DESCRIPTION OF THE PROJECT

Environmental Regulations, Codes and Standards

Extensive Regulations, Codes and Standards address environmental and construction

matters and these are referred to as applicable in this document. Notwithstanding this
document, compliance with them shall not discharge the contractor from complying with
any other legislative requirements applicable at the time of construction.
The Control of Pollution Act (COPA), 1974 gives Local Authorities power to control all
noise during construction. Section 61 of COPA 1974 outlines the procedure to obtain
consent for work on construction sites. If consent has not been obtained, and/or the
required noise limits are not being met, the Local Authority may impose requirements
according to Section 60. A Section 61 application would be made.
BS 5228 Parts 1 and 2, 1997 Noise and Vibration Control on Construction and Open
Sites and other relevant EC directives also cover noise emanating from work on
building sites.
Control of dust, smoke and air pollution is covered by the Clean Air Acts, 1993; Control
of Substances Hazardous to Health (COSHH) Regulations 2002; Health and Safety at
Work Act 1974, and the Environmental Protection Act 1990.
The Health and Safety at Work Act, 1974 and associated Regulations and HSE
Guidance Notes cover general safety of construction workers and passers-by.
Monitoring of this would be the responsibility of the Planning Supervisor and the local
HSE Officer.

Section 80 of the Building Act, 1984 requires 6 weeks notice of intended demolition
works. The local planning authority may then impose conditions appropriate to the
scale of demolition.
The Highways Act, 1980 requires Contractors to maintain free passage for pedestrians
and vehicles around their work-sites and to obtain permission from the Local Authority’s
Highway Authority, before the public highway can be opened up, excavated or built
upon. The Act also requires contractors to obtain licences, permission for hoardings,
fenced storage areas, scaffolding, gantries or strips in the public highway.
The Road Traffic Regulation, Act 1984 contains provisions for the making of Traffic
Regulation Orders (TRO), and other matters relating to the control of road traffic.
Prior to any discharge of surface water or de-watering effluent to rivers/watercourses,
soakaways, or sewers, consent must be obtained from the Environment Agency (EA).
Discharge consents are based on the Water Resources Act 1991.
The Environmental Protection Act, 1990 establishes the principle of integrated pollution
control, reforms the management of waste disposal and updates the law on statutory
nuisances likely to cause personal discomfort or be prejudicial to health. The
Hazardous Waste (England and Wales) Regulations 2005 apply controls on
movements of hazardous waste. The Landfill (England and Wales)(Amendment)
Regulations 2004 place responsibility on the landfill operators and producers of waste
to ensure the separation of different classifications of waste based upon waste
acceptance criteria, prior to disposal to landfill. If specific types of waste such as
hazardous waste exceed the criteria then pre-treatment is required prior to disposal.
As of April 2008 Site Waste Management Plans (SWMPs) are a legal requirement for
all projects over £250,000 in value. Existing guidance is provided in Site Waste
Management Plans, Guidance for Construction Contractors and Clients, Voluntary
Code of Practice, Department of Trade and Industry, 2004.
The Ancient Monuments and Archaeological Act 1979, as amended by the National
Heritage Act 1983, includes requirements for investigation of buildings or sites of
historic or archaeological interest. A Watching Brief may be required under Planning
Policy Guidance 16 (PPG16): Archaeology and Planning 1990, whereby a professional
archaeologist would be present during excavation work. This Act also required
Scheduled Ancient Monument Consent for works affecting any Scheduled Monument.
The Planning (Listed Buildings and Conservation Areas) Act 1990 imposes a system of
control over works that affect Listed Buildings. It is an offence for any person to carry
out any works comprising demolition, alteration or extension to a Listed Building without
written consent from the Local Planning Authority or the Secretary of State,

Babergh District Council (BDC) does not have definitive Code of Construction Practice
standards and procedures.

1.0 Management of the EMP

The following sections outline how this EMP document is to be managed by construction
staff, including the General Contractor and BLPC personnel. This management section
contains guidance on Roles and Responsibilities and Documentation.

3.1 Roles and Responsibilities to implement this EMP

Construction staff will ensure that the environmental commitments of this document and
the EIA will be met and that work proceeds in compliance with environmental
regulations and construction specifications. The following sections outline the roles and
responsibilities of construction staff with respect to environmental management:
The principal contractor appointed by the applicant authority would have responsibility
for:
· Implementing the EMP;
· Monitoring Sub-Contractor's performance to the EMP;
· Developing and implementing mechanisms for dealing with problems; and
· Acting as a point of contact for consultation and feedback with legal consultees, the
public and other interested parties. The principal contractor would be responsible for
establishing management procedures for compliance with:
· All relevant legislation;
· The environmental controls and mitigation measures contained in the EMP; and
· Any environmental or other codes of conduct required by the applicant authority.
c) The contractor will ensure that a copy of this EMP is available on-site and the site
personal is familiar with its contents.
The principal contractor would undertake monthly environmental inspections to audit
compliance of the site works with the EMP and will records general inspection of site
conditions. Compliance records would also be available for inspection by representatives
of the JEC development authority and other government agencies as applicable. In
addition, the contractor would submit monthly progress reports to the applicant authority
following site inspections to provide continuous feedback on environmental performance
at the site.

