RMPs MUST be updated at least once EVERY five (5) years. Owners and operators responsible for RMP implementation should review the factsheet A Checklist for Submitting your Risk Management Plan (pdf). This factsheet provides a checklist to consider in updating and resubmitting RMPs.
Use EPA’s RMP*eSubmit for your resubmissions. For additional information see the RMP*eSubmit Users’ Manual (PDF).
RMPs must be fully updated SOONER than the five-year anniversary date, if any of the following changes below occur [40 CFR 68.190(b)].
- Within 6 months of a change that alters the Program Level that applies to any covered process;
- Within 6 months of a change that requires a revised off-site consequence analysis;
- Within 6 months of a change that requires a revised PHA or hazard review;
- The date on which a new regulated substance is first present in an already covered process above a threshold quantity;
- The date on which a regulated substance is first present above a threshold quantity in a new process; and
- Three years after the date when a substance is first regulated by EPA.
“Re-submissions” (NOT corrections!) re-set the five-year anniversary date by which the next update is due. To “re-submit”, all nine sections of your RMP MUST BE updated.
Correcting an RMP
“Correcting” an RMP refers to changing ONLY a part of an existing RMP, such as changing a contact name or revising only a certain section. Corrections do NOT generate a new anniversary date.