Lismore Base Hospital Redevelopment Stage 3C Independent Environmental Audit
Assessment of John Holland’s Environmental Management System Compliance Against the SSD 8963 Conditions of Consent
Audit Reference: AQ1238.01
Audit Organisation: John Holland Pty Ltd
Auditors: Nilda Soto, Lead Auditor, AQUAS
Ana Maria Munoz, Auditor, AQUAS
Date of Audit: 27 November 2018
Draft Report Submitted: 20 December 2018
Final Report Submitted: 21 December 2018
Amendment, Distribution & Authorisation Record
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Distribution list of electronic copies
Copy No. Revision No. Issued to
1.0 Final CBRE ‐ Mohaned El Gubbi
No reproduction of this document or any part thereof is permitted without prior written permission of AQUAS Pty Limited. This report has been prepared and reviewed in accordance with our Quality control system. This report has been prepared by: ANA MARIA MUNOZ Date: 21/12/2018 Environmental Auditor This report was reviewed by: NILDA SOTO Date: 21/12/2018 Lead Environmental Auditor
© Copyright AQUAS Pty Ltd ABN: 40 050 539 010 All rights reserved. No material may be reproduced without prior permission. While we have tried to ensure the accuracy of the information in this publication, the Publisher accepts no responsibility or liability for any errors, omissions or resultant consequences including any loss or damage arising from reliance in information
in this publication. AQUAS Pty Ltd www.aquas.com.au
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1. Executive Summary 4
2. Introduction 5
2.1 Background 5
2.2 Audit Objectives 5
2.3 Audit Scope 5
2.4 Date and Location of Audit 5
2.5 Audit Period 5
3. Audit Methodology 6
3.1 Audit Team 6
3.2 Audit scope development 6
3.3 Desktop review 6
3.4 Opening Meeting 6
3.5 Audit Process 6
3.6 Project Status 7
3.7 Audit Compliance Status Descriptors 7
3.8 Closing Meeting 7
4. Document Review 8
5. Audit Findings 9
5.1 Audit Overview and Environmental Performance 9
5.2 Audit Site Inspection 10
5.3 Key Strengths 11
6. Recommendations 12
7. Conclusion 13
Appendices
Appendix A. Audit Attendance Sheet 14
Appendix B. Audit Declaration Form 15
Appendix C. Audit Checklist 16
Appendix D. Audit Photos 29
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1. Executive Summary
This report details the findings of the Independent Environmental Audit of the construction works undertaken by John Holland at the Lismore Base Hospital Redevelopment Stage 3C.
Consent for the Stage 3 activities, comprising construction and operation of four storey addition levels (7 to 10) was granted on the 20th of September 2018.
Current works for Levels 7 to 10 include crane operations surveying, scaffolding, formwork, concrete pouring, steel post‐tensioning, structural framing and stormwater pipe works. John Holland is the nominated Principal Contractor for the project and is responsible for the management of environmental aspects associated with the works.
The audit was conducted by AQUAS on 27th November 2018 at Lismore Base Hospital, 60 Uralba Street, Lismore NSW. The audit scope included a review on the implementation of John Holland’s Environmental System in accordance with the requirements of AS/NZS ISO 14001 Environmental Management Systems.
The environmental audit confirmed that John Holland has addressed and implemented the majority of environmental requirements outlined in the AS/NZS ISO 14001. This audit does not include the findings identified on the Compliance Audit which was undertaken on the same day. Refer to AQ1238.01a Compliance Audit Report LBH Stage 3C. No Non‐Compliances and Not‐Triggered findings were identified during this audit. Three (3) Opportunities for Improvement were detected. The Lismore Base Hospital (LBH) 3C Obligations Register was sighted including some of the Conditions; however not all Development Consent Conditions for Stage 3C of the project were included in this register. Frequency and process to evaluate the compliance requirements need to be established and documented. Refer to Section 5.1.1 of this report, OFI‐01.
The contractor has identified the most significant environmental aspects at the worksite and implemented suitable controls. There was evidence of inductions and regular toolbox talks to maintain environmental awareness of all workers at the site. A Construction Environmental Management Plan (CEMP) was in place and had been submitted to Department of Planning and relevant project stakeholders. It has been recommended to establish a specific frequency for reviews of the Plan and related documents, to ensure information and controls are maintained up to date. Refer to Section 5.1.1 of this report, OFI‐02.
Environmental controls for the identified aspects were in place and were consistent with the CEMP and legal requirements. These included suitable signage, noise and vibration controls, compliance with working hours, waste management, erosion and sedimentation measures and traffic controls. Communication means have been established to allow for community enquiries, feedback and complaints, however the community consultation and stakeholder’s communication were not fully described and/or referenced in the CEMP. It has been suggested to reference the Community Consultation Strategy and Stakeholders Management Plan into the CEMP. Refer to Section 5.1.1 of this report, OFI‐03.
A Workplace Emergency Response Plan is in place and has identified potential environmental emergencies. No environmental incidents have occurred so far and no non‐conformances have been raised. Environmental audits for the project have been planned.
The details of the audit process and findings of this audit are detailed in the following sections of this report. This report has been prepared following the Independent Audit Guidelines from the Department of Planning and Environment ‐ June 2018.
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2. Introduction
2.1 Background
CBRE has engaged AQUAS to undertake independent environmental audits during the delivery of Lismore Base Hospital (LBH) Stage 3C Redevelopment North Tower Extension Works project and verify compliance with all specific environmental legal obligations and the requirements of the AS/NZS ISO 14001. Stage 3C comprises the construction of an additional four floors to the North Tower (Levels 7 to 10), which will be fully integrated into the existing floors (Levels 3 to 6) of North Tower.
2.2 Audit Objectives
This audit was conducted to confirm compliance of the John Holland Environmental Management System and its implementation against the requirements of the AS/NZS ISO 14001 including all relevant legal obligations not limited to the Development Consent SSD 8963.
2.3 Audit Scope
The audit reviewed John Holland’s implementation of their Environmental Management System for the construction activities currently taking place as part of the Hospital Stage 3C Redevelopment project.
2.4 Date and Location of Audit
AQUAS conducted a desktop review of John Holland’s Environmental Management system on the on the 15th of November 2018. Subsequently, the site audit was conducted on 27th November 2018 at the Lismore Base Hospital Stage 3C site – 60 Uralba Street, Lismore NSW.
2.5 Audit Period
This is the first independent environmental audit being undertaken by AQUAS during Construction period. This audit was undertaken in accordance with the Department of Planning and Environment’s Independent Audit Guidelines, June 2018 and the Standard AS/NZS ISO 19011:2014 Guidelines for Auditing Management Systems.