3.2 Documentation
An important part in implementing the environmental practices during construction is ensuring
that all relevant and pertinent documents are available to construction staff as well as regulatory
agencies. The following measures should be implemented to ensure that all information is
properly disseminated:
(a) All relevant project documentation shall be present on site at all times including,
specifications, construction drawings, EMP, and all permits and approvals;
(b) All practices, and procedures outlined in these documents shall be implemented and adhered
to; and
(c) The contractor will ensure that any reporting required by regulations or this EMP is
conducted in a timely manner.

2.0 Environmental Procedures For Construction

The procedures included in this section of the Construction EMP outline the Mitigative Measures
and Best Management Practices (BMPs) that will be implemented throughout construction to
minimize the potential effects on the environment. The procedures included in this document will
be modified/updated to meet the changing needs of the project as it proceeds through the design
and construction phases. Environmental management involves compliance with: local planning
requirements and environmental regulations; PME guidelines, practices and procedures; and
conformity with good management practices and standards of the industry. The environmental
aspects of the construction of the development operations of the JEC are as follows:
(a) Agricultural Soils;
(b) Contaminated Soils;
(c) Vegetation Clearing;
(d) Erosion and Sediment Control;
(e) Beach Construction;
(f) Traffic Control;
(g) Dust Control;
(h) Equipment Maintenance;
(i) Noise Control;
(j) Petroleum, Oils, and Lubricants (POL) Storage, Handling and Disposal; and
(k) Spills of Hydrocarbons and Hazardous Materials.
4.1 Agricultural Soils
The conservation and maintenance of both agricultural and forest soils are of primary concern
during construction. Construction activities have the potential to have long-term impacts by
changing the physical and chemical properties of these soils and affecting productive capability
and future land use. The most common impacts are loss of topsoil resulting from construction
activity or erosion, mixing of subsoil and topsoil, and compaction.
(a) Ensure that topsoil is removed from any agricultural work areas prior to grading or trenching;
(b) Ensure that topsoil and subsoil piles are separated;
(c) Ensure that topsoil is not used for trench backfill or padding;
(d) Ensure that topsoil and subsoil and restored in the proper sequence;
(e) All topsoil stripping shall be monitored by construction staff to ensure that
topsoil in removed to the correct depth;
(f) All stockpiled topsoil material shall be protected from erosion.
4.2 Contaminated Soils
Soil excavation is required for the installation of the Plant facilities and its associated oil pipeline.
During these activities, it is possible that soil or water suspected of contamination from known or
unknown sources, may be encountered. The purpose of these environmental management
practices, which includes detailed procedures, is to set out the recommended steps for consistent,
safe and environmentally responsible handling of such soil or waters. It will assist construction
personnel in:
(a) Identifying soil suspected of contamination;
(b) Identifying contaminated soil;
(c) Minimizing risk to human health and safety, and to the environment when such soils are
encountered;
(d) Handling such soil in a manner that is in compliance with the relevant environmental
legislation; and
(e) Minimizing risk to the construction schedule.
The procedures outlined apply to situations either foreseen or unforeseen. Where excavations of
soils suspected of contamination are anticipated prior to the project, the SITE ENGINEER
should be contacted as early as possible in the planning stages. For the purposes of this EMP and
for construction of the Project, some standard definitions for Suspect and Contaminated Soil is as
follows:
Suspect Soil: A soil suspected of being contaminated, based on either sight, smell, past or present
land use, or a combination thereof.
Contaminated Soil: A soil containing a substance or material whose concentration exceeds
regulated limits, or may:
(a) pose a threat to worker health or safety;
(b) pose a threat to the environment; or
(c) pose a threat to public safety.

