RMP eSubmit Webinar Questions and Answers
Not sure how “official” these Q&A’s are, but they were provided by EPA to questions that were asked during their RMP Webinars the last couple of months. I will post
1. Regulations
Q: Will the new Homeland Security regulations (CFATS) impact the Risk Management Plan submission and sharing of sensitive data?
A: No. Homeland Security regulations do not impact RMP submissions. The CFATS regulations do not permit facilities to withhold from EPA or other federal agencies information required for compliance with these other agencies’ regulations. Even when information may be an input into analyses required by CFATS, such as chemical quantity, that information must continue to be supplied to EPA and other federal agencies, and may not be labeled as Chemical-terrorism Vulnerability Information (CVI) when supplied to those agencies. The RMP regulation already restricts the sharing of Offsite Consequence Analysis information submitted to EPA in RMPs.
Q: Are we required to re-submit with RMP*eSubmit, even if it has been less than 5 years since our last submittal?
A: No. There have been no changes to the reporting requirements.
2. Owner / Operator (Certifying Officials) & Preparers
Q: Can the owner/operator designate a position title instead of the name of the Certifying Official?
A: No. They have to designate an actual person (not a company) and a signature is required.
Q: Can a contractor prepare a submission for a facility.
A: Yes, a contractor can be designated as a Preparer by the Certifying Official.
Q: Must the Certifying Official be the plant or site manager?
A: The Certifying Official must be “the owner, operator, or a designated senior management official for the facility.” This basically means it can be the plant manager or a senior manager on site (e.g., ESH manager, operations manager, etc.) or a corporate officer if you have a multi-facility company where you have a corporate officer to certify submissions. The owner/operator or designated senior management official is not an hourly employee. Of course there are small facilities where there are only a few people on site; in those cases it is usually the plant manager or site owner.
Q: Our plant manager is the Certifying Official for TRI. Can the same person be a Certifying Official for RMP or does it need to be someone else in our organization?
A: The plant manager could be the Certifying Official; however, he has to submit a separate ESA for RMP.
Q: Does the highest ranking officer at the site complete the “Certifying Official” requirements?
A: The Certifying Official can be the owner, plant manager, or a senior manager at the facility. It doesn’t have to be the senior official on site, but it can’t be a low-level employee. It can also be a corporate officer if you have a multi-facility company manager at the facility. The Certifying Official should be someone who can sign official documents on the facility’s behalf.
Q: Where can I find the definition of Certifying Official?
A: Definitions can be found on page 1 of the RMP*eSubmit Users’ Manual. (http://www.epa.gov/emergencies/docs/chem/RMPeSubmit_users_manual.pdf) Basically, the Preparer and Certifying Official can be the same person. The Preparer enters the data. The Certifying Official actually approves and submits the RMP.
Q: I am a contractor with about a dozen separate clients who want me to be their Preparer. Do I need 12 separate accounts or just one?
A: No, only one CDX account is needed. The Certifying Official will provide you with an Authorization Code (AuthCode) for each RMP facility, once they have registered.
Q: I manage eight RMP submissions for our company. As the Certifying Official, can I also be the submitter for each location or for just one?
A: You can be the Certifying Official for all of your company’s facilities.
Q: Can we have several Certifying Officials for one company – one for each location?
A: Yes, you can have a different Certifying Official for each facility. Each Certifying Official has to create their own account in CDX, then create an Electronic Signature Agreement (ESA) and mail it to the Reporting Center.
Q: What if our Certifying Official left the facility?
A: You need to have another person become the Certifying Official. They would need to go through the same process: CDX ID and ESA. You can have more than one Certifying Official, for backup purposes. (If you know that the Certifying Official has left the company, please make sure to get his/her account de-activated by calling CDX Help Desk.)
Q: What do you do if you are a consultant who has been hired to prepare the RMP for a company?
A: You become a Preparer. After the RMP is prepared, the Certifying Official completes the process.
3. Submitting and Accessing RMPs
Q: Are hardcopy (paper) RMPs still accepted?
A: Yes, paper submissions will be accepted, but we encourage people to use RMP*eSubmit. Typically, paper submissions have errors because the electronic validation process is not involved in the creation of the submission. Paper submissions may take longer to process due to the manual steps involved.
Q: Will old RMPs be uploaded into the new system?
A: Only the facility’s latest RMP will be uploaded into the RMP*eSubmit system.
Q: For new facilities, some fields don’t apply, such as the date of the previous compliance audit. Does this cause an error?
A: No. If the field is not pertinent to a new facility, it will not cause an error.
Q: What if my RMP facility is no longer in operation? How can I deactivate the RMP?
A: The De-registration form is Appendix E of the RMP*eSubmit Users’ Manual.
Q: What is RMP*Comp and where can I find it?
A: RMP*Comp can be found on our Web site. It is a free program that you can use to complete the offsite consequence analyses (both worst case scenarios and alternative scenarios) required under the Risk Management Program rule.
Q: Will EPA employees be able to view incomplete RMP Submittals?
A: No. An incomplete submittal is not accepted by system as a submission, so only the Preparer can see their incomplete (or draft) submission.
