| Brief Description of Assignment |
: |
The Scope of service of Environment Counselors includes, but not limited to the following:
A. Scope of work related to environmental monitoring, regulatory and safeguard issues are described below where, the Environment Counselors will work under the PIU and co-ordinate with the ES cell of BEZA and shall:
1. use appropriate environmental inspection form during monitoring and inspection of any given enterprise of the EZ. Environmental Counselors be appropriately trained on using of the inspection forms and conducting inspections at the EZ enterprises;
2. Work closely with Environment Consultant, Environmental and Social cell of BEZA, various agency associated with the sub-project such as Design and Supervision Consultant, master Developers, Contractors, investors, etc. and ensure that all the activities and measures are implemented as per the ESMF/ESMP;
3. Review various environmental and other safeguard documents with regard to their compliance with ESMF/ESMP;
4. Monitor and counsel on the environmental management issues including regulatory requirements such as, issuance of NOC/ECC, environmental management plan, effluent discharge, sludge management, air emissions, noise, chemical and hazardous materials management, solid and hazardous waste management, emergency response and cleaner production, environmental awareness and training, Environmental Best Management Practices for promoting house-keeping, energy/water use efficiency, low carbon emission technologies etc. of the enterprises of BSMSN and other EZs (as required by BEZA) as appropriate and report to the Project Director and the Authority;
5. Carry out regular visits to sub-project implementation sites to supervise as well as provide onsite guidance to the Master Developers, investors and the contractors on the implementation environmental management procedures of BSMSN Development project;
6. Support, assist and cooperate with the environmental lab analyst/technicians for BEZA Green Laboratory in BSMSN with a view to ensure standard operation and maintenance, implementation of testing and quality controls as per the type, range and volume of the environmental testing services such as sample collection, handling, transportation, preservation, test report delivery, waste disposal, instrumental handling, troubleshooting and maintenance etc.
7. Prepare and submit monthly progress reports and quarterly progress reports to the PD, on all the aspects related to the environmental compliance in EZs;
8. Follow up with BEZA, the Master Developer and the contractors, and other agencies in addressing various environmental safeguard actions agreed with the GoB and the World Bank from time to time and provide timely update to the CCU and the Bank.
9. Receive direction from Environment/Social Consultants, Environmental and Social Cell and assist BEZA for overall environmental monitoring activities.
B. The scope of work related to on-site inspection, environmental sampling and reporting in EZs will include, but not be limited, to the following:
On-Site Inspection Activities for ETP /STP/ATP/Waste Management
a. Purpose of Inspection: The Environment Counselor will inspect enterprises operations to gather information about the enterprise’s compliance or noncompliance as per requirement of the law of the land i.e. environmental laws, regulations and policies. The purpose of the inspection is to ascertain compliance or non-compliance and the environmental integrity of site conditions and enterprise operations.
b. Upon Arrival at Site: Even if the Environmental Counselor knows where to go in the plant, he should go to the main office first to identify himself and to notify the plant officials or any other person of his presence. Although the Environmental Counselor has the authority to enter to conduct an inspection, he should avoid walking around the site without the knowledge of the company’s personnel for safety reasons. The inspector may use camera to keep evidence of his inspection.
Inspections may either be announced or scheduled with the enterprise before hand, or conducted at random without prior scheduling.
c. Sampling Identification and Labeling: In the case of sampling, each sample container shall indicate:
Name and Address of the industry, Sample number, Sample location, Collection date and time, Field preservation of the sample, Required analysis, Sample collected by, Remarks/ special instructions, Initial of enterprises responsible staff on the sample container
d. Inspection Forms: The Environment Counselor will complete the appropriate Inspection Forms for each inspection.
The following information at minimum should be included, in the case of sampling:
# Name and location of the Industry, Date & Time, Location and field sketches, Sampling purpose, Contact names, Sample location (end of the pipe/discharge point), Sample description, Observations, Field measurements (TDS, pH, DO, Temperature, Electrical Conductivity etc), Weather conditions, i.e. temperature, rainfall etc (anything else that may affect the integrity of the sample).
Other pertinent information from the Inspections Forms must also be completed, as noted on each Form.
e. Packaging and Labeling of Samples: All collected samples must be properly packed to ensure sample integrity, required for proper analysis. This means:
# Preventing breakage, Absorbing leakage.
All packaging and labeling must link completely with paperwork regarding:
# Seals on the containers, Scribes on glass bottles, Initials of the sample collectors, Identification of industry and location of sample, Dates and times of sampling.
If there is reason to believe that there is a violation that must be corrected immediately, tell the person in authority. Inspectors must tell a person in authority at the enterprise about any violation that they have a reasonable ground to believe may occur, is occurring or has occurred. In exigent circumstances, they can issue a direction verbally where the environment, human life or health is at risk and at the same time report it to the Zone Authority.
ii. Post Inspection Activities
The post inspection activities that occur at the office are critical to an inspection’s overall success. Much of the post inspection activities are administrative and therefore good office practices should not be underestimated.
a. Samples to the Laboratory: Environmental Counselor will coordinate the steps of collecting wastewater, sludge or any other waste samples during any given inspection. Any samples should be collected during an announced or unannounced inspection following the national protocols of sample collections. To preserve the integrity of the samples, it should be delivered to the DoE or DoE certified lab as soon as possible for analysis.
b. Sample Custody: A sample is under custody if:
# It is in your possession; It is in your view after being in your custody; It is held in a designated secure area.
A chain of custody is established when a reconstruction of who had access to the sample from the time it was collected until final analysis is completed regardless of which team member actually collected the evidence.
c. Enter the Inspection Information into the Database: After the inspection, all relevant information must be entered into a database, including inspection, enforcement and response to violations, if and when such database becomes available.
d. Generate an Inspection Report: An Environmental Counselor shall generate his/her inspection report soon after he/she has completed his/her site inspection. A fresh memory results in the best report. The Inspection Report is a complete and concise statement about what happened during an inspection. The report does not have to be fancy or elaborate but it does have to be factually correct and accurate. The report should be sent to the Person Responsible for Environmental Management of the respective.
e. Follow-up Action: The Environmental Counselor must keep track of the time limits set in the authority’s instructions to the company for any action/enforcement that the authority wanted the company to undertake. A plan should be made to conduct a follow-up inspection sometime after this deadline to determine compliance. Enforcement actions include fines, penalties or other punitive measures based on the violations or non-compliant activity in questions will be established by the EZ Authority.
If a violation is not found and a follow-up inspection is not deemed necessary, the industry should at least receive a letter with a summary of their effluent test results after the approval of the authority. |
