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  • Change of owner and RMP facility ID number

    If a facility is sold to a new owner, does it keep its' original RMP Facility ID number? Yes. The facility will keep the ID number assigned by EPA.

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  • Facility ID number and re-registering a facility

    If a facility deregisters, then reregisters, should the facility use the original RMP Facility ID or will it be assigned a new ID? The facility should use the original ID assigned by EPA.

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  • Resubmission of RMP for a facility that previously deregistered

    A covered facility deregisters its RMP because it no longer has more than a threshold quantity of a regulated substance in a covered process. If the facility becomes subject to the CAA §112(r) risk management program regulations at a later date and submits a new RMP, should the facility submit…

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  • If a covered process has an accident, when does it lose eligibility for Program 1 status?

    A process covered under 40 CFR Part 68 is eligible for Program 1 requirements if it meets all of the criteria listed at 40 CFR §68.10(b). Those criteria include a requirement that the process cannot have had an accidental release of a regulated substance that led to offsite death, injury…

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  • Do Program 1 processes have to complete a process hazard analysis?

    Do owners or operators of Program 1 processes have to complete a process hazard analysis? No. The Program 1 requirements do not include a process hazard analysis (40 CFR §68.12(b)). Program 3 processes require completion of a process hazard analysis (40 CFR §68.12(d)(3)) while Program 2 processes must complete a…

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  • Is a hazard review synonymous with a process hazard analysis (PHA)?

    The prevention program requirements under 40 CFR Part 68, Subparts C and D, include hazard reviews and process hazard analyses. Is a hazard review synonymous with a process hazard analysis (PHA)? No. A hazard review is different from a PHA. A hazard review is part of the Program 2 prevention…

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  • Applicability of program levels and prevention program requirements for co-located vessels

    I have a tank with 1,000,000 pounds of toluene diisocyanate (TDI), which is covered under the RMP rule, but not under OSHA PSM. Considered by itself, the TDI would be Program 2 for EPA. The tank, however, is close to equipment that has chlorine above the applicable threshold and is…

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  • Changing from a Program 2 or 3 process to a Program 1 process

    If five years have passed since the last accident involving a covered process, and that process meets the other two requirements identified under 40 CFR §68.10(b) for Program 1 eligibility, could that process become a Program 1 process even if it had previously been identified as a Program 2 or…

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  • RMP Records Maintained Onsite

    Pursuant to 40 CFR Part 68, Subpart G, the owner or operator of a stationary source subject to the risk management program regulations in Part 68 must develop and submit a risk management plan (RMP). Does the owner or operator have to maintain a written copy of the RMP on…

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  • Process identification and distance between vessels

    How far apart do separate vessels have to be to be considered different processes? There is no hard and fast rule for how great this distance should be before you do not need to consider the vessels as part of one process. Two vessels at opposite ends of a large…

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  • What does "same industrial group" mean?

    Operations at a site that belong to the same three-digit North American Industry Classification System (NAICS) code prefix (which has replaced the old SIC codes) belong to the “same industrial group. In addition, where one or more operations at the site serve primarily as support facilities for the main operation…

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  • Updating RMP if EPA lists a new substance

    What if EPA lists a new substance? You will have three years from the date on which the new listing is effective to come into compliance for any process that is covered because EPA has listed a new substance.

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  • How often must compliance audits be performed?

    How often must owners or operators of stationary sources subject to the risk management program regulations perform compliance audits? The regulations at 40 CFR §§68.58(a) and 68.79(a) state that owners or operators must certify that they have evaluated compliance with the applicable prevention program provisions at least once every three…

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  • How may state and local rules be more stringent?

    In what ways may state and local rules be more stringent? Does this document ( General Risk Management Program Guidance ) provide guidance on state and local differences? States and localities may impose more detailed requirements, such as requiring more documentation or more frequent reporting, specifying hours of training or…

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  • Should tank capacity be considered when determining thresholds?

    When determining whether a threshold amount of a regulated substance is present in a process (e.g., a tank), must the owner or operator of a stationary source consider the total capacity of the process, or the actual amount of regulated substance contained in the process? The threshold determination is based…

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