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United States
Environmental Protection
Agency
Office of Solid Waste
and Emergency Response
EPA 550-B-1 4-002
April 2014
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 2014. This fact sheet provides important information about 2014 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 based on the date of your most recent, full submission. This date is
provided in the response 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?

In March 2009, EPA launched RMP*eSubmit, a Web-based system that allows facilities to securely
submit and make corrections to their RMPs. The RMP*eSubmit software application is easy to use,
improves data quality, and enables you to access your RMP 24 hours a day, 7 days a week.
Information from previous RMPs has been imported into the RMP*eSubmit system to help facilities
with their resubmissions. The data requirements have not changed.

EPA phased-out the "RMP*Submit" software in late 2009; the software is no longer supported.

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                                                       April 2014

HOW DO I SET UP AN ACCOUNT?

Important Definitions:

      Central Data Exchange (CDX) is a secure, online 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 email
      address).
     Your EPA Facility Identification Number (Facility ID #) can be found in the response EPA sent
      to you  acknowledging receipt of your most recent RMP.
         o  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 email after you have signed,
      printed all pages, and mailed your ESA to the RMP Reporting Center.

Print al[ pages of the ESA. Sign the completed ESA and mail all pages  to EPA's RMP Reporting
Center:
             RMP Reporting Center
             P.O.  Box 10162
             Fairfax, VA 22038
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   >^ The RMP Reporting Center will review and process the ESA, and send an email to the
      Certifying Official indicating that the electronic signature has been received and approved.
          o  NOTE: The email will also include a unique Authorization Code. This Authorization
             Code will be used by an RMP Preparer that Certifying Official assigns 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. 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 Google Maps (https://maps.google.com/),
      Google Earth (http://www.google.com/earth/), Bing Maps (http://www.bing.com/maps/), and
      MapQuest (http://www.mapguest.com/satellite-maps/).

   >^ Check Your North American Industry Classification System (NAICS)  code to make sure
      your covered process(es) are coded correctly. The Census Bureau maintains a Website
      with the 2014 NAICS Codes (https://www.census.gov/eos/www/naics/) and a list of the
      correspondence between the NAICS 1997 and NAICS 2002 codes.

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
Office of Emergency Management

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 CHECKLIST FOR SUBMITTING RMP                                                       April 2014

      analysis are still valid and make changes, as appropriate. The results of your review should be
      documented and maintained as part of your RMP records. Any changes to the scenarios
      resulting from your 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 may use your own GIS
      (Geographic Information System) software and obtain the latest Census data (such as through
      https://www.census.gov/geo/), or use the mapping application MARPLOT, from the CAMEO
      software suite (http://www2.epa.gov/cameo).

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 processes, 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.


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.
Office of Emergency Management

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 CHECKLIST FOR SUBMITTING RMP                                                       April 2014

      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 and verifying that PHA recommendations have
      been resolved; and reviewing incident investigation reports. Updated and revalidated PHAs
      completed to comply with OSHA's Process Safety Management Standard (29 CFR
      1910.119(e)) (for processing covered under both the RMP regulations and PSM standard)
      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 processes, 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 processes,
             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 processes, you are required
             to inspect and test your process equipment according to the schedule that you have
             established based on good engineering practices.
         o   Operating procedures (40 CFR 68.89): For Program 3 processes 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 processes only, if you make
             changes to the process other than "replacements in kind", you are required to update
             your process safety information and any procedures and affected by the change.

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.qov/emerqencies/quidance.htm
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 CHECKLIST FOR SUBMITTING RMP                                                      April 2014

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://emergencvmanagement.supportportal.com/ics/support/KBSplash.asp

Chemical Accident Prevention Provisions 40 CFR Part 68
http://www.epa.gov/emergencies/lawsregs.htm
WHAT NON-EPA RESOURCES ARE AVAILABLE ON THE WEB?

2012 NAICS Codes (Census Bureau)
https://www. census.gov/eos/www/naics/

Process Safety Management Standard (OSHA)
http://www.osha.gov/SLTC/processsafetvmanagement

Some Tools to Verify your Latitude and Longitude Coordinates
Google Maps: https://maps.google.com/
Google Earth: http://www.google.com/earth/
Bing Maps: http://www.bing.com/maps/
MapQuest: http://www.mapguest.com/satellite-maps/


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 Website:
http://www.epa.gov/epahome/wherevoulive.htm.

You can also call the toll free Superfund, TRI, EPCRA, RMP & Oil Information Center (also known as
the "Info Center"):

      800-424-9346 Toll  Free
      703-412-9810 Metropolitan DC area and international calls
      Monday - Friday: 10:00 AM - 5:00 PM Eastern Time / Closed on Federal Holidays

RMP*eSubmit  Software Support: For software questions, contact the RMP Reporting Center:

      703-227-7650 All domestic and international calls
      Monday - Friday: 8:00 AM - 4:30 PM Eastern Time / Closed on Federal Holidays
      RMPRC@epacdx.net
Office of Emergency Management

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