RMP*eSubmit is EPA's free web-based application for electronically filing the Risk Management Plan required under 40 CFR Part 68. It is the only authorized method for submitting an RMP — EPA does not accept paper submissions. Access runs through EPA's Central Data Exchange (CDX). This guide walks through the full submission process: account setup, role assignment, the section-by-section workflow, certification, common validation errors, and the events that trigger early resubmission. Whether you're filing for the first time or your 5-year resubmission, the steps below will help avoid the delays and errors that most often hold up RMP submissions.
Initial Setup: CDX and RMP*eSubmit Accounts
Before any plan can be submitted, the people involved must have CDX accounts with the appropriate RMP*eSubmit roles. The certifying official, in particular, must complete CDX's electronic signature agreement — a step that includes identity verification and can take several business days.
Step 1: Register for CDX
Go to cdx.epa.gov and create a CDX user account. Provide your name, organization, business email, and a security profile. CDX will require you to select an EPA program; for RMP, choose the Risk Management Plan (RMP*eSubmit) program service.
Step 2: Choose your role
RMP*eSubmit defines three role types:
- Certifying Official. A senior official with authority to certify that the RMP is true, accurate, and complete. Must complete the CDX electronic signature agreement (eSign) and identity proofing.
- Preparer. Anyone authorized to enter or edit data on behalf of the facility. Cannot certify or submit but can prepare a plan and route it to the certifying official.
- Viewer. Read-only access. Useful for compliance staff, auditors, and legal reviewers who need to review submissions but should not edit or submit.
Step 3: Identity proofing for the certifying official
Certifying officials must verify their identity through CDX's LexisNexis-based identity proofing or by submitting a paper electronic signature agreement. Identity proofing is instant if successful but can fail if your address or credit history doesn't match available records, in which case you fall back to the paper agreement (typically 5 to 10 business days).
Step 4: Link the account to your facility
Each facility in RMP*eSubmit is identified by its EPA Facility ID. New facilities are assigned an ID at first submission. Existing facilities have an ID from prior submissions, which preparers and certifying officials must request access to within CDX.
The Submission Workflow
Once accounts are in place, the submission workflow is straightforward but data-intensive. Most of the work is collecting and validating the underlying facility data, not navigating the portal.
Standard workflow
- Log in to CDX and select the RMP*eSubmit application
- Open the facility by EPA Facility ID (or create a new one for first submissions)
- Import or create the RMP — resubmissions can pre-populate from the prior submission
- Complete each section of the plan (registration, executive summary, OCA, prevention program, emergency response, accident history)
- Validate the plan using the built-in validation checks
- Resolve errors and warnings before forwarding to the certifying official
- Forward to the certifying official for review
- Certify and submit using the certifying official's CDX credentials
- Save the confirmation — transaction ID, date, and PDF copy of the submitted RMP
Section-by-Section Walkthrough
RMP*eSubmit is organized in sections that mirror the Risk Management Plan's required content under 40 CFR 68.150 through 68.185. Below is what to expect in each.
Section 1: Registration
Facility identifying information — name, address, latitude/longitude, owner/operator, parent company, NAICS codes, EPA Facility ID, Dun & Bradstreet number, FRS ID. Also captures the number of full-time employees, OSHA PSM coverage status, and whether the facility is in a CAA Title V air permit program.
Section 2: Toxics Worst-Case
For each regulated toxic substance above its TQ, document the worst-case release scenario: substance, scenario type (gas, liquid evaporation, gas liquefied under refrigeration), quantity released, release rate, release duration, distance to toxic endpoint, residential population within the distance, and a free-text scenario description. See our guide to offsite consequence analysis for modeling guidance.
Section 3: Toxics Alternative Releases
For Program 2 and Program 3 processes, document at least one alternative release scenario per regulated toxic substance. Same data fields as worst-case, but reflecting more likely release scenarios with active mitigation.
Section 4: Flammables Worst-Case
For each regulated flammable substance above the 10,000 lb TQ, document the worst-case release: vapor cloud explosion model, quantity released, distance to 1 psi overpressure endpoint, and residential population within the distance.
Section 5: Flammables Alternative Releases
One collective alternative scenario for flammables (Program 2 and 3 processes), reflecting more likely release events with mitigation.
Section 6: Five-Year Accident History
Each accidental release of a regulated substance from a covered process during the prior five years that resulted in deaths, injuries, significant property damage on-site, or known offsite consequences. See our accident history guide for reportability criteria and required information.
Section 7: Prevention Program (Program 2 or Program 3)
Per-process data describing the prevention program. Program 3 requires entries for PHA dates, expected revalidation, training dates, MOC procedures, MI procedures, and so on. Program 2 has a streamlined version. See our program levels guide for the differences.
