If your facility was required to submit a Risk Management Plan (RMP) for a Program 2 or Program 3 process, you must announce and hold a public meeting by February 1, 2000. Certification that this meeting was held must be submitted to the Federal Bureau of Investigation (FBI) by June 5, 2000.
The purpose of the public meeting is to describe and discuss the local implications of the facility’s RMP, including a summary of off-site consequence analysis information. The meeting can be held in coordination with the local emergency planning commission, other local public officials, or in conjunction with another nearby facility. Facilities meeting the definition of “small business stationary source” can opt to publicly post a summary of the off-site consequence analysis instead of holding the meeting.
This public meeting requirement is the result of the Chemical Safety Information, Site Security and Fuels Regulatory Relief Act (PL 106-40), which primarily concerns the public availability of the Off-site Consequence Analysis sections of Risk Management Plans (RMPs) under regulations implementing Section 112(r) of the Clean Air Act. The act was signed into law by President Clinton on August 5, 1999.
Update 2004
All facilities who submitted their initial RMPs on or before the original June 21, 1999 deadline resubmitted and updated their RMPs by June 21, 2004. This scenario applies to the majority of facilities who must submit RMPs. If however, a facility has updated its RMP after June of 1999, they must update it and resubmit it to the EPA five years after the postmark date of the latest submission. In preparation for the June, 2004 deadline, the EPA issued the final rule of the RMP reporting requirements in March. The rule includes additional requirements to the 1999 rule such as the addition of reporting several new data elements. A new version of RMP*Submit (EPA’s software for RMP submission) was released in April. For further information about new requirements or when you must next resubmit your facilities RMP, please visit this EPA site
EES can help you meet these public-meeting requirements under 112(r) RMP. We can help you publicize and plan the meeting, summarize your off-site consequence analysis information, and prepare FBI certification. Contact us at 215-881-9401.