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  • Certification Statement for Correction

    Does the certifying official have to sign a certification statement for a correction to a Risk Management Plan? If so, does that certification apply to the entire RMP or just for the correction being made? Yes, the certifying official must sign a digital certification statement in RMP*eSubmit, and it will…

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  • RMP Information Center

    If I have additional questions regarding the RMP regulations, who can I contact via telephone for further assistance? You may contact the EPCRA, RMP & Oil Information Center, a publicly accessible service that provides up-to-date information on the regulatory requirements of the RMP program, including the applicability, program levels, off-site…

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  • When part of a site is sold, what facility ID number is used?

    If a site is divided up as part of a sale and part of the site is kept by the original owner and the remainder is sold or leased, what facility ID is used? The section of the site that is retained by the original owner will keep the original…

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  • Are barracks and family housing units on military bases considered public receptors?

    Barracks are not considered public receptors, family housing units are. Public receptors include any "offsite residences ... inhabited or occupied by the public at any time without restriction by the stationary source where members of the public could be exposed to toxic concentrations, radiant heat, or overpressure, as a result…

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  • What is the definition of injury?

    Under the hazard assessment requirements of 40 CFR Part 68, Subpart B, an owner or operator must document a five-year accident history including all accidental releases from covered processes that resulted in deaths, injuries, or significant property damage on site, or known offsite deaths, injuries, evacuations, sheltering in place, property…

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  • Would change in population data require an RMP update?

    As part of the hazard assessment under 40 CFR Part 68, Subpart B, a source is required to estimate in its risk management plan (RMP) the population within a circle that has its center at the process and its radius equal to the distance to the endpoint concentration (40 CFR…

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  • Do Program Level 1 processes need to do five-year accident histories?

    What is the relationship between the accident history criteria for Program 1 and the five-year accident history? If my process is eligible for Program 1, do I still need to do a five-year accident history? The five-year accident history is an information collection requirement that is designed to provide data…

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  • Are on-site areas with unrestricted access considered public receptors?

    A process covered under 40 CFR Part 68 is eligible for Program 1 requirements if it meets all of the criteria listed at 40 CFR §68.10(b). One of those criteria is that the distance to a toxic or flammable endpoint for a worst-case release assessment is less than the distance…

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  • Are areas occupied solely by employees considered public receptors?

    When analyzing off-site consequences for the purpose of a worst-case or alternative release scenario under the risk management program regulations (40 CFR Part 68), are areas occupied solely by employees at the source considered to be public receptors? No. Such areas at the stationary source are not to be included…

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  • Applicability of compliance audit provisions to non-prevention program elements

    I have a Program 2 covered process and a Program 3 covered process at my stationary source. I am required (by 40 CFR Section 68.58 and 40 CFR Section 68.79) to certify compliance with prevention program requirements every three years. These compliance audits specifically address the prevention program portions of…

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  • Does a five-year update satisfy the requirement to conduct a compliance audit?

    The owner or operator of a stationary source with a Program 2 or Program 3 process must conduct a compliance audit at least every three years to ensure compliance with the prevention program requirements and must revise and update the risk management plan (RMP) at least every five years (§§68.58…

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  • RMP Program Level 2 and 3 compliance audit frequency

    Pursuant to the risk management program regulations, facilities with Program Level 2 and 3 processes must perform compliance audits at least once every three years (40 CFR §§68.58 and 68.79). Do regulated facilities have to perform the audits within exactly three years or can facilities perform the audits any time…

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  • Does a PHA for OSHA satisfy EPA's PHA requirement for Program 3?

    The risk management program regulations require that an initial process hazard analysis (PHA) for each Program 3 process be completed no later than June 21, 1999 (or by the time the process first has more than a threshold quantity of a regulated substance, if that occurs after June 21, 1999)…

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  • Do compliance audits cover non-prevention program requirements?

    Does the compliance audit requirement cover all of the Part 68 requirements or just the prevention program requirements? The compliance audit requirement applies only to the prevention programs under Subpart C. If you have a Program 2 process, you must certify that you have evaluated compliance with the Program 2…

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  • How often must employees complete refresher training?

    How often must employees of facilities that are subject to the risk management program complete refresher training? A facility owner or operator must provide refresher training at least every three years, and more often if necessary, to each employee operating a process in order to ensure that the employee understands…

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