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3. Audit Methodology
3.1 Audit Team
AQUAS environmental auditors for this audit were:
Name Company Position Certification
Nilda Soto AQUAS Lead Environmental Auditor
Exemplar Global Principal Environmental Auditor; Certificate No. 115002
Ana Maria Munoz AQUAS Environmental Auditor Certification for Environment Auditor in progress.
3.2 Audit scope development
AQUAS developed a checklist based on AS/NZS ISO 14001 Environmental Management Systems requirements. Refer to Appendix C of this report.
3.3 Desktop review
Prior to the audit, AQUAS undertook a desktop review of John Hollands’s Construction Environmental Management Plan (CEMP), Construction Management Plan (CMP) and all related environmental sub‐plans for Lismore Base Hospital Redevelopment Stage 3C ‐ North Tower on the 15th of November 2018.
3.4 Opening Meeting
An opening meeting was held with CBRE representative, John Holland project personnel and AQUAS auditors as per the Audit Attendance Sheet on 27th November 2018 at 8:35am. Refer to Appendix A of this report.
Key items were discussed as follows:
Confirmation of the purpose and scope of the audit.
Overview of the Project and current status of the works.
Occurrence of Environmental incidents.
Overview of the audit process in accordance with the proposed Audit Program.
3.5 Audit Process
The audit commenced with a visitors site induction follow by a physical site inspection where status of construction works and relevant environmental controls in place could be observed. The site walk covered all development areas (Level 7‐10), site sheds, loading/unloading area and construction site relevant surroundings.
The site walk was followed by review of environmental records and general discussions with John Holland project personnel for verification of the Environmental Management System implementation on the project.
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Name and position of persons interviewed:
Name Organisation Position
Brett Popham John Holland Project Manager
Michael Sawyer John Holland Safety Advisor / Environmental Representative
Will Roberts John Holland Senior Project Engineer
3.6 Project Status
Lismore Base Hospital Redevelopment Project ‐ Stage 3C includes the construction of four floors to the North Tower (Levels 7 to 10), which will be fully integrated into the existing floors of North Tower.
Current construction site works included crane operations surveying, scaffolding, formwork, concrete pouring, steel post‐tensioning, structural framing and stormwater pipe works.
3.7 Audit Compliance Status Descriptors
The following audit criteria were used for the rating of audit findings.
Audit Compliance Status
NC – Non‐Compliant
NT – Not triggered
OFI – Opportunity for Improvement
3.8 Closing Meeting
The closing meeting was held on 27th September 2018 at 2:45pm with representatives of CBRE, John Holland and AQUAS. General feedback and the findings of the audit were discussed during the closing meeting.
AQUAS auditors acknowledged the cooperation, openness and hospitality of John Holland staff during the conduct of this audit.
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4. Document Review
The following documents were reviewed and/or sighted as part of this audit:
Construction Environmental Management Plan (CEMP) Rev.10 – 26/9/18
Construction Management Plan (CMP) Rev.1 – 29/3/18
Traffic Management Plan (TMP) Rev. 6 – 19/9/18
Noise and Vibration Management Plan Rev. D – 26/9/18
Waste Management Plan Rev. T – 26/9/18
Dust and Air Quality Management Plan Rev. H – 19/9/18
Water Quality, Erosion and Sediment Control Management Plan Rev. H – 19/9/18
Cultural Heritage Management Plan Rev. H – 19/9/18
Site Contamination & Hazardous Substances Management Plan Rev. F – 19/9/18
Notification of Commencement for LBH Stage 3C – 3/10/18
Site Orientation Checklist ‐ LBH Stage 3B
Community Communication Strategy Rev. 1.0 – 7/9/18
Stakeholder Management Plan LBH Stage 3B Rev. 3 – 27/5/18
Obligations Register LBH Stage 3C (Extract)
Dilapidation Report Lismore Base Hospital North Tower Extension (NTX) – 17/9/18
Accessibility Compliance Statement (Construction Certificate) LBH Stage 3C NTX – 26/11/18
Workplace Risk Assessment (WRA) Rev. 6 – 17/7/18
Certificate of Calibration for Sound Level Meter – 12/10/17
Tower Crane Daily/Weekly Safety & Service Log – 19/11/18‐25/11/18
Elevated Working Platform Log Book dated 29/11/18.
Building Certification for Crown Building Work certificate No. 18/124020‐3 – 20/9/18
Design Certificate – Structural for LBH Stage 3B2 and North Tower Extension – 16/6/17
Design Certificate – Mechanical for LBH Stage 3B2 and North Tower Extension – 21/3/18
Design Certificate – Electrical for LBH Stage 3B2 and North Tower Extension – 7/8/17
Toolbox Talk Meeting Record Lindores Construction Logistics – 20/11/8
Pre‐start Meeting Record ‘Laser’ Plumbing Contractor – 22/11/18
Workplace Emergency Response Plan Rev.7 – 27/7/18
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5. Audit Findings
5.1 Audit Overview and Environmental Performance
The audit determined that John Holland has well‐implemented controls for environmental management within the construction activities currently being undertaken. Three (3) Opportunities for Improvement (OFIs) were raised during the audit.
No non‐compliances and five not‐triggered requirements were identified during the Compliance Audit against the Conditions of the Development Consent SSD 8963 which are not included in this report. Refer to AQ1238.01a Compliance Audit Report ‐ LBH Stage 3C.
The following is an overview of key Environmental areas reviewed in this audit:
5.1.1 Environmental Planning and Resources
o A Lismore Base Hospital (3C) Obligation Register was sighted with general project requirements and Development Conditions of Consent for Stage 3B; however, the LBH 3C Obligations Register does not include all the Development Conditions of Consent for Stage 3C of the project (SSD 8963). Frequency and process to evaluate the compliance requirements need to be established and documented – OFI‐01.
o The CEMP includes some references to legal and other requirements and John Holland noted that this information is reviewed periodically; however the CEMP does not indicate how compliance requirements will be evaluated, how often and what records will be maintained. A minimum review frequency for the CEMP and the LBH 3C Obligations Register has not been established or documented – OFI‐02.
o Environmental resources are allocated to the project as required. A number of trades work on different activities, e.g. formwork, posttensioning, concreting, electrician, etc.
o The CEMP contains information relevant to the environmental aspects and controls for the project o A Workplace Risk Assessment (WRA) was also presented which includes details of environmental
aspects, impacts, controls and action plans for Stage 3B.
