If your facility stores or handles certain quantities of hazardous substances, you are likely subject to the EPA’s Risk Management Plan (RMP) Rule under Section 112(r) of the Clean Air Act. Vanguard helps industrial and chemical facilities comply with these stringent regulations by developing and maintaining comprehensive Risk Management Plans.
Our team of environmental compliance experts delivers strategic guidance, plan development, and agency coordination—keeping your business in full compliance while prioritizing the safety of your employees and community.
What Is RMP?
A Risk Management Plan (RMP) is a federally mandated disaster-prevention plan that outlines how your facility will prevent and respond to chemical accidents involving regulated substances. It includes:
- Offsite consequence analysis (OCA)
- Five-year accident history
- Prevention programs
- Emergency response programs
- Compliance audits and documentation
Facilities must submit their RMP to the EPA and often to state, county, and local authorities, depending on jurisdictional authority.
Who Is Subject to RMP Rule 112(r)?
You must comply with RMP requirements if your facility:
- Stores or uses any of the 258 regulated substances identified by the EPA.
- Exceeds threshold quantities (TQs) (e.g., 10,000 pounds of anhydrous ammonia, 20,000 pounds of propane).
- Substances must be connected to a process.
- Falls under one of the three RMP Program Levels, based on process complexity and public risk.
Industries frequently impacted include:
- Chemical manufacturing
- Agricultural facilities (fertilizer storage)
- Cold storage and food processing
- Petroleum refining
- Water and wastewater treatment plants
- Industry and Manufacturing (if substances are present in excess of TQs)
Vanguard’s RMP Compliance Services
We provide full-service, turnkey compliance management, including:
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RMP Development & Submission
- Conducting process hazard analyses (PHA)
- Modeling worst-case and alternative release scenarios
- Preparing and submitting the RMP via EPA’s RMP*eSubmit portal
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Program Level Determination
- Identifying applicable RMP Program Level (1, 2, or 3)
- Aligning prevention and emergency response programs accordingly
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Plan Updates & Revalidations
- Reviewing and updating plans every 5 years or when processes change
- Performing compliance audits and revalidations
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Emergency Response Coordination
- Preparing facility-specific emergency response plans
- Coordinating with Local Emergency Planning Committees (LEPCs)
- Supporting internal and community training exercises
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Employee Training
- Training staff on accident prevention, chemical handling, and emergency procedures
- Documenting training records for regulatory review
Why RMP Compliance Matters
RMP compliance is not just a regulatory obligation—it protects your facility, your employees, and your surrounding community against catastrophic chemical incidents.
Non-compliance can result in:
- Enforcement penalty polices of $124,000 per day per violation
- Regulatory enforcement actions
- Increased insurance premium costs
- Facility shutdowns or operating restrictions
Contact Vanguard for RMP Compliance Services
Risk Management Plan (RMP) compliance is essential for facilities handling hazardous substances under Section 112(r) of the Clean Air Act. Vanguard helps you meet EPA requirements through complete plan development, submission, and ongoing support—from modeling and audits to emergency coordination and training. Call (918) 641-5588 or contact us today to ensure your facility is prepared, compliant, and protected.