Why Operational Experience Matters in Environmental Compliance

Oct 12, 2026 · Allan Cummins

Aerial view of a waste or recycling site surrounded by bushland, with access tracks and nearby wetlands.

Running a waste or recycling site in Victoria has always meant juggling trucks, people, plant and product. Since the Environment Protection Act 2017 took effect on 1 July 2021, it has also meant showing, every day, that you are managing your risks of harm to people and the environment.

The general environmental duty (GED) applies to every business, and EPA Victoria expects waste operators in particular to understand their risks and control them so far as reasonably practicable. Add in the complexities of permissions, waste tracking, combustible waste storage, stormwater and leachate, dust, odour and noise, and a fast-growing fire risk from lithium-ion batteries in the waste stream. The result is a compliance load that can swamp a lean site team.

Why bring in outside help?

Most operators don't lack commitment to compliance. They often lack the time, expert knowledge, and a second set of eyes. An external environmental compliance consultant gives you both.

Specialist knowledge on tap. The legislation, regulations, EPA guidance and permission conditions change regularly. A consultant tracks those changes so your managers don't have to.
An independent view. It's hard to spot the risks you walk past every day. A fresh, objective audit finds gaps before EPA, a hostile neighbour or a fire does.
Capacity when you need it. Permission applications, amendments, incident responses and annual reporting come in peaks. A consultant scales up for those, without a permanent headcount.
Credibility with the regulator. Well-structured risk assessments, management plans and responses to EPA notices show a site that knows what it's doing.

Where external compliance advice often falls short

Plenty of consultants can quote the Act. Fewer can tell you how to effectively apply your controls on the ground. They've never been on site at 6 am on a Monday, with a queue of trucks at the weighbridge and two operators off sick. Have they?

That gap is where compliance fails in practice. A fire management plan can look excellent on paper but relies on controls the site (realistically), can never achieve. An incident procedure can be technically correct and still be too complicated for a loader driver to follow. A pollution control can be specified without considering how it will be maintained, by whom, and with what budget.

EPA's recent actions show how these gaps play out. In April 2026, EPA fined a Derrimut recycler $10,000 after a processing-line fire, likely sparked by lithium-ion batteries. It was the site's third fire that year. EPA cited a failure to notify it promptly, as the permission required, and no adequate smoke management process. In August 2026, EPA began snap inspections of 50 skip bin operators, after an earlier blitz in the state's south-west found more than half of inspected sites lacked the permissions they needed.

Neither case turns on legal interpretation. Both are operational problems with compliance consequences.

The CRA difference: we've run sites like yours.

CRA's consultants haven't always been consultants. We've operated highly regulated sites ourselves. We understand the pressures that face an operation on a day-to-day basis.

Our team brings over 50 years of hands-on experience running hazardous waste handling facilities, liquid waste treatment plants, landfills, oil recycling and other resource recovery facilities.

That experience changes the advice you get.

Controls that work on the ground. We take the time to visit and understand your site and workforce. We design procedures around your specific operations, plant, staffing and throughput, so they work rather than filed away and forgotten about.
We speak your crew's language. We can walk the floor with your leading hand, understand the workarounds, and fix the root cause instead of writing another rule.
Practical, costed priorities. We know what a bunded storage area, a thermal camera or extra stockpile separation actually costs to build and maintain. You get a plan ranked in priority order by risk and by value for money.
Faster, calmer incident response. Having managed fires, spills and odour complaints ourselves, we know what EPA needs to hear, and when, and what the site needs to do in the first hour of an event.
Stronger permission applications. Applications and amendments land better when the operating detail is credible. We write them knowing how the site will really run.

In practice: safer stockpiles at a regional council site

A regional Victorian council asked CRA to help reduce the fire risk at one of its waste sites. Over time, the stockpile layout had grown to suit day-to-day convenience. It no longer gave the separation and access needed to stop a fire spreading or to fight one safely.

Rather than impose a textbook layout, we worked on site with the council's operators. Together we redesigned where each stockpile sat, how far apart they were and how plant and emergency services could reach them. Every change was tested against how the site really runs: public drop-off, truck and loader movements, and collection schedules.

