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Submitting Annual Certification for Operating Procedures to EPA

The owner or operator of a facility who must prepare a Risk Management Plan (RMP) for a Program 3 process is required to develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in each covered process consistent with the process safety information (40 CFR §68.69(a)). The owner or operator shall certify annually that these operating procedures are current and accurate (§68.69(c)). Does this require the owner or operator to submit an annual update or certification to EPA or the implementing agency?

The EPA does not require RMP-regulated facilities to submit an annual update or certification of operating procedures to the agency. However, RMP-regulated facilities must submit, in RMP*eSubmit, the date of the most recent review or revision of operating procedures upon submission of a first-time RMP, pursuant to §68.10, and during subsequent RMP re-submissions, pursuant to §68.190. RMP-regulated facilities can submit an updated date of the most recent review or revision of operating procedures at any time by completing a correction of the RMP in RMP*eSubmit.

Additional information on Program Level 3 operating procedure requirements can be found in Chapter 7, page 7-9, of the General Guidance on Risk Management Programs for Chemical Accident Prevention (40 CFR Part 68) (EPA550-B-04-001). This document is available at the following URL: