Office of Solid Waste

an Emergency Response

(5104)

EPA 550-B-04-002

March 2004

www.epa.gov/emergencies

RMP*Submit 2004TM

User’s Manual
What’s New for 2004

RMPs must be fully updated and re-submitted at least once every five years. Most RMPs were

submitted by the initial deadline of June 21, 1999, so they must be updated and re-submitted by

June 21, 2004, unless they were updated and re-submitted previously. EPA is releasing

RMP*Submit 2004 to facilitate RMP re-submissions in calendar year 2004. 

Importing your old data: RMP*Submit 2004 can import your older versions of RMPs. 

When RMP*Submit imports these older versions, it will check the

NAICS code, the county name, the DUNS number, and the lat/long

and display any errors found.

Improved features: CNew NAICS selector to help you select your NAICS code;

CEnhanced user interface, including larger screen size and larger

fonts;

CIndicators for critical and mandatory fields; 

CImproved data validation;

CUpdated county name listing; and

CImproved accessibility features and support for Windows High

Contrast modes.

Changes to RMP*Submit

In 2004, EPA revised the Agency's Chemical Accident Prevention Rule (Risk Management

Program) to include several new data elements in Risk Management Plans (RMPs) and to change

several requirements regarding the filing of RMPs.

RMP*Submit 2004 incorporates the new data elements:

a.An e-mail address for the emergency contact person (if an email address exists).

b.Name, address, and telephone number of the consultant/contractor who prepared RMP,

if any.

c.The purpose and type of any submission that revises or otherwise affects previously

filed RMPs.

RMP*Submit 2004 also reflects the fact that the revised rule eliminates the requirement to

include a brief description of your facility’s off-site consequence analysis in the RMP Executive

Summary. 

Other rule changes do not affect RMP*Submit 2004, but you should be aware that the revised

rule requires the five-year accident history portion of RMPs (section 6) to be revised within six

months of any accident that meets the accident history reporting requirements. Emergency

contact information also must be corrected within one month of a change.
WHERE TO GO FOR HELP

RMP Reporting Materials:

Visit our website for updates and information about RMP*Submit, for guidance documents,

industry-specific model plans, Off-Site Consequence Analysis specific guidance and calculator,

Frequently Asked Questions, Fact Sheets and other information:

http://yosemite.epa.gov/oswer/ceppoweb.nsf/content/RMPS.htm

RMP Contacts:

Under the Clean Air Act section 112, States can choose to take delegation of the RMP Program.

If they do, they become the Implementing Agency for that State. In delegated States, you may

contact your State Implementing Agency for assistance. In all other States, your EPA regional

office is the implementing agency and you may contact them for assistance. We maintain

current phone numbers for State and regional contacts on our website:

http://yosemite.epa.gov/oswer/ceppoweb.nsf/content/112r-sts.htm

RMP Regulatory Questions:

If you have a question about an RMP reporting requirement, you can also call the toll free

RCRA, Superfund & EPCRA Call Center at:

Phone: (800) 424-9346 or (703) 412-9810 [Washington, DC area callers please use this

number]

TTY: (800) 553-7672 or (703) 412-3323 [Washington, DC area callers please use this

number]

When: Monday - Friday, 9:00 am - 5:00 pm Eastern Time

Closed Federal Holidays

Internet: www.epa.gov/epaoswer/hotline

Email: epacallcenter@bah.com

RMP*Submit Software Support:

For software questions or installation problems, contact the RMP Reporting Center at:

Phone: (301) 429-5018

When: Monday - Friday, 8:00 am - 4:30pm Eastern Time

Closed Federal Holidays

Email: userrmp.usersupport@epcra.org
Table of Contents

Chapter 1 Getting Started . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Ch. 1 Pg. 1

A. Introduction .................................................. Ch. 1 Pg. 1

B. Before You Start . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Ch. 1 Pg. 1

C. Hardware and Software Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Ch. 1 Pg. 3

D. Installation Instructions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Ch. 1 Pg. 3

E. Importing Data . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Ch. 1 Pg. 3

F. Using RMP*Submit . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Ch. 1 Pg. 4

G. Welcome and Main Menu Screens . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Ch. 1 Pg. 8

Chapter 2 Entering Data . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Ch. 2 Pg. 1

Section 1: Registration . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Ch. 2 Pg. 1

Section 2: Toxics: Worst-Case . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Ch. 2 Pg. 17

Section 3: Toxics: Alternative releases . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Ch. 2 Pg. 22

Section 4: Flammables: Worst-Case . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Ch. 2 Pg. 26

Section 5: Flammables: Alternative Releases . . . . . . . . . . . . . . . . . . . . . . . . Ch. 2 Pg. 29

Section 6: Five-year accident history ............................... Ch. 2 Pg. 32

Section 7: Prevention Program for Program 3 Processes . . . . . . . . . . . . . . . . Ch. 2 Pg. 43

Section 8: Prevention Program for Program 2 Processes . . . . . . . . . . . . . . . . Ch. 2 Pg. 54

Section 9: Emergency Response Program ........................... Ch. 2 Pg. 59

Executive Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Ch. 2 Pg. 62

Chapter 3 How to Assemble and Submit Your RMP . . . . . . . . . . . . . . . . . . . . . . . Ch. 3 Pg. 1

Completeness Check . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Ch. 3 Pg. 1

Certification Letter . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Ch. 3 Pg. 3

Where to send completed RMP Reports . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Ch. 3 Pg. 5

Record Keeping . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Ch. 3 Pg. 6

Chapter 4 Submitting CBI and Trade Secrets ............................ Ch. 4 Pg. 1

Chapter 5 What to Expect After You Submit . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Ch. 5 Pg. 1

Chapter 6 Corrections to Your RMP . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Ch. 6 Pg. 1

Chapter 7 Updating and Certifying All 9 Sections of Your RMP: Re-submission

........................................................ Ch. 7 Pg. 1

Chapter 8 Notifying EPA that Your Facility is No Longer Covered by RMP: 

De-registration

..................................................................... Ch. 8 Pg. 1
Ch. 1 Pg. 1

Appendices

A Risk Management Plan Form

B Paper Submission Cover Form

C Sample Certification Letters

D CBI Substantiation Form

E CBI Unsanitized Data Element Form

F How to Report your Facility Latitude and Longitude

G Keyboard Commands for RMP*Submit

List of Exhibits

Exhibit 1. Welcome screen

Exhibit 2. Main Menu screen

Exhibit 3. List of Risk Management Plans screen

Exhibit 4. Latitude and Longitude Values for Specific Cities

Exhibit 5. Example Calculation of Full-Time Equivalent Employees

Exhibit 6. Program Eligibility Criteria

Exhibit 7. Atmospheric Stability Classes

Exhibit 8. RMP*

Submit Keyboard Equivalents
Ch. 1 Pg. 2

CHAPTER 1 GETTING STARTED

A. Introduction

The RMP*Submit User Manual provides assistance in preparing and submitting Risk

Management Plans (RMPs). RMP*Submit software is the free tool EPA developed to facilitate

electronic submission and is designed to significantly reduce errors in submission through

“checks “ for each data element. If you are unable to submit your RMP electronically, submit

your RMP on the Risk Management Plan Form (see Chapter 3). 

The RMP*Submit User Manual includes:

–Technical help on using RMP*Submit;

–Instructions on how to complete each data element;

–Details on how to submit your RMP; and

–What to expect after you submit. 

RMP*Submit has four functions:

C Data Entry - Allows you to add new or edit existing RMPs (first-time submissions,

corrections, and re-submissions); check your RMP for completeness; and create the

submission file.

C Edit Certification Letters - Allows you to edit the template for the certification letter to

accompany your submission (for Program 1, for Program 2 or 3, and for a corrected

RMP).

C Import - Allows you to import RMPs from previous versions of RMP*Submit. Also, if

you used your own software to create your RMP, you can import the data and use

RMP*Submit to verify the "completeness" of your RMP. 

C Edit De-registration Letter- Generates a de-registration letter.

This RMP*Submit Manual provides instructions for entering all sections of the RMP. It also

includes a copy of the RMP paper form (Appendix A) for those who need to submit their RMP on

paper. In addition, Appendices C and D include the necessary forms for claiming Confidential

Business Information (CBI), since these forms may not be submitted electronically.

B. Before You Start

–Are you subject to the RMP reporting requirements? Check the requirements, and for

updates and re-submissions check your 5-year anniversary date if you already have an RMP in the

system.

–What is your EPA Facility ID? If you already have an RMP in the system, you have an EPA

Facility ID. It is essential that we match your new RMP to any earlier versions. Your EPA

Facility ID appears in a letter sent by the EPA Reporting Center after your first-time submission. 

The number has twelve digits. Call the EPA Reporting Center if you need help at (301) 429-5018. 
Ch. 1 Pg. 3

First-time submissions should leave the EPA Facility ID blank.

–What category are your processes in: Program 1, 2 or 3? Each process at your facility

having more than a specified amount (“threshold quantity”) of a covered chemical (“regulated

substance”) will be in one of these categories. The category determines some of your reporting

requirements and governs how you enter the data.

C. Hardware and Software Requirements

RMP is designed to run on Microsoft Windows versions 98, NT 4.0, 2000, ME, and XP. To

install and run RMP*Submit, you will need 165 MB of available hard disk space. You will also

need a minimum of 16 MB RAM for Windows 98 or a minimum of 32 MB RAM for Windows

NT 4.0, 2000, ME, and XP. Listed below are the minimum computer hardware and software

requirements for installing and running RMP*Submit:

Personal Computer: Pentium II or newer

Printer: Standard inkjet or laser printer

Mouse: Standard (note: mouse wheel is not supported)

D. Installation Instructions

RMP*Submit can be installed by downloading the program files from the EPA website:

http://yosemite.epa.gov/oswer/ceppoweb.nsf/content/ap-rmsb.htm

To install RMP*Submit from Internet download:

1. Using a Web browser, navigate to the EPA Web site and locate and click upon the link to

install RMP*Submit (rmpsubmit.exe).

2. When prompted by the Web browser whether to Open or Save the file, select to Open it.

3. Follow the ensuing system prompts. You will be able to save RMP*Submit to a directory

of your choice. The default is: C:\Program Files\RMP Submit V3.

The installation program will inform you if the installation was successful. If you encounter

problems during installation, follow the instructions provided by the installation program. 

Notes for users with dial-up connections

C Downloading RMP*Submit 2004 can take as long as three hours. The progress bar

advances as it downloads each installation section from the Web server. Sections that are

considerably larger than the others may result in the progress bar not moving for an

extended period of time. Please be patient; the progress bar will advance again, once the

downloading is complete. If your connection to the Internet is interrupted, the installation

will resume where it left off after the connection has been reestablished.
Ch. 1 Pg. 4

C Dial-up users may wish to download the application over several sessions. In order to do

this, perform the following steps:

1. Click on the Progress Meter Cancel button during the installation. 

2. You will be asked if you would like to Exit or Resume the application. Select Exit. 

3. If you are prompted to Abort or Retry the installation, select Abort. 

4. Next, you will be asked if you would like to roll back the installation. Select No. 

5. When you are ready to continue the installation, using a Web browser, navigate to the

EPA Web site and locate and click upon the link to install RMP*

Submit (rmpsubmit.exe). 

Downloading will resume where it was last aborted.

E. Importing Data

You may have RMP data from a previous version of RMP*Submit or another source that you

want to import into RMP*Submit 2004. When RMP*Submit 2004 imports older versions, it will

check the NAICS code, the county name, the DUNS number, and the lat/long and display any

errors found. 

L Tip If you plan to import old RMPs, do not erase your copy of the previous version of

RMP*Submit until you have successfully imported the data into RMP*Submit

2004.

To import data from a previous version of RMP*Submit, you will need a copy of your RMP

submission file called “rmp.txt.” You may have copied this file to either a diskette or your hard

drive. 

If you don’t have a copy of the submission file, but do have a copy of a previous version of

RMP*Submit, you can generate the submission file using the previous version. 

To create a copy of your submission file, open the earlier version of RMP*Submit and:

1. Select an RMP from the List of Risk Management Plans Screen and click the Submit

button. 

2. Next, RMP*

Submit prompts you to enter an output drive letter. 

3. Enter the drive where you want to save your RMP. The RMP filename will be rmp.txt.

If you need an electronic copy of your RMP submission file, you may call the RMP Reporting
Ch. 1 Pg. 5

Center at (301 429-5018), or contact your State Implementing Agency. Because of security

concerns pertaining to the off-site consequence analysis portions of RMPs, you will be asked to

provide documentation of your position at the facility before EPA or another agency provides you

with the electronic copy of the facility’s RMP.

If you are importing data from another source (for example, a commercial software package), the

data must be in an ASCII file formatted in accordance with the Risk Management Plan ASCII File

Format. See EPA’s website at: http://yosemite.epa.gov/oswer/ceppoweb.nsf/content/RMPS.htm.

To import data:

1. Click the Import button from the Main Menu screen. The Select Import File Dialog Box

appears.

2. Select the drive, folder, and specific file name of the RMP to import into RMP*

Submit. 

Click in the Open button.

3. If errors are detected in importing your text file, you will receive an error message. 

4. Click OK to display the error message log for your RMP. The RMP Import Error Log

Screen will display. Select File, Print function to view or print the RMP Import Error

Log. 

F. Using RMP*Submit

Some points before you begin entering data:

‘ RMP*Submit automatically saves the information you enter.

‘ RMP*Submit provides “Help.” Use the Help button or, to get context-specific help, place

cursor in field and press <F1>.

‘ Drop down lists are provided to ensure that users select appropriate choices for RMP data

elements where applicable.

‘ Date fields can be entered in several different formats, including:

8/16/03 8/16/2002 August 16, 2003

August-16-2003 aug-16-2003 aug-16-98

Aug 16 03 16 aug 2003 aug-16 (inserts current year)

No matter how you enter the date, it will be displayed as 08/16/2003.

‘ Check boxes are yes/no fields. The default is “no.” A check indicates a response of

“yes.” Clicking inside the boxes or pressing the space bar toggles the check mark (X) on

and off. 
Ch. 1 Pg. 6

‘ Similar to Windows, RMP*Submit has a function to reverse the last change. The

Edit/Undo function will restore one data field. Pressing <Esc> twice will restore an

entire page.

‘ The status bar, located in the lower left-hand corner of the RMP*Submit window, displays

helpful formatting information and brief instructions about selected fields, command

buttons, or menu items.

‘ It is important that you create backup copies of your RMP*Submit data, to avoid having to

re-enter the information after a system malfunction.

‘ To help ensure that your RMP is complete and accurate, RMP*Submit checks many (but

not all) data fields as you enter data. 

Navigating RMP*Submit

Most users will navigate within RMP*

Submit using a mouse. Information about navigating with

the keyboard is found in Appendix K of this manual. You can access functions from the menu

bar or the command buttons on each screen.

Creating Backup Copies of Your Data

It is important that you create backup copies of your RMP*Submit data, to avoid having to

re-enter the information after a system malfunction. There are several circumstances that can

result in the loss of your data:

‘ A hard drive failure may require you to re-format or to replace your drive.

‘ If your computer is turned off while the system is updating the RMP database, the

database can become corrupt and unusable.

‘ If, for any reason, you re-install the RMP*Submit application, the RMP database will be

overwritten with a new, empty database file.

To backup your RMP data, simply copy the file SRMPDATA2002.MDB to an alternate location. 

SRMPDATA2002.MDB can be found in the directory or folder to which you installed the

RMP*Submit application, usually C:\Program Files\RMP Submit V3. It is recommended that

you copy this file to a diskette (the A drive), CD, or to some other removable media (such as a zip

drive). You may also choose to copy the file to a network file server drive. The important point

is that the file be copied to a drive that is different from the one you are using to run

RMP*Submit. You should exit the RMP*Submit application before making the backup copy. 

The frequency of backup depends on how much time you spend entering data. Making a backup

after each hour of data entry means that you will have, at most, one hour of data re-entry after
Ch. 1 Pg. 7

restoring from the backup copy.

Restoring Your Data from a Backup Copy

To restore your data, copy the file SRMPDATA2002.MDB from the backup location into the

directory of folder to which you installed the RMP*Submit application, usually C:\Program

Files\RMP Submit V3 overwriting if necessary the SRMPDATA2002.MDB file that may already

be there. In case of re-installation of RMP*Submit, perform the re-installation before copying the

SRMPDATA2002.MDB backup copy.

Checking Your Entry for Completeness 

To help ensure that your RMP is complete and accurate, RMP*Submit checks many (but not all)

data fields as you enter data. 

‘ If you skip an essential field, RMP*Submit prompts you to enter data before proceeding. 

‘ If you enter a value outside the acceptable range of values, RMP*Submit prompts you to

enter an acceptable value before proceeding. 

‘ If you attempt to leave a record that contains blanks in required fields, RMP*Submit asks

if you want to identify the required fields in the form that have not been filled in. 

‘ RMP*Submit has an extensive validation function that checks an entire RMP and allows

you to create a report of all errors. 

To have RMP*Submit check your RMP data for errors:

1. Select an RMP and click the Check button from the List of Risk Management Plans

Screen. If RMP*Submit finds any errors it will prompt you to view the error report. 

2. The validation function will also be executed automatically each time you Create

Submission File, as described in the next section of this manual.

Printing Your RMP Data

RMP*

Submit provides the capability to print an entire RMP or selected parts of an RMP from

within any section of the current RMP.

1. Click Print from the List of Risk Management Plans Screen or select <File, Print> from

the Menu bar. The RMP Report Options Dialog Box will appear. 
Ch. 1 Pg. 8

2. Click Entire RMP or select a section or subsection of the RMP to print. 

3. Click the Preview button to view your RMP before printing. When you preview an RMP,

each section is displayed as a separate report. You may print or close each report as

appropriate. 

4. Click the Print button to send the RMP directly to the printer without previewing it. 

5. Click the Cancel button to return to the previous Data Entry screen. 

Create Submission File

Once you have completed entering your RMP data, you can create a disk for submitting your

RMP to EPA.

1. Select an RMP from the List of Risk Management Plans Screen and click the Create

Submission File button.

2. A message box will display, asking if this is your first submission, a correction or a resubmission. If you answer "Correction" or "Resubmission," RMP*

Submit will check to

make sure that you have entered your RMP Facility Identifier. See Chapters 6 and 7 for

more information about submitting.

3. Next, RMP*Submit prompts you as to whether you wish to output this RMP to a floppy

diskette. If so, insert a formatted diskette into the appropriate drive.

4. Enter the drive where you want to save your RMP (Drive A: is the default), and click OK. 

For example, if your 3.5-inch disk drive is drive B:, you would enter “b”. Next, another

message box will display that says, “RMP will be output to file a:\rmp.txt. Is diskette in

Drive?” (A: represents the output drive you have chosen). Make sure that your disk is in

the correct drive and click OK. Your RMP is output (saved) to your submission disk with

the filename rmp.txt. The Create Submission File function will automatically validate

the selected RMP. If there are no critical errors, the RMP will be exported to a text file. 

You will also be asked if you would like to preview the error report described in Section

4.3.2. If critical errors are found during validation, this operation will be terminated. 

View the error report to see where errors exist in your RMP.
Ch. 1 Pg. 9

G. Welcome and Main Menu Screens

Welcome to RMP*Submit Screen

When you start RMP*

Submit, the Welcome to RMP*Submit screen appears. The Welcome

Screen (Exhibit 1) summarizes the steps for entering and submitting RMP data. Click the Print

button to print this screen. Click the Close button to close the Welcome screen and go to the

Main Menu. To disable the Welcome screen so that it does not display again, click the "Don't

display this message again" box at the bottom of the Welcome screen. To re-enable the display

of this dialog box, select Edit –> Options – > User Settings from the menu bar of the Main

Menu.

Exhibit 1. Welcome to RMP*

Submit screen

L Tip When the Welcome to RMP*Submit screen first appears, clicking the vertical

scroll bar may cause all the text to be highlighted (selected). If so, simply click

inside the text box or press <F2> to clear (unselect). 
Ch. 1 Pg. 10

Main Menu

When you close the Welcome screen, the Main Menu form (Exhibit 2) provides access to four

major functions: Data Entry; Edit Certification Letters; Import; and Create De-registration Letter.

Exhibit 2. Main Menu screen

Description of the Major Functions:

Data Entry

The Data Entry function allows you to add new or edit existing RMPs (first-time submissions,

corrections, and re-submissions); delete RMPs; check your RMP for completeness; print; and

create the submission file.