Contaminated Trench Water: Trench liquids; water and/or free product hydrocarbons, which by
association with contaminated soils represent a risk similar to that of contaminated soil.
In the event that contaminated areas are identified during construction activities (e.g., grading,
trenching) the following general measures will be followed:
(a) suspend all work in the immediate area;
(b) notify the SITE ENGINEER of the situation;
(c) the SITE ENGINEER will advise BLPC;
(d) BLPC will conduct a preliminary site assessment to determine whether the soil in question
could potentially be contaminated;
(e) secure the area to prevent additional disturbance;
(f) contact the landowner and the Environmental Protection Department for direction on
appropriate mitigation;
(g) a mutually acceptable restoration plan will be developed in consultation with the
Environmental Protection Department; and
(h) specialists will be deployed to the area to direct clean-up and disposal of contaminated
materials, if applicable.
In areas of foreseen contaminated soil or waters, circumstances and characteristics of the
contaminated soil and/or waters will be known. For foreseen areas of contamination, previous
reports or investigations will have, in most cases, collected the data necessary for handling and
mitigation. In most, if not all cases, the Environmental Protection Department will have been
consulted on the foreseen areas and the planned mitigation, if any, for these situations. In all cases
of “Foreseen areas of Contamination” contaminated soils will be excavated and returned to the
pipeline trench, unless directed otherwise. In the event of discovery of unforeseen suspected or
contaminated soil and/or waters, the following detailed procedure will be implemented. The
mitigation procedure consists of the following steps:
A. Identification;
B. Preliminary Assessment;
C. Secure Suspect Soil and Excavated Area; and
D. External Contacts
Each of these steps is described in detail below:
A. Identification:
Suspect soil can usually be identified by sight and smell observations (dependent upon the
contaminant present). Some obvious signs of contamination include, but are not limited to:
(a) Soil discoloration
(b) Unusual or different soil texture
(c) Unusual odour
(d) Vegetation distress
(e) Standing water or trench with a hydrocarbon sheen
(f) Abandoned industrial waste (storage tanks and/or infrastructure)
When either suspect or contaminated soils are encountered during excavation, work in the area
will be suspended. The SITE ENGINEER will be informed immediately.
B. Preliminary Assessment:
BLPC has the responsibility for conducting a preliminary site assessment of the situation. Based
on the evidence (sight, smell and land use), BLPC will assess whether the soil in question could
potentially be contaminated. Some questions BLPC should answer when assessing the situation
are:
(a) What is the specific location where the suspect/contaminated soil was encountered?
(b) What are the adjacent land uses?
(c) Who encountered the suspect/contaminated soil?
(d) How was it encountered? Was it dug, oozing, flowing, solid, etc.?
(e) How much was excavated or encountered (volume of soil/liquids recorded)?
(f) Can it be determined without a third party consultant whether or not the suspect soil is in
fact contaminated?
(g) Should boreholes or test-pits be installed and the soils sampled and tested?
Being able to answer most or all of these questions will assist other
internal/external parties (i.e., BLPC), in determining what course of action to take. As a
precautionary approach, any suspected materials will be sampled by BLPC for laboratory
analysis. Based on the preliminary assessment, and in conjunction with discussion with the work
crews, and the Environmental Protection Department, BLPC may decide that continued delay of
the work is not warranted, and work should continue.
C. Secure Suspect Soil and Excavated Area:
In the event that suspect/contaminated soil is encountered, the area will be secured and any
unnecessary contact with the soil will be avoided. Work in the vicinity of these soil and/or waters
will be moved to another location at the work site wherever possible. Any suspect/contaminated
soil that has been excavated will be secured using the available resources. Potential securing
methods will include:
a) placing the soil on a plasticized tarp;
b) covering the soil with a plasticized tarp to isolate if from other materials;
c) storing the soil away from any watercourses, watersheds, crops, etc.; and
d) placing berms around the tarp to isolate and contain the soil.
If an excavation can be safely left open, the area will be secured as is, until further direction can
be obtained. If the excavation cannot be safely left open, then it will be backfilled. Work will be
suspended if:
a) continuing to excavate in a suspect/contaminated site could pose a threat to the health and
safety of the worker(s);
b) installing pipe in contaminated soil may compromise the integrity of the pipe at a later date; or
c) issues of non-compliance with environmental legislation may result from continuing to work in
areas of contaminated soils.
BLPC will ensure that situations involving suspect/contaminated soil are handled appropriately
including the proper removal, treatment, and disposal of any soil and/or waters, if necessary. In
most, if not all cases contaminated soils will be excavated and returned to the pipeline trench. In
consultation with the Environmental Protection Department it is determined that their presence
poses an increased environmental risk to adjacent “clean” properties, than previously occurred,
clean-up and remediation measures may be necessary. These measures will be developed in
consultation with regulatory agencies in the event this occurs.
D. External Contacts:
The factors that determine which external parties should be involved in a suspect/contaminated
soils incident include:
(a) location (i.e., property owners)
(b) nature of contamination
(c) source of contamination
Property owners will be considered as external contacts, whether they are private or public
entities. BLPC will be responsible for determination of what external contacts will be made and
when these contacts will be made.

