I have been seeing a lot of RMP citations for failure to UPDATE the facility’s RMP every five (5) years. By far the number one issue this year based on the ESAs I have been trending. But one question comes to mind… RMP differs in PSM in a couple of ways, one way being that RMP requires the facility to have a documented “management system to oversee the implementation of the risk management program elements”. If you’re forgetting to do your five-year update doesn’t this indicate your management system is NOT functioning?!?!? For the life of me, I can not understand why EPA merely cites for not doing something every five years when the bigger issue is a FAILED MANAGEMENT SYSTEM which I can almost guarantee that if this simple requirement was missed there is much more missing within the RMP program at the facility! So when some people cry foul that EPA/OSHA issue too many citations, consider this trend. It would be EASY and logical for EPA to issue two citations for this failure to update and in my opinion, the FAILURE of the management system that should have directed someone to do the 5-year update is much more serious than merely missing a date. Here is EPA’s RMP Management system requirements: