RMP reporting requirements, when to update, and how to submit using the new web-based system

Executive Summary (40 CFR 68.155)

• Mustbriefly describe the following elements
• Accidental release prevention and emergency response policies at your facility
• Your facility and the regulated substances handled
• General accidental release prevention program and chemical-specific prevention steps
• Five-year accident history
• Emergency response program
• Planned changes to improve safety (common deficiency)
• Be specific! (a general statement on safety policies does NOT suffice)

Updating Plan

• Updates may correlate to program updates, however there are additional circumstances that require update, regardless of change in program (40 CFR 68.190)

Required Reviews, Updates, and Resubmittal of RMPs

• No later than three years after a newly regulated substance is first listed by EPA (68.190(b)(2))
• No later than the dateon which a new regulated substance is first presentin an already-covered or new process above a threshold quantity (68.190(b)(3)-(4))

• Within 6 months of a change that

  • Requires a revised PHA or hazard review (68.190(b)(5))

  • Requires a revised off-site consequences analysis as provided in 40 CFR 68.36 (68.190(b)(6))

  • Alters the program level that applied to any covered process (68.190(b)(7))

  • At least every five years from the date of the initial submission or most recent resubmission

    • Resubmissions are full updates of the RMP, not just a correction

  • If a facility becomes no longer subject to this regulation, submit a deregistration to EPA within 6 months indicating that the facility is no longer covered (68.190(c))

    • Reasons for deregistration  

      • Terminated operations

      • No longer uses any regulated substance    

      • Reduced inventory of all regulated substances below thresholds

Corrections to Plan (40 CFR 68.195)

• Not big enough to warrant full update
• Does not alter the 5-year anniversary date
• Required Corrections to the RMP
• New Accident History Information
  • Within 6 months of any accidental release meeting the five-year accident history reporting criteria
    • The five-year accident history portion (68.168)
    • Date of the most recent incident investigation and the expected date of completion of any changes resulting from the investigation (68.175(j) and (l))
• Emergency contact information (68.195(b))
  • Within one month of any change in the emergency contact information required under 40 CFR 68.160(b)(6)
  • Common Deficiency

Source (pdf)