Q: Does entering a PHA completion (or update) date that is more than 5 years in the past cause an error or a warning?
A: Yes. A warning message will appear in this case, but it may be overridden by the Preparer.
Q: Does entering an operating procedure review date that is more than one year in the past cause an error or warning?
A: Yes. A warning message will appear in this case, but it may be overridden by the Preparer.
Q: In the past, we where required to have an RMP postmarked by the date that we had a regulated quantity on site. How does this work with this system? Do we only need to request an RMP ID by the time we have the regulated quantity on site?
A: The RMP must be submitted, and the prevention program must be in place on site by the time the chemical is present above a threshold quantity in a process. In other words, the replacement for the postmark date under the old system will be the date of receipt of the electronic submission (i.e., the day the Certifying Official submits the RMP in CDX).
Q: My client’s facility has an existing RMP is in the system and there are no significant changes. Approximately how long will it take to complete the online submittal?
A: Since you will be modifying only a small amount of data, the process should not take very long. RMP*eSubmit will be pre-populated with your facility’s last RMP.
4. Central Data Exchange (CDX) and the Electronic Signature Agreement (ESA)
Q: How do I find out if we already have a CDX account, and the login and password information?
A: The CDX account is tied to a specific person, not a facility. So, if another person at your facility has an account, and they are going to also be involved in RMP submissions, they can use that account. If they have forgotten the password, the CDX help desk can help them recover it. If, on the other hand, that person with the existing CDX account will not be involved in RMP submissions, the person who will certify and/or prepare the RMP will need a CDX account.
Q: While working in CDX, the screen tends to timeout due to inactivity. Will this be an issue for Certifying Official /Preparers?
A: Timing-out is a security feature of the system. The systems will time-out after inactivity. Your work will automatically be saved.
Q: I have only one facility. Can I send just the last page of the Electronic Signature Agreement (ESA)?
A: Send all pages of the ESA, otherwise we will not have all of your facility information and will not be able to complete the registration process. The first page(s) contain facility and Certifying Official information. The next section contains the legal requirements and the last page contains the signatures. All are important parts of the ESA and it is a legally binding document.
Q: If there is already an electronic signature on file in CDX for other programs, will another be required for RMP?
A: Yes. You will need to submit an ESA specifically for RMP*eSubmit.
Q: How do facility owner/operators obtain an Electronic Signature Agreement?
A: Creating and submitting an ESA is part of the CDX registration process. It is covered in the RMP*eSubmit Users’ Manual and the system walks the users through the required steps. The person that the facility designates as the Certifying Official (this could be the owner/operator), goes into the system to create the ESA.
Q: How long does it take to get the authorization code (AuthCode) once the ESA has been submitted?
A: As soon as the RMP Reporting Center receives the complete ESA in the mail, they will usually process the ESA the same working day. It could take a couple of days to a week during periods of high demand. If your ESA is complete, the Reporting Center will send the AuthCode by e-mail to the Certifying Official. If there are any discrepancies in the ESA, the Reporting Center will contact the Certifying Official to resolve the issue(s). It’s a good idea to get the ESA done early – do not leave it to the last minute!
Q: I have a CDX account, but the Certifying Official is new. Do I set up a new account?
A: The person who will have the role as Certifying Official will need their own CDX account. Only the Certifying Official can create an account.
Q: Is the password limited to letters and numbers, or can I use “special” characters?
A: You must use letters and numbers. You can not use special characters.
Q: Will I need to register with RMP*eSubmit as the regulating authority or will I still review submissions with RMP*Info?
A: No. Regulating authorities should not register for RMP*eSubmit. Regulating authorities will continue to use RMP*Info to view submissions.
Q: I have a CDX account for TRI-ME Web. How do I get an account for RMP?
A: You can use your CDX account for TRI, just add a “new role” using the process outlined in the PowerPoint presentation or as described in the RMP*eSubmit Users’ Manual.
Q: We have multiple US sites covered by RMP, so should a single corporate officer complete the Electronic Signature Agreement (ESA) for all sites or should each plant manager complete an ESA for each site individually?
A: You can do either – whichever works for you. If that single person is responsible for all sites, then one ESA is needed. If each plant manager is responsible for their own facility, then separate ESAs are required. You decide.
Q: What if I can’t remember my CDX User Name and Password?
A: You can call the CDX Help Desk, and they will help you recover it: 888-890-1995. The number can also be found on the CDX home page: http://cdx.epa.gov.
Q: Who should we call if we submitted our ESA, but haven’t heard anything yet?
A: You may contact the RMP Reporting Center on 703-227-7650.
Q: We have a CDX account from previous administrative changes. Will we still have to go through the profile set-up and ESA process?
A: You can login using your existing CDX account, but you will need to register for RMP*eSubmit and prepare and submit all pages of the Electronic Signature Agreement.
5. Webinar-specific Questions
Q: Will we be able to get a copy of the Power Point presentation and the questions and answers that have been submitted?
A: Yes, we will provide information at the end presentation. It is a large file to download, so we will be sending you a link to an ftp site where you can download it.