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  • Hot Work Definition and Requirements

    Facilities subject to the Program 3 Prevention Program requirements in 40 CFR Part 68 must include in their Risk Management Plan the date of the most recent review or revision of hot work permit procedures in Section 7.13. What is considered hot work and what are the requirements related to…

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  • Do I have to conduct incident investigations of releases resulting from theft?

    The incident investigation provisions of 40 CFR Part 68 (§§68.60 and 68.81) require facilities to investigate incidents that resulted in or could reasonably have resulted in a catastrophic release. Are covered facilities required to perform incident investigations of releases resulting from theft of covered substances, such as anhydrous ammonia? If…

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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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  • 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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  • 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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  • 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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  • Change of Ownership

    If a facility that is subject to the risk management program regulations in 40 CFR Part 68 is sold to another owner, is the facility required to make a correction or a full update of its risk management plan (RMP)? If there are no changes in the covered operations at…

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  • RMP*eSubmit preparer access

    How does a new Preparer get access to a Risk Management Plan (RMP) via RMP*eSubmit? First, the person must register with CDX. To register with CDX, go to https://cdx.epa.gov/ and complete the registration process for a Risk Management Plan “Preparer”. Once set up as a “Preparer”, the Certifying Official needs…

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  • Is there one document available that includes the latest version of the Renovation, Repair, and Painting (RRP) Rule, with all amendments added to their associated locations, in complete form, and not including the preamble?

    Answer: Yes. Visit the RRP Web site at https://www.epa.gov/lead/answers-frequent-questions-about-epas-lead-renovation-repair-and-painting-rrp-rule Question Number: 23002-19407 Find a printable PDF copy of all frequent questions pertaining to lead .

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  • Will insurance premiums go up for contractors covered by the Renovation, Repair, and Painting (RRP) Rule that work in homes and child-occupied facilities with lead-based paint?

    The practice of carrying insurance to cover work in older homes from potential lead poisoning damages is not new. The RRP Rule, because it sets a clear standard of care and allows contractors to demonstrate that they meet that standard by taking appropriate training and using proper work practices, could…

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  • I am planning to renovate my home. How can I find a lead-safe certified firm?

    EPA has a searchable database to help you locate lead-safe certified firms near you at: https://cdxapps.epa.gov/ocspp-oppt-lead/firm-location-search . In addition, you can call EPA's lead hotline at 1-800-424-LEAD (5323) if you have questions. Question Number: 23002-18044 Find a printable PDF copy of all frequent questions pertaining to lead .

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  • How much will it cost contractors to comply with the RRP Rule?

    Answer: In order to comply with the RRP rule, renovators will incur costs for EPA certification and costs to take a training course from an EPA-accredited training provider, as well as for supplies needed in order to carry out the required lead-safe work practices designed to reduce exposure to lead…

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