Odour in the Regulatory Spotlight: What EPA Victoria Enforcement Means for Operators

Odour has moved firmly into the regulatory spotlight in Victoria recently, with EPA Victoria taking increasingly strong enforcement action where offensive odours impact local communities. Under the Environment Protection Act 2017 (Vic), operators are now being held to account not only for licence compliance, but for their broader obligations under the General Environmental Duty (GED).

In a significant escalation, the Supreme Court of Victoria recently ordered a major waste management company to pay $1 million into an EPA administered restorative justice fund after the company admitted to breaching licence conditions and the GED. The breaches related to persistent odour impacts from a landfill in Melbourne’s south east.

EPA activity has also intensified across several industrial precincts. In suburbs including Sunshine, Brooklyn and Laverton North, EPA conducted targeted inspection blitzes of more than 30 industrial facilities, issuing at least 10 compliance notices requiring immediate corrective action.

These notices commonly required operators to:

  • Repair gaps and leaks in buildings and enclosures
  • Upgrade or improve ventilation and air filtration systems
  • Conduct airflow studies to demonstrate effective capture and containment
  • Implement formal odour monitoring and structured community engagement programs

How Odour is Assessed in Victoria

Odour assessment in Victoria is guided by EPA Publication 1883, Guidance for assessing odour. The guidance recognises that odour cannot be reliably assessed through continuous instrumentation alone and instead requires a weight of evidence approach focused on real world impacts at sensitive receptors such as residences, schools and workplaces.

EPA commonly requires the engagement of qualified odour consultants to prepare independent odour assessment reports. Depending on the nature and severity of the issue, assessments may be undertaken at:

  • Level 1, qualitative screening and risk assessment
  • Level 2, detailed field assessment and targeted monitoring
  • Level 3, comprehensive assessment, often including dispersion modelling, for example, to evaluate the effectiveness of proposed changes or control measures

The level of assessment is typically driven by complaint history, risk profile and the scale of potential impacts.

Odour Management Checklist for Operators

Recent enforcement outcomes demonstrate that operators must be able to prove, not merely assert, that odour risks are being effectively managed. The checklist below summarises key expectations under EPA guidance and current regulatory practice.

1. Understand Your Odour Risk
  • Identify all odour generating activities under normal, abnormal, start up and shutdown conditions
  • Map nearby sensitive receptors and understand prevailing meteorological conditions
  • Review complaint history, incidents and previous investigation findings

2. Maintain Effective Containment and Controls
  • Ensure buildings and sheds are properly sealed to prevent fugitive emissions
  • Regularly inspect roofs, walls, doors, vents and ductwork
  • Confirm odour control systems such as biofilters, scrubbers and carbon units are appropriately sized, maintained and operating as designed
  • Maintain clear inspection and maintenance records

3. Assess and Manage Off Site Impacts
  • Focus assessments on impacts at sensitive receptors, not just site boundaries
  • Use dispersion modelling for new, expanded or modified operations
  • Reassess odour risks whenever production rates, materials or operating hours change

4. Respond Effectively to Complaints
  • Treat odour complaints as formal regulatory evidence
  • Maintain clear procedures for recording, investigating and responding to complaints
  • Correlate complaints with operational activities and weather conditions
  • Document corrective actions and outcomes

5. Engage with the Community
  • Provide a clear and accessible contact point for odour concerns
  • Proactively communicate during higher risk activities or unusual operations
  • Keep records of engagement and complaint responses

6. Demonstrate GED Compliance and Be Inspection Ready
  • Be able to demonstrate that all reasonably practicable steps to minimise odour have been taken
  • Train staff in odour awareness and response procedures
  • Ensure site managers can clearly explain odour risks and control measures
  • Regularly review odour controls against EPA guidance and industry best practice
  • Maintain up to date odour management plans and monitoring records
  • Address identified issues promptly

How Trinity Can Help

If you have received an odour complaint, an EPA notice or request for an odour assessment, or if you would like to proactively review your odour risks, Trinity Consultants can assist.

Contact our team on 07 3255 3355 or via our contact form to request a complimentary 15 minute phone consultation. We can help identify the most appropriate path forward for your specific situation, including site inspections, field assessments, and odour dispersion modelling.