Site inspections provide a direct means to
track and ensure the enforcement of specified environmental protection and
pollution control measures. The
inspections should be undertaken by the ET to ensure that appropriate
environmental protection and pollution control mitigation measures are properly
implemented. Additionally, the ET should
be responsible for defining the scope of the inspections, detailing any
deficiencies that are identified, and reporting any necessary action or
mitigation measures that are implemented as a result of the inspection.
Site inspections should be carried out at
least once per week. The areas of
inspection should not limited to the general environmental conditions in the
vicinity of the site and the pollution control and mitigation measures within
the site; the environmental conditions outside the site area which are likely
to be affected, directly or indirectly, by site activities. The ET Leader should make reference to
the following information in conducting the inspections:
·
the EIA
Study and EM&A recommendations on environmental protection and pollution
control mitigation measures;
·
ongoing
results of the EM&A programme;
·
works
progress and programme;
·
individual
works method statements which should include proposals on associated pollution
control measures;
·
contract
specifications on environmental protection;
·
relevant
environmental legislation and guidelines; and
·
previous site inspection results undertaken.
The inspection results and their
associated recommendations on improvements to the environmental protection and
pollution control works should be submitted to the IEC and the Contractor, as
appropriate, within one working day, for reference and for taking immediate
action. They should also be
presented, along with the remedial actions taken, in the monthly EM&A
report. The Contractor should
follow the procedures and time-frames stipulated in the environmental site
inspection for the implementation of mitigation proposal. An action reporting system should be
formulated and implemented to report on any remedial measures implemented
subsequent to the site inspections.
The ET should 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
associated investigation work, as specified in the Action Plan for
environmental monitoring and audit.
8.2
Compliance with Legal
and Contractual Requirements
There are contractual environmental
protection and pollution control requirements, which the Contractor should
comply with, in addition to
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 should sent to the ET Leader for vetting to
see whether sufficient environmental protection and pollution control measures
have been included.
The ET should review all the progress and
programme of the works to check that relevant environmental laws have not been
violated, and that any foreseeable potential for violating the laws can be
prevented.
The Contractor should also make available
for inspection relevant documents to the ET so that the checking and auditing
process can be carried out. The relevant documents are expected to include the
updated work progress reports, the updated works programme, the application
letters for different licences/permits under the environmental protection laws,
all valid licences/permits and environmental related records. The site diary should also be available,
upon request, to the ET during his site inspection.
After reviewing the documentation, the ET Leader
should advise the IEC and the Contractor of any non-compliance with the
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 is incompatible with the
works programme or may result in a potential violation of environmental
protection and pollution control requirements by the works in due course, he should
also advise the Contractor and the ER accordingly.
Upon receipt of the advice, the Contractor
should undertake immediate action to remedy the situation. The ER should follow up to ensure that
appropriate action has been taken by the Contractor in order to satisfy
contractual and legal requirements.