--- title: "RMMP Template & Checklist: What EPA Victoria Expects" description: "RMMP template and checklist: the sections EPA Victoria expects in your risk management and monitoring program, and how to self-check yours." --- [Skip to content](https://automatedenvironmental.com.au/industry-articles/rmmp-template-checklist-what-epa-victoria-expects-from-your-risk-management-plan#main) [![](https://automatedenvironmental.com.au/hubfs/ae-terminal/img/ae-mark-300.png) Automated EnvironmentalEnvironmental consulting · VIC](https://automatedenvironmental.com.au/) Services [**EMP**Environmental Management Plans*Planning & GED compliance for operations and construction*](https://automatedenvironmental.com.au/environmental-management-plans/) [**RMMP**Risk Management & Monitoring Programs*EPA licence & permit G05 conditions*](https://automatedenvironmental.com.au/risk-management-and-monitoring-program-development-rmmps/) [**LFG RA**Landfill Gas Risk Assessments*Developing near a current or former landfill*](https://automatedenvironmental.com.au/landfill-gas-risk-assessments/) [**PSI**Preliminary Site Investigations*Contamination screening for planning & due diligence*](https://automatedenvironmental.com.au/preliminary-site-investigations/) [**CEMP**Construction EMPs*The plan your planning permit condition asks for*](https://automatedenvironmental.com.au/construction-environmental-management-plans/) [**DIGITISED**Digitised compliance monitoring*Inspections, records and dashboards that stay current*](https://automatedenvironmental.com.au/digitised-compliance-monitoring/) [How it works](https://automatedenvironmental.com.au/how-it-works/) [About](https://automatedenvironmental.com.au/about/) [Insights](https://automatedenvironmental.com.au/resources-insights/) [Contact](https://automatedenvironmental.com.au/contact/) [1300 390 039](tel:1300390039) [Book a consultation](https://automatedenvironmental.com.au/contact/) ≡ [Home](https://automatedenvironmental.com.au/)/ [Industry articles](https://automatedenvironmental.com.au/industry-articles)/ Guide Guide · March 2026 # RMMP Template & Checklist: What EPA Victoria Expects From Your Risk Management Plan ## The RMMP Checklist Use this checklist to assess whether your RMMP is complete. Tick items that are fully addressed; note gaps for action. ### ☐ Document Control - \[ \] 1. Document has a version number and date of issue - \[ \] 2. A revision history records all previous versions with dates and change summaries - \[ \] 3. The document has been formally approved with a named approver, role, and date - \[ \] 4. A document owner is identified with responsibility for maintaining and reviewing the RMMP - \[ \] 5. The scope of the RMMP is clearly defined (which premises, activities, and areas it covers) - \[ \] 6. The relationship to other site documents is noted (e.g., links to Emergency Management Plan, other environmental plans) ### ☐ Site Description and Context - \[ \] 7. Site address, EPA licence number, and licence categories are stated - \[ \] 8. All licensed activities are described, not just the primary activity - \[ \] 9. A current site plan is referenced or included (showing buildings, drainage, chemical storage areas, sensitive areas) - \[ \] 10. The receiving environment is described — nearby waterways, groundwater, residential areas, conservation areas - \[ \] 11. Sensitive receptors within and adjacent to the site are identified - \[ \] 12. Relevant site history (contamination, incidents, regulatory actions) is noted ### ☐ Risk Identification and Assessment - \[ \] 13. The risk assessment methodology is documented (risk matrix included, with criteria for each consequence and likelihood category) - \[ \] 14. The risk assessment covers all licensed activities, including maintenance, loading/unloading, and contractor activities - \[ \] 15. The risk assessment addresses normal operations, abnormal/upset conditions, and emergency scenarios - \[ \] 16. Risks from all relevant environmental pathways are assessed: stormwater, groundwater, air, noise, waste - \[ \] 17. The risk register is presented in a table format with a minimum of: risk description, likelihood, consequence, risk rating (pre-controls), existing controls, residual risk rating, required action - \[ \] 18. All risks rated "high" or above have documented actions to reduce them to an acceptable level (SFARP) - \[ \] 19. The basis for the risk rating is defensible — low-rated risks are not simply dismissed without explanation - \[ \] 20. The risk assessment was conducted with input from people who know the site operations (operators, maintenance, EHS staff) - \[ \] 21. The risk assessment references relevant EPA guidance, codes of practice, or industry standards that informed the assessment ### ☐ Risk Controls - \[ \] 22. Controls are documented for all significant risks (not just the highest-rated risks) - \[ \] 23. Controls are described specifically — what the control is, where it is, how it works, who maintains it - \[ \] 24. The hierarchy of controls has been considered — engineering controls are preferred over administrative controls - \[ \] 25. A gap analysis has been conducted: additional controls required to reach SFARP are identified with a responsible person and target completion date - \[ \] 26. The control register is cross-referenced to the risk register (each risk can be matched to its controls) - \[ \] 27. Inspection and maintenance requirements for physical controls (e.g., bunds, interceptors) are documented ### ☐ Monitoring Program - \[ \] 28. A monitoring schedule/table is included covering all monitoring activities - \[ \] 29. Each monitoring entry specifies: parameter, monitoring method, monitoring location, frequency, trigger/action level, corrective action procedure - \[ \] 30. The monitoring program can be traced back to the risk register — each significant risk has at