The purpose of an RMMP
As the holder of an operating licence or other permission with a G05/C05 condition, you have a legal obligation to prepare and document an RMMP.
Your RMMP is a systematic way of identifying and documenting risks to human health and the environment arising from activities at your site, and how those risks are assessed, controlled, managed and monitored.
Your RMMP should demonstrate to EPA that you have assessed and are regularly monitoring your risks and the effectiveness of your controls.
How EPA uses your RMMP
EPA uses your RMMP as a roadmap to understand what activities at your site may pose a potential risk to the environment or human health and how these risks are being minimised, controlled and monitored. For this reason, EPA expects that your RMMP is easy to follow and contains specific information and references as outlined in this guideline.
Preparing an RMMP
From Site Description to Training of this guideline describe the type of information to include in your RMMP (Part 1 of your GO5/CO5 permission condition).
To assist with meeting Part 2 of your G05/C05 permission condition, EPA expects the RMMP to be a single, consolidated document describing site activities, risks, and the controls used to manage those risks. Where controls rely on detailed monitoring, inspection, maintenance, or operational procedures, these documents should be referenced rather than included in full, with supporting documents included as appendices where practical. Extensive or frequently updated documents do not need to be appended. Referenced documents must be current and made available to EPA on request. Appendix A is an example of a checklist you may include to complete your RMMP submission.
EPA expects duty holders with multiple permissioned sites to have a separate RMMP for each of those sites. This is because risks at each site may vary depending on location, environmental setting and other factors. EPA uses this site-specific information to understand your activities, potential risks and associated controls for compliance assessments and site inspections. To ensure EPA has access to site-specific information and to avoid duplication, there is flexibility in presenting site-specific information in the main document and the common information as appendices (such as corporate standards).
A suitably experienced person, such as an environmental consultant, may assist you in preparing your RMMP. EPA’s website provides information on working with consultants.
It is important to consult with and involve your staff when preparing your RMMP. Having staff involved can provide valuable insights, practical knowledge and experience. This will help you to fully understand all your activities, the risks they pose to human health and the environment, and how those risks are to be managed. An RMMP is a living document. It should foster a sense of ownership and accountability, leading to better site management and environmental performance.
If you have a GO5/C05 condition in your permission, your RMMP must be signed by a ‘duly authorised officer’. This is a person who is accountable and authorised by your organisation to sign the document on its behalf. This authorisation is a matter for each organisation.
EPA may request a copy of your RMMP at any time. If you have a G05/C05 permission condition you must provide it on request. This means you should have an up-to-date RMMP (including supporting information) that can be provided to EPA by email, file share or other means.
Existing environmental management systems and plans
EPA acknowledges that organisations may have existing management systems or plans in place which coincide with some of the RMMP requirements described in this guideline. Those systems may be digitised and may be shared across similar sites. Examples of shared or digitised systems include:
- environmental management plans (including Waste Management Plan)
- incident reporting systems
- risk management systems
- internal auditing systems
- environmental policies and standards
- environmental performance objectives and reporting.
To avoid duplication, RMMPs may reference and link to existing documents or systems.
The RMMP is not intended to replace or duplicate your existing environmental management systems and plans. Any supporting documentation or digital systems that are embedded in your site management system may form part of your RMMP.
Your RMMP may contain a brief description of your existing systems and documents. You may provide a summary of the key information contained in those documents, with detailed references or links to fulfil RMMP requirements. These documents may include:
- plans
- process descriptions
- monitoring program reports
- data
- procedures
- human health and environmental impact assessments
- diagrams, drawings and flowcharts
- documents required as part of your licence or permission (for example, Health and environment management plan).
Implementing your RMMP
Your RMMP should accurately reflect your organisation’s operations, procedures and controls. When you have established your RMMP, your next step is to implement it.
These steps may include:
- defining roles and responsibilities so that each employee understands their part
- providing training to build awareness and competency
- establishing a system for continuous review and auditing to maintain the RMMP’s relevance and effectiveness over time (see Environmental performance).
Incorporating these elements will ensure your RMMP remains a dynamic and valuable tool for effectively managing your human health and environmental risks.
Reviewing your RMMP
EPA expects you to regularly review and update your RMMP to ensure it is current and relevant to your site activities.
Management of Change lists potential triggers for reviewing your RMMP.
You should clearly indicate the review frequency, date of the most recent review, name of the reviewer(s), and a summary of the key significant changes made based on that review.
It is important to evaluate the effectiveness of your RMMP throughout all stages of its implementation. This is part of a continuous improvement approach to managing your risks. In this way, your RMMP forms part of meeting your obligations to prevent or minimise risks under the GED.
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