Section 8: Emergency Response
Whether the facility responds to releases with its own employees, the date of the most recent emergency response plan review, the date of the most recent emergency response training, and a description of coordination with local responders and the LEPC.
Section 9: Executive Summary
A free-text narrative covering the facility, regulated substances and quantities, OCA highlights, the prevention program, emergency response, planned changes to improve safety, and accident history. The executive summary becomes part of the public RMP record.
Validation, Errors, and Warnings
RMP*eSubmit runs a built-in validation pass before allowing submission. Errors must be resolved; warnings can be acknowledged but should be reviewed.
Common errors
- Missing required field (e.g., quantity released, distance to endpoint, NAICS code)
- Invalid format (latitude or longitude out of range, ZIP code wrong length)
- Cross-section inconsistencies (process listed in OCA not appearing in prevention program)
- Missing certifying official assignment
- Accident history flagged but no accident records entered
Common warnings
- Worst-case distance exceeds typical range for the substance and quantity
- Population estimate appears unusually low or high
- Prevention program review date older than would be expected
- Worst-case scenario type unusual for the substance
Certification and Submission
The certifying official's review
The certifying official is responsible for reviewing the entire RMP and certifying that it is true, accurate, and complete to the best of their knowledge. Do not treat this as a rubber-stamp step. Common review focus areas: registration accuracy, OCA inputs, accident history completeness, executive summary alignment with internal records, and any new or removed processes since the prior submission.
Electronic signature
Submission requires the certifying official's CDX password and an answer to one of their security questions. The combination acts as their electronic signature under EPA's Cross-Media Electronic Reporting Rule (CROMERR).
Confirmation and copy of record
Successful submissions return a transaction ID and a downloadable PDF copy of the submitted plan. Save both. The PDF is your record of what was submitted; the transaction ID is required for support cases and future modifications.
After Submission
Public access
Most of the RMP becomes part of the public record once submitted. The OCA-related data section is restricted (accessible to qualified federal officials and limited state and local responders) but most of the rest is publicly available through EPA's RMP database. Plan accordingly — what's in the executive summary will be read by neighbors, NGOs, and journalists.
Confirmation email and audit trail
CDX sends a confirmation email after submission. Save it with your transaction ID and PDF. EPA inspectors typically request these during audits to verify timely submission.
Resubmission Cycle and Triggering Events
The RMP must be resubmitted at least every five years and within six months after specific triggering events.
Routine 5-year resubmission
The clock starts on the date of initial submission. Resubmission must occur within five years of the most recent full submission. Many facilities resubmit slightly early to avoid scheduling pressure.
Triggering events for early resubmission
- A newly regulated substance is first present above its TQ in a covered process
- A regulated substance is first present above its TQ in an additional covered process
- A change requires revised PHA, hazard review, or OCA
- A change to emergency response program elements
- A change in NAICS code that affects program level
- A change that places a process under or removes it from PSM coverage
- An RMP-reportable accident with offsite consequences
Submission deadline: within six months of the triggering event for substantive changes, or within six months for RMP-reportable accidents.
How Software Streamlines RMP Submission
Most of the friction in RMP submission comes from data collection — chasing down the prevention program element status, accident history, OCA results, and emergency response details from disparate spreadsheets, file shares, and email threads. EHS software solves the data collection problem by holding all the underlying records in one structured system.
What Ecesis tracks that maps to RMP*eSubmit fields
- Chemical inventories with maximum quantities by process for TQ comparison and registration
- OCA results with model inputs, distances, and population estimates linked to each scenario
- PHA records with completion dates and revalidation due dates for each process
- Training completion for operators and contractors
- MOC records with implementation dates and status
- MI inspection completion for each piece of covered equipment
- Compliance audits with most-recent dates and findings
- Incident investigations with reportability flags for accident history
- Emergency response plans with review dates, training dates, and LEPC coordination
What this means at submission time
Instead of pulling data from twelve different sources and reconciling inconsistencies, the certifying official sees a structured pre-submission report showing every RMP*eSubmit field with its current value, the source record, and the date of last verification. Submission becomes a review step rather than a research project.
Ecesis Software for RMP Submission
EPA RMP Software
Structured data feeding RMP*eSubmit fields directly
Compliance Calendar
5-year resubmission deadlines and triggering event tracking
Management of Change
Catch resubmission triggers at the MOC review stage
Incident Management
Accident history with RMP-reportable flags
Hazard Analysis
PHA records with revalidation dates for prevention program data
Document Management
Process safety information feeding the RMP record