4.3 Vegetation Clearing

The removal of any trees, crops or vegetation from the proposed Project site and pipeline right of
way will be required to facilitate construction activities. To minimize the potential impacts of
vegetation removal the following environmental practices shall be implemented: (a) Larger
woody material and agricultural crops shall be considered for salvage and use;
(b) All other cleared material shall be disposed of in an appropriate manner that is approved by
the SITE ENGINEER;
(c) All clearing activities shall be confined to the approved working areas as approved by the
SITE ENGINEER;
(d) The clearing of large trees shall be minimized where possible.
4.4 Erosion and Sediment Control
Erosion and sediment concerns can arise both during the construction phase of the Project and
following construction when the site clean-ups have occurred. Suitable mitigative measures are
therefore required for temporary site conditions which occur for a relatively short period during
the construction phase as well as for the permanent conditions following the completion of the
facilities and cleanup of the work sites.
The grade or slope of the working areas that will be disturbed during the construction phase will
determine the amount and complexity of the mitigative measures that will be required to ensure
adequate erosion and sediment control. Generically, erosion and sediment control measures will
include the application of structures such as:
(a) Runoff Controls - diversion berms, cross trenches, chutes, check dams, interceptor swales;
(b) Erosion Control - diversion ditch and dispersion aprons, gravel sheeting, mulch, erosion
control blankets; and
(c) Sediment Control - sediment fence, straw bale barriers, filter berms, sediment traps, settling
ponds.
The following points and definitions comprise the basic principles of erosion and sediment
control. The CONTRACTOR shall implement these measures where there is a risk of surficial
erosion and loss of soil:
(a) Areas where soil or subsoil has been exposed shall be stabilized by:
grading exposed areas to a slope which minimizes the potential for erosion;
applying appropriate erosion and sediment control measures; and seeding, mulching or
covering with erosion control matting where deemed appropriate by the on-site Inspector or
Engineer.
(b) Sediment and erosion control structures shall be installed prior to site disturbance and meet
the quality as outlined in the construction or manufacturers specifications. These measures shall
only be removed when the disturbed area is stabilized.
(c) Sediment and erosion protection measures shall be inspected daily and also during or
immediately following heavy rain events. Sediment fences and buffer “zones” shall be
maintained in an effective working condition.
4.5 Beach Construction
Should the CONTRACTOR choose to move equipment to the site via a barge from the port to
the Arawak beach, a small roadway and beachhead will need to be constructed. The
CONTRACTOR will implement the following procedures to ensure potential impacts from
construction are minimized:
(a) The CONTRACTOR will review any relevant conditions of the site approval in advance of
the work with the SITE ENGINEER to plan the work needs; (b) Prior to any construction, the
SITE ENGINEER will contact the University of West Indies to survey the beach for potential
turtle nests and to relocate where possible; .
(c) The access road and beachhead will be constructed using large boulders and rock for easy
removal after use;
(d) Construction of the road and beachhead will be restricted to the footprint of the former
roadway used during the construction of the Arawak plant;
(e) All barging operations must be completed with the utmost care to prevent spills to the marine
environment;
(f) Barges will be floated into position at high tide and secured; (g) All trucks and equipment will
be restricted to the roadway and there will be no equipment allowed on the beach outside of the
road footprint;
(h) BLPC will have a representative present at all times during equipment offloading;
(i) The CONTRACTOR will stop all work immediately if conditions are observed that may have
an adverse environmental effect; and
(j) The roadway will be removed and the beach will be restored to its original condition once
shipments are complete.
4.6 Dust Control
During dry conditions, excessive dust may be generated fro the work sites and access roads. This
may have a detrimental impact on the local environment, construction safety or integrity, and may
also cause disruption to the normal activities of nearby residences. The CONT RACTOR will
implement the following procedures to ensure potential impacts from construction are minimized:
(a) the CONTRACTOR will apply dust suppressants such as water, calcium chloride, or tree
lignin based dust suppressant on the work sites as required (calcium chloride will not be used on
agricultural fields); (b) the CONTRACTOR will ensure rock drills are equipped with dust
collectors in good working order; (c) the CONTRACTOR will ensure adequate control of dust at
work sites that are in proximity to nearby residences; (d) the SITE ENGINEER and the
CONTRACTOR will consult with local road authorities prior to application of dust suppressants
on public access roads; and (e) the CONTRACTOR will ensure that in areas of sensitive land
use dust generation is monitored and controlled.
4.7 Traffic
An important consideration during construction will be the impacts on traffic during the pipeline
construction as much of the routing occurs along existing roads and residential streets. Where it
will be necessary to modify the existing traffic flows in areas of construction, modifications may
include partial lane closures, full lane closures, and road closures with detours. The
CONTRACTOR will implement the following procedures to ensure potential impacts from
construction are minimized: (a) Provide the Ministry of Public Works Traffic Division with the
schedule for pipeline construction and road closures at least one month in advance to minimize
conflicts with other road work. This schedule will be updated weekly; (b) Prior to commencing
pipeline construction on a section of public road, a description of the road closures and estimated
time of closure will be provided to newspapers to ensure the public is aware of the project; (c)
The public will be provided with advance information on road closures through weekly
announcements in the newspapers and through radio and television; (d) Road closures will
be posted with detour signs and the detour routes will be fully sign posted throughout to
ensure traffic follows the correct routing; and (e) Where partial and full lane closures, proper
road signs, flag persons and/or temporary traffic lights will be utilized to assist traffic movement.
4.8 Noise Control
During construction, excessive noise from construction equipment may become a nuisance to
nearby residents. The following procedures will be implemented to ensure potential impacts from
