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. If this is the first RMP for a facility, what should the facility enter for that section?

First-time RMP submissions for newly regulated stationary sources, or new processes at pre-existing regulated facilities, are not required to include a compliance audit date in the RMP. In these situations, the compliance audit date should be left blank.