The commands "New" and "Edit" allow you to enter the data elements for the Registration, Worst

Case, and Alternative Release Scenarios, Five-Year Accident History, Program Level 2 and

Program Level 3 Prevention Programs, and Emergency Response Plan, and Executive Summary

sections of the RMP. 
Ch. 1 Pg. 11

When you select Data Entry, if you have not previously created an RMP or if there are no

existing RMPs, you will go directly to the Section 1 Registration Information Screen. If you have

existing RMPs, the List of Risk Management Plans Screen will be displayed (Exhibit 3). The List

of Risk Management Plans Screen displays a list of previously entered RMPs, by facility name. 

Exhibit 3. List of Risk Management Plans screen

To edit an existing RMP: 

Double-click on the facility name to go directly to the “Section 1. Registration

Information” screen. 

To execute any of the RMP functions (Edit, Delete, Check, Print, Create Submission File) for an

existing RMP:

Single-click on the facility name. This will highlight the name. Then, click on the

appropriate button to execute the following RMP functions: 

C New RMP – Add a new RMP facility plan

C Edit the selected RMP – This will open “Section 1. Registration

Information” screen

C Delete selected RMP – All records for the selected RMP will be deleted. 
Ch. 1 Pg. 12

C Check – The RMP will be checked for completeness.

C Print – This function will print the RMP.

C Create Submission File – This function will create the file for submission.

C Close – Data Entry screen will be closed

Edit Certification Letter

Part 68 specifies that a signed certification statement must be sent with each RMP:

68.185 Certification. 

(a) For Program 1 processes, the owner or operator shall submit in the RMP

the certification statement provided in § 68.12(b)(4) of this part.

(b) For all other covered processes, the owner or operator shall submit in the

RMP a single certification that, to the best of the signer's knowledge,

information, and belief formed after reasonable inquiry, the information

submitted is true, accurate, and complete.

This function will allow you to edit the template for the certification letter to accompany your

submission (for Program 1, for Program 2 or 3, and for a corrected RMP). You can cut and paste

this text into your own word processing package to finalize and print the letter. Sample

certification letters are provided in Appendix C. 

The certification statement must be signed by the owner or operator or a senior official with

management responsibility for the person (or persons) completing the RMP. The owner,

operator, or official must certify the accuracy and completeness of the RMP by signing and dating

the certification statement. The statement applies to all the information supplied in the RMP and

should be signed only after the form is complete. The name and title of the person signing the

statement should be printed or typed on the certification. The certification statement submitted

must bear the original signature of the person making the certification. 

Import

You may have RMP data from a previous version of RMP*Submit or another source that you

want to import into RMP*

Submit 2004. When RMP*Submit 2004 imports older versions, it will

check the NAICS code, the county name, the DUNS number, and the lat/long and display any

errors found. 

Additional information about the Import function is presented earlier in this chapter.
Ch. 1 Pg. 13

Create De-registration Letter

Changes may occur at your facility that make it no longer subject to part 68 (e.g., you replace the

regulated substances in your processes with unregulated substances). In that event, you must

submit a letter to the RMP Reporting Center within six months and include the effective date of

the de-registration (the date on which your facility was no longer covered by part 68) and the

reason for the de-registration. The letter must be signed by the owner or operator and include

your EPA FACILITY ID as assigned by the RMP Reporting Center (also known as RMP ID)

number. 

The Create De-registration Letter function will generate a letter for you. See Chapter 8 for

more details.
Ch. 2 Pg. 1

CHAPTER 2 ENTERING DATA

When you create a new RMP for a facility, you must start with Section 1 Registration

Information. The other sections of the RMP are only accessible while the Registration

Information Screen for the facility is open. 

You cannot enter data for Sections 2 through 5, 7, and 8 until you have entered facility name and 

process-specific information. 

Section 1: Registration

All covered facilities must complete the registration portion of the RMP even if you have only

Program 1 processes. The registration consists of facility identification information.

1.1.a. Facility Name. Provide the name of your facility. The name must be specific to the site; if

the site is part of a large corporation, the name may be the corporate name plus the location (for

example ABC Chemicals - Hightown Plant). Throughout the Risk Management Program, the

term “facility” means “any buildings, structures, equipment, installations or substance emitting

stationary activities (i) which belong to the same industrial group, (ii) which are located on 

one or more contiguous properties, (iii) which are under the control of the same person (or

persons under common control), and (iv) from which an accidental release may occur.” 

1.1.b. Parent Company #1 Name. Your parent company is the corporation or other business

entity that owns at least 50 percent of the voting stock of your company. If you are owned by a

joint venture, enter the first of your two major owners here. If your company does not have a

parent company, leave this data element blank.

1.1.c. Parent Company #2 Name. If you are owned by a joint venture, enter the name of the

second major owner here.

1.2 EPA Facility Identifier. The EPA Facility ID # must be left blank for first-time

submissions. Otherwise, use the number that was assigned to your facility by the RMP Reporting

Center after your first submission. The RMP Reporting Center included this number in their

acknowledgment letter. The EPA Facility ID # is a unique, 12-digit number. (If you don’t have

your EPA Facility ID#, call the RMP Reporting Center at 301-429-5018.)

1.3. Other EPA Systems Facility Identifier. Enter one of the following Facility Identification

numbers, in order of preference:

TRI (Toxic Release Inventory) Facility ID number (15 characters) 

Or

Resource Conservation and Recovery Act (RCRA) RCRIS Handler ID (12 characters)
Ch. 2 Pg. 2

(This Handler ID is the same as the RCRA Biennial Reporting System (BRS) ID. Soon,

BRS and RCRIS will be combined into the same system called RCRAInfo which will also

use this ID.)

Or

Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)

CERCLIS Site ID (7 characters)

If you know you have a facility ID for reporting to one of the EPA programs above, but do not

know what it is, you can find it by doing a search of EnviroFacts’ Facility database on the Internet

at: http://www.epa.gov/enviro/html/fii/fii_query_java.html or calling the EPCRA Hotline at

800-424-9346.

If your facility does not have an ID Number as described above, leave this data element blank.

1.4.a. Facility Dun and Bradstreet Number (DUNS). A Dun and Bradstreet Number (DUNS)

is a nine-digit identification number that allows your facility to be cross-referenced to various

business information. If you have a DUNS number, it should be available from your treasurer or

financial officer. You can also ascertain the number through Dun and Bradstreet (check their

website at www.dnb.com). If you don't have a DUNS number, leave this data element blank.

1.4.b-c. Parent Company Dun & Bradstreet Number(s) (DUNS). Enter the DUNS number of

your parent company(ies), if applicable. If you are owned by a joint venture, enter the numbers

for your two major owners. If you do not have a parent company or your parent company does

not have a DUNS number, leave this item blank.

1.5.a-e. Facility Location Address. Enter your facility location address, including the street,

city, state, and zip code (including the 4 digit extension, if applicable) of your facility. This is the

location where regulated substances are present. The city should be the local legal jurisdiction,

for example, a township or village. Use local street and road designations, not post office or

rural box numbers. This location may not represent the mailing address. EPA will not

attempt to mail correspondence to this address. All correspondence will be mailed to the

address provided at 1.6.c-h. If your location and mailing address are the same, then you will fill

in the same address at 1.6.c-h. 

1.5.f. Facility County. Enter the county in which the facility is located.

1.5.g-h. Facility Latitude and Longitude.

Enter the latitudinal and longitudinal coordinates of your facility in decimal degrees. You can

enter decimal latitude or longitude values to six decimal points precision. For example, a facility

with latitude / longitude of:
Ch. 2 Pg. 3

TRI Facility Siting Tool

EPA has developed the TRI Facility Siting Tool to allow facilities that submit Toxic

Release Inventory (TRI) reports to obtain their latitude and longitude. This tool may also be

used by facilities submitting Risk Management Plans (RMP). The tool asks you to enter

either a zip code or a city and state. It then provides a map that you can zoom into and pan

sideways, to identify your location. Once you get to the maximum zoom-in level, it will

show a satellite photo over the map, to further assist in pinpointing your exact location. The

tool will then display the latitude and longitude in “degrees/minutes/seconds” format. You

should use the DMS Calulator button in RMP*Submit to convert to decimal degrees. 

The TRI Facility Siting Tool can be accessed at the following web address:

http://www.epa.gov/tri/report/siting_tool/index.htm

If you use the TRI Facility Siting Tool to obtain your latitude and longitude, you should put

the following values in the additional latitude/longitude fields:

i. Lat/Long Method: I2 - Interpolation-Photo

m. Source Map Scale Number: 24000

k. Horizontal accuracy measure (m): 25

l. Horizontal Reference Datum Code: 002 - North American Datum of 1983

For additional information about latitude and longitude, see Appendix F of this manual.

39/ 1' 42", -76/ 42' 43" (degrees/minutes/seconds format) 

would be entered as 

39.028333, -076.711944 (decimal degrees format)

The DMS Calculator button provides a function to convert from degrees/minutes/seconds to

decimal degrees.

Enter only numerical data. Do not preface numbers with letters such as N or W to denote the

hemisphere. For most facilities using RMP*Submit, the hemispheres will be North or West,

which would correspond to a positive latitude and a negative longitude. You would therefore

enter no sign for latitude and a "-" sign as the first character for longitude.

It is important to provide accurate latitude and longitude values in your RMP. RMP*Submit will

help you enter accurate coordinates by letting you know if the value that you enter falls outside of

the range of values for the county in which your facility is located.

L Tip Be careful not to reverse your latitude and longitude coordinates. Latitude

in the 48 contiguous states ranges from 25/ to 49/ while longitude ranges

from -72/ to -124/.
Ch. 2 Pg. 4

1.5.i. Method for determining Latitude and Longitude. You also must indicate the method

that you used to determine your latitude and longitude data. 

1.5.j. Description of location identified by Latitude and Longitude. You must also describe

the exact location your latitude and longitude values represent. See Appendix F for the complete

lists of codes to be used for this element. The most common Latitude and Longitude location

descriptions are PG (Plant Entrance - General) and CE (Center of Facility).

1.5.k. Horizontal Accuracy Measure. You must also provide the measure of the accuracy (in

meters) of the latitude and longitude coordinates. 

1.5.l. Horizontal Reference Datum Code. You must provide the code that represents the

reference datum used in determining latitude and longitude coordinates you entered in 1.5.g and

1.5.h, respectively. The range of permissible values is given in Appendix F.

1.5.m. Source Map Scale Number. The number that represents the proportional distance on the

ground for one unit of measure on a map or photo. This field must be supplied if you have chosen

a lat/Long Method of type “Interpolation - Map” (I1) or “Interpolation - Photo” (I2).

1.6.a. Owner or Operator Name. Enter the name of the legal owner or operator of the facility

(person, company, association, or government agency).

1.6.b. Owner or Operator Phone. Enter the owner or operator’s business phone number,

including area code.

1.6.c-h. Owner or Operator Mailing Address. EPA will mail all correspondence to this

address. It need not be the facility address. Enter the owner or operator’s business mailing

address, including street or P.O. or rural box, city, state, and zip code (including 4 digit extension,

if applicable). The city should be the local legal jurisdiction, for example, a township or village. 

In this instance, you should use post office and rural box numbers, if appropriate. 

If your owner/operator mailing address is the same as your facility address, click the Copy

Facility button to automatically fill in this information.

If your owner/operator address is a foreign address, click the Switch to Foreign Address button

and proceed.

1.7.a. Name of person responsible for RMP (part 68) implementation.

1.7.b. Title of person or position responsible for RMP (part 68) implementation.

Enter the name and title of the person or position with overall responsibility for the risk

management program at your site. Although the individual’s name is not required, the title of the

person or the position that has this responsibility is required. 

1.8. Emergency Contact. 
Ch. 2 Pg. 5

1.8.a-b. Name and Title. Enter the name plus the title or job classification of the person

designated as the emergency contact. If you have more than one contact person, you may want

to list the others in your Executive Summary.

Your emergency contact should be:

g An employee of or a contractor to your facility;

g Knowledgeable about your site;

g Aware of all emergency plans; and

g Able to provide emergency response support or direct response personnel to

provide support. 

1.8.c. Phone Number. Enter the phone number, including area code, where the emergency

contact can be reached during normal business hours. You most likely will enter the facility

phone number here. If your facility does not have a phone number, you may enter the business

phone number of the emergency contact, the phone number of a dispatcher, or the customer

service phone number.

1.8.d-e. 24-Hour Phone Number & Extension or Pin Number. Enter the phone number,

including area code, where the emergency contact can be reached during non-working hours. 

You may enter the emergency contact’s 24-hour “beeper” number. There is a space for an

extension or pin number, if applicable.

1.8.f. Emergency Contact E-mail address. This is a new element in 2004. Provide an e-mail

address (if one exists) for the emergency contact. Enter N/A if no email address exists.

1.9.a. Facility or Parent Company E-Mail Address (Optional). You may choose to provide an

e-mail address to which inquiries from the public could be sent. The e-mail address could be for

the person who developed your RMP or your public liaison office. 

1.9.b. Facility Public Contact Phone Number (Optional). You may choose to provide a phone

number for public inquiries. It could be the phone number of the person who developed your

RMP or of your public liaison office.

1.9.c. Facility or Parent Company WWW Homepage Address (Optional). You may choose to

provide an Internet address where the public can obtain more details on your accident prevention

program, offsite consequence analysis, or other facility or corporate information.

1.10. LEPC (Optional). Enter the name of your Local Emergency Planning Committee (LEPC)

for your planning district. LEPCs were created to do local planning under the Emergency

Planning and Community Right to Know Act (EPCRA) of 1986. In RMP*Submit, you will select

your LEPC's name from a pick list based on the facility county and zip code information that you

have provided. If you do not know your LEPC's name, you can call your local fire department or

refer to the LEPC Database on the Internet at: http://www.epa.gov/swercepp/lepclist.htm. This

data element will help your LEPC find the facilities in its jurisdiction. 
Ch. 2 Pg. 6

1.11. Number of full-time equivalent employees on site. Enter the number of full-time

equivalent employees who work at your facility. To determine the number of full-time equivalent

employees at your facility, add together the fractions of full-time work performed by part-time or

seasonal employees and round to the nearest whole number (see example below). Do not include

contract employees. If your facility is un-manned or is staffed only by part-time employees, you

should briefly explain these circumstances in the executive summary.

For example, suppose a facility has 10 regular full-time employees, two part-time employees that

each work 30 hours per week, and seven seasonal employees that each work 40 hours per week

for three months of the year. You should count the two part-time employees as 3/4 of an

employee each because they work 3/4 that of a full-time employee and the seven seasonal

employees as a 1/4 of a full-time employee each, for the same reason. As shown in the table

below you get 13.25, which you should round to the nearest whole number. You should enter

“13" for the number of full-time employees.

Type of Employee Number of Employees Times the

Fraction of a Full-Time

Employee 

Full-Time Equivalent

Employees

Full-time (40 Hours) 10 x 1 10

Part-Time (30 hours) 2 x 0.75 1.5

Seasonal (3

months/year)

7 x 0.25 1.75

Total 13.25 (rounded to 13)

Exhibit 5. Example Calculation of Full-Time Equivalent Employees

1.12.a. Covered by OSHA’s Process Safety Management (PSM) of Highly Hazardous

Chemicals Standard (29 CFR 1910.110). This data element applies to your facility as a whole

and is not a process-by-process determination. Therefore, if any process at your facility is subject

to the OSHA PSM standard, select this data element, even if the PSM process is not covered by

the RMP rule. For further information, about OSHA’s PSM standard, see 

www.osha-slc.gov/SLTC/processsafetymanagement.gov.

1.12.b. Covered by EPCRA section 302. Check this box if you have on site more than a

threshold planning quantity of a substance that is an extremely hazardous substance (EHS)

defined in 40 CFR 355. If you are subject to those requirements, check this element, regardless

of whether the EHS is an RMP regulated substance or is held in a process below the 112(r)

threshold quantity. Two quick hints: 
Ch. 2 Pg. 7

(1) If you are subject to the RMP rule because you have more than a threshold quantity of a 

toxic substance listed under Section 112(r), you are subject to EPCRA section 302 and

must select this data element. 

(2) If you are subject to the RMP rule only as a result of flammable substances, you are not

subject to EPCRA section 302, and you can leave this data element blank. 

1.12.c. CAA Title V Air Operating Permit ID. Title V of the Clean Air Act requires major

sources of air pollution to obtain permits. If your facility has been issued a Title V operating

permit by a federal, state, or local permitting agency, check this element and enter your permit

number.

1.13. OSHA Star or Merit Ranking (Optional). Check the box if your facility has received a

Star or Merit Ranking under OSHA’s Voluntary Protection Program.

1.14. Last Safety Inspection (by an External Agency) Date.

Record the date of your last safety inspection by an external agency.

1.15. Last Safety Inspection Performed by an External Agency (select one ).

Select the agency (or agencies) that performed the inspection. If you select “Other,” please

specify the agency. If your last safety inspection was a joint inspection, enter multiple agencies

by typing them into the field.

1.16. Will this RMP involve Predictive Filing? 

Predictive Filing is an RMP filing option that allows your facility to submit an RMP which

includes regulated substances which may not actually be present at the facility at the time the

RMP is submitted. This option is intended to assist facilities such as chemical warehouses,

chemical distributors, batch processors and the like whose operations involve highly variable

types and quantities of regulated substances but who are able to forecast their inventory with

some degree of accuracy. Under 40 CFR §68.190, a facility is required to update and re-submit its

RMP no later than the date on which a new regulated substance is first present in a covered

process above a threshold quantity. By using Predictive Filing, you will not be required to update

and re-submit your RMP when you receive a new regulated substance if that substance was

included in your latest RMP submission (as long as you receive it in a quantity that does not

trigger a revised offsite consequence analysis as provided in 40 CFR §68.36).

If you use Predictive Filing, you should implement your Risk Management Program and prepare

your RMP in exactly the same way as if all of the substances included in the RMP were actually

present. This means that you must meet all rule requirements for each regulated substance for

which you file, whether or not that substance is actually present on site at the time you submit

your RMP. Depending on the substances for which you file, this may require you to perform

additional worst-case and alternative-case scenarios and to implement additional prevention

program elements. Note that if your facility uses this option you must still update and resubmit

your RMP if you receive a new regulated substance which was not included in your latest RMP. 

Your facility must also continue to comply with the other update requirements stated in 40 CFR
Ch. 2 Pg. 8

§68.190.

If your facility uses Predictive Filing, the RMP database for your facility will indicate that your

facility has filed a predictive RMP. This will inform users of the database that some of the

chemicals in your RMP may not actually be present on site, but will not indicate which specific

chemicals are on site at any given time. Therefore, you may receive more frequent questions

from the public, local officials, or implementing agencies about your actual chemical inventory. 

EPA encourages you to engage in more frequent dialogue with these parties, and in particular

with local emergency planners, emergency responders, and community officials to update them

on your current inventory of regulated substances.

1.17. Process-Specific Information

Click the <Processes> button located at the bottom of the last page of the Registration Data Entry

form. The number in parentheses indicates the number of processes that you have already

entered. 

In this section of the registration, answer five questions for EACH covered process at your

facility. A few examples follow the descriptions of the data elements below.

The system generates a Process ID # automatically to track multiple processes as you fill out the

remaining sections of your RMP.

Process Description. This description is optional. It is provided to help you (if you need to)

track multiple processes as you fill out the remaining sections of your RMP. This description will

not be submitted to EPA with the RMP data.

1.17.a. Program Level. Each covered process must be assigned to a program level that reflects

the process’ potential for public impacts and the level of effort needed to prevent accidents. The

rule requirements the process must meet depend on the program level to which it is assigned. 

Following is a brief description of the applicability criteria for each program level, but you should

consult the rule and Chapter 2 of the General Guidance for Risk Management Programs in

determining the program level applicable to your covered processes:

Program 1 Program 2 Program 3 (unless eligible for

Program 1)
Ch. 2 Pg. 9

Process has experienced no

accident in past 5 years that

resulted in significant off-site

impacts,

No public receptors in

worst-case circle, and

Emergency response

coordinated with local

responders.

Process is not eligible for

Program 1 or subject to

Program 3.

Process is subject to OSHA

PSM, or

Process is in NAICS code

32211, 32411, 32511, 325181,

325188, 325192, 325199,

325211, 325311, or 32532.

Exhibit 6. Program Eligibility Criteria

A process can qualify for Program 1 even if the process is already subject to OSHA PSM. For

Program 1 processes, the implementing agency will inspect and enforce only with respect to the

minimal Program 1 requirements. If you assign a process to Program 2 or 3, the implementing

agency will inspect and enforce with respect to all the requirements of the higher program levels,

even though it may qualify for Program 1. However, if you are already in compliance with the

prevention elements of Program 2 or Program 3, you may want to use the RMP to inform the

community of your prevention efforts.

KEY POINTS TO REMEMBER

In determining program levels for your process(es), keep in mind the following:

(1) The program levels apply to individual processes and generally indicate the

risk management measures necessary to comply with this regulation for the

process, not the facility as a whole. The eligibility of one process for a program

level does not influence the eligibility of other covered processes for other

program levels.

