Verification report examples

Example: Verification of a clean up plan under a remedial notice

We received a pollution report about a large chemical spill on unsealed soil at a chemical manufacturing plant. EPA authorised officers had reasonable belief the site had been polluted.

We issued a remedial notice with several requirements, including:

• the duty holder must develop a clean up plan
• an environmental auditor must verify the plan was prepared in accordance with EPA guidelines.

The duty holder engages a suitably qualified environmental consultant, and an EPA-appointed environmental auditor.

Before engagement

The environmental auditor confirms:

• they and their company have had no prior involvement with the site or duty holder which would compromise their independence
• they have the appropriate expertise to undertake the works.

Undertaking the verification

On receiving the clean up plan from the consultant, the environmental auditor:

• reviews the plan against relevant EPA guidelines for clean up plans, and any additional relevant requirements of the clean up plan and its verification outlined within the notice.
• notes several deficiencies and provides comments back to the consultant
• receives an updated clean up plan which addresses their comments
• prepares a verification report concluding the clean up plan in accordance with EPA guidelines that has achieved the requirements of the notice.

Given EPA is interested in ensuring the clean up plan is appropriate, the environmental auditor arranges a meeting to discuss their verification with EPA’s Environmental Audit Unit and the EPA officer who issued the remedial notice. During the meeting, the environmental auditor briefly explains the clean up plan and how they verified it.

Submitting the verification report

The environmental auditor completes and attaches the cover sheet to the verification report and submits it to the duty holder. The duty holder emails this to the EPA authorised officer who issued the notice.

After receiving the clean up plan and verification, EPA revokes the remedial notice. EPA issues a new notice to implement the clean up plan.

Example: Verification of a risk management and monitoring program (RMMP) as required by an EPA remedial notice

Medium-density fibreboard (MDF) manufacturer and wholesaler, Less Wood’s Good Pty Ltd, received an EPA improvement notice (IMPN-0000XXXX). EPA stated its risk management and monitoring program (RMMP) does not clearly identify all sources of dust and air emissions, and it is not clear whether the controls are effective.

The relevant EPA improvement notice requirement is:

By 03/04/2025 you must engage an independent EPA-appointed industrial facilities auditor appointed under Part 8.3 of the Environment Protection Act 2017 to verify that the controls stated in your risk management and monitoring program in relation to dust and air emissions are appropriate and effective.

Less Wood’s Good contacts an environmental auditor who explains that EPA requires a verification report.

Before engagement

The environmental auditor confirms:

• relevant details and requests a copy of the EPA improvement notice
• they and their company have had no prior involvement with the site or duty holder which would compromise their independence
• they have the appropriate expertise to undertake the works
• the scope of work to complete the verification, including:
  • review of existing reports and documentation to understand site conditions and potential risks
  • optional allowance for a virtual meeting with EPA and the duty holder (if required)
  • optional allowance for a site inspection for the environmental auditor to observe site activities, potential risks and current and proposed controls
  • review the RMMP and conduct a gap analysis of existing risks and controls in relation to dust and air emissions
  • preparation of an environmental auditor verification report.

The environmental auditor explains to the duty holder that EPA expects a verification report. The environmental auditor offers to meet with EPA to confirm details, if required. The duty holder agrees to proceed with the scope of work.

Undertaking the verification

The environmental auditor receives a copy of the RMMP and supporting documents from Less Wood’s Good. They undertake an inspection at the site, reviews the RMMP and considers whether it broadly meets the requirements of EPA’s guidance.

The environmental auditor provides comments for consideration including:

• some risks related to dust and air emissions did not appear to have been identified and assessed
• environmental performance objectives had not been clearly defined
• further discussion of risk control measures is required to provide an understanding of whether these manage risks so far as reasonably practicable.

Through providing comments and queries, the environmental auditor is careful not to direct the consultant or duty holder towards particular solutions, timelines, risk categorisations, etc. However, where the environmental auditor believes further information or consideration is required before they could verify that the EPA notice requirement has been met, they communicate this to the duty holder so that updates can be made as required.

The consultant responds to the environmental auditor’s comments and updates the RMMP. The finalised RMMP is then provided to the environmental auditor for review.

Writing the verification report

The background of the report summarises the reason and requirements of the verification.

