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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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  • 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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  • 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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