Rmp Presentation

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EPA’s initiative for Web-EPA’s initiative for Web-based RMP submissionsbased RMP submissions

RMP*eSubmitRMP*eSubmit

TopicsTopics

RMP*eSubmit OverviewRMP*eSubmit Overview MilestonesMilestones CDX Registration ProcessCDX Registration Process RMP Data Entry & Submission RMP Data Entry & Submission

ProcessProcess PublicationsPublications Q & AQ & A

EPA’s initiative for WEPA’s initiative for Web-basedeb-based RMP RMP submissionssubmissions

Current System: RMP*SubmitCurrent System: RMP*SubmitRMP

Reporting Center

RMP Database

Lots ofProcessing

RMP*Submit

EPA’s initiative for WEPA’s initiative for Web-basedeb-based RMP RMP submissionssubmissions

Disadvantages of RMP*SubmitDisadvantages of RMP*Submit

• Limited validationLimited validation

• Facilities often lose their last submissionFacilities often lose their last submission

• Heavy processing load with manual stepsHeavy processing load with manual steps

• Cumbersome mail back notification and resubmission Cumbersome mail back notification and resubmission

cyclecycle

• New Certification Letter required for each submissionNew Certification Letter required for each submission

• Security issue: mailing of sensitive dataSecurity issue: mailing of sensitive data

EPA’s initiative for WEPA’s initiative for Web-basedeb-based RMP RMP submissionssubmissions

New System: RMP*eSubmitNew System: RMP*eSubmitRMP Submission via the InternetRMP Submission via the Internet

RMP Database

EPA’s Firewall EPA’s Firewall

Central Data Exchange

(CDX)

What about the What about the Certification Certification

Letter? Letter?

XReplaced by a Replaced by a

one-time one-time Electronic Electronic Signature Signature

Agreement Agreement

EPA’s initiative for WEPA’s initiative for Web-basedeb-based RMP RMP submissionssubmissions

Central Data Exchange (CDX)Central Data Exchange (CDX)

• EPA’s secure portal for entering and retrieving EPA’s secure portal for entering and retrieving

informationinformation

• Many other data systems are currently using CDX:Many other data systems are currently using CDX:

AQS, eBeaches, eIUR, LEAD, NEI, NESHAPS, PMN, RCRA, SDWIS, AQS, eBeaches, eIUR, LEAD, NEI, NESHAPS, PMN, RCRA, SDWIS,

TRI-ME, TSCA, UCMR2, RMP*WebRC TRI-ME, TSCA, UCMR2, RMP*WebRC

• Facilities will use CDX to gain access to RMP*eSubmitFacilities will use CDX to gain access to RMP*eSubmit

• Facilities can use their existing CDX account, if they Facilities can use their existing CDX account, if they

have onehave one

RMP Reporting

Center

EPA’s initiative for WEPA’s initiative for Web-basedeb-based RMP RMP submissionssubmissions

How the Electronic Signature Process Will WorkHow the Electronic Signature Process Will Work

CDX

Fill out the Fill out the ElectronicElectronicSignatureSignatureAgreementAgreement

Facility Facility Owner/OperatoOwner/Operator obtains Loginr obtains LoginID & PasswordID & Password

1.

2.

Reporting Center Reporting Center connects CDX ID connects CDX ID with one or morewith one or moreRMP Facility IDsRMP Facility IDs

3.

Mail to Mail to Reporting Reporting CenterCenter

MilestonesMilestones

Launched RMP*eSubmit – Launched RMP*eSubmit – March 2009March 2009 Remove RMP*Submit from Web site ~ Remove RMP*Submit from Web site ~ July 2009July 2009 No longer accept submissions from RMP*Submit No longer accept submissions from RMP*Submit

~ ~ January 2010January 2010

1.1. Certifying Official sets up CDX account & registers for Certifying Official sets up CDX account & registers for

RMP*eSubmitRMP*eSubmit

- Add Program: “Risk Management Plan (RMPESUBMIT)”- Add Program: “Risk Management Plan (RMPESUBMIT)”

- Add Role/Program ID: “Certifying Official”- Add Role/Program ID: “Certifying Official”

2.2. Certifying Official completes Electronic Signature Agreement Certifying Official completes Electronic Signature Agreement

(ESA) via online form(ESA) via online form

- ESA includes list of facilities belonging to the Certifier- ESA includes list of facilities belonging to the Certifier

- Certifying Official prints and signs the ESA- Certifying Official prints and signs the ESA

