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RMP*eSubmit

EPA’s initiative for Web-


based RMP submissions
Topics
 RMP*eSubmit Overview
 Milestones
 CDX Registration Process
 RMP Data Entry & Submission
Process
 Publications
 Q&A
EPA’s initiative for Web-based RMP
submissions
Current System: RMP*Submit
RMP
Reporting Center
RMP*Submit

Lots of
Processing

RMP
Database
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
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
X
Letter? RMP
Replaced by a Database
one-time
Electronic
Signature
Agreement
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 will use CDX to gain access to RMP*eSubmit

• Facilities can use their existing CDX account, if they

have one
EPA’s initiative for Web-based RMP
submissions
How the Electronic Signature Process Will Work
Facility
1. Owner/Operato
r 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 to
Reporting
Center RMP
Reporting
Center
Milestones
 Launched RMP*eSubmit – March 2009
 Remove RMP*Submit from Web site ~ July 2009
 No longer accept submissions from RMP*Submit
~ January 2010
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”
1. 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
1. RC validates the ESA, sets up database access & e-mails
Certifying Official an authorization code for a Preparer
2. Preparer sets up their own CDX account
- Add Role: “Preparer” (using authorization code obtained
from Certifying Official)
1. 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 Program: “Risk Management Plan (RMPESUBMIT)”
- Add Role/Program ID: “Certifying Official”
1. 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
1. RC validates the ESA, sets up database access & e-mails
Certifying Official an authorization code for a Preparer
2. Preparer sets up their own CDX account
- Add Role: “Preparer” (using authorization code obtained
from Certifying Official)
1. Preparer enters RMP data for facility
Accessing CDX
 Open Internet browser and navigate
to:
https://cdx.epa.gov/
 If you receive a “Certificate Error:
Navigation Blocked” screen, override it by
clicking on “Continue to this website (not
recommended)”
If you receive this message,
click “Continue to this
website…” to continue to
CDX.
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 and
Password?
 A: Call the CDX Help Desk: 888-890-1995
Registration Process for
Facilities New to CDX
Click here to register
for RMP*eSubmit.
A person can register to
be a “Certifying Official”
or a “Preparer” or both.
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 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 Certifier actually submits it.
 Preparer and Certifier could be the same person.
Registration Process for
Facilities With an Existing CDX
Account
TRIME Web Certify
Submission Click here to add new
account profile.
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”
1. 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
1. RC validates the ESA, sets up database access & e-mails
Certifying Official an authorization code for a Preparer
2. Preparer sets up their own CDX account
- Add Role: “Preparer” (using authorization code obtained
from Certifying Official)
1. Preparer enters RMP data for facility
Certifying
Official
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!

 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 AuthCode once the ESA has
been submitted?
 A: Once received, processing could take a few days to a week.
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”
1. 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
1. RC validates the ESA, sets up database access & e-mails
Certifying Official an authorization code for a Preparer
2. Preparer sets up their own CDX account
- Add Role: “Preparer” (using authorization code obtained
from Certifying Official)
1. 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”
1. 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
1. RC validates the ESA, sets up database access & e-mails
Certifying Official an authorization code for a Preparer
2. Preparer sets up their own CDX account
- Add Role: “Preparer” (using authorization code obtained
from Certifying Official)
1. Preparer enters RMP data for facility
Preparers complete
CDX registration by
entering an
authorization code.
The code is provided to
the Certifier by e-mail
from CDX
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”
1. 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
1. RC validates the ESA, sets up database access & e-mails
Certifying Official an authorization code for a Preparer
2. Preparer sets up their own CDX account
- Add Role: “Preparer” (using authorization code obtained
from Certifying Official)
1. Preparer enters RMP data for facility
RMP Data Entry
& 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 &
Corrections
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.
User is Preparing an
RMP “Correction”

System prohibits
certain changes

Changing some data


fields will trigger a
system warning
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
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
 Chemical Emergency Preparedness and Prevention
in Indian Country
 Updated RMP technical guidance documents
(General guidance, industry sector guidance, OCA
guidance)
Webinar-specific Questions…
 Q: After the Webinar, can I get a copy of questions
submitted?
 A: A list of frequent questions was sent to the participants
prior to the Webinar. We continue to compile the Q & As
and will post them to our Web site.
 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.
Questions?
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.