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  • When were RMPs initially required to be submitted?

    When must the risk management plans (RMPs) required under 40 CFR Part 68, Subpart G, initially be submitted? For chemicals currently listed as regulated substances at 40 CFR §68.130, compliance with the risk management program requirements (including submission of RMPs) is required by June 21, 1999, or the date on…

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  • Is the RMP submission date the postmark date or EPA's receipt?

    Initial RMPs must be "submitted" by a certain date, and RMPs must be updated at least every five years from the date of its submission. What constitutes "submission" for purposes of meeting and determining these deadlines - postmarking the RMP or EPA's receipt of the RMP by the due date…

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  • Updating RMP if substance no longer held in excess of threshold quantity

    If a facility had a covered process that was previously subject to the Program 2 or 3 requirements, but no longer holds the regulated substance in excess of the threshold quantity due to a decrease in production or storage, must the facility update its risk management plan (RMP)? If a…

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  • Who should sign the certification statement?

    The owner or operator of a stationary source must submit in the RMP a statement certifying that the RMP is accurate and complete (40 CFR §68.185). Who should sign this certification statement? EPA has not promulgated regulations under 40 CFR Part 68 specifying who must sign the certification statement nor…

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  • What do I do with my indoor plants during the cleaning?

    You may leave plants on your property and inside your home or place of business. However, the cleaning team will not move any of your belongings, including plants. You may want to consider moving plants outside for the day, if possible, and watering them before you leave.

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  • How does EPA verify accuracy and completeness of RMPs?

    What does EPA plan to do to verify the accuracy and completeness of submitted Risk Management Plans (RMPs)? All RMPs received by EPA go through an electronic verification process that checks the submission for its completeness. This completeness check determines whether information has been provided for all of the required…

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  • Are facilities required to use an Integrated Contingency Plan?

    A number of federal statutes and regulations require emergency response planning (e.g., risk management planning under the Clean Air Act Section 112(r), contingency planning under RCRA, and facility response planning under the Oil Pollution Act). On June 5, 1996, the National Response Team (NRT), published the Integrated Contingency Plan ("One…

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  • Will an Integrated Contingency Plan satisfy RMP requirements?

    The National Response Team's Integrated Contingency Plan guidance, or "One Plan," provides a format for consolidating multiple emergency response plans required under RCRA, OPA, SPCC, DOT, OSHA, and CAA §112(r). Will an Integrated Contingency Plan satisfy all of the risk management program requirements under 40 CFR Part 68? No. An…

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  • Inclusion of release scenarios in executive summary

    Do I have to include a description of my worst-case and alternative release scenario in my executive summary? I'm concerned that the description contains sensitive information, which if included in the executive summary will be available to the public without restriction. No, facilities are not required to include a description…

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  • Withdrawal of an erroneous RMP submission

    What should a facility do if it submitted a risk management plan (RMP) but later discovers that it was never subject to the risk management program requirements? If a facility discovers that it submitted an RMP in error and was never subject to the risk management program regulations, it should…

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  • Changes required for adding new reactor vessels for same substance

    What if I change a process by adding new reactor vessels, but do not change the substances? Because increasing the number of reactor vessels is usually a major change to your process, you will have six months to update your RMP to reflect changes in your prevention program elements and…

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  • Who is responsible for preparing and submitting an RMP for leased propane tanks?

    If an owner of a stationary source leases propane tanks from a gas supplier, who is responsible for preparing and submitting the risk management plan (RMP) addressing the propane tanks? The owner of the stationary source is responsible for preparing and submitting the RMP. The risk management program regulations apply…

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  • New owner using existing RMP

    If a Risk Management Plan (RMP) facility is sold to a new owner, does the new owner have to develop a whole new RMP? Or can they use the existing RMP? No, a facility does not complete a new RMP as the facility keeps the original EPA Facility ID number…

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  • What happens if any of my items get damaged during the cleaning process?

    If any items get damaged, an independent appraiser will estimate the value of the item by using the videos and photos of your belongings to determine a fair value for the item that needs to be replaced. The assessment will then be presented to you for your approval. If you…

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  • What should I do with food items?

    Any food in your kitchen cabinets and refrigerator/freezer that you will not need while you are away can be left in place. This includes items such as spices, canned, boxed, and bagged foods, and refrigerated/frozen foods. Before you leave your home or office, please be sure to empty all garbage…

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