rmp e-submit webinar presentation
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EPA’s Initiative for Web-based RMP Submissions
RMP*eSubmit
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Topics
RMP*eSubmit Overview Milestones CDX Registration Process RMP Data Entry & Submission Process Publications Q & A
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EPA’s initiative for Web-based RMP submissions
Old System: RMP*SubmitRMP
Reporting Center
RMP Database
Lots ofProcessing
RMP*Submit
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EPA’s initiative for Web-based RMP submissions
Disadvantages of RMP*Submit
• Limited validation
• Facilities often lose their last submission
• Heavy processing load with manual steps
• Cumbersome mail back notification and resubmission cycle
• New Certification Letter required for each submission
• Security issue: mailing of sensitive data
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EPA’s initiative for Web-based RMP submissions
New System: RMP*eSubmitRMP Submission via the Internet
RMP Database
EPA’s Firewall
Central Data Exchange
(CDX)
What about the Certification Letter?
XReplaced by a
one-time Electronic Signature Agreement
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EPA’s initiative for Web-based RMP submissions
Central Data Exchange (CDX)
• EPA’s secure portal for entering and retrieving information
• Many other data systems are currently using CDX:
AQS, eBeaches, eIUR, LEAD, NEI, NESHAPS, PMN, RCRA, SDWIS,
TRI-ME, TSCA, UCMR2, RMP*WebRC
• Facilities use CDX to gain access to RMP*eSubmit
• Facilities can use their existing CDX account, if they have one
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RMP Reporting
Center
EPA’s initiative for Web-based RMP submissions
How the Electronic Signature Process Works
CDX
Fill out the ElectronicSignatureAgreement
Facility Owner/Operator obtains LoginID & Password
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Reporting Center connects CDX ID with one or moreRMP Facility IDs
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Mail complete ESA to the Reporting Center
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Milestones
Launched RMP*eSubmit – March 2009
Removed RMP*Submit 2004 from Web site –July 2009 RMP*Submit 2004 software is no longer supported
Approximately 10,860 transactions have been submitted via RMP*eSubmit
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1. Certifying Official sets up CDX account & registers for RMP*eSubmit- Add Program: “Risk Management Plan (RMPESUBMIT)”- 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 their facility
Steps to set up RMP*eSubmit access for a facilityOverview
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1. Certifying Official sets up CDX account & registers for RMP*eSubmit- Add Program: “Risk Management Plan (RMPESUBMIT)”- 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
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Accessing CDX
Open Internet browser & navigate to:
https://cdx.epa.gov/
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A few questions…
Q: How do I find out if we already have a CDX account? A: Call the CDX Help Desk: 888-890-1995
Note: A CDX account is associated with a specific person, nota facility. If a person at your facility has an account and they will be involved in
RMP submissions, they can use that account. But, if the person with the existing CDX account will not be involved in
RMP submissions, then the person who will certify and/or prepare the RMP will need a CDX account.
Q: What if I can't remember my CDX User Name & Password? A: Call the CDX Help Desk: 888-890-1995
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Registration Process for Facilities New to CDX
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Click here to register for RMP*eSubmit.
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A person can register to be a “Certifying Official” or a “Preparer” or both.
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Note: E-mail notifications are sent to both the “My CDX” inbox and to the personal e-mail address.
E-mails sent from EPA CDX contain important information concerning your RMP. Please be sure to read them.
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A few questions… Q: Can the owner/operator designate a position title instead of
the name of the Certifying Official? A: No. They have to designate an actual person (not a company) and a signature is
required.
Q: Does the highest ranking officer at the site complete the "Certifying Official" requirements?
A: The Certifying Official can be the owner, plant manager, or a senior manager at the facility – they should be someone who can sign official documents.
Q: Where can I find the definition of “Certifying Official?” A: Page 1 of the RMP*eSubmit Users’ Manual.
The Preparer enters the data. The Certifying Official approves and submits the RMP. Preparer and Certifying Official could be the same person.
Q: What if our “Certifying Official” changes/leaves the facility? A: They must inform the Help Desk (888-890-1995) to deactivate the Certifying
Official’s account.
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Registration Process for Facilities With an Existing CDX Account
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TRIME Web: Certify Submission
Click here to add new account profile.