(2) Any process can be eligible for Program 1, even if it is subject to OSHA PSM

or is in one of the NAICS codes subject to Program 3. 

(3) Program 2 is the default program level. There are no "standard criteria" for

Program 2. Any process that does not meet the eligibility criteria for either

Programs 1 or 3 is subject to the requirements for Program 2.

Refer to Chapter 2 of the General Guidance for Risk Management Programs for more

information on determining the Program levels of your processes. Once you determine the

Program level, simply enter 1, 2, or 3 for this data element. 
Ch. 2 Pg. 10

L Tip Note that you will not be allowed to enter NAICS codes or chemicals until you

enter the program level for the process. Also note that the program level that you

enter relates to other sections of the RMP. Once you have entered the program

level, the only way you can change it is by deleting the entire Process record and

entering a new Process record.

1.17.b. NAICS Code(s). The North American Industry Classification System (NAICS)

categorizes businesses by fitting them into descriptive categories that correspond to five-digit or

six-digit codes. NAICS codes have replaced SIC codes, with which you may be familiar. For

example, pulp mills are NAICS code 32211, paper mills are 322121 or 322122, and metal platers

are 332813. The first three digits of a five or six-digit code define a major business sector and

the last two or three digits indicate an establishment’s specialty within the major sector. 

For this data element you should provide the NAICS code that most closely corresponds to the

process; it will not necessarily be the same NAICS code for your facility as a whole. For

example, if you manufacture chlorine, then process it to make cleaners, the chlorine

manufacturing is in NAICS code 325818 and the cleaner manufacturing is in NAICS code

325612. If your chlorine manufacturing vessel is connected by pipes to, or co-located with, the

cleaner manufacturing vessel, they are considered one "process" by the RMP rule. In such a

case, you should enter the NAICS code that describes the primary activity of the "process." In

the example above, if the chlorine and cleaner vessels are interconnected, the primary activity of

the "process" is manufacturing cleaner, since that is the ultimate product of the "process." You

may also enter additional NAICS codes if you wish to identify other aspects of a process not

captured by the NAICS codes for the primary activity. In the example above, you could also

enter NAICS code 325181 for chlorine manufacturing, if you so desire. If you do enter multiple

NAICS codes, be sure to enter your primary NAICS code first. 

You should determine the NAICS codes for your processes based on your activities on site using

the 2002 North American Industry Classification System Manual. Appendix B of the General

Guidance for Risk Management Programs provides the NAICS codes for the industry sectors

most likely to be subject to 40 CFR Part 68. RMP*Submit also contains the full list. You may

also access the full list online at www.census.gov/epcd/www/naics.html and a cross-walk

between SIC codes and NAICS codes at http://www.census.gov/epcd/www/naicstab.htm.

In addition to these resources, note the availability of the NAICS Code Selector under the

NAICS Help button, available on the NAICS Codes screen.

Below is the conversion from SIC codes to NAICS codes for the Program 3 NAICS codes. Note

there are 2 duplicates listed in the NAICS column because of the conversion. The 9 SIC codes

translate into a total of 10 NAICS codes.

SIC NAICS Sector 

2812 325181 Alkalies and chlorine

2821 325211 Plastics and resins
Ch. 2 Pg. 11

2873 325311 Nitrogen fertilizer

2879 32532 Pesticide and other agricultural chemicals

2911 32411 Petroleum refineries

2611 32211 Pulp mills only

2819 325188 All other basic inorganic chemical manufacturing

2865 32511 Aromatics have been combined with aliphatics from 2869 to form

the new petrochemical manufacturing

325192 Other covers the cyclic crude and intermediate manufacturing

2869 32511 Aliphatics, joined with aromatics in petrochemical manufacturing;

325188 Carbon bisulfide, moved to "All other basic inorganic chemical

manufacturing" (covered from old 2819);

325199 Other, moved to "All other basic organic chemical manufacturing."

1.17.c.1. Chemical Name. For each covered process, select the names of all regulated

substances held above the threshold. Many regulated substances have synonyms; however, you

must enter the name of the regulated substance as it appears in 40 CFR § 68.130. If you have a

NFPA-4 flammable mixture containing regulated flammables, you may list it as a “flammable

mixture.” List all of the regulated substances contained in the mixture; however, only report the

quantity of the entire mixture, not the individual substances. RMP*Submit will automatically

enter the corresponding CAS number.

1.17.c.3. Quantity. For each chemical reported in 1.17.c.1, estimate the maximum quantity (in

pounds) held in the covered process at any one time during the calendar year to two significant

digits. For example:

5,333 pounds should be reported as... 5,300 pounds

107,899 pounds should be reported as... 110,000 pounds

128,000 pounds should be reported as... 130,000 pounds
Ch. 2 Pg. 12

Can I use Maximum Quantity On-Site Data from my EPCRA Tier II Reports? 

Not directly. EPCRA Tier II reports require maximum quantity on-site in specified ranges. The RMP registration

asks for the maximum quantity in a process. Therefore, if your facility has several covered processes containing

the same regulated substance above the threshold, estimate on a process-by-process basis the maximum quantity

of the regulated substance in each process. 

You may be able to use raw Tier II data to estimate the quantity of a regulated substance in a process. It is likely

that in preparing your Tier II reports you estimated the quantity of a regulated substance in each process or

building and then added the quantities together to estimate the total maximum on-site. Therefore, you can take

the estimates you used to calculate your Tier II ranges for your RMP registration.

How do I Report Maximum Quantity in a Process for Mixtures or Trade Name Products? 

Toxics. If the regulated toxic substance present in a process is part of a mixture or trade name product, determine

the maximum quantity of the mixture or trade name product and then calculate the weight percent of the regulated

toxic substance to report for quantity. Do not include the weight of the entire mixture or trade name product.

Flammables. For regulated flammable substances that are part of a mixture, and the mixture meets the criteria of

NFPA-4, report the weight of the mixture.
Ch. 2 Pg. 13

EXAMPLE 1

Suppose you have 21,365 pounds of ammonia in a covered process classified as other basic

inorganic chemicals (NAICS code 32518) and do not have ammonia in any other covered

processes. Report your ammonia maximum as:

Process Number: 1

Process Description: Basic Inorganic Chemicals

1.17.a. Program Level: 2

1.17.b. NAICS Code(s): 32518

1.17.c. Chemical 1.17.c.1. Name: 1.17.c.2. CAS #: 1.17.c.3. Quantity (lbs.):

Ammonia 7664-41-7 21,000

Now suppose that in addition to the 21,365 pounds, you also have 25,600 pounds of ammonia in

another covered process classified as nitrogenous fertilizers (NAICS code 325311). In this case,

report a second process as:

Process Number: 2

Process Description: Nitrogenous fertilizer

1.17.a. Program Level: 2

1.17.b. NAICS Code(s): 325311

1.17.c. Chemical 1.17.c.1. Name: 1.17.c.2. CAS #: 1.17.c.3. Quantity (lbs.):

Ammonia 7664-41-7 26,000
Ch. 2 Pg. 14

EXAMPLE 2

You received one shipment of a nitric acid solution last year that filled your 5,000-gallon storage

tank. You know that the solution contains 95% nitric acid, which is a regulated chemical with a

threshold quantity of 5,000 pounds.

First, convert gallons to pounds:

The density of 95% nitric acid is about 12 pounds per gallon, so you calculate the total weight of

solution by multiplying 5,000 gallons by 12 to get 60,000 pounds. 

Then, calculate the portion of the solution attributable to the regulated toxic substance:

To calculate the weight of nitric acid, you multiply 60,000 pounds by 0.95 to get 57,000 pounds. 

Report the nitric acid in this process as follows:

Process Number: 3

Process Description: Storage - nitric acid

1.17.a. Program Level: 2

1.17.b. NAICS Code(s): 325311

1.17.c. Chemical 1.17.c.1. Name: 1.17.c.2. CAS #: 1.17.c.3. Quantity (lbs.):

Nitric Acid 7697-37-2 57,000
Ch. 2 Pg. 15

1.18.a. RMP Preparer Name. If an outside contractor or consultant prepared the RMP for the

facility, enter the name of the contractor or consultant. 

1.18.b. RMP Preparer Telephone. Enter the telephone number of the contractor or consultant

who prepared the RMP for the facility. 

1.18.c-g. RMP Preparer Address. Enter the street address, city, state, and zip code of the

contractor or consultant who prepared the Risk Management Plan for the facility.
Ch. 2 Pg. 16

Overview of Sections 2-5: Offsite Consequence Analysis

You must submit data on:

1. Worst-case release scenario analysis of covered processes as follows:

Report one worst-case release scenario for each Program 1 process. Program 1 processes

must have no public receptors within the distance to the endpoint in the worst-case

analysis. 

If your facility has Program 2 or Program 3 processes, report one worst-case release

scenario to represent all Program 2 and Program 3 processes having toxic regulated

substances present above the threshold quantity, and one worst-case release scenario to

represent all Program 2 and Program 3 processes having flammable regulated substances

present above the threshold quantity. If you have more than one Program 2 or 3 process,

you will report the worst-case release scenario for the Program 2 or 3 process that would

have the greatest potential impact on the public (i.e., the greatest distance to endpoint). 

You may also need to submit an additional worst-case scenario for either hazard class

(i.e., toxic or flammable), if a worst-case release from elsewhere at your facility would

potentially affect a different set of public receptors than those affected by your initial

worst-case scenario(s).

2. Alternative release scenario analysis of Program 2 and Program 3 processes as follows:

Present one alternative release scenario for each regulated toxic substance held above the

threshold quantity in a Program 2 or 3 process, including the substance considered in the

worst-case analysis.

Present one alternative release scenario to represent all flammable substances held above

the threshold quantity in a Program 2 or 3 process.

Note that alternative release scenarios should be those that will reach an endpoint offsite,

unless no such scenario exists.

You may include one graphic (map or diagram) in electronic format for each release scenario

that you report, but it is not required.

Using a flammable mixture for your OCA: You may have registered a flammable mixture for

a process, even if the entire flammable mixture does not ever occur together in one vessel in the

process. When reporting the OCA, choose the flammable mixture from the registration section,

but do the modeling based on the specific components of the flammable mixture that are

contained in the vessel that you are modeling for the OCA. 

Refer to Chapter 4 of the General Guidance for Risk Management Programs for more details on

the requirements of the Offsite Consequence Analysis.
Ch. 2 Pg. 17

Section 2: Toxics: Worst-Case

Complete this section for each toxic worst-case scenario you report.

2.1.a. Chemical name. Enter the name of the regulated toxic chemical you evaluated in the

worst-case scenario.

2.1.b. Percent weight of chemical (if in a mixture). If your worst-case scenario involves the

release of a mixture containing a regulated substance, enter the percentage weight of the

regulated substance in the mixture. Leave blank if it is not a mixture.

2.2. Physical state. Select the physical state of the chemical in the vessel that you are modeling.

a. Gas. 

b. Liquid. 

c. Gas liquified by pressure.

d. Gas liquified by refrigeration.

2.3. Model used (select one). Select the source of your results for your worst-case release

analysis or enter another model name in "Other":

a. EPA’s OCA Guidance Reference Tables or Equations

b. EPA’s RMP Guidance for Ammonia Refrigeration Reference Tables or Equations

d. EPA’s RMP Guidance for Waste Water Treatment Plants Reference Tables or 

Equations

e. EPA’s RMP Guidance for Warehouses Reference Tables or Equations

f. EPA’s RMP Guidance for Chemical Distributors Reference Tables or Equations

g. EPA’s RMP*CompTM

h. Areal Locations of Hazardous Atmospheres (ALOHA®)

z. Other model (specify)

2.4. Scenario. Select one of the following which describes your worst-case release scenario.

(Note: This list is set by the regulation.)

a. Gas release. A release of the substance in a vapor state.

b. Liquid spill and vaporization. A release of the substance in a liquid state with

subsequent vaporization.

2.5. Quantity released (lbs). Enter the quantity of toxic chemical you used for your worst-case

scenario analysis in pounds to 2 significant digits. This is the total amount that would be lost

from a vessel or pipeline, even if the release location was inside a building or into other

containment. The "release rate" or the rate at which the chemical actually gets into the outside

air for the downwind dispersion analysis, is reported in 2.6 below. See Chapter 2 on

Determining Worst-Case Scenarios in the RMP Offsite Consequence Analysis Guidance for

more details. Here's how to report the quantity to 2 significant digits:

 5,333 pounds should be reported as... 5,300 pounds

107,899 pounds should be reported as... 110,000 pounds 
Ch. 2 Pg. 18

If you have less than 1 pound released, round up to 1 pound. You may want to clarify that in

your Executive Summary.

2.6. Release rate (lbs/minute). Enter the rate of release to the outside air in pounds per minute

to 1 significant digit. For example:

4.3 pounds per minuteshould be reported as... 4 pounds per minute

19 pounds per minute should be reported as... 20 pounds per minute

For gases, a gas liquefied by pressurization alone, or a gas liquefied by refrigeration where the

released refrigerated liquid forms a pool of 1 cm or less in depth, the release rate should be the

total quantity released divided by 10 minutes (this is a regulatory requirement) and multiplied by

the appropriate mitigation factor if a mitigated release. See Chapter 4 of the General Guidance

for Risk Management Programs for more information.

The worst-case release scenario for liquid substances assumes that the liquid is instantaneously

spilled on the ground or other surface followed by volatilization into the air. For the release of a

liquid or a gas liquefied by refrigeration where the refrigerated liquid forms a pool deeper than 1

cm, the release rate to the air should be the rate of volatilization based on the properties of the

substance and size of the liquid pool formed by the released substance, multiplied by the

appropriate release mitigation factor if a mitigated release.

2.7. Release duration (minutes). Indicate the length of time in minutes to the nearest 10

minutes for the entire quantity released from the vessel, pipeline, or other source to be released

to the outside air. 

For gases, a gas liquified by pressurization alone, or a gas liquified by refrigeration where the

released refrigerated liquid forms a pool of 1 cm or less in depth, you should assume that the

release duration is 10 minutes. 

For a liquid or a gas liquified by refrigeration where the released refrigerated liquid forms a pool

deeper than 1 cm, the release duration should be the time required for a pool formed by the

released substance to completely vaporize. 

Although in some cases it may take longer than 60 minutes for the pool to completely volatilize,

most dispersion models use the release rate and calculate the maximum downwind dispersion

distance within 60 minutes; therefore, you may enter 60 minutes for your duration even if the

duration from your modeling is longer than 60 minutes. You can also enter the exact duration

from your modeling up to 9999 minutes.

2.8. Wind speed (meters/second). This value has been set by EPA at 1.5 meters per second,

unless you can demonstrate that local meteorological data applicable to your facility show a

higher minimum wind speed at all times during the last three years. If you can demonstrate

higher minimums existed, these minimums may be used. Provide the wind speed in meters per
Ch. 2 Pg. 19

second.

2.9. Atmospheric Stability Class. This value has been set by EPA at "F" stability class, unless

you can demonstrate that local meteorological data applicable to your facility show a less stable

atmosphere at all times during the last three years. If you can demonstrate less stable conditions

existed, you may use the appropriate stability class.

2.10. Topography (select one). Indicate whether the local topography is urban or rural. Urban

means that there are many obstacles in the immediate area; obstacles include buildings or trees. 

Rural means that the terrain is generally flat and unobstructed in the immediate area.

2.11. Distance to endpoint (miles). Indicate the distance to the endpoint in miles to 2

significant digits, using the endpoint specified for the chemical in 40 CFR Part 68, Appendix A. 

Convert your modeling results into miles by dividing the distance in feet by 5280 or yards by

1760. Refer to the following to determine 2 significant digits:

 .397 miles should be reported as... .40 miles

 9.345 miles should be reported as... 9.3 miles

 20.764 miles should be reported as... 21 miles

2.12. Residential population within distance to endpoint. Estimate the population within the

circle with a center at the point of the release and a radius determined by the distance to the

endpoint to two significant digits (e.g., 5,500 people rather than 5,483). Population estimates

include only residential populations. You should base your population estimates on the latest

Census data. Information on sources of Census data can be found on the website.

2.13. Public receptors within distance to endpoint. Public receptors must be identified within

the circle with a center at the point of the release and a radius determined by the distance to the

endpoint. Public receptor means locations where members of the public may be exposed to toxic

concentrations, radiant heat, or overpressure as a result of the release. Public receptors include

locations within the facility's property boundary to which the public has routine and unrestricted

access during or outside business hours (e.g. a recreation field). Locations inhabited or occupied

by the public at any time without restriction by the source (such as fences or security guards) are

public receptors (see the General Guidance for Risk Management Programs for more

information on identifying public receptors). You do not need to list specific locations or

estimate populations at these locations. The presence of these receptors may be determined

using local street maps. Select all that apply.

a. Schools. Public and private elementary, secondary, or post-secondary educational

institutions (e.g., colleges).

b. Residences

c. Hospitals

d. Prisons or Correctional facilities

e. Recreation areas. Including stadiums, parks, and public pools.

f. Major commercial, office, or industrial areas. Including industrial parks, office

buildings, shopping malls, commercial areas, and commercial farms. 
Ch. 2 Pg. 20

g. Other (Specify). Include any other additional information here. 

2.14. Environmental receptors within distance to endpoint. Environmental receptors must be

identified within the circle with a center at the point of the release and a radius determined by the

distance to the endpoint. Environmental receptor means natural areas, such as national or state

parks, forests, or monuments; officially designated wildlife sanctuaries, preserves, refuges, or

areas; and federal wilderness areas, that could be exposed at any time to toxic concentrations,

radiant heat, or overpressure as a result of the release. Environmental receptors can be identified

on local U.S. Geological Survey maps, which can be found at many libraries. Select all that

apply.

a. National or state parks, forests, or monuments

b. Officially designated wildlife sanctuaries, preserves, or refuges

c. Federal wilderness areas

d. Other (Specify). Include any other additional information here. 

2.15. Passive mitigation considered. Mitigation means specific activities, technologies, or

equipment designed or deployed to capture or control substances that have been released to

minimize exposure of the public or the environment. Passive mitigation means equipment,

devices, or technologies that function without human, mechanical, or other energy input. Select

all passive mitigation measures that were considered in defining the release quantity or rate to

the worst-case scenario.

a. Dikes. A low wall that acts as a barrier to prevent a spill from spreading.

b. Enclosures. Physical containment of the release within a structure (e.g., a building).

c. Berms. A mound or wall of earth at the top or bottom of a slope that prevents a spill

from spreading.

d. Drains. A channel that carries off surface water.

e. Sumps. A pit or tank that catches liquid runoff for drainage or disposal.

f. Other (specify)

2.16. Graphics file name (Optional). You may submit one graphic file to illustrate each

release scenario. Click to the button to the right of the Graphic File field (the button with three

dots). Locate the graphic file, and press “Open.”

Graphics will be accepted in either GIF or JPEG file format. These are the most popular

graphics formats in use today on the Internet. Most commercial drawing, painting, or scanning

software supports these two graphics file formats. You may want to search 

www.shareware.com for a list of graphics programs that are available for download, either as

shareware or evaluation versions.

JPEG (pronounced "jay-peg") is a standardized image compression mechanism. JPEG stands for

Joint Photographic Experts Group, the original name of the committee that wrote the standard. 

JPEG is designed for compressing either full-color or gray-scale images of natural, real-world

scenes. It works well on photographs, naturalistic artwork, and similar material. 
Ch. 2 Pg. 21

GIF (tm) is a standard for defining generalized color "raster" images. This "Graphics

Interchange Format" allows high-quality, high-resolution graphics to be displayed on a variety of

graphics hardware and is intended as an exchange and display mechanism for graphics images. 
Ch. 2 Pg. 22

Section 3: Toxics: Alternative releases

Complete this section for each toxic regulated substance held above the threshold quantity in a

Program 2 or Program 3 process. 

3.1.a. Chemical Name. Enter the name of the regulated toxic chemical you evaluated in the

alternative release scenario.

3.1.b. Percent weight of chemical (if in a mixture). If your alternative scenario involves the

release of a mixture containing a regulated substance, enter the percentage weight of the

regulated substance in the mixture. Leave blank if it is not a mixture.

3.2. Physical state. Select the physical state of the chemical in the vessel that you are modeling.

a. Gas.

b. Liquid.

c. Gas liquified by pressure.

d. Gas liquified by refrigeration.

