A Pollution Incident Response Management Plan (PIRMP) is a plan that can be immediately implemented following a pollution incident to reduce risks to human health and the environment. It is a legislative requirement for all Environmental Protection Licence holders in NSW to have a PIRMP in accordance with section 153A of the Protection of the Environment Operations Act 1997 (POEO Act).
A pollution incident can be in the form of noise pollution, air pollution, water pollution or land pollution and has the potential to occur in any location where chemicals are stored or handled, or even where significant noise can be produced.
The NSW Environment Protection Authority (EPA) have recently revisited their guidelines for writing a PIRMP, which are due to be released in late 2019. With the new guidelines, the EPA has emphasised the importance of the following:
- Ensuring all relevant staff onsite are trained in incident response procedures and documenting training details;
- Identifying a person specifically in charge of contacting emergency services, the local council, NSW EPA and WorkCover immediately after a pollution incident;
- Defining the trigger for the PIRMP to be used;
- Corresponding with neighbouring sites to understand chemical storage and use on surrounding properties that should be considered during a pollution incident;
- Documenting all chemicals contained onsite that may not be used in production (e.g. asbestos in the buildings, corrosive cleaning chemicals etc);
Identifying the likelihood of hazards, mitigation methods and residual risk; - Describing safety equipment and personal protective equipment kept onsite, including the location of the equipment; and
- Including detailed maps (approximately three different maps is recommended) of the location of all chemicals, fire fighting equipment, spill/incident response equipment, stormwater and drainage plans including direction of flow, the maximum extent of the pollution incident (plume size) and a defined site boundary (as per your EPL).
A PIRMP should be simple enough to follow in an emergency, but detailed enough to cover all aspects that should be considered in relation to any potential pollution incident.
iEnvi staff have completed several PIRMPs and reviewed PIRMPs across NSW. In addition, our team have recently completed training and received guidance from the EPA as to how to create an effective and compliant PIRMP under the new requirements. If you or your company hold an Environmental Protection Licence in NSW and require a PIRMP, contact the iEnvi team at [email protected] for more information on how we can help.
PIRMPs are only a legislative requirement in NSW, however we recommend you consider a Spill/Incident Response Management Plan in any state if you store or handle significant volumes of chemicals at your site.
In the event of a pollution incident to air, land or waters in other states, there is a legal obligation to notify the environmental governing body, as per the following diagram:
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