6.1
Site inspection
provides a direct means to initiate and enforce specified environmental
protection and pollution control measures. These should 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.
6.2
The ET Leader should
be responsible for formulating the environmental site inspection, the
deficiency and action reporting system, and for carrying out the site
inspection works. Within 21 days of
the construction contract commencement, he should 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.
6.3
Regular site
inspections should be carried out at least once per week. The areas of inspection should 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 should make reference to the following information in conducting the
inspection:
(i) EIA
recommendations on environmental protection and pollution control mitigation
measures;
(ii) works
progress and programme;
(iii) individual works methodology proposals (which should include
proposal on associated pollution control measures);
(iv) contract specifications on environmental protection;
(v) relevant environmental protection and pollution control
laws; and
(vi) previous site inspection results.
6.4
The Contractor should
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 should be submitted to the IEC and the Contractor within 24
hours. The Contractor should 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.
6.5
Ad hoc site inspections
should also be carried out 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.
Compliance with
Legal and Contractual Requirements
6.6
There are contractual
environmental protection and pollution control requirements as well as
environmental protection and pollution control laws in
6.7
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 should 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.
6.8
The ET Leader should
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.
6.9
The Contractor should
regularly copy relevant documents to the ET Leader so that works checking can
be carried out. The document should
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 should also be available
for the ET Leader's inspection upon his request.
6.10
After reviewing the
document, the ET Leader should 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 should
also advise the Contractor and the ER accordingly.
6.11
Upon receipt of the
advice, the Contractor should undertake immediate action to correct the
situation. The ER should follow up
to ensure that appropriate action has been taken in order to satisfy
contractual and legal requirements.
6.12
Complaints should be
referred to the ET Leader for action.
The ET Leader should 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.