As I have said before, one of EPA’s most cited RMP matters is the lack of “updating the RMP with emergency contact information within a month of the change“. But today, the EPA offered some insight for those who may not have an emergency contact assigned within the month of the change. For me, there are MUCH LARGER ramifications for a facility who feels they do not have the proper personnel in place that can take over the emergency management role, if even just on an interim basis; after all, we are talking about a facility that exceeds the threshold of an Extremely Hazardous Substance and that is required to have a “management system” in place to manage these risks. But here is what EPA has to say about the “paperwork” aspect of this dilemma…