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In addition, public works and
housing project specifications have been revised to facilitate
use of recycled materials as hardcore in foundations, sub-base
in road pavement and concrete in technically less demanding
works (ETWB has identified some 100 projects).
Whilst these requirements so far affect mainly
public sector projects, it is widely anticipated that they
will in time begin to feature in private sector projects
(examples are already evident, described further below), and
will eventually filter down to SME sub-contractors and
sub-sub-contractors. Although there is no recommendation to
mandate ISO14001 in the construction sector, the CIRC report
(para 8.50) encourages its voluntary adoption, with mandatory
certification "preferably considered at a later stage when the
construction industry has acquired more expertise in tackling
the environmental challenge".
ENVIRONMENTAL LEGISLATION AND
REGULATIONS
The key supply chain pressure facing all
construction related companies is compliance with legislative
and regulatory requirements. Construction companies in
particular have financial reasons for avoiding environmental
convictions since these are considered when tendering for
government contracts. Environmental legislation in Hong Kong
consists of:
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Environmental ordinances and
regulations - the Air Pollution Control Ordinance
(APCO), Ozone Layer Protection Ordinance (OLPO), Noise
Control Ordinance (NCO), Water Pollution Control
Ordinance (WPCO), Waste Disposal Ordinance (WDO),
Environmental Impact Assessment Ordinance (EIAO);
and
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Environmentally-related ordinances and
regulations - the Factories and Industrial Undertakings
Ordinance, Occupational Safety and Health Ordinance,
Dangerous Goods Ordinance, Antiquities and Monuments
Ordinance, Public Health and Municipal Services
Ordinance, and others. |
New legislation and amendments are regularly
introduced. On 2nd July 2004, the Legislative Council passed a
Bill to implement a construction waste disposal charging
scheme that will provide further supply chain pressure for
environmental protection.
In addition to statutory requirements,
construction companies also face various Codes of Practice,
Technical Memoranda, Guidance Notes, Practice Notes for
Professional Persons, Practice Notes for Authorized Persons
and Registered Structural Engineers and Technical Circulars
that address environmental matters related to construction
sites.
Clearly for any company to be assured of
compliance with relevant legislation and codes, a systematic
process is required to identify, understand and keep up to
date with the many requirements in place. This is a
fundamental element and benefit of the ISO14001
EMS.
GOVERNMENT TECHNICAL
CIRCULARS
ETWB Technical Circulars (TCs) are the key
means of implementing policies and procedures relating to
construction sites. Some 46 current TCs (issued from 1988 to
date) include explicit requirements for environmental
protection. New TCs since 2002, in addition to specifying the
management of environmental impacts (e.g. ecological
protection, waste minimisation, etc), are increasingly
exerting a strong influence on the behaviour of contractors in
several areas, particularly by:
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Including environmental criteria in the
Management of Sub-contractors by Contractors (TC
47/2002);
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Evaluating environmental performance in
the Contractors' Performance Index System (TC
24/2002);
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Integrating environmental factors
within Tender Evaluation for Works Contracts (TC
08/2004); and
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Introducing management systems and
staged payments for waste management (TCs 14/2003 and
15/2003). |
TC 14/2003 (Role of Departmental Safety and
Environmental Advisor on HSE Protection on Construction Sites)
gives an insight into future developments, stating in Section
1 that:
"The objective to revise and extend the duties
of Departmental Safety Advisor is to enhance the communication
and management on environmental performance of contractors on
construction sites so that the established framework for the
safety management system and the Pay for Safety Scheme can be
extended for applying to environmental protection."
Such requirements, although non-statutory,
create strong drivers to the second and third tier players of
the supply chain to move towards improved environmental
management.
CLIENT REQUIREMENTS -
PUBLIC WORKS AND RELATED DEPARTMENTS
Environmental supply chain requirements of
public works and related departments include:
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Adoption of environmental management
practices on site to minimize adverse impacts caused by
the construction activities, including trip ticket
systems, waste management plans, pay for site
cleanliness, environmental monitoring and independent
environmental checking;
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Encouragement in contract documents and
specifications to use less environmentally damaging
building materials and construction technologies new to
Hong Kong such as prefabrication, left-in formworks and
slip form construction;
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Requirements for satisfactory
contractor environmental performance in terms of
compliance and mitigation of noise, water, air and waste
problems both in the past (for tender evaluation) and
during current projects. |
Contracts for public buildings also
increasingly include requirements for environmental
assessments using the Hong Kong Building Environmental
Assessment Method (HK-BEAM)2 . Only the EPD at present requires
the implementation of an ISO14001 EMS for the design, build
and operation of waste management facilities since 2000
(environmental monitoring is also specified, with a portion of
the contract sum allotted for compliance with environmental
requirements).
[2]
HK-BEAM has to date been adopted by 95 major
developments, approximately 30% of which have been
commissioned by public sector clients.
CLIENT REQUIREMENTS - PRIVATE
DEVELOPERS AND UTILITY COMPANIES
Environmental requirements of private
developers and utility companies include:
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Environmental requirements in tender
specifications, in most cases focusing on compliance
with regulatory requirements;
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Design and construction guidelines
requiring or encouraging best environmental practices
such as the use of more environmentally-friendly
materials and the recycling of reusable waste materials;
and
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More stringent requirements, such as
the adoption of an Environmental Management Plan and
Environmental Monitoring and Auditing are also required
for projects designated under the Environmental Impact
Assessment Ordinance. |
More recently, requirements for Waste
Management Plans, Environmental Management Plans, and
employment of an independent environmental checker have been
introduced in isolated and individual private sector projects.
Private developers have also been keen to explore construction
technologies new to Hong Kong such as prefabrication, left-in
formworks and slip form construction. A large number of
private developers also require their construction projects to
be assessed against and certified under HK-BEAM.
CLIENT REQUIREMENTS - MAIN
CONTRACTORS
Many of Hong Kong's leading main contractors
have already obtained certification to ISO14001, and more
continue to do so. Unlike other industries in which global
partners and customers have demanded ISO14001 certification,
its adoption in the construction industry has arisen on a
purely voluntary basis.
Under a typical mode of operation in
construction sector: Client/Designer - Main Contractors - Main
contactors - Sub-contractors (service providers/materials
suppliers), the main contractors play an important role in
communicating the environmental requirements from the clients
to their sub-contractors. Main contractors generally issue
environmental guidelines to their sub-contractors that specify
compliance with statutory and client requirements. Most main
contractors appear to take full control of the construction
project and site operation, with sub-contractors found to play
minor roles in environmental protection (such as participation
in training and education programmes), as they may simply
supply labour and equipment to the main contractors without
direct involvement in environmental management in construction
projects.
As such the environmental requirements of
clients are to a large degree absorbed by the main contractors
and seldom reach the second or third tier players of the
supply chain. Little significant or direct pressure appears to
be directed to sub-contractors or sub-sub contractors other
than requirements arising from the main contractors' adoption
of an EMS, whether or not this is certified to ISO14001.
However there is a strong desire from main contractors for
sub-contractors to improve their environmental performance and
ensure the necessary standards on site.
SOURCES OF ENVIRONMENTAL
SUPPORT
The environmental supply chain requirements of
local client organisations can be broadly categorised into
five main areas:
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