Your Checklist for Updating Your Facility’s Risk Management Program

Facilities, including food and beverage manufacturers, that use certain flammable and toxic substances in amounts that exceed threshold quantities must have a documented Risk Management Plan (RMP) per Environmental Protection Agency (EPA) requirements. Companies must update and resubmit their RMP at least every five years.

The EPA requires each facility to review all sections of their RMP, update where appropriate, and certify that the entire RMP is accurate and complete.

According to the EPA’s checklist, here are the key elements that should be reviewed for resubmission:

Section 1: Registration Information

• Review registration information and make necessary corrections.
• Verify the facility’s latitude and longitude coordinates.
• Check your North American Industry Classification Systems (NAICS) code to make sure your processes are coded correctly. The most recent codes can be found on the Census Bureau’s website.

Sections 2 – 5: Worst Case and Alternate Release Scenarios

• Review and update your Offsite Consequence Analysis (OCA) to determine whether the parameters and assumptions used in the analysis are still valid. Any changes should be noted in your resubmission.

Section 6: Accident History

• Update your five-year accident history to include any reportable releases that have occurred over the past five years from a covered process that could result in death, injury, or significant property damage. You must also include known any deaths, injuries, evacuations, sheltering in place, property damage or environmental damage.
• Accidents that occurred more than five years ago may be removed from your history.

Section 7 and 8: Prevention Program

• Report the most recent dates of your prevention program activities for those facilities with RMP.

Section 9: Emergency Response

• Document your most recent training and review of your emergency response program in your resubmission. 
• Ensure the action plan matches an appropriate ammonia response, including if the location is a responding location in the event of an emergency. 
• Make sure all contact information for local emergency responders is up to date.

Circumstances under which you need to resubmit early

The five-year timeline to resubmit is based on your most recent, full RMP submission. 

However, it may be necessary to periodically update your RMP information before the anniversary date. An update may be necessary under the following circumstances:

• If any change alters the Program Level that applies to any existing covered process, the RMP must be resubmitted within six months of that change.
• If a change requires a revised OCA, the RMP must be resubmitted within six months of that change.
• If a change requires a revised Process Hazard Analysis (PHA) or project hazard review, the RMP must be resubmitted within six months of that change, including any project PHA’s when needed.
• If a new regulated substance is present above the threshold quantity in an existing covered process, the RMP must be resubmitted on the date which the new substance is present. Regulated substances can be found on the EPA website along with their threshold quantities.
• If a regulated substance is present above the threshold quantity in a new process, the RMP must be resubmitted immediately on the date which the substance is present above the threshold quantity.
• If the EPA begins regulating a new substance, the RMP must be resubmitted within three years of the date the substance is first regulated.
• If a change occurs that makes the facility no longer subject to RMP.
• If a new public receptor is constructed near your facility.  According to 40 CFR §68.3, a public receptor is defined as including “offsite residences, institutions (e.g., schools, hospitals), industrial, commercial, and office buildings, parks, or recreational areas inhabited or occupied by the public at any time without restriction by the stationary source where members of the public could be exposed to toxic concentrations, radiant heat, or overpressure, as a result of an accidental release.”
• If a release meets the reporting criteria of 40 CFR §68.42. These criteria include deaths, injuries, or significant property damage on site, or known offsite deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage.
• If the facility’s contact information changes.

Your facility’s updated RMP can be submitted online using the EPA’s RMP*eSubmit software.

To learn more about how to ensure your facility’s RMP is up to date, call us at 800.488.2900 or reach out to foodforthought@stellar.net.