By Automated Environmental · Last reviewed July 2026. General information for Victorian businesses — not legal advice.
The General Environmental Duty (GED) — section 25 of the Environment Protection Act 2017 — attaches to the conduct of your activities: it follows the organisation, not the premises named on the notice. Once a notice, incident or audit teaches your business about a risk and the controls that answer it at one site, the Act's state-of-knowledge test means you now know — or ought reasonably to know — about that risk wherever the same activity is carried on. And "reasonably practicable" is measured against that knowledge. So an EPA notice at one of multiple sites is, in substance, a question about all of them.
Section 25 requires you to eliminate, or otherwise reduce, risks of harm to human health and the environment from pollution and waste, so far as reasonably practicable. It applies to anyone whose activities create such a risk — every business, every site, at all times, with or without an EPA permission. A remedial notice, by contrast, is site-anchored: an authorised officer attended a premises and directed action there (see what notices EPA Victoria can issue). The notice names one address because that is where the officer stood; the duty was never confined to it.
EPA's guidance on the phrase (Publication 1856) weighs the likelihood of harm; the degree of harm, including impacts that add up over time; what you know, or ought reasonably to know, about the risk and ways of eliminating or reducing it; and the availability, suitability and cost of controls. And note: likelihood can be understood partly by whether the harm has occurred before on your site and whether it has commonly occurred on other sites — comparing sites is part of the test, and for a multi-site operator the nearest other sites are your own. Full explainer: our guide to "reasonably practicable".
The test is assessed against what you actually know and what someone in your circumstances should reasonably know about your risks and how to control them — your state of knowledge, which EPA expects you to keep current. A notice is knowledge of the most direct kind — a regulator telling you, in writing, that a specific risk at a specific site required action. Closing it out teaches you the gap and the controls that answer it. From that day, at any other site running the same activity with the same materials, that risk is something your organisation knows about — "we hadn't looked at the other sites" is no answer when the test asks what you ought reasonably to have known. And the bar keeps moving as knowledge and technology improve — see why the compliance bar rises over time.
The named site still comes first: the notice carries a hard due date, and penalties for missing it are considered under EPA's enforcement policy. Read it in full, diarise the deadline, respond to what it actually requires — step by step in Received an EPA notice in Victoria? If it directs an Environmental Management Plan (EMP), The EPA told you to get an EMP covers contents, cost and deadline. A notice complied with or revoked confirms you met that notice — not that EPA endorses your plan, and nothing about the sites it hasn't seen.
Once the named site is under control, ask what the notice implies. In our work with multi-site operators, this is the step most often deferred — the noticed site absorbs the attention, and the lesson stays where it landed. Three questions, asked honestly:
If an officer walked another of your sites tomorrow with Site A's questions, would the answers improve?
EPA's Compliance and Enforcement Policy (Publication 1798) sets out how it uses its powers: no tolerance for non-compliance, with proportionate regulatory action; decision-making criteria that include the consideration of risk and of behaviour and motivations for compliance; and compliance defined as an ongoing process of assessing risk and improving controls.
We can't tell you how EPA would weigh any particular case. But look at what those criteria make relevant. If the same risk later causes harm at another of your sites, the questions that follow are about knowledge and behaviour: what did the organisation know after the first notice, and what did it do with it? Treat the notice as a lesson and set a prioritised program moving, and you are doing what the policy calls compliance. File it as a single-site problem, and the account gets harder — not because a second notice triggers automatic escalation, but because your own state of knowledge is among the things the Act measures you against. You choose now which account is available later.
Two responses fail: every site an island, each waiting for its own notice; and panic — everything, everywhere, immediately — which collapses into little anywhere. The factors that define "reasonably practicable" also sequence a portfolio honestly:
And the economics improve: a framework built once is reused, so each added site takes less work than a standalone project — see the economics of multi-site compliance.
Three real ones. An in-house environment function with real capacity can run it — the duty doesn't oblige you to engage anyone. (Notices commonly direct a plan prepared by a suitably qualified person, sometimes an independent one; if yours does, in-house won't answer that limb.) Any suitably qualified environmental consultant can do it — look for Environment Protection Act 2017 fluency (not only ISO experience), portfolio thinking and a written fixed-fee scope. Doing nothing is not on the list: the notice has already told you what EPA thinks of the risk.
Automated Environmental is a Victorian environmental consultancy doing exactly this work — the urgent site first, then the framework across the rest. If you're mid-notice, send EPA's letter to us at /epa-notice/ and a consultant replies within one business day with a plain-English read of what it requires and your deadlines — free, confidential, no obligation. If the sideways look is the part on your desk, our multi-site EMP programs page explains how a portfolio program is scoped — a no-pressure way to work out what your sites actually need.
The notice's directions bind you at the premises it names, but the General Environmental Duty applies to the conduct of your activities at every site, at all times. What a notice teaches you about a risk and its controls joins your state of knowledge, and what is reasonably practicable at your other sites is assessed against it.
It is what you actually know, plus what someone in your circumstances should reasonably know, about your risks of harm and the ways of eliminating or reducing them. EPA expects businesses to keep that knowledge current, so what counts as reasonably practicable moves over time.
No. The notice and its deadline come first at the site it names. Across the rest, the test weighs likelihood, degree of harm, your knowledge, and the availability, suitability and cost of controls — so a documented, risk-ranked program is a reasoned way to respond. Leaving the other sites unexamined is not.
EPA's published Compliance and Enforcement Policy says its decision-making criteria include the consideration of risk and of behaviour and motivations for compliance, and defines compliance as an ongoing process of assessing risk and improving controls. How that is weighed in a particular case is for EPA, but what you knew and what you did about it sit squarely within those criteria.
Related reading: Received an EPA notice in Victoria? · What "reasonably practicable" means · Why the compliance bar rises · The economics of multi-site compliance
This article is general information, not legal advice. Notices carry hard deadlines — if you've received one, get advice specific to your situation promptly.