5.1.2 Support
o John Holland project staff and subcontractors have to undertake a site induction, which contains awareness of environmental measures to be considered during construction.
o Toolbox Talks and prestart meeting are conducted to maintain ongoing awareness of safety and environmental matters onsite.
o John Holland has established means of internal and external communications, which include email, regular internal, subcontractor and client meetings, Aconex transmittals, etc. Community communications, e.g. letterbox drops are sent out as required.
o A Community Consultation Strategy and Stakeholder Management Plan have been developed; however community consultation and stakeholders communication was not fully described in the CEMP as required by the Condition of Consent B12 (a) – OFI‐03.
o A ‘Disruption Works Notice’ system is in place to inform the client of any construction works taking place which will affect the hospital operations.
o The Construction Environmental Management Plan (CEMP) has been developed along with the Environmental Sub‐plans and other environmental documentation required by the Development Conditions of Consent.
o So far, revisions of the environmental documentation have been submitted to Planning, however it was suggested that the CEMP should specify a minimum review frequency to ensure it is maintained up to date – OFI‐02.
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o Relevant environmental records are maintained in different ways, e.g. hard copies kept in folders at the site office or near the plant and equipment, other project records are stored in Aconex and in the office shared drive.
5.1.3 Operations
o Site signage was in place with the required project contact information. o Hours of work as per the Development Consent. o Design certificates were available to be compliant with structural, mechanical and electrical BCA
and Australian Standards requirements. o A Construction Noise and Vibration Management Plan was available. Controls were in place for
noise mitigation. Noise monitoring is conducted as required and communication with Hospital and other sensitive receivers was managed for any exceedances.
o Waste classification is outlined in the Waste Management Plan. Waste report by Richmond was available.
o Bins and containers for different waste types were available throughout the site. o Waste is appropriately segregated, o Erosion and sedimentation controls were effective and in place within the site. o A mix of solid hoardings and fencing was installed in the perimeter of the site and monitored to
ensure good condition and security of the site. Additionally, John Holland indicated that Hospital personnel conducts patrols during the night.
o A Workplace Emergency Response Plan is in place which includes a number of emergency scenarios and actions to follow for each one of them, including environmental emergencies.
o Spill kits were available onsite. o Scaffolds installed and tagged. o Concrete well managed onsite.
5.1.4 Performance Evaluation
o Site environmental inspections are conducted weekly basis. Inspection reports were available for Traffic, Plant and People (GMR) inspection, daily checks by traffic controllers and records for traffic management inspections.
o Construction work site checklist was completed by CBRE and John Holland on fortnightly basis. o Project information is available on Department of Planning and John Holland’s website about
statutory approvals, approved strategies, complaints and other project information.
5.1.6 Improvement
o No environmental non‐compliances have been identified so far in the project. o There is a 24‐hour enquiries number in the signage outside the worksite available for the
community. o No complaints have been received for Stage 3C. A Complaints Register is available where
information about the complaints is recorded including resolution reached. One complaint for Out of Hours Noise was recorded, but this was for Stage 3B.
o No environmental incidents have occurred so far in the project.
5.2 Audit Site Inspection
The site inspection was conducted at 9.20am on the 27th November 2018. AQUAS auditors and John Holland project staff walked through the construction site, including levels 7‐10, site sheds, loading/unloading area, common area/lunch shed and construction site relevant surroundings.
Please refer to photos in Appendix D.
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5.3 Key Strengths
Construction Environmental Management Plan (CEMP) and other environmental sub‐plans have been developed to meet the requirements of the Development Consent Conditions SSD 8963.
Environmental resources have been allocated to the project and environmental inspections have been undertaken periodically.
Site induction have been carried out to project staff and subcontractors, induction contains awareness of environmental measures to be considered during construction.
Internal and external communication mechanisms have been established.
Erosion and sedimentation controls were in place around the construction site.
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6. Recommendations
The table below outlines the identified audit findings raised during this audit.
There were nil no‐compliant findings, nil not‐triggered requirements and 3 opportunities for improvement as follows:
Finding
No. Ref. No. Audit Finding Comment/ Recommendation
OFI‐01 ISO 14001 Cl. 6.1.3
The presented LBH 3C Obligations Register does not include all the Development Conditions of Consent for Stage 3C of the project (SSD 8963).
LBH 3C Obligations Register to be fully developed to include all the Conditions of Consent for Stage 3C of the project (SSD 8963).
Also, it is recommended that CEMP includes a reference to this Register in Section 6.3 and Appendix 2.
OFI‐02 ISO 14001 Cl. 6.1.3; 9.1.2
SSD – A7, A8, A9, C28
CEMP does not indicate how compliance requirements will be evaluated, how often and what records will be maintained. A minimum review frequency for the CEMP and the LBH 3C Obligations Register has not been established or documented.
CEMP to describe evaluation of
compliance requirements and to
establish and document a minimum
review frequency of the CEMP, the
LBH 3C Obligations Register and any
other relevant environmental
documents.
OFI‐03 SSD ‐ B12
ISO 14001 Cl. 7.4, 8.1
Community consultation and stakeholders communication was not fully described in the CEMP. It was noted that these processes are included in the Community Consultation Strategy and the Stakeholder Management Plan.
CEMP to include a reference to the Community Consultation Strategy and the Stakeholder Management Plan in Section 7.4
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7. Conclusion This audit was completed to assess the environmental controls established by John Holland against the requirements of the ISO 14001 Environmental Management Systems and the SSD 8963 Development Consent for the project. The audit confirmed that John Holland has implemented its Environmental Management System to a satisfactory level and only opportunities for improvement were identified as part of the review.
The following table summarises the audit findings by rating category:
Findings Rating Findings
Non‐Complaint 0
Not triggered 0
Opportunity for Improvement 3
John Holland is required to action the identified opportunities for improvement in order to comply with the SSD 8963 Development Conditions of Consent and to enhance the Environmental performance during the progress of the Project.
Feedback from this audit should be taken as an opportunity to make improvements in the Environmental Management System established by John Holland for the Lismore Base Hospital (LBH) Redevelopment Stage 3C Project.
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Appendix A. Audit Attendance Sheet
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Appendix B. Independent Audit Declaration Form
Audit Compliance Codes: NC: No-Complaint; NT: Not triggered; OFI: Observation for Improvement AQ1238.01B ENVIRONMENTAL AUDIT REPORT ‐ LBH STAGE 3C ‐ 20181221 FINAL PAGE 16 OF 31
Appendix C. Audit Checklist
Item No.
ISO 14001
SSD8963 CoC Audit Criteria Audit Evidence Compliance
Rating
1.0 Environmental Compliance Obligations
1.1 6.1.3 The Contractor has identified all legal and other requirements relevant to its environmental aspects and how they apply to the project.
