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Risk Management Planning (RMP)
Regs, Guides, Publications & Fact Sheets
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Re-submitting, Correcting, or Withdrawing a Risk Management Plan (RMP)

 

bullet Re-submitting a Risk Management Plan (RMP) bullet Correcting an RMP bullet Deregistering a Facility bullet Withdrawing an RMP for Flammable Fuels  

Re-Submitting an RMP

RMPs must be updated at least once every five years. Owners and operators responsible for RMP implementation should review the factsheet "A Checklist for Resubmitting your Risk Management Plan (RMP) for Chemical Accident Prevention" (6 pp, 174K, About PDF). This factsheet provides a checklist to consider in updating and resubmitting RMPs.

You must fully update your RMP for re-submission sooner than the five-year anniversary date, if any of the changes specified below occur [as specified in 40 CFR 68.190(b)].
 

bulletWithin 6 months of a change that alters the Program Level that applies to any covered process; bulletWithin 6 months of a change that requires a revised off-site consequence analysis; bulletWithin 6 months of a change that requires a revised PHA or hazard review; bulletThe date on which a new regulated substance is first present in an already covered process above a threshold quantity; bulletThe date on which a regulated substance is first present above a threshold quantity in a new process; and bulletThree years after the date when a substance is first regulated by EPA.

Re-submissions re-set the five-year anniversary date by which you must next update your RMP. To re-submit, you must update all nine sections of your RMP. For an electronic RMP, revise the original RMP as needed and submit the updated RMP as a re-submission on diskette. Chapter 7 of RMP*Submit 2004 User’s Manual (PDF) (97 pp, 274K, About PDF) provides detailed information on how to generate the re-submission on diskette.

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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.

To correct your RMP and submit the correction on diskette, you can use the RMP*Submit software. Chapter 6 of the RMP*Submit 2004 User’s Manual (6 pp, 53K, About PDF) provides detailed information on how to generate the correction on diskette.

Facilities who have complete RMPs in the system can make some limited administrative corrections using EPA’s new RMP*WebRC. For further information on RMP*WebRC, contact the Reporting Center (301-429-5018).

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De-Registering a Facility

Changes may occur at your facility that make it no longer subject to the RMP regulations at 40 CFR 68 (e.g. you replace the regulated substances in your process with unregulated substances.) In that event, you should submit a letter to the RMP Reporting Center within six months and include the effective date of the de-registration (the date on which you facility was no longer covered by the RMP regulation). The letter should be signed by the owner or operator and include your RMP ID number (the 12-digit ID number assigned by EPA).

RMP*Submit 2004 will generate the letter for you by running the de-register function (from the Main Menu).

If your facility de-registers and later becomes subject to the RMP regulation again, you will need to submit a new RMP. Submit the new RMP as a re-submission (see Re-submitting Your RMP above) using your previous EPA Facility ID #.

De-registered facilities will be noted as such in RMP*Info. De-registered RMPs will remain in RMP*Info for 15 years.

Remember to include the 12-digit EPA Facility Identification number (usually beginning with 1000) that was assigned to your facility. The EPA Facility ID was given to you in the notification letter you received from the RMP Reporting Center regarding the submission status of your RMP.

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Withdrawing an RMP for Flammable Fuels

Who can withdraw?
If you submitted an RMP reporting only flammable substances that are used as fuel or that are held for sale as a fuel at a retail facility (defined below), you may remove the RMP from the database because you never were subject to the RMP rule.

What if I submitted an RMP that includes other RMP-listed substances in addition to a flammable substance used as fuel or that are held for sale as a fuel at a retail facility?
If your RMP includes such fuels and also other RMP-listed chemicals, you can submit a new RMP with the fuels deleted (See “Resubmitting your RMP” and “Corrections” on this webpage). Or you can simply leave the RMP including the fuels in the database voluntarily.

Why are flammable substances used as a fuel or held for sale as a fuel at a retail facility excluded from RMP reporting?
When originally issued in 1996, the Chemical Accident Prevention rule required facilities having more than a threshold amount of certain flammable substances to submit an RMP by June 21,1999. However, shortly before that date, the rule was stayed with respect to flammable substances used as fuel or held for sale as a fuel at a retail facility, so that facilities with such fuels were not required to include them in their initial RMPs. In August of 1999, Congress enacted the Chemical Safety Information, Site Security and Fuels Regulatory Relief Act to permanently remove from the rule flammable substances used as a fuel or held for sale as a fuel at a retail facility (defined in the Act as a “stationary source at which more than one-half of the income is obtained from direct sales to end users or at which more than one-half of the fuel sold, by volume, is sold through a cylinder exchange program”). In March 2000, EPA amended the Chemical Accident Prevention Regulations (40 CFR 68) to exclude flammable fuels that are used as fuel or that are held for sale as a fuel at a retail facility.

