FIGURES
Figure 10.1 Environmental Complaint Procedure Flow Chart
APPENDICES
Appendix A Implementation Schedule for Environmental Mitigation Measures
Appendix B Site inspection Proforma
Appendix C Example of Complaint Log
10.1.1.1
Site
inspection 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.
10.1.1.2
The
ET is responsible for the formulation of an environmental site inspection,
deficiency and remedial action reporting system and for carrying out the site
inspection works. In consultation
with the Independent Environmental Checker (IEC), the ET shall prepare a
procedure for the site inspection, deficiency and remedial action reporting
requirements and submit this to the Contractor for agreement and to the
EngineerĄŠs Representative (ER) for approval within 21 days of commencement to
the construction contract.
10.1.1.3
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. The implementation schedule of mitigation
measures is summarised in Appendix A. It shall 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:
ĄP
The EIA recommendations on environmental
protection and pollution control mitigation measures with regard to air
quality, noise, waste management;
ĄP
On-going results of the EM&A
programme;
ĄP
Works progress and programme;
ĄP
Individual works methodology proposals
(which shall include proposals on associated pollution control measures);
ĄP
The contract specifications on
environmental protection and pollution prevention;
ĄP
The relevant environmental protection and
pollution control laws, ProPECC Notes; and
ĄP
Previous site inspection results.
10.1.1.4
The
Contractor shall update with the ET on all relevant information of the contract
for him to carry out the site inspections. The site inspection results and
associated recommendations on improvements to the environmental protection and
pollution control works shall be submitted, in a site inspection proforma (see Appendix B), by the ET to the IEC, the ER and the Contractor
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.
10.1.1.5
The
ER, ET, IEC and Contractor shall conduct ad hoc site inspections if significant
environmental problems are identified. The IEC shall also conduct random site
audits and inspections. Inspections
may also be required subsequent to receipt of any environmental complaints (an example of the complaint log is
provided in Appendix
C), or as part of the investigation work, for
environmental monitoring and audit.
10.1.1.6
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.
10.2.1.1
Complaints shall be referred to the ET Leader
for carrying out complaint investigation procedures. The ET Leader shall prepare a flow chart
of the complaint response procedures that addresses, complaint receiving channels,
responsible parties/contacts for information, the investigation process,
procedures for the implementation of mitigation/remedial action, 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.
10.2.1.2
The ET Leader shall undertake the following
procedures upon receipt of a complaint:
ĄP
Log the complaints and dates of receipt
onto the complaint database to be kept by the Contractor and inform the Engineer,
ER and IEC immediately;
ĄP
Investigate with the Engineer/ ER and
Contractor the complaints to determine their validity, and assess whether the
source of the problems is due to the construction works activities;
ĄP
Identify the mitigation measures if the
complaints are valid and due to the construction works of the project;
ĄP
Advise the Contractor if mitigation
measures are required;
ĄP
Review the ContractorĄŠs responses to the
identified mitigation measures, and the updated situation;
ĄP
Undertake additional audit in order to
verify the situation if necessary, and review that the circumstances leading to
the complaints would not recur;
ĄP
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
ĄP
Record the complaints, investigations,
subsequent action and findings in the monthly EM&A reports.
10.2.1.3
A
flow chart of the complaint response procedures during construction phase is shown
in Figure
10.1.
10.3.1.1
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 monthly EM&A
reports prepared by the ET and verified by IEC prior to circulation to the
Contractor, ER and submitted to EPD.