Section 6.3 of the CEMP Table 5, includes the Federal, State, Local and Client requirements. Also, the LBH 3C Obligations Register was presented including some of the Development Consent Conditions; however not all conditions are included in this register, for example condition B12 (vii), C26, Appendix 1. It was recommended to: - Make reference to the LBH 3C Obligation Register in the CEMP section 6.3 and
Appendix 2, as appropriate. - Fully developed the Obligation Register to include all the Conditions of Consent
(SSD 8963) for Stage 3C of the project.
OFI-01
1.2 6.1.3 The Contractor has procedures for periodically evaluating compliance with applicable legal requirements. Records of the results of periodic evaluations are maintained
It was indicated that the Obligations, Approvals and License Register (PRJ-04369-01 LBH Stage 3B) gets reviewed periodically. This register was included in Appendix 2 of the CEMP, however, this register only includes Consent Conditions for the SSD6848. Therefore it is required that all Consent Conditions for the SSD8963 are included in the LBH 3C Obligations Register and this register is included in Appendix 2. Evaluation of Compliance will be done through the independent environmental audits every six months. This audit will be the first review. It is recommended that the CEMP indicates how compliance will be evaluated, how often and what records will be maintained.
OFI-02
1.3 6.1.3 9.1.2
The Contractor periodically evaluates compliance with other requirements to which it subscribes, and keeps records of the results of evaluations.
CEMP has information of environmental aspects, impacts and controls; information is reviewed periodically, however a specific review frequency has not been established in the CEMP. Also, John Holland Environmental Representative undertakes Environmental Inspections to verify compliance on site, sighted checklist completed on the 16/11/2018.
OFI-02
2.0 Support
2.1 Competency, training and awareness
2.2 7.2 The Contractor has ensured that employees and subcontractors are competent on the basis of appropriate education, training or experience.
Currently there are about 15-20 sub-contractors working on site. Toolbox talks and pre-starts are carried out with relevant subcontractors on daily and weekly basis; sighted examples for: Toolbox talk meeting record for Lindores Construction Logistics – 20/11/8
Audit Compliance Codes: NC: No-Complaint; NT: Not triggered; OFI: Observation for Improvement AQ1238.01B ENVIRONMENTAL AUDIT REPORT ‐ LBH STAGE 3C ‐ 20181221 FINAL PAGE 17 OF 31
Item No.
ISO 14001
SSD8963 CoC Audit Criteria Audit Evidence Compliance
Rating
Relevant training and competency records have been retained.
and Pre-start meeting record for ‘Laser’ Plumbing Contractor – 22/11.Other contractors on site were: BOSFORM (form workers), Rio Force (Steel reinforcement) and FREYSSINET (posttensioning) contractors.
Relevant training and licenses are requested to subcontractors prior to start on site. Sighted electrician license expiring on 01/02/2019 and Crane Operator High Risk Work License expiring on 14/03/2022.
2.3 7.3 The Contractor has established a procedure to provide awareness to employees and subcontractors on: a) the importance of conformity with the environmental
policy, procedures and requirements of the EMS b) the significant environmental aspects and related
actual or potential impacts associated with their work, and the environmental benefits of improved personal performance,
c) their roles and responsibilities in achieving conformity with the EMS
d) the potential consequences of not following the procedures
Site Induction presentation was presented including Environmental policy, Environmental key aspects and Environmental requirements from the SSD8963. Site Orientation Checklist was sighted for Electrician completed 26/11/18. Induction also includes working hours, hazardous substances, emergencies and other specific environmental elements.
2.5 Communication
2.6 7.4.2 Procedures are in place for ensuring internal communication with regard to the environmental aspects and the EMS.
Section 7.3 of the CEMP indicates internal communication will take place via Toolbox talks, site co-ordination, pre-starts and JH team meetings. Sighted weekly sub-contractors toolbox talks including controls to be considered during the month and actions.
2.7 7.4.3 Procedures are in place for communications with external parties, e.g. a) EPA, Council, Hospital, others b) Community engagement – provision of information,
sensitive receivers, follow up
Section 7.4 of CEMP describes external communication with stakeholders. Also, a Community Communication Strategy SSD 17_8963 was issued on the 13/9/18 which includes the communications plan and mechanisms. It was indicated that Lismore Hospital leads a meeting with the local community and council and any queries or actions are communicated to John Holland Project Manager.
2.8 7.4 A6 Evidence of consultation with relevant parties including details of the consultation undertaken, the outcome, matters resolved and unresolved, and the details of any disagreement remaining and how it was addressed.
Community Communication Strategy specifies that consultation occurred in April 2018 with UCRH, Rous Water and Ngulingah Land Council. Also, it was indicated that Lismore Base Hospital staff was consulted when developing the Traffic Control Plan (TCP). Lismore Hospital runs a meeting with the local community and council, as necessary.
Audit Compliance Codes: NC: No-Complaint; NT: Not triggered; OFI: Observation for Improvement AQ1238.01B ENVIRONMENTAL AUDIT REPORT ‐ LBH STAGE 3C ‐ 20181221 FINAL PAGE 18 OF 31
Item No.
ISO 14001
SSD8963 CoC Audit Criteria Audit Evidence Compliance
Rating
Meetings were carried out for Stage 3B, no meetings have been conducted so far for Stage 3C.
2.9 7.4 B8 A Community Communication Strategy must be prepared to provide mechanisms to facilitate communication between the Applicant, the relevant Council and the community (including adjoining affected landowners and businesses, and others), during the D&C of the development and for a min of 12 months following the completion of construction.
The Community Communication Strategy must: a. identify people to be consulted during the design
and construction phases; b. set out procedures and mechanisms for the regular
distribution of accessible information about or relevant to the development;
c. provide for the formation of community-based forums, if required, that focus on key Env. Mgt. issues for the development;
d. set out procedures and mechanisms through which the community can discuss or provide feedback, respond to enquiries and to resolve any issues and mediate any disputes that may arise in relation to construction.
The Community Communication Strategy must be submitted to the Planning Secretary for approval no later than 2wks before the commencement.
Community Communication Strategy SSD 17_8963 dated 07/09/2018 issued on the 13/09/18 was sighted. The project has signage outside construction site in case any person from the Hospital or local community has any enquiries. Site Manager and Project Manager phone numbers are included. Community Communication Strategy includes:
a. List of stakeholders who have been consulted during the redevelopment construction period, e.g. Hospital executives, local businesses, Lismore City Council, CRRH, Rous Water, etc.
b. Communications mechanisms e.g. newsletters, website updates. Last newsletter was reviewed by HI.
c. Lismore Hospital leads meetings with HI/CBRE/Community and others. d. Letters were distributed to the community describing construction works.
