Under the Clean Air Act, if you are required to file a Risk Management Plan (RMP), you are also required to update your plan every 5 years. EPA has started to warn companies to update their plans or face penalties.
For example, in a streamlined enforcement process, EPA’s Region 2 office continually identifies facilities that currently have risk management plans in place to see which plans are overdue. Where the Agency finds facilities that have not updated their plans on time, EPA is giving that facility a chance to comply and pay a discounted penalty. This was the case recently for the Kuehne Chemical Company in South Kearny, New Jersey. As a result of EPA’s enforcement efforts, the company updated its plan and paid a $1,400 penalty for late filing. Additional enforcement actions are planned in the coming months.
For assistance in submitting an updated RMP, facilities should contact the RMP Reporting Center at 301-429-5018. Additionally, EPA has developed a new method for preparing and submitted your RMP which became available on March 13, 2009. The new method is called RMP*eSubmit and information about RMP*eSubmit and how to set up an RMP*eSubmit account can be found here.