- Certifying Official mails ESA to the RMP Reporting Center- Certifying Official mails ESA to the RMP Reporting Center

3.3. RC validates the ESA, sets up database access & e-mails RC validates the ESA, sets up database access & e-mails

Certifying Official an authorization code for a PreparerCertifying Official an authorization code for a Preparer

4.4. Preparer sets up their own CDX accountPreparer sets up their own CDX account

- Add Role: “Preparer” (using authorization code obtained - Add Role: “Preparer” (using authorization code obtained

from Certifying Official) from Certifying Official)

5.5. Preparer enters RMP data for facility Preparer enters RMP data for facility

Steps to set up RMP*eSubmit access for a facilitySteps to set up RMP*eSubmit access for a facilityOverviewOverview

1.1. Certifying Official sets up CDX account & registers for Certifying Official sets up CDX account & registers for

RMP*eSubmitRMP*eSubmit

- Add Program: “Risk Management Plan (RMPESUBMIT)”- Add Program: “Risk Management Plan (RMPESUBMIT)”

- Add Role/Program ID: “Certifying Official”- Add Role/Program ID: “Certifying Official”

2. Certifying Official completes Electronic Signature Agreement

(ESA) via online form

- ESA includes list of facilities belonging to the certifier

- Certifying Official prints and signs the ESA

- Certifying Official mails ESA to the RMP Reporting Center

3. RC validates the ESA, sets up database access & e-mails

Certifying Official an authorization code for a Preparer

4. Preparer sets up their own CDX account

- Add Role: “Preparer” (using authorization code obtained

from Certifying Official)

5. Preparer enters RMP data for facility

Steps to set up RMP*eSubmit access for a facility

Accessing CDXAccessing CDX

Open Internet browser and navigate Open Internet browser and navigate to: to:

https://cdx.epa.gov/https://cdx.epa.gov/ If you receive a “Certificate Error: If you receive a “Certificate Error:

Navigation Blocked” screen, override it by Navigation Blocked” screen, override it by clicking on “Continue to this website (not clicking on “Continue to this website (not recommended)”recommended)”

If you receive this message, click “Continue to this website…” to continue to CDX.

A few questions…A few questions…

Q: How do I find out if we already have a CDX Q: How do I find out if we already have a CDX account?account? A: Call the CDX Help Desk: 888-890-1995 A: Call the CDX Help Desk: 888-890-1995

NoteNote: A CDX account is associated with a specific person, : A CDX account is associated with a specific person, notnot a facility. a facility.

If a person at your facility has an account and they will be If a person at your facility has an account and they will be involved in RMP submissions, they can use that account.involved in RMP submissions, they can use that account.

But, if the person with the existing CDX account will But, if the person with the existing CDX account will notnot be be involved in RMP submissions, then the person who will certify involved in RMP submissions, then the person who will certify and/or prepare the RMP will need a CDX account.and/or prepare the RMP will need a CDX account.

Q: What if I can't remember my CDX User Name and Q: What if I can't remember my CDX User Name and

Password? Password? A: Call the CDX Help Desk: 888-890-1995 A: Call the CDX Help Desk: 888-890-1995

Registration Process for Registration Process for Facilities New to CDXFacilities New to CDX

Click here to register for RMP*eSubmit.

A person can register to A person can register to be a “Certifying Official” be a “Certifying Official” or a “Preparer” or both.or a “Preparer” or both.

A few questions…A few questions… Q: Can the owner/operator designate a position title instead Q: Can the owner/operator designate a position title instead

of of the name of the Certifying Official? the name of the Certifying Official?

A: No. They have to designate an actual person and a signature A: No. They have to designate an actual person and a signature is is

required.required.

Q: Does the highest ranking officer at the site complete the Q: Does the highest ranking officer at the site complete the "Certifying Official" requirements?"Certifying Official" requirements?

A: The Certifying Official can be the owner, plant manager, or a A: The Certifying Official can be the owner, plant manager, or a senior manager at the facility – they should be someone who senior manager at the facility – they should be someone who

can sign official documents.can sign official documents.

Q: Where can I find the definition of “Certifying Official?” Q: Where can I find the definition of “Certifying Official?” A: Page 1 of the A: Page 1 of the RMP*eSubmit Users’ ManualRMP*eSubmit Users’ Manual. .

The Preparer enters the data. The Preparer enters the data. The Certifier actually submits it. The Certifier actually submits it. Preparer and Certifier could be the same person.Preparer and Certifier could be the same person.