Stakeholder Management Plan was sighted (LBH-PP-JH-Y-0011-03-SKMP-270718). Plan describes the communication tools with stakeholders:
- Meeting with community members – monthly or as requested. - Local residents and business – letterbox drop and door knock, as required. This
Plan needs to be referenced in the CEMP. Presented letter from Department of Planning to Health Infrastructure dated 04/10/2018 approving the Community Communication Strategy for Lismore Base Hospital redevelopment Stage 3C.
3.0 Documentation
3.1 7.5 The Contractor has procedures for control of documents and records, which includes: a. approval of documents for adequacy prior to issue b. review and update and re-approval
Section 6.7 of the CEMP indicates that there is a Project Documentation and Control procedure from John Holland JH-MPR-QUA-005 which will be followed to manage documents in this project. During the audit the following environmental documents were sighted:
- Construction Environmental Management Plan (CEMP)
Audit Compliance Codes: NC: No-Complaint; NT: Not triggered; OFI: Observation for Improvement AQ1238.01B ENVIRONMENTAL AUDIT REPORT ‐ LBH STAGE 3C ‐ 20181221 FINAL PAGE 19 OF 31
Item No.
ISO 14001
SSD8963 CoC Audit Criteria Audit Evidence Compliance
Rating
c. changes and current revision status of documents are identified
d. relevant versions of applicable documents are available
e. ensuring that documents remain legible and readily identifiable
f. ensuring that relevant documents of external origin for the planning and operation of the EMS are identified and their distribution controlled
g. preventing the unintended use of obsolete documents and applying suitable identification to them if they are retained
- Construction Management Plan (CMP) North Tower - Dust and Air Quality sub-plan - Water Quality, Erosion and Sediment Control Sub-plan - Cultural heritage Management Sub-plan - Noise and Vibration Management Sub-Plan - Waste Management Sub-Plan - Site Contamination & Hazardous Substances Sub-Plan
All sighted plans and sub-plans had a revision number, a document control number, they have been reviewed and approved. Plans are available in the Department of Planning website. Environmental records will be archived and retained for 7 years or longer where specified by the Contract.
3.2 7.4, 8.1
B12, B13
Construction Environmental Management Plan a. Prior to the commencement of construction works, a
CEMP must be prepared and include, but not be limited to, the following:
i) community consultation and complaints handling;
ii) hours of work; iii) 24 hour contact details of site manager; iv) management of dust and odour to protect the
amenity of the neighbourhood; v) stormwater control and discharge; vi) measures to ensure that sediment and other
materials are not tracked onto the roadway by vehicles leaving the site;
vii) external lighting in compliance with AS4282:1997 Control of the Obtrusive Effects of Outdoor Lighting; and
viii) waste classification (for materials to be removed) and validation (for materials to remain) be undertaken to confirm the contamination status in these areas of the site.
CEMP for Lismore Base Hospital Stage 3C North Tower: LBH-PP-JH-Y-0004-09-CEMP dated 26/9/18 Rev.10 was sighted.
i. Section 7.4 indicates there will be external communication with Community Groups & Section 7.5.1 describes management of complaints. It was recommended that CEMP makes reference to the Community Consultation Strategy and the Stakeholder Management Plan.
ii. Section 5.1 iii. Section 5.2 includes site contact details iv. Dust and Air Quality Sub-plan version H dated 19/9/18 Section 6.0 defines the
environmental control measures and safeguards. v. Water Quality Erosion and Sediment Control Sub-Plan version H dated 19/9/18
Section 9.0 includes management of stormwater. vi. Water Quality Erosion and Sediment Control Sub-Plan version H dated 19/9/18
Section 7.0 outlines sediment controls. vii. Appendix 2 (Table 15) Outdoor lighting; however this table needs to be updated
to include all the Conditions of Consent for Stage 3C. Refer to OFI-01. viii. Waste Management Sub-Plan version I dated 26/9/18 section
6.0 indicates waste classification and disposal.
OFI-03
Audit Compliance Codes: NC: No-Complaint; NT: Not triggered; OFI: Observation for Improvement AQ1238.01B ENVIRONMENTAL AUDIT REPORT ‐ LBH STAGE 3C ‐ 20181221 FINAL PAGE 20 OF 31
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Other Specific Management Plans: b. Construction Traffic and Pedestrian Management
Sub-Plan c. Construction Noise and Vibration Management Sub-
Plan d. Construction Waste Management Sub-Plan
Prior to the commencement of construction works, a CEMP must be submitted for the approval of the Certifying Authority and a copy submitted to the Planning Secretary.
Sighted Plan and Sub-Plans for: b. Traffic Management Plan LBH-PP-JH-Y-0007-06-TMP Rev. 6 - 19/9/18 in place. c. Noise and Vibration Management Sub-Plan JH-ECP-ENV-004 CNVMP Rev. E 26/9/18 in place. d. Waste Management Sub-Plan JH-ECP-ENV-005 WM Rev. I - 26/9/18 in place. CEMP was submitted to CBRE. CEMP (Rev.7) available in the Department of Planning website. Also, sighted Building Certification for Crown Building Work, certificate No. 18/124020-3 from McKenzie Group which includes the CEMP Rev. 9 dated 19/09/2018 as part of the attachments No. 9.
3.3 8.1 B14 The Construction Traffic and Pedestrian Management Sub-Plan (CTPMP) as required by condition B12,must address, but not be limited to, the following matters: a. be prepared by a suitably qualified and experienced
person(s); b. be prepared in consultation with Council; c. detail measures to be implemented to ensure road
safety and network efficiency during construction considering general traffic, cyclists and pedestrians and bus services;
d. detail heavy vehicle routes, access and parking arrangements;
e. include a Driver Code of Conduct to: i) minimise the Impacts of earthworks and
construction on the local and regional road network;
ii) minimise conflicts with other road users; iii) minimise road traffic noise; and iv) ensure truck drivers use specified routes;
f. include a program to monitor the effectiveness of these measures;
Traffic Management Plan for Lismore Base Hospital Stage 3C (LBH-PP-JH-Y-0007-06-TMP) Rev. 6 dated 19/9/18 was sighted. Plan included: a. TCP was prepared by Traffic Control Innovations (TCI) Consultant. b. Consultation and approval of TCP was sighted with Lismore City Council. Presented email approving TCP in Appendix 6 of the TCMP. c. Section 3.0 Vehicular Traffic Impacts d. Section 1.3 and 3.3 site access, section 4.2 parking e. Section 3.4 general construction deliveries included a driver code of conduct f. The following monitoring activities are undertaken:
- Joh Holland carries out internal audits one their company Global Mandatory Requirements (GMRs), there is one for is Traffic, Plant and People; sighted record on the 31/10/2018.
