The owner or operator of a facility who must prepare a Risk Management Plan (RMP) for a Program 3 process is required to develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in each covered process consistent with the process safety information (40 CFR §68.69(a)). The owner or operator shall certify annually that these operating procedures are current and accurate (§68.69(c)).
Does this require the owner or operator to submit an annual update or certification to EPA or the implementing agency?