Frequent Questions

Five-year accident history in initial RMP submission

The owner or operator of a stationary source subject to 40 CFR Part 68 must include a five-year accident history that includes significant accidental releases of one or more of the regulated substances from a covered process in the five years prior to the submission of an initial or updated Risk Management Plan (RMP) (§68.42(a)). Do newly constructed facilities need to complete the five-year accident history in their initial RMP submission?

If a facility has had no accidents meeting the rule's accident reporting criteria in the previous 5 years, it will not need to include information in the five-year accident history in their initial RMP submission. The five-year accident history only covers releases from a covered process involving a regulated substance held above its threshold quantity in the process. If a facility did not have any releases that meet this criterion, the plan preparer may want to explain the lack of any five-year accident history records in the Executive Summary of the plan. In RMP*eSubmit, newly constructed facilities, or any other facility that does not have any accidents to include in the five-year accident history, may simply leave this section blank.

If an accident occurs after the initial RMP submission that meets the reporting criteria, the plan must be corrected to include the accidental release in the five-year accident history within six months of the accident (§68.195). In addition, when an RMP is updated as required by §68.190, it must contain an updated five-year accident history including all of the accidents that meet the reporting criteria and that occurred within five years of the date on which the updated RMP is submitted.

 

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