ALARP Beyond the Workplace: Environmental Risk Management in Western Australia

The first two Insights in this series explored the origins of ALARP (As Low As Reasonably Practicable) and how it operates within Western Australia’s workplace health and safety (WHS) framework. These Insights outlined how risks must be reduced by balancing the likelihood and consequence of harm against the cost, time and effort required to implement control measures.

This third and final Insight in the series extends this discussion beyond workplace safety and into environmental regulation in Western Australia (WA). While the term ALARP is not consistently used across all environmental legislation, it is applied in certain regulatory frameworks and reflected more broadly through equivalent concepts such as “all reasonable and practicable measures” and the requirement to avoid or minimise impacts.

This Insight examines how ALARP principles align with the environmental mitigation hierarchy, explains how the “reasonably practicable” test is applied across WA’s key environmental approval pathways, and highlights how these expectations are reflected in mining and petroleum regulatory frameworks. It also provides practical takeaways for organisations to proactively manage, document and justify environmental risks in a way that supports both regulatory compliance and sustainable outcomes.

ALARP across WA’s Environmental Frameworks

Environmental regulation in Western Australia spans multiple acts and frameworks. While environmental laws do not consistently use the specific safety acronyms ALARP or SFAIRP (so far as is reasonably practicable), the core philosophy remains embedded in the state’s risk-based approval processes.

Instead of ALARP, terms like “all reasonable and practicable measures”, “avoid or minimise impacts”, or “best practicable measures” are used to set a clear expectation that environmental risks must be reduced as far as reasonably achievable. Regardless of which specific act governs a project, the expectations for environmental approvals remain the same. Proponents must:

• Identify and assess risks to environmental values.
• Demonstrate that impacts have been avoided or minimised wherever reasonably practicable.
• Justify residual impacts and explain why further controls are not reasonably achievable.
• Regulators assess this by considering current science, available technology, industry standards, and whether the cost of further controls is grossly disproportionate to the environmental benefit (EPA, 2025a).

Universal Tools– ALARP and the Mitigation Hierarchy

In workplace safety, ALARP is achieved using the “Hierarchy of Controls”. In Environmental Management, the mitigation hierarchy is used which aligns closely with ALARP principles. The mitigation hierarchy requires proponents to:

1. Avoid environmental harm where reasonably practicable.

2. Minimise impacts through design improvements, operational controls, and technological solutions.

3. Rehabilitate or restore disturbed environments.

4. Offset residual impacts only after all other measures have been exhausted (EPA, 2014).

Just like in safety, higher-order controls (elimination or avoidance) are always preferred over administrative or compensatory measures. Offsets, like administrative controls in safety, are not substitutes for meaningful risk reduction; they are measures of last resort (DWER, 2020).

The Reasonably Practicable Test in WA Environmental Law 

As established in earlier Insights, the “reasonably practicable” test requires decision-makers to weigh the likelihood and severity of potential harm against the availability, suitability, and cost of control measures (Safe Work Australia, 2025). A control can only be rejected if the cost or effort to implement is grossly disproportionate to the benefit it provides (HSE, 2022).

Here is how the reasonably practicable test is applied across WA’s environmental approval pathways:

1- The Environmental Protection Act, 1986 (Part IV) – The EIA Process

The Environmental Impact Assessment (EIA) process for major project approvals closely aligns with ALARP. Proponents must show that all feasible mitigation measures have been considered and that environmental risks have been systematically evaluated. Key elements include:

• Assessment of the likelihood and consequence of environmental harm.
• Application of best available technology and contemporary industry practice.
• Consideration of alternatives, including project redesign or relocation.
• Recognition that cost alone is not a sufficient reason to reject higher-order controls where significant environmental harm is possible (EPA, 2025a).

2- The Environmental Protection Act, 1986 (Part V)- Day to day operations and clearing.

For day-to-day operations managed under works approvals and licensing, Section 51 (b) of the Act makes it an offence if a business fails to take “all reasonable and practicable measures to prevent or minimise emissions”. Works Approvals applications are expected to apply a hierarchy of controls to prevent, control and abate, and mitigate environmental harm.