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Click here to register for RMP*eSubmit.
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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. Preparer enters RMP data for facility
Steps to set up RMP*eSubmit access for a facility
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Certifying Official
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Verify that the information is correct and PRINT ALL PAGES.
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This document is legally binding.
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Print ALL pages – Mail ALL pages of the ESA to the Reporting Center!
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A few questions… Q: Can I send just the last page of the ESA?
A: No! SEND ALL PAGES OF THE ESA!ALL PAGES ARE IMPORTANT AND LEGALLY BINDING!
Q: Can I fax the ESA? A: No! Mail the original printed version of the ESA with the original (wet ink) signatures.
Q: If I already have an ESA on file in CDX for other programs, will another ESA be required for RMP?
A: Yes. Submit the ESA specifically for RMP*eSubmit. And again, send all pages of the ESA.
Q: How long does it take to get the Authorization Code once the ESA has been submitted?
A: Once received, processing could take a few days to a week before you receive the AuthCode.
Don’t wait to the last minute to send your ESA.
Q: We sent an ESA with incorrect information. Should we send another ESA? A: No! Contact the Reporting Center (703-227-7650) for instructions.
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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. Preparer enters RMP data for facility
Steps to set up RMP*eSubmit access for a facility
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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. Preparer enters RMP data for facility
Steps to set up RMP*eSubmit access for a facility
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Preparers complete CDX registration by entering an Authorization Code.
The code is provided to the Certifying Official by e-mail from CDX.
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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. Preparer enters RMP data for their facility
Steps to set up RMP*eSubmit access for a facility
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RMP Data Entry & the Submission Process
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This CDX User has registered as both Certifying Official and Preparer.
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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.
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When the error is corrected, the error message will disappear.
The Preparer can proceed to the next data element.
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After the Preparer has completed entering information in all appropriate sections, they will then click the “Validate” button.
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These errors must be corrected before the RMP can be submitted.
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The Preparer’s final step is to submit the RMP to the Certifying Official.
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The RMP submission is now awaiting certification.
The RMP submission is now awaiting certification.
The RMP submission is now awaiting certification.
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(Logged in as Certifying Official)
View the RMP…then Certify or Reject.
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e-Signature page: the Certifying Official verifies that the information is correct.
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RMP Resubmissions & Corrections
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Definitions A Correction should be used to report administrative or
other changes at your facility (e.g. changes in emergency contact information, facility address, or changes in accident history.) This does not require an update of your entire RMP. Submitting a corrected RMP does not change your five-year anniversary date. If your facility has not submitted an RMP Resubmission by its anniversary date, you will not be able to make an RMP Correction – you must submit an RMP Resubmission in this instance. The Correction button enables you to enter data for your facility and update the RMP as a Correction.
A Resubmission is an update of all nine sections of your RMP. Revising your previous RMP appropriately and submitting the updated RMP Resubmission will re-set your five-year anniversary date. The Resubmission enables you to enter the data for your facility and update the RMP as a Resubmission.
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User is Preparing an RMP “Correction.”
Changing some data fields will trigger a system warning.
System prohibits certain changes.
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The system prohibits certain changes during a Correction (Preparer attempted to change distance to endpoint by more than a factor of 2).
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The system allows this Correction if distance to endpoint changed by less than a factor of 2.
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Publications
Visit: www.epa.gov/emergencies/rmp A Checklist for Submitting Your Risk Management
Plan (RMP) for Chemical Accident Prevention RMP*eSubmit User’s Manual RMP Fact Sheet The General Duty Clause Fact Sheet Updated RMP technical guidance documents (General
guidance, industry sector guidance, OCA guidance)
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Webinar-specific Questions…
Q: Can I get a copy of frequently asked questions? A: A list of frequent questions and answers was sent to the
participants prior to the Webinar. If you did not receive the frequent questions and answers, please
contact Kristine Mikulka: Kristine_Mikulka@sra.com
Q: Will I be able to get a copy of the Power Point presentation?
A: Yes. It is a large file – we will send a link to an ftp site where you can download it. Please download the file within one week of receiving the e-mail link.
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Questions?
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Thanks for participating!Please visit
www.epa.gov/emergencies/rmpfor 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.
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