construction are minimized: (a) the CONTRACTOR will use noise abatement equipment, in
good working order, on all heavy machinery used on the project; and (b) wherever possible, the
CONTRACTOR shall minimize noise levels during construction. 4.9 Petroleum, Oils, and
Lubricants (POL) Storage, Handling and Disposal By implementing proper handling storage
and disposal of POLs during construction, the likelihood of accidental events that result in
impacts to the environment are greatly reduced. The following procedures will be implemented to
ensure the proper handling, storage and disposal of these materials:(a) Fueling and lubrication of
equipment shall occur in designated and approved locations;(b) Regular inspections of hydraulic
and fuel systems on machinery shall be done, and leaks shall be repaired immediately upon
detection;(c) Washing, servicing and fueling of mobile equipment shall not be allowed within 30
m of a waterway or drainage systems;(d) Waste oils and lubricants shall be retained in a tank or
closed container and disposed of in an approved manner;(e) Greasy or oily rags or materials
subject to spontaneous combustion shall be deposited and stored in an appropriate receptacle.
This material shall be removed from the work site on a regular basis and shall be disposed of in
an approved existing waste disposal facility; and (f) All hazardous materials shall be stored with
secondary containment and properly signed.
4.10 Fuel and Hazardous Material Spills
This Contingency Plan presents a detailed response system to deal with accidents such as the
release of petroleum, oils, or lubricants (POLs) or other hazardous liquids. The objectives of the
Plan are to minimize:
(a) danger to persons;
(b) pollution of land and water;
(c) extent of affected area;
(d) degree of disturbance during clean-up; and
(e) degree of disturbance to wildlife.
In addition to these Project specific response plans, the “National Oil Spill Contingency Plan for
Barbados” provides a coordinated approach of key government agencies and the petroleum
sector to spill response. It covers oil spills to land and to the marine environment. The pIan: (f)
Assigns duties and responsibilities to government personnel and the petroleum sector in
responding to a spill; (g) Identifies the location, acquisition, and maintenance of equipment and
supplies available for containment and cleanup in the event of a spill; (a) Provides a system of
surveillance and reporting for early notification of spills; (b) Establishes a national response
centre from which to coordinate resources and response personnel; (c) Provides oil spill response
procedures for containment, dispersal, cleanup and disposal; and (d) Provides a link to
international agencies for assistance and resources, should this be necessary. The primary
responsibility for the clean-up and associated costs lies with the discharger. However, the Director
of the Central Emergency Relief Organization (CERO) will act as the National Coordinator for
the spill and has the overall responsibility for monitoring the cleanup operations. To provide
advice and resources to deal with spills the Barbados National Response Team has been formed,
which includes government agency and industry membership. This team is chaired by the Chief
Environmental Engineer of the Ministry of Physical Development and recommends policy for
emergency preparedness in dealing with spills. The National Coordinator will activate the
Barbados National Response Team upon notification of a spill. The response to a spill is
described in five phases: 1. The discharger should immediately provide notification of a spill. In
some cases, the spill may be discovered and reported by others. The spill report should be as
complete as possible and include:
(a) Name, address and telephone number of reporting source;
(b) On-scene telephone number;
(c) Exact location and time of spill;
(d) Estimated amount and type of pollutant;
(e) Source of pollutant and cause of spill;
(f) Actions being taken to control spill;
(g) Wind Speed and direction; and
(h) Speed and direction of current; damage observed. 2. The spill will be investigated for severity
and impacts. Based on this assessment, the resources of the Barbados National Response Team
will be deployed as necessary. For more serious spills additional assistance from external
resources may also be requested. 3. Measures will be taken to contain the spill and reduce the
spread or impact. Under some circumstances dispersants may be necessary. 4. The clean up
activities will be undertaken to recover as much oil as possible. Disposal of the recovered
materials will be done to the satisfaction of the Environmental Protection Department of the
Ministry of Physical Development and Environment. 5. Documentation of the incident will be
provided including any sampling results and costs for cleanup Response Action Plan (a) Training
of personnel is the responsibility of the CONTRACTOR and all appropriate personnel will be
trained before commencement of work on the Project. (b) The individual who discovers a leak or
spill shall immediately attempt to stop and contain the leak or spill as per instructions received
during personnel training courses. (c) Work in the immediate area of a spill or leak shall be halted
and the spill shall be reported to the SITE ENGINEER; (d) BLPC will report spills to the
Environmental Engineering Department and the Coordinator for the National Oil Spill Response
Team as per applicable regulatory requirements. (e) The CONTRACTOR will submit a written
report to the Environmental Engineering Department as required by applicable legislation. A copy
will be provided to BLPC. (f) The CONTRACTOR will have the full authority to take
appropriate action without unnecessary delay. (g) The CONTRACTOR shall assume the overall
responsibility of coordinating a clean-up which will include the following actions: (i) deploy on-
site personnel to contain the spilled material using a dyke, pit, absorbent material or booms, as
appropriate; (ii) assess site conditions and environmental impact of various clean-up procedures;
(iii) choose and implement an appropriate clean-up procedure; (iv) deploy on-site personnel to
mobilize pumps and empty drums (or other appropriate storage) to the spill site; (v) apply
absorbents as necessary; (vi) remove any contaminated soil as directed by the Site Engineer; (vii)
dispose of all contaminated debris, water, soil, cleaning materials, and absorbents by placing in an
approved disposal site; and (viii) take all necessary precautions to ensure that the incident does
not recur. (h) During the construction activities, the following spill response resources shall be
available at an appropriate location in readiness to respond to accidental releases of fuels and/or
hazardous materials: (i) Absorbent materials (e.g., sorbent pads, Sorb-All, vermiculite). (ii) Small
equipment such as shovels, rakes, tool kit, sledgehammer, buckets, stakes, tarpaulins, one empty
drum, protective equipment. (iii) Fire extinguisher.

