SITE ENVIRONMENTAL AUDIT & ENVIRONMENTAL
Site inspection provides
a direct means to initiate and enforce specified environmental protection and
pollution control measures. These should be undertaken 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.
The ET Leader should be
responsible for formulating the environmental site inspection, the deficiency
and action reporting system, and for carrying out the site inspection
works. He / she should submit a proposal for site inspection and
deficiency and action reporting procedures to the Contractor for agreement, and
to the SOR for approval. The ET’s proposal for rectification would be
made known to the IEC.
inspections should be carried out at least once per week. The areas of
inspection should not be limited to the environmental situation, pollution
control and mitigation measures within the site, the site inspections 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
Leader should make reference to the following information in conducting the
The EIA and EM&A
recommendations on environmental protection and pollution control mitigation
measures (including dust control measures and good site practice measures for
Ongoing results of the
Work progress and
Individual work methodology proposals (which
shall include proposal on associated pollution control measures);
on environmental protection;
Relevant environmental protection and
pollution control laws; and
inspection results undertaken by the ET and others.
The Contractor should
keep the ET Leader updated with all relevant information on the construction
contract necessary for him / her to carry out the site inspections.
Inspection results and associated recommendations for improvements to the
environmental protection and pollution control works should be submitted to the
IEC and the Contractor within 24 hours for reference and for taking immediate
action. The Contractor should follow the procedures and time-frame as
stipulated in the deficiency and action reporting system formulated by the ET
Leader to report on any remedial measures subsequent to the site inspections.
The ET should also
carry out ad hoc site inspections if significant environmental problems are
identified. Inspections may also be required subsequent to receipt of
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
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.
In order to ensure that
the works are undertaken in compliance with the contractual requirements on
environmental aspects, all works method statements submitted by the Contractor
to the SOR for approval should 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 9.1.
The ET Leader should
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 could be prevented.
The Contractor should
regularly copy relevant documents to the ET Leader so that works checking could
be carried out. The document should 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 should also be available
for the ET Leader's inspection upon his / her request.
After reviewing the
documentation, the ET Leader should advise the IEC and 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 / she should also advise the Contractor and
the SOR accordingly.
Upon receipt of the
advice, the Contractor should undertake immediate action to correct the
situation. The SOR should follow up to ensure that appropriate action has
been taken to satisfy contractual and legal requirements.
Complaints should be
referred to the ET Leader for action. The ET Leader should undertake the
following procedures upon receipt of any complaint:
log complaint and date
of receipt onto the complaint database and inform the IEC immediately;
investigate the complaint to determine its
validity, and assess whether the source of the problem is due to works
measures in consultation with the IEC if a complaint is valid and due to works;
advise the Contractor if mitigation
measures are required;
review the Contractor's response on the
identified mitigation measure(s) and the updated situation;
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;
monitoring and audit to verify the situation if necessary, and review that
circumstances leading to the complaint do not recur;
report investigation results and
subsequent actions to complainant (if the source of complaint is EPD, the
results should be reported within the timeframe assigned by the EPD); and
record the complaint, investigation, the
subsequent actions and the results in the monthly EM&A reports.
A flowchart indicating
the complaint handling procedures is presented in Figure