CCAMLR adopted a new conservation measure in 2007 (CM 22-06) to ensure that significant adverse impacts of bottom fishing gear on Vulnerable Marine Ecosystems (VMEs) are avoided. Due to the high levels of uncertainty surrounding both the evidence of VME presence and the consequences of interaction with different types of gear, a risk management framework is proposed, similar to that which has been used successfully by IMAF to minimise the effects of longline fishing mortality on seabirds. The aim of this risk management is to avoid significant adverse impacts on VMEs from bottom fishing activities. This paper provides definitions of VMEs and summaries of their characteristics including natural agents of disturbance, frequency of disturbance and longevity and growth rates of dominant habitat-forming organisms. The likelihood and consequences of bottom fishing activities, with associated uncertainties, is then analysed and evaluated using standard techniques. Different types of evidence of VMEs in the CCAMLR Area are used in the risk analysis. Risk mitigation can then be used to reduce risk to acceptable levels.