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  • Can I submit a plan that includes substances not currently present at the facility?

    Can an RMP regulated facility submit a Risk Management Plan (RMP) that includes substances not held at the facility at the time of submission? Yes. Predictive filing is an option that allows owners and operators of facilities whose operations involve highly variable types and quantities of regulated substances (e.g., chemical…

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  • Is classified information exempt from inclusion in the risk management plan (RMP) under 40 CFR Part 68?

    Yes. Part 68 does not require disclosure of classified information in violation of federal laws, regulations, or executive orders ( 61 FR 31695 ; June 20, 1996). The regulations clearly state that the RMP will exclude classified information (40 CFR §68.150(d)). Classified data or information excluded from the RMP may…

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  • Submitting Annual Certification for Operating Procedures to EPA

    The owner or operator of a facility who must prepare a Risk Management Plan (RMP) for a Program 3 process is required to develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in each covered process consistent with the process safety information (40 CFR…

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  • Updating RMP with Change in Ownership

    Pursuant to the risk management program regulations in 40 CFR §68.10, an owner or operator of a stationary source that has more than a threshold quantity of a regulated substance in a process must prepare a risk management plan (RMP). If a facility changes owner, but the manufacturing operations have…

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  • RMP Executive Summary Elements

    The owner or operator of a stationary source subject to 40 CFR Part 68 must include an Executive Summary in their Risk Management Plan. What elements must be included in the RMP Executive Summary? Pursuant to 40 CFR §68.155, the Executive Summary must briefly describe the following: accidental release prevention…

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  • Is the EPA Facility Identifier number the same as the RCRA ID number?

    Owners or operators of a facility subject to the risk management program regulations must include an EPA Facility Identifier number (EPA Facility ID) in their risk management plan (RMP) (40 CFR §68.160(b)(8)). Is this ID number the same as a facility's RCRA ID number? The RMP Facility Identifier is a…

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  • If a facility moves (their address changes) is it assigned a new RMP Facility ID?

    Yes. The facility is treated as a new facility and would be assigned a new number by EPA.

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  • Submitting a partial RMP

    Can a facility submit a partial risk management plan (RMP) (e.g., using the predictive filing option) and then update the plan when all elements of the RMP can be implemented? No. Facilities should not attempt to submit partial risk management plans (the RMP*eSubmit software will not allow incomplete RMPs to…

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  • No Procedure for Requesting RMP Five-Year Review Extension

    The Risk Management Program (RMP) regulations require the owner or operator of a stationary source to revise and update the source's RMP at least once every five years from the date of its initial submission or most recent full update (§68.190(b)). Is there a procedure for obtaining an extension to…

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  • Requesting RMP*eSubmit authorization code

    As the Certifying Official, how can I retrieve our lost Authorization Code needed by our new Preparer to access the facility’s Risk Management Plan (RMP) within RMP*eSubmit? The Certifying Official should contact the RMP Reporting Center ([email protected] / 703-227-7650) to request the Authorization Code.

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  • Submittal Process when Claiming Confidential Business Information (CBI)

    Pursuant to the risk management program regulations, facilities may make a claim of confidential business information (CBI) unless otherwise stated in 40 CFR §68.151. How does a facility that is claiming CBI submit its RMP? For a facility to claim information as CBI, the facility must submit to EPA a…

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