1.1.1 Adherence to the Environmental Management Plan

The Project Manager will be responsible for monitoring compliance with the
Environmental Management Plan. The Contractor shall ensure that all construction staff,
sub-contractors, suppliers, etc. are familiar with, understand and adhere to, the
Environmental Management Plan. Failure by any employee of the Contractor, Sub-
contractors, Suppliers etc. to show adequate consideration to the environmental aspects of
this contract shall be considered sufficient cause for the Project Manager to have the
employee removed from the site. Project Manager will also order the removal of
equipment form the site that is causing continual environmental damage (e.g. leaking oil
or diesel). Such measures will not replace any legal proceedings the Developer may
institute against the Contractor. The Project Manager shall order the Contractor to
suspend part or all of the works if the Contractor and/or any Sub-contractors, Suppliers,
etc., fail to comply with both the Environmental Management Plan and construction
procedures supplied by the Contractor. The suspension will be enforced until such time as
the offending procedure or requirement is corrected and/or if required remedial measures
put in place. No extension of time will be granted for such delays and all costs will be
borne by the Contractor.

1.1.2 Contractors Boards

The Contractor may only erect temporary construction boards in areas agreed by
Municipality.
1.1.3 Construction Procedures
The Contractor shall submit written procedures for all activities that could be potentially
harmful to the environment. Such construction procedures shall include timing of
activities, equipment and materials to be used (where applicable), visual screening,
protection of the site, methods for cleaning the site both during construction and on
completion of the works, disposal of waste and any other information deemed necessary.
Construction procedures shall be submitted to the Project Manager at least five working
days prior to commencing work on an activity. The Contractor shall not commence work
on any activity until such time as the construction procedure has been scrutinized and
agreed to in writing by the Project Manager. In addition, the Contract Manager may call
for emergency construction procedures to be submitted within 24 hours of work
commencing on activities that are deemed harmful to the environment and for activities
of which the developer was previously unaware. If absolutely necessary, changes may be
made to construction procedures once construction has commenced. In such instances the
proposed changes must be agreed to in writing by the Project Manager prior to
commencing with the change.