- Daily sign-in register and daily checks were sighted dated 19/11/2018 signed by a Traffic Controller from TCI employee.
- Traffic Management inspections undertaken by John Holland, sighted completed one on the 9/10/2018; frequency of inspections: ‘as required’.
- Construction work site checklist is completed by CBRE and John Holland on fortnightly basis.
g. Disruptions are notified via the newsletter and/or letter box to the residents and the Hospital. Sighted newsletter 3/4/18 for lower north tower and a newsletter for the installation of the crane.
Audit Compliance Codes: NC: No-Complaint; NT: Not triggered; OFI: Observation for Improvement AQ1238.01B ENVIRONMENTAL AUDIT REPORT ‐ LBH STAGE 3C ‐ 20181221 FINAL PAGE 21 OF 31
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g. if necessary, detail procedures for notifying residents and the community (including local schools),of any potential disruptions to routes.
Also, there are some meetings carried out with representatives of the community. These meetings are led by Lismore Hospital and actions communicated to John Holland, as appropriate.
3.4 8.1 B15 The Construction Noise and Vibration Management Sub-Plan (CNVMP) as required by condition B12,must address, but not be limited to, the following matters:
a. be prepared by a suitably qualified and experienced noise expert;
b. be prepared in consultation with Council and all noise sensitive receivers where noise levels exceed the construction noise management level in EPA's Interim Construction Noise Guideline (DECC, 2009);
c. describe procedures for achieving the noise management levels in EPA's Interim Construction Noise Guideline (DECC,2009);
d. describe the measures to be implemented to manage high noise generating works such as piling, in close proximity to sensitive receivers;
e. include strategies that have been developed with the community for managing high noise generating works;
f. describe the community consultation undertaken to develop the strategies in condition B15(e); and
g. include a complaints management system that would be Implemented for the duration of the construction.
Noise and Vibration Management Plan for Lismore Base Hospital Stage 3C JH-ECP-ENV-004 revision D dated 26/9/18 was sighted.
a. Plan was prepared by Resonate Consultants.
b. A Newsletter was distributed for the start of the North Tower Extension. Also, Section 4.1 describes the process for consultation during construction
c. Section 6.1.1 Noise management levels
d. Section 6.1.2 highly noise affected
e. Section 6.1.2 – restriction the hours of construction works. So far no ‘Out of Hours’ works have been carried out for Sage 3C of the project.
f. Section 4.0 – consultation during construction
g. Section 4.2 indicates the complaint management procedure. This is further described in the Stakeholder Management Plan. A Complaint Register is maintained in the NSW Government website (DPE) for Lismore Hospital Redevelopment. So far 1 complaint was received for Stage 3B (2) on the 3/7/2018 regarding an Out of Hours noise. None for Stage 3C.
3.5 8.1 B16 The Construction Waste Management Sub-Plan (CWMP) as required by condition B12,must address, but not be limited to, the following matters where relevant:
a. detail the quantities of each waste type generated during construction and the proposed reuse, recycling and disposal locations;
b. removal of hazardous materials, particularly the method of containment and control of emission of
Waste Management Plan for Lismore Base Hospital Stage 3C JH-ECP-ENV-005 revision I dated 26/9/18 was sighted.
a. Section 6.0 includes waste type and estimated quantities. A table with construction waste classification and transport/disposal method was sighted, however the waste disposal facility is not included. Also, reference to asbestos should deleted as there are no asbestos in this stage of the project. Sighted report from Richmond Waste - October 2018 with quantities.
Audit Compliance Codes: NC: No-Complaint; NT: Not triggered; OFI: Observation for Improvement AQ1238.01B ENVIRONMENTAL AUDIT REPORT ‐ LBH STAGE 3C ‐ 20181221 FINAL PAGE 22 OF 31
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fibres to the air, and disposal at an approved waste disposal facility in accordance with the requirements of the relevant legislation, codes, standards and guidelines, prior to the commencement of any building works.
b. Section 6.0 indicates that non-hazardous waste will be disposed of at Northern Rivers Waste (Lismore NSW).
3.6 7.5 A7,A8, A9, C28
Revision of Strategies, Plans and Programs The strategies, plans and programs required under this consent must be prepared, combined, updated and staged (if applicable). Within three months of:
a. the submission of a compliance report; b. the submission of an incident report; c. the submission of an Independent audit; d. the approval of any modification of the conditions of
this consent; or e. the Issue of a direction of the Planning Secretary
which requires a review, The strategies, plans and programs must be reviewed and approved and the Department and the Certifier must be notified in writing that a review is being carried out.
Sighted for Lismore Base Hospital North Tower Extension Level 7-10: - Approved Plans (NSW Government website) - Site Plan Proposed DA1000 Rev. 3 dated 20/09/2018 - GA level 10 DA22010 Rev. DA 20/09/2018. - Crane Consent – SSD - Contract Program that includes North Tower, Lower Tower and Upper Tower. - Construction Program.
Approval from Department of Planning was received on the 20/09/2018. CEMP has been reviewed at least annually, this year 4 revisions have been made: one in May and 3 in September 2018. In general review of the CEMP and associated documents is done as necessary, however a minimum review frequency is not established or documented.
OFI-02
3.7 Control of records
3.8 7.5.3 The Contractor has established and maintained necessary records to demonstrate conformity to the requirements of its EMS and the Standard, and the results achieved.
Sighed environmental records in hard copies, DPE website and other electronic forms: - Site Induction and Site Orientation Checklist. - Toolbox Talks and pre-start meetings (hard copies). - Traffic Management inspections and Construction work site checklist. - Waste report from Richmond Waste. - Approved Plans and letters sent to DEP.
3.9 7.5.3 Procedures have been established for the identification, storage, protection, retrieval, retention and disposal of records.
Section 6.7 indicates that at practical completion the environmental records will be archived as per JH-MPR-BUA-018 Records Management and retained for 7 years or longer where specified by the Contract. John Holland manages records as part of the Head Office Management System procedures.
Audit Compliance Codes: NC: No-Complaint; NT: Not triggered; OFI: Observation for Improvement AQ1238.01B ENVIRONMENTAL AUDIT REPORT ‐ LBH STAGE 3C ‐ 20181221 FINAL PAGE 23 OF 31
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4.0 Operation
4.1 Operational controls
4.2 8.1 The Contractor has identified and planned controls associated with the significant environmental aspects to ensure that operations are carried out under conditions that minimise harm to the environment.
