10.1.1.1 Site inspections should be conducted regularly to ensure that appropriate environmental protection and pollution control mitigation measures are properly implemented for the construction works activities associated with the Trunk Road T2 Project, as they are one of the most effective tools to enforce the environmental protection requirements at the works sites and works areas.
10.1.1.2
Regular site inspections should
be carried out and led by the Engineer and attended by the Contractor and ET at
least once every week. The areas of
inspection should not be limited to the environmental conditions and pollution
control and mitigation measures within the works sites and works areas. Instead, it should also review the
environmental conditions of locations that are beyond the boundary of the works
sites and works areas likely to be affected directly or indirectly by the
construction site activities. During the
inspection, the following information should be referred to:
·
The
EIA and EM&A recommendations on the environmental protection and pollution
control mitigation measures;
·
Ongoing
results of the EM&A programme;
·
The
works progress and programme;
·
Proposals
of individual works methodologies (which should include the proposal of the
associated pollution control measures);
·
Contract
specifications on environmental protection and pollution prevention control;
·
The
relevant environmental protection and pollution control legislation; and
·
Previous
site inspection findings undertaken by the ET and/or others.
10.1.1.3 The Contractor should keep the Engineer and ET updated with all the relevant environmental related information on the construction contract to carry out the site inspections. The inspection findings and associated recommendations for improvements to the environmental protection and pollution control and outcome of the improvement should be recorded and followed up by the Contractor in an agreed time-frame.
10.1.1.4 The Engineer, ET and Contractor should also carry out ad hoc site inspections if significant environmental problems are identified. Inspections may also be required subsequent to the receipt of environmental complaints, or as part of the investigation work, as specified in the Event and Action Plans for the EM&A programme.
10.2 Compliance with Statutory and Contractual Requirements
10.2.1.1
There are contractual
requirements and legislation in
10.2.1.2
In
order to ensure the works are in compliance with the contractual requirements,
all method statements of major works should be submitted by the Contractor to
the Engineer for approval and to the ET for vetting so as to ensure whether
sufficient environmental protection and pollution control measures have been
incorporated. The Environmental
Mitigation Implementation Schedule is included in Appendix A.
10.2.1.3
The
Engineer and ET should also review the progress and programme of the
construction works in order to check that the relevant environmental
legislation has not been violated and that any foreseeable potential for
violating laws can be prevented.
10.2.1.4
The
Contractor should provide the update of the relevant documents to the Engineer
and ET, so that the checking can be carried out in good time. Such documents should at least include the
updated works progress reports, works programme, application letters for
environmental licenses / permits, and all valid licenses/permits. The Contractor’s site diary and environmental
records should also be available for inspection by the relevant parties.
10.2.1.5
The
Engineer and ET should advise the Contractor of any non-compliance with the
contractual and legislative requirements on the environmental protection and
pollution control so that they can timely take the follow-up action as
appropriate. If it would still be
insufficient to comply with the environmental protection and pollution control
requirements, The Engineer and ET should provide further advice to the
Contractor to take remedial action to resolve the problems.
10.2.1.6
Upon
the receipt of such advice, the Contractor should undertake the immediate
action to remedy the situation. The
Engineer should follow up to ensure that appropriate action has been taken in
order to satisfy the contractual and legal requirements.
10.3
Environmental Complaints
10.3.1.1
Complaints should be referred
to the ET for action, who should undertake the following procedures upon the
receipt of complaints:
·
To
log the complaints and dates of receipt onto the complaint database to be kept
by the Contractor and inform the Engineer, ET and IEC immediately;
·
To
investigate with the Engineer and Contractor the complaints to determine their
validity, and assess whether the source of the problems is due to the
construction works activities;
·
To
identify the mitigation measures if the complaints are valid and due to the
construction works;
·
To
advise the Contractor if mitigation measures are required;
·
To
review the Contractor’s responses to the identified mitigation measures, and
the updated situation;
·
To
undertake the additional monitoring and audit in order to verify the situation
if necessary, and review that the circumstances leading to the complaints would
not recur;
·
If
the complaint is referred by the EPD, to submit interim report to the EPD on
the status of the complaint investigations and follow-up action within the time
frame assigned by the EPD; and
·
To
record the complaints, investigations, subsequent action and findings in the
monthly EM&A reports.
10.3.1.2
During the complaint
investigation, the Contractor and Engineer should coordinate with the ET to
provide all the necessary information and assistance for the completion of the
investigation. If mitigation measures are
identified to be required, in consultation with the IEC, the Contractor should
promptly implement such measures and the Engineer should ensure that the
measures have been carried out properly.
A flow chart of the complaint response procedures is shown in Figure 10.1.