Food processing facilities that use certain flammable and toxic substances in amounts that exceed threshold quantity must have a documented Risk Management Program (RMP) per Environmental Protection Agency (EPA) requirements. Companies must also update and resubmit their RMP every five years and 2014 marks one of those five year cycles.
The EPA recommends that facilities review all nine sections of their RMP, update where appropriate, and certify that the entire RMP is true, accurate, and complete.
According to the EPA’s checklist, here are some key elements that should be reviewed for resubmission:
Section 1: Registration Information
- Review registration information and make any necessary corrections to ensure that it is up-to-date.
- Verify the facility’s latitude and longitude coordinates. Latitude and longitude coordinates were reported incorrectly previously on many RMPs.
- Check your North American Industry Classification System (NAICS) code to make sure your covered processes are coded correctly. The Census Bureau maintains a website with the 2014 NAICS Codes (https://www.census.gov/eos/www/naics/).
Sections 2 – 5: Worst Case and Alternate Release Scenarios
- Review and update your offsite consequence analysis (OCA) at least once every five years. You should review your documentation to determine whether the parameters and assumptions used in the analysis are still valid and make changes, as appropriate.
Section 6: Accident History
- Update your five-year accident history. Include any accidental releases that occurred over the past five years from a covered process and resulted in deaths, injuries, or significant property damage on site, or known off-site deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage. You may remove from your accident history any accident that occurred more than five years ago.
Sections 7 and 8: Prevention Program
- Report the most recent dates of your prevention program activities for those facilities that have been designated as Program 2 and Program 3 processes.
Section 9: Emergency Response
- Document your most recent review of your emergency response program and most recent training in your resubmission.
It may be necessary to periodically update your RMP information before the five year anniversary resubmission requirement. An update may be necessary under the following circumstances when:
- Changes at the facility require a revised PHA
- A new public receptor is constructed near your facility
- An accidental release meets the reporting criteria of 68.42
- Facility emergency contact information changes
- A new regulated substance is first listed with the EPA
- A regulated substance first becomes present above threshold quantities at your facility
- A change occurs that makes the facility no longer subject to RMP
- Minor administrative changes are necessary.
Your facility’s updated RMP can be submitted online using the EPA’s RMP*eSubmit software.
To learn more about how to ensure that your RMP is up to date and is resubmitted appropriately, call us at 800-488-2900.