Incident and emergency management are key requirements under:
- Section 25 of the EP Act: the GED
- Section 31 of the EP Act: the duty to take action to respond to harm by a pollution incident
- in some cases, permission conditions.
It is important to include environmental emergency and incident management plans and procedures in your RMMP as they are key controls for minimising risks.
Incident management
An environmental incident is a departure from standard operating conditions that can or does have an impact on human health or the environment. Examples of environmental incidents may include:
- an emergency
- pollution and notifiable incidents (Part 3.4 of the EP Act)
- an event that poses a threat to human health or the environment (which does not necessarily trigger Part 3.4 of the EP Act)
- noncompliance with a permission condition
- noncompliance with an environmental performance indicator
- a complaint received regarding an environmental issue
- a failure of pollution controls.
Your RMMP should include a description of your environmental incident management procedure and supporting systems and how these are used to inform any reviews and prevent recurrence.
This environmental incident management procedure should identify:
- the purpose and scope of the procedure
- responsibilities
- criteria for incidents, including the distinction between an incident, notifiable incident and emergency
- types of incidents and management of those incidents
- notification requirements (including, but not necessarily limited to, notifying EPA)
- incident investigation
- corrective actions
- record management.
It is common practice to describe how you use the lessons learned from incidents, near misses and emergencies to review your risk register. These can provide valuable insight into unforeseen risks or failure of controls. EPA expects your RMMP reviews (see Reviewing your RMMP) to be informed by your incident records and past performance.
The description in your RMMP should also include a list of the types of events that would be considered an environmental incident at your site.
These should be consistent with your risk register (see Risk register).
Emergency management
An emergency is an unplanned event or accident that causes or threatens to cause severe harm to human health, property or the environment. An emergency requires immediate action to reduce its impact and escalation. Emergency events might involve fire, flood, a hazardous spill (for example, from tank or pipe failure), vehicle impact or sabotage.
As part of your RMMP, EPA expects you to have an emergency management plan in place, which ensures that if a risk of harm to human health or the environment from pollution or waste did occur, its harmful effects would be minimised.
Emergency management plans typically include:
- a description of the types of emergencies that may occur, as identified through your risk assessments
- methods for mitigating the environmental impacts
- communications and reporting requirements to EPA
- training of emergency response personnel
- post-emergency actions.
Your emergency management plan should be described in your RMMP and may be included as an attachment or reference.
For guidance on developing an emergency management plan, see part 6 of Management and storage of combustible and waste materials (Publication 1677).
Reporting incidents and emergencies
You should have a documented procedure for the reporting of incidents, emergencies and near misses.
The reporting process should include:
- details of the incident
- the response to the incident
- outcomes of any remedial actions taken
- investigations into the cause of the incident
- actions taken to prevent recurrence.
EPA expects your incident reporting procedure to identify internal and external reporting requirements, such as those imposed by your permission conditions and Part 3.4 of the EP Act – Duties relating to pollution incidents.
The procedure should describe the types of incidents that may be reportable to EPA. For example, mercury exceedances from a stack, uncontained spills and discharges, or unplanned operational upsets causing significant dust or odour with impacts beyond the site boundary.
Updated