Every five years, facilities such as water and wastewater treatment plants, propane storage facilities, chemical distributors, and others are required to maintain and follow a Risk Management Program documented in a Risk Management Plan (RMP). The rule applies to facilities that store specific amounts of the chemicals listed in Title 40 of the Code of Federal Regulations §68.190.
The original deadline for RMP implementation was July 21, 1999. Since that time, facilities have completed the required five-year updates at least twice. Depending upon the last submittal date, many of the region’s water and wastewater facilities were due to update their RMPs last year, or will be required to do so in 2015. It is important to revisit your facility’s last submittal date, review the components of the RMP, and complete a compliance audit in a timely fashion to meet the requirements mandated by the U.S. Environmental Protection Agency (USEPA). It should be noted that while the timeline for many of the requirements follows a five-year schedule, a Compliance Audit of your RMP must be completed every three years.
One exception to the RMP submittal timeline is if a process change occurs that affects the quantity of specific chemicals located at a facility. A change would trigger an update sooner than the five-year timeline. The five-year anniversary date is calculated as five years from the postmarked date of the facility’s most recent submission. The USEPA includes the date in its letters that acknowledge receipt of RMPs.
In addition to updating the RMP every five years, facilities are required to keep operating procedures and safety information current; provide and record employee refresher training; and review/update the hazard analysis. Facilities are also required to complete a compliance audit of the RMP at least once every three years. Completion of these steps should also be documented in the updated RMP submittal.
If you need help determining your five-year anniversary date, you can call the USEPA’s RMP Reporting Center for assistance at 703-227-7650. The USEPA’s instructions for submitting an RMP online can be accessed by clicking here. The staff of AE2S is also available to support development, updating, and compliance related to RMP requirements. For help, contact Miranda Kleven, PE or Jarda Solc, PE at 701-746-8087; or Aaron Vollmer, PE, at 763-463-5036.