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									                 Hume Highway Duplication – Sturt Highway to Holbrook
                         Construction Environmental Management Plan

              APPENDIX I

                    To the

               PLAN (CEMP)

              Project No: N829


NHA                Page 1 of 30                   N829-EN-201I REV02
RTA Procedure for Policy Number PN 025 (PN 025P)
(Environment – Policy Procedure)
RTA Corporate Policy - Procedure

Procedure for Environmental Incident Reporting


                To ensure the RTA has processes to capture and report environmental incidents during
                RTA activities.

                Read this procedure in conjunction with policy PN-025 Environmental Incident Reporting.

Scope and Coverage

                This Procedure is for the use of all RTA staff in all regions and directorates where
                environmental incidents may occur. The Procedure is to clearly define the requirements of
                RTA staff to report environmental incidents. The procedure does NOT cover
                environmental incidents caused by traffic accidents.

                This Procedure is also to assist staff to formulate regional plans or equivalent in consultation
                with environmental advisors and officers in Sydney and regions. The procedure provides
                the scope of information required to be included in the plans.


                Section A: Background, planning and response
                Section B: Notification and reporting process
                Appendix 1:      Key contact list
                Appendix 2:      Example local incident plan outline
                Appendix 3:      Environmental Incident Report Form
                Appendix 4:      Incident follow up form
                Appendix 5:      Environment protection legislation and offences
                Appendix 6:      Glossary of terms and abbreviations
                Schedule 1: Erosion and sedimentation incident communication process


                All RTA staff are responsible for reporting an environmental incident when they see one.

                Supervisors and managers are responsible for ensuring environmental incidents are
                reported to the appropriate level as set out in this document (refer Section B).

                Environmental advisors and managers are responsible for giving advice on whether
                environmental incidents need to be reported to external agencies.

                                                     Page 1 of 29
 Procedure for Environmental Incident Reporting             Effective date: March 2005
 Version: 1.0                                               Approved by: General Manager Environment Branch
 Last updated: March 2005                                   UNCONTROLLED WHEN PRINTED
               Environment Branch is responsible for assisting with advice and the reporting process,
               monitoring environmental incidents and monitoring and reviewing this procedure.

               Legal Branch is responsible for providing legal advice, assisting with investigations of
               incidents and preparation of reports for DEC and other regulators for major incidents.


               The environmental incident register is used to record and monitor all environmental
               incidents within the RTA. The register will assist with record keeping, reporting and
               determining improvements to the incident response. The register is kept by corporate
               Environment Branch. Managers are responsible for reporting incidents and submitting an
               Environmental Incident Report Form to environment staff or environment managers.
               Environment staff and environment managers are required to submit the form to the
               Environment Branch and/or the EMS Working Party monthly. Environment Branch is
               responsible for entering incidents on the register and monitoring and measuring the
               effectiveness of incident management and of this procedure.

Quality Records



               Refer to Appendix 6.

Additional Information

               Contact details: Environmental Officer – EMS Environment Branch, Centennial Plaza,
                                Sydney 9218 6327

               Effective date:          3 March 2005

               Review date:             3 March 2005

Procedure replaces

               Nil Appendices

                                                       Page 2 of 29
Procedure for Environmental Incident Reporting                Effective date: March 2005
Version: 1.0                                                  Approved by: General Manager Environment Branch
Last updated: March 2005                                      UNCONTROLLED WHEN PRINTED


1.1    What is an Environmental Incident?

The RTA defines an environmental incident as:

          an unexpected event that may result in harm to the environment and requires
          some action to minimise the impact or restore the environment.

This definition relates only to incidents involving the RTA or its contractors and is for internal reporting
processes as outlined in this procedure. Environmental incidents involving the RTA and its contractors
can include (but not be limited to) the following:

      !      spills of fuels, oils, chemicals and other hazardous materials;
      !      overflow of sediment basin or other containment devices;
      !      failure of temporary erosion and sediment controls;
      !      contamination of waterways or land;
      !      accidental starting of fire or fire breaking out of containment;
      !      breach of licence, permit or approval requirement;
      !      breach of legislative requirements;
      !      illegally dumped waste;
      !      unplanned disturbance of acid sulphate soils (or subsequent pollution);
      !      accidental harm or damage to vegetation, fauna or habitat (eg hollow logs);
      !      accidental damage to heritage items or locations (Aboriginal and non-Aboriginal);
      !      public complaints arising from RTA’s activities (relating to environmental issues).

1.2    Construction, Maintenance and other Site-Based Activities

The RTA Environment Management System (EMS) and contract specification clauses provide direction
to prevent incidents through promotion of best practice and standardised procedures.

During construction, maintenance and other site-based activities (e.g. geotechnical investigations etc.),
RTA staff and Contractors must attempt to prevent environmental incidents caused by their work
activities by following best practice protocols. All contractors (internal and external) must have their
own Contractor’s Environmental Management Plan (CEMP) which must include details of emergency

To ensure contractors enact the commitments in their CEMP an audit and inspection program must be
in place. All regions must have a regular audit and inspection schedule in place to ensure this occurs.

                                                   Page 3 of 29
This schedule must be completed in conjunction with and approved by the Regional Environmental

1.3       Incident Levels

The use of the terms “minor” and ”major” for this Procedure defines the level of response required by

•     “minor” indicates that work crews can manage the incident as part of their usual duties.

