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  • Change of owner and RMP facility ID number

    If a facility is sold to a new owner, does it keep its' original RMP Facility ID number? Yes. The facility will keep the ID number assigned by EPA.

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  • Facility ID number and re-registering a facility

    If a facility deregisters, then reregisters, should the facility use the original RMP Facility ID or will it be assigned a new ID? The facility should use the original ID assigned by EPA.

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  • Resubmission of RMP for a facility that previously deregistered

    A covered facility deregisters its RMP because it no longer has more than a threshold quantity of a regulated substance in a covered process. If the facility becomes subject to the CAA §112(r) risk management program regulations at a later date and submits a new RMP, should the facility submit…

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  • RMP Records Maintained Onsite

    Pursuant to 40 CFR Part 68, Subpart G, the owner or operator of a stationary source subject to the risk management program regulations in Part 68 must develop and submit a risk management plan (RMP). Does the owner or operator have to maintain a written copy of the RMP on…

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  • Visit and examination requirements for SPCC self-certification

    Pursuant to 40 CFR §112.6, the owner or operator of a facility that meets the criteria in §112.3(g) for either a Tier I or Tier II qualified facility may self-certify the facility's SPCC Plan. As part of the self-certification, the owner or operator must certify that he or she has…

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  • Change of Ownership

    If a facility that is subject to the risk management program regulations in 40 CFR Part 68 is sold to another owner, is the facility required to make a correction or a full update of its risk management plan (RMP)? If there are no changes in the covered operations at…

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  • RMP*eSubmit preparer access

    How does a new Preparer get access to a Risk Management Plan (RMP) via RMP*eSubmit? First, the person must register with CDX. To register with CDX, go to https://cdx.epa.gov/ and complete the registration process for a Risk Management Plan “Preparer”. Once set up as a “Preparer”, the Certifying Official needs…

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  • Are renovations performed on detached garages, sheds and other detached outbuildings on the property subject to the RRP Rule?

    Yes. EPA interprets target housing to include pre-1978 buildings or structures that are (1) located on the residential portion of the property, and (2) associated with the residential use of the property. As a practical matter, the entire property of most urban and suburban residential lots is normally considered to…

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  • How do the RRP requirements apply to renovations on a pre-1978 building that contains both multi-room apartments (i.e., target housing) and zero-bedroom dwellings?

    In pre-1978 buildings that contain a mix of target housing and zero-bedroom dwellings, the Lead Renovation, Repair, and Painting (RRP) Rule applies only to renovations performed in target housing and common areas. Common areas are those portions of a property generally accessible to residents/users of target housing, and can exist…

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  • Does zoning affect the target housing determination? For example, would a pre-1978 house that is zoned for commercial or office use, but used for residential purposes be considered target housing?

    In determining whether a pre-1978 property is target housing, it is the actual or intended use of the property that matters, not its zoning classification. Therefore, a pre-1978 house that is used or intended to be used as a residence, even if only temporary, is target housing regardless of its…

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  • Five-year Anniversary Due Date and Time

    Pursuant to the risk management program regulations in 40 CFR §68.190, the owner or operator of a stationary source shall revise and update the RMP at least once every five years from the date of initial submission. At what time on the 5-year anniversary date is the RMP due? The…

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  • Required Contractor Contact Information

    A facility that uses a contractor to prepare its RMP must include in the registration section the name, mailing address, and telephone number of the contractor who prepared the RMP (40 CFR §68.160(b)(14)). When a contractor only prepares a portion of an RMP on behalf of a facility, does the…

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  • If a facility changes owners and significant changes have been made to plant operations is the facility required to update all sections of the RMP and resubmit it to EPA?

    Yes. If the facility has new ownership and plant operations have changed significantly, the new facility owner/operator needs to do a resubmission. For details on how to resubmit, see the Web page for RMP*eSubmit .

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  • RMPs for stationary source with multiple program levels

    If a stationary source comprises some covered processes that meet the eligibility requirements for one of the three programs (i.e., Program 1, 2, or 3) and some processes that are subject to a different program, must the owner or operator of the source submit multiple risk management plans (RMPs)? No…

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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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