Registration Process for Registration Process for Facilities With an Existing CDX Facilities With an Existing CDX

AccountAccount

TRIME Web Certify

Submission Click here to add new Click here to add new account profile.account profile.

1. Certifying Official sets up CDX account & registers for

RMP*eSubmit

- Add Role: “Certifying Official”

2.2. Certifying Official completes Electronic Signature Agreement Certifying Official completes Electronic Signature Agreement

(ESA) via online form(ESA) via online form

- ESA includes list of facilities belonging to the certifier- ESA includes list of facilities belonging to the certifier

- Certifying Official prints and signs the ESA- Certifying Official prints and signs the ESA

- Certifying Official mails ESA to the RMP Reporting Center- Certifying Official mails ESA to the RMP Reporting Center

3. RC validates the ESA, sets up database access & e-mails

Certifying Official an authorization code for a Preparer

4. Preparer sets up their own CDX account

- Add Role: “Preparer” (using authorization code obtained

from Certifying Official)

5. Preparer enters RMP data for facility

Steps to set up RMP*eSubmit access for a facility

Certifying Official

A few questions…A few questions… Q: Can I send just the last page of the ESA?Q: Can I send just the last page of the ESA?

A: A: No!No! Send Send all pages all pages of the ESAof the ESA – – allall pages are pages are important!important!

Q: Can I fax the ESA?Q: Can I fax the ESA? A: No. Mail the original printed version of the ESA with the A: No. Mail the original printed version of the ESA with the

original original (wet ink) signatures. (wet ink) signatures.

Q: If I already have an ESA on file in CDX for other programs, Q: If I already have an ESA on file in CDX for other programs, will another ESA be required for RMP?will another ESA be required for RMP? A: Yes. Submit the ESA specifically for RMP*eSubmit. A: Yes. Submit the ESA specifically for RMP*eSubmit. And again, send And again, send allall pages of the ESA. pages of the ESA.

Q: How long does it take to get the AuthCode once the ESA Q: How long does it take to get the AuthCode once the ESA hashas been submitted?been submitted? A: Once received, processing could take a few days to a week.A: Once received, processing could take a few days to a week.

1. Certifying Official sets up CDX account & registers for

RMP*eSubmit

- Add Role: “Certifying Official”

2. Certifying Official completes Electronic Signature Agreement

(ESA) via online form

- ESA includes list of facilities belonging to the certifier

- Certifying Official prints and signs the ESA

- Certifying Official mails ESA to the RMP Reporting Center

3.3. RC validates the ESA, sets up database access & e-mails RC validates the ESA, sets up database access & e-mails

Certifying Official an authorization code for a PreparerCertifying Official an authorization code for a Preparer

4. Preparer sets up their own CDX account

- Add Role: “Preparer” (using authorization code obtained

from Certifying Official)

5. Preparer enters RMP data for facility

Steps to set up RMP*eSubmit access for a facility

1. Certifying Official sets up CDX account & registers for

RMP*eSubmit

- Add Role: “Certifying Official”

2. Certifying Official completes Electronic Signature Agreement

(ESA) via online form

- ESA includes list of facilities belonging to the certifier

- Certifying Official prints and signs the ESA

- Certifying Official mails ESA to the RMP Reporting Center

3. RC validates the ESA, sets up database access & e-mails

Certifying Official an authorization code for a Preparer

4.4. Preparer sets up their own CDX accountPreparer sets up their own CDX account

- Add Role: “Preparer” (using authorization code obtained - Add Role: “Preparer” (using authorization code obtained

from Certifying Official) from Certifying Official)

5. Preparer enters RMP data for facility

Steps to set up RMP*eSubmit access for a facility

Preparers complete CDX registration by entering an authorization code. The code is provided to the Certifier by e-mail from CDX

1. Certifying Official sets up CDX account & registers for

RMP*eSubmit

- Add Role: “Certifying Official”

2. Certifying Official completes Electronic Signature Agreement

(ESA) via online form

- ESA includes list of facilities belonging to the certifier

- Certifying Official prints and signs the ESA

- Certifying Official mails ESA to the RMP Reporting Center

3. RC validates the ESA, sets up database access & e-mails

Certifying Official an authorization code for a Preparer

4. Preparer sets up their own CDX account

- Add Role: “Preparer” (using authorization code obtained

from Certifying Official)

5.5. Preparer enters RMP data for facility Preparer enters RMP data for facility

Steps to set up RMP*eSubmit access for a facility

RMP Data Entry RMP Data Entry & the Submission Process& the Submission Process

This CDX User has registered as both Certifying Official and Preparer.