•     “major” indicates that assistance other than the regular work crews would be required and that the
      incident must be reported to a higher level and may need to be reported to the DEC and other

It is the responsibility of managers at the local level to decide if an environmental incident is minor or
major. In determining the appropriate category for an incident, consideration must be given to the
potential for an environmental incident to escalate from its current status and/or level of impact.

Minor (Environmental) Incident: an incident that has an impact or is likely to have an impact on the
environment but can be readily handled by work crews, with limited or no adverse impacts on the
environment, clients, stakeholders, community, RTA operations or the well-being of staff.

This level of incident is typically resolved as part of the normal operations of the work group or by pre-
arranged response protocols and is reported at the local level, verbally to management and through the
Environmental Incident Report Form (refer Appendix 3).

Major (Environmental) Incident: an incident of magnitude that requires considerable levels of resourcing
support (or potential to develop to such magnitude) and has, or is likely to have, significant impact
(within the meaning of the POEO Act) on the environment, clients, stakeholders or community. This
includes incidents that:
      !    require notification to other authorities (eg DEC, Hazmat, Health, Agriculture, Fisheries);
      !    involve a high level of work to clean up;
      !    have widespread actual or potential adverse impact on the environment or community health;
      !    have potential to have an adverse impact on the well-being of staff or the public.

This level of incident must be reported immediately and escalated through reporting channels to
management/environment staff verbally and a written form must be provided by the next working day
(using the Environmental Incident Report Form – refer Appendix 3). This level of incident may need to
be reported to the DEC.

It is the responsibility of the local management to report major incidents to local environment staff and
to the Environment Branch. It is the responsibility of environment staff to whom the incident is reported
to give advice on whether the incident must be reported to the DEC. If the relevant
manager/environment staff cannot be contacted, project staff must notify the DEC pollution line directly.
Refer to Section B for further details.

                                                   Page 4 of 29

2.1     General Prevention Strategies to be Applied to Worksites

Strategies must be developed to prevent environmental incidents from occurring where possible. Some
of these strategies are outlined in this section.

2.1.1       Development of Local Plans
RTA Directorates and Regions must develop and implement an Environmental Incident Management
Plan that includes:

        !      a response contact list within work areas (Directorates or regions) and for external
               agencies (e.g. HAZMAT, local council, Department of Environment and Conservation etc);
        !      a local incident plan to identify resources and roles during an incident (refer Appendix 2 for
               an outline of information to be included);
        !      a communications procedure for incidents based on the framework set out in this
        !      an awareness and training programme for environmental incidents delivered to new and
               current staff;
        !      reporting process to ensure incidents are reported to the appropriate level (as outlined in
               Section B) quickly and efficiently;
        !      debriefing process after significant or major incidents to ensure that there is full
               accountability for actions and that opportunities are identified, documented and considered
               for the improvement of response actions, management and follow-up actions, as well as
               minimising the risk of further recurrences (where appropriate);
        !      education of external parties with respect to RTA protocols;

Other methods of preventing environmental incidents include:

        !      the addition of specific clauses to contract specifications to account for individual site
               variations (where applicable); and
        !      the inclusion of specific site requirements in contractor’s documentation (e.g. work method
               statements) to prevent environmental incidents.

These actions are to be done in accordance with standard RTA specification procedures.

                                                    Page 5 of 29
2.2       Training and Awareness

2.2.1      Emergency and Clean-up
Clean up and removal of waste are identified in RTA’s Quality Assurance (Environmental) Specifications.
As such, they must be included in the RTA’s and Contractor’s systems and translated into procedures,
work method statements or equivalent.

All staff must be made aware of their obligations in relation to notification of environmental incidents and
in taking action to minimise their impact. General emergency procedure awareness training must be
provided to all staff, especially in relation to identifying the key contact lists and reporting.

Training in the use of clean-up equipment (including spill kits) must also be provided to all field staff.
Work crews must be trained in using spill kits, including instruction in the use of individual components of
the spill kits.

2.2.2      Environmental Awareness
Environmental awareness training for works under the Single Invitation Maintenance Contract (SIMC),
which includes basic responses to incidents and safety training such as safe storage practices is available
to RTA and council work crews.

Regional Managers and project managers in conjunction with environmental staff, must ensure that this
level of environmental awareness training is incorporated into induction training for new employees, into
safety refresher training for current employees and delivered as a reminder through regular staff
newsletters, toolbox talks etc.

2.2.3      Safety Training
All work crews must receive safety training. In addition, staff must receive specialist safety training for the
use of chemicals and products used as part of their work duties, including:
      !    competency based training for those handling dangerous goods/hazardous materials;
      !    safe storage of goods;
      !    the use of material safety data sheets.

Staff who have not received this training should not handle dangerous goods or hazardous materials,
rather they should only identify the incident and report the occurrence immediately.

2.3       Specialist Functional Support Roles

The nature of some environmental incidents will require specialist services for clean-up, sampling,
removal or management. The need for engaging this level of support throughout an incident must be
determined by the Site Manager/Supervisor. Contact lists for specialist services are available from the
Environment Branch, Environmental Officer Water and Contaminated Land (refer Contact List in
Appendix 1).

Each RTA Directorate and Region shall:
      !    develop and maintain controlled contact lists for local services for clean-up and restoration
           within regions;
      !    review the lists every 12 months or as required and revise where needed; and
      !    control the lists through the quality system or EMS forms (refer Appendix 1).

                                                     Page 6 of 29
The basic response to all types of environmental incident is shown in Table 1.

Directorates need to ensure that the environmental incident management plans that are developed
follow the basic incident response described in Table 1.

