EPA’s Initiative for Web-based RMP Submissions

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

Old System: RMP*SubmitOld System: RMP*SubmitRMP

Reporting Center

RMP Database

Lots ofProcessing

RMP*Submit


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


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


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 use CDX to gain access to RMP*eSubmitFacilities 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


How the Electronic Signature Process WorksHow the Electronic Signature Process Works

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 Mail complete complete ESA to the ESA to the Reporting Reporting CenterCenter

MilestonesMilestones Launched RMP*eSubmit – Launched RMP*eSubmit – March 2009March 2009 Removed RMP*Submit 2004 from Web site – Removed RMP*Submit 2004 from Web site – July 2009July 2009

RMP*Submit 2004 software is no longer supportedRMP*Submit 2004 software is no longer supported

More than 6,700 transactions were submitted via More than 6,700 transactions were submitted via

RMP*eSubmit in 2009RMP*eSubmit in 2009 ~ 5,950 were First-time Submissions or Resubmissions~ 5,950 were First-time Submissions or Resubmissions ~ 750 were Corrections~ 750 were Corrections

No longer accept submissions from RMP*Submit 2004 – No longer accept submissions from RMP*Submit 2004 –

January 2010January 2010 CBI submissions via RMP*eSubmit – CBI submissions via RMP*eSubmit – Coming soon!Coming soon!

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


- 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 their facility Preparer enters RMP data for their 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


- 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 & navigate to: Open Internet browser & navigate to:

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

Blocked” screen, override it by clicking Blocked” screen, override it by clicking “Continue to this website (not recommended)”“Continue to this website (not 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 If a person at your facility has an account and they willwill be 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 But, if the person with the existing CDX account willwill notnot be be involved in RMP submissions, then the person who involved in RMP submissions, then the person who willwill certify 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 & Q: What if I can't remember my CDX User Name &

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.

Note: E-mail notifications Note: E-mail notifications are sent to both the “My are sent to both the “My CDX” inbox and to the CDX” inbox and to the personal e-mail address.personal e-mail address.

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

the name of the Certifying Official? the name of the Certifying Official? A: No. They have to designate an actual person (not a company) and a A: No. They have to designate an actual person (not a company) and a

signature is signature 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" "Certifying Official"

requirements?requirements? A: The Certifying Official can be the owner, plant manager, or a senior 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 manager at the facility – they should be someone who can sign official documents.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 Certifying Official approves and submits the RMP. The Certifying Official approves and submits the RMP. Preparer and Certifying Official could be the same person.Preparer and Certifying Official could be the same person.

Q: What if our “Certifying Official” changes/leaves the facility?Q: What if our “Certifying Official” changes/leaves the facility? A: They must inform the Help Desk (888-890-1995) to deactivate the A: They must inform the Help Desk (888-890-1995) to deactivate the

Certifying Official’s account. Certifying Official’s account.

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.

Click here to register for RMP*eSubmit.

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








Certifying Official

Verify that the information is correct and PRINT ALL PAGES.

This document is legally binding.

Print ALL pages – Mail ALL pages of the ESA to the Reporting Center!

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 ALL PAGES OF THE ESA!SEND ALL PAGES OF THE ESA! ALL PAGES ARE IMPORTANT AND LEGALLY BINDING!ALL PAGES ARE IMPORTANT AND LEGALLY BINDING!

Q: Can I fax the ESA?Q: Can I fax the ESA? A: A: No!No! Mail the original printed version of the ESA with the original (wet ink) signatures. 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 Q: If I already have an ESA on file in CDX for other programs, will another ESA ESA be required for RMP?be required for RMP?

A: Yes. Submit the ESA specifically for RMP*eSubmit. And again, send A: Yes. Submit the ESA specifically for RMP*eSubmit. And again, send allall pages of the ESA. pages of the ESA.

Q: How long does it take to get the Authorization Code once the ESA has Q: How long does it take to get the Authorization Code once the ESA has

been submitted?been submitted? A: Once received, processing could take a few days to a week before you receive the A: Once received, processing could take a few days to a week before you receive the

AuthCode. AuthCode. Don’t wait to the last minute to send your ESA.Don’t wait to the last minute to send your ESA.

Q: We sent an ESA with incorrect information. Should we send another ESA?Q: We sent an ESA with incorrect information. Should we send another ESA? A:A: No!No! Contact the Reporting Center (703-227-7650) for instructions. Contact the Reporting Center (703-227-7650) for instructions.


RMP*eSubmit







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







RMP*eSubmit









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)



Preparers complete CDX registration by entering an Authorization Code.

The code is provided to the Certifying Official by e-mail from CDX.


RMP*eSubmit












5.5. Preparer enters RMP data for their facility Preparer enters RMP data for their 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, the error message will disappear.

The Preparer can proceed to the next data element.

After the Preparer has completed entering information in all appropriate sections, they will then 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

…then Certify or Reject.

e-Signature page: the Certifying Official verifies that the information is correct.

RMP Resubmissions & RMP Resubmissions & CorrectionsCorrections

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

or other changesor other changes at your facility (e.g. changes in 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 RMPyour RMP. Revising your previous RMP appropriately . 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 A Checklist for Submitting Your Risk

Management Plan (RMP) for Chemical Accident Management Plan (RMP) for Chemical Accident PreventionPrevention

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 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: Can I get a copy of frequently asked questions?Q: Can I get a copy of frequently asked questions? A: A list of frequent questions and answers was sent to A: A list of frequent questions and answers was sent to

the participants prior to the Webinar. the participants prior to the Webinar. If you did not receive the frequent questions and answers, If you did not receive the frequent questions and answers,

please contact Kristine Mikulka: [email protected] contact Kristine Mikulka: [email protected]

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.

http://www.epa.gov/emergencies/rmp

EPA’s Initiative for Web-based RMP Submissions

Documents

Transcript of EPA’s Initiative for Web-based RMP Submissions