2 Compliance with Legal
and Contractual Requirements
6.3 Environmental Complaints
List of Figures
Figure 6.1 Environmental
Complaint Flow Diagram
Appendices
Appendix A Implementation
Schedule of Proposed Mitigation Measures
6.1.1.1
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 (including
mitigation measures listed in the implementation schedule presented in Appendix A) are properly
implemented. The site inspection is one
of the most effective tools to enforce the environmental protection
requirements at the works area.
6.1.1.2
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 IEC for agreement, and to the SOR for approval. The ET’s proposal for rectification would be
made known to the IEC.
6.1.1.3
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
·
The Environmental Permit
conditions
·
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
·
relevant environmental
protection and pollution control laws
·
previous site inspection
results undertaken by the ET and others
6.1.1.4
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 IEC and the Contractor within
24 hours for reference and for taking immediate action. The Contractor shall follow the procedures
and time-frame 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.
6.1.1.5
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.
6.2.1.1
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.
6.2.1.2
In
order that the works are in compliance with the contractual requirements,
relevant sections (e.g. sections related to environmental measures) of works
method statements submitted by the Contractor to the SOR for approval shall be
sent to the ET Leader for vetting to see whether sufficient environmental
protection and pollution control measures have been included.
6.2.1.3
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.
6.2.1.4
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.
6.2.1.5
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.
6.2.1.6
Upon
receipt of the advice, the Contractor shall undertake immediate action to
correct the situation. The SOR shall
follow up to ensure that appropriate action has been taken in order to satisfy
contractual and legal requirements.
6.3.1.1
Handling of environmental
complaints should follow the environmental complaint flow diagram and reporting
channel as presented in Figure 6.1.
6.3.1.2
During the complaint
investigation work, the Contractor and SOR shall cooperate with the ET in
providing all 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 works. The SOR shall ensure that the
measures have been carried out by the Contractor.