&EPA
United States
Environmental Protection
Agency
Office of Solid Waste
an Emergency Response
(5104)
EPA 550-F-04-001
February 2004
www.epa.gov/emergencies
                    A Checklist for Resubmitting Your  Risk

                    Management Plan (RMP)  For Chemical

                    Accident Prevention

                    In 1996, EPA established a list of extremely hazardous substances and issued
                    regulations for the prevention and mitigation of accidental releases of those
                    substances under section 112(r) of the Clean Air Act. Facilities covered by the
                    regulations are required to implement a risk management program and submit
                    a description of the program (called a risk management plan, or RMP) to EPA.
                    RMPs must be updated at least once every five years, and most covered
                    facilities must update their RMPs in 2004. This fact sheet provides a checklist
                    for preparing a 5-year update. It is important that owners, operators, plant
                    managers, and others responsible for RMP implementation review this
                    information and take appropriate steps to update their RMPs.
                    The 5-Year Update Requirement

                    If you are the owner or operator of an
                    RMP-covered facility, EPA's Chemical
                    Accident Prevention regulations at 40
                    CFR Part 68 require that you fully update
                    and resubmit your RMP at least once
                    every 5 years.  If certain process
                    changes described in 40 CFR section
                    68.190 occur at your facility prior to the
                    5-year anniversary of your RMP, you
                    must update and resubmit your RMP
                    before those changes are made. The 5-
                    year anniversary date is reset whenever
                    you fully update and resubmit your RMP.
                    The majority of facilities submitted their
                    initial RMPs by the original June 21,
                    1999 deadline and have not resubmitted
                    their RMPs since.  This means that most
                    RMPs must be fully updated and
                    resubmitted to EPA by June 21, 2004.

                    This document covers information
                    important to the 2004 resubmissions as
                    well as provides a checklist to consider in
                    updating and resubmitting your RMP.

                    How to Determine Your 5-Year
                    Anniversary Date

                    If you submitted your initial RMP before
                    the original June 21, 1999-deadline, you
                    are required to submit your 5-year
                                       update by June 21, 2004, not before. If
                                       you filed early, you may have received
                                       correspondence indicating an earlier due
                                       date.  However, EPA's interpretation of
                                       the regulations is that RMPs initially due
                                       on June 21, 1999 must be updated by
                                       June 21, 2004, not before.

                                       If you submitted your initial RMP after
                                       June 21, 1999, or have resubmitted
                                       since your initial submission, your 5-year
                                       anniversary date is calculated as 5 years
                                       from the postmark date of your latest
                                       submission.

                                       Important Information for 2004

                                       In July 2003, EPA proposed to amend
                                       RMP reporting requirements in several
                                       ways, including the addition of several
                                       new data elements. The comment period
                                       for this proposal closed on September
                                       15, and EPA plans to issue the final rule
                                       at the earliest possible date. The new
                                       version of RMP*Submit (EPA's software
                                       for RMP submission) will reflect any new
                                       reporting requirements resulting from this
                                       final rule. Consequently, the new version
                                       of RMP*Submit cannot be released until
                                       the final rule is issued. EPA currently
                                       estimates that the new version of
                                       RMP*Submit (known as RMP*Submit
                                       2004) will be released in March 2004.
                                       The final rule, an accompanying fact
                                       sheet, and information regarding the
                                       availability of RMP*Submit 2004 will be
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posted, as they become available, on EPA's Office of
Emergency Prevention, Preparedness and Response
website at http://www.epa.gov/emergencies. Interested
parties may also receive email information updates by
subscribing to OEPPR's listserv.  (See page 6 of this
document for information on how to subscribe to the
listserv.)

If you submitted your initial RMP  by the June 21, 1999
deadline and have not  resubmitted an RMP since, you
will be reguired to include in your resubmission any
new data elements added by the final rule.  All others
will be reguired to submit a correction of their RMPs to
include the new data elements, as applicable.
Information about correcting your RMP is not covered
in this document but will be available in the
RMP*Submit 2004 Users Manual.

