Risk Based Work Plan Form

DR ELIZABETH GIBSON, General Manager of CMPA provides an update on the Risk Based Work Plan Form.

The Department of State Development, Business and Infrastructure (DSDBI) is implementing the Government response to the EDIC Inquiry into Greenfields Mineral exploration and Project Development in Victoria (2013).

One of the recommendations is the requirement for a risk based work plan. This concept was introduced through the Mineral Resources (Sustainable Development) Amendment Act 2014 s 16 which will replace s 40 in the Mineral Resources (Sustainable Development) Act 1990 from December 2016.

However, as a result of the Hazelwood Mine Fire inquiry recommendations this date will be bought forward to December 2015. One of the issues that has been raised with the Minister by CMPA is the need to separate mines from quarries due to the greater and different risk profile of mines as evidenced with the Hazelwood mine fire.

As discussed in previous issues of Sand & Stone, DSDBI is in the process of finalising a risk based work plan form that will be made available electronically.

From CMPA’s perspective a Work Plan has four purposes:

1. To prescribe the activity proposed on the site.
2. To be a reference point for the community and other interested parties to scrutinise.
3. To be a “contract of evidence” between the regulating bodies (DSDBI and Council) and the applicant.
4. To be a reference document for all parties to demonstrate ongoing compliance.

As discussed on 18 June, 2014 with DSDBI at the Workshop, CMPA highlighted a number of areas that need to be addressed:

• Change use of the term “risk” to “activity assessment” in the Form and Guidelines.
• Recognise and outline how the Risk Based Work Plan Form will address the impacts of current sequencing of approval: Work Plan followed by Planning Permit.
• Provide tangible and quantitative evidence that the Risk Based Work Plan Form will stream line the process, thereby reducing proponent time and cost and meets the “Draft Guiding Principles for a Reformed Work Plan”.
• Implementation of the Work Plan Form must be accompanied by training and education of proponents and ERR inspectors. Training and education must include discussion and refinement in order to have a consistent approach across ERR as to what constitutes low, medium, high and very high risk.
• An expanded code of practice for quarries (e.g. Blasting and Drilling, Traffic, Noise, Dust etc.).

However, unless there is clear and tangible benefit to CMPA members, many of which operate small quarries (but larger than 5 Ha), CMPA cannot support the draft Risk-based Quarry Work Plan Form and Guidelines. Attached is a table of Contents from a Work Plan template developed by CMPA which has been given to DSDBI and may be considered as an alternative.

Table of Contents

“The Table of Contents developed by CMPA encompasses all requirements for a Work Plan and Work Authority and, hence, meets all obligations.”

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