3.3. Model used (select one). Select the source of your results for your alternative release

analysis or enter another model name in "Other."

a. EPA’s OCA Guidance Reference Tables or Equations

b. EPA’s RMP Guidance for Ammonia Refrigeration Reference Tables or Equations

d. EPA’s RMP Guidance for Waste Water Treatment Plants Reference Tables or

Equations

e. EPA’s RMP Guidance for Warehouses Reference Tables or Equations

f. EPA’s RMP Guidance for Chemical Distributors Reference Tables or Equations

g. EPA’s RMP*CompTM

h. Areal Locations of Hazardous Atmospheres (ALOHA®)

z. Other model (specify)

3.4. Scenario. Select one of the following which describes your alternative release scenario or

enter another scenario in Other. (Note: This list is set by the regulation):

a. Transfer Hose Failure. Failure of the connection between two or more vessels.

b. Pipe Leak. Release through a rupture in a pipe.

c. Vessel Leak. Release through a rupture in a vessel.

d. Overfilling. Release due to filling a pipe, vessel, or other container past its capacity.

e. Rupture Disk/Relief Valve. Release due to failure of a rupture disk/relief valve to

function properly. A rupture disk/relief valve is a valve that relieves pressure beyond a

specified limit; a relief valve closes upon return to normal operating conditions.

f. Excess Flow Valve Failure. Release caused by the failure of excess flow device to

function properly and prevent surges from reaching downstream equipment.

g. Other (specify)

3.5. Quantity released (lbs). Enter the quantity of toxic chemical you used for your alternative
Ch. 2 Pg. 23

scenario analysis in pounds to 2 significant digits. If you have less than 1 pound released, round

up to 1 pound. You may want to clarify that in your Executive Summary.

3.6. Release rate (lbs/minute). Enter the rate of release to the outside air in pounds per minute

to 1 significant digit. For example:

4.3 pounds per minuteshould be reported as... 4 pounds per minute

19 pounds per minute should be reported as... 20 pounds per minute

For gases, a gas liquefied by pressurization alone, or a gas liquefied by refrigeration where the

released refrigerated liquid forms a pool of 1 cm or less in depth, the release rate should be the

total quantity released divided by 10 minutes (this is a regulatory requirement) and multiplied by

the appropriate mitigation factor if a mitigated release. See Chapter 4 of the General Guidance

for Risk Management Programs for more information.

3.7. Release duration (minutes). Indicate the length of time in minutes to the nearest minute

for the released quantity to be released to the outside air (from the time the release starts to the

time it is mitigated or stopped). See Chapter 4 of the General Guidance for Risk Management

Programs for more information. 

3.8. Wind speed (meters/second). If you used the OCA Guidance or one of EPA’s model

program guidance documents, indicate 3 meters per second. If you modeled your scenario

separately, indicate the wind speed used. 

3.9. Atmospheric Stability Class. If you used the OCA Guidance or one of EPA’s model

program guidance documents, list "D" stability. If you modeled your scenario separately,

indicate the stability class used. 

3.10. Topography (select one). Indicate whether the local topography is urban or rural. Urban

means that there are many obstacles in the immediate area; obstacles include buildings or trees. 

Rural means that the terrain is generally flat and unobstructed in the immediate area.

3.11. Distance to endpoint (miles). Indicate the distance to the endpoint in miles to 2

significant digits, using the endpoint specified for the chemical in 40 CFR Part 68, Appendix A. 

Convert your modeling results into miles by dividing the distance in feet by 5280 or yards by

1760. Refer to the following to determine 2 significant digits:

 .397 miles should be reported as... .40 miles

 9.345 miles should be reported as... 9.3 miles

 20.764 miles should be reported as... 21 miles

3.12. Residential population within distance to endpoint. Estimate the population within the

circle with a center at the point of the release and a radius determined by the distance to the

endpoint to two significant digits (e.g., 5,500 people rather than 5,483). Population estimates

include only residential populations.
Ch. 2 Pg. 24

3.13. Public receptors within distance to endpoint. Public receptors must be identified within

the circle with a center at the point of the release and a radius determined by the distance to the

endpoint. Public receptor means locations where members of the public may be exposed to toxic

concentrations, radiant heat, or overpressure as a result of the release. Public receptors include

locations within the facility's property boundary to which the public has routine and unrestricted

access during or outside business hours (e.g. a recreation field). Locations inhabited or occupied

by the public at any time without restriction by the source (such as fences or security guards) are

public receptors (see the General Guidance for Risk Management Programs for more

information on identifying public receptors). You do not need to list specific locations or

estimate populations at these locations. The presence of these receptors may be determined

using local street maps. Select all that apply.

a. Schools. Public and private elementary, secondary, or post-secondary educational

institutions (e.g., colleges).

b. Residences

c. Hospitals

d. Prisons or Correctional facilities

e. Recreation areas. Including stadiums, parks, and public pools.

f. Commercial, office, or industrial areas. Including industrial parks, office buildings,

shopping malls, commercial areas, and commercial farms. 

g. Other (Specify). Include any other additional information here. 

3.14. Environmental receptors within distance to endpoint. Environmental receptors must be

identified within the circle with a center at the point of the release and a radius determined by the

distance to the endpoint. Environmental receptor means natural areas, such as national or state

parks, forests, or monuments; officially designated wildlife sanctuaries, preserves, refuges, or

areas; and federal wilderness areas, that could be exposed at any time to toxic concentrations,

radiant heat, or overpressure as a result of the release. Environmental receptors can be identified

on local U.S. Geological Survey maps, which can be found at many libraries. Select all that

apply.

a. National or state parks, forests, or monuments

b. Officially designated wildlife sanctuaries, preserves, or refuges

c. Federal wilderness areas

d. Other (Specify). Include any other additional information here. 

3.15. Passive mitigation considered. Select all passive mitigation measures that were

considered in defining the release quantity or rate of the alternative release scenario. 

a. Dikes. A low wall that acts as a barrier to prevent a spill from spreading.

b. Enclosures. Physical containment of the release within a structure (e.g., a building).

c. Berms. A mound or wall of earth at the top or bottom of a slope that prevents a spill

from spreading.

d. Drains. A channel that carries off surface water.

e. Sumps. A pit or tank that catches liquid runoff for drainage or disposal.

f. Other (specify). List a type other than what is listed above.
Ch. 2 Pg. 25

3.16. Active mitigation considered. Active mitigation means equipment, devices, or

technologies that need human, mechanical, or other energy input to function. By regulation,

active mitigation can be considered in determining the alternative scenario, but not in

determining the worst case scenario. Select all that were considered in defining the release

quantity or rate of the alternative release scenario.

a. Sprinkler systems. A system for protecting a building against fire by means of

overhead pipes which convey an extinguishing fluid through heat activated outlets.

b. Deluge systems. A system to overflow an area of a release with water or other

extinguishing fluid.

c. Water curtain. A spray of water from a horizontal pipe through nozzles; the curtain

may be activated manually or automatically.

d. Neutralization. Making a toxic chemical harmless through chemical reaction.

e. Excess flow valve. A device in the outlet of a vessel at a hose connection that stops

the flow of liquid or gas if the piping or hoses downstream fail and a predetermined

excess flow rate is reached.

f. Flares. A device for disposing of combustible gases from a chemical process by

burning them in the open.

g. Scrubbers. A pre-release protection measure that uses water or aqueous mixtures

containing scrubbing reagents to remove discharging liquids and possibly also treating

the discharging chemical.

h. Emergency shutdown systems. Controls that are triggered when process limits are

exceeded and that shut down that process.

i. Other (specify)

3.17. Graphics file name (Optional). You may submit one graphic file to illustrate each release

scenario. Click to the button to the right of the Graphic File field (the button with three dots). 

Locate the graphic file, and press “Open.”

Graphics will be accepted in either GIF or JPEG file format. See 2.23 for an explanation of GIF

and JPEG.
Ch. 2 Pg. 26

Section 4 Flammables: Worst-Case

Complete this section for each flammable worst-case scenario you report.

4.1. Chemical. Enter the name of the regulated flammable chemical you evaluated in the worstcase scenario.

4.2. Model used (select one). Select the source of your results for your worst-case release

analysis or enter another model name in "Other."

a. EPA’s OCA Guidance Reference Tables or Equations

c. EPA’s RMP Guidance for Propane Storage Facilities Reference Tables or Equations

d. EPA’s RMP Guidance for Waste Water Treatment Plants Reference Tables or

Equations

e. EPA’s RMP Guidance for Warehouses Reference Tables or Equations

f. EPA’s RMP Guidance for Chemical Distributors Reference Tables or Equations

g. EPA’s RMP*CompTM

z. Other model (specify)

4.3. Scenario. This data element is fixed. By regulation, for flammables, the worst case

assumes an instantaneous release and a vapor cloud explosion, which is an explosion of a cloud

containing a flammable vapor or gas and air.

4.4. Quantity released (lbs). Enter the quantity of flammable substance you used for your

worst-case scenario analysis in pounds to 2 significant digits. This is the total amount that would

be lost from a vessel or pipeline used in the calculation of distance to 1 psi reported in 4.6. See

Chapter 2 on Determining Worst-Case Scenarios in the RMP Offsite Consequence Analysis

Guidance for more details. Here's how to report the quantity to 2 significant digits:

 5,333 pounds should be reported as... 5,300 pounds

107,899 pounds should be reported as... 110,000 pounds 

If you have less than 1 pound released, round up to 1 pound. You may want to clarify that in

your Executive Summary.

4.5. Endpoint used. This data element is fixed. Because the scenario is fixed by regulation as

vapor cloud explosions, the endpoint which applies to vapor cloud explosions is fixed at 1 psi

overpressure.

4.6. Distance to endpoint (miles). Indicate the distance to the endpoint in miles to 2 significant

digits, using the endpoint specified for the chemical in 40 CFR Part 68, Appendix A. Convert

your modeling results into miles by dividing the distance in feet by 5280 or yards by 1760. 

Refer to the following to determine 2 significant digits:

 .397 miles should be reported as... .40 miles

 9.345 miles should be reported as... 9.3 miles

 20.764 miles should be reported as... 21 miles
Ch. 2 Pg. 27

4.7. Residential population within distance to endpoint. Estimate the population within the

circle with a center at the point of the release and a radius determined by the distance to the

endpoint to two significant digits (e.g., 5,500 people rather than 5,483). Population estimates

include only residential populations.

4.8. Public receptors within distance to endpoint. Public receptors must be identified within

the circle with a center at the point of the release and a radius determined by the distance to the

endpoint. Public receptor means locations where members of the public may be exposed to toxic

concentrations, radiant heat, or overpressure as a result of the release. Public receptors include

locations within the facility's property boundary to which the public has routine and unrestricted

access during or outside business hours (e.g. a recreation field). Locations inhabited or occupied

by the public at any time without restriction by the source (such as fences or security guards) are

public receptors (see the General Guidance for Risk Management Programs for more

information on identifying public receptors). You do not need to list specific locations or

estimate populations at these locations. The presence of these receptors may be determined

using local street maps. Select all that apply.

a. Schools. Public and private elementary, secondary, or post-secondary educational

institutions (e.g., colleges).

b. Residences

c. Hospitals

d. Prisons or Correctional facilities

e. Recreation areas. Including stadiums, parks, and public pools.

f. Commercial, office, or industrial areas. Including industrial parks, office buildings,

shopping malls, commercial areas, and commercial farms. 

g. Other (Specify). Include any other additional information here. 

4.9. Environmental receptors within distance to endpoint. Environmental receptors must be

identified within the circle with a center at the point of the release and a radius determined by the

distance to the endpoint. Environmental receptor means natural areas, such as national or state

parks, forests, or monuments; officially designated wildlife sanctuaries, preserves, refuges, or

areas; and federal wilderness areas, that could be exposed at any time to toxic concentrations,

radiant heat, or overpressure as a result of the release. Environmental receptors can be identified

on local U.S. Geological Survey maps, which can be found at many libraries. Select all that

apply.

a. National or state parks, forests, or monuments

b. Officially designated wildlife sanctuaries, preserves, or refuges

c. Federal wilderness areas

d. Other (Specify). Include any other additional information here. 

4.10. Passive mitigation considered. Select all passive mitigation measures that were

considered in defining the release quantity or rate for the worst-case scenario.

a. Blast Walls. A heavy wall used to isolate buildings or areas that contain highly

combustible or explosive materials.

b. Other (specify)
Ch. 2 Pg. 28

4.11. Graphics file name (Optional). You may submit one graphic file to illustrate each

release scenario. Click to the button to the right of the Graphic File field (the button with three

dots). Locate the graphic file, and press “Open.”

Graphics will be accepted in either GIF or JPEG file format. See 2.16 of this manual for an

explanation of GIF and JPEG.
Ch. 2 Pg. 29

Section 5: Flammables: Alternative Releases

Complete this section for each flammable alternative release scenario you report.

5.1. Chemical. Enter the name of the regulated flammable chemical you evaluated in the

alternative release scenario.

5.2. Model used (select one). Select the source of your results for your alternative release

analysis or enter another model name in "Other."

a. EPA’s OCA Guidance Reference Tables or Equations

c. EPA’s RMP Guidance for Propane Storage Facilities Reference Tables or Equations

d. EPA’s RMP Guidance for Waste Water Treatment Plants Reference Tables or 

Equations

e. EPA’s RMP Guidance for Warehouses Reference Tables or Equations

f. EPA’s RMP Guidance for Chemical Distributors Reference Tables or Equations

g. EPA’s RMP*CompTM

z. Other model (specify)

5.3. Scenario. Select one of the following or enter another scenario in Other:

a. Vapor Cloud Explosion. An explosion of a cloud containing a flammable vapor or

gas and air.

b. Fireball. The atmospheric burning of a fuel-air cloud in which the energy is mostly

emitted in the form of radiant heat. As the buoyancy forces of the hot gases begin to

dominate, the burning cloud rises and becomes spherical in shape. Often caused by the

ignition of a vapor cloud of a flammable substance.

c. BLEVE. Boiling Liquid Expanding Vapor Explosion (BLEVE) is used to describe the

sudden rupture of a vessel/system containing liquefied flammable gas under pressure due

to radiant heat flux. The pressure burst and the flashing of the liquid to vapor creates a

blast wall and potential missile damage, and immediate ignition of the expanding fuel-air

mixture leads to an intense combustion creating a fireball.

d. Pool Fire. The combustion of material evaporating from a layer of liquid at the base

of the fire.

e. Jet Fire. Gas or liquid discharging or venting from a rupture will form a jet that

"blows" into the atmosphere in the direction the hole is facing, all the while entraining

and mixing with air. If the jet is flammable and encounters an ignition source, a flame jet

may form.

f. Vapor Cloud Fire. A flash fire results from the ignition of a released flammable cloud

in which there is essentially no increase in the combustion rate.

g. Other (specify)

5.4. Quantity released (lbs). Enter the quantity of the flammable substance you used for your

alternative scenario analysis in pounds to 2 significant digits. If you have less than 1 pound

released, round up to 1 pound. You may want to clarify that in your Executive Summary.
Ch. 2 Pg. 30

5.5. Endpoint used. For vapor cloud explosions, the endpoint is 1 psi overpressure; for a

fireball the endpoint is 5 kW/m2 for 40 seconds; for vapor cloud fires or jet fires, a lower

flammability limit (expressed as a percentage) may be listed as specified in NFPA documents or

other generally recognized sources. These are listed in the OCA Guidance.

5.6. Distance to endpoint (miles). Indicate the distance to the endpoint in miles to 2 significant

digits, using the endpoint specified for the chemical in 40 CFR Part 68, Appendix A. Convert

your modeling results into miles by dividing the distance in feet by 5280 or yards by 1760. 

Refer to the following to determine 2 significant digits:

 .397 miles should be reported as... .40 miles

 9.345 miles should be reported as... 9.3 miles

 20.764 miles should be reported as... 21 miles

5.7. Residential population within distance to endpoint. Estimate the population within the

circle with a center at the point of the release and a radius determined by the distance to the

endpoint to two significant digits (e.g., 5,500 people rather than 5,483). Population estimates

include only residential populations.

5.8. Public receptors within distance to endpoint. Public receptors must be identified within

the circle with a center at the point of the release and a radius determined by the distance to the

endpoint. Public receptor means locations where members of the public may be exposed to toxic

concentrations, radiant heat, or overpressure as a result of the release. Public receptors include

locations within the facility's property boundary to which the public has routine and unrestricted

access during or outside business hours (e.g. a recreation field). Locations inhabited or occupied

by the public at any time without restriction by the source (such as fences or security guards) are

public receptors (see the General Guidance for Risk Management Programs for more

information on identifying public receptors). You do not need to list specific locations or

estimate populations at these locations. The presence of these receptors may be determined

using local street maps. Select all that apply.

a. Schools. Public and private elementary, secondary, or post-secondary educational

institutions (e.g., colleges).

b. Residences

c. Hospitals

d. Prisons or Correctional facilities

e. Recreation areas. Including stadiums, parks, and public pools.

f. Commercial, office, or industrial areas. Including industrial parks, office buildings,

shopping malls, commercial areas, and commercial farms. 

g. Other (Specify). Include any other additional information here. 

5.9. Environmental receptors within distance to endpoint. Environmental receptors must be

identified within the circle with a center at the point of the release and a radius determined by the

distance to the endpoint. Environmental receptor means natural areas, such as national or state

parks, forests, or monuments; officially designated wildlife sanctuaries, preserves, refuges, or

areas; and federal wilderness areas, that could be exposed at any time to toxic concentrations,
Ch. 2 Pg. 31

radiant heat, or overpressure as a result of the release. Environmental receptors can be identified

on local U.S. Geological Survey maps, which can be found at many libraries. Select all that

apply.

a. National or state parks, forests, or monuments

b. Officially designated wildlife sanctuaries, preserves, or refuges

c. Federal wilderness areas

d. Other (Specify). Include any other additional information here. 

5.10. Passive mitigation considered. Select all passive mitigation measures that were

considered in defining the release quantity or rate for the alternative scenario.

a. Dikes. A low wall that acts as a barrier to prevent a spill from spreading.

b. Fire Walls. A wall constructed to prevent the spread of fire.

c. Blast Walls. A heavy wall used to isolate buildings or areas that contain highly

combustible or explosive materials.

d. Enclosures. Physical containment of the release within a structure (e.g., a building).

f. Other (specify)

5.11. Active mitigation considered. Active mitigation means equipment, devices, or

technologies that need human, mechanical, or other energy input to function. Select all that were

considered in defining the release quantity or rate of the alternative release scenario.

a. Sprinkler Systems. A system for protecting a building against fire by means of

overhead pipes which convey an extinguishing fluid through heat activated outlets.

b. Deluge Systems. A system to overflow an area of a release with water or other

extinguishing fluid.

c. Water Curtain. A spray of water from a horizontal pipe through nozzles, the curtain

may be activated manually or automatically.

d. Excess Flow Valve. A system for diverting overflow.

e. Other (specify)

5.12. Graphics file name (Optional). You may submit one graphic file to illustrate each

release scenario. Click to the button to the right of the Graphic File field (the button with three

dots). Locate the graphic file, and press “Open.”

Graphics will be accepted in either GIF or JPEG file format. See 2.16 of this manual for an

explanation of GIF and JPEG.
Ch. 2 Pg. 32

Section 6: Five-year accident history 

Although much of the RMP is a summary of the risk management program at your facility, this

portion of the RMP includes all of the five-year accident history information required under 40

CFR § 68.42. Therefore, for this section of the RMP you can simply insert the data you

compiled for § 68.42. Only report accidents involving listed substances.

A reportable accident involves a part 68 regulated substance in a covered process if the release

resulted in deaths, injuries, property damage onsite, or known offsite deaths, injuries, property

damage, or environmental damage, evacuations, or sheltering-in-place.

Did your facility have any reportable accidents in the last 5 years? If your facility did not

have any reportable accidents in the last five years, then check no to confirm and leave the rest

of this section blank. If your facility did have reportable accidents in the last five years, then fill

in this section for each accident.

6.1. Date of accident. Indicate the date on which the accident occurred.

6.2. Time accident began. Indicate the time the release began.

6.3. NAICS Code of process involved. Enter the NAICS code that most closely corresponds to

the process; it will not necessarily be the same NAICS code for your facility as a whole. As

described in Registration, the NAICS code system classifies businesses by fitting them into

descriptive categories that correspond to five-digit or six-digit codes. Appendix B of the

General Guidance for Risk Management Programs provides the NAICS codes for the industry

sectors most likely to subject to 40 CFR Part 68. You may also access the full list on-line at

http://www.census.gov/epcd/www/naics.html.

Although you are only required to report accidents on covered processes, you may choose to

report other accidents as well. Therefore, RMP*Submit provides the full list of NAICS codes to

choose from.