For Native Vegetation Clearing Permits. Applicants must adhere to the mitigation hierarchy and provide evidence that they have pursued alternatives to eliminate or reduce the need for clearing (DMPE, 2026).

Across all Part V approvals, offsets will only be considered as a last resort, once avoidance and minimisation measures have been clearly demonstrated.

3- The Mining Act 1978

The Mining Development and Closure Proposal (MDCP) Guidelines explicitly require proponents to demonstrate that environmental impacts have been reduced to a level as low as reasonably practicable (ALARP) through appropriate project design, mitigation measures and operational controls (DMPE, 2025).

To meet these requirements, proponents must assess environmental risks, consider available control measures, and justify why the selected controls are appropriate. The MDCP framework requires proponents to demonstrate that all reasonable and practicable measures have been implemented, and that environmental impacts have been avoided or minimised wherever possible throughout the project life cycle, including design, operation and closure (DMPE,2025).

Furthermore, all WA mining operations are governed by the Work Health and Safety (Mines) Regulations 2022, which legally mandates the application of SFAIRP for the design, construction, and closure of mine sites. The mandate bridges the gap between physical safety and long-term environmental stability, particularly for high-risk structures like tailings storage facilities (WorkSafe WA, 2022).

4- Petroleum and Geothermal Energy Resources Regulations 2012– Environmental Plans

For onshore petroleum and geothermal activities, operators must submit Environment Plans that explicitly demonstrate that all environmental risks are assessed and controlled to ALARP (DEMIRS, 2024). The guidelines for the development of Petroleum, Geothermal and Pipelines Environmental Plans in Western Australia 2024, highlight that operators must continuously review the environmental impacts and risks and demonstrate that they are reduced to ALARP at all times.

5- Dangerous Goods Safety Act, 2004

While primarily a safety framework, this Act’s duties extend directly to the environment. Part 2, Section 8 states that anyone storing or transporting dangerous goods must implement controls that reduce risks to people, property, and the environment to as the lowest level reasonably practicable. The WorkSafe WA Dangerous Goods Risks assessment template explicitly mentions ALARP to support this (WA-WorkSafe, 2025).

Adaptive Management, Continuous Improvement, and Shred Responsibility 

A critical feature of environmental ALARP is that it is not static. What is considered reasonably practicable evolves as knowledge, technology, and industry standards improve.

Under WA’s environmental regulatory framework:

• Environmental management plans must be updated as new risks emerge.
• Monitoring data is used to reassess whether existing controls remain effective.
• Approval conditions may be amended if actual impacts exceed predicted levels (EPA, 2025a; DEMIRS, 2024; DMPE, 2025).

The evolving nature of ALARP is particularly evident in high-risk industries, where changing standards reshape what is considered “reasonably practicable.” Tailings storage facilities (TSFs) provide a strong example. Following major global failures, expectations for design, monitoring, and governance have strengthened under the Global Industry Standard on Tailings Management (Hidayat, 2025). As these standards evolve, what is considered reasonably practicable in WA increases, highlighting that compliance is not static and must adapt as safer and more effective measures become achievable.

Environmental ALARP operates across multiple stakeholders. Proponents must justify environmental risk decisions with robust scientific evidence and transparent documentation. Regulators assess whether proposed controls reflect current best practice and community expectations. Community members and Traditional Owners play a role through consultation processes that inform risk tolerance and impact acceptability (EPA, 2024).

Stakeholder engagement is increasingly recognised as a core component of environmental governance in WA. Consultation does not remove risk, but it influences how risk is understood and managed. In this way, environmental ALARP incorporates not only technical feasibility but also social and cultural considerations (EPA, 2024).

