The difference between an RMP Correction and Update and the six (6) changes that will trigger an Update

RMPs must be updated at least once every five years. EPA offers a  Checklist for Submitting your Risk Management Plan (RMP).

We must fully update your RMP for resubmission sooner than the five-year anniversary date if any of these changes occur:

• If a change alters the Program Level that applies to any covered process, the RMP must be resubmitted within SIX (6) months of that change.
• If a change requires a revised Off-site Consequence Analysis, the RMP must be resubmitted within SIX (6) months of that change.
• If a change requires a revised process hazard analysis or hazard review, the RMP must be resubmitted within SIX (6) months of that change.
• If a NEW regulated substance is present above the threshold quantity in an already covered process, the RMP must be resubmitted on the date which the NEW SUBSTANCE IS PRESENT.
• If a regulated substance is present above the threshold quantity in a new process, the RMP must be resubmitted on the date which the SUBSTANCE IS PRESENT ABOVE THE THRESHOLD QUANTITY.
• If EPA begins regulating a new substance, the RMP must be resubmitted within THREE (3) years of the date the substance is first regulated.

Resubmissions reset the five-year anniversary date by which you must next update your RMP.

To resubmit, you MUST UPDATE ALL NINE (9) SECTIONS of your RMP.