Section 5.5.1 of the CEMP identifies the key environmental aspects of the project (8 in total). The Environmental Impact Statement (dated 13 Jan 2015) includes all the environmental aspects and impacts for the project. During site audit the Workplace Risk Assessment (WRA) Rev. 6 (17/7/18) was sighted which includes environmental aspects and controls e.g. noise management, traffic management, waste management, etc.
4.3 C2 Site Notice. A site notice(s): a. must be prominently displayed at the boundaries of
the site for the purposes of informing the public of project details Including, but not limited to the details of the Builder, Certifier and Structural Engineer.
b. is to satisfy all but not be limited to, the following requirements:
i) minimum dimensions of the notice must measure 841mm x 594 mm (A1) with any text on the notice to be a minimum of 30-point type size;
ii) the notice is to be durable and weatherproof and is to be displayed throughout the works period;
iii) the approved hours of work, the name of the site/ project manager, the responsible managing company (if any),its address and 24-hour contact phone number for any inquiries, including construction/ noise complaint must be displayed on the site notice; and
iv) the notice(s) is to be mounted at eye level on the perimeter hoardings/fencing and is to state that unauthorised entry to the site is not permitted.
Site Notice in place at Little Uralba Street. Signage included: Name of project, principal contractor, name and contact number of the site manager and project manager, after hours contact, site office address. Signage dimensions appear to be appropriate, is in good conditions and was mounted at eye level at the entry of the construction site.
Audit Compliance Codes: NC: No-Complaint; NT: Not triggered; OFI: Observation for Improvement AQ1238.01B ENVIRONMENTAL AUDIT REPORT ‐ LBH STAGE 3C ‐ 20181221 FINAL PAGE 24 OF 31
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4.3 8.1 C3 Operation of Construction Plant and Equipment All plant and equipment used on site, or to monitor the performance of the development must be:
a. maintained in a proper and efficient condition; and b. operated in a proper and efficient manner.
Plant hazard assessment to Tower Crane was completed - Lindores. Also a weekly log book is maintained sighted Tower Crane Daily/Weekly Safety & Service Log – 19/11/18-25/11/18 No. 69407023. Elevated Working Platform Log Book dated 29/11/18.
4.4 C4-C6 Construction Hours Construction, including the delivery of materials to and from the site, may only be carried out between 7am and 6pm, Mondays to Fridays inclusive; and between 8am and 1pm, Saturdays. No work may be carried out on Sundays or public holidays. Activities may be undertaken outside of the hours in Condition C4 if required:
a. by the Police or a public authority for the delivery of vehicles, plant or materials; or
b. in an emergency to avoid the loss of life, damage to property or to prevent environmental harm.
c. works are Inaudible at the nearest sensitive receivers.
d. works are approved in advance in writing by the Planning Secretary and sufficient justification is provided for the works.
Notification of such activities must be given to affected residents before undertaking the activities or as soon as is practical afterwards. Rock breaking, rock hammering, sheet piling, pile driving and similar activities may only be carried out between the 9am to 12pm, Monday to Friday; 2pm to 5pm Monday to Friday; and 9am to 12pm, Saturday.
Construction Hours are as per CEMP - Section 5.1 of the CEMP indicates the hours of work Mon-Fri 7am-6m, Sat 8am-1pm and no work on Sunday or public holidays. No ‘Out of Hours’ works have been carried out so far for Stage 3C. Not required so far. Section 5.1 of the CEMP includes the same hours of work for Rock breaking, rock hammering, etc. However this requirements is not applicable as these activities will not be carried out for Stage 3C.
4.5 8.1 C8 Construction Traffic All construction vehicles (excluding worker vehicles) are to be contained wholly within the site, except if located in
There is a loading/unloading area on Little Uralba St, also concrete trucks to access via the southern end of little Uralba St. Confirmed during the site walk.
Audit Compliance Codes: NC: No-Complaint; NT: Not triggered; OFI: Observation for Improvement AQ1238.01B ENVIRONMENTAL AUDIT REPORT ‐ LBH STAGE 3C ‐ 20181221 FINAL PAGE 25 OF 31
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an approved on-street work zone, and vehicles must enter the site before stopping.
4.6 C10 SafeWork Requirements To protect the safety of work: personnel and the public, the work site must be adequately secured to prevent access by unauthorised personnel, and work must be conducted at all times in accordance with relevant SafeWork requirements.
PPE worn by workers sighted on construction site. Hospital security guards do patrols at night around the Hospital and construction site work area and site compounds. There is wire on top of the mesh.
4.7 C11 No Obstruction of Public Way The public way (outside of any approved construction works zone) must not be obstructed by any materials, vehicles, reuse, skips or the like, under any circumstances, unless there is prior written approval from the relevant authority. Non-compliance with this requirement will result In the Issue of a Notice by the relevant Authority to stop all works on site.
One street was closed for the construction site to take place. That is Little Uralba Street. No other public areas have been obstructed by the construction works. Traffic Control Plans are in place, when there is road closure or any obstruction will take place. Sighted TCP for Crane Set-up.
4.8 8.1 C12 Construction Noise Limits The development must be constructed to achieve the construction noise management levels detailed in the Interim Construction Noise Guideline (DECC, 2009). All feasible and reasonable noise mitigation measures must be implemented and any activities that could exceed the construction noise management levels must be identified and managed in accordance with the management and mitigation measures identified in the approved CNVMP.
Project has not exceeded the required noise levels. Noise monitoring happens, as required. The Acoustic Logic Report includes a list of activities that will be carried out in the project Stage 3C and there is no need for a permanent noise monitoring device on site.
4.9 8.1 C19, C20
Dust Minimisation The Applicant must take all reasonable steps to minimise dust generated during all works authorised by this consent. During construction, the Applicant must ensure that:
a. exposed surfaces and stockpiles are suppressed by regular watering;
During the site walk dust was sighted on Level 8 and 9. John Holland did a clean-up (vacuum and wet-sweep) of the rubbish on scaffold, timbers left in set-downs, and concrete dust accumulated on the slab.
a. Complaint b. Confirmed
Audit Compliance Codes: NC: No-Complaint; NT: Not triggered; OFI: Observation for Improvement AQ1238.01B ENVIRONMENTAL AUDIT REPORT ‐ LBH STAGE 3C ‐ 20181221 FINAL PAGE 26 OF 31
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b. all trucks entering or leaving the site with loads have their loads covered;
c. trucks associated with the development do not track dirt onto the public road network;
d. public roads used by these trucks are kept clean; and
e. land stabilisation works are carried out progressively on site to minimise exposed surfaces
c. If needed will clean the street d. Complaint e. All gravel. Streets are in good conditions
4.10 C21 Disposal of Seepage and Stormwater Not to be pumped to the street stormwater system unless approved
There is an underground basin connected to stormwater system from Council. Basin measurements 97.2m3 – 4.5 x 12 x 1.8m. Environmental Representative undertakes monthly visual inspection of the basin to check any sediments. So far the water appear to be cleared.
