United States Office of Solid Waste EPA 550-R-09-001
Environmental Protection and Emergency Response September 2009
Agency www.epa.gov/emergencies
A CHECKLIST FOR SUBMITTING YOUR RISK MANAGEMENT PLAN (RMP)
FOR CHEMICAL ACCIDENT PREVENTION
In 1996, EPA established a list of substances regulated for risk of accidental release and issued rules
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 many covered facilities must update their
RMPs in 2009. This fact sheet provides important information about 2009 submissions and a
checklist to consider in preparing and resubmitting 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.
WHAT IS THE 5-YEAR UPDATE REQUIREMENT?
If you are the owner or operator of an RMP 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 §68.190 occur at your facility prior to the 5-year
anniversary of your RMP, you must update and resubmit your RMP. The 5-year anniversary date is
reset whenever you fully update and resubmit your RMP.
Your 5-year anniversary date is calculated as 5 years from the postmark date of your most recent
submission. This date is provided in the letter that EPA sent to you acknowledging receipt of your
most current RMP. If you need help determining your 5-year anniversary date, you can call the RMP
Reporting Center for assistance.
ARE THERE ANY CHANGES IN REPORTING FOR 2009?
In March 2009, EPA launched RMP*eSubmit, a Web-based system that allows facilities to securely
submit and make corrections to their RMPs. Facilities are encouraged to use the new RMP*eSubmit
system because it is easy to use, will improve data quality, and will enable you to access your RMP
24 hours a day, 7 days a week. Information from previous RMPs will be imported into the
RMP*eSubmit system to help facilities with their resubmissions. The data requirements have not
changed.
EPA will phase-out the "RMP*Submit" software in late 2009.
To use RMP*eSubmit you must have the following:
• Internet access
• JavaScript enabled Internet browser
• Central Data Exchange (CDX) account
Office of Emergency Management
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CHECKLIST FOR SUBMITTING RMP September 2009
HOW DO I SET UP AN ACCOUNT?
Important Definitions:
Central Data Exchange (CDX) is a secure, on-line location on EPA's network. CDX provides
standardized and secure information collection services and infrastructure for EPA program
partners. For example, CDX manages several Agency regulatory and monitoring programs,
receiving submissions from facilities. Once you set up your CDX account, you will
immediately be able to access your RMP through CDX.
Certifiers/Certifying Officials are facility owners or operators who must certify the accuracy
and completeness of the information reported in the RMP. They have signed and submitted a
one-time Electronic Signature Agreement (ESA) to the EPA. The ESA legally binds the
Certifier's electronic submission to their signature. Only Certifiers can submit the RMP.
Preparers have been granted permission by a facility to access the facility's existing RMP.
They prepare data for a new or updated RMP. A Certifier may also be the Preparer of an
RMP, or they may choose to delegate the responsibility to a specific individual. CDX notifies
the Certifier when the new or corrected RMP is ready for the Certifier's review and
submission. A delegated Preparer cannot submit the RMP.
Before you begin you will need:
• Your facility name, location, mailing address, and basic contact information (including e-mail
address).
• Your facility identifier (facility ID #) which can be found in the letter that EPA sent to you
acknowledging receipt of your most current RMP. NOTE: If this is the first time an RMP is
being submitted for your facility you do not need a facility ID #.
Step 1: Register the Certifying Official in CDX
>^ To use RMP*eSubmit, the Certifying Official must have a CDX account.
>^ To register with CDX, go to http://cdx.epa.gov, and complete the registration process for a
Risk Management Plan "Certifying Official." (See EPA's RMP*eSubmit Users' Manual at
http://www.epa.gov/emergencies/content/rmp/rmp esubmit.htm for detailed instructions).
Step 2: Complete the Electronic Signature Agreement (ESA) and mail it to EPA
The electronic signature is used to verify that the Certifying Official reviewed and submitted the RMP
in the RMP*eSubmit system.
>^ You will complete the ESA at the time you initially register in CDX, or, if you already had a
CDX account, at the time you add RMP*eSubmit access to your CDX account profile.
>^ CDX will guide you through the process of completing and submitting your ESA. You will
need your Facility ID #, unless this is the first time an RMP is being submitted for your facility.
If this is a first-time submission, CDX will prompt you to type in the name and address of the
facility in place of the facility ID #. You will receive a facility ID # via e-mail after you have
signed and submitted your ESA.
Print all pages of the ESA. Sign the completed ESA and mail all pages to EPA's RMP Reporting
Center:
RMP Reporting Center
P.O. Box10162
Fairfax, VA 22038
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CHECKLIST FOR SUBMITTING RMP September 2009
>^ The RMP Reporting Center will review and process the ESA, and send an e-mail to the
Certifying Official indicating that the electronic signature has been received and approved.
o NOTE: The e-mail will also include a unique Authorization Code. This Authorization
Code will be used by an RMP "Preparer" that you assign to enter data in
RMP*eSubmit for your facility.
Step 3: Register the "Preparer" and activate RMP*eSubmit access in CDX
>^ If the Certifying Official is also the Preparer: log in to CDX, add "Preparer" to your profile, and
enter your Unique Authorization Code.
