Unlike OSHA, EPA wants to keep close tabs on you. Their instrument for doing so is the RMP Submit. RMP stands for Risk Management Plan. Here is an explanation of the RMP Submit requirements found in Title 40 CFR Part 68 Subpart G:
This subpart outlines the requirements for submitting a Risk Management Plan (RMP) for facilities handling regulated substances. It includes the submission process, deadlines, exclusion of classified information, procedures for confidential business information, and the requirements for an executive summary and registration form. The required information for the RMP includes source location, ownership, contact information, emergency procedures, regulated substances, release scenarios, accident history, prevention programs, and updates. It also outlines requirements for offsite consequence analysis and a five-year accident history. Additionally, it details the information needed for prevention and emergency response programs, certification for covered processes under Program 3, NAICS codes, safety information review, training programs, maintenance procedures, compliance audits, incident investigations, and emergency response coordination. The RMP must be reviewed and updated at specific intervals, and any necessary updates must be submitted to the EPA in the specified format. If a facility is no longer subject to the RMP requirements, a de-registration must be submitted to the EPA.
Here are some notable instances which trigger an RMP Update:
At least once every five (5) years from the date of its initial submission
Within six (6) months of a change that requires a revised PHA
Within six (6) months of a change that requires a revised Hazard Assessment
Within six (6) months of a change that alters the Program level that applied to any covered process (e.g., going above or below 10,000 lbs of ammonia)
More urgently, the RMP Submit needs to be corrected in the following scenarios:
Within six (6) months after a release which meets the five-year accident history criteria
Within one (1) month of any change to the emergency contact information
Note: The RMP Submit is required in OSHA's process safety management standard, which is why they it is not traditionally understood as being part of the 14 elements of PSM.
If you need help with an initial RMP Submit, update, or correction, submit a request through our contact page.
Comments