12.1
Site
Inspections
12.1.1
Site inspection provides a direct
means to trigger and enforce specified environmental protection and pollution
control measures. These shall be
undertaken regularly and 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.
12.1.2
The ET Leader shall be responsible for formulating the
environmental site inspection, the deficiency and remedial action reporting
system, and for carrying out the site inspection works. He shall submit a proposal for site
inspection and deficiency and remedial 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 IC(E).
12.1.3
Regular site inspections shall be
carried out at least once per week.
The areas of inspection shall 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 shall make reference to the
following information in conducting the inspection:
·
the EIA and EM&A recommendations
on environmental protection and pollution control mitigation measures;
·
ongoing results of the EM&A
program;
·
works progress and programme;
·
individual works methodology proposals
(which shall include proposal on associated pollution control measures);
·
contract specifications on
environmental protection and pollution prevention control;
·
relevant environmental protection and
pollution control laws;
·
previous site inspection results
undertaken by the ET and others.
12.1.4 The Contractor shall 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 shall be submitted to the IC(E) and the
Contractor within 24 hours for reference and for taking immediate remedial
action. The Contractor shall
follow the procedures and time-frame stipulated in the environmental site
inspection, and the deficiency and remedial action reporting system formulated
by the ET Leader, to report on any remedial measures subsequent to the site
inspections.
12.1.5
The ET shall also carry out ad hoc
site inspections 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.
12.2
Compliance with Legal and Contractual
Requirements
12.2.1
There are contractual environmental
protection and pollution control requirements as well as environmental
protection and pollution control laws in Hong Kong with which construction
activities must comply.
12.2.2
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. The implementation schedule of mitigation measures is
summarised in Appendix C.
12.2.3
The ET Leader shall 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.
12.2.4
The Contractor shall regularly copy
relevant documents to the ET Leader so that works checking could be carried out
effectively. The document shall 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 shall also be available
for the ET Leader's inspection upon his request.
12.2.5
After reviewing the documentation, the
ET Leader shall advise the 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 shall also advise the Contractor
accordingly.
12.2.6
Upon receipt of the advice, the
Contractor shall undertake immediate action to remedy the situation. The ER shall follow up to ensure that
appropriate action has been taken in order to satisfy contractual and legal
requirements.
12.3
Environmental
Complaints
12.3.1
Complaints shall be referred to the ET
Leader for action. The ET Leader
shall undertake the following procedures upon receipt of any complaint:
(i)
log complaint and date of receipt onto the complaint database and
inform the IC(E) 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 IC(E) 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 identified through EPD, the results should be
reported within the timeframe assigned by EPD);
(ix)
record the complaint, investigation, the subsequent actions and the
results in the monthly EM&A reports.
12.3.2
A flow chart of the complaint response
procedures is shown in Figure 12.1.