What is the difference between an update and a correction to a risk management plan (RMP)?
Updates and resubmissions require the owner or operator to review and revise all sections of the RMP as needed to bring the RMP up to date and the submission must be accompanied by a letter certifying that the entire RMP is true, accurate, and complete. The five-year anniversary date for resubmitting the RMP is reset with any update and resubmission. By contrast, a correction changes only individual data entries in the RMP. Corrections may include clerical errors, minor administrative changes, or changes of ownership when covered process operations do not change. Corrections do not entail the review and revision of all nine sections of the RMP, nor do they affect the five-year anniversary date for updating and resubmitting the RMP (69 FR 18819, 18820; April 9, 2004).