As I stated last week and posted my updated RMP Audit Checklist ER questions, the RMP ER coordination activities should be at least in your “planning/discussion” phase with your off-site responders/resources. Even though 68.10(b) states that compliance with these activities must be completed by March 14, 2018 and the fact that the amendments did not become effective until September 21, 2018, many have been led to believe there is some kind of “grace period” for these coordination activities. Bottom line… there is NO grace period and these coordination efforts should be well underway in the Year 2020.