There is some language in the EPA’s Risk Management Plan program requirements that tends to cause some confusion…
The owner or operator of a stationary source shall revise and update the RMP submitted under ยง68.150 as follows:
(5) Within six months of a change that requires a revised PHA or hazard review
So when are we required to “revise our PHA” other than when we have to do our 5-year revalidation?