[Piers Pettit] Welcome to this quick video guide on the revised guidelines for risk management and monitoring programs, also known as RMMPs.
In this session, we'll go through a quick overview of our RMMPs and the guideline review process, the main outcomes from the public consultation, what's new in the guideline, what we did not change, some questions you may have about the guidelines, and, what's next?
Risk management and monitoring programs were introduced in 2021 as a condition in certain permissions.
The intent and purpose of RMMPs are to:
provide a systematic approach or framework for you to identify and manage your risks, demonstrate to EPA that duty holders have a risk management framework in place, help EPA determine compliance with permission conditions and duties under the Act, and help EPA officers to understand your site, the risks of harm from activities, and check the controls are effective.
We released a guideline to assist duty holders to prepare their own RMMPs when the permission condition was introduced in 2021.
And while that initial guideline met requirements, we heard your concerns that it needed more clarity around content, intent and purpose.
To improve the guideline, we drafted a revised version in 2025 and went out to public consultation via Engage Victoria to gather additional feedback.
Victorians had a choice of filling out a survey, uploading a submission or both.
We had strong participation across many sectors including waste and recycling, water, agriculture, small business and the resources sector.
We also received a small number of submission from consultants and community. And here is what we learn from this work.
The feedback we received was largely positive. Most participants considered the revised content an improvement.
The areas where participants thought we could be clearer was in minimising duplication, especially for those duty holders with multiple sites.
Participants were neutral about whether the case studies clarified expectations on preparing RMMPs.
We found the survey results echoed what people are saying in their written submissions.
The top themes for feedback identified were:
clarification: providing extra information on technical aspects of the guidelines
formats and documents: participants were still unclear about how to present their information
case studies and examples: examples reflected common and difficult scenarios where desirable and
mandatory versus advisory: provide more clarity around what information was mandatory and what was just recommended.
This feedback has shaped the updated guideline.
We'll now go through some of the key changes you will see in the guideline.
First, the title of the guideline has changed from 'Implementing the general environmental duty for licence holders' to: 'Preparing a risk management and monitoring program'.
We've reworked the structure of the guideline to be more logical and usable.
We've included a breakdown of sub elements of the G5 condition so duty holders can understand how to comply with each element of the condition.
This new section describes how to prepare and submit RMMPs.
This section details how we use your RMMP, the format and structure of RMMPs, including our preference for one document per site, specifically for those duty holders with multiple sites.
We've included some examples of how you could present your site description. We've given improved guidance around the risk management framework, particularly for things such as risk methodology and risk registers.
We've also introduced the concept of critical controls, which is closely tied with risk control performance objectives.
We heard that many duty holders found it difficult to define environmental performance and how to evaluate environmental performance, so we fleshed out these terms and others.
The monitoring section has been expanded where we've introduced trigger action responses and, as requested, we've included lots of examples and case studies to support the main content of the guideline.
Some of these examples include: a conceptual site model, a risk register, environmental performance objectives and indicators, risk control, performance objectives and indicators, trigger action response approaches, a monitoring plan and an example checklist to help you prepare your RMMP.
Some of the things that we have not added or changed are: an RMMP template, sector specific examples, examples of how to demonstrate 'so far as reasonably practicable', or changes to the permissions framework.
We have not: defined the risk appetite for duty holders to adopt for their risk management framework, or defined time frames and requirements for submitting and review of RMMPs. However, we have retained the distinction between environmental performance indicators and licence limits.
These things have not changed in the guidelines because our guidelines are intended to be generic and used across all licence sectors. It's difficult to create a one-size-fits-all solution for RMMPs, or, because they were out of scope and may be considered for future updates to other EPA guidelines.
Here are some questions that we can answer about the updated guideline.
For the first question, there's no need for duty holders to resubmit their RMMPs just because the guideline has been updated. However, you should review your RMMPs when certain things happen, such as when a scheduled review is due (such as yearly or two yearly), if an incident or near miss occurs, or if a case of non-compliance is identified.
The guidelines are for guidance only.
If a part of an RMMP is tied to a legal requirement, the guideline clearly say so through the use of the word 'must'.
The regulatory approach on RMMPs is to understand what's happening at the activity side, together with what's been documented in the RMMP.
EPA officers use the RMMP to understand the risks from the activities at a site and the controls in place to manage risks.
They also check how well you, as the duty holder are putting your risk management system into practise.
So, the guidelines have been updated and are now clearer and easier to use.
Visit the EPA website to read the guideline and understand how the guideline is a useful tool to help you manage your risks and comply with licence.
Visit Engage Victoria to read our response to public comment report which outlines in further detail the feedback we received, what we changed and what we didn't.
If you have any further questions or concerns, please get in contact with us at EPA.
Thank you.
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