EPA Victoria releases updated guideline for preparing Risk Management and Monitoring Programs (RMMPs)

EPA Victoria updates its Risk Management and Monitoring Program guideline under the Environment Protection Act 2017

Overview of the EPA Victoria RMMP Guideline

On 17 June 2024, EPA Victoria released an updated regulatory guideline for preparing Risk Management and Monitoring Programs (RMMPs), with final updates confirmed on 18 June 2024. The guideline is published under the Environment Protection Act 2017 (Vic) and sets out the regulator’s precise expectations for how permission holders must structure, document, and implement their risk management and monitoring obligations. This is not a minor administrative refresh. The updated guideline provides a standardised, prescriptive framework that replaces the previous, more discretionary approach to RMMP preparation, and it applies across all industry sectors holding EPA permissions, including operating licences and works approvals.

For environmental consultants, EPA-appointed auditors, and the clients they advise, including manufacturers, waste processors, developers, and utility operators, the release of this guideline establishes a definitive benchmark against which compliance will be measured. The document is structured to assist permissioned duty holders understand exactly what the EPA will look for when assessing whether an RMMP satisfies permission condition OL_G5. It also extends its usefulness to duty holders who are not operating under a permission but who are seeking to align their internal risk management systems with the General Environmental Duty (GED) under Section 25 of the Act.

The practical significance of this update reaches beyond Victoria’s borders. As Australian regulators progressively move away from prescriptive pollution control rules toward performance-based, duty-of-care frameworks, EPA Victoria’s RMMP guideline serves as a model for how a modern environmental regulator operationalises those principles in documented, auditable form. Environmental professionals working across Queensland, New South Wales, South Australia, and Western Australia will recognise the parallels with their own jurisdiction’s shifting regulatory expectations, making this guideline relevant as a reference point for best practice across the country.

Key details of the EPA Victoria RMMP guideline requirements

The updated guideline defines six mandatory content elements that a compliant RMMP must address. Each element carries specific expectations that go well beyond a narrative description of site activities. The first element is a comprehensive site description, which must provide a full physical and operational profile of the site, including layout, processes, materials handled, waste streams, and surrounding land uses. This baseline forms the foundation against which all subsequent risk assessments must be anchored. Vague or generic site descriptions will be assessed as inadequate against the OL_G5 condition.

The second and third elements address risk management and environmental performance objectives respectively. The risk management component requires a systematic assessment of all potential risks to human health and the environment arising from site operations. Critically, this assessment must directly align with the General Environmental Duty under Section 25 of the Environment Protection Act 2017 (Vic), which requires all persons conducting activities to understand the risks of harm those activities may pose and to take reasonably practicable steps to minimise those risks. The environmental performance objectives that follow must be measurable and specific. The guideline makes clear that broad commitments such as “minimise environmental impact” are insufficient. Objectives must be expressed in terms that allow the regulator, an auditor, or a third party to objectively assess whether they are being achieved.

The fourth element, monitoring and evaluation, requires standardised protocols to track the effectiveness of critical risk controls. This means that monitoring activities must be tied directly to the risk controls identified in the preceding risk assessment, not simply conducted as standalone ambient monitoring. The program must demonstrate a logical chain from identified risk, through control measure, to monitoring metric, through to evaluation trigger and response. The fifth element covers incident and emergency management, requiring documented procedures for emergency response and recovery that are operationally realistic and tested. The sixth element mandates structured training records for all personnel engaged in high-risk activities, with evidence of instruction, supervision, and competency assessment.

The guideline applies to all EPA Victoria operating licences carrying permission condition OL_G5, which is a standard condition attached to licences issued under the Environment Protection Act 2017 (Vic). Importantly, the document explicitly notes it is also designed for use by duty holders across all industry sectors, not only those holding permissions. This broadens its relevance as a risk governance benchmark for any organisation managing environmental risks in Victoria, regardless of whether a formal permission has been issued.

Australian context: how this guideline fits within Victoria’s and Australia’s broader environmental regulatory frameworks

The release of this guideline is a direct product of the structural shift in Victoria’s environmental regulation that occurred when the Environment Protection Act 2017 (Vic) replaced the longstanding Environment Protection Act 1970 (Vic). The 2017 Act fundamentally reoriented Victoria’s approach from a regime centred on prescriptive licence conditions and pollution parameters to one that places a positive, proactive General Environmental Duty on all persons conducting activities that may give rise to risks of harm. This shift mirrors similar legislative trajectories in Queensland and other Australian jurisdictions.

References and related sources

• Primary source: www.epa.vic.gov.au
• epa.vic.gov.au
• epa.vic.gov.au
• EPA Victoria

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This is an iEnvi Machete news summary. Prepared by iEnvi to summarise the source article for contaminated land, groundwater, remediation, approvals and site risk professionals.

Published: 24 Jun 2026

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