1.2 ENVIRONMENTAL AWARENESS TRAINING

The Project Manager will provide a general environmental awareness session for all
employees of the Contractor, sub-contractors, suppliers etc. The initial training session
will be held prior to any work commencing on site. The Contractor shall ensure that all
construction personnel, including senior site staff, sub-contractors and suppliers, etc
attend an environmental awareness training session prior to commencing work on site.
The Contractor shall allow two hours for this initial session. The Contractor shall provide
the Project Manager with the names of construction personnel, and the activities in which
they will be engaged to enable the scheduling of the awareness session. Additional staff,
sub-contractors and suppliers coming onto the site must be informed of all environmental
requirements prior to them commencing their duties.
1.3 SITE ESTABLISHMENT
1.3.1 Demarcation of the Site
The “site” here refers to all areas required for construction purposes. The boundary of the
site will be agreed with the Project Manager. The Project Manager will be responsible for
the demarcation of the outer perimeter of the construction site. The method of
demarcating the boundaries shall be determined by the Contractor and agreed to by the
Project Manager prior to any work being undertaken. The method of demarcation consists
of steel droppers placed at regular intervals, with nylon rope between the markers where
this prove to be safe, but where people move closely pass construction work, netting
should be provided preventing building material from falling into these paths. The
Contractor shall maintain the demarcation line and ensure that materials used for
construction on the site do not blow on or move outside the site and environs, or pose a
threat to people. The boundaries of the site shall be demarcated prior to any work
commencing on the site. The site boundary demarcation fence shall be removed when the
site is established. The Contractor shall ensure that all his plant, labour and materials
remain within the boundaries of the site, unless otherwise agreed in writing with Project
Manager. Failure to do so may result in the Project Manager requiring the Contractor to
fence the boundaries of the site with wire mesh at his own expense to the satisfaction of
the Project Manager and municipality. It will be the responsibility of the Contractor to
decide on an appropriate system of protective fencing for the site. The Contractor shall
be responsible to ensure that building materials such as sand is not blown away and take
the necessary precautions to prevent sand from blown by the wind.
1.3.2 Ablution Facilities
The Contractor shall provide the necessary ablution facilities for all site personnel. The
siting of toilets shall be agreed with the Project Manager. The Contractor shall supply an
adequate number of chemical or other suitable and approved toilets throughout the site
where construction personnel will be operating. Toilets shall be easily accessible and
where applicable shall be capable of being relocated. The toilets shall be secured to
prevent them from blowing over, and the doors shall be provided with an external closing
mechanism to prevent toilet paper form being blown out. Toilet paper dispensers shall be
provided in all toilets. Toilets shall be cleaned and serviced regularly. The Contractor
shall ensure that any chemicals and/or waste from the toilets are not spilled on the ground
at any time. Should there be spillage of chemicals and/or waste, the Project Manager shall
require the Contractor to place the toilets on a solid base with a sump. The contractor will
be required to provide a suitable and approved and to remove accumulations of chemicals
and waste from the site and dispose of it at an approved waste disposal site or sewage
plant base at his own expense. Abluting anywhere other than in the toilets shall not be
permitted. The Contractor shall be responsible for cleaning up any waste deposited by
personnel.
1.3.3 Provision of Water
The Contractor shall be responsible for providing construction, drinking and washing
water for his staff and the professional supervisory staff. Construction water shall be
obtained from locations as agreed with the Municipality.
1.4 MATERIALS HANDLING AND STORAGE
1.4.1 Petroleum, Chemical, Harmful and Hazardous Materials
The Contractor shall comply with all relevant national, regional and local legislation with
regard to the storage, transport, use and disposal of petroleum, chemical, harmful and
hazardous substances and materials. The Contractor shall obtain the advice of the
manufacturer with regard to the safe handling of such substances and materials.
1.5 CEMENT AND CONCRETE OPERATIONS
The Contractor is advised that cement and concrete are regarded as materials that are
potentially damaging to the natural environment on account of the very high pH of the
material, and the chemicals contained therein. The Contractor shall ensure that all
operations that involve the use of cement and concrete are carefully controlled. Water and
slurry from concrete mixing operations shall be contained to prevent pollution of the
ground surrounding the mixing points. Old cement bags shall be placed in wind and spill
proof containers as soon as they are empty. The Contractor shall not allow closed, open or
empty bags to lie around the site.
1.6 SOLID WASTE MANAGEMENT
Waste here refers to all construction debris and domestic waste. The Contractor shall
supply waste bins/skips throughout the site at locations where construction personnel are
working. The bins shall be provided with lids and an external closing mechanism to
prevent their contents blowing out. The Contractor shall ensure that all personnel
immediately deposit all waste in the waste bins for removal by the Contractor. Bins shall
be emptied on a daily basis and the waste removed to the construction camp where it
shall be properly contained in a scavenger, water and wind-proof containers until
disposed of. The bins shall not be used for any purposes other than waste collection.
Petroleum, chemical, harmful and hazardous waste throughout the site shall be stored in
enclosed, bunded areas, the location of which shall be determined on site in conjunction
with the Project Manager. The bunded areas shall be clearly marked. Such waste shall be
disposed of off-site at a hazardous waste disposal site.
1.7 WASTE WATER MANAGEMENT
1.7.1 Discharge of Construction Water
Construction water refers to all water affected by construction activities. The Contractor
shall construct and operate the necessary collection facilities to prevent pollution. The
Contractor shall dispose of collected waste water in a manner that complies with
municipal regulations.
1.7.2 Prevention of Ground, Groundwater and/or Water Pollution
The Contractor shall comply with the Water Act, Act 36 of 1998 and other national,
regional and local legislation. The Contractor shall notify the Project Manager and the
Municipality, immediately of any pollution incidents on site. The Contractor shall obtain
Drizit pads and booms, or similar designed products or materials to soak up oil, petrol
and diesel. These materials shall be readily available for use wherever construction
equipment is working, fuel and lubricants is being offloaded and stored and equipment is
filled and serviced. The Contractor shall ensure that he is familiar with the correct use
and disposal of any materials designed to soak up petroleum products. 1.8 SITE
CLEAN UP AND REHABILITATION
1.8.1 Site Clean Up
The Contractor shall ensure that all temporary structures, equipment, materials, waste and
facilities used for construction activities are removed upon completion of the project. The
Contractor shall clear and clean the construction site to the satisfaction of the Project
Manager upon completion of the project.
1.10.2 Accidents on Site
The Contractor shall comply with the Occupational Health and Safety Act, National
Building Regulations and any other national, regional or local regulations with regard to
safety on site. The Contractor shall ensure that contact details of the local medical
services are available to the relevant construction personnel prior to commencing work.
1.10.3 Petroleum, Chemical, Harmful and Hazardous Materials
The Contractor shall ensure that he is familiar with the requirements for the safe handling
and disposal of petroleum, chemical, harmful and hazardous materials. The Contractor
shall be responsible for establishing an emergency procedure for dealing with spills of
release of these substances. He shall also ensure that the relevant construction personnel
are familiar with these emergency procedures. The Contractor shall submit his emergency
procedure to the Project Manager prior to bringing on site any such substances.

