Use this checklist to assess whether your RMMP is complete. Tick items that are fully addressed; note gaps for action.
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.
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.
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.
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.
For a concise reference summary of RMMP requirements, download our Fact Sheet on Preparing Comprehensive RMMPs. 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.
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.
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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.