Table 1: Basic Environmental Incident Response Procedure

          IDENTIFY                 Identify the environmental incident and make sure the area is
                                   safe for staff and public.

             STOP                  Respond immediately and take action to stop the incident
                                   from spreading or escalating (if safe to do so).

          CONTAIN                  Contain any material which has or may have escaped.

          CLEAN UP                 Clean up as much as possible and seek assistance where

           REPORT                  Report and escalate as required.

In general terms, the response required for any environmental incident, will include:

      !      identification of environmental incident (e.g. notified by an observer);
      !      immediate response to contain the incident/potential incident (e.g. bunding for spills or
             orphan drums);
      !      a preliminary assessment of the level of the environmental incident (i.e. minor or major) and
             whether additional resources are required (e.g. Fire Brigade, HAZMAT or other);
      !      notify appropriate RTA contacts;
      !      identification of the source and/or cause of the environmental incident (e.g.
             known/unknown substance);
      !      clean up of the affected site to a satisfactory condition in accordance with specialist advice
             (where required); and
      !      notify the DEC and other authorities (if required).

                                                 Page 7 of 29
3.1.1   Response Team/On-Site Crews
There are a number of key resources which must be provided to all work crews to enable them to
respond quickly and effectively to any type of incident, including:

    !   an environmental incident management plan which has been developed within each
        Directorate/Region (see Section A, 2.1.1);

    !   Material Safety Data Sheet (MSDS) for work related chemicals and products, as well as those for
        commonly used chemicals etc.;

    !   spill clean-up kits (absorbent material, booms, hand tools, pumps, containers etc.);

    !   appropriate personal protective equipment (PPE); and

    !   pocket guides that provide a summary of actions required.

                                                Page 8 of 29

      ALL environmental incidents must be reported (through the channels outlined in this Procedure).
      What may seem initially to be a small or insignificant incident may have the potential to develop
      into a more extensive problem with greater or long-term consequences.

Table 2 shows the incident levels defined in this Procedure and identifies the level of immediate verbal
notification required.

 Table 2:      Incident verbal notification levels

                Incident Level                       Minor                         Major
  Notification to local management and
                                                      Yes                           Yes
  environment staff

  Notification to RTA Environment Branch               No                           Yes
  and relevant higher management (e.g.
  General Managers)

  Notification to DEC and other authorities            No            As appropriate (refer to designated
                                                                        environment staff for advice)

For major incidents where these need to be (or may need to be) notified to the DEC, staff are to
contact their local environmental staff for advice IMMEDIATELY when the incident has occurred.

4.1   When must DEC be notified of an environmental incident?

Under the Protection of the Environment Operations Act 1997 (POEO Act), there is a duty to notify
the appropriate regulatory authority (broadly, the DEC or the local council) of a pollution incident,
where material harm to the environment is caused or threatened. Material harm includes actual or
potential harm to the health or safety of human beings or to ecosystems that is not trivial or that results
in actual or potential loss (refer definitions) or property damage of an amount over $10,000.

Accordingly, under this procedure major incidents must be notified where they meet the requirements
described above. If in doubt, project staff should seek assistance from environmental staff. However at
all times, and especially when environmental staff are not available, a precautionary approach should be
employed and incidents should be reported. If the relevant manager/environment staff cannot be
contacted, project staff must notify the DEC pollution line directly.

In addition to these requirements, the Erosion and Sedimentation Incident Communication Process must
be followed when there is an incident of this nature. The Process is attached to this Procedure as
Schedule 1.

RTA activities may be governed by an Environment Protection Licence under the POEO Act. These
licences contain a number of conditions relating to RTA operations and activities including allowable
pollution levels, reporting requirements and obligations to notify DEC of any breaches of the licence or
POEO Act. Staff must always report in accordance with licence conditions.

                                                 Page 9 of 29
Advice should be sought from environment staff with regard to the notification of incidents to the DEC.
Upon identifying an incident and reaching a conclusion or obtaining advice that the DEC must be
notified, as soon as practicable, the relevant RTA officer must:

   1.     Notify the RTA Environment Branch immediately by phone (9218 6318).

   2.     Notify the DEC by telephoning the Pollution Line (131 555) and provide the following succinct
          and factual information:

          !    time, date, location and likely duration of incident;
          !    location of place where pollution is occurring or likely to occur;
          !    type of incident (e.g. chemical spill, water pollution etc.);
          !    extent of incident (e.g. magnitude of spill, area covered etc.); and
          !    action taken or proposed to be taken to deal with the incident and any resulting pollution
               or threatened pollution.
          [Note:    s150 of the POEO Act (Relevant information to be given) clearly identifies the
                    relevant information to be provided to the DEC].

   3.     Submit environmental incident report form.

DEC Authorised Officers have extensive powers under environmental protection legislation to
investigate compliance and obtain records. Only factual information is to be provided to the DEC.
Avoid speculation on origin, causes or outcomes of an environmental incident in discussions with the

The specific statutory requirements relating to the notification of pollution or environmental harm

    !   pollution incidents under section 148 of the Protection of the Environment Operations Act
    !   fires under section 64 of the Rural Fires Act 1997;
    !   discovery or cause of land contamination under section 60 of the Contaminated Land
        Management Act 1997;
    !   harm or ‘pick’ a threatened species, endangered population or endangered ecological
        community under section 118A of the National Parks and Wildlife Act, 1974,
    !   discovery of an Aboriginal relic under section 91of the National Parks and Wildlife Act 1974;
    !   discovery of Aboriginal remains under section 20 of the Commonwealth Aboriginal and Torres
        Strait Islanders Heritage Protection Act, 1984; and
    !   discovery of a relic under section 146 of the Heritage Act 1977.