>^ If the Certifying Official designates someone else as the Preparer, please provide that
designee with the Authorization Code for your facility. Preparers will be required to provide
this information when registering and activating their RMP*eSubmit access in CDX.
WHAT ARE THE SUBMISSION AND RESUBMISSION REQUIREMENTS?
For your submission and/or resubmission, you are required 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, 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.gov/tri/report/siting 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 Web sites also have siting tools,
such as, Geocode.com (http://www.geocode.com/) the Latitude Longitude Position Finder
(http://www.iuqqlinq.orq/bin/un.cqi/map-find), and Satellite Signals
(http://www.satsig.net/maps/lat-long-finder.htm ). The RMP*eSubmit Users' 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 U.S. Census Bureau at http://landview.census.gov.
>^ Check Your North American Industry Classification System (NAICS) code to make sure
your covered process(es) are coded correctly. The Census Bureau maintains a Web site
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).
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CHECKLIST FOR SUBMITTING RMP September 2009
*NOTE: RMP*eSubmit will be updated to include the 2007 NAICS Codes in the near future.
Sections 2-5: Worst Case and Alternate Release Scenarios
>^ Review and update your offsite consequence analysis (OCA) at least once every 5
years. Under the regulations, you are required to review and update your offsite
consequence analysis (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
analysis 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 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 U.S. Census Bureau. These publications,
including the County and City Data Book: 2000 (www.census.gov/prod/www/ccdb.html), are
available on the Census Bureau Web site (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 Web site 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:
http://ww.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.
Sections 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.
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CHECKLIST FOR SUBMITTING RMP September 2009
SOME THINGS TO REMEMBER
The regulations require you to periodically implement or review several aspects of your prevention
and emergency response programs. You should ensure that you are up-to-date with implementation
of these requirements. 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
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:
o 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.
o 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.
o Maintenance (40 CFR §68.56): 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.
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CHECKLIST FOR SUBMITTING RMP September 2009
o Operating procedures (40 CFR §68.89): For Program 3 only, you are required to
certify annually that your operating procedures are current and accurate.
o 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.
WHAT EPA RESOURCES ARE AVAILABLE ON THE WEB?
RMP Guidance
http://www.epa.gov/emergencies/content/rmp/rmp guidance.htm#General
Industry-Specific RMP Guidance
http://www.epa.gov/emergencies/guidance.htm
Offsite Consequence Analysis (OCA) Guidance
http://www.epa.gov/emergencies/content/rmp/rmp guidance.htm#OCA
RMP*eSubmit
http://www.epa.gov/emergencies/content/rmp/index.htmtfpreparing
Frequently Asked Questions (FAQs) about RMP
http://www.epa.gov/emergencies/content/rmp/caa fags.htm
Chemical Accident Prevention Provisions 40 CFR Part 68
http://www.epa.gov/emergencies/lawsregs.htm
TRI Facility Siting Tool
http://www.epa.gov/tri/report/siting tool/index.htm
LandView®
http://landview.census.gov
WHAT NON-EPA RESOURCES ARE AVAILABLE ON THE WEB?
2002 NAICS Codes (Census Bureau)**
http://www.census.gov/epcd/naics02/naicod02.htm
**NOTE: RMP*eSubmit will be updated to include the 2007 NAICS Codes in the near future.
Census 2000 Summary File
www.census.gov/prod/2003pubs/prodpr02-2.pdf
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CHECKLIST FOR SUBMITTING RMP September 2009
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.gov/SLTC/processsafetymanagement
Latitude Longitude Position Finder
http://www.iuggling.org/bin/un.cgi/map-find
Satellite Signals
http://www.satsig.net/maps/lat-long-finder.htm
WHERE DO YOU GO FOR HELP?
RMP Questions: Under Clean Air Act §112, states can choose to take delegation of the RMP
program. If they do, they become the implementing agency for that state
(http://www.epa.gov/emergencies/docs/chem/W-Chap-10.pdf). 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 Web site:
http://www.epa.gov/emergencies/where you live.htm.
You can also call the toll free RCRA, Superfund & EPCRA Call Center:
Phone: 800-424-9346 or 703-412-9810 (Metro DC area callers please use this number)
TDD: 800-553-7672 or 703-412-3323 (Metro DC area callers please use this number)
When: Monday - Thursday, 10:00 a.m. - 3:30 p.m. Eastern Time
Extended Hours of Operation (May, June, and July):
Monday - Friday, 9:00 a.m. - 5:00 p.m. Eastern Time
Closed Federal Holidays
RMP*eSubmit Software Support: For software questions, contact the RMP Reporting Center:
Phone: 703-227-7650
When: Monday - Friday, 8:00 a.m. - 4:30 p.m. Eastern Time
Closed Federal Holidays
E-mail: RMPRC@epacdx.net
HOW CAN YOU RECEIVE 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 e-mail to:
lyris@lists.epa.gov and include the words: subscribe EPA-CEPP your_name in the body of the
message. Replace "your_name" with your first and last names.
Office of Emergency Management
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