least one monitoring activity linked to it - \[ \] 31. Monitoring locations are shown on a site map (sample points labelled and referenced in the monitoring schedule) - \[ \] 32. Trigger levels are defined for all parameters — and the basis for each trigger level is documented (licence condition, EPA guideline, site-specific basis) - \[ \] 33. A corrective action procedure is documented for each trigger level — what happens when a result exceeds the trigger - \[ \] 34. Data recording and retention requirements are specified (format, storage, retention period) - \[ \] 35. Reporting requirements are addressed — when and how monitoring results are reported internally and to EPA ### ☐ Emergency Response - \[ \] 36. Emergency scenarios identified in the risk register are addressed in the emergency response provisions - \[ \] 37. Immediate response actions are documented for each emergency scenario - \[ \] 38. Notification procedures are documented, including EPA's 24-hour Emergency Line (1300 372 842) - \[ \] 39. Emergency response roles are named (by role, not just "Management") with current contact details - \[ \] 40. Emergency equipment is inventoried with locations referenced to the site plan - \[ \] 41. Post-incident review procedures are documented - \[ \] 42. Emergency response provisions have been reviewed within the past 12 months to ensure contact details and procedures are current ### ☐ Roles and Responsibilities - \[ \] 43. A table of roles and responsibilities covers all key RMMP activities (monitoring, inspection, corrective action, review) - \[ \] 44. Responsibilities are assigned to roles, not individuals by name (names change; roles persist) - \[ \] 45. Competency requirements for key roles are documented - \[ \] 46. Training records referencing the RMMP exist and are maintained ### ☐ Review Schedule and Records - \[ \] 47. The scheduled review interval is documented (and meets the minimum required under OL\_G5) - \[ \] 48. Material change triggers for unscheduled review are listed - \[ \] 49. The review process is documented (who reviews, how changes are incorporated, how revised versions are approved) - \[ \] 50. Records of previous RMMP reviews are maintained and accessible ### ☐ General Quality - \[ \] 51. The RMMP is site-specific — it couldn't be mistaken for a generic template - \[ \] 52. The document is internally consistent — cross-references between the risk register, control register, and monitoring program are accurate - \[ \] 53. Language is specific and actionable — not aspirational or vague - \[ \] 54. The RMMP has been reviewed by someone who wasn't involved in preparing it - \[ \] 55. The RMMP is readily accessible to staff and available to EPA on request --- **Score your RMMP:** Count the items ticked. A fully compliant RMMP should tick all 55 items. Gaps in the Document Control, Risk Assessment, and Monitoring sections are typically the most significant from EPA's perspective. --- ## Common Gaps — and How to Close Them Even experienced EHS teams miss these: **Gap: Monitoring frequency not matched to risk level** High-risk pathways (e.g., a bund area containing large volumes of a hazardous chemical adjacent to a waterway) should be monitored more frequently than low-risk pathways. If everything is monitored quarterly regardless of risk level, the monitoring program doesn't reflect a risk-based approach. *Fix:* Review each monitoring activity against the risk rating of the pathway it's monitoring. Increase frequency for high-risk pathways; document your rationale. **Gap: Trigger levels set at licence limits rather than action levels** Setting your trigger level at the EPA licence limit (the maximum permitted value) means you only act when you're at the boundary of compliance. You have no early warning system. *Fix:* Establish two-tier trigger levels: an Alert Level (lower threshold requiring investigation) and an Action Level (higher threshold requiring immediate corrective action). The Action Level can align with your licence limit; the Alert Level should be set below it. **Gap: Risk assessment doesn't cover contractor activities** Contractors working on site — maintenance contractors, tanker drivers, demolition contractors — introduce risks that your risk assessment needs to address. *Fix:* Add a section to your risk assessment that addresses contractor activities. Map contractor risks to your control register (e.g., contractor induction requirements, permit-to-work systems). **Gap: RMMP prepared but never communicated** The RMMP was prepared, approved, and filed — but the people responsible for implementing it have never been told what it requires of them. *Fix:* Hold a toolbox talk or training session on RMMP requirements for all staff with implementation responsibilities. Document the training. Update the RMMP's roles and responsibilities section if you find responsibilities were unclear. --- ## Aligning With the GED: What "SFARP" Actually Means for Your RMMP The General Environmental Duty's SFARP standard doesn't demand the absolute best controls in the world — but it does require you to demonstrate that you've **actively considered** what controls are available and chosen controls that represent a genuine, proportionate response to the risks. In practice, aligning your RMMP with the GED means: - **Referencing industry standards and best practice** — EPA codes of practice, industry association guidelines, and Australian Standards relevant to your activities should inform your risk assessment and control selection - **Updating controls as better options become available** — if a new technology or practice becomes standard in your industry, you should be evaluating whether to adopt it - **Documenting your reasoning for control choices** — if you've chosen a lower-cost control over a higher-cost one, document why the cost of the higher-cost option is disproportionate