Appendix 5 lists the penalties for offences under the POEO Act including breaches of licence conditions.

                                                  Page 10 of 29
It is important that there is consistency in the way that the environmental incident is reported.
Therefore, incidents must be reported by project staff and project managers through the Environmental
Incident Report Form (refer Appendix 3). The incident report form and any subsequent reports must
include factual information. Speculation about the causes and outcomes must be excluded. The
completed reports must be forwarded through environment staff to the EMS Co-ordinator in
Environment Branch.

The information from the form will be entered into the Corporate Environmental Incident register for
the purposes of record keeping, reporting (eg annual environment report) and to monitor and improve
responses to environmental incidents. Directorates are encouraged to keep their own environmental
incident registers to manage environmental issues at the local level.

Information contained in the form or report should be verified by the relevant Project Manager by

    !   the initial reports of the incident – who made the first report, at what time, and what
        information was provided, what instructions for actions were given; and

    !   the incident diary or field notes kept by those involved in the incident – identify and investigate
        any inconsistencies.

Should initial forms or reports be subsequently found to have ambiguities or other errors, then these
should be annotated with full explanation and clarification within the initial forms/reports. A copy of the
original form/report must be retained on file.

Incidents which may have caused material harm to the environment or which are potential breaches of
the POEO Act or conditions of environmental approvals may be investigated and prosecuted by the
DEC. The General Manager Environment Branch must be contacted in relation to these incidents and
document control must be observed. This includes any communications, documents, records, written
statements or reports (for example, emails and file notes) internally between RTA personnel.

Under the POEO Act, the DEC can issue a Notice to Provide Information requesting any and all
information regarding an incident to assist in their investigations of alleged pollution incidents, for
example letters, emails, memoranda, drawings, files and other project information. The RTA must
submit any information requested by the DEC. Communications with Legal Branch, for the purpose of
obtaining legal advice in relation to incidents, may be subject to legal professional privilege. Documents
subject to legal privilege are not required to be produced to the DEC under a Notice to Provide
Information. Environment Branch will provide advice and will co-ordinate a response with Legal Branch.
Legal Branch will assist in the investigation of incidents, prepare legal advice and assist with the
preparation of reports to the DEC.

                                                Page 11 of 29
Once an incident has been stabilised and notification has been provided to relevant areas, further
investigation and a written report are required. It is crucial that the details of the incident are recorded
throughout the course of the incident management process using a diary or other note taking forms such
as a log.

All incidents must be recorded and reported. Incident reporting provides an opportunity to accurately
identify issues that can enable improvements in operational performance and management, as well as the
response to and management of incidents. The information gathered and actions taken as part of this
process allow the RTA to demonstrate due diligence and provides crucial information for any future
defence of actions that may be required.

Table 3 summarises the actions required by managers following reporting of environmental incidents.

Table 3: Post reporting actions

                             Actions                                    Minor                  Major
 Complete Environmental Incident Report Form                       Yes (pages 1 & 2     Yes (pages 1 to 3)
 Send completed form to the Regional Environmental                        Yes                   Yes
 Adviser or Senior Environmental Adviser, Manager
 Environmental Systems, and Environment Branch

 Send all relevant information to Legal Branch                            No                    Yes

 Complete Incident Follow Up Form and submit to local                     Yes                   Yes
 environment staff

 Undertake a debrief                                                      No                    Yes

 Implement outcomes of the debrief                                        NA                    Yes


Major incidents will require more detailed reporting than the information included in the Environmental
Incident Report Form, regardless of the outcomes of the incident. A Major Environmental Incident
Report will need to be obtained and submitted to Environment Branch and Legal Branch. A template
for the report is available from Legal Branch and can be obtained on request. The level of reporting
should reflect the nature of the incident and may be used in DEC investigations or RTA investigations to
identify causes of the incident or to improve prevention or management strategies.

In determining whether to impose a penalty for breach of the POEO Act (refer Appendix 5), the DEC
will take into account a number of considerations. Accordingly, the following matters should be
addressed in the report:
      !   the extent of the harm caused or likely to be caused to the environment by the incident;
      !   the practical measures that were taken to prevent, control, abate or mitigate that harm;
      !   the extent to which the RTA could reasonably have foreseen the harm caused or likely to be
          caused to the environment by the incident; and
      !   the extent to which the RTA had control over the causes that gave rise to the incident.
                                                 Page 12 of 29
In addition the report must include:
      !   the measures that could reasonably be introduced to prevent or mitigate the effects of a similar
          incident occurring in the future; and
      !   the results of the performance assessment

It may be necessary to undertake a debriefing session to provide the appropriate level of detail required
for the report.

7.2       DEBRIEF

Debriefing sessions are designed to provide an opportunity to reflect on the causes, management and
outcomes of incidents and provide a mechanism for identifying opportunities to learn from the process,
including the development of improved methods of risk management to prevent further incidents or to
manage incidents more effectively.

The debrief shall take place as soon as practicable following the termination of the incident and within
4 weeks of the incident to ensure the best recall of events. It is more effective to have the debrief
facilitated by an independent party who was not involved in the incident but has a good understanding of
incident management and has good negotiation and conflict resolution skills. This could be someone
from the same or different area of the RTA.