6.4. Release duration. Indicate the approximate length of time of the release in hours and

minutes. (Format: HHHMM)

6.5.a.i. Chemical name. Indicate the regulated substance(s) released. Use the name of the

substance as listed in Section 68.130 rather than a synonym. If the release was a NFPA-4

flammable mixture containing regulated flammables, you may list it as a “flammable mixture”

and list all of the regulated substances contained in the mixture. For the quantity released, you

only report the quantity of the entire mixture, not the individual substances. Only report

chemicals that are listed substances. 

6.5.a.ii. CAS number. Provide the Chemical Abstracts Service (CAS) registry number for each

chemical name in 6.5.a.i. above. CAS numbers are listed in 40 CFR § 68.130 and in EPA’s
Ch. 2 Pg. 33

General Guidance for Risk Management Programs . RMP*Submit will automatically generate

the CAS # based on the chemical name chosen. For flammable mixtures, because there is no

CAS #, leave this field blank. RMP*Submit will assign a "dummy" CAS number of all zeros for

flammable mixtures.

6.5.b. Quantity released. Estimate the amount of each substance released in pounds. The

amount should be estimated to two significant digits, or as close to that as possible. For

example, if you estimate that the release was between 850 and 900 pounds, provide a best guess. 

We realize that you may not know precise quantities.

For toxics in a mixture, determine the maximum quantity of the mixture and then multiply the

weight of the regulated toxic substance to determine the quantity; do not report the weight of

the entire mixture. For example, if you have a 100,000 pound mixture of ammonia at 20%

concentration, then you would multiply the weight percent (20%) by the total quantity (100,000

pounds) to determine the quantity released of ammonia was 20,000 pounds. 

For flammables in a mixture that meets the criteria of NFPA-4, report the entire quantity of the

mixture, rather than that of the individual regulated substances.

6.5.c. Percent weight of toxic chemical in mixture. If a toxic substance was in a mixture when

released, indicate the percentage weight of the regulated substance in the mixture.

6.6. Release event. Indicate which of the following release events best describes your accident. 

Select at least one: 

a. Gas Release. A gas release is a release of the substance as a gas (rather than

vaporized from a liquid). If you hold a gas liquefied under refrigeration, report the

release as a liquid spill.

b. Liquid Spill/Evaporation. A liquid spill/ evaporation is a release of the substance in

a liquid state with subsequent vaporization.

c. Fire. A fire is a combustion producing light, flames, and heat.

d. Explosion. An explosion is a rapid chemical reaction with the production of noise,

heat, and violent expansion of gases.

e. Uncontrolled /runaway reaction. A release event caused by an uncontrolled

chemical reaction that generates excessive heat, pressure, or harmful reaction products. 

Such events may involve highly exothermic chemical reactions, self-reactive substances

(e.g., substances that undergo polymerization), unstable, explosive, or spontaneously

combustible substances, substances that react strongly with water or other contaminants,

oxidizers, peroxide-forming substances, or other types of chemical reactions that generate

harmful products or byproducts. This category of release event may often occur in

conjunction with one of the previous categories. In such cases, be sure to check this

category in addition to any other applicable release event category (e.g., explosion). The

burning of ordinary flammable substances is not typically included in this category.

6.7. Release source. Indicate all that apply.
Ch. 2 Pg. 34

a. Storage Vessel. A storage vessel is a container used only to store or hold (as opposed

to react, mix, or move) a regulated substance. Storage vessels include transportation

containers (e.g., railcars or tank trucks) being used for on-site storage.

b. Piping. Piping refers to a system of pipes used to carry a fluid (gas, liquid or solid

solution, etc.).

c. Process Vessel. A process vessel is a container in which regulated substances under

certain conditions (eg. Temperature, pressure) participate in a process (substances are

manufactured, blended to forma mixture, reacted to convert them into some other final

product or form, or heated to purify).

d. Transfer Hose. A transfer hose is a flexible tube used to connect, often temporarily,

two or more vessels.

e. Valve. A valve is a device used to regulate the flow in piping systems or machinery. 

Relief valves open to release pressure in vessels.

f. Pump. A pump is a device that raises, transfers, or compresses fluids or that attenuates

gases by suction or pressure or both.

g. Joint. The surface at which two or more mechanical components are united.

h. Other. Specify other source of the release.

6.8. Weather conditions at time of event (if known). This information is important to those

concerned with modeling the effects of accidents. Reliable information from those involved in

the incident or from an on-site weather station is ideal. However, the rule does not require your

facility to have an on-site weather station. If you do not have an on-site weather station, use

information from your local weather station, airport, or other source of meteorological data. 

Historical wind speed and temperature data (but not stability data) can be obtained from the

National Climatic Data Center (NCDC) at (828) 271-4800; NCDC staff can also provide

information on the nearest weather station. To the extent possible, complete the following:

a.i. Wind speed. Wind speed is an estimate of how fast the wind is traveling. 

a.ii. Wind speed units. Indicate the units in which the speed is expressed as either miles

per hour, meters per second, or knots. 

a.iii. Wind direction. Wind direction is the direction from which the wind comes. For

example, a wind that blows from east to west would be described as having an eastern

wind direction. Describe wind direction as one of the 16 standard compass readings [N,

S, E, W, NE, SE, NW, SW, NNE, ENE, ESE, SSE, SSW, WSW, WNW, NNW], using

the abbreviation. For example, wind direction must be reported as S for South, NE for

Northeast, or SSW for South-Southwest.

b. Temperature. The ambient temperature at the scene of the accident in degrees

Fahrenheit. If you did not keep a record, you can use the high (for daytime releases) or

low (nighttime releases) for the day. Local newspapers publish these data.

c. Atmospheric Stability Class. Depending on the amount of incoming solar radiation
Ch. 2 Pg. 35

as well as other factors, the atmosphere may be more or less turbulent at any given time. 

Meteorologists have defined six atmospheric stability classes, each representing a

different degree of turbulence in the atmosphere. When moderate to strong incoming

solar radiation heats air near the ground, causing it to rise and generating large eddies, the

atmosphere is considered unstable, or relatively turbulent. Unstable conditions are

associated with stability classes A and B. When solar radiation is relatively weak, air

near the surface has less of a tendency to rise and less turbulence develops. In this case,

the atmosphere is considered stable or less turbulent with weak winds; the stability class

is E or F. Stability classes D and C represent conditions of more neutral stability, or

moderate turbulence. Neutral conditions are associated with relatively strong wind

speeds and moderate solar radiation. Enter either A, B, C, D, E, or F.

Exhibit 7. Atmospheric Stability Classes

SURFACE WIND SPEED 

AT 10 METERS 

ABOVE GROUND

DAY NIGHT*

Meters per

second

Miles per

hour

Incoming Solar Radiation Thinly

Overcast

or $ 4/8

low cloud

# 3/8

Cloud

Strong** Moderate Slight***

< 2 <4.5 A A-B B

2-3 4.5-7 A-B B C E F

3-5 7-11 B B-C C D E

5-6 11-13 C C-D D D D

>6 >13 C D D D D

*Night refers to one hour before sunset to one hour after dawn.

** Sun high in the sky with no clouds.

*** Sun low in the sky with no clouds.

d. Precipitation present. Precipitation may take the form of hail, mist, rain, sleet, or

snow. Check the box to indicate there was precipitation at the time of the accident.

e. Unknown weather conditions. If you have no record for any of the weather data,

indicate “unknown.” We realize that you may not have weather data for accidents that

have occurred prior to June 1996. You must, however, collect these data during future

accident investigations.

6.9. On-site impacts. Complete each of the following about on-site effects. Enter a number for

each entry; if there were no impacts, enter 0.
Ch. 2 Pg. 36

a. Deaths. Indicate the number of on-site deaths that are attributable to the accident or

mitigation activities. On-site deaths include anyone (employees, contractors, responders,

or others) who was killed by direct exposure to toxic concentrations, radiant heat, or

overpressures from the accidental release or from indirect consequences of a vapor cloud

explosion from an accidental release (e.g., flying glass debris or other projectiles). If

there were no on-site deaths, enter 0. Specify the deaths as:

a.i. Employees & contract employees

a.ii. Public responders (example, fire department personnel)

a.iii. Public (example, visitors)

b. Injuries. An injury is any effect that results either from direct exposure to toxic

concentrations, radiant heat, or overpressures from the accidental release or from indirect

consequences of a vapor cloud explosion from an accidental release (e.g., a window

shattering after an explosion) and that requires medical treatment or hospitalization. 

Medical treatment means treatment, other than first aid, administered by a physician or

registered professional personnel under standing orders from a physician (OSHA OII

Log, 1904.12). Your OSHA occupational injury and illness log will help complete these

items for employees. If there were no on-site injuries, enter 0. Specify the injuries as:

a.i. Employees & contract employees

a.ii. Public responders (example, fire department personnel)

a.iii. Public (example, visitors)

c. Property damage. Estimate the value of the equipment or business structures at your

facility that were damaged by the accident or mitigation activities. Record the value in

American dollars. Insurance claims may provide this information. Do not include any

losses that you may have incurred as a result of business interruption. If there was no onsite property damage or no known damage, enter 0.

6.10. Known off-site impacts. These are impacts that you should be aware of (e.g., from media

reports) or that were reported to your facility. You are not required to conduct an additional

investigation to determine off-site impacts. Enter a number for each entry; if there were no

impacts, enter 0.

a. Deaths. Indicate the number of off-site deaths that are attributable to the accident or

mitigation activities. Off-site deaths include anyone who was killed by direct exposure to

toxic concentrations, radiant heat, or overpressures from the accidental release or from

indirect consequences of a vapor cloud explosion from an accidental release (e.g., a

window shattering after an explosion). Responders killed while on site responding to the

release are considered on-site deaths and should not be reported here (See 6.9, On-Site

Impacts). If there were no known off-site deaths, enter 0.

b. Hospitalizations. Indicate the number of people requiring hospitalization. 

Hospitalization means any effect that results either from direct exposure to toxic

concentrations, radiant heat, or overpressures from accidental releases or from indirect
Ch. 2 Pg. 37

consequences of a vapor cloud explosion from an accidental release (e.g., a window

shattering after an explosion) and that requires hospitalization (i.e., admittance to the

hospital). If there were no known off-site hospitalizations, enter 0.

c. Other medical treatment. Indicate the number of people requiring medical treatment. 

Medical treatment means any effect that results either from direct exposure to toxic

concentrations, radiant heat, or overpressures from accidental releases or from indirect

consequences of a vapor cloud explosion from an accidental release (e.g., a window

shattering after an explosion) and that requires medical treatment. If there was no known

medical treatment, enter 0.

d. Evacuated. Estimate the number of people who were evacuated to prevent exposure

that might have resulted from the accident. A total count of the number of people

evacuated is preferable to the number of houses evacuated. People who were ordered to

move simply to improve access to the site for emergency vehicles are not considered to

have been evacuated, but people who normally-occupy a building or area and who are

prevented from entering or returning (i.e., blockaded) in order to prevent potentially

harmful exposure should be considered to have been evacuated. If there were no

evacuations, enter 0.

e. Sheltered-in-place. Estimate the number of people who were sheltered-in-place

during the accident. Sheltering-in-place occurs when the incident commander orders

residents to remain inside their home or place of work until the emergency has ended to

prevent exposure to the substance. Usually these are associated with an emergency

broadcast or similar method of mass notification by response agencies. If no one

sheltered in place, enter 0.

f. Property damage. Estimate the value of the equipment or structures offsite that were

damaged by the accident or mitigation activities. Record the value in American dollars. 

Insurance claims may provide this information. Any level of offsite property damage

triggers reporting. There is no lower limit below which you would not have to report. If

there was no property damage, enter 0.

g. Environmental damage. Indicate whether any environmental damage occurred and

specify the type. The damage is not limited to environmental receptors listed in the rule. 

Any damage to the environment (e.g., dead or injured animals, defoliation, water

contamination) must be reported. Select all that apply.

g.1. Fish or animal kills.

g.2. Tree, lawn, shrub, or crop damage

g.4. Water contamination

g.4. Soil contamination

g.5. Other (specify)

6.11. Initiating event. Select the one initiating event that best describes the immediate cause of
Ch. 2 Pg. 38

the accident.

a. Equipment Failure. A device or piece of equipment failed or did not function as

designed. For example, the vessel wall corroded or cracked. 

b. Human Error. An operator performed a task improperly, either by failing to take the

necessary steps or by taking the wrong steps.

c. Natural (weather conditions, earthquake). Weather conditions, such as lightning,

hail, ice storms, tornados, hurricanes, earthquakes, floods, or high winds, caused the

accident.

d. Unknown.

6.12. Contributing factors. These are factors that contributed to the accident occurring, but

were not the initiating event. If you conducted an investigation of the release, you should have

identified factors that led to the initiating event. Select all that apply.

a. Equipment failure. A device or piece of equipment failed to contain substance or did

not function as designed, thereby allowing a substance to be released.

b. Human error. A person performed an operation improperly or made a mistake which

resulted in an accident.

c. Improper procedures. The procedure did not reflect the proper method of operation,

the procedure omitted steps that affected the accident, or the procedure was written in a

manner that allowed for misinterpretation of the instructions.

d. Overpressurization. The process was operated at pressures exceeding the design

working pressure.

e. Upset condition. Release was caused by incorrect process conditions (e.g., increased

temperature or pressure).

f. By-pass condition. The failure occurred in a pipe, channel, or valve that diverts fluid

flow from the main pathway when design process or storage conditions are exceeded

(e.g., overpressure). By-pass conditions may be designed to release the substance to

restore acceptable process or storage conditions and prevent more severe consequences

(e.g., explosion).

g. Maintenance activity or inactivity. The failure occurred because of maintenance

activity or inactivity. An example of maintenance activity is putting the wrong gasket on

a tank fitting. An example of maintenance inactivity is storage racks that remained

unpainted for so long that corrosion caused the metal to fail.

h. Process design failure. The failure resulted from an inherent flaw in the design of the

process (e.g., pressure needed to make product exceeds the design pressure of the vessel).
Ch. 2 Pg. 39

i. Unsuitable equipment. The equipment used was incorrect for the process. For

example, the forklift was too large for the corridors.

j. Unusual weather conditions. Weather conditions, such as lightning, hail, ice storms,

tornados, hurricanes, earthquakes, floods, or high winds caused the accident.

k. Management error. The failure occurred due to any management error or

management system error not included in categories a through j above. Such factors may

include inadequate training, inadequate oversight, inadequate hazard analysis, or other

management-related factors.

l. Other (specify)

6.13. Off-site responders notified (select one). Indicate whether response agencies (e.g.,

police, fire, medical services) were notified. Check one of the following choices:

a. Notified Only

b. Notified and Responded

c. No, not notified

d. Unknown. 

6.14. Changes introduced as a result of the accident. Indicate any measures that you have

taken at the facility to prevent recurrence of the accident. Select at least one.

a. Improved/upgraded equipment. A device or piece of equipment that did not

function as designed was repaired or replaced.

b. Revised maintenance. Maintenance procedures were clarified or changed to ensure

appropriate and timely maintenance including inspection and testing (i.e., increasing the

frequency of inspection or adding a testing method).

c. Revised training. Training programs were clarified or changed to ensure that

employees and contract employees are aware of and are practicing correct safety and

administrative procedures.

d. Revised operating procedures. Operating procedures were clarified or changed to

ensure that employees and contract employees are trained on appropriate operating

procedures.

e. New process controls. New process designs and controls were installed to correct

problems and prevent recurrence of an accidental release.

f. New mitigation systems. New mitigation systems were initiated to limit the severity

of accidental releases.

g. Revised emergency response plan. The emergency response plan was revised.

h. Changed process. Process was altered to reduce the risk (e.g., process chemistry was

changed).

i. Reduced inventory. Inventory was reduced at the facility to reduce the potential

release quantities and the magnitude of the hazard.

j. None. No changes initiated at facility as a result of the accident (i.e., none were

necessary or technically feasible). There may be some accidents that could not have been
Ch. 2 Pg. 40

prevented because they were caused by events that are too rare to merit additional steps. 

For example, if a tornado hit your facility and you are located in an area where tornados

are very rare, it may not be reasonable to design a “tornado-proof” process even if it is

technically feasible.

k. Other (specify).
Ch. 2 Pg. 41

Overview of Prevention Program (Sections 7-8)

How Must Prevention Program Data Be Reported?

Prevention program data must be reported on a process-by-process basis. In other words, you

must fill out the prevention program section of the RMP for each Program 2 or Program 3

process you have that is subject to the RMP rule.

How to report the prevention program for a process depends on how many units the process

contains and whether the prevention program applies different safeguards to different units in the

process. The RMP rule broadly defines "process" to include interconnected or co-located

production and storage units. Under the definition, multiple units and, in some cases, whole

sources may be a single "process" for purposes of the RMP rule. For multiple unit processes,

EPA recognizes that prevention program implementation may involve different safeguards for

different units in the process. For example, different production units may have different

operating procedures. At the same time, some safeguards, such as management of change

procedures, may apply to all the units in the process. To accommodate these circumstances,

RMP*Submit includes two features which make it easier to indicate how a prevention program

applies to a multiple-unit process. 

If your process consists of two or more units and different safeguards apply to different units in

that process, you can report the prevention program for that process in one of the two following

ways. You must, however, use one of the two ways to report your program.

- Use the description field in the prevention program to describe in narrative form how

your prevention program is implemented with respect to the different units in the process. 

You could start by listing the common prevention program elements you implement for

all of the units (e.g., use of an alarm system or standard management of change

procedures). You would then indicate what additional prevention program elements you

employ for specified units (e.g., use of a dike for certain process units). 

- Report your prevention program for the process on a unit-by-unit basis by filling out the

prevention program portion of the RMP for every unit in the process, rather than for the

process as a whole. That way, the differences in the program as it relates to each unit

will be clear from the report. However, as noted above, some aspects of a prevention

program may be common to all units. To simplify the reporting of common elements, 

RMP*Submit has an autocopy feature that allows you to enter data elements only once. 

This feature works by entering the common elements into RMP*Submit and then hitting

the COPY function at the bottom of the screen to copy that information to another

prevention program "record." (If you are submitting on paper, you can achieve the same

effect by filling in the common data elements first and then copying the pages containing

the common data elements.) To complete the prevention program record for each unit,

enter the remaining data which is unique to each.
Ch. 2 Pg. 42

If your process consists of only one unit, or you apply every element of your prevention program

to all the units in the process, you are not required to complete the description section of this

portion of the RMP or report on a unit-by-unit basis. However, you may use the description

field to elaborate on your prevention program.

Many prevention program data elements ask you to enter the date for the most recent "review or

revision" of a prevention program element required by part 68. For your first RMP submission,

if you are subject to prevention program requirements only under the RMP rule (as opposed to

other federal or state laws), you should enter the date by which you completed the prevention

program element being addressed. For instance, for data element number 7.5, "Date of most

recent review or revision of operating procedures," you should enter the date by which you met

the operating procedures requirements of section 68.69(a) of the RMP rule (if applicable to you). 

 Since this requirement must be met by the time your first RMP is due, you may enter the date

you complete or submit your first RMP. In the case of data element number 7.3 ("Date on

which safety information was last reviewed or revised"), you should enter the date you met the

requirement of section 68.65(a) (if applicable to you), since section 68.65(a) requires you to

meet the requirement before you conduct the process hazard analysis for the process. 

If you are subject to prevention program requirements under other federal or state laws, you may

be in compliance with RMP prevention program requirements as a result of complying with the

other laws. Sources subject to OSHA PSM, for example, may already meet RMP prevention

program requirements for Program 3 processes, since those requirements are nearly identical to

OSHA PSM prevention program requirements. For your first RMP submission, if you have

fulfilled RMP prevention program requirements in complying with other federal or state laws,

you should enter the date you complied with the requirement or the date you last reviewed or

revised the relevant aspect of your program, whichever is later. For example, OSHA PSM and

the RMP rule both require covered sources to compile and update (under specified

circumstances) process safety information. If you previously compiled the information for

purposes of complying with OSHA PSM and you have not updated it since, you should enter the

date you compiled it for OSHA in your RMP. If you have updated the information since

compiling it, you should enter the date of the update.

For subsequent RMP submissions, you should enter the date by which you completed any review

or revision of a prevention program element. Several prevention program elements must be

reviewed and, if necessary, revised following a change affecting the process (see, e.g.,

requirement to update safety information in section 68.75(d)). Under the compliance audit

requirement of sections 68.58 or 68.79 of the RMP Program, all prevention program elements

must be reviewed and, if appropriate, revised every three years. When you re-submit your next

RMP (due every 5 years or sooner based on the requirements in section 68.190), you are required

to fully update and certify all nine sections of the RMP. If, by the time you re-submit, you have

reviewed or revised one or more prevention program elements as a result of a change or an audit,

you must enter the date of your review or revision.
Ch. 2 Pg. 43

Section 7: Prevention Program for Program 3 Processes

Complete this section for each prevention program you report for a Program 3 process.

