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…
Q. Pursuant to the risk management program regulations, the owner or operator of a regulated stationary source is required to submit a correction within one month of any change in the emergency contact information (40 CFR §68.195(b)). What should the owner or operator do for the required correction if they do not have a replacement contact in place within one month?
A. EPA recognizes that personnel changes may sometimes take longer than a month, but in that event, it expects the owner or operator to have assigned the responsibility to someone in the interim. Given the electronic means of correcting such information, EPA believes it is reasonable to require facilities to keep this information relatively current, even if that means supplying the name of an interim emergency contact person until a permanent person is in place.
Q&A Posted today 12/21/2017
Source of all EPA RMP “Frequently Asked Question”: https://emergencymanagement.zendesk.com/hc/en-us