The system will catch some errors immediately after incorrect data is entered.

Here the Preparer forgot to put a minus sign on the facility longitude.

Other errors will be caught in the validation step.

When the error is corrected, no error message will appear. The Preparer can proceed to the next data element.

When the Preparer has completed entering information in all appropriate sections, they should click the “Validate” button.

These errors must be corrected before the RMP can be submitted

The Preparer’s final step is to submit the RMP to the Certifying Official.

The RMP submission is now awaiting certification.

(Logged in as Certifying Official)

View the RMP

RMP Resubmissions & RMP Resubmissions & CorrectionsCorrections

DefinitionsDefinitions A A CorrectionCorrection should be used to report should be used to report administrativeadministrative

or other changes at your facility (e.g. changes in or other changes at your facility (e.g. changes in emergency contact information, facility address, or emergency contact information, facility address, or changes in accident history.) This does not require an changes in accident history.) This does not require an update of your entire RMP. Submitting a corrected update of your entire RMP. Submitting a corrected RMP does RMP does notnot change your five-year anniversary date. change your five-year anniversary date. If your facility has not submitted an RMP Resubmission If your facility has not submitted an RMP Resubmission by its anniversary date, you will by its anniversary date, you will notnot be able to make an be able to make an RMP Correction – you RMP Correction – you mustmust submit an RMP submit an RMP Resubmission in this instance. The Correction button Resubmission in this instance. The Correction button enables you to enter data for your facility and update enables you to enter data for your facility and update the RMP as a Correction.the RMP as a Correction.

A A ResubmissionResubmission is an update of is an update of allall nine sections of nine sections of your RMP. Revising your previous RMP appropriately your RMP. Revising your previous RMP appropriately and submitting the updated RMP Resubmission will re-and submitting the updated RMP Resubmission will re-set your five-year anniversary date. The Resubmission set your five-year anniversary date. The Resubmission enables you to enter the data for your facility and enables you to enter the data for your facility and update the RMP as a Resubmission. update the RMP as a Resubmission.

User is Preparing an RMP “Correction”

Changing some data fields will trigger a system warning

System prohibits certain changes

The system prohibits certain changes during a correction (Preparer attempted to change distance to endpoint by more than a factor of 2)

The system allows this correction if distance to endpoint changed by less than a factor of 2

PublicationsPublications

Visit: Visit: www.epa.gov/emergencies/rmpwww.epa.gov/emergencies/rmp A Checklist for Submitting Your Risk Management A Checklist for Submitting Your Risk Management

Plan (RMP) for Chemical Accident PreventionPlan (RMP) for Chemical Accident Prevention RMP*eSubmit User’s ManualRMP*eSubmit User’s Manual RMP Fact SheetRMP Fact Sheet The General Duty Clause Fact SheetThe General Duty Clause Fact Sheet Chemical Emergency Preparedness and Chemical Emergency Preparedness and

Prevention in Indian CountryPrevention in Indian Country Updated RMP technical guidance documents Updated RMP technical guidance documents

(General guidance, industry sector guidance, (General guidance, industry sector guidance, OCA guidance)OCA guidance)

Webinar-specific Questions…Webinar-specific Questions…

Q: After the Webinar, can I get a copy of questions Q: After the Webinar, can I get a copy of questions

submitted?submitted? A: A list of frequent questions was sent to the participants A: A list of frequent questions was sent to the participants

prior to the Webinar. We continue to compile the Q & As prior to the Webinar. We continue to compile the Q & As and will post them to our Web site.and will post them to our Web site.

Q: Will I be able to get a copy of the Power Point Q: Will I be able to get a copy of the Power Point

presentation?presentation? A: Yes. It is a large file – we will send a link to an ftp site A: Yes. It is a large file – we will send a link to an ftp site

where you can download it.where you can download it.

Questions?Questions?

Thanks for participating!Thanks for participating!Please visitPlease visit

www.epa.gov/emergencies/rmpwww.epa.gov/emergencies/rmp for more informationfor more information

For RMP regulatory information, contact the

Superfund, TRI, EPCRA, RMP & Oil Information

Center (also known as the “Call Center”): 800-

424-9346.

For CDX account information, contact the CDX Help

Desk: 888-890-1995.

For RMP technical information, contact the RMP

Reporting Center: 703-227-7650.