10.0          ENVIRONMENTAL AUDIT. 10-1

10.1          Site Inspection. 10-1

10.2          Environmental Complaints 10-2

10.3          Documentation. 10-2

 

FIGURES

Figure 10.1               Environmental Complaint Procedure Flow Chart

 

APPENDICES

Appendix A             Implementation Schedule for Environmental Mitigation Measures

Appendix B              Site inspection Proforma

Appendix C              Example of Complaint Log

 

 

 

 

 


10.0                   ENVIRONMENTAL AUDIT

10.1                    Site Inspection

10.1.1.1         Site inspection 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.

10.1.1.2         The ET is responsible for the formulation of an environmental site inspection, deficiency and remedial action reporting system and for carrying out the site inspection works.  In consultation with the Independent Environmental Checker (IEC), the ET shall prepare a procedure for the site inspection, deficiency and remedial action reporting requirements and submit this to the Contractor for agreement and to the EngineerĄŠs Representative (ER) for approval within 21 days of commencement to the construction contract.

10.1.1.3         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.  The implementation schedule of mitigation measures is summarised in Appendix A.  It shall 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:

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

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

ĄP               Works progress and programme;

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

ĄP               The contract specifications on environmental protection and pollution prevention;

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

ĄP               Previous site inspection results.

 

10.1.1.4         The Contractor shall update with the ET on all relevant information of the contract for him to carry out the site inspections. The site inspection results and associated recommendations on improvements to the environmental protection and pollution control works shall be submitted, in a site inspection proforma (see Appendix B), by the ET to the IEC, the ER and the Contractor 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.

10.1.1.5         The ER, ET, IEC and Contractor shall conduct ad hoc site inspections if significant environmental problems are identified. The IEC shall also conduct random site audits and inspections.  Inspections may also be required subsequent to receipt of any environmental complaints (an example of the complaint log is provided in Appendix C), or as part of the investigation work, for environmental monitoring and audit.

10.1.1.6         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. 

10.2                    Environmental Complaints

10.2.1.1         Complaints shall be referred to the ET Leader for carrying out complaint investigation procedures.  The ET Leader shall prepare a flow chart of the complaint response procedures that addresses, complaint receiving channels, responsible parties/contacts for information, the investigation process, procedures for the implementation of mitigation/remedial action, 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.  

10.2.1.2         The ET Leader shall undertake the following procedures upon receipt of a complaint:

ĄP               Log the complaints and dates of receipt onto the complaint database to be kept by the Contractor and inform the Engineer, ER and IEC immediately;

ĄP               Investigate with the Engineer/ ER and Contractor the complaints to determine their validity, and assess whether the source of the problems is due to the construction works activities;

ĄP               Identify the mitigation measures if the complaints are valid and due to the construction works of the project;

ĄP               Advise the Contractor if mitigation measures are required;

ĄP               Review the ContractorĄŠs responses to the identified mitigation measures, and the updated situation;

ĄP               Undertake additional audit in order to verify the situation if necessary, and review that the circumstances leading to the complaints would not recur;

ĄP               If the complaint is referred by the EPD, to submit interim report to the EPD on the status of the complaint investigations and follow-up action within the time frame assigned by the EPD; and

ĄP               Record the complaints, investigations, subsequent action and findings in the monthly EM&A reports.

10.2.1.3         A flow chart of the complaint response procedures during construction phase is shown in Figure 10.1.

10.3                    Documentation

10.3.1.1         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 monthly EM&A reports prepared by the ET and verified by IEC prior to circulation to the Contractor, ER and submitted to EPD.