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How to Optimize Your PSM Program | The 2 RMP Elements: 02 RMP Submit | Blog No. 74



[This blog series derives from a technical paper written by Eli Macha, President of Macha PSM]


RMP Submits (Risk Management Plan Submits) are also required to be submitted to the EPA as part of their RMP program. The RMP Submit is a summary of the RMP program which needs to be submitted initially and at least every five years. Currently, this requirement is met by submitting information through the EPA’s Central Data Exchange portal, commonly called CDX.[1] 


If no one at a facility has CDX access to the facility’s account, then this should be the first order of business for the person responsible for the RMP program. Once someone has access, then they can update the information as necessary. If the facility is unsure of its submission status, they can look up the facility’s info through the RMP lookup tool.[2] In short, the PSM practitioner should get access to CDX and ensure there is an RMP submission and that it was submitted within the past five years.


         Next, what are some mistakes to avoid? First, check the emergency contact listed on the RMP Submit to ensure it is still correct. If there has been a change to the emergency contact, this needs to be corrected within one month.[3] While the person responsible for the RMP may have changed, this is surprisingly not a triggering event for an RMP correction. PSM Coordinators should also check to see if any other relevant triggering events have occurred which would have necessitated a RMP correction or update: new accident history information,[4] a change requiring a revised PHA,[5] a change requiring a revised offsite consequence analysis,[6] etc.


         While RMP Submits tend to be fairly standard documents, there is some room for optimization. First of all, ensure your process inventories are being correctly reported. In an effort to demonstrate exactitude, many facilities will list an inventory as an exact number, such as 34,873 lbs. Per the RMP’s explicit requirements, this figure should be rounded to the two most significant digits: 35,000 lbs.[7] 


Another area where the RMP Submit can be optimized is the executive summary section. This text tends to be boilerplate, but since this is public information, facilities might do well to speak to the conviction’s of the facility’s leadership regarding their commitment to employee and public safety. As the RMP*eSubmit Use Manual from December 2023 puts it, “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.”[8]




[3] Title 40 CFR §68.195(b)

[4] Title 40 CFR §68.195(a)

[5] Title 40 CFR §68.190(b)(5)

[6] Title 40 CFR §68.190(b)(6)

[7] Title 40 CFR §68.160(b)(7)

 
 
 

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