What the Risk Management Program requires

Under section 112(r) of the Clean Air Act, EPA's Risk Management Program rule — 40 CFR Part 68 — applies to stationary sources with more than a threshold quantity of a regulated toxic or flammable substance in a process. Covered facilities must develop a risk management program and submit a Risk Management Plan to EPA, generally updating it at least every five years or sooner after certain changes.

Where OSHA's PSM standard focuses on protecting workers, RMP extends attention to the surrounding community and environment. Its core components are:

Hazard assessment — worst-case and alternative release scenarios with off-site consequence analysis, and a five-year accident history.
Prevention program — scaled by program level, and closely aligned with PSM for Program 3 processes.
Emergency response program — coordination with local responders, and for some facilities a full emergency response plan and exercises.
Management system — clear assignment of responsibility for the program.
Risk Management Plan — submitted electronically to EPA.

Program levels

RMP program levels (summary)
Program	General eligibility	Prevention requirements
Program 1	No public receptors within the worst-case release distance and no qualifying accidents with off-site consequences in the past five years.	Limited; certification that the criteria are met, plus emergency response coordination.
Program 2	Processes not eligible for Program 1 and not subject to Program 3.	Streamlined prevention program, including a hazard review.
Program 3	Processes not eligible for Program 1 that are subject to OSHA PSM or fall in specified industry (NAICS) codes.	Full prevention program closely mirroring OSHA PSM, including a PHA.

Rule status: a regulation in transition

RMP has been amended several times, and facilities need to track which requirements apply and when.

2024 — Safer Communities by Chemical Accident Prevention (SCCAP) rule
EPA finalized amendments adding, among other things, safer technology and alternatives analysis (STAA) for certain Program 3 processes in NAICS 324 and 325, third-party audits after certain accidents, root cause analysis requirements, expanded employee participation and greater information availability. Many provisions carry a compliance date of May 10, 2027.
2025 — Reconsideration announced
In March 2025, EPA announced it would reconsider the 2024 rule.
February 2026 — "Common Sense Approach to Chemical Accident Prevention" proposed rule
EPA proposed rescinding or narrowing many 2024 provisions — including most STAA, third-party audit, employee participation and information availability requirements — while retaining others. The public comment period closed on May 11, 2026.
Now
As of our last review (November 2026), EPA had not issued a final rule. The 2024 amendments remain the regulation in effect until a final rule changes them.

Plan for both outcomes

Because final requirements and compliance dates could change, we help clients prioritize work that is valuable under any outcome — sound hazard analysis, root cause investigation and emergency coordination — while monitoring rulemaking. Always confirm current requirements on EPA's RMP pages.

How we help

Applicability & program level

Inventory review against 40 CFR 68.130 thresholds, process definition and documented program-level determinations.

Off-site consequence analysis

Worst-case and alternative release scenarios using EPA guidance or dispersion modeling, with clear documentation of assumptions.

Prevention program

PHA or hazard review, procedures, training, mechanical integrity, MOC, PSSR, audits and incident investigation.

Emergency response & plan updates

Responder coordination, exercise planning and support preparing Risk Management Plan updates and corrections.

RMP and PSM together

For most Program 3 facilities, RMP and PSM share one set of process safety activities. We design programs so that a single PHA, MOC system and audit satisfy both rules where requirements align, and we flag where they differ — for example, RMP's off-site consequence analysis, accident history reporting and plan submission.

Typical deliverables

Applicability and program-level determination memo
Hazard assessment and off-site consequence analysis documentation
Prevention program and emergency response gap assessment
Risk Management Plan update support
Compliance audit report
Regulatory change briefing tailored to your facility

Frequently asked questions

How often must a Risk Management Plan be updated?

At least once every five years, and earlier when certain changes occur, such as a new regulated substance above threshold, a change requiring a revised PHA or hazard review, or a change in program level. Specific triggers are listed in 40 CFR 68.190.

Does hiring a consultant guarantee compliance?

No. Compliance remains the owner or operator's responsibility. We provide engineering analysis, documentation and recommendations; implementation and ongoing performance rest with the facility.

Is ammonia refrigeration covered by RMP?

Anhydrous ammonia is a regulated toxic substance with a 10,000-pound threshold under RMP. Many refrigeration facilities above that quantity are covered, often under Program 3 because they are also subject to PSM.

EPA Risk Management Program (RMP)