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  • Compliance Audit Date for First Time RMP Submissions

    Facilities subject to the Risk Management Program (RMP) requirements in 40 CFR Part 68 with Program Level 2 and 3 processes must perform compliance audits at least once every three years (40 CFR §§68.58 and 68.79). Section 7.10 of the RMP requires the date of the most recent compliance audit…

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  • RMP Facility Relocates

    Under the risk management program regulations in 40 CFR §68.190, owners or operators must revise and update their risk management plan (RMP) if they meet any of the specified criteria or deregister the RMP within 6 months if they are no longer subject to the rule. However, what should stationary…

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  • Voluntary Implementation and Submission of RMP

    Pursuant to the risk management program regulations in 40 CFR Part 68, owners and operators of a stationary source that have more than a threshold quantity of a regulated substance in a process must implement and submit a risk management plan (RMP) to EPA. If the risk management program regulations…

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  • EPA identification of facilities failing to submit RMPs

    What does EPA do to identify facilities that did not file an initial or updated RMP but were required to do so? EPA examines a number of existing databases to identify potential non-filers. If anyone has any information about any facility that may be subject to the Risk Management Program…

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  • Determining a facility's latitude and longitude

    A facility subject to the risk management program requirements in 40 CFR Part 68 must specify its latitude and longitude coordinates in Section 1.5 of the risk management plan (RMP). What tools are available to accurately determine a facility’s latitude and longitude? The owner or operator of a regulated facility…

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  • If a facility changes owners, but the manufacturing operations have not changed, are they REQUIRED to update their RMP?

    Yes. If the owner of a facility changes, the RMP on record with EPA should reflect the current owner by the date ownership changes or responsibility for operation of the facility is transferred. You do not have to update each section of your RMP if the only thing that has…

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  • When must RMPs be submitted, updated, and corrected?

    When must the risk management plans (RMPs) required under 40 CFR Part 68, Subpart G, be submitted? When are updates and corrections required? Compliance with the risk management program requirements (including submission of an RMP) is required by the date on which a regulated substance first becomes present above a…

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  • Difference between RMP update and RMP correction

    What is the difference between an update and a correction to a risk management plan (RMP)? Updates and resubmissions require the owner or operator to review and revise all sections of the RMP as needed to bring the RMP up to date and the submission must be accompanied by a…

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  • After a reportable accident, do I have to revise my RMP?

    I recently submitted my five-year RMP update required by section 68.190 (b)(1) and included my accident history for the previous five years. Two months later, we had another reportable accident. Do I have to do anything to revise my RMP? Yes. You must revise your accident history within six months…

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  • Does EPA confirm receipt of a facility's RMP?

    A facility subject to the risk management program regulations must submit its risk management plan (RMP) to EPA via the RMP*eSubmit system. Does EPA confirm receipt of the facility's RMP? When a facility's certifying official submits a complete RMP to EPA using RMP*eSubmit, the system will automatically generate and send…

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  • Five-year accident history in initial RMP submission

    The owner or operator of a stationary source subject to 40 CFR Part 68 must include a five-year accident history that includes significant accidental releases of one or more of the regulated substances from a covered process in the five years prior to the submission of an initial or updated…

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  • What are the possible health effects of nitrate exposure?

    Short-term: Excessive levels of nitrate in drinking water have caused serious illness and sometimes death. The serious illness in infants is due to the conversion of nitrate to nitrite by the body, which can interfere with the oxygen-carrying capacity of the child’s blood leading to blue baby syndrome (methemoglobinemia). This…

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  • What is nitrate?

    Nitrate (NO3) is a compound of nitrogen and oxygen naturally found in air, soil, water, and some food. Plants and animals require nitrates for their survival and growth, and the human body also produces this compound. In industry, nitrate is used as fertilizers for crops and lawns. Additionally, nitrates are…

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  • I use a carbon filter. Will this help?

    Activated carbon filters, such as those in a “Brita” water pitcher, DO NOT remove nitrates.

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  • Certifying Official Qualifying Criteria

    The owner or operator of a stationary source must complete a statement certifying that the risk management plan (RMP) is accurate and complete (40 CFR §68.185), a function performed by the Certifying Official through RMP*eSubmit. Are there criteria for qualifying as a Certifying Official when submitting an RMP in RMP*eSubmit…

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