7.                   SITE ENVIRONMENTAL AUDIT


Site Inspections


7.1        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.


7.2        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).


7.3        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.


7.4        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.


7.5        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.


Compliance with Legal and Contractual Requirements


7.6        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.


7.7        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 B.


7.8        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.


7.9        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.


7.10      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.


7.11      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.


Environmental Complaints


7.12      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.

7.13      A flow chart of the complaint response procedures is shown in Figure 7.1.