Risk Management Program – Release of RMP*eSubmit and Other Guidance

For many facilities subject to the Risk Management Program provisions of 40 CFR Part 68 that were required to submit a Risk Management Plan (RMP) by the initial 1999 compliance date, a 5-year update is due this year.  On March 13, 2009, U.S. EPA released the newest software for submitting a new or updated RMP: RMP*eSubmit.  The new RMP*eSubmit software and additional guidance information is available at the following U.S. EPA website:

http://www.epa.gov/oem/content/rmp/rmp_esubmit.htm#more.

RMP*eSubmit will replace RMP*Submit 2004, which will be phased out in 2009.  U.S. EPA encourages facilities to use RMP*eSubmit.  However, U.S. EPA will accept an updated RMP using RMP*Submit 2004 from facilities that have already begun preparing their RMP submittals.  Those facilities that were required to complete the Chemical Facility Anti-terrorism Standards (CFATS) Chemical Security Assessment Tool (CSAT) in 2008 (as described in ALL4’s August 2008 4 The Record article “Chemical Facility Anti-terrorism Standards (CFATS) Deadline Approaching“), may recognize some of the same registration features in RMP*eSubmit that accompanied the CSAT Top-Screen submittal.

Even if your facility’s RMP is not due until June 2009, there are several tasks that should be completed now:

1. Register the Certifying Official in the Central Data Exchange (CDX) (http://cdx.epa.gov).
2. Complete the Electronic Signature Agreement (ESA) and mail it back to U.S. EPA.  The ESA is used to verify that the Certifying Official reviewed and submitted the EMP in the RMP*eSubmit system.
3. Register the “Preparer” and activate RMP*eSubmit access in CDX.  The Certifying Official may designate another person as the Preparer.  In this case, the Certifying Official may provide the Preparer with the Authorization Code for the facility.  Preparers are then required to provide the Authorization Code when registering and activating their RMP*eSubmit access in CDX.