9        Site Environmental Audit

 9.1             Site Surveillance

 9.1.1.1                   Site surveillance 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.

 9.1.1.2                   The ET Leader is responsible for formulation of the environmental site inspection, deficiency and action reporting system, and for carrying out the site inspections under the EM&A works.  He shall prepare and submit a proposal on the site inspection, deficiency and action reporting procedures within 21 days of the construction contract commencement to the Contractor for agreement and to the ER and IEC for approval.

 9.1.1.3                   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.  It should 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:

 l   The EIA recommendations on environmental protection and pollution control mitigation measures with regard to air quality, noise, waste management;

 l   On-going results of the EM&A programme;

 l   Works progress and programme;

 l   Individual works methodology proposals (which shall include proposals on associated pollution control measures);

 l   The contract specifications on environmental protection and pollution prevention;

 l   The relevant environmental protection and pollution control laws, ProPECC Notes; and

 l   Previous site inspection results.

 9.1.1.4                   The Contractor shall update with the ET on all relevant information of the contract for him to carry out the site inspections.  The inspection results and its associated recommendations on improvements to the environmental protection and pollution control works shall be submitted to the IEC and the Contractor in a site inspection proforma 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.

 9.1.1.5                   The ER, ET and Contractor shall conduct ad hoc site inspections if significant environmental problems are identified.  The IEC shall also conduct independent site audits.  Inspections may also be required subsequent to receipt of any environmental complaints, or as part of the investigation work, for environmental monitoring and audit.

 9.2             Compliance with Legal & Contractual Requirements

 9.2.1.1                   There are contractual environmental protection and pollution control requirements as well as environmental protection and pollution control laws in Hong Kong, with which the activities associated with the construction of the helipad shall comply.

 9.2.1.2                   To ensure the works comply with the contractual requirements, all method statements of major works should be submitted by the Contractor to the ER for approval and to the ET for vetting so as to ensure whether sufficient environmental protection and pollution control measures have been incorporated. 

 9.2.1.3                   The ER and ET shall 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 the laws can be prevented.

 9.2.1.4                   The Contractor shall regularly copy relevant documents to the ER and ET so that the checking work can be carried out.  The documents shall at least include the updated Work Progress Reports, the updated Works Programme, application letters for different license/permits under the environmental protection laws, and all valid licence(s)/permit(s).  The site diary shall also be available for the ET’s inspection upon his request.

 9.2.1.5                   After reviewing the document, the ET Leader shall advise the ER and the Contractor of any non-compliance with the 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 not cope with the works programme or may result in potential violation of environmental protection and pollution control requirements by the works in due course, he shall also advise the Contractor and the ER accordingly.  The review shall be copied to IEC for any follow-up action.

 9.2.1.6                   Upon receipt of the advice, the Contractor shall undertake immediate action to remedy the situation.  The ER shall check that the Contractor has taken appropriate action in order that the environmental protection and pollution control requirements are fulfilled.

 9.3             Environmental Complaints

 9.3.1.1                   Complaints reviewed on environmental issues shall be referred to the ET Leader for carrying out complaint investigation procedures.  The ET shall prepare a flow chart of the complaint response procedures addressing complaint receiving channels, responsible parties/ contracts for information, the investigation process, procedures for implementation of remedial actions, 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.

 9.3.1.2                   Upon receipt of complaints the ET shall undertake the tasks outlined below.

 l   Log complaint and date of receipt onto the complaint database and information the IEC immediately;

 l   Investigate the complaint to determine its validity, and to assess whether the source of the problem is due to works activities;

 l   If a complaint is valid and due to works, identify mitigation measures in consultations with the IEC;

 l   If mitigation measures are required, advise the Contractor accordingly;

 l   Review the Contractor’s implementation of the identified mitigation measures, and the concurrent situation;

 l   If the complaint is transferred from EPD, submit interim report to EPD on status of the complaint investigation an follow-up action within the time frame assigned by EPD;

 l   Undertake additional monitoring and audit to verify the complaint if necessary, and ensure that any valid reason for complaint does not recur through proposed amendments to work methods, procedures, machines and/or equipment, etc;

 l   Report the investigation results and the subsequent actions to the source of complaint. (If the source of complaint is identified through EPD, the results should be reported within the time frame assigned by EPD); and

 l   Complete the log of the complaint, investigation, actions and outcome in the monthly EM&A report(s).

 9.3.1.3                   During the complaint investigation work, the Contractor and ER shall co-operate with the ET Leader in providing all the necessary information and assistant for completion of the investigation.  If mitigation measure are identified to be required in the investigation in consultation with the IEC, the Contractor shall promptly carry out measures.  The ER shall ensure that the Contractor has implemented the mitigation measures.

 9.4             Documentation

 9.4.1.1                   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 EM&A report prepared by the ET and endorsed by IEC prior to circulation to the Contractor, ER and EPD.