Will an Integrated Contingency Plan satisfy RMP requirements?
The National Response Team's Integrated Contingency Plan guidance, or "One Plan," provides a format for consolidating multiple emergency response plans required under RCRA, OPA, SPCC, DOT, OSHA, and CAA §112(r). Will an Integrated Contingency Plan satisfy all of the risk management program requirements under 40 CFR Part 68?
No. An Integrated Contingency Plan (ICP) does not include all of the 40 CFR Part 68 risk management program requirements. An ICP can, however, be used to satisfy the emergency response plan requirements of 40 CFR Section 68.95(a)(1) for Program 2 and Program 3 processes (61 FR 31673; June 20, 1996).