2. Topics
RMP*eSubmit Overview
Milestones
CDX Registration Process
RMP Data Entry & Submission Process
Publications
Q&A
2
3. EPA’s initiative for Web-based RMP submissions
Old System: RMP*Submit
RMP
Reporting Center
RMP*Submit
Lots of
Processing
RMP
Database
3
4. 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
4
5. EPA’s initiative for Web-based RMP submissions
New System: RMP*eSubmit
RMP Submission via the Internet
EPA’s Firewall
Central Data
Exchange
(CDX)
What about the
Certification Letter?
X
RMP
Replaced by a Database
one-time Electronic
Signature Agreement
5
6. 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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7. EPA’s initiative for Web-based RMP submissions
How the Electronic Signature Process Works
Facility
1. Owner/Operator
obtains Login
ID & Password
CDX
3. Reporting Center
connects CDX ID
Fill out the with one or more
Electronic RMP Facility IDs
Signature
2. Agreement Mail complete
ESA to the
Reporting
Center RMP
Reporting
Center
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8. 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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9. Steps to set up RMP*eSubmit access for a facility
Overview
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
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10. Steps to set up RMP*eSubmit access for a facility
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
10
11. Accessing CDX
Open Internet browser & navigate to:
https://cdx.epa.gov/
11
14. 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, not
a 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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27. 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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28. 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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41. 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. Preparer sets up their own CDX account
- Add Role: “Preparer” (using Authorization Code obtained from
Certifying Official)
5. Preparer enters RMP data for facility
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51. Print ALL pages
– Mail ALL pages
of the ESA to the
Reporting
Center!
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52. 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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53. 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. Preparer sets up their own CDX account
- Add Role: “Preparer” (using Authorization Code obtained from
Certifying Official)
5. Preparer enters RMP data for facility
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56. 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. Preparer sets up their own CDX account
- Add Role: “Preparer” (using Authorization Code obtained from
Certifying Official)
5. Preparer enters RMP data for facility
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61. 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. 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
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70. 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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71. When the error is
corrected, the error
message will
disappear.
The Preparer can
proceed to the next
data element.
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79. The RMP submission
The RMP submission
is The RMP submission
now awaiting
is is now awaiting
now awaiting
certification.
certification.
certification.
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98. 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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99. User is Preparing an
RMP “Correction.”
System prohibits
certain changes.
Changing some data
fields will trigger a
system warning.
99
100. The system prohibits
certain changes
during a Correction
(Preparer attempted to
change distance to
endpoint by more
than a factor of 2).
100
101. The system allows
this Correction if
distance to endpoint
changed by less than
a factor of 2.
101
105. 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)
105
106. 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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108. Thanks for participating!
Please visit
www.epa.gov/emergencies/rmp
for 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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