Repurpose Recycling (RR) Ltd runs a recycling operation on the Central Coast of New South Wales. RR processes construction and demolition waste, including timber, plasterboard, foam, insulation, cardboard, plastic and metals. Australia's recycling sector is widely considered to be in a crisis situation since China stopped its intake of foreign materials for its recycling industry. RR has accumulated a large stockpile of materials at its facility.

An increasing number of fires have occurred in recycling facilities in Australia and overseas. Lithium ion batteries, widely used in mobile phones and other electronic devices, are a growing cause of fires, along with discarded aerosol bottles and other flammable items that get mixed in to waste materials.

Bill is employed as a facility manager for RR. His responsibilities include maintenance of the sprinkler system that is meant to be triggered in the event of a fire. During his last check of the system, Bill fails to notice that a sensor device was not working.

A fire breaks out in the facility and the sprinkler system does not deploy properly. Due to the large stockpile of materials, it takes two days for the fire to be fully extinguished. During this time, thick smoke spreads across the local community and toxins from burning construction waste are dispersed into the air.

A nearby metal fabrication business, Weld Works, has to cease work during this 48-hour period as it is unsafe to operate. Weld Works is unable to complete a welding job and the client takes the fabrication work to a competitor. Weld Works estimates a loss of $75,000.

A number of residents in the affected area experience temporary eye and skin irritation and breathing difficulties. One resident, Neal, has a chronic lung disease and is admitted to hospital suffering severe,acute respiratory distress. The treating doctor fails to look up Neal's medical history in the electronichealth record system. Had the doctor done so she would have seen that Neal has a serious allergy to a drug used to treat airway inflammation. The doctor administers this drug to Neal, causing him to go intoshock. Neal dies. His partner, Graham, is devastated by Neal's death and is diagnosed with majordepression.

The NSW Environment Protection Authority (EPA), established by theProtection of the Environment Administration Act 1991, regulates recycling and waste facilities. Facilities that handle construction and demolition waste must comply with regulatory requirements for waste storage. An environmental protection officer inspected the RR facility six weeks before the fire. The officer issued a letter warning RR to reduce its stockpile of waste materials as she considered that the large stockpile of materials posed a potential hazard. Due to the demands of an increasing number of facility inspections across the state, the EPA had not yet followed up on the warning letter to RR. In the event of non-compliance with a warningletter, the EPA has authority to suspend a facility's licence to operate and order immediate remediation of a hazard.

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