A Checklist for Your 5-Year Update

For your 5-year update and resubmission, you are
reguired to review all nine sections of your RMP,
update as appropriate,  and certify that the entire
updated RMP is true, accurate, and complete. The
following  is a checklist  of some key elements in  your
RMP that you should review for your resubmission.

Section 1: Registration Information

• •    Review your registration information and
       make any necessary corrections to ensure
       that it is up-to-date.

       Remember that your "facility location address"
       is the physical  location where regulated
       substances are present. The "facility location
       address" cannot be a post office or rural box
       number. Also,  remember that your "mailing
       address" is the address that EPA will use for
       sending all non-electronic correspondence.

• •    Verify your  latitude and longitude
       coordinates.

       Latitude and longitude coordinates were
       reported incorrectly in many  RMPs.  The
       latitude and longitude of your facility can be
       determined in several different ways, including
       through the use of global positioning system
       (GPS) receivers, U.S. Geological Survey
       (USGS) topographic maps
       (http://mac.usgs.gov/maplists/index.html), and
       web-based siting tools. EPA maintains a web-
       based siting  tool as part of the Toxic Release
       Inventory (TRI) program at
       http://www.epa.qov/tri/report/sitinq tool/index.htm.
       The tool combines interactive maps and aerial
       photography to help users get latitude and
       longitude coordinates (in degrees, minutes, and
       seconds) of their sites. Several commercial
       websites also have siting tools, such as,
       Geocode.com (http://www.geocode.com/) and
       Topozone.com (http://www.topozone.com).
       The RMP*Submit manual describes the use of
       these tools in more detail.

       Additionally, LandView® (version 5 or 6) can
       be used to determine latitude and longitude.
       LandView® has the added benefit that it also
       contains the Census 2000 data. LandView® is
       available for purchase from the US Census
       Bureau at http://landview.census.gov.

• •     Check whether the North American Industry
       Classification System (NAICS) code for
       your covered process(es) has changed.

       Because NAICS was revised in 2002, you
       should also check whether the  NAICS code you
       reported for your covered process(es) is still
       valid. The NAICS codes for construction and
       wholesale trade changed substantially.  A
       number of other classification codes have also
       been revised. The Census Bureau maintains a
       website  with a list of the 2002 NAICS Codes
       (http://www.census.qov/epcd/naics02/naicod02.htm)
       and a list of the correspondence between the
       NAICS 1997and NAICS 2002 codes
       (http://www.census.gov/epcd/naics02).

Sections 2 through 5: Worst Case and Alternate
Release Scenarios

• •     Review and update your offsite
       consequence analyses (OCA) at least once
       every 5 years.

       Under the regulations, you are  reguired to
       review and update your offsite  conseguence
       analyses (OCA) at least once every five years
       (40 CFR 68.36). You should review your
       documentation to determine whether the
       parameters and assumptions used in the
       analyses are still valid and make changes as
       appropriate.  The results of this review should
       be documented and maintained as part of your
       RMP records. Any changes to  the scenarios
       resulting from this review,  including changes in
       the distance-to-endpoint(s), should  be reported
       in your resubmission.

• •     In your OCA, use current data to estimate
       population.

       You should review the data used to estimate
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       population and environmental receptors and
       update that information as appropriate.  You
       may have used Census data to estimate the
       residential population within the distance to
       endpoint.  If so, you should update this
       estimate based on the latest Census data.

       The 2000 Census data can be found in
       publications of the US Census Bureau.  These
       publications, including the County and City
       Data Book: 2000
       (www.census.qov/prod/vvww/ccdb.html), are
       available on the Census Bureau website
       (www.census.gov') and in public libraries.
       Additionally, two Census products are available
       that facilitate calculation of the population
       within the relevant geographical areas for OCA
       analysis (i.e., within the circle defined by the
       distance-to-endpoint for your worst-case and
       alternative release scenarios).  The first is
       LandView® (version 5 or 6). Information about
       obtaining LandView® can be found on the
       Census website at  http://landview.census.gov.
       The other product is the Census 2000
       Summary File  1.  Information about the
       Census 2000 Summary File can be found at:
       www.census.gov/prod/2003pubs/prodpr02-
       2.pdf.

