Risk Management Program Reminder

Since 1999, facilities such as water and wastewater treatment plants, propane storage facilities, chemical distributors, and others that store specific amounts of the chemicals listed in Title 40 of the Code of Federal Regulations §68.190 have been required to maintain and follow a Risk Management Program documented in a Risk Management Plan (RMP). The original deadline for RMP implementation, which included electronic submittal of plan components to the United States Environmental Protection Agency (USEPA), was July 21, 1999. Facilities subject to the RMP requirement must fully update and resubmit the RMP at least once every five years. For many of the region’s water and wastewater facilities, the upcoming calendar year (2014) will mark five years since the last RMP update was submitted. Now is the time to revisit your last submittal date, review the components of your plan, and complete a compliance audit in a timely fashion to meet the mandated requirements.

One exception to the RMP submittal timeline is if a process change that affects the quantity of a covered chemical occurs. 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. AE2S Nexus staff are also available to support development, updating, and compliance related to RMP requirements. Miranda Kleven, PE, and Jarda Solc, PE, are particularly familiar with the process. They can be contacted at 701-746-8087.