Key participants in the environmental incident (including participants external to the RTA, if required)
and the local RTA environmental staff shall attend the debriefing session.

Prior to the debrief meeting, the debrief facilitator should gather information from the key parties
involved in the response and management of the environmental incident, including chronology of events
and actions taken and compile a summary of the incident. The aim of the debrief is to:
      !   review the incident events;
      !   reach agreement on the key issues arising from the response and management of the
          environmental incident;
      !   provide a detailed report for major incidents; and
      !   establish the basis for improving the future capabilities of the RTA environmental incident

The key issues arising can generally be identified within the following categories:
      !   incident management and arrangements;
      !   operational arrangements - response capabilities (resources, timing and availability);
      !   people issues (e.g. safety, rostering, capability, management);
      !   management systems (e.g. response, notification, reporting, investigation, improvement); and
      !   interactions (e.g. other agencies, public, within RTA sections).

Any outcomes from the debrief must be documented by project staff and forwarded to the Regional
Environmental Advisor and Environment Branch for distribution state wide so that lessons learnt can be
shared in the organisation. A template follow up form is attached in Appendix 4 with instructions and
ideas of information to be included.

                                                   Page 13 of 29
APPENDIX 1                   KEY CONTACT LIST
Contact lists shall be developed by each RTA Region and must be reviewed every 6 months (revised as
required) to ensure accuracy and currency and shall be maintained as quality controlled documents.
Contact lists must be available to all RTA staff and displayed or located in a readily accessible location (eg
intranet, notice board, work crew vehicles).


[Each Region must provide contact details]

Include relevant contact details for:

         a) RTA Region, Division and Head Office contacts

         b) RTA Environment Staff (see list given below in A.1.4)

         c) Specialist clean-up (RTA personnel, local contractors).


[Each Region must provide contact details]

Emergency                                       000
Pollution Line (DEC)                            131 555
Poisons Information Centre                      131 126 (24 hours)
DEC Regional Contact                            check DEC web site for appropriate local contact details
[Local telephone numbers for each regions (or division as required) ]

Police (local)                                  [insert local contact number]
Fire (local)                                    [insert local contact number]
HAZMAT (local)                                  [insert local contact number]
Hospital (local)                                [insert local contact number]
Medical Centre (local)                          [insert local contact number]

                                                 Page 14 of 29

[Each Region must provide contact details]

Include local contact details for:

         -   waste removal and disposal contractors

         -   sampling and analysis contractors

         -   land and water spill clean-up (e.g. Port Authorities, Waterways, etc.)

         -   specialist chemical advice – (see DEC register or identify local specialists)

         -   specialist equipment not available to RTA (e.g. equipment hire companies, other
             government agencies, suppliers of equipment such as hazmat drums etc. etc.)

                                                  Page 15 of 29

            Position                    Name                       Office        Office No      Mobile No

Operations and Services

Manager, Environmental Services   Geoff Cahill             Blacktown          (02) 8814 2990   0407 418 458

Manager, Environmental Systems    Rokeya Sabur             Yennora            (02) 8814 2610   0438 693 486

Northern Environmental Adviser    Greg Collins             Grafton            (02) 6640 1072   0411 406 519

Hunter Environmental Adviser      David Ledlin             Newcastle          (02) 4924 0281   0411 126 989

Hunter/Northern Environmental     Tracey Kelly             Newcastle          (02) 4924 0695   0439 300 118

Western Environmental Adviser     Mark Arrow               Parkes             (02) 6861 1628   0417 435 839

Western Environmental Officer     Silvana Deluca           Parkes             (02) 6861 1629   0429 456 844

South-West Environmental          Michial Sutherland       Wagga Wagga        (02) 6938 1143   0418 204 230

South West/Southern               Erwin Budde              Wagga Wagga        (02) 6938 1195   0429 699 905
Environmental Officer

Southern Environmental Adviser    Terry McCoy              Wollongong         (02) 4221 2583   0408 480 992


Environmental Services Manager    John O’Donnell           Grafton            (02) 6640-1058   0408 975 647
(Pacific Highway Office)


GM Environment                    Erica Adamson            Centennial Plaza   (02) 9218 6318   0439 401 052

Manager, Environmental            Steve Isles              Centennial Plaza   (02) 9218 6420   0418 646 667

Manager, Environmental Planning   Bruce McNamara           Centennial Plaza   (02) 9218 6364
& Assessment

                                                   Page 16 of 29
The elements to be included in a local incident plan that will form part of the local environmental incident
procedure (see Section A, 3.1.1) are outlined in the following table.

Elements to Include in Local Incident Plan                 Contact Details / Location of Equipment

Key Response Personnel:                                    Include a list of contact details (see Appendix 1 for
Identify who will take responsibility for                  suggested inclusions in the list) as an appendix to
action/response to an incident. List the key               the local plan.
personnel by position (e.g. work crew member,
Supervisor, Project Manager, Regional Manager

Available Resources:
Identify all resources available at short notice to
initiate a response to an environmental incident
and undertake clean-up procedures.

Human Resources:                                           Include a list of contact details.
Identify all personnel (by position may be more
appropriate) that can respond to various incidents.
It may be appropriate to identify specific resources
for each of the types of incidents (e.g. spills,
construction and maintenance activities and orphan
waste) depending on skills of individuals.

Equipment and machinery:                                   Include a list of equipment and its location with
Identify equipment or machinery available to local         contact details to gain access to this equipment.
RTA work crews (this may include such things as
hand tools, spill kits, booms, vehicles, earth moving
and other machinery etc.).