Section 6: Accident History

• •     Update your 5-year accident history.

       You must update your accident history to
       include any accidental releases that occurred
       over the past five years from a covered
       process and resulted in deaths, injuries, or
       significant property damage on site, or known
       off-site deaths, injuries, evacuations, sheltering
       in place, property damage, or environmental
       damage. You  may remove from your accident
       history any accident that occurred more than 5
       years ago.

Section 7 and 8: Prevention Program

• •     For Program 2 and Program 3, report the
       most recent dates of your prevention
       program activities in your resubmission.

Section 9: Emergency Response

• •     Report the dates of your most recent review of
       your emergency response program and most
       recent training  in your resubmission.
Recurring Requirements

In addition to requirements for updating your RMP, the
regulations require several aspects of your prevention
and emergency response programs to be periodically
implemented or reviewed. You should ensure that you
are up-to-date with implementation of these recurring
requirements. As indicated previously, you should
reflect the most recent information for your prevention
and emergency response programs in your RMP
update.  For example, you should report the date of
your most recent hazard review/process hazard
analysis update, and the completion date for any
changes resulting from the hazard review/process
hazard analysis update, in your resubmission.

The following highlights some of these recurring
requirements:

Prevention Program

»•      For Program 2, review and update your
       hazard review at least once every 5 years.

       If your process is designated as Program 2,
       you are required to review and update your
       hazard review at  least once every five years
       (40 CFR  68.50). The review and any updates
       of the hazard review,  as well as resolution of
       any problems identified, must be documented.

«•      For Program 3, update and revalidate your
       process  hazard analysis (PHA) at least once
       every 5 years.

       If your process is designated as Program 3,
       you are required to update and revalidate your
       process hazard analysis (PHA) at least once
       every five years (40 CFR 68.67) to assure that
       your PHA is consistent with the current
       process.  This update and revalidation must  be
       conducted by a team.

       To update and revalidate your PHA, you should
       evaluate  your current process hazard analysis
       for accuracy and  completeness.  This
       evaluation should include checking that all
       modifications to your process are reflected in
       the PHA  ; evaluating the  process safety
       information to ensure that it is complete,
       current, and accurate; verifying that operating
       procedures are adequate, up-to-date, and
       implemented; documenting that any PHA
       recommendations have been incorporated into
       equipment design, process conditions,
       mechanical integrity, operating procedures,
       training, and emergency response; verifying
       that recommendations have been
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   implemented; and reviewing incident
   investigation reports. Updated and revalidated
   PHAs completed to comply with OSHA's
   Process Safety Management Standard (29
   CFR 1910.119(e)) are acceptable to meet this
   requirement, provided that they also consider
   offsite consequences.

   The revalidation and any updates of the
   process hazard analyses, as well as resolution
   of any recommendations, must be
   documented. This documentation must be
   retained as part of your RMP records for the
   life of the process.
   For Program 2 and Program 3 processes,
   verify that you have carried out any
   recurring prevention program
   implementation requirements

   The regulations require several aspects of your
   prevention program to be periodically
   implemented or reviewed. These are some
   reminders about your prevention program
   activities:

   >•       Training in operating procedures (40
          CFR 68.54 and 68.71): For both
          Program 2 and 3, you  are required to
          provide refresher training in operating
          procedures at least every three years,
          and more often if necessary.
       •>      Compliance audits (40 CFR 68.58 and
              68.79): For both Program 2 and 3, you
              are required to audit your procedures
              and practices for compliance with the
              regulations at least every three years
              to verify their adequacy and
              implementation.

       •>       Maintenance (40 CFR 68.56 and ): For
              both Program 2 and  3, you are
              required to inspect and test your
              process equipment according to the
              schedule that you have established
              based on good engineering practices.

       •>      Operating procedures (40  CFR 68.89):
              For Program 3 only,  you are required
              to certify annually that your operating
              procedures are current and accurate.

