Don’t let fools scare you! EPA RMP 3rd Party Compliance Audits

Yes, as I posted a couple of weeks ago, the RMP Amendments are now in effect (at least those with compliances dates that have passed – some have dates further out).  One such requirement that seems to be causing a stir is “3rd Party Audits” for Program 2 and 3 Level RMP processes (e.g. 68.59 and 68.80).  LinkedIn and other social media platforms have less than scrupulous contractors/consultants telling everyone their next 3-year RMP compliance audit must all be done by a “third-party”… NOTHING could be further from the truth!  The requirement(s) for a “third-party audit” are applicable under the following circumstances AND ONLY under these circumstances:

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