Additional Resources:
Identify any additional resources that may be
required for a response to an environmental
incident or to undertake clean-up procedures. List
any resources that may not be available to your
work crews or regions and identify where they
may be located. For example, this may include:

Human resources:                                           Include a list of agencies/groups and their contact
!   additional personnel (e.g. other government
    agencies, local councils, SES, local community
    groups etc.).

!   specialist personnel (e.g. scientists, engineers).

Equipment:                                                 Include a list of equipment and providers and their
                                                           contact details and location. This may include
Identify:                                                  other agencies, equipment hire businesses, local
                                                           council etc.).
!   equipment or machinery not available to local
    RTA work crews (this may include such things

                                                      Page 17 of 29
Elements to Include in Local Incident Plan                 Contact Details / Location of Equipment
    as sand bags and sand to contain spills, earth
    moving machinery etc.).

!   additional equipment required by additional
    personnel (e.g. protective or safety wear, hand
    tools etc.)

Devise a local communication strategy that ensures
that the key personnel are notified of incidents (e.g.
Project Manager, Regional Manager, environmental
staff, Legal Branch etc.).

Training:                                                  Include a list of the personnel requiring the various
List the training requirements for staff designated        training.
for response to environmental incidents.

This may include:

!   use of containment devices (e.g. booms, sand
    bags, spill kits etc.);

!   operation of machinery (e.g. earth moving
    machinery, etc.);

!   safety:

    -   basic safety training;
    -   specialist training.

!   environmental awareness training – to assist in
    understanding the implications of incidents;

!   incident management training – to assist in co-
    ordinating and effecting an efficient response
    to an environmental incident.

                                                      Page 18 of 29


1.   Complete pages 1 and 2 for ALL environmental incidents.

2.   Submit report to Environment Staff.

3.   Complete page 3 (in addition to pages 1 and 2) for major environmental incidents.

4.   Submit all information for major environmental incidents to Environment Branch who will request a
     separate report to be submitted (refer Section 7 of the Environmental Incident Reporting Procedure).

This form is also available on the intranet. [intranet address to be provided]

                                               Page 19 of 29
RTA ENVIRONMENTAL INCIDENT REPORT FORM                                                                            Page 1
Incident Report Number: (to be filled in by EMS Co-ordinator) __________________________

This form is to be completed: - for ALL environmental incidents which occur due to RTA works or on RTA worksites
                                     - by Senior Site Management, Registry Manager, Works Supervisor, Project Manager
Remember to be succinct, stick to the facts and do not make assumptions. Only record information you know to be correct.
Project Name                                                                                   Region
Date of incident:                                            Time of incident:                                 AM/PM
Duration of incident:                              hr/min
Description of Incident (provide a brief
description of what happened during the incident)
EXACT location of the incident: (include
landmarks and features, nearest cross street, etc
to make it easier to identify at a later date)
Extent of incident: (provide sketch if appropriate
and attach to this form)

Quantity or volume of material escaped or
causing incident: (provide a known amount or an
estimate if quantity unknown)
Estimate of distance to nearest waterway:
(waterway can include stormwater drains and dry
Type of activity that caused incident: (what works
were in progress at the time of the incident?)
How was the incident identified ? (e.g. RTA
employee, Council, community, complaint)
Name & Contact of complainant: (where

Type of Incident: (tick category)
#     Spill (including fuel, oil, waste material     #      Erosion and sedimentation         #    Contaminated water discharge
      or other polluting substance)                         incident (Go to Schedule 1)            (if involves muddy water, go to
                                                                                                   Schedule 1)
#     Noise Emission/Complaint                       #      Unauthorised/accidental damage    #    Unauthorised/accidental
                                                            to heritage item                       vegetation removal or harm
#     Other (provide details)

Level of Incident: (tick category)
Level                    Example                                                             Action
#     minor              e.g. no material has escaped the site or caused material            Go to page 2 of this form
                         harm to the environment – it is easy to clean up without
                         additional assistance
#     major              eg material has escaped the site causing pollution of               Go to pages 2 and 3 of this form
                         downhill/downstream areas which will require clean up
                         involving other agencies and/or additional resources not
                         available to local site management. Damage has occurred
                         or is likely to occur to the environment.

Environmental Incident Report Form                                                                                     Page 1
RTA ENVIRONMENTAL INCIDENT REPORT FORM                                                              Page 2

Any other details of the incident (including any information which did not fit in spaces above, as well as any
special circumstances of the day or the location):

What immediate actions/control measures were taken to rectify or contain the incident?

Any corrective/preventive actions undertaken?

Name:                                                  Position:

Signature:                                             Date:

If the DEC does not need to be contacted, these first two pages of the completed form are to be
sent/faxed to the relevant Environmental staff:
          Operations and Services:      Regional Environmental Adviser or Local Environmental Officer or
                                        Manager, Environmental Services or Manager, Environmental
          Motorways:                    Environmental Services Manager
          Corporate and Others:         Environment Branch

Environmental Incident Report Form                                                                           Page 2
RTA ENVIRONMENTAL INCIDENT REPORT FORM                                                        Page 3
(ONLY complete this page if the environmental incident was reported to the Department of Environment
and Conservation (DEC))

To be completed by: the relevant Unit or Branch Manager – eg Senior Project Manager, Road Services
                    Project Manager, Registry Manager, Vehicle Regs Manager

Was DEC notified?                        YES / NO
Who Notified the DEC?                Name:                               Position:

Notification method:          # telephone      # on site   Date of notification:     /   /
                                                           Time of notification:             AM/PM
Has there been a DEC Pollution Line Complaint?
        YES / NO                                           DEC Complaint No:
Other authorities notified and why:

Name:                                                      Position:
Signature:                                                 Date:            /        /

If the DEC was contacted, ALL pages of the completed form must be forwarded IMMEDIATELY to the
General Manager, Environment Branch. (Fax: 02 9218 6970)

Refer to the RTA’s Environmental Incident Reporting Policy and Procedure which is to be followed.