to the benefit The SFARP assessment isn't a one-time exercise. It's an ongoing obligation embedded in the review cycle of your RMMP. --- ## Review Frequency: What OL\_G5 Requires Most OL\_G5 conditions require: | Trigger | Review Required? | | --- | --- | | Scheduled interval (typically 3 years) | Yes | | Material change to licensed activity | Yes — within 12 months | | Significant environmental incident at site | Yes — promptly after incident | | EPA direction | Yes — within the timeframe EPA specifies | | Regulatory change (new licence condition, new EPA guideline) | Best practice — yes | A "material change" includes changes to: - Processes or production methods - Chemicals used or stored (new chemicals, increased quantities) - Plant or equipment (new or significantly modified plant) - Site layout, drainage, or containment - Throughput or operating hours - Key personnel with RMMP responsibilities Document the change in your RMMP's revision history and update the relevant sections. Don't just update the version number — ensure the content actually reflects the change. --- ## Download Our Free Fact Sheet For a concise reference summary of RMMP requirements, download our **[Fact Sheet on Preparing Comprehensive RMMPs](https://automatedenvironmental.com.au/hubfs/47551411/Fact%20Sheet%20on%20Preparing%20Comprehensive%20RMMPs.pdf)**. It covers the key content requirements and is useful for sharing with site management or board members who need to understand the obligation at a high level. --- ## Need Help Building or Reviewing Your RMMP? Automated Environmental has prepared RMMPs for EPA Victoria licence holders across a wide range of industries and licence categories. Whether you're starting from scratch, updating a document that's fallen behind, or preparing for an EPA audit, we can help you produce a compliant, practical RMMP that will hold up to scrutiny. [Learn more about our RMMP development service →](https://automatedenvironmental.com.au/risk-management-and-monitoring-program-development-rmmps/) [View all environmental compliance services →](https://automatedenvironmental.com.au/services/) --- ## Frequently Asked Questions **Q: Can I use this checklist to self-assess my existing RMMP before an EPA audit?** Yes — that's exactly what it's designed for. Work through the 55 items systematically. Any item you can't tick represents a gap you should address before EPA reviews the document. If you find significant gaps, prioritise fixing them rather than waiting for EPA to identify them. **Q: Our RMMP is 200 pages long. Is longer better?** Not necessarily. EPA Publication 1851.1 doesn't specify a minimum length — it specifies minimum content. A clear, well-structured 40-page RMMP with a tight risk register, specific controls, and a linked monitoring program will hold up better than a 200-page document that's padded with generic content and can't be followed by someone new to the site. Quality and clarity beat volume. **Q: How specific do monitoring trigger levels need to be?** Specific enough to be actionable. If your trigger level is "visually turbid", that's too vague — different observers will have different interpretations. If your trigger level is "TSS \> 50 mg/L (Alert) or \> 100 mg/L (Action) measured by \[Method X\]", that's actionable. For numerical parameters, your trigger levels should reference a specific value with clear units. For qualitative observations (odour, visual discharge), describe what the alert condition looks like as specifically as possible. **Q: Does the RMMP need to be certified or submitted to EPA?** Under OL\_G5, you are not required to submit your RMMP to EPA for approval unless directed to do so. You are required to maintain a current, compliant RMMP and make it available to EPA on request. EPA may review it during a scheduled licence audit, a complaint-response inspection, or an incident investigation. The obligation to ensure compliance sits entirely with you. Related reading: [How to prepare an RMMP](https://automatedenvironmental.com.au/industry-articles/how-to-prepare-an-rmmp-for-epa-victoria-complete-guide-2026) · [RMMP requirements for licence holders](https://automatedenvironmental.com.au/industry-articles/rmmp-requirements-for-epa-operating-licence-holders-what-you-need-to-know) · [EMP vs RMMP](https://automatedenvironmental.com.au/industry-articles/emp-vs-rmmp-whats-the-difference) · [What is an EMP?](https://automatedenvironmental.com.au/industry-articles/what-is-an-emp-environmental-management-plan) · [Environmental Management Plans (Victoria)](https://automatedenvironmental.com.au/environmental-management-plans/) *This article is general information, not legal advice. Professional advice should be obtained for specific circumstances.* ## Does this apply to your site? The first conversation is free, and we reply within one business day. 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If your trigger level is \"visually turbid\", that's too vague — different observers will have different interpretations. If your trigger level is \"TSS > 50 mg/L (Alert) or > 100 mg/L (Action) measured by [Method X]\", that's actionable. For numerical parameters, your trigger levels should reference a specific value with clear units. For qualitative observations (odour, visual discharge), describe what the alert condition looks like as specifically as possible." }, "name" : "How specific do monitoring trigger levels need to be?" }, { "@type" : "Question", "acceptedAnswer" : { "@type" : "Answer", "text" : "Under OL_G5, you are not required to submit your RMMP to EPA for approval unless directed to do so. You are required to maintain a current, compliant RMMP and make it available to EPA on request. EPA may review it during a scheduled licence audit, a complaint-response inspection, or an incident investigation. 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