EPA requires you to update your RMP at least every five years. It doesn’t take long to do at all if you haven’t changed much in the last five years. You’ll almost always find a little thing to change, even if it’s just a better contact phone number.
Honestly, it takes less than an hour if nothing much has changed – it’s all done online and is fairly hassle-free. Don’t skip this easy step and end up like these fertilizer distributors did:
Two ammonia fertilizer distributors have agreed to pay over $33,000 for failing to update their plans for preventing chemical releases at eight facilities throughout Washington. One distributor will pay $13,521 and the other will pay $19,986 to settle alleged violations of the Risk Management provisions of section 112(r) of the federal Clean Air Act
Go to the EPA Website for more RMP information.
Update: Please see the comments for an excellent reminder by Peter Thomas.
Thanks for sharing Brian and putting together this blog. Its also important to note that there are other things that can trigger the need to submit a corrected/revised RMP to the USEPA. A revised RMP must be submitted within the following time period for the following reasons
1. Within 6 months of a change that alters the Program level of a process
2. Within 6 months of a change that requires a revised offsite consequence analysis
3. Within 6 months of a change that requires a revised PHA
4. No later than the date on which a regulated substance is first present above a threshold quantity in a new process
5. No later than the date on which a new regulated substance is first present in an already covered process above a threshold quantity
6. No later than 3 years after a newly regulated substance is first listed by the USEPA
7. Within 6 months of new accident history data becoming available
8. Within 1 month of a change in emergency contact information
I’ve found that #8 is especially important to keep in mind because people change jobs often and it is not always the first thing on the mind of the new emergency contact to update the RMP.
You’re exactly right Peter. #8 is also the one I find most often – in fact I have actually had the EPA try to reach an emergency contact and get a disconnected number. They then tried the secondary contact that was the Security Company at the facility. The security company refused to give the EPA inspector a contact at the company. Needless to say he wasn’t very pleased by the time I talked to him!