Risk Management Plans

Owners or operators of covered facilities are required to implement a risk management program that includes a hazard assessment, an accident prevention program and an emergency response program. It also requires the submission of a summary of these program elements called a risk management plan (RMP) to EPA. At a minimum, RMPs must be updated at least once every five years. As required by rule, RMPs may need to be updated more frequently depending on changes at the facility.  North Carolina's Risk Management Program rule 15A NCAC 2D .2100 simply adopted the federal requirements. Meeting federal requirements is all that is required to comply with the state program. In order to submit an RMP with EPA, facilities must first setup an RMP*eSubmit account.

Setting Up An RMP*eSubmit Account

RMP*eSubmit is a web-based program that allows facilities to securely submit and make corrections to their RMPs. The program is accessed through EPA's Central Data Exchange (CDX) network. To activate an account:

1. Identify the "Certifying Official": Identify the owner or operator who will certify information that will be reported in the RMP.
2. Identify the "Preparer": Identify who will be responsible for accessing and maintaining the facility's RMP. It's important to note that the Certifying Official can also be the Preparer or can designate someone else.
3. Register the "Certifying Official" in CDX: Go to http://cdx.epa.gov and complete the registration process for "RMPESUBMIT: Risk Management Plan".
4. Complete the Electronic Signature Agreement (ESA): The ESA is accessed at the same time of the initial registration. The complete ESA will need to be printed, signed by the Certifying Official, and mailed to the RMP Reporting Center.
5. Activate the RMP*eSubmit account in CDX: Once the RMP Reporting Center receives the signed ESA, a response containing an authorization code will be emailed to the Certifying Official. The Certifying Official can then use the authorization code to activate their account.

RMP Trends Analysis

In order to measure the effectiveness of the program, a set of performance indicators is used to evaluate success. These indicators include measuring actions taken by industry to mitigate chemical hazards. Some of the hazard mitigation strategies include substituting hazardous materials for less hazardous materials, minimizing quantities of hazardous materials needed, modifying the regulated process by minimizing pressures or temperatures, and by simplifying the regulated process.

As the table below demonstrates, the number of subject facilities and associated processes continues to trend downward. A further analysis of the facilities no longer subject to the rule revealed that 39% removed the hazardous material from their regulated process and another 16% reduced inventories of hazardous materials to below threshold quantities. Of the remaining facilities subject to the rule, the trend of hazardous materials stored on site continues to trend upward. This increase trend in regulated substances can be mostly attributed to the increase in demand for propane.

Available Resources

• EPA's Central Data Exchange
• RMP*eSubmit Users' Manual
• EPA's Checklist for Submitting an RMP
• EPA's Guidance on Re-submitting, Correcting, De-registering or Withdrawing a RMP