The result was a markedly safer site that stayed easy to manage every day. Fire risk came down without disrupting residents using the site, the operators' routines or the overall flow of vehicles and material.

What working with CRA looks like

We start on site, not at a desk. A typical engagement follows four steps.

Walk the site with your team. We see how material actually moves, where it's stored and how the crew works.
Map your obligations to your operations. We line up the GED, your permission conditions and relevant EPA guidance against what happens on the ground.
Prioritise and fix. We are always assessing risks. You get a risk-ranked action list, with practical controls at a realistic cost.
Stay in your corner. We can support you through inspections, notices, incidents, permission changes and annual reporting.

Our services include:

Environmental risk assessments;
Environmental risk management and monitoring plans (RMMP's)
Fire risk assessments;
Combustible waste management plans (CRWM storage plans);
Compliance audits;
EPA permission applications and amendments;
Incident and notice response;
Training for site staff.

Whoever you engage, ask one question: has this person ever run a site like mine? The answer tells you a lot about whether their advice will survive in your operation.

2026-2027: Increased EPA scrutiny on industry

EPA has said its 2026–27 priorities include increasing industry compliance and targeting illegal and unsafe practices in waste and recycling. For operators, that means more scrutiny and less room for paperwork that doesn't match practice.

CRA bridges that gap. We bring the regulatory knowledge you'd expect from a consultant, and the operational experience you'd expect from someone who has stood on your site and taken the time to really understand it.

Allan Cummins is a Director of Circular Resources Australia.

To talk about your site, contact CRA today at admin@craus.com.au or call one of our team:

Allan Cummins: 0402 275 713

Andrew Swann: 0438 667 790

Sources

EPA Victoria, Fined following recycling fire, 30 April 2026
EPA Victoria, EPA targets skip bin operators in statewide compliance blitz, 24 August 2026
EPA Victoria, Annual delivery plan 2026–27
EPA Victoria, Management and storage of combustible recyclable and waste materials guidance (publication 1667)

Why Operational Experience Matters in Environmental Compliance

Why bring in outside help?

Where external compliance advice often falls short Plenty of consultants can quote the Act. Fewer can tell you how to effectively apply your controls on the ground. They've never been on site at 6 am on a Monday, with a queue of trucks at the weighbridge and two operators off sick. Have they?

​

The CRA difference: we've run sites like yours. CRA's consultants haven't always been consultants. We've operated highly regulated sites ourselves. We understand the pressures that face an operation on a day-to-day basis.

Our team brings over 50 years of hands-on experience running hazardous waste handling facilities, liquid waste treatment plants, landfills, oil recycling and other resource recovery facilities.

That experience changes the advice you get.

Controls that work on the ground. We take the time to visit and understand your site and workforce. We design procedures around your specific operations, plant, staffing and throughput, so they work rather than filed away and forgotten about.

We speak your crew's language. We can walk the floor with your leading hand, understand the workarounds, and fix the root cause instead of writing another rule.

Practical, costed priorities. We know what a bunded storage area, a thermal camera or extra stockpile separation actually costs to build and maintain. You get a plan ranked in priority order by risk and by value for money.

Faster, calmer incident response. Having managed fires, spills and odour complaints ourselves, we know what EPA needs to hear, and when, and what the site needs to do in the first hour of an event.

Stronger permission applications. Applications and amendments land better when the operating detail is credible. We write them knowing how the site will really run.

What working with CRA looks like

We start on site, not at a desk. A typical engagement follows four steps.

Walk the site with your team. We see how material actually moves, where it's stored and how the crew works.

Map your obligations to your operations. We line up the GED, your permission conditions and relevant EPA guidance against what happens on the ground.

Prioritise and fix. We are always assessing risks. You get a risk-ranked action list, with practical controls at a realistic cost.

Stay in your corner. We can support you through inspections, notices, incidents, permission changes and annual reporting.

Our services include:

Environmental risk assessments;

Environmental risk management and monitoring plans (RMMP's)

Fire risk assessments;

Combustible waste management plans (CRWM storage plans);

Compliance audits;

EPA permission applications and amendments;

Incident and notice response;

Training for site staff.