Failure to update RMP is more than 68.190 violation!

I see numerous RMP citations for businesses failing to update its RMP submittal every five years. And the EPA will issue a single citation using 68.190. One day, I hope the EPA will take this a step further and issue another citation against 68.15…

ยง 68.15 Management.

(a) The owner or operator of a stationary source with processes subject to Program 2 or Program 3 shall develop a management system to oversee the implementation of the risk management program elements.

(b) The owner or operator shall assign a qualified person or position that has the overall responsibility for the development, implementation, and integration of the risk management program elements.

(c) When responsibility for implementing individual requirements of this part is assigned to persons other than the person identified under paragraph (b) of this section, the names or positions of these people shall be documented and the lines of authority defined through an organization chart or similar document.

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