11.1
Site inspection provides a direct
means to trigger and enforce specified environmental protection and pollution
control measures. These shall be undertaken regularly and 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.
11.2
The ET Leader shall be responsible
for formulating the environmental site inspection, the deficiency and remedial action
reporting system, and for carrying out the site inspection works.
The proposal for rectification would be made known to the IEC.
11.3
Regular site inspections shall be carried
out at least once per week. The areas of inspection shall not be limited to the
environmental situation and the 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;
§
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 and pollution prevention control;
§
Relevant environmental protection
and pollution control laws;
§
Previous site inspection results
undertaken by the ET and others.
11.4
The Contractor shall keep the ET Leader updated with all
relevant information on the construction contract necessary for him/her 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 remedial action. The Contractor
shall follow the procedures and time-frame stipulated in the environmental site
inspection, and the deficiency and remedial action reporting system formulated
by the ET Leader, to report on any remedial measures subsequent to the site
inspections.
11.5
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 Event and Action Plan for
environmental monitoring and audit.
11.6
There are contractual environmental protection and pollution
control requirements as well as environmental protection and pollution control
laws in
11.7
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.
11.8
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.
11.9
The Contractor shall regularly copy relevant documents to
the ET Leader so that works checking could be carried out effectively.
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/her request.
11.10
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/she shall also
advise the Contractor accordingly.
11.11
Upon receipt of the advice, the Contractor shall undertake
immediate action to remedy the situation. The ER shall follow up to
ensure that appropriate action has been taken in order to satisfy contractual and
legal requirements
11.12
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 ER and
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. Undertake
additional monitoring and audit to verify the situation if necessary, and
review that circumstances leading to the complaint do not recur;
vii. If
the complaint is transferred from EPD, submit interim report to EPD on status
of the complaint investigation and follow-up action within the time frame
assigned by EPD;
viii. Record
the complaint, investigation, the subsequent actions and the results in the
monthly EM&A reports.
11.13
A flow chart of the complaint response procedures is shown
in Figure 11.1.