Service · Multi-site EMP programs
A risk found at one site is a question about all of them.
Victoria's General Environmental Duty follows your organisation, not a single premises. What your business learns at one site — from an incident, an audit or an EPA notice — it is expected to act on at every site where the same risk exists. We build one consistent EMP framework across your whole portfolio, at a per-site cost that falls as the program grows.
Why multi-site is different
The state of knowledge follows you.
Under the Environment Protection Act 2017, what is "reasonably practicable" is set by your state of knowledge — what your organisation knows, or ought reasonably to know, about a risk and its controls (s 6(2); EPA Publication 1856). Knowledge doesn't stay at the site where you gained it.
So when an incident, an audit or an EPA notice identifies a risk at one premises, the compliance bar rises at every site where that risk exists. EPA's published enforcement approach weighs risk and the duty holder's behaviour — and "we knew from Site A and did nothing at Site B" is a hard position to defend.
Multi-site operators are increasingly expected to manage environmental risk as a portfolio: one consistent, documented framework, applied site by site — not a different answer at every gate.
Had a notice at one site?
Close it out properly first — then treat it as the trigger to look sideways. Our EPA notice guide covers the first part; a portfolio program is the second.
PORTFOLIO · OPERATING SITES
The program
One framework. Site-specific substance.
01 · BASELINE
Portfolio risk snapshot
Every site profiled against the same criteria — activities, setting, receptors, existing documents — so you can see the whole board before spending on any single square.
02 · FRAMEWORK
One EMP architecture
A single structure, terminology and control library across the portfolio — with a genuinely site-specific risk register and monitoring program inside each site's EMP.
03 · ROLLOUT
Staged, priority-first
Highest-risk or regulator-facing sites first, then waves. Each wave gets faster and cheaper — the framework, precedents and controls are already built.
04 · ASSURANCE
Keep it live
Annual review cycle, EMP audits of existing documents, and an optional digitised inspection layer so implementation is visible across every site from one dashboard.
The economics
The second site costs less than the first. The tenth, much less.
EMP drafting on our platform is automated where automation is honest — assembly, consistency, formatting — so senior consultant time goes into each site's actual risk calls. Build the framework once and every subsequent site inherits it: per-site pricing falls as the program grows.
Programs are quoted in writing as a not-to-exceed program price with a per-site schedule — so the board sees the whole number, not an open-ended engagement.
Portfolio scoping call — free
Sites, activities, what exists today, where the regulator pressure is. You leave with a clear read on exposure, whether or not you proceed.
Priority sites first
The sites with live notices, licences or the highest risk get full site-specific EMPs first — inspection, conceptual site model, risk register, controls, monitoring.
Rollout waves
The framework carries across the remaining sites in scheduled waves, each faster than the last.
Program review
Annual review keeps every site's EMP current as activities, regulations and the state of knowledge move — including audits of EMPs you already hold.
Fit
Built for organisations like these.
- Groups holding multiple EPA licences, permits or registrations across Victoria.
- Organisations that have just closed out a notice at one site — and want the other sites answered before EPA asks.
- ISO 14001-certified (or certifying) businesses whose sites need genuine site-level substance behind the certificate.
- Property and industrial-estate operators responsible for many tenanted premises.
- Portfolios with existing EMPs that need auditing and refreshing rather than rewriting — we run audit-mode programs too, including one across an 11-site agricultural portfolio.
FAQ
Multi-site questions.
Does every site get the same EMP?
No — that would defeat the point. Every site gets the same framework, structure and control library, but its own conceptual site model, risk register and monitoring program. Consistent where consistency helps; site-specific where the regulator demands it.
We received a notice at one site. Are we obliged to act at the others?
The General Environmental Duty applies at every site, at all times. Once your organisation knows about a risk and its controls from one site, that knowledge is part of the "state of knowledge" the law measures you against wherever the same risk exists. A prioritised program is the defensible way to get ahead of that — urgent site first, portfolio behind it.
How is a multi-site program priced?
Per site, on a falling schedule — the framework is built once and each subsequent site inherits it. You get a written not-to-exceed program quote with the per-site schedule before anything starts. The indicative single-site EMP pricing is the ceiling, not the pattern.
We already have EMPs. Can you audit rather than rewrite?
Yes. Audit-mode programs review each site's existing EMP against current regulations and actual site conditions, fix what needs fixing, and put the portfolio on a common review cycle — usually far cheaper than starting again.
Related reading
The thinking behind portfolio programs.
Map your portfolio exposure in one call.
Free scoping conversation: your sites, what exists today, where the risk sits, and what a program would actually cost. No obligation.