8.1
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.
8.2
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 IEC.
8.3
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.
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.
8.4
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 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.
8.5
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.
8.6
There
are contractual environmental protection and pollution control requirements as
well as environmental protection and pollution control laws in
8.7
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.
8.8
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.
8.9
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.
8.10
After
reviewing the documentation, the ET Leader shall advise the IEC 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.
8.11
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.
8.12
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 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.
8.13
A flowchart indicating the
complaint handling procedures is presented in Figure 8.1.