3.10 Performance Monitoring

Environmental Monitoring
A monitoring programme of the environmental effects of the demolition and
construction works would be implemented to agreed BDC requirements. This would:
• Evaluate the effectiveness of environmental mitigation, and identify environmental
problems and appropriate responses at an early stage;
• Ensure that the works are carried out in accordance with the provisions of the CEMP;
and
• Identify and implement any environmental improvements that would contribute to the
overall environmental performance of the project.
Safety Monitoring
The requirements of the Management of Health and Safety at Work Regulations 1992,
the Construction (Design and Management) Regulations 1994 and the Construction
(Health, Safety and Welfare) Regulations 1996 would be adhered to.
There would be continuous monitoring of safety standards on-site during all demolition
and construction activities. To ensure that compliance with all existing and forthcoming
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statutory requirements and industry good practice is adhered to, the Principal
Contractor would issue a Health and Safety Plan in line with Construction (Design and
Management) Regulations 1994. In doing so, regard would be had to the features
listed below to ensure that no compromises are made which might jeopardise the
safety of employees, contractors, or the public:
• Construction work on-site;
• Hazardous materials and chemicals;
• Operating procedures;
• Work permits; and
• Emergency response.
The health and safety performance of the Principal Contractor would be the subject of
regular reviews, in accordance with the Applicant’s Corporate Health and Safety Policy.
Inspection and Auditing
The Applicant would wish to reassure itself that the CEMP is being adhered to by the
Principal Contractor. To this end, Site inspections and more formal audits by the EVM
would be undertaken. These are likely to use a checklist pro-forma, which would cover
the environmental issues addressed in the CEMP.
Where a problem is identified, corrective action would be identified by the EVM in
conjunction with the Site Manager and Principal Contractor. This could take the form
of, for example, further direct mitigation, changes to procedures or additional training.
It is envisaged that BDC would have direct access to the EVM’s representative to
ensure that any non-compliances with the requirements of the CEMP are speedily
rectified.
Contingency Planning
Although a serious incident is unlikely to occur during the demolition and construction
phase, it is necessary to have procedures in place to deal with emergencies and
incidents. Environmental incidents can be defined as unexpected events that lead to,
or could in different circumstances have led to, adverse effects on people, property or
on environmental resources such as habitats or historic features.
The Principal Contractor would develop a series of plans, which would set out the
response in the unlikely event of an incident occurring during demolition and
construction such as a fuel spillage or an episode of unexpectedly elevated noise
and/or dust levels. The procedures would include provision for incident reporting.
Appropriate equipment and training would be provided for emergency response to
spillages.