Risk Management Plan (RMP) Compliance

Risk Management Program Regulation Overview

As part of section 112(r) of the Clean Air Act, the Chemical Accident Prevention Provisions require facilities that produce, handle, process, distribute, or store certain chemicals to develop a Risk Management Program, prepare a Risk Management Plan (RMP), and submit the RMP to the EPA. Compliance with EPA's RMP requirements (40 CFR 68.130) for water and wastewater systems must address three key areas:

1. Prevention Program
2. RMP Hazard Assessment
3. Submittal Requirements

For various reasons, some individual states have implemented state-specific RMP requirements in addition to the federal requirements for these key areas. To further complicate matters, some states have been designated as OSHA-delegated states and others have been designated as EPA-delegated states, each with their own unique thresholds and compliance requirements. Water and wastewater treatment operators must be knowledgeable about the specific compliance requirements applicable to their facility. MHC’s expertise, automation technology, and understanding of the various federal and state-specific compliance standards can help you simplify and manage your risk management program.

What we do for you

We provide a cost-effective, hassle-free risk management program for all aspects of water and wastewater treatment facility compliance. Clients across the U.S. confirm the unique benefits of our RMP Compliance Service. The service consists of two components:

Initial Compliance Review and Set-Up:

1. Compliance Audit of each facility and treatment process
2. Hazard Assessment or Hazard Analysis as needed
3. Create and/or update all RMP written documentation, including:
   • Hazard Assessment or Hazard Analysis
   • RMP Prevention Program with all elements as required by EPA
   • Complete registration forms and electronic files using the most current version of EPA’s RMP Submit software
4. Set-up and training of designated personnel on use of the Compliance Alert Service
5. Secure, online storage of all RMP documents for access from any Internet connection

Ongoing Monthly Compliance Maintenance Services:

1. Regular contact to identify any operational change that might affect regulatory compliance and to review online Compliance Alert together
2. Ensuring compliance with the recurring requirements of the RMP standards, as needed, including:
   • Written Prevention Program updates
   • Compliance Audits and reports
   • Hazard Review/Analysis updates and reports
   • Operating Procedures updates and training materials
   • Written Hazard Assessment updates
3. Submitting EPA Registration updates
4. Conducting an annual RMP Compliance Audit of each water facility to verify compliance
5. Providing onsite support upon request in conjunction with an EPA or state inspection related to RMP
6. Providing a Compliance Guarantee to pay any fines resulting from MunicipalH2O’s errors or omissions