What if the quantity in the process fluctuates? I may not have a threshold quantity now, but I will intermittently exceed the threshold quantity.
You do not need to comply with the rule and file an RMP unless you have more than threshold quantity in a process; however, once you have more than threshold quantity in a process, you must be in compliance immediately. In this situation, with fluctuating quantities, it may be prudent to file now, so you will be in compliance when your quantity exceeds the threshold. You may also want to consider a “predictive filing” (see Chapter 9 of the General Guidance On Risk Management Programs For Chemical Accident Prevention (40 CFR Part 68) for more information on predictive filing).