Background
Elf Farm Supplies operates a licensed agricultural supply facility and holds an Environmental Protection Licence under the Protection of the Environment Operations Act. As a licence holder, the facility is required to prepare, maintain, and test a Pollution Incident Response Management. EPS has been engaged over multiple years to support the ongoing review and testing of the PIRMP to ensure it remains current, practical, and aligned with regulatory obligations.
Complexity
The engagement involved managing compliance and operational risk within an active agricultural supply facility, including:
- Interpreting evolving statutory requirements under the Protection of the Environment Operations framework
- Ensuring the PIRMP reflected site-specific risks and operational practices
- Testing incident response procedures without disrupting day-to-day operations
- Maintaining staff awareness and capability across changing personnel and roles
Solution
EPS undertook a structured and independent review and testing program to assess the effectiveness of the client’s pollution incident preparedness and response arrangements.
- Regulatory Review: Assessed the PIRMP against legislative requirements and relevant regulatory guidance
- Plan Evaluation: Reviewed incident scenarios, notification procedures, and response measures for practical application
- Testing and Exercises: Led PIRMP testing activities to evaluate staff understanding and operational readiness
- Improvement Planning: Identified gaps and opportunities for refinement and supported plan updates
EPS worked closely with the client to ensure findings were clearly communicated, improvement actions were proportionate, and updates were embedded within existing governance and operational systems.
Impact
The ongoing review and testing program strengthened the client’s approach to pollution incident management and regulatory compliance.
- Supported continued compliance with PIRMP and Environmental Protection Licence requirements
- Reduced operational and regulatory risk through regular testing and review
- Improved staff understanding of roles and responsibilities during incident scenarios
- Enabled continuous improvement of emergency response procedures
