A facility that uses a contractor to prepare its RMP must include in the registration section the name, mailing address, and telephone number of the contractor who prepared the RMP (40 CFR §68.160(b)(14)). When a contractor only prepares a portion of an RMP on behalf of a facility, does the facility have to include the contractor’s contact information in the RMP?
Contractor information is required only when a contractor prepares the entire RMP submission. When a facility uses a contractor’s services to assist in developing only portions of their risk management programs (e.g., the process hazard analysis, modeling for the off-site consequence analysis (OCA), or training), the requirement to include contractor information does not apply.
If a facility owner or operator prepares an RMP update and uses information from the previous RMP that a contractor prepared, the owner or operator is required to review the information to make sure it is current. Therefore, contractor information is not required because the owner or operator is preparing the RMP for this update.