Environmental Incident Report Form                                                                     Page 3
APPENDIX 4                       INCIDENT FOLLOW UP FORM
Use this form to notify other areas or regions of any follow up actions or opportunities which have been identified for
improvement or to assist in preventing this sort of incident from recurring. Do not include site location or Contractor details.
Forward this form to your local environmental staff who will work with the EMS co-ordinator to update any procedures and to
circulate around the state.

Cause of incident.

Give a very brief description of how the incident occurred and what the incident consisted of. Do not
include site specific information which could identify the project.

Photo if available.

Details of any measures taken or proposed to be taken to prevent or mitigate against a recurrence of
such an event.

The following actions have been taken:

     •    List actions that have been taken in dot points.

     •    Keep it succinct and to the point while giving enough explanation.

     •    Mention any innovations to overcome the problem and/or procedural and/or documentation
          changes which need to be implemented.

     •    Include any forward planning information.

                                                              23 of 29
                           AND OFFENCES
The Protection of the Environment Administration Act 1991 (NSW) establishes the DEC as the
regulatory authority with general responsibility for investigating and reporting on any alleged non-
compliance with environment protection legislation. It provides the mechanism for prosecutions or
other regulatory action.

Activities undertaken by the RTA are regulated by various other environmental protection legislation.

In addition, RTA activities may be governed by an Environment Protection Licence under the Protection
of the Environment Operations Act 1997 (POEO Act). These licences contain a number of conditions
relating to RTA operations and activities including allowable pollution levels, reporting requirements and
obligations to notify DEC of any breaches of the licence or POEO Act.

More detailed information regarding environmental legislative requirements that are applicable to
potential environmental impacts caused by the RTA is given in the RTA’s Schedule of Environmental
Legislative Requirements which is available on the intranet at
http://home.rta.nsw.gov.au/org/ceo/envb/legis/index.html. A register of Environment Protection Licences
held by the RTA is included in the "Database of Authority Permits and Licences" retained and maintained
in accordance with the RTA Client Services EMS.


The environment protection legislation includes provision for significant penalties for land, air, water and
noise pollution offences (fines up to $1 million for corporations (including the RTA) and fines for
individuals up to $250,000 and imprisonment of up to seven years for wilful or negligent actions).

Breaches of Environment Protection Licence conditions attract fines up to $250,000 for corporations and
fines up to $120,000 for individuals. Minor breaches of Licence conditions and minor pollution of the
environment are dealt with by the DEC by issuing Penalty Infringement Notices with fines up to $1,500
for individuals and $5,000 for corporations.

             Offence                            Corporation                            Individual

Tier 1                                           $1 million                    $250,000 and/or 7 years
(wilful/negligent offences under                                                   imprisonment
Part 5.2 of POEO Act)
Tier 2                                           $250,000                              $120,000
(other offences under POEO
        continuing offences                  $120,000 per day                      $60,000 per day
Tier 3                                             $5,000                               $1,500
(dealt with by penalty notices)

                                                   24 of 29

AIIMS                       Australian Inter-Service Incident Management System
CEMP                        Contractor’s Environmental Management Plan
DEC                         Department of Environment and Conservation
EnvSFA                      Environmental Services Functional Area (EnvSFA) – co-ordinated by the
                            NSW DEC (as defined in the NSW DISPLAN and ENVIROPLAN)
EPA                         NSW Environment Protection Authority (now incorporated into the
                            Department of Environment and Conservation)
ESB                         RTA Environmental Services Branch
HAZMAT                      hazardous materials – generally refers to NSW Fire Brigades specialist
                            response unit
MSDS                        material safety data sheets
NSWFB                       NSW Fire Brigade
OH&S                        Occupational health and safety
POEO                        Protection of the Environment Operations Act 1997
PPE                         personal protective equipment
RS                          RTA Road Services
SES                         State Emergency Services
SIMC                        Single Invitation Maintenance Contract
SWMS                        safe work method statement
TMC                         Transport Management Centre

 combat agency              agency identified in the DISPLAN as the agency primarily responsible for
                            controlling the response to an emergency [State Emergency and Rescue
                            Management Act, 1989].

 DISPLAN                    the NSW State Disaster Plan (2000) is prepared by the State Emergency
                            Management Committee in compliance with the State Emergency and
                            Rescue Management Act, 1989 and is authorised by the Minister for
                            Emergency. DISPLAN identifies the process for co-ordinating response
                            by all agencies with responsibilities for an emergency.

 environmental incident     any unexpected event that may result in harm to the environment and
                            requires some action to minimise the impact or restore the environment
                            [defined by RTA].