Prevention program description. If different safeguards apply to different units in your

process, use this field to explain how the prevention program for the process relates to the

different units in the process. For example, "This process includes three interconnected

production units, A, B, and C. Everything in this prevention program applies to all three units,

with the following exceptions:

- The dates of the PHA, which are 01/02/97, 6/5/96 and 4/3/96 for units A, B and C, respectively.

- Production unit A uses only a scrubber as a process control, while units B and C have relief

valves and scrubbers.

- The water curtain indicated as a mitigation measure applies only to production unit C."

If you have so many "exceptions" that it gets too complicated to explain as above, but you still

have many common data elements, you can report your prevention program on a unit-by-unit

basis. To simplify such reporting, you can use the autocopy feature in RMP*Submit so that you

only have to enter the common data elements once. First, enter the common elements into

RMP*Submit (or the paper form, if you are submitting in paper), then hit the COPY function at

the bottom of the screen to copy that information to another prevention program "record" (if you

are submitting in paper, photocopy the pages). To complete the prevention program record for

each unit, enter the remaining data which is unique to each.

7.1. NAICS code for the process. Enter the NAICS code that most closely corresponds to the

process; it will not necessarily be the same NAICS code for your facility as a whole. The

NAICS code that you choose must be one that you've already entered in the Registration Section

for the covered process. If you have two processes with the same NAICS code, explain in the

above description field which of the two processes this prevention program relates to. 

RMP*Submit will produce a list of the NAICS codes that you have already entered for your

registered processes as a pick list for this data element. As described in the Registration section

of this manual, the NAICS code system classifies businesses by type using descriptive categories

that correspond to five-digit or six-digit codes. 

7.2. Chemical name(s). For each prevention program, provide the names of all regulated

substances held above the threshold in the covered units. If you have an NFPA-4 flammable

mixture containing regulated flammables, you may list it as a flammable mixture. You do not

need to list the individual substances in the flammable mixture.

7.3. Date on which the safety information was last reviewed or revised. The safety

information requirements for Program 3 processes can be found at 40 CFR §68.65. For your

first RMP submission, enter the date you complied with the requirement of §68.65(a) (compile

safety information) for the process or the date you last reviewed or revised the safety

information, whichever is later. (As explained in the introduction to Section 7, the date you

enter may depend on whether you are subject to the same or similar requirement under other
Ch. 2 Pg. 44

federal or state laws.) For subsequent RMPs, enter the date the safety information was most

recently reviewed or revised. Safety information may be reviewed or revised as a result of,

among other things, a change to the process (see §68.75(d)) or a periodic audit of the prevention

program (see §68.79(a)). If the safety information was not reviewed or revised since the

previous RMP was submitted, reenter the date provided in the previous RMP.

7.4. Process Hazard Analysis (PHA). The PHA requirements for Program 3 processes can be

found at 40 CFR §68.67. Provide the following information about the PHA you conducted for

the process. 

a. Date of last PHA or PHA update. The date you completed or updated your most

recent PHA. 

b. Technique used. Check any of the following techniques that you used to evaluate the

hazards of your process or part of the process (see Chapter 7, Appendix 7-A, of the 

General Guidance for Risk Management Programs for a description of these techniques). 

Select at least one:

b.1. What If

b.2. Checklist

b.3. What If/Checklist (combined)

b.4. HAZOP

b.5. Failure Mode & Effects Analysis

b.6. Fault Tree Analysis

b.7. Other (specify)

7.4.c. Expected or actual date of completion of all changes resulting from last PHA

or PHA update. Enter the date you completed or expect to complete any changes

resulting from the PHA. This may be blank if there were no changes.

7.4.d. Major hazards identified (select at least one). Any major hazards that were

identified for the process or part of the process as a result of the PHA. Major hazards are

described below.

7.4.d. Major Hazard Description

1. Toxic Release If an accidental release occurred, a regulated toxic substance

could be released. For listed toxics, a toxic release will always be

a major hazard. 

2. Fire Process upsets, leaks, equipment failure, etc., could result in a fire. 

For listed flammables, fire will always be a major hazard. Fire

may also be a hazard for some listed toxics, and in some processes

could cause a toxic release.
7.4.d. Major Hazard Description

Ch. 2 Pg. 45

3. Explosion Confined or unconfined vapor cloud explosions. For listed

flammables, explosion will generally be a major hazard. 

Explosion may also be a hazard for toxics, especially those

handled under extreme conditions.

4. Runaway reaction An uncontrolled reaction that proceeds at an increasing rate.

5. Polymerization A chemical reaction that produces the bonding of two or more

monomers.

6. Overpressurization Instantaneous energy release or detonation.

7. Corrosion Corrosion could lead to destruction of equipment and release of a

regulated substance. Corrosion is likely to be a major hazard for

substances identified as corrosives on MSDSs unless the

equipment used limits the hazard.

8. Overfilling Filling a tank or vessel beyond its maximum safe capacity.

9. Contamination A release could occur if inappropriate substances are introduced

into storage or process vessels. Contamination may be a major

hazard when controlling inappropriate substances (e.g., H 2O) is

difficult.

10. Equipment failure Equipment failure is likely to be a major hazard for most

processes, because such failure could lead to a release. Equipment

failure includes cracks, weld failures, disk failures, ruptures,

pump/gauge/control system failures, etc.

11. Loss of cooling,

heating, electricity,

instrument air

These losses could be major hazards if they could lead to a

release. For example, loss of cooling could lead to an increase in

pressure and failure of a vessel or pipe, and a loss of heating or

power could lead to unstable processes. These conditions are less

likely to be major hazards for substances handled at atmospheric

temperatures and pressures.

12. Earthquake Report earthquakes as a major hazard only if there is a great

enough risk of their occurring at your site that you plan and design

for them. 

13. Floods (Flood Plain) Report floods as a major hazard only if there is a great enough risk

of their occurring at your site that you plan and design for them. 

14. Tornadoes Report tornadoes as a major hazard only if there is a great enough

risk of their occurring at your site that you plan and design for

them.
7.4.d. Major Hazard Description

Ch. 2 Pg. 46

15. Hurricanes Report hurricanes as a major hazard only if there is a great enough

risk of their occurring at your site that you plan and design for

them.

16. Other Specify any other major hazards not listed above.

7.4.e. Process controls in use (select at least one). All of the process controls used on

the process or part of the process. Process controls are equipment and associated

procedures used to prevent or limit releases and are described below. If none are

applicable, check "none."

7.4.e. Process Controls Description

1. Vents An opening provided for the discharge of pressure or release

of pressure from tanks, vessels, or processing equipment.

2. Relief valves A valve that relieves pressure beyond a specified limit and

recloses upon return to normal operating pressure.

3. Check valves A device for automatically limiting the flow in a piping system

to a single direction.

4. Scrubbers A pre-release protection measure that uses water or aqueous

mixtures containing scrubbing reagents to remove discharging

liquids and may treat the discharging chemical.

5. Flares A pre-release protection measure used to burn waste gases and

vapors and discharge their combustion products into the

atmosphere.

6. Manual shutoffs Manual controls of the shutoff flow to a pipe or vessel.

7. Automatic shutoffs Controls the shutoff flow to a pipe or vessel and are triggered

automatically when process conditions are exceeded.

8. Interlocks A switch or other device that prevents activation of a piece of

equipment when a protective door is open or some other

hazard exists.

9. Alarms and procedures Systems that trigger a warning device after the occurrence of a

hazardous condition and procedures to activate an alarm

system.

10. Keyed bypass A bypass system that is activated by a control signal.
7.4.e. Process Controls Description

Ch. 2 Pg. 47

11. Emergency air supply A backup system to provide air to a process when the regular

air supply fails.

12. Emergency power Backup power systems.

13. Backup pump A secondary pump intended to serve the same function as the

primary pump if the primary pump fails.

14. Grounding equipment

and bonding

Devices that ground and bond electrical equipment to avoid

explosions and to provide a good electrical path to the ground.

15. Inhibitor addition A substance that is added to a reaction that is capable of

stopping or retarding a chemical reaction.

16. Rupture disks A device that relieves pressure beyond a specified limit.

17. Excess flow device Flow-limiting equipment that protects downstream equipment

from surges.

18. Quench system A system that cools by removing excess heat or immersing

liquid into a cooling medium.

19. Purge system A system that replaces the atmosphere in a container with an

inert substance to prevent the formations of an explosive

mixture.

20. None None are applicable.

21. Other Specify any other process controls that you may use on your

process and that are not specified above.
Ch. 2 Pg. 48

7.4.f. Mitigation systems in use (select at least one). All of the mitigation systems you

have in place to control a release from the process or part of the process. Mitigation

systems are described below. If none are applicable, check "none."

7.4.f. Mitigation Systems Description

1. Sprinkler systems A system for protecting a building against a fire by means of

overhead pipes that release an extinguishing material through

heat activated outlets.

2. Dikes A low wall that acts as a barrier to prevent a spill from

spreading.

3. Fire walls A wall constructed to prevent the spread of fire.

4. Blast walls A heavy wall used to isolate buildings or areas that contain

highly combustible or explosive materials.

5. Deluge system A system to overflow an area with a release of water or other

extinguishing fluid.

6. Water curtain A spray of water from a horizontal pipe through nozzles. The

curtain may be activated manually or automatically.

7. Enclosure Something that facilitates the physical containment of a

release within a structure (e.g., a building).

8. Neutralization Controlling a release by neutralizing the released chemical.

9. None None are applicable.

10. Other Specify any other mitigation systems you may have in place

on your process and that are not listed above.

7.4.g. Monitoring/detection systems in use (select at least one). All of the monitoring

and detection systems you have installed to detect a release of a regulated substance from

the process or part of the process. Monitoring and detection systems are described

below. If none are applicable, check "none."

7.4.g. Monitoring &

Detection Systems

Description

1. Process area detectors Detection systems located on or close to process equipment. 

Detection systems include indicator tubes, and

chromatographic, spectrometric, electrochemical, and

colorimetric gas analysis.
Ch. 2 Pg. 49

2. Perimeter monitors Integrated detection networks at the source boundary. 

Detection systems can include fluorescent SO2 analyzers,

photoelectric tape sensors, or electrolytic chlorine detectors.

3. None None are applicable.

4. Other Specify any other monitoring and detection systems you have

in place and that are not listed above.

7.4.h. Changes since last PHA or PHA update (select at least one). All of the changes

made to the process or part of the process since the last PHA. If none are applicable,

check "none."

7.4.h. Changes Since Last

PHA or PHA Update

 Description

1. Reduction in chemical

inventory

A decrease in the quantity of regulated substances stored onsite.

2. Increase in chemical

inventory

An increase in the quantity of regulated substances stored onsite.

3. Change in process

parameters

Examples of changes in process parameters include an

increase or decrease in temperature, pressure, flow rates, etc.

4. Installation of process

controls

The addition of controls such as those described in 7.4.e.

5. Installation of process

detection systems

The addition of systems such as those described in 7.4.g.

6. Installation of perimeter

monitoring systems

The addition of systems such as those described in 7.4.g.

7. Installation of mitigation

systems

The addition of systems such as those described in 7.4.f.

8. None recommended Select “none” if the PHA team did not recommend any

changes to the process.

9. None None are applicable.

10. Other Specify any other changes made to the process since the last

PHA that are not listed above.
Ch. 2 Pg. 50

7.5. Date of most recent review or revision of operating procedures. The operating

procedures requirements for Program 3 processes can be found at 40 CFR §68.69. For your first

RMP submission, enter the date you complied with the requirement of §68.69(a) (develop and

implement written procedures) for the process or the date you last reviewed or revised the

operating procedures, whichever is later. (As explained in the introduction to Section 7, the date

you enter may depend on whether you are subject to the same or similar requirement under other

federal or state laws.) For subsequent RMPs, enter the date of the most recent review or revision

of the operating procedures. Operating procedures may be reviewed or revised as a result of,

among other things, a change to the process (see §§68.69(c) and 68.75(e)), annual certification of

the operating procedures (see 68.69(c)), or a periodic audit of the prevention program (see

§68.79(a)).

7.6. Training. The training requirements for Program 3 processes can be found at 40 CFR

§68.71. 

7.6.a. Date of most recent review or revision of training programs. For your first

RMP submission, enter the date you ensured that the training you provide the employees

operating the process meets the requirements of §68.71(a), or the date you last reviewed

or revised your training programs, whichever is later. (As explained in the introduction

to Section 7, the date you enter may depend on whether you are subject to the same or

similar requirement under other federal or state laws.) For subsequent RMPs, enter the

date of the most recent review or revision of the training you provide. Training programs

may be reviewed or revised as a result of, among other things, a change to the process

(see § 68.75(c)) or a periodic audit of the prevention program (see §68.79(a)). If the

training was not reviewed or revised since the previous RMP was submitted, reenter the

date provided in the previous RMP.

7.6.b. Type of training provided (select at least one).

1. Classroom

2. On the job

3. Other (specify)

7.6.c. Type of competency testing used (select at least one). Identify how employees

were tested to determine and evaluate comprehension of the training materials.

1. Written test

2. Oral test

3. Demonstration

4. Observation

5. Other (specify)

7.7. Maintenance. The maintenance requirements for Program 3 processes can be found at 40

CFR §68.73. Enter the following:

7.7.a. The date that you most recently reviewed or revised the maintenance

procedures. For your first RMP submission, enter the date you complied with the
Ch. 2 Pg. 51

requirements of §68.73(b) (establish and implement written maintenance procedures) for

the process, or the date you last reviewed or revised the maintenance procedures,

whichever is later. (As explained in the introduction to Section 7, the date you enter may

depend on whether you are subject to the same or similar requirement under other federal

or state laws.) For subsequent RMPs, enter the date of the most recent review or

revision of the maintenance procedures. Maintenance procedures may be reviewed or

revised as a result of, among other things, a change to the process (see § 68.75(c)) or a

periodic audit of the prevention program (see §68.79(a)). If the procedures were not

reviewed or revised since the previous RMP was submitted, reenter the date provided in

the previous RMP.

7.7.b. The date of the most recent equipment inspection or test

7.7.c. The equipment that was inspected or tested (list equipment). 

7.8. Management of change. The management of change requirements for Program 3 processes

can be found at 40 CFR §68.75. Enter the following:

7.8.a. The date of the most recent change (if any) that triggered the management of

change procedure.

7.8.b. The date that you most recently reviewed or revised the management of

change procedures at your site. For your first RMP submission, enter the date you

complied with the requirements of 68.75(a) (establish and implement written procedures)

for the process, or the date you last reviewed or revised the management of change

procedures, whichever is later. (As explained in the introduction to Section 7, the date

you enter may depend on whether you are subject to the same or similar requirement

under other federal or state laws.) For subsequent RMPs, enter the date of the most

recent review or revision of the procedures. Management of change procedures may be

reviewed or revised as a result of, among other things, a periodic audit of the prevention

program (see §68.79(a)). If the procedures were not reviewed or revised since the

previous RMP was submitted, reenter the date provided in the previous RMP.

7.9. Date of most recent pre-startup review. The pre-startup review requirements for Program

3 processes can be found at 40 CFR §68.77. Enter the date of the most recent pre-startup review

(if any) for this process. 

7.10. Compliance audits. The compliance audit requirements for Program 3 processes can be

found at 40 CFR §68.79. If you did not conduct a compliance audit prior to submitting your first

RMP (you are not required to do so), leave these fields blank. 

7.10.a. Date of most recent compliance audit

7.10.b. Expected or actual date of completion of all changes resulting from the

compliance audit. This may be left blank if there were no changes.
Ch. 2 Pg. 52

7.11. Incident investigation. The incident investigation requirements for Program 3 processes

can be found at 40 CFR §68.81. Enter the following:

7.11.a. Date of your most recent incident investigation (if any). If you have not had

an incident investigation, leave this field blank.

7.11.b. The expected or actual date of completion of all changes resulting from the

incident investigation. This may be blank if there were no changes.

7.12. Date of most recent review or revision of employee participation plans. The employee

participation requirements for Program 3 processes can be found at 40 CFR §68.83. For your

first RMP submission, enter the date you complied with the requirements of §68.83(a) (develop a

written plan) for the process, or the date you last reviewed or revised the employee participation

plans, whichever is later. (As explained in the introduction to Section 7, the date you enter may

depend on whether you are subject to the same or similar requirement under other federal or state

laws.) For subsequent RMPs, enter the date of the most recent review or revision of the plan. 

Employee participation plans may be reviewed or revised as a result of, among other things, a

periodic audit of the prevention program (see §68.79(a)). If the plan was not reviewed or revised

since the previous RMP was submitted, reenter the date provided in the previous RMP. 

7.13. Date of most recent review or revision of hot work permit procedures. The hot work

permit requirements for Program 3 processes can be found at 40 CFR §68.85. For your first

RMP submission, enter the date you complied with the requirement of §68.85 for the process or

the date you last reviewed or revised the hot work permit procedures, whichever is later. (As

explained in the introduction to Section 7, the date you enter may depend on whether you are

subject to the same or similar requirement under other federal or state laws.) For subsequent

RMPs, enter the date of the most recent review or revision of your hot work permit procedures. 

Hot work permit procedures may be reviewed or revised as a result of, among other things, a

periodic audit of the prevention program (see §68.79(a)). If the procedures were not reviewed or

revised since the previous RMP was submitted, reenter the date provided in the previous RMP. 

7.14. Date of most recent review or revision of contractor safety procedures. The contractor

safety requirements for Program 3 processes can be found at 40 CFR §68.87. Leave this field

blank if you do not have any contractors. Otherwise, for your first RMP submission, enter the

date you complied with the requirements of §68.87(b)(4) (develop and implement safe work

practices for contractors) for the process, or the date you last reviewed or revised the contractor

safety procedures, whichever is later. (As explained in the introduction to Section 7, the date

you enter may depend on whether you are subject to the same or similar requirement under other

federal or state laws.) For subsequent RMPs, enter the date of the most recent review or revision

of the procedures. Contractor safety procedures may be reviewed or revised as a result of,

among other things, a change to the process (see §68.75(c)) or a periodic audit of the prevention

program (see §68.79(a)). If the procedures were not reviewed or revised since the previous RMP

was submitted, reenter the date provided in the previous RMP. 

7.15. Date of most recent evaluation of contractor safety performance. Leave this field

blank if you do not have any contractors or have not yet evaluated contractor performance. 
Ch. 2 Pg. 53

Otherwise, enter the date of your most recent evaluation of contractor safety performance. If you

have more than one contractor involved in operating or maintaining the process, enter the date

you completed your evaluations of all the contractors.
Ch. 2 Pg. 54

Section 8: Prevention Program for Program 2 Processes

Complete this section for each prevention program you report for a Program 2 process.

Prevention program description. If different safeguards apply to different units in your

process, use this field to explain how the prevention program for the process relates to the

different units in the process. For example, "This process includes three interconnected

production units, A, B, and C. Everything in this prevention program applies to all three units,

with the following exceptions:

- The dates of the hazard review, which are 01/02/97, 6/5/96 and 4/3/96 for units A, B and C,

respectively.

- Production unit A uses only a scrubber as a process control, while units B and C have relief

valves and scrubbers.

- The water curtain indicated as a mitigation measure applies only to production unit C."

If you have so many "exceptions" that it gets too complicated to explain as above, but you still

have many common data elements, you can report your prevention program on a unit-by-unit

basis. To simplify such reporting, you can use the autocopy feature in RMP*Submit so that you

only have to enter the common data elements once. First, enter the common elements into

RMP*Submit (or the paper form, if you are submitting in paper), then hit the COPY function at

the bottom of the screen to copy that information to another prevention program "record" (if you

are submitting in paper, photocopy the pages). To complete the prevention program record for

each unit, enter the remaining data which is unique to each.

8.1. NAICS code for the process. Enter the NAICS code that most closely corresponds to the

process; it will not necessarily be the same NAICS code for your facility as a whole. The

NAICS code that you choose must be one that you've already entered in the Registration Section

for the covered process. If you have two processes with the same NAICS code, explain in the

above description field which of the two processes this prevention program relates to. 

RMP*Submit will produce a list of the NAICS codes that you have already entered for your

registered processes as a pick list for this data element. As described in the Registration section

of this manual, the NAICS code system classifies businesses by type using descriptive categories

that correspond to five-digit or six-digit codes. 

8.2. Chemical name(s). For each prevention program, provide the names of all regulated

substances held above the threshold in the covered units. If you have an NFPA-4 flammable

mixture containing regulated flammables, you may list it as a “flammable mixture” and list all of

the regulated substances contained in the mixture.

