Identification and assessment of risks to human health and the environment presented by your activities is central to development of your risk management and monitoring program. The risk assessment draws together information from all the issues you have identified so far and identifies those site activities that require some form of control to reduce their potential health and environmental impacts to an acceptable level. A method for businesses to prepare a risk management framework is described in Assessing and controlling risk: A guide for business (EPA publication 1695). The entire risk assessment process must be documented, and those documents maintained to provide a basis for your identified risks and to enable future, regular reassessment of risks.

Environmental aspects

After completing your risk assessment, you will have identified environmental aspects, which are those that can have a risk of harm to human health and the environment. These will require action to control the risks they present. Remember that environmental aspects are an element of the organisation’s activities that interact or can interact with the environment.

Compliance obligations

Your risk assessment will also have identified your compliance obligations. These might include those arising from, but not limited to:

• your EPA licence conditions;
• the Act and subordinate legislation;
• company policy;
• industry group codes; or
• supplier agreements.

Risks and opportunities

When you have an understanding of your activities and have prepared a conceptual site model, you may have discovered some environmental performance risks and opportunities that might not have been identified as an environmental aspect or a compliance obligation during the risk assessment. These might be upcoming changes in raw material type, quantity or quality, production scale, company policy, or market demand. Any risk or opportunity identified at this stage must be considered when setting your environmental performance objectives and considering potential for and management of environmental risks.

Once you have had a close look at your risks and opportunities, you might discover ways of updating your activities to improve process efficiency, reduce materials losses, enhance environmental performance, increase site safety, or reduce operating costs. The risk assessment and control process should be regarded as a tool to help you improve your overall activities, as well as meeting your licence condition OL_G5 obligations.

Environmental performance objectives

Your next step in complying with licence condition OL_G5 is to set and document in your RMMP your environmental performance objectives for your activities. Environmental performance objectives specify the goals you set for elimination or reduction of the identified risks of your activities (i.e. your environmental performance).

When establishing your environmental performance objectives, you should take into account:

• environmental aspects;
• compliance obligations;
• accepted industry or activity standards; and
• any risks and opportunities identified by your analysis of your organisation and activities (assisted by your conceptual site model).

They should be:

• consistent with your environmental policy;
• measurable where practicable;
• monitored;
• communicated; and
• updated as appropriate.

Each environmental performance objective should include environmental performance indicators that you can measure to determine if an environmental performance objective has been met.

Environment reference standards

From time to time, EPA will set and review environment reference standards (ERS) that will be used to report on environmental conditions in Victoria (Part 5.2 of the Act). These may include ambient environmental quality pollutant measures, ambient environmental quality ecological measures, measures for human health or the health of other species, and targets for emission of pollutants. These standards are published in the Government Gazette and on the EPA website. When you identify environmental performance objectives, you should consider environment reference standards set by EPA.

Elimination or mitigation of risk of harm so far as reasonably practicable (SFARP)

We have produced guidance about how to determine what is Reasonably practicable (EPA Publication 1856).

When setting your environmental performance objectives, you must take into account section 6 of the Act:

6 The concept of minimising risks of harm to human health and the environment
(1) A duty imposed on a person under this Act to minimise, so far as reasonably practicable, risks of harm to human health and the environment requires the person—
(a) to eliminate risks of harm to human health and the environment so far as reasonably practicable; and
(b) if it is not reasonably practicable to eliminate risks of harm to human health and the environment, to reduce those risks so far as reasonably practicable.

To assist you with determining what is (or was at a particular time) reasonably practicable in relation to the minimising risks of harm to human health and the environment, section 6(2) of the Act requires that you must have regard to:

• the likelihood of those risks eventuating;
• the degree of harm that would result if those risks eventuated;
• what the person concerned knows, or ought reasonably to know, about the harm or risks of harm and any ways of eliminating or reducing those risks;
• the availability and suitability of ways to eliminate or reduce those risks; and
• the cost of eliminating or reducing those risks.

This direction requires you to exercise a degree of judgement on what level of risk reduction you need to apply to your activities. Being the person best placed to understand the actual or potential risks of harm to human health and the environment presented by your activities, you are best placed to identify SFARP for those risks. The test for what is reasonably practicable is an objective test; that is, it is to be judged by the standard of behaviour expected of a reasonable person in the duty-holder’s position who is required to comply with the same duty and is:

• committed to providing the highest level of protection for people against risks to human health and the environment; and
• proactive in taking measures to protect human health and the environment.