Your RMMP is a documented approach to ensuring the risks associated with your activities are eliminated or minimised in accordance with the GED. The steps below are designed to help you prepare the RMMP which you must maintain and make available to the Authority on request.

Understanding your organisation

The first step in developing your RMMP is to develop a clear understanding of the environmental setting of your activities. This will help you to identify and assess the various ways your activities can interact with and pose risks to the environment, and your responsibilities to protect the environment by minimising those risks. This can help you with developing a conceptual site model (see below for a description of this process), which will support your risk assessment.

Describe your activities

Arrange a dedicated time for a meeting attended by relevant personnel across multiple levels of the organisation, including operational staff, leadership and management personnel.

Your activities, for the purposes of this guide, are taken to include all operations, functions, receival and dispatch of substances, storage or possession of waste or any other substance or thing, chemical and physical conversion, or anything prescribed by the Act to be an activity.

Starting from site inputs (raw materials), work your way through to site outputs (products and services) and waste streams, considering each element of the activities that is involved between these two points. For example, depending on the activities conducted at your site, your RMMP may include, but is not limited to:

  • raw materials – their nature, source, and storage;
  • waste acceptance processes;
  • energy sources;
  • energy stores (above ground and underground fuel storage tanks, batteries, capacitors);
  • internal materials handling such as bulk storage and its containment – including secondary containment of materials such as bunding of liquids;
  • hazardous materials;
  • process streams – step through each stream and identify how each step may be hazardous to the environment. Include discharge points – both fugitive and controlled;
  • your products – their nature (such as their chemical composition or physical properties), handling, storage at, and transport from the site;
    waste-generating activities – where each waste is generated, its nature and quantity, where it is stored, its transport from the site, and where it is disposed of;
  • environmental protection equipment – noise shrouds, dust extraction hoods and filters, air scrubbers, bunding;
  • site drainage systems, including segregation of liquid process wastes and protection of surface water;
  • process upsets such as break downs, failure of environmental protection equipment;
  • procurement decision philosophy and how it might include consideration of environmental consequences of various decision drivers;
  • engineering maintenance programs including those for environmental protection equipment;
  • management of contractors or other external personnel working at your site, including induction, training and supervision;
  • decommissioning of equipment;
  • change of activities;
  • plant closure and site remediation (partial or complete site closure); and
  • site security.

Once you have prepared a description of your site activities, spend some time walking around the site to check how well your description reflects all elements of actual day-to-day activities. After an appropriate time (for example a week) you may wish to tweak the description to add some details or amend others. Always chat with the people who are doing the actual work. They may handle materials in ways that you were unaware of and be aware of discharges you had missed. This description should be regularly reviewed (see description of review process below) to ensure its currency. This should happen at least annually, or after each change to activities, environmental incident, or receipt of a complaint.

Describe your environmental setting

Determining the risk to the environment presented by your activities initially involves identifying all major elements of the surrounding environment. These may include physical components (such as local airshed, land, surface waters, and groundwater), biological components (animal and plant communities), and social components (nearby residential areas, schools, hospitals, cultural land uses).

Describe the expectations of interested parties

Interested parties can be both internal and external. Considering interested parties early in the assessment process provides those parties with an opportunity to express their thoughts about the site’s performance and ongoing environmental risks. It also gives everyone clarity about the assessment process and how decisions are made.

Internal interested parties

Key internal interested parties can include general managers, in-house experts, section managers, and, importantly, those personnel involved in the hands-on conducting of the activities. Bear in mind that risk management is the responsibility of every employee, from the managing director through to the employee sorting materials in the lay-down yard. It must be supported and driven from the top but also encourage input from any employee who sees an incident, notices a hazard or identifies an opportunity for improvement.

If your activities are part of a larger company that has set corporate environmental performance standards over and above EPA licence requirements, you should consider inclusion of these requirements in your assessment if they are relevant to your activities.

External interested parties

External issues may include cultural, social, legal, regulatory, industry body, or financial considerations. Critical external party considerations for the RMMP are environmental protection obligations under the Act and conditions of your EPA licence.
Social components may be more important than you first think. If your activities have the potential to discharge, for example, odours, noise, dust, smoke, you may think these are just part of your normal activities. Some neighbours, especially those who have become sensitised to these emissions from prolonged exposure, may find even minute amounts of these discharges to be offensive. In such circumstances, you must consider the risks to human health and amenity.

Conceptual site model

A conceptual site model is an excellent way of capturing and presenting your collated information about site activities. A conceptual site model can be a flow diagram, ‘mind map’, web diagram or a diagrammatic representation of the site layout that depicts the relationships between:

  • site activities, hazards and the environment;
  • risk pathways; and
  • potential impacts on environmental receptors – and their environmental values.

Developing a conceptual site model has several benefits, including:

  • providing an easily understandable communication tool for conveying the risks, assumptions and uncertainties to all parties;
  • encouraging businesses to think through and clarify their assumptions about cause–effect relationships (how hazards and environmental aspects affect receptors);
  • identifying knowledge gaps and determining data needs;
  • assisting with the development of monitoring programs; and
  • providing a holistic view of a site’s activities.

Conceptual site models will vary in complexity, depending on your activities and their associated risks to human health and the environment. They should be tailored to fit the level of analysis required for the risk assessment. You might need to revise the model to allow for changes in activities and available information over time.

Sites with activities that present few risks may have a very simple model, whereas sites that present many high risks with complex interactions may require a series of models to show all relationships. You can have several models that take you from the broad scale down to a finer scale showing more detail. In some places you might include some text to explain the links.

It is also important that, where any assumptions have been made or knowledge is incomplete, these are identified, reviewed and documented as uncertainties. You should resolve these gaps as far as reasonably practicable and address any uncertainties. Data and information can be collected through monitoring to address these knowledge gaps and update the model during later revisions. This will build up the robustness of your model.

The valuable information you have collated in your conceptual site model then feeds into your aspects register, which forms part of the risk assessment.

Reviewed 9 March 2022