8.3. Safety information. The safety information requirements for Program 2 processes can be

found at 40 CFR §68.48. Enter the following:

8.3.a. The date that you most recently reviewed or revised the safety information. For your

first RMP submission, enter the date you complied with the safety information requirements of
Ch. 2 Pg. 55

§68.48(a) (compile safety information) for the process, or the date you last reviewed or revised

the safety information, whichever is later. (As explained in the introduction to Section 7, the

date you enter may depend on whether you are subject to the same or similar requirement under

other federal or state laws.) For subsequent RMPs, enter the date the information was most

recently reviewed or revised. Safety information may be reviewed or revised as a result of,

among other things, a major change to the process (see §68.48(c)) or a periodic audit of the

prevention program (see §68.58(a)). If the safety information was not reviewed or revised since

the previous RMP was submitted, reenter the date provided in the previous RMP. 

8.3.b. Federal or state regulations or industry-specific design codes and standards used to

demonstrate compliance with the safety information requirement (select at least one). Are

you subject to any of the following Federal or state regulations? Do you use any of the

following industry-specific design codes and standards to demonstrate compliance with the

safety information requirement? If none are applicable, check "none."

8.3.b.1. NFPA 58 (or state law based on NFPA 58). – NFPA stands for National Fire

Protection Association; NFPA 58 is a propane (LP gas) handling code. Note that state

propane laws are generally based on NFPA 58. Select “NFPA 58” if your process is

subject to a state or local law based on NFPA 58 or if you follow NFPA 58 in any event.

 

8.3.b.2. OSHA (29 CFR 1910.111) – OSHA’s rule for operations handling anhydrous

ammonia. Select “29 CFR 1910.111” if your process is subject to this rule. 

8.3.b.3. ASTM Standards – Select this if you follow American Society of Testing

Materials standards. ASTM establishes standards for materials, products, systems, test

methods, specifications, classifications, definitions, and recommended practices. 

8.3.b.4. ANSI Standards – Select this if you follow American National Standards

Institute standards. ANSI nationally coordinates voluntary standards. ANSI standards

cover areas as definitions, terminology, symbols, and abbreviations; materials,

performance characteristics, procedure, and methods of rating; methods of testing and

analysis; size, weight, and volume, safety, health, and building construction. 

8.3.b.5. ASME Standards - Select this if you follow American Society of Mechanical

Engineers standards. ASME conducts research and develops boiler, pressure vessel, and

power test codes. It also develops safety codes and standards for equipment. 

8.3.b.6. None – If your facility does not apply to the Program 2 process any national

standards such as those noted above, and is not subject to any federal or state rules or

laws such as those noted above, select “none.”

8.3.b.7. Other (specify) – If you apply any other standards to your process safety

equipment, select “other” and specify the standards you apply. Some examples of other

standards include the National Electrical Manufacturers Association (NEMA) standards
Ch. 2 Pg. 56

and the American Petroleum Institute (API) standards. There may also be other codes

that apply.

8.3.b.8. Comments – In this section, please explain how federal, state or local

regulations or industry-specific design codes and standards are being used to demonstrate

compliance with the safety information requirement.

8.4. Hazard Review. The hazard review requirements for Program 2 processes can be found at

40 CFR §68.50. Enter the following:

8.4.a. The date of completion of the most recent hazard review or update (must be

within the five years prior to submission of the RMP).

8.4.b. The expected or actual date of completion of all changes resulting from the

hazard review. This may be blank if there were no changes.

8.4.c. Major hazards identified (select at least one). All major hazards that were

identified for the Program 2 process or part of the process at your facility as a result of

the hazard review. Major hazards are described in 7.4.d. 

8.4.d. Process controls in use (select at least one). All of the process controls used on

the Program 2 process or part of the process. Process controls are equipment and

procedures used to prevent or limit releases. Process controls are described in 7.4.e. If

none are applicable, check "none."

8.4.e. Mitigation systems in use (select at least one). All of the mitigation systems you

have in place to control a release should one occur from the Program 2 process or part of

the process. Mitigation systems are described in 7.4.f. If none are applicable, check

"none."

8.4.f. Monitoring/detection systems in use (select at least one). All of the monitoring

and detection systems installed to detect a release of a regulated substance from the

Program 2 process or part of the process. Monitoring and detection systems are

described in 7.4.g. If none are applicable, check "none."

8.4.g. Changes since last hazard review or hazard review update (select at least

one). All of the changes made to the process or part of the Program 2 process since the

last hazard review. Hazard review changes are described in 7.4.h. If none are applicable,

check "none."

8.5. Date of most recent review or revision of operating procedures. The operating

procedures requirements for Program 2 processes can be found in the RMP regulation at 40 CFR

§68.52. For your first RMP submission, enter the date you complied with the requirements of

§68.52(a) (prepare written procedures) for the process, or the date you last reviewed or revised
Ch. 2 Pg. 57

the operating procedures, whichever is later. (As explained in the introduction to Section 7, the

date you enter may depend on whether you are subject to the same or similar requirement under

other federal or state laws.) For subsequent RMPs, enter the date of the most recent review or

revision of the operating procedures. Operating procedures may be reviewed or revised as a

result of, among other things, a major change to the process (see §68.52(c)) or a periodic audit of

the prevention program (see §68.58(a)). (See Chapter 7 of the General Guidance for Risk

Management Programs for a discussion of what constitutes a major change.) If the operating

procedures were not reviewed or revised since the previous RMP was submitted, reenter the date

provided in the previous RMP.

8.6. Training. Training requirements for Program 2 processes can be found at 40 CFR §68.54. 

Enter the following:

8.6.a. Date of most recent review or revision of training programs. For your first

RMP submission, enter the date you complied with the requirements of §68.54(a)

(training) for the process, or the date you last reviewed or revised the training programs,

whichever is later. (As explained in the introduction to Section 7, the date you enter may

depend on whether you are subject to the same or similar requirement under other federal

or state laws.) For subsequent RMPs, enter the date of the most recent review or

revision of the training you provide. Training programs may be reviewed or revised as a

result of, among other things, a major change to the process (see § 68.54(d)) or a periodic

audit of the prevention program (see §68.58(a)). If the training was not reviewed or

revised since the previous RMP was submitted, reenter the date provided in the previous

RMP.

8.6.b. Type of training provided (select at least one).

1. Classroom

2. On the job

3. Other (specify)

8.6.c. Type of competency testing used (select at least one). Identify how employees

were tested to determine and evaluate comprehension of the training materials.

1. Written test

2. Oral test

3. Demonstration

4. Observation

5. Other (specify)

8.7. Maintenance. The maintenance requirements for Program 2 processes can be found at 40

CFR §68.56. Enter the following:

8.7.a. The date that you most recently reviewed or revised the maintenance

procedures. For your first RMP submission, enter the date you complied with the

requirements of §68.56(a) (prepare and implement maintenance procedures) for the
Ch. 2 Pg. 58

process, or the date you last reviewed or revised the maintenance procedures, whichever

is later. (As explained in the introduction to Section 7, the date you enter may depend on

whether you are subject to the same or similar requirement under other federal or state

laws.) For subsequent RMPs, enter the date of the most recent review or revision of the

maintenance procedures. Maintenance procedures may be reviewed or revised as a result

of, among other things, a major change to the process (see §68.56(a)) or a periodic audit

of the prevention program (see §68.58(a)). If the procedures were not reviewed or

revised since the previous RMP was submitted, reenter the date provided in the previous

RMP.

8.7.b. The date of the most recent equipment inspection or test

8.7.c. The equipment that were inspected or tested (list equipment). 

8.8. Compliance Audits. The compliance audit requirements for Program 2 processes can be 40

CFR §68.58. If you did conduct a compliance audit prior to submitting your first RMP (you are

not required to do so), leave these fields blank. 

8.8.a. The date of your most recent compliance audit.

8.8.b. The expected or actual date of completion of all changes resulting from the

compliance audit. This may be blank if there were no changes.

8.9. Incident Investigation. The incident investigation requirements for Program 2 processes

can be found at 40 CFR §68.60. Enter the following:

8.9.a. The date of your most recent incident investigation (if any). If you have not

had an incident investigation, leave this field blank.

8.9.b. The expected or actual date of completion of all changes resulting from the

incident investigation. This may be blank if there were no changes.

8.10. Date of most recent change that triggered review or revision. Enter the date of the

most recent change that triggered a review or a revision of safety information, the hazard review,

operating or maintenance procedures, or training. 
Ch. 2 Pg. 59

Section 9: Emergency Response Program

Complete this section once for all covered processes.

The extent to which you need to fill out this portion of the RMP depends on whether your

employees will respond to releases of regulated substances at your facility. Under §68.90(b), if

your employees will not respond to releases, you are not required to comply with the

requirements for an emergency response program provided you meet the following criteria: (1) if

you hold one or more regulated toxic substances over threshold quantities, your facility must be

included in the community emergency response plan developed under the Emergency Planning

and Community Right-to-Know Act (EPCRA); (2) if you hold only one or more regulated

flammable substances over threshold quantities, you must have coordinated response actions

with the local fire department; and (3) you must have appropriate mechanisms in place to notify

emergency responders when there is a need for a response.

If your employees will respond to releases of regulated substances at your facility, you are

subject to §68.95 and must fill out all the data items in this section of the RMP. If your

employees will not respond to releases of regulated substances at your facility, you need only

respond to the first two (9.1.a & 9.1.b) and last three (9.7.a, 9.7.b, & 9.8) emergency response

data elements.

9.1. Written emergency response (ER) plan

9.1.a. Is your facility included in the community emergency response plan? If your facility

is subject to part 68 because it has one or more regulated toxic substances above threshold

quantities, it is probably included in a local emergency response plan under the Emergency

Planning and Community Right-to-Know Act (EPCRA). Under §303 of EPCRA, local

emergency planning committees (LEPCs) must prepare an emergency response plan for facilities

in their planning district having toxic substances listed under EPCRA §302 in excess of the

threshold planning quantity established under that section. Most of the toxic substances listed in

part 68 are also listed under EPCRA §302, and the EPCRA thresholds for those substances are

generally the same or lower than the part 68 thresholds for the same substances. Consequently,

part 68 facilities with toxic substances listed under both EPCRA and part 68 should be included

in community emergency response plans. 

In addition, facilities subject to part 68 as a result of flammable substances may also be covered

by community emergency response plans, since LEPCs can, and sometimes do, include other

hazardous substances, including flammables, in their plans. If you are not sure whether your

facility is included in your community’s local emergency plan, check with your LEPC. 

As noted above, if your employees are not going to respond to releases of regulated substances at

your facility and you have one or more part 68 regulated toxic substances over threshold

quantities, your facility must be included in the local emergency response place under EPCRA.
Ch. 2 Pg. 60

Check this question if your facility is included in the community’s emergency response plan. 

9.1.b. Does your facility have its own written emergency response plan? Check this question

if you have a response plan (not just an emergency action plan as required by OSHA under 29

CFR 1910.38). 

9.2. Does your facility's ER plan include specific actions to be taken in response to

accidental releases of regulated substance(s)?

9.3. Does your facility's ER plan include procedures for informing the public and local

agencies responding to accidental releases?

9.4. Does your facility's ER plan include information on emergency health care?

These data elements (9.2, 9.3, 9.4) reflect the three mandatory components of the emergency

response plan required under §68.95(a)(1). For an emergency response plan to be in compliance

with this requirement, you must be able to answer “yes” to each of these questions.

9.5. Date of most recent review or update of your facility's ER plan.

Indicate the date on which you most recently reviewed or updated your plan. Section

68.95(a)(4) requires that ER plans be reviewed and updated “as appropriate” to reflect changes at

the facility and to ensure that employees are informed of changes.

9.6. Date of the most recent ER training for your facility’s employees.

Indicate the date of the most recent emergency response training at your facility. Emergency

response training includes drills involving your personnel with or without outside emergency

response agencies and tabletop exercises of your emergency response plan. Single purpose drills

(e.g., alarm system drills) may be listed, but exercises that test more aspects of the plan are

preferable.

Part 68 does not specify a schedule for conducting employee response training. You should

note, however, that other planning requirements (e.g., HAZWOPER) may establish a more

formal schedule for conducting training (e.g., eight hours of annual refresher training).

9.7.a-b. Local agency with which your facility's ER plan or response actions are

coordinated. If you have an ER plan, indicate the name and phone number of the agency with

whom you have coordinated your plan. Section 68.95(c) requires that a facility’s ER plan be

coordinated with the community emergency response plan under EPCRA for the facility’s

community. The LEPC for the facility’s community will typically be the agency with which ER

plans are coordinated. 

If you do not have an ER plan, indicate the agency with which you have coordinated response

activities. As noted above, §68.90(b) provides that if you have regulated toxic substances and

your employees will not be responding to releases of those substances, your facility must be

included in the community emergency response plan developed by the LEPC for your
Ch. 2 Pg. 61

community. If that is the case for your facility, indicate the name and phone number of your

LEPC here. If you have only regulated flammable substances and your employees will not be

responding to releases of those substances, you must have coordinated response actions with the

local fire department. If that is case for your facility, indicate the name and phone number of

your local fire department here.

9.8. What other Federal or State emergency plan requirements is the facility subject to?

Indicate all of the federal and state emergency response regulations or statutes to which your

facility is subject. Select at least one. All RMP facilities are subject to OSHA emergency

planning requirements at either 29 CFR 1910.38 or 29 CFR 1910.120.

a. OSHA Regulations at 29 CFR 1910.38. These are OSHA’s Emergency Action Plan

regulations. All RMP facilities are subject to either these OSHA regulations or OSHA

regulations at 29 CFR 1910.120.

b. OSHA Regulations at 29 CFR 1910.120. These are OSHA’s Hazardous Waste

Operations and Emergency Response (HAZWOPER) Plan regulations. All RMP

facilities are subject to either these OSHA regulations or OSHA regulations at 29 CFR

1910.38.

c. Clean Water Act Regulations at 40 CFR 112. These are EPA’s Oil Spill Prevention

Control and Countermeasures (SPCC) regulations under the Clean Water Act.

d. RCRA Regulations at 40 CFR 264, 265, and 279.52. These are EPA’s permitting

regulations for solid waste under the Resource Conservation and Recovery Act (RCRA).

e. OPA 90 Regulations at 40 CFR 112, 33 CFR 154, 49 CFR 194, or 30 CFR 254.

These are EPA, U.S. Coast Guard, Department of Transportation, and Department of the

Interior facility response plan regulations under the Oil Pollution Act of 1990 (OPA 90).

f. State EPCRA Rules or Laws. These are state emergency planning and community

right-to-know (EPCRA) laws. Federal EPCRA does not require facility response plans,

but some state laws may.

g. Other. Specify any other emergency response regulations or laws to which your

facility is subject.
Ch. 2 Pg. 62

Executive Summary

The executive summary must include a brief description of your facility's risk management

program. You determine the length; it may be as short as two or three pages or, if you have

many processes, it may need to be more lengthy. You should view the Executive Summary as an

opportunity to communicate in your own words the nature of the risks posed by your facility to

your community and to explain what you have done to minimize those risks. The summary can

be an excellent vehicle to display the effort and resources your facility has put into its accident

prevention program. 

Your executive summary can not be claimed as CBI. Do not include any CBI data in your

executive summary. 

If your executive summary is short, it can be "cut" from the word processing program you are

using and "pasted" into the text box on the Executive Summary screen. Alternatively, you may

type the executive summary straight into the text box. To expand the visual size of the text box,

press [shift-F2].

To report long executive summaries, you have 2 options:

1) Attach your entire executive summary in a separate ASCII file: While you are

using your word processing program, save the executive summary as an ASCII Text file

(most word processing program allow you to do this). Then, in RMP*Submit’s

Executive Summary screen, click on the box with the 3 dots (...) at the bottom of the

screen to "browse" your system and locate the ASCII Text file. Select the ASCII Text

file containing your executive summary, and RMP*Submit will store that filename. 

When you are ready to submit your RMP, choose "Create Submission File" from the

"List of Risk Management Plans" screen, and the executive summary file will be

automatically stored on the submittal disk along with the rest of the RMP.

2) Cut and paste part of the executive summary and attach the rest: Enter part of

your executive summary into the text box on the Executive Summary page in

RMP*Submit by either cutting and pasting text or typing it in. Then, attach the rest of

the executive summary in a separate ASCII Text file using the instructions in #1 above. 

IMPORTANT - A summary of the off-site consequence analysis (OCA) for the worst-case

and alternative release scenario(s) is no longer required to be included in the executive

summary. While the RMP rule originally required that the executive summary briefly describe

the OCA for worst-case and alternative release scenario(s), EPA amended the RMP rule in 2004

to remove this requirement because of security concerns.
Ch. 2 Pg. 63

The Executive Summary must briefly describe the following elements:

The accidental release prevention and emergency response policies at your facility

Describe your facility's overall approach to chemical safety. You may want to include any

corporate policies (if applicable) and an overview of senior management commitment to safety

and implementation of safe procedures.

Your facility and the regulated substances handled 

Provide a description of your facility so that the public has a clear picture of the facility, its

processes, and products. Describe the primary activities at the facility (e.g., manufacturer of

polyethylene, pulp mill, etc.) and the regulated substances used. In addition, you may want to

mention the quantities of these substances handled or stored at your facility.

The general accidental release prevention program and chemical-specific prevention steps

You may wish to mention the rules and regulations with which your facility complies, such as

the OSHA PSM rule. You should also highlight practices that you believe are important to your

prevention program. The steps you list may be either technological (e.g., backup systems) or

procedural/managerial (e.g., improved maintenance or training).

The five-year accident history

Do not present accident history information in table form here; more details will be provided in

the data elements. This should be a written summary; for example, “We have had five accidental

releases of chlorine in the past five years; the largest release was 1,500 pounds. No one offsite

was injured, but several houses were evacuated as a precautionary measure during the October

1995 and May 1996 releases.”

The emergency response program

Briefly describe the elements of your response program such as coordination with local

emergency responders, training received by personnel, drills conducted by your facility, public

notification and alert systems, as appropriate.

Planned changes to improve safety

List any upcoming events such as training, installation of new mitigation or control equipment or

technology, organizational changes, etc., that will improve safety at your facility.
Ch. 3 Pg. 1

CHAPTER 3 HOW TO ASSEMBLE AND SUBMIT YOUR RMP

A complete RMP submission package includes at least two items:

1. The RMP in ASCII format, created by using either RMP*Submit or a

commercial RMP software product, on a diskette or CD. If you do not have the

capability to submit electronically, see the section on “Paper Submission” below. 

Include only 1 RMP on each diskette/CD or form.

2. A certification statement for the entire RMP, signed (with an original signature)

and dated.

Submit only one RMP and accompanying certification statement per envelope to ensure

that the certification statement is applied to the appropriate RMP. If you are claiming

CBI, additional items are required ; see Chapter 4: Submitting CBI & Trade Secrets of

this manual for more information. Do not send other correspondence with your RMP. 

Completeness Check

One advantage of submitting electronically (using RMP*Submit or a commercial RMP

software package) is that you will be able to check whether your RMP is “complete” in

the sense that you have provided information for the RMP data elements that every

facility must complete. 

Using RMP*Submit, you can run the Check function (from the List of Risk Management

Plans screen) to verify the “completeness” of your RMP at any time. Once you have

completed entering your RMP data, you should execute the Check function to check for

errors. The Check function is a button on the List of Risk Management Plans screen

(See Exhibit 3). The Check function is also executed automatically each time you

execute the Create Submission File function. 

The CHECK function will create an Error Report if your RMP is “incomplete.” It is

important to note, however, that the “completeness” check provided by RMP*Submit is 

not a compliance check. It will not indicate whether your RMP meets all applicable part

68 requirements; it will only indicate that you have provided the right type of information

for those data elements that every facility submitting an RMP must at a minimum

complete. RMP*Submit cannot discern if you have provided correct information or if

you should have completed data elements in addition to those required of every facility. 

Consequently, you should not rely on RMP*Submit’s “completeness” check to determine

whether your RMP fully complies with the requirements of part 68.

If you used a commercial RMP software program, you can still use RMP*Submit to

verify the “completeness” of your RMP. RMP*Submit can import an RMP ASCII file. 

Once a new ASCII file is imported, run the CHECK function to verify “completeness.” 
Ch. 3 Pg. 2

RMP*Submit will produce an Error Report if it detects that the RMP is not “complete” or

if it detects any of the following errors: 

1) You have omitted critical and mandatory data elements such as:

--Facility name and address; 

--For each process (section 1): program level, chemical name, CAS # and NAICS code;

--For each OCA section (sections 2-5): chemical name;

--For each Accident History (section 6): chemical name, CAS #, & date;

--For each Prevention Program (sections 7-8): NAICS, chemical name, CAS #.

2) You have entered data elements which do not meet specific “validation” criteria.

