What is an EMP (Environmental Management Plan)?

For Victorian business owners and operators. Last reviewed June 2026.

What is an Environmental Management Plan (EMP)?

An Environmental Management Plan (EMP) is a written document that sets out how a business identifies, controls and monitors the environmental risks created by its activities. In Victoria, an EMP is the practical way a business demonstrates that it is meeting its obligations under the Environment Protection Act 2017 — in particular the General Environmental Duty (GED).

In short: an EMP is both a working management system that helps a site operate responsibly, and a regulator-facing record that can be provided to EPA Victoria to show risks are being managed "so far as reasonably practicable".

Why EMPs exist: the Environment Protection Act 2017

On 1 July 2021, Victoria's environment protection laws changed fundamentally. The Environment Protection Act 2017 moved away from the older licence-condition model — where the regulator specified exactly what each operator had to do — and towards a risk-based, duties model. The cornerstone of that model is the General Environmental Duty.

The GED (section 25 of the Act) provides that anyone — household or business — who engages in an activity that may give rise to risks of harm to human health or the environment from pollution or waste must eliminate or reduce those risks so far as reasonably practicable. It applies at all times, and there are significant penalties for businesses that do not meet it.

The law sets out what outcome must be achieved (minimise risk) but not exactly how. An EMP is the mechanism through which a business works out, documents and demonstrates that it is doing so.

What goes into an EMP?

A robust EMP is built on the same risk-management framework EPA Victoria sets out in its guidance. A well-structured plan typically includes:

• Site setting and environmental conditions — what and where the site is, surrounding and sensitive land uses, geology, groundwater and nearby surface water.
• Site activities — emissions to air, discharges to land, stormwater and trade waste, and the waste streams the operation generates.
• A Conceptual Site Model (CSM) — the source–pathway–receptor links that explain how a hazard could reach something or someone that matters.
• An environmental risk assessment — hazards identified and risks assessed using a recognised method and risk matrix.
• Environmental performance objectives — the standards the site is aiming to meet.
• Controls — the practical measures (engineering, operational, administrative) used to reduce risk, set out using a hierarchy of controls.
• Risk-based monitoring — what is measured, the trigger levels, and how the operator responds, escalates, reports and keeps records.
• Incident response and emergency management, roles and responsibilities, and staff training.
• Review triggers — when and why the plan is updated.

Together, those sections turn a legal obligation into a document that can be used day to day and provided to a regulator on request.

Who needs an EMP?

An EMP is generally relevant where any of the following apply to an operation:

• The business holds an EPA permission (a licence, permit or registration) whose conditions require it to document how risk is managed.
• The business has received an EPA notice — for example an improvement notice — requiring it to develop and implement an environmental management plan.
• The operation carries a real risk of environmental harm and needs to demonstrate compliance with the General Environmental Duty.
• The business manages contaminated land or industrial waste.

For a step-by-step walk-through, see: Do I need an Environmental Management Plan?

EMP, RMMP and environmental policy — what's the difference?

These terms are often used loosely, so it helps to be precise:

• An EMP is the broad document that shows how environmental risk is managed at a site.
• A Risk Management and Monitoring Program (RMMP) is the specific risk-and-monitoring document that certain EPA permission conditions require licence and permit holders to prepare. The two share the same risk-management backbone. See EMP vs RMMP: what's the difference?
• An environmental policy is a short statement of intent — it is not a substitute for a documented, site-specific EMP.

Frequently asked questions

Is an EMP a legal requirement in Victoria?

The Environment Protection Act 2017 does not always name "an EMP" as such, but it does require businesses to minimise risks of harm so far as reasonably practicable, and a documented EMP is the standard, accepted way to demonstrate that. Where a business holds an EPA permission or has received an EPA notice, a documented plan may be effectively required.

How long is an EMP?

It depends entirely on the site and its risks. A small, low-risk operation may have a concise plan; a complex industrial facility will have a far more detailed one. The appropriate length is whatever is needed to genuinely manage the risk.

Does an EMP ever expire?

An EMP is a living document. It should be reviewed and updated when activities change, when an incident occurs, or on a set review cycle, so that it continues to reflect how the site actually operates.

Who can prepare an EMP?

An EMP should be prepared by someone with the environmental and regulatory expertise to assess the risks correctly. Businesses commonly engage an environmental consultant to prepare a plan that will stand up to EPA scrutiny.

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.