4.11 8.1 C22, C23
Waste Storage and Processing Waste must be secured and maintained within designated waste storage areas at all times and must not leave the site onto neighbouring public or private properties. All waste generated during construction must be assessed, classified and managed in accordance with the Waste Classification Guidelines Part 1: Classifying Waste (EPA,2014).
There is a designated area and a Richmond Waste Bin in place on the ground floor. Also, each floor has a waste bin in place. Waste report received from Richmond Waste. Sighted report for October 2018 indicating the amounts and type of waste.
4.12 Emergency preparedness and response
4.13 8.2 The Contractor has established procedures to: a. identify potential emergency situations and
potential accidents that can have an impact(s) on the environment
b. determine how it will respond to them
Workplace Emergency Response Plan LBH-PP-JH-0012-07-ERP (Rev. 7 dated 27/7/18) in place for Lismore Base Hospital project. Evacuation Diagram was displayed in site shed including emergency assembly point, location of first aid kits and emergency contact lists. Emergency exit signs located at each floor.
4.14 8.2 The emergency response procedures include measures to prevent or mitigate associated adverse environmental impacts.
Workplace Emergency Response Plan includes environmental emergencies such as: air supply contamination, spill/release, etc. Spill kits were available, sighted spill kit at level 10 and ground floor were sighted during site walk.
Audit Compliance Codes: NC: No-Complaint; NT: Not triggered; OFI: Observation for Improvement AQ1238.01B ENVIRONMENTAL AUDIT REPORT ‐ LBH STAGE 3C ‐ 20181221 FINAL PAGE 27 OF 31
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4.15 8.2 Emergency preparedness and response procedures are periodically reviewed and revised, as necessary, in particular, after the occurrence of accidents or emergency situations. Emergency preparedness and response procedures are periodically tested, where practicable
Note: Emergency evacuations drills have not been carried out yet.
4.16 Incident Management
4.17 C26 The Department must be notified in writing ID [email protected] immediately after the Applicant becomes aware of an incident The notification must identify the development (Including the development application number and the name of the development if it has one), and set out the location and nature of the Incident. Subsequent notification must be given and reports submitted in accordance with the requirements set out in Appendix 1.
Section 7.5.2 of CEMP has details for incidents management. There is also an Incident procedure from John Holland JH-MPR-SQE-010 in place. No environmental incidents have been reported so far for this project.
5.0 Performance Evaluation (9.0)
5.1 Monitoring and measurement
5.2 9.1 Documented procedures have been established to monitor and measure on a regular basis the key characteristics of operations that can have significant environmental impacts.
CEMP Section 10 Table 13 includes all the monitoring and reporting details. Environmental inspections are undertaken on weekly basis by Environmental Representative. Also, construction work site checklist is completed by CBRE and John Holland on fortnightly basis.
5.3 9.1.1 The procedures include: c. the documenting of information to monitor
performance d. effectiveness of applicable operational controls e. conformity with the organization's environmental
objectives and targets
Section 10 of CEMP indicates inspections checklists and corrective actions will be used.
Audit Compliance Codes: NC: No-Complaint; NT: Not triggered; OFI: Observation for Improvement AQ1238.01B ENVIRONMENTAL AUDIT REPORT ‐ LBH STAGE 3C ‐ 20181221 FINAL PAGE 28 OF 31
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5.4 9.1.1 Monitoring and measuring equipment is calibrated, maintained and stored as necessary. Records or calibration are maintained
Section 10 of CEMP indicates that calibration of monitoring equipment will be recorded in the project pack M&E register. Calibration record sighted for sound level meter unit previously used on site (last used during previous demolition phase early 2018 dated 12/10/17). No noise monitoring has been required for the current stage 3C. In the event that monitoring is required JH would borrow a calibrated unit from the Sydney office.
5.5 Internal Audit
5.6 9.2 The Contractor has ensured that internal audits and monitoring of the EMS are conducted at planned intervals to determine:
a. whether it conforms to planned arrangements for environmental management including the requirements of the Standard
b. whether it has been properly implemented and is maintained
Section 11 of the CEMP indicates that environmental audits of the project are taken in 3 types: project audits, JH internal audits and 3rd party audits (this one). Internal audits are conducted initially within 12 weeks and 6-monthly thereafter. Independent Environmental Audits (3rd party) will be carried out every 6 months as indicated in the Audit Program sent from CBRE to Health Infrastructure. John Holland has a HSEQ Internal Audits Schedule for 2018. Sighted HSE Risk 3 month look-ahead tool with audits for Nov 2018 to Jan 2019.
6.0 Improvement (10.0)
6.1 Nonconformity, corrective and preventive action
6.2 10.2 Procedures are in place for: a. identifying and correcting nonconformities and
taking actions to mitigate impacts b. investigating nonconformities, determining their
causes and taking actions to avoid their recurrence c. evaluating the need for actions to prevent
nonconformities or avoid their occurrence d. recording the results of actions taken e. reviewing the effectiveness of corrective and
preventive actions
Section 10 of CEMP indicates that results of audits will identify non-conformances and corrective / preventive actions. No non-conformances or corrective actions have been raised for this project so far. Zero EPA breaches.
6.3 10.2 Any necessary changes arising from corrective and preventive actions are reflected in the EMS documentation.
No reviews or changes have been required so far.
AQ1238.01B ENVIRONMENTAL AUDIT REPORT ‐ LBH STAGE 3C ‐ 20181221 FINAL PAGE 29 OF 31
Appendix D. Audit Photos
Photo 1 – Construction Site Notice displayed at the entrance of project Photo 2 – Steel installation works at Level 10
Photo 3 – General purposes bin located for mix rubbish at Level 10 Photo 4 – Scaffolding at Level 7
AQ1238.01B ENVIRONMENTAL AUDIT REPORT ‐ LBH STAGE 3C ‐ 20181221 FINAL PAGE 30 OF 31
Photo 5 – Silt fence located at the Ground floor Photo 6 – Richmond Waste bin located at loading area
Photo 7 – Sedimentation control between loading area and site sheds Photo 8 – Geotextile covering pit
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Photo 9 – Scaffold Tag Photo 10 – Sedimentation controls at the end of Little Uralba Street
Photo 11 – Level 8 vacuumed and wet‐swept Photo 12 – Scaffold in Level 9 clear of rubbish
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