Environmental performance is the ongoing process of assessment and improvement to continuously reduce (eliminate or minimise) your organisation’s risks of harm to human health and the environment. In assessing and reporting on your environmental performance, you need to consider:
- your obligations under the EP Act and Regulations (for example, GED)
- the conditions of your permission
- the environmental values listed in the Environment Reference Standard
- your organisation’s environmental policy
- environmental performance objectives and indicators
- risk control performance objectives
- industry or activity standards
- the implementation of an environmental management system framework (for example, AS/NZS ISO 14001:2016)
- your risk assessment
- past environmental performance
- any past incidents.
It is important to verify whether you are achieving your environmental performance targets. This typically involves collecting and analysing data and using metrics to track your progress against environmental objectives and measures.
Environmental performance objectives
Environmental performance objectives specify the goals that you set to eliminate or minimise identified risks from your activities. They define your desired outcomes for environmental performance and compliance. The objectives may reflect the commitments in your organisation’s environmental policy, if it has one.
Environmental performance objectives can focus on reducing key environmental risks related to your activities (such as risks to air or water quality) or a particular pollutant that is high risk They can be business-wide or site-specific and should be developed with input from your stakeholders.
To demonstrate continual improvement, environmental performance objectives should be meaningful and measurable. Where reasonably practicable they may go beyond base-level performance against statutory and licence requirements. They may also vary depending on the relevant timeframes they are assessed against.
Environmental performance indicators
Each environmental performance objective should have one or more associated performance indicators. These indicators track progress towards achieving your objectives. They need to be specific, measurable, achievable, relevant and time-bound (SMART). Monitoring these indicators helps you to understand whether you need to make any improvements or changes to your operations, environmental performance objectives or risk management processes.
Environmental performance indicators are different to licence limits. Licence conditions set an upper limit for emissions or discharges that you must not exceed. Complying with licence conditions does not necessarily mean you are minimising risks or improving your performance. Any additional measures you can take to reduce emissions or discharges should be included in your environmental performance objectives and reflected in your environmental performance indicators. This is one way to demonstrate how you apply the GED principles in practice.
Your environmental performance objectives and indicators should be clearly defined in your RMMP. For example, the information may be presented as a table or in dot points. Some examples of environmental performance objectives and associated indicators are below.
Examples of environmental performance objectives and associated indicators
Case study 1a
Risk control performance objectives
Setting risk control performance objectives provides a benchmark to assess how effectively your controls are working. They assist in identifying whether an implemented control:
- is functioning as intended; and
- is effective; or
- requires any corrective action.
Risk control performance objectives should be defined for your critical controls. Risk control performance objectives may be based on industry standards and codes. It is important that the key requirements you set for your risk control performance objectives are specific, measurable, achievable, relevant and time-bound (SMART).
The number of risk control performance objectives needed may depend on the complexity of your operations. For a site with simple operations, it may be possible to monitor the performance for all control measures. For a more complex site it may be more practical to group the risk control performance objectives. For example, you may group your risk control performance objectives according to key operational areas of your site or segments of the environment. Importantly, this should be done in a way that is meaningful for your organisation and for EPA.
You set risk control performance objectives with the intent of achieving your environmental performance objectives. Monitoring risk control performance objectives helps you understand how you are progressing toward your environmental performance objectives.
EPA expects you to clearly define your risk control performance objectives in your RMMP and demonstrate how they support your environmental performance objectives. Risk control performance objectives related to engineering or operational controls may be documented in your maintenance framework (for example, maintenance or asset management plans).
Example risk control performance objectives and indicators
Case study 1b
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