All data elements required for an RMP to be “complete” must contain a response that is

appropriate for the kind of information requested or RMP*Submit will generate an Error

Report. For example, all date fields must contain a 2-digit month between 01 and 12, a

2-digit day between 01 and 31, and a 4-digit year (MM/DD/YYYY). RMP*Submit will 

not indicate whether the date or other information provided is correct or meets regulatory

requirements.

3) You have entered data elements which are inconsistent across sections of the

RMP. For example, for every toxic chemical reported in the registration section for

Program 2 and 3 processes, there must be a toxic alternative release scenario reported.

Errors in #1 above make your RMP submission unprocessable and RMP*Submit cannot generate

an ASCII file. Errors generated in #2 & #3 above will still generate the ASCII file for

submission. Therefore, you can choose to submit an RMP that is "incomplete," meaning it

contains errors. However, if you submit an "incomplete" RMP, you will not be in compliance

with the part 68 requirement to submit a RMP meeting all applicable regulatory requirements by

the applicable due date.

Creating the RMP Submission File on Diskette

When you are ready to submit your RMP, run the Create Submission File function (from the

RMP List screen) to create an ASCII file for submission. RMP*Submit will once again run the

validation program to check for “completeness.” 

Graphics Files

In Sections 2 through 5, you may have included a graphics file name. If so, remember that you

must take the extra step of copying the file to the diskette or CD that contains your RMP

submission ASCII file, or an additional diskette or CD that contains just your graphics file. 

Make sure the file name in the scenario and the actual name of the file match exactly. Make sure

they are identified in the RMP with a specific worst case or alternative release scenario. 
Ch. 3 Pg. 3

How to Label Your Submission Diskette

You must attach a label to each diskette (not the diskette’s jacket). The label must be typed or

legibly handwritten. A sample label with the necessary information is shown below. While the

types of packaging and shipping to use for submitting diskettes are left to your discretion, be

sure to package them in a way to avoid damage. Damaged diskettes or CDs are unprocessable.

RMP 

Facility Name

Date: 6/1/1999 Disk 1 of 1 

Contact: RMP Contact Name &

 Phone Number

Certification Letter

A certification letter is required for all RMP submissions.

68.185 Certification. 

(a) For Program 1 processes, the owner or operator shall submit in the RMP

the certification statement provided in § 68.12(b)(4) of this part.

(b) For all other covered processes, the owner or operator shall submit in the

RMP a single certification that, to the best of the signer's knowledge,

information, and belief formed after reasonable inquiry, the information

submitted is true, accurate, and complete.

The certification statement submitted must bear the original signature of the person

making the certification. Photocopied, faxed or otherwise duplicated signatures are not

originals. Be sure to include the signed copy with your RMP submission.

The certification statement must be signed by the person at the facility responsible for the

Risk Management Program (the owner or operator or a senior official with management

responsibility for the person (or persons) completing the RMP). The owner, operator, or

official must certify the accuracy and completeness of the RMP by signing and dating the

certification statement. The statement applies to all the information supplied in the RMP

and should be signed only after the form is complete. The name and title of the person

signing the statement should be printed or typed on the certification. 
Ch. 3 Pg. 4

Sample certification letters are provided in Appendix C. In addition, RMP*Submit

contains the text of the sample letters under the "Main Menu," –> "Tools," –> "Edit

Certification Letters." You can cut and paste this text into your own word processing

package to finalize and print the letter

Unprocessable and Incomplete RMPs

The Reporting Center will process all RMPs using the same Check function found in

RMP*Submit. If any of the fields needed for ASCII file generation are missing (error in #1

above), the Center will be unable to process your RMP and you will be so notified. If any other

errors (like those in #2 & #3 above) are detected, an Error Report will be generated and the RMP

will be marked as "incomplete." Both "complete" and "incomplete" RMPs will be included in

the RMP database. Error reports for those that are incomplete, as well as a list of RMPs that

cannot be processed, will also be included. The RMP database is temporarily unavailable on the

Internet, but information from it is available to the public on request. A copy of any Error

Report generated for your RMP will be mailed to you with your notification letter. 

In addition to missing required fields (an error in #1 above), an RMP submitted on diskette will

be unable to be processed for the following reasons:

--There is a virus on the diskette you submitted that could not be removed at our

Reporting Center.

--The submitted diskette, or the ASCII file on the diskette you submitted, is

unreadable (for example, damaged diskette).

--More than one Risk Management Plan was reported in a single submission.

In addition to inconsistencies in data elements (an error in #2 or #3 above), an RMP will be

considered incomplete if you do not include a certification letter with your submission or the

signature on the certification letter is not an original.

Attention: If you consider any of the information you are required to report to be

confidential business information (CBI), please read the following:

Before you submit your RMP, review the regulatory provisions (40 CFR §2.208)

governing CBI claims and decide if the information you consider confidential

meets the applicable criteria for CBI. See Chapter 4 for instructions on how to

claim CBI.

DO NOT include the information you believe meets the criteria for CBI in

your RMP (regardless of whether you use RMP*Submit or the paper RMP form).

Because the Clean Air Act requires that RMPs be available to the public, any

information you include in your RMP CANNOT be claimed CBI in the future. 
Ch. 3 Pg. 5

Paper Submissions - Forms and Instructions

If you are unable to submit your RMP on diskette, use the paper form provided in

Appendix A. Our Reporting Center can only process paper RMPs submitted using that

form. If you submit on paper, you are asked to complete the Paper Submission Form

(Appendix B) and send it with your RMP. 

Attention: If you consider any of the information you are required to report to be

confidential business information (CBI), please read the following:

Before you submit your RMP, review the regulatory provisions (40 CFR §2.208)

governing CBI claims and decide if the information you consider confidential

meets the applicable criteria for CBI. 

DO NOT include the information you believe meets the criteria for CBI in

your RMP (regardless of whether you use RMP*Submit or the paper RMP form). 

 Because the Clean Air Act requires RMPs to be available to the public, any

information you include in your RMP CANNOT be claimed CBI in the future. 

At the same time you submit your RMP, you must submit ON SEPARATE

PAPER FORMS the information that you are claiming CBI and your

substantiation that the information meets the criteria for CBI. 

Refer to Chapter 4 of the User's Manual for complete instructions on how to

submit CBI.

Where to send completed RMP Reports

Send reports by regular mail to:

Risk Management Plan (RMP) Reporting Center

P.O. Box 1515

Lanham-Seabrook, Maryland 20703-1515

(301) 429 5018

Send certified mail, overnight mail, and hand-delivered submissions only to:

Risk Management Plan (RMP) Reporting Center

c/o CSC

Suite 300

8400 Corporate Drive

New Carrollton, MD 20785

(301) 429 5018

Record Keeping 

You are required to maintain records that support what is reported in your RMP and your

implementation of the Risk Management Program for five years (40 CFR §68.200).
Ch. 4 Pg. 1
Ch. 4 Pg. 2

CHAPTER 4 SUBMITTING CBI AND TRADE SECRETS

On January 6, 1999, EPA published a final rule in the Federal Register specifying which RMP

data elements may not be claimed as confidential business information (CBI) or trade secret and

what procedures must be followed to claim information as CBI. The regulatory provisions, at

sections 68.151 and 68.152, provide that if you claim any RMP information as CBI, you must

submit to EPA a sanitized RMP (either on diskette or paper), a Substantiation Form (for

explaining why you believe the information meets the criteria for CBI), and an Unsanitized Data

Elements Form (on paper only) (see Appendices D & E for forms). The sanitized, or redacted,

RMP should not include any CBI. Any CBI included in a sanitized RMP (either in diskette or

paper form) will be automatically loaded into RMP*Info and will be available to the public. 

Report any information claimed as CBI only on the Unsanitized Data Elements Form. The

Unsanitized Data Elements Form is only for those data elements that you are claiming as CBI,

not for the entire RMP. 

For a data element that requires you to report information that you believe meets the applicable

criteria for CBI , you may claim the information as CBI in one of the following ways:

If you are submitting on diskette - Check the CBI box at the top of the screen where

that data element appears and leave the field blank. 

If you are submitting on the RMP Paper Form - Write "CBI" in the space provided for

that data element on the sanitized RMP.

However, if you are claiming chemical name as CBI, you must report one of the following

generic chemical categories. These will appear in the chemical pick lists in RMP*Submit once

you check the CBI box at the top of the screen.

CBI Acids

CBI Amines, Ammonia, and Hydrazines

CBI Arsenic and Phosphorus Compounds

CBI Boron Compounds

CBI Carbonyl Compounds

CBI Cyanides and Nitriles

CBI Esters, Alcohols, Aldehydes, and Furans

CBI Halogenated Organic Compounds

CBI Halogens and Halogen Oxides

CBI Isocyanates and Isothiocyanates

CBI Nitrogen Oxides and Organic Nitro Compounds

CBI Organic Silanes

CBI Oxiranes and Azirdines

CBI Selenium and Sulfer Compounds

CBI Flammable Substance
Ch. 4 Pg. 3

In summary, a complete RMP package with a CBI claim must include #1, #2, #4 & #5, and

possibly #3:

1. A sanitized, complete RMP in which the data elements claimed CBI are left blank

except for an indication that the information has been claimed as CBI (e.g., for RMPs on

diskette, the “CBI” box has been checked). This should be submitted on diskette or on

the paper RMP form. This version of the RMP will be in RMP*Info, the publicly

accessible database.

2. Sanitized CBI Substantiation Form(s) (Appendix D). If your explanation of why

information is CBI entails providing other information you believe is CBI, you must

complete two versions of the CBI Substantiation Form -- a sanitized version and an

unsanitized version. The sanitized version should omit the information you claim is

confidential and leave in its place the notation “information claimed confidential.” The

sanitized form should be submitted on paper only. If you are claiming multiple data

elements as CBI, you may need multiple substantiation forms. All pages of all forms

must be stapled together. Sanitized Substantiation Forms will be available to the public

on request.

3. Unsanitized CBI Substantiation Form(s) (Appendix D). If your substantiation includes

CBI, you must also include an unsanitized version of a completed CBI Substantiation

Form that provides the information that you claim is CBI. This should be submitted on

paper only. If you are claiming multiple data elements, you will need multiple

substantiation forms. All pages of all forms must be stapled together. 

4. An Unsanitized CBI Data Elements Form (Appendix E) that provides the RMP

information that you claim is CBI. This should be submitted on paper only. Staple all

pages together.

5. Certification Letter - signed and dated.

An RMP submission that claims CBI and does not contain the proper forms, will be considered

“incomplete.”
1

* RMP*Info, the publicly accessible database of RMPs previously available on the

Internet, is temporarily unavailable. However, information from RMP*Info is available to the

public on request.

Ch. 5 Pg. 1

CHAPTER 5 WHAT TO EXPECT AFTER YOU SUBMIT

Once your RMP is processed, you will be notified regarding the submission status of your RMP. 

Notification can be expected within several weeks, although delays may occur during peak

submission times. The notification will contain the following information:

(1) Your EPA Facility Identification Number.

 A unique EPA Facility Identification Number (also referred to as the RMP Identification

Number) is assigned to a facility upon its first submission and always stays with a facility, even

when ownership changes. If this is your initial RMP submission, this notification provides you

this number. Save the number. You will need it for all subsequent RMP submissions,

corrections, and correspondence specific to that facility.

(2) Complete/Incomplete Status of your submitted RMP.

Once your RMP is received at the RMP Reporting Center, it will be screened for the kind

of errors described previously. If any such errors are found, you will receive an Error

Report. Please note that this Error Report will also be included with your RMP in

RMP*Info1. Refer to Chapter 6: Corrections to your RMP, for instructions on how to

correct any errors you may have.

(3) The postmark date of your RMP.

You must update your RMP at least every five years. As a general rule, the five-year

anniversary for updating the RMP is calculated based on the postmark date of your last

RMP submission. Since you may not know the exact postmark date, we will provide it to

you for your records. For RMPs filed before the initial due date of June 21, 1999, the

first five-year anniversary is June 21, 2004. Note that 40 CRF §68.190(b) requires you

to update your RMP under several different circumstances, some or all of which could

occur before the fifth anniversary of your last RMP submission.

(4) If you submitted on paper, we will send you a paper copy of the printout of your RMP.

Paper submittals will be entered into RMP*Info manually by data entry staff. You will

receive a print out of your RMP as it appears in RMP*Info.
Ch. 6 Pg. 1

68.195 Required Corrections

The owner or operator of a stationary source for which a RMP was submitted shall correct

the RMP as follows:

(1) New accident history information – For any accidental release meeting the fiveyear accident history reporting criteria of §68.42 and occurring after [insert

publication date of rule], the owner or operator shall submit the data required under

§68.168, §68.170(j), and §68.175(l) with respect to that accident within six months of

the release or by the time the RMP is updated under §68.190, whichever is earlier.

(2) Emergency contact information – Beginning June 21, 2004, within one month of

any change in the emergency contact information required under §68.160 (b)(6), the

owner or operator. shall submit a correction of that information.

Chapter 6 Corrections to Your RMP

EPA has established a "correction" procedure for making changes to your RMP that reflect

administrative or other minor changes at your facility that do not require an update of your entire

RMP. This procedure can be used to make corrections you are required to make to your RMP

(e.g., change in emergency contact information) as well as corrections that you may choose to

make (change in facility email address). Submitting a corrected RMP does not change the fiveyear anniversary date for updating your entire RMP.

When to Correct Your RMP

You must correct your RMP if the changes specified in §68.195 (see box below) occur. (Note:

“stationary source” is the term used by the regulations to refer to a facility).

Additionally, if you receive a notification from the RMP Reporting Center that informs you that

your RMP is "incomplete," provide the needed information as soon as possible using the

corrections procedure. You may also discover other errors on your own, may need to make a

change to reflect a change in ownership of the facility, or may need to make minor

administrative changes such as provide a new phone number or contact name. You can correct

your RMP to implement such administrative changes. You may also correct your RMP to

remove OCA data from your Executive Summary. 

How To Correct Your RMP

The process for making corrections or administrative changes to an electronically submitted

RMP requires that you change the original RMP as needed and submit the corrected RMP on

diskette or CD with an accompanying paper certification.
Ch. 6 Pg. 2

Correction for New Accident History Information

If you have a reportable accident, you must revise section 6 of your RMP to include

information about the accident within six months of the accident’s occurrence. If the

accident involved a Program 2 or 3 process, you must also revise the incident investigation

information for that process in the RMPs, reported as part of Prevention Program

Information, section 7 or 8 of the RMP. Specifically, in section 7 or 8, you must revise: (1)

the date of investigation (40 CFR 68.170(j)); and (2) the expected date of completion of any

changes due to that accident investigation (40 CFR 68.175(l)).

The criteria for determining which accidents must be included in the five-year accident

history are found at 40 CFR 68.42. Guidance on the criteria and the reportable data elements

for the five-year accident history are found in the General Risk Management Program

Guidance, available on our website at:

(http://yosemite.epa.gov/oswer/ceppoweb.nsf/content/EPAguidance.htm).

Note: EPA is developing a new tool that will allow facilities to make certain corrections

and other small changes to the administrative sections of the RMP on-line, eliminating

the need to mail diskettes and certification letters for such corrections. The internetbased tool for correcting the administrative sections of the RMPs on-line (known as

RMP Web Registration Correction) will be available in May 2004. Further information

about this tool will be on EPA’s website at www.epa.gov/emergencies.

If you submitted an RMP on paper, make the changes in red ink on the printout of your RMP

submission (which the Reporting Center will mail back to you with your notification letter). 

You must also submit a new certification letter for these corrections. A sample certification

letter for corrections/updates can be found in Appendix C.

When you are ready to submit your corrected RMP, click on the button “Create Submission

File.” RMP*Submit will prompt you for:

Submission Type:

" First-time RMP Submission 

" Correction to my current RMP

" Re-Submission (all 9 sections are updated and certified)

Be sure to check the "correction" box. Also, select your reason for the correction from the pick

list. The pick list choices are:

C01 Clerical error corrected

C02 Additional information supplied

C03 Minor administrative change

C04 Notification of facility ownership change
Ch. 6 Pg. 3

C05 New accident history information

C06 Change in emergency contact information

C07 New data element required by EPA

C08 Optional data element requested by EPA

C09 Removed OCA description from executive summary
Ch. 7 Pg. 1

CHAPTER 7 UPDATING AND CERTIFYING ALL 9 SECTIONS OF

YOUR RMP: RE-SUBMISSION

In general, you must fully update your RMP no later than 5 years after the postmark date of your

last submission, or sooner if any of the changes specified in §68.190(b) (see box below) occur. 

However, the five-year anniversary for facilities that submitted an RMP before the initial due

date of June 21, 1999, is June 21, 2004, not earlier. Note that the regulation uses the term

“stationary source” to refer to a facility.

68.190 Updates.

(b) The owner or operator of a stationary source shall revise and update the

RMP submitted under § 68.150 as follows:

(1) Within five years of its initial submission or most recent update

required by paragraphs (b)(2)-(b)(7) of this section, whichever is later. 

(2) No later than three years after a newly regulated substance is first

listed by EPA;

(3) No later than the date on which a new regulated substance is first

present in an already covered process above a threshold quantity;

(4) No later than the date on which a regulated substance is first

present above a threshold quantity in a new process;

(5) Within six months of a change that requires a revised PHA or

hazard review;

(6) Within six months of a change that requires a revised offsite

consequence analysis as provided in §68.36; and

(7) Within six months of a change that alters the Program level that

applied to any covered process.

To submit a "re-submission," you must update all nine sections of your RMP. If you submitted

electronically, revise your previous RMP as appropriate and submit the updated RMP on

diskette. You must also submit a new certification letter for the updated RMP that covers all the

information in the RMP. A sample certification letter can be found in Appendix C. Resubmissions will re-set the 5-year anniversary date by which you must next update your RMP at

the latest. 

When you are ready to "Submit" your updated RMP, RMP*Submit will prompt you for:

Submission Type:

"First-time RMP Submission 

"Correction to my current RMP

"Re-submission (all 9 sections are updated and certified)

Be sure to check the "Re-submission" box. Also, select your reason for the re-submission from
Ch. 7 Pg. 2

the pick list. The pick list choices are:

R01 Newly regulated substance listed by EPA (40 CFR 68.190(b)(2))

R02 Newly regulated substance above TQ in already covered process (40 CFR

68.190(b)(3))

R03 Regulated substance present above TQ in new (or previously not 

covered) process (40 CFR 68.190(b)(4))

R04 Revised PHA / Hazard Review due to process change (40 CFR

68.190(b)(5))

R05 Revised OCA due to change (40 CFR 68.190(b)(6))

R06 Change in program level of covered process (40 CFR 68.190(b)(7))

R07 5-year update (40 CFR 68.190(b)(1))

R08 Process no longer covered (source has other processes that remain

covered) (40 CFR 68.190(b)(7))

R09 Voluntary update (not described by any of the above reasons)
Ch. 8 Pg. 1

68.190 Updates

(c) If a stationary source is no longer subject to this part, the owner or operator shall submit a

de-registration to EPA within six months indicating that the stationary source is no longer

covered.

CHAPTER 8 NOTIFYING EPA THAT YOUR FACILITY IS NO

LONGER COVERED BY RMP: DE-REGISTRATION

Changes may occur at your facility that make it no longer subject to the RMP regulations at 40

CFR Part 68 (e.g. you replace the regulated substances in your process with unregulated

substances.) If your facility is no longer covered by RMP, you must notify EPA as specified in

§68.190(c) (see box below). Note that the regulation uses the term “stationary source” to refer to

a facility.

To de-register, 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 part 68). The letter should be signed by the owner or operator and include your RMP

ID number (the 12-digit ID number assigned by EPA).

You can use RMP*Submit to generate the letter for you by running the de-register function

(from the Main Menu screen).

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 Chapter 7 of this manual)

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.

Important Reminders

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.

Current Mailing Address for RMP Reporting Center
Ch. 8 Pg. 2

Mail the signed letter to:

Risk Management Plan (RMP) Reporting Center

P.O. Box 1515

Lanham-Seabrook, Maryland 20703-1515

For courier and overnight delivery packages, the address is:

Risk Management Plan (RMP) Reporting Center

c/o CSC

Suite 300

8400 Corporate Drive

New Carrollton, MD 20785
Ch. 9 Pg. 2

GLOSSARY OF ACRONYMS & TERMS

CBI Confidential Business Information

CPU Central Processing Unit

DLL Dynamic Link Library

EPA Environmental Protection Agency

EPCRA Emergency Planning and Community Right-to-Know Act

GPF General Protection Fault

MB Megabyte(s)

NAICS North American Industrial Classification System

OCA Offsite Consequence Analysis 

Pick List A list of items to choose for an answer. 

POTWs Publicly Owner Treatment Works

RAM Random Access Memory

RMP Risk Management Plan

VGA Video Graphics Adapter