RMPs were first submitted to EPA in June 1999 by facilities that store or handle highly toxic or flammable chemicals. Last summer, EPA proposed a list of changes to RMP submittal requirements that it intends to implement by March 2004. The new rule will affect emergency contact information, RMP revision "triggers," executive summary information, and additional data elements.
"This is not earth-shattering," said David Heinold, senior risk management specialist with ENSR International, an environmental and energy development services company. "EPA looked at what information was included in the RMPs and the usefulness of that information. Some of the proposed changes are fairly mundane, such as including the specific person who's responsible for reporting and the phone number for that person. Another change is the triggering mechanism of when the plan needs to be updated. If a facility has an off-site release, it will need to update the RPM, rather than wait for the five-year renewal."
ENSR has helped over 100 clients to prepare and implement their original risk management plans at more than 500 facilities. To request a copy of ENSR's Risk Management Planning Update, call (800) 722-2440 or visit www.ensr.com/request.
"The changes aren't particularly burdensome," admitted Heinold, "But there are additional reporting requirements that must be met to comply with the provisions of the rule."