The environmental auditor summarises the evidence they reviewed, as the example below shows.

Within the conclusion of the verification report the environmental auditor states:

EPA Improvement Notice IMPN-0000XXXX requires that the Industrial Facilities Auditor verify that controls stated in the Risk Management and Monitoring Program (RMMP) prepared for Less Wood’s Good Pty Ltd, in relation to dust and air emissions are appropriate and effective. As summarised above, the environmental auditor has reviewed the RMMP and supporting evidence and considers it has been prepared in general accordance with relevant EPA guidance on RMMPs

The environmental auditor recommends that if ongoing site inspections identify additional sources of dust emissions then the RMMP should be updated to address risks associated with these.

The environmental auditor completes a cover sheet. They attach the RMMP to the completed verification report.

Submitting the verification report

The environmental auditor provides the completed verification report to Less Wood’s Good. Less Wood’s Good emails a copy of the completed verification report to the EPA authorised officer who issued the notice.

Example: Verification of a hydrogeological assessment

The manager of a closed landfill site Room2Ntoom Pty Ltd contacted an environmental auditor to request verification of an updated hydrogeological assessment (HA). This was prompted by requirements of an EPA Environmental Action Notice (EAN-0000XXX).

The environmental auditor requests a copy, noting the following requirements:

• General requirement: By 11/03/25 you must engage a suitable qualified person to complete a Hydrogeological Assessment that is consistent with EPA Publication 668: Hydrogeological Assessment (Groundwater Quality) Guidelines, and has been verified by an EPA-appointed Environmental Auditor.
• Reporting requirement: By 01/04/25 you must provide in writing to the Authorised Officer listed on Page 1 of this Notice a Hydrogeological Assessment, that is consistent with EPA Publication 668: Hydrogeological Assessment (Groundwater Quality) Guidelines, has been verified by an EPA-appointed Environmental Auditor, and includes, but is not limited to:
  • a review of groundwater, leachate and LNAPL gauging data and laboratory analytical data available in historical reports;
  • an assessment of the adequacy of the groundwater, leachate and LNAPL monitoring network and potential data gaps;
  • the maximum levels of leachate to be maintained which minimises the impacts on groundwater and allows effective management of landfill gas.

The environmental auditor and duty holder agree on a scope for the verification engagement.

Undertaking the verification

The duty holder engages a consultant to complete the HA. The duty holder provides the environmental auditor a draft HA for comment. The environmental auditor provides comment on the draft HA. The duty holder (and their consultant) finalises the HA and shares it with the environmental auditor for review.

The environmental auditor uses a checklist to systematically review the HA for data quality, sources, consistency, accuracy and compliance with regulations. The environmental auditor fills out the HA checklist from Publication 668: Hydrogeological Assessment (Groundwater Quality) Guidelines (668.1).

Writing the verification report

The environmental auditor fills out the table below.

The environmental auditor critically evaluates the conceptual hydrogeological model and the risk assessment. This is to determine if they are adequate for assessing the risk of harm. This does not require the environmental auditor to conclude whether there is a risk of harm. Instead, it determines whether sufficient hydrogeological work has been completed or recommended.

In conclusion, the environmental auditor states:

• Based on the environmental auditor’s assessment as detailed within this verification report, the environmental auditor verifies that the ‘CS Environmental, 2025, Hydrogeological Assessment, 4 Perfect Parks Ave, Undertown, VIC’ meets the requirements of EAN-0000XXXX. Based on the environmental auditor’s review, the HA appears to support that risk is appropriately understood, or that otherwise, recommendations have been made to address data gaps.
• The environmental auditor notes that CS Environmental has recommended the installation of an additional groundwater well and minor update to the monitoring required by the RMMP. The environmental auditor recommends that the next environmental auditor verification of the RMMP includes consideration of whether these recommended updates have been incorporated.

Submitting the verification report

The environmental auditor includes the following attachments for completeness:

• Appendix A - Hydrogeological assessment checklist
• Appendix B – Current EPA Notice
• Appendix C - Hydrogeological Assessment Report
• Report coversheet:

The environmental auditor provides the completed verification report to the duty holder. The duty holder emails the verification report to the EPA authorised officer who issued the environmental action notice.