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RMPs must be updated at least once every five years. Owners and operators responsible for RMP implementation should review the factsheet "A Checklist for Resubmitting your Risk Management Plan (RMP) for Chemical Accident Prevention" (6 pp, 174K, About PDF). This factsheet provides a checklist to consider in updating and resubmitting RMPs.
You must fully update your RMP for re-submission
sooner than the five-year anniversary date, if any of
the changes specified below occur [as specified in
40 CFR 68.190(b)].
Re-submissions re-set the five-year anniversary date by which you must next update your RMP. To re-submit, you must update all nine sections of your RMP. For an electronic RMP, revise the original RMP as needed and submit the updated RMP as a re-submission on diskette. Chapter 7 of RMP*Submit 2004 User's Manual (PDF) (97 pp, 274K, About PDF) provides detailed information on how to generate the re-submission on diskette.
"Correcting" an RMP refers to changing only a part of an existing RMP, such as changing a contact name or revising only a certain section. Corrections do not generate a new anniversary date.
To correct your RMP and submit the correction on diskette, you can use the RMP*Submit software. Chapter 6 of the RMP*Submit 2004 User's Manual (6 pp, 53K, About PDF) provides detailed information on how to generate the correction on diskette.
Facilities who have complete RMPs in the system can make some limited administrative corrections using EPA's new RMP*WebRC. For further information on RMP*WebRC, contact the Reporting Center (301-429-5018).
Changes may occur at your facility that make it no
longer subject to the RMP regulations at
40 CFR 68 (e.g. you replace the regulated substances
in your process with unregulated substances.) In that
event, you should submit a letter to the RMP Reporting
Center within six months and include the effective date
of the de-registration (the date on which you facility
was no longer covered by the RMP regulation). The letter
should be signed by the owner or operator and include
your RMP ID number (the 12-digit ID number assigned by
RMP*Submit 2004 will generate the letter for you by running the de-register function (from the Main Menu).
If your facility de-registers and later becomes subject to the RMP regulation again, you will need to submit a new RMP. Submit the new RMP as a re-submission (see Re-submitting Your RMP above) using your previous EPA Facility ID #.
De-registered facilities will be noted as such in RMP*Info. De-registered RMPs will remain in RMP*Info for 15 years.
Remember to include the 12-digit EPA Facility Identification number (usually beginning with 1000) that was assigned to your facility. The EPA Facility ID was given to you in the notification letter you received from the RMP Reporting Center regarding the submission status of your RMP.
Who can withdraw?
If you submitted an RMP reporting only flammable substances that are used as fuel or that are held for sale as a fuel at a retail facility (defined below), you may remove the RMP from the database because you never were subject to the RMP rule.
What if I submitted an RMP that includes
other RMP-listed substances in addition to a flammable
substance used as fuel or that are held for sale as a
fuel at a retail facility?
If your RMP includes such fuels and also other RMP-listed chemicals, you can submit a new RMP with the fuels deleted (See "Resubmitting your RMP" and "Corrections" on this webpage). Or you can simply leave the RMP including the fuels in the database voluntarily.
Why are flammable substances used as a fuel
or held for sale as a fuel at a retail facility excluded
from RMP reporting?
When originally issued in 1996, the Chemical Accident Prevention rule required facilities having more than a threshold amount of certain flammable substances to submit an RMP by June 21,1999. However, shortly before that date, the rule was stayed with respect to flammable substances used as fuel or held for sale as a fuel at a retail facility, so that facilities with such fuels were not required to include them in their initial RMPs. In August of 1999, Congress enacted the Chemical Safety Information, Site Security and Fuels Regulatory Relief Act to permanently remove from the rule flammable substances used as a fuel or held for sale as a fuel at a retail facility (defined in the Act as a "stationary source at which more than one-half of the income is obtained from direct sales to end users or at which more than one-half of the fuel sold, by volume, is sold through a cylinder exchange program"). In March 2000, EPA amended the Chemical Accident Prevention Regulations (40 CFR 68) to exclude flammable fuels that are used as fuel or that are held for sale as a fuel at a retail facility.
Why should I withdraw or revise my RMP?
A number of RMPs reporting such fuels remain in EPA's RMP database. They have come to EPA's attention because the Agency's database identifies RMPs that have not been updated by their five-year anniversary, which occurred for many facilities in mid-2004. The facilities that submitted RMPs reporting exempt flammable fuels still have the options of withdrawing or revising their RMPs.
What does "withdrawal" mean?
"Withdrawal" of such an RMP means that the RMP will be completely removed from the database, since its submission was never required. By contrast, "de-registration" of an RMP, described above on this website, occurs when changes at a facility which has been subject to the rule make the facility no longer subject to the RMP requirements. RMPs of de-registered facilities remain in the database as non-current RMPs for fifteen years.
How do I withdraw my RMP?
The owner or operator of a facility who has an RMP reporting only exempt flammable fuels (i.e., flammable substances used as fuel or held for sale as a fuel at a retail facility) can write to us at:
The owner or operator can write a letter or use a form in Wordperfect (1 pg, 7K) or PDF (1 pg, 7K, About PDF). In the letter, the owner or operator should provide us his or her EPA facility ID number, the facility name and address as listed in the RMP, and a signed statement that the chemical listed in the RMP is not subject to the RMP rule per the exclusion described above, and that the facility wishes to withdraw its RMP, or the owner or operator can use a form in Wordperfect (1 pg, 7K) or PDF (1 pg, 8K, About PDF).