The Clean Air Act Section 112(r) Risk Management Program rule regulates the storage, handling and/or processing of specified toxic and flammable substances. Affected facilities must develop and register a Risk Management Plan (RMP) that includes a hazard assessment, prevention program, and emergency response program. Regulated facilities must update and resubmit the RMP every five years. This 5-year update requires review and revision of all RMP sections, as needed, to bring the RMP up to date. The 5-year anniversary date is reset whenever a facility fully updates and resubmits the RMP. For facilities following the schedule of the rule, June 21, 2009 may be the date for the required 5-year renewal. (To find your anniversary date, go to http://data.rtknet.org/rmp/ and search for your facility, or contact EPA's RMP Reporting Center at (301) 429-5018.) In 2009, EPA requires online RMP reporting using new software RMP*eSubmit.
EPA estimates approximately 8,000 facilities will be updating their RMPs in June 2009. If your facilities requires an RMP update, Trinity Consultants can help you:
- Determine any updates of regulatory applicability to processes
- Renew/update release scenarios and perform hazard assessment
- Review/update the prevention program
- Review/update the emergency response program
- Prepare the RMP renewal submission