       >•      Management of change (40 CFR
              68.75): For Program 3 only, you are
              required to update your process safety
              information and your procedures and
              practices for a covered process in the
              event of any change to the process
              chemicals, technology, equipment, or
              procedures.

Emergency Response Program

>•      You are required to periodically review and
       update, as appropriate, your emergency
       response program and to notify your
       employees of any changes to your emergency
       response plan (40 CFR 68.95).  You should
       verify that your facility is  currently  included in
       the community emergency response plan and
       you should also review and update your
       procedures for notifying emergency responders
       in an emergency.
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                               EPA Resources on the Web

          Download General RMP Guidance
                 http://vosemite.epa.gov/oswer/ceppoweb.nsf/content/EPAquidance.htmtfGeneral

          Download Industry-specific RMP Guidance
                 http://yosemite.epa.gov/oswer/ceppoweb.nsf/content/EPAguidance.htm

          Download Offsite Conseguence Analysis (OCA) Guidance
                 http://yosemite.epa.gov/oswer/ceppoweb.nsf/content/EPAguidance.htmtfGeneral

          Download RMP*Submit
                 http://yosemite.epa.gov/oswer/ceppoweb.nsf/content/ap-rmsb.htm

          Freguently Asked Questions (FAQs) about RMP
                 http://yosemite.epa.gov/oswer/ceppoweb.nsf/content/caa-fags.htm

          RMP Implementing Agency Contacts
                 http://yosemite.epa.gov/oswer/ceppoweb.nsf/content/112r-sts.htm

          TRI Facility Siting Tool
                 http://www.epa.gov/tri/report/siting tool/index.htm
                            Non-EPA Resources on the Web

                 2002 NAICS Codes (Census Bureau)
                        http://www.census.gov/epcd/naics02/naicod02.htm

                 Census 2000 Summary File
                        www.census.gov/prod/2003pubs/prodpr02-2.pdf

                 County and City Data Book:2000 (Census Bureau)
                        http://www.census.gov/prod/www/ccdb.html

                 Geocode.com
                        http://www.geocode.com

                 Process Safety Management (OSHA)
                        http://www.osha-slc.gov/SLTC/processsafetymanagement/

                 Risk Management Program 40 CFR Part 68 (Government Printing Office)
                        http://www.access.gpo.gov/nara/cfr/cfrhtml 00/Title 40/40cfr68 00.html

                 Topozone.com
                        http://www.topozone.com

                 LandView®
                        http://landview.census.gov
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                                      Where to go for help

RMP Questions:

       Under Clean Air Act section 112, states can choose to take delegation of the RMP program. If they do, they
       become the implementing agency for that state. In delegated states, you may contact your state
       implementing agency for assistance. In all other states, your EPA regional office is the implementing
       agency for your state and you may contact them for assistance. We maintain current phone numbers for
       state and EPA regional contacts on our website at: www.epa.gov/emergencies.

RMP Regulatory Questions:

       If you have a question about an RMP reporting requirement, you can also call the toll free RCRA,
       Superfund  & EPCRA Call Center at:
       Phone: (800) 424-9346 or (703) 412-9810 [DC area callers please use this number]
       TDD:   (800) 553-7672 or (703) 412-3323 [DC area callers please use this number]
       When:  Monday - Friday, 9:00 am - 5:00 pm Eastern Time
              Closed Federal Holidays

RMP*Submit Software Support:

       For software questions or installation problems, or mailing and receipt issues, contact the RMP Reporting
       Center at:
       Phone: (301)429-5018
       When:  Monday - Friday, 8:00 am - 4:30pm Eastern Time
              Closed Federal Holidays
       Email:  userrmp.usersupport@epcra.org
How to get RMP program updates from EPA by e-mail

              You can receive periodic updates about the RMP program and other aspects of prevention,
              preparedness and emergency response through our listserv.

              To subscribe, send an email to: lyris@lists.epa.gov

              Include the words:

                     subscribe EPA-CEPP your_name

              in the body of the message.  Replace "your_name" with your first and last names.
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