9 Site
Environmental Audit
9.1 Site
Surveillance
9.1.1.1
Site
surveillance provides a direct means to trigger and enforce the specified environmental
protection and pollution control measures are in compliance with the contract
specifications. They shall be undertaken
regularly and routinely by ET to inspect the activities at the works site in
order to ensure that appropriate environmental protection and pollution control
mitigation measures are properly implemented by the Contractor in accordance
with the EM&A recommendations.
With well-defined pollution control and mitigation specifications and
a well-established site inspection, deficiency and action reporting system,
the site inspection is one of the most effective tools to enforce the environmental
protection requirements on the site.
9.1.1.2
The ET
Leader is responsible for formulation of the environmental site inspection,
deficiency and action reporting system, and for carrying out the site inspections
under the EM&A works. He shall
prepare and submit a proposal on the site inspection, deficiency and action
reporting procedures within 21 days of the construction contract commencement
to the Contractor for agreement and to the ER and IEC for approval.
9.1.1.3
The ET
shall conduct a site inspection at least once per week during the construction
period of the Project. The areas
of inspection shall include, but are not be limited to, the environmental situation,
and pollution control and mitigation measures within the site.
It should also review the environmental situation outside the site area
that 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:
l The EIA recommendations on environmental protection
and pollution control mitigation measures with regard to air quality, noise,
waste management;
l On-going results of the EM&A programme;
l Works progress and programme;
l Individual works methodology proposals (which
shall include proposals on associated pollution control measures);
l The contract specifications on environmental
protection and pollution prevention;
l The relevant environmental protection and pollution
control laws, ProPECC Notes; and
l Previous site inspection results.
9.1.1.4
The Contractor
shall update with the ET on all relevant information of the contract for him
to carry out the site inspections.
The inspection results and its associated recommendations on improvements
to the environmental protection and pollution control works shall be submitted
to the IEC and the Contractor in a site inspection proforma 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, deficiency and action reporting system
formulated by the ET to report on any remedial measures subsequent to the site
inspections.
9.1.1.5
The ER,
ET and Contractor shall conduct ad hoc site inspections if significant environmental
problems are identified. The IEC
shall also conduct independent site audits.
Inspections may also be required subsequent to receipt of any environmental
complaints, or as part of the investigation work, for environmental monitoring
and audit.
9.2 Compliance with Legal & Contractual Requirements
9.2.1.1
There
are contractual environmental protection and pollution control requirements
as well as environmental protection and pollution control laws in Hong Kong,
with which the activities associated with the construction of the helipad shall
comply.
9.2.1.2
To ensure
the works comply with the contractual requirements, all method statements of
major works should be submitted by the Contractor to the ER for approval and
to the ET for vetting so as to ensure whether sufficient environmental protection
and pollution control measures have been incorporated.
9.2.1.3
The ER
and ET shall 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 the laws can be prevented.
9.2.1.4
The Contractor
shall regularly copy relevant documents to the ER and ET so that the checking
work can be carried out. The documents
shall at least include the updated Work Progress Reports, the updated Works
Programme, application letters for different license/permits under the environmental
protection laws, and all valid licence(s)/permit(s).
The site diary shall also be available for the ET’s inspection upon his
request.
9.2.1.5
After
reviewing the document, the ET Leader shall advise the ER 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 may not cope with the works programme or may result in potential violation
of environmental protection and pollution control requirements by the works
in due course, he shall also advise the Contractor and the ER accordingly.
The review shall be copied to IEC for any follow-up action.
9.2.1.6
Upon
receipt of the advice, the Contractor shall undertake immediate action to remedy
the situation. The ER shall check
that the Contractor has taken appropriate action in order that the environmental
protection and pollution control requirements are fulfilled.
9.3 Environmental
Complaints
9.3.1.1
Complaints
reviewed on environmental issues shall be referred to the ET Leader for carrying
out complaint investigation procedures.
The ET shall prepare a flow chart of the complaint response procedures
addressing complaint receiving channels, responsible parties/ contracts for
information, the investigation process, procedures for implementation of remedial
actions, guidelines for communication and public relation with the complainant
etc. The flow chart shall be agreed
by all parties and issued to the Contractor, ER and IEC for reference.
9.3.1.2
Upon
receipt of complaints the ET shall undertake the tasks outlined below.
l Log complaint and date of receipt onto the complaint
database and information the IEC immediately;
l Investigate the complaint to determine its validity,
and to assess whether the source of the problem is due to works activities;
l If a complaint is valid and due to works, identify
mitigation measures in consultations with the IEC;
l If mitigation measures are required, advise the
Contractor accordingly;
l Review the Contractor’s implementation of the
identified mitigation measures, and the concurrent situation;
l If the complaint is transferred from EPD, submit
interim report to EPD on status of the complaint investigation an follow-up
action within the time frame assigned by EPD;
l Undertake additional monitoring and audit to
verify the complaint if necessary, and ensure that any valid reason for complaint
does not recur through proposed amendments to work methods, procedures, machines
and/or equipment, etc;
l Report the investigation results and the subsequent
actions to the source of complaint. (If the source of complaint is identified
through EPD, the results should be reported within the time frame assigned by
EPD); and
l Complete the log of the complaint, investigation,
actions and outcome in the monthly EM&A report(s).
9.3.1.3
During
the complaint investigation work, the Contractor and ER shall co-operate with
the ET Leader in providing all the necessary information and assistant for completion
of the investigation. If mitigation
measure are identified to be required in the investigation in consultation with
the IEC, the Contractor shall promptly carry out measures.
The ER shall ensure that the Contractor has implemented the mitigation
measures.
9.4 Documentation
9.4.1.1
All documentation
is required to be filed in a traceable and systematic manner and ready for inspection
upon request. All EM&A results
and findings shall be documented in the EM&A report prepared by the ET and
endorsed by IEC prior to circulation to the Contractor, ER and EPD.