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Certifying Official Qualifying Criteria

The owner or operator of a stationary source must complete a statement certifying that the risk management plan (RMP) is accurate and complete (40 CFR §68.185), a function performed by the Certifying Official through RMP*eSubmit. Are there criteria for qualifying as a Certifying Official when submitting an RMP in RMP*eSubmit?

The regulations in Part 68 do not specify who should be a Certifying Official or that the individual must meet any eligibility criteria such as responsibility for a certain number of employees or budget levels. However, the Certifying Official is typically the facility owner or operator, or a designated senior management official employed by the facility such as a plant manager, environmental manager, or RMP manager. This person must have knowledge of what the individual is certifying to verify the accuracy and completeness of the RMP. In addition, the Certifying Official must have a Central Data Exchange (CDX) account and complete an Electronic Signature Agreement (ESA) to obtain the authorization code necessary to prepare and submit the RMP.