ASBG prepared its submission on the draft Guidelines: Pollution Incident Response Management Plans (PIRMP). Overall the Guidelines are an improvement over the current version with a much clearer set of what is expected from PIRMPs well explained. However, a major issue was raised with the literal interpretation that any pollution incident should result in retesting and updating of the site's PIRMP within 30 days. ASBG considers the Guidelines are an opportunity to interpret the meaning of s98E(2)(b) POEO (General) Regulation to mean incidents that are Material Harm. Another related issue is interpretation of what should be involved in a PIRMP update. ASBG argues the PIRMP is primarily an incident response plan and should only deal with upstream risk issues limited to management practices and not engineering and process changes.
 ASBG\'s Submission on the Draft PIRMP Guidelines 2019 | 822 kB |
