RMP Implementation
Guide

Step 1: Inventory all regulated substances

Build a complete inventory of every chemical present at the facility and cross-reference it against the EPA's list of regulated substances at 40 CFR 68.130. The list includes approximately 77 toxic substances and 63 flammable substances, each with its own threshold quantity (TQ).

Step 2: Define each covered process

A "process" under RMP includes any activity involving a regulated substance, including storage, handling, manufacturing, use, and on-site movement. Interconnected vessels and co-located vessels that could be involved in a single release are treated as one process.

Step 3: Compare maximum quantity to TQ

For each process, calculate the maximum quantity of the regulated substance that could be present at any one time. If that maximum quantity equals or exceeds the threshold quantity, the process is covered by RMP. Mixtures are evaluated based on the regulated substance content using the rules at 40 CFR 68.115.

Program 1 (least burdensome)

Available only when the worst-case release scenario shows no public receptors within the distance to a toxic or flammable endpoint, AND no accidents with offsite consequences in the last five years, AND emergency response is coordinated with local responders. Most facilities do not qualify.

Program 2

The default for processes that don't qualify for Program 1 and aren't subject to OSHA PSM. Requires a streamlined prevention program (safety information, hazard review, operating procedures, training, maintenance, compliance audits, incident investigation).

Program 3

Required for any process subject to OSHA PSM (29 CFR 1910.119) or in any of ten specific NAICS codes (32211, 32411, 32511, 325181, 325188, 325192, 325199, 325211, 325311, 32532). Requires the full PSM-equivalent prevention program.

Worst-case release scenario

For each regulated toxic substance, model the release of the largest quantity in a single vessel or pipe over ten minutes. For flammables, model the explosion of the entire quantity. Determine the distance to the toxic endpoint or 1 psi overpressure and identify any public or environmental receptors within that distance.

Alternative release scenarios (Program 2 and 3)

Identify more likely release scenarios that could reach an offsite endpoint — transfer hose failures, vessel ruptures with active mitigation, process upset releases. At least one alternative scenario must be analyzed for each regulated toxic substance and one collective alternative scenario for flammables.

5-year accident history

Compile a rolling history of all accidental releases of regulated substances from covered processes that resulted in deaths, injuries, significant property damage on-site, or known offsite consequences (deaths, injuries, evacuations, sheltering in place, property damage, environmental damage). The history feeds the RMP submission and influences program level eligibility.

Process safety information (Program 3)

Document the hazards of regulated substances (toxicity, permissible exposure limits, physical and reactivity data), the technology of the process (P&IDs, block flow diagrams, design basis, safe operating limits), and the equipment used (materials of construction, relief system design, ventilation, codes and standards). Maintain through document management software with version control and review-date tracking.

Process hazard analysis (Program 2 hazard review, Program 3 PHA)

Identify, evaluate, and control hazards using an appropriate methodology — What-If, Checklist, What-If/Checklist, HAZOP, FMEA, or Fault Tree Analysis. PHAs must be revalidated every five years. Use hazard analysis software to document studies, track findings, and assign corrective actions.

Operating procedures and training

Write clear written procedures for startup, normal operations, temporary operations, emergency shutdown, normal shutdown, and startup after a turnaround or emergency shutdown. Train operators initially and at least every three years on the procedures. Training management software automates scheduling and certification tracking.

Mechanical integrity (Program 3)

Maintain process equipment with written procedures, employee training, inspection and testing on appropriate frequencies, deficiency correction, and quality assurance for new construction. Schedule and document inspections through preventive maintenance software integrated with PHA findings.

Management of change (Program 3)

Establish and implement written procedures to manage changes to process chemicals, technology, equipment, procedures, and facilities affecting a covered process. Track each change through MOC software with review, approval, training updates, and documentation.

Pre-startup safety review (Program 3)

Before introducing a regulated substance to a new or significantly modified facility, perform a PSSR to confirm construction matches design specifications, all safety procedures are in place, PHA recommendations have been resolved, and operators have been trained. Documented through MOC workflows.

Compliance audits

Audit the entire RMP program at least every three years. Maintain the two most recent audit reports and document corrective actions. Audits must be performed by someone knowledgeable in the process. Track audits and findings through audit software.

Incident investigation

Investigate any incident that resulted in or could reasonably have resulted in a catastrophic release. Begin within 48 hours, identify root causes, document findings, and track corrective actions to closure. Incident management software standardizes investigations and accident history reporting.

Employee participation, contractors, hot work (Program 3)

Develop a written employee participation plan and consult employees on PHA, MOC, and other elements. Establish procedures for selecting, evaluating, and overseeing contractors. Issue hot work permits for non-routine work in or near covered processes.

Responding facilities

Facilities whose employees respond to releases must have a written emergency response plan that includes notification procedures, response procedures for releases, evacuation procedures, employee training, equipment maintenance, and program reviews.

Non-responding facilities

Facilities relying on community responders must coordinate with local emergency responders, ensure the facility is included in the community emergency response plan, and provide responders with the information needed to respond effectively.

LEPC and local responder coordination

Engage your Local Emergency Planning Committee (LEPC) early. Provide them with chemical inventory information (often required separately under EPCRA Section 312), worst-case scenario data, and points of contact. Document coordination meetings, drills, and exercises through emergency planning software.

What goes in the plan

The RMP itself summarizes the prevention program (it does not include all underlying documentation). Sections include facility identification, registration, executive summary, the 5-year accident history, prevention program data for each program level, emergency response program data, and certification by a senior official.

Submission timing

Initial RMP must be submitted within three years of becoming subject to RMP, or before any regulated substance is first present in a covered process above the TQ. After initial submission, the plan must be resubmitted at least every five years and within six months after specific triggering events.

Triggering events for early resubmission

Resubmission is triggered by: a newly regulated substance reaching threshold for the first time at a process; a change that renumbers a covered process to a new program level; an RMP-reportable accident; a change requiring revised PHA, hazard review, or offsite consequence analysis; a change to emergency response program elements; or any other change that revises the information in the RMP.

Recurring obligations

• 5-year RMP resubmission (rolling)
• 5-year PHA revalidation (Program 3)
• 3-year compliance audit cycle
• 3-year operator training refresh
• Annual operating procedure certification
• Ongoing 5-year accident history maintenance
• Periodic emergency response exercises

Triggering events that drive updates

• Any MOC that changes process safety information, PHA scope, or operating procedures
• An RMP-reportable accident
• A program level change (e.g., facility falls into PSM coverage)
• A new regulated substance reaching threshold
• Significant changes to the emergency response program