Takeaways for WA Businesses 

To successfully navigate WA’s evolving environmental regulations and to meet the ALARP standard, businesses need to translate theory into practice across three key areas:
 

• Treat environment like safety: Apply the same level of rigour used in safety management to environmental risks, recognising that environmental harm can lead to significant regulatory, financial, reputational, and long-term liability consequences (NOPSEMA, 2025).
• Document and justify decisions: Maintain clear records showing that alternatives were considered, higher-order controls were prioritised, and any residual impacts are transparently justified to build regulatory confidence (DMPE, 2025).
• Invest proactively in controls: Prioritise early investment in higher-order mitigation measures to reduce long-term approval risk and liability, while demonstrating that risks have been reduced to a reasonably practicable level (EPA, 2025a).

As regulatory expectations continue to evolve, organisations must ensure their environmental risk management frameworks are robust, well-documented, and capable of continual improvement. If your organisation requires support or advice on embedding ALARP principles into its environmental or broader risk management systems, please contact us at enquiries@integratesustainability.com.au or call 08 9468 0338.
 

ISPL-ALARP Beyond the Workplace: Environmental Risk Management in Western Australia- PDF

 

References

DEMIRS. (2024, Nov). Guidelines for the development of Petroleum, Geothermal and Pipelines Environmental Plans in Western Australia. Retrieved from Department of Energy, Mines, Industry Regulation and Safety: https://www.wa.gov.au/system/files/2025-02/env-peb-177.pdf

DMPE. (2025, November 27). Mining Development and Closure Proposals. Retrieved from Department of Mines, Petroleum and Exploration: https://www.wa.gov.au/organisation/department-of-mines-petroleum-and-exploration/mining-development-and-closure-proposals

DMPE. (2026, March). Native vegetation clearing permit lodgement- Mineral Resources. Retrieved from wa.gov.au: https://www.wa.gov.au/organisation/department-of-mines-petroleum-and-exploration/native-vegetation-clearing-permit-lodgement-mineral-resources

DWER. (2020, December). Guideline Risk Assessments. Retrieved from https://www.wa.gov.au/system/files/2023-06/guideline-risk-assessments.pdf

EPA. (2024, December). EPA Stakeholder Engagement Plan. Retrieved from Environmental Protection Authority: https://www.epa.wa.gov.au/sites/default/files/24250208%20EPA%20stakeholder%20engagement%20plan.pdf

EPA. (2025, November). Environment Impact Assessment Practical Guide. Retrieved from Environmental Protection Authority: https://www.epa.wa.gov.au/sites/default/files/Policies_and_Guidance/EIA%20Practice%20Guide%20%E2%80%93%20Nov%2025.pdf

EPA. (2014, August) WA Environmental Offset Guidelines. Retrieved from Environmental Protection Authority: https://www.epa.wa.gov.au/sites/default/files/Policies_and_Guidance/WA%20Environmental%20Offsets%20Guideline%20August%202014.pdf

Hidayat, M. (2025, December 26). Global Industry Standard on Tailings Management: 77 Essential Requirements. Retrieved from Discovery Alert : https://discoveryalert.com.au/tailings-management-2025-safety-evolution-standards/

HSE. (2022). Guidance on ALARP Decisions in COMAH. Retrieved from Health and Safety Executive: https://www.hse.gov.uk/foi/internalops/hid_circs/permissioning/spc_perm_37/

NOPSEMA. (2025, June 28). Environmental plan content requirements. Retrieved from National Offshore Petroleum Safety and Envrionment Managament Authority: https://www.nopsema.gov.au/sites/default/files/documents/Environment%20Plan%20Content%20Requirements%20Guidance%20Note.pdf

Safe Work Australia. (2025). Managing risks. Retrieved from Safe Work Australia: https://www.safeworkaustralia.gov.au/safety-topic/managing-health-and-safety/identify-assess-and-control-hazards/managing-risks

WorkSafe WA. (2025). Dangerous goods risk assessment template. Retrieved from Worksafe WA: https://www.worksafe.wa.gov.au/publications/dangerous-goods-risk-assessment-template

WorkSafe WA. (2022). Work Health and Safety (Mines) Regulations 2022. Retrieved from Department of Justice Parlimentary Counsel’s Office : https://www.legislation.wa.gov.au/legislation/statutes.nsf/law_s53266.html