Use your SBMP to protect your backside

Have You Thought about How to Use Your SBMP to Protect Your Backside! 

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A Site Based Management Plan (SBMP) is often required under the conditions of an Environmental Authority for a site engaging in an Environmentally Relevant Activity (ERA) as licensed by the Department of Environment and Science (DES), such as on-site wastewater treatment systems (ERA 63 in QLD).

Actions taken in accordance with a detailed and well prepared SBMP can demonstrate compliance with the Environmental Protection Act and protect you from prosecution in the event of an emergency that causes the unlicensed release of contaminants into the environment.


One of our clients recently experienced significant wet weather over a 10-day period, which caused massive flooding and filled the on-site treated effluent ponds to capacity. This posed a high risk of the ponds overtopping into the adjacent creek and compromising the integrity of the pond wall.

To avoid this, site personnel followed the wet weather contingency plan outlined in the site’s SBMP and, over two days, irrigated above the daily limit outlined in the site’s environmental authority to increase the pond capacity.

Although the site exceeded their daily irrigation limit, by following the contingency plan in their SBMP, the actions taken prevented the uncontrolled release of treated effluent into the creek and maintained the structure of the ponds; thereby fulfilling the site’s general environmental duty to prevent or minimise environmental harm.


Simmonds & Bristow, on behalf of the client, notified DES of the breach and provided DES with a detailed incident report to fulfil the site’s duty to notify the incident and to demonstrate that it had also fulfilled its general environmental duty to minimise/prevent environmental harm.

DES was “satisfied that site staff took appropriate measures to mitigate the potential risks to site infrastructure, and the environment given the scale of the wet weather event.” No penalties were issued and the Department’s conclusion that staff complied with their general environmental duty and took appropriate measures to minimise the potential risk to the environment confirmed the validity and appropriateness of the site’s SBMP.


SBMPs for on-site wastewater systems typically provide for at least the following functions:

  • Routine operating procedures to prevent or minimise environmental harm;
  • Maintenance practices and procedures to ensure that all plant, equipment and reticulation systems used are maintained in good working order;
  • Contingency plans and emergency plans to deal with foreseeable risks and hazards, e.g., wet weather events;
  • Monitoring contaminant releases into the environment and maintaining environmental reports;
  • Monitoring of compliance with any requirements of the site’s Environmental Authority and maintaining records of compliance;
  • Recording and handling of environmental complaints;
  • Stormwater Management Plan;
  • Waste Management Plan;
  • Irrigation Management Plan, if applicable to your site;
  • Staff training and awareness of environmental issues.

Simmonds & Bristow has experience with preparing SBMPs and can assist you with developing an SBMP or reviewing an existing SBMP.

For specific advice for your site, please contact us

Call 1800 620 690