&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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