 ENVIROPLAN                 NSW State Environmental Services Functional Area Plan (2001) is a
                            supporting plan of the NSW Disaster Plan (DISPLAN) and was prepared
                            by the State Emergency Management Committee in compliance with the
                            State Emergency and Rescue Management Act, 1989 and is authorised by
                            the Minister for Emergency. This plan focuses on the protection of the
                                               25 of 29
                         environment during emergencies, including the control and co-ordination
                         arrangements for the protection of the environment during and
                         emergency and recovery operations. It applies throughout NSW,
                         including inland and State waters. The co-ordinating agency is the
                         Department of Environment and Conservation and is assisted by the
                         NSW Fire Brigade and Ports Corporation as combat agencies.

hazardous materials      means anything that, when produced, stored or moved, used or
                         otherwise dealt with without adequate safeguards to prevent it form
                         escaping, may cause injury or death or damage to property [Source: Fire
                         Brigades Act 1989, as amended].

hazardous material       means any spillage or escape of a hazardous material during its
emergency                manufacture, use, handling, transport, storage in sufficient quantity to
                         endanger, or threaten damage or destroy any property or the
                         environment and requires a significant and co-ordinated response. Such
                         emergencies may be land based, or occur in the inland waters of NSW
                         [Source: HAZMATPLAN]

HAZMATPLAN               NSW State Hazardous Materials Emergency Sub-Plan (1999) – a sub-plan
                         of the NSW Disaster Plan (DISPLAN) and was prepared by the State
                         Emergency Management Committee in compliance with the State
                         Emergency and Rescue Management Act, 1989 and is authorised by the
                         Minister for Emergency. This plan details the special arrangements for all
                         hazardous materials emergencies which occur in NSW (except those
                         emergencies which occur on State waters). The NSW Fire Brigade is
                         responsible for rendering hazardous materials or situations safe.

incident response team   work crew or team that provides the clean-up activities associated with
                         the environmental incident. Can also refer to those associated with the
                         management of the incident response.

loss                     under the POEO Act includes reasonable cost/expenses incurred in taking
                         reasonable means to make good harm or potential harm.

material harm            to the environment includes any direct or indirect alteration of the
                         environment that has the effect of degrading the environment and,
                         without limiting the generality of the above, includes any act or omission
                         that results in pollution [Source: POEO Act 1997].

management               management of an environmental incident includes the planning and
                         preparation for initiating responses to incidents as well as the control of
                         activities for the duration of an incident.

pollution incident       “means an incident or set of circumstances during or as a consequence of
                         which there is, has been or is likely to be a leak, spill or other escape of a
                         substance, as a result of which pollution has occurred, is occurring or is
                         likely to occur. It includes an incident or set of circumstances in which
                         waste has been placed or disposed of on premises unlawfully, but it does
                         not include an incident or set of circumstances involving only the emission
                         of any noise or odour” [source: s147 POEO Act 1997].

orphan waste             any material with potential to pollute that has been abandoned and the
                         owner can not be readily identified (e.g. drums, waste etc.).

                                            26 of 29
reporting   includes initial notification of event/incident, completion of Environmental
            Incident Forms, as well as the investigation and detailed reporting after the
            termination of an incident.

response    includes actions undertaken to minimise, prevent or clean-up effects of an
            incident that has the potential to or is causing environmental harm.

                               27 of 29
                                         SCHEDULE 1



RTA is committed to undertaking all works in accordance with best practice environmental design and
management to avoid or mitigate potential environmental impacts of maintenance and construction

RTA undertakes to implement this communication process to provide prompt and proactive advice to
DEC’s senior management regarding the occurrence and management of erosion and sedimentation
control incidents arising during works by or for RTA.

This communication process is to be followed for all RTA projects including all work conducted on
behalf of the RTA by external contractors.

Communication Process:

In the event of an erosion and sedimentation incident (eg escape of sediment laden water from an RTA
project site) the communication process outlined below must be implemented as a matter of high
priority and urgency. The communication process outlined in this Schedule must be followed as soon as
practicable after a person becomes aware of the incident.

Prompt execution of each step in the project chain is very important. If any person in the
communication chain, is not able to be contacted promptly, contact the next person in the chain eg as
indicated by the dotted lines in the flowchart below.

This communication process must be completed on the day the incident is identified.

Formal Notification via the DEC Pollution Line:

The communication process indicated in Figure 1 is to be carried out in addition to providing notification
to the DEC Pollution Line in accordance with the Protection of the Environment Operations Act, 1997.

Notification to the Pollution Line (131 555) must also be carried out by site staff in accordance with
Section 5 of the Procedure for Environmental Incident Reporting .

                                                  28 of 29
Figure 1: Communication Process for Erosion and Sedimentation Incidents

           Erosion and sedimentation
             incident occurs on site

          Project staff to advise Project

                                                                 Project Manager and
           Project Manager to advise                        Environment Officer/Regional
        Environment Officer and Regional                      Advisor to ensure incident
          Environmental Advisor (if not                     control management activities
         available proceed to next step)                      are undertaken to minimise
                                                             impacts on the environment

         Project Manager or Environment
                                                                Project Manager or
     Officer/Regional Advisor to notify RTA's                       Environment
       Manager Environmental Services of
                                                            Officer/Regional Advisor to
     incident and management action (if not
                                                            report via DEC's "Pollution
          available proceed to next step)                    Line" in accordance with
                                                            requirements of the POEO

        Manager Environmental Services
          to advise General Manager
        Environment and Director Client

         GM Environment to advise RTA
          Chief Executive and DEC's
         Executive Director Operations
         and DEC Regional Manager (if

       The RTA to provide the DEC with
        an incident report following the

                                                29 of 29

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