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EMP vs RMMP: what's the difference?

4 minute read

Clarifying two terms that are often used interchangeably. Last reviewed June 2026.

EMP vs RMMP: what's the difference?

An Environmental Management Plan (EMP) and a Risk Management and Monitoring Program (RMMP) are closely related documents built on the same risk-management framework — both are used to demonstrate compliance with Victoria's General Environmental Duty under the Environment Protection Act 2017. The key difference is context: an RMMP is the specific document that certain EPA permission conditions require licence and permit holders to prepare, while EMP is the broader term for a documented environmental management system that any business can use to show how it manages risk — whether or not it holds a permission.

What is an RMMP?

A Risk Management and Monitoring Program is a document that records how a permission holder proposes to minimise risks of harm to human health or the environment, in accordance with the General Environmental Duty. EPA Victoria's guidance, Preparing a risk management and monitoring program, sets out the expected framework.

Certain EPA permissions carry a condition requiring an RMMP. These include conditions on operating licences, development licences, pilot project licences, permits, and authorisations of discharge and disposal. The RMMP must generally be documented in writing, signed by an authorised officer of the business, and made available to EPA on request.

An important point EPA itself makes: complying with an RMMP permission condition does not automatically mean a business is complying with the General Environmental Duty. The RMMP is how compliance is demonstrated — but the duty to actually minimise risk so far as reasonably practicable stands on its own.

What is an EMP?

An Environmental Management Plan is the broader document that sets out how a business identifies, controls and monitors environmental risk at a site. It serves as both a working management system and a regulator-facing record. An EMP uses the same backbone as an RMMP — site description, conceptual site model, risk assessment, controls, performance objectives, monitoring, incident response and review — and is the natural document where compliance needs to be demonstrated but a specific RMMP permission condition is not the trigger (for example, when responding to an EPA notice, or proactively managing the General Environmental Duty). See What is an EMP? for the full picture.

How they overlap

In practice, EMPs and RMMPs share the same structure. Both are built around the EPA's risk-management process:

  • Describe the site — activities, environmental setting, sensitive receptors and a conceptual site model.
  • Manage the risk — identify hazards, assess risks, implement and check controls, and manage change.
  • Set performance objectives — environmental and risk-control objectives, with indicators.
  • Monitor — operational and environmental monitoring, trigger-action responses, evaluation and continuous improvement.
  • Plan for incidents — incident and emergency management and reporting.
  • Train people and keep the document under review.

Because the frameworks align so closely, a well-prepared plan can often serve either purpose — a permission condition or a broader duty — provided it is scoped correctly from the outset.

Which one applies?

  • A business holding an EPA licence or permit with an RMMP condition needs an RMMP that satisfies that condition.
  • A business that has received an EPA notice requiring an environmental management plan needs an EMP scoped to satisfy the notice. See Received an EPA notice?
  • A business demonstrating compliance with its General Environmental Duty proactively is generally best served by an EMP.
  • Where it is unclear which applies, an environmental consultant can determine the right document. See Do I need an EMP?

Frequently asked questions

Is an EMP the same as an RMMP?

They are closely related but not identical. An RMMP is the specific risk-and-monitoring document required by certain EPA permission conditions. An EMP is the broader term for a documented environmental management system. Both demonstrate compliance with the General Environmental Duty and share the same risk-management framework.

Does an RMMP mean a business is complying with the General Environmental Duty?

Not automatically. EPA is explicit that complying with an RMMP permission condition does not, on its own, mean a business is complying with the General Environmental Duty. The RMMP documents and demonstrates compliance, but the duty to genuinely minimise risk applies independently.

Which EPA permissions require an RMMP?

Conditions requiring an RMMP appear on permissions such as operating licences, development licences, pilot project licences, permits, and authorisations of discharge and disposal. The conditions on the specific permission should be checked.

Can one consultant prepare both?

Yes. Because EMPs and RMMPs share the same underlying framework, a consultant experienced in Victorian EPA requirements can prepare whichever document the situation calls for.

Related reading: What is an EMP? · Do I need an EMP? · Where to get an EMP

This article is general information, not legal advice. EPA guidance does not impose compliance obligations and is not a statement of the law. Professional advice should be obtained for specific circumstances.