Why should I withdraw or revise my RMP?
A number of RMPs reporting such fuels remain in EPA’s RMP database. They have come to EPA’s attention because the Agency’s database identifies RMPs that have not been updated by their five-year anniversary, which occurred for many facilities in mid-2004. The facilities that submitted RMPs reporting exempt flammable fuels still have the options of withdrawing or revising their RMPs.

What does “withdrawal” mean?
“Withdrawal” of such an RMP means that the RMP will be completely removed from the database, since its submission was never required. By contrast, “de-registration” of an RMP, described above on this website, occurs when changes at a facility which has been subject to the rule make the facility no longer subject to the RMP requirements. RMPs of de-registered facilities remain in the database as non-current RMPs for fifteen years.

How do I withdraw my RMP?
The owner or operator of a facility who has an RMP reporting only exempt flammable fuels (i.e., flammable substances used as fuel or held for sale as a fuel at a retail facility) can write to us at:

RMP Reporting Center
P.O. Box 1515
Lanham-Seabrook, MD 20703-1515

The owner or operator can write a letter or use a form in Wordperfect (1 pg, 7K) or PDF (1 pg, 7K, About PDF). In the letter, the owner or operator should provide us his or her EPA facility ID number, the facility name and address as listed in the RMP, and a signed statement that the chemical listed in the RMP is not subject to the RMP rule per the exclusion described above, and that the facility wishes to withdraw its RMP, or the owner or operator can use a form in Wordperfect (1 pg, 7K) or PDF (1 pg, 8K, About PDF).

 

This page was updated on 23-Mar-2017

 

 

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Contact information:
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Table of Contents for Environmental Health & Safety Online for EHS Professionals http://www.ehso.com/contents.php
Environmental and safety services for business - training, consulting, assessments, ISO14000, report and permit preparations and expert testimony. http://www.ehso.com/EHSservices/enviserv.htm
EHSO is looking for environmental and safety service providers, such as trainers, consultants, CIH's, etc., anywhere in the United States to provide their services to our site visitors.  Write us for more information. Email: or click on feedback

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Copyright 2013 Benivia, LLC (dba EHSO) All rights reserved.

 

Contact information:
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Table of Contents for Environmental Health & Safety Online for EHS Professionals http://www.ehso.com/contents.php
Environmental and safety services for business - training, consulting, assessments, ISO14000, report and permit preparations and expert testimony. http://www.ehso.com/EHSservices/enviserv.htm
EHSO is looking for environmental and safety service providers, such as trainers, consultants, CIH's, etc., anywhere in the United States to provide their services to our site visitors.  Write us for more information. Email: or click on feedback

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Copyright 2013 Benivia, LLC (dba EHSO) All rights reserved.

 

Contact information:
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Table of Contents for Environmental Health & Safety Online for EHS Professionals http://www.ehso.com/contents.php
Environmental and safety services for business - training, consulting, assessments, ISO14000, report and permit preparations and expert testimony. http://www.ehso.com/EHSservices/enviserv.htm
EHSO is looking for environmental and safety service providers, such as trainers, consultants, CIH's, etc., anywhere in the United States to provide their services to our site visitors.  Write us for more information. Email: or click on feedback

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Contact information:
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Environmental and safety services for business - training, consulting, assessments, ISO14000, report and permit preparations and expert testimony. http://www.ehso.com/EHSservices/enviserv.htm
EHSO is looking for environmental and safety service providers, such as trainers, consultants, CIH's, etc., anywhere in the United States to provide their services to our site visitors.  Write us for more information. Email: or click on feedback

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Table of Contents for Environmental Health & Safety Online for EHS Professionals http://www.ehso.com/contents.php
Environmental and safety services for business - training, consulting, assessments, ISO14000, report and permit preparations and expert testimony. http://www.ehso.com/EHSservices/enviserv.htm
EHSO is looking for environmental and safety service providers, such as trainers, consultants, CIH's, etc., anywhere in the United States to provide their services to our site visitors.  Write us for more information. Email: or click on feedback

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