Risk Management Program (RMP) Development and Support
Cognascents Consulting Group provides Risk Management Program (RMP) development and support to help facilities manage accidental release risks and support EPA RMP compliance. We connect hazard assessments, prevention programs, emergency planning, and Risk Management Plan documentation to the chemicals, operations, and response capabilities of your facility.
When Clients Engage Us
Common reasons organizations engage RMP services
Organizations typically engage Cognascents for RMP development and support when they are facing:
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▸A new facility that triggers RMP coverage under Clean Air Act Section 112(r) and the 40 CFR 68.130 threshold quantities
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▸EPA RMP rule changes under active rulemaking that have outpaced your current program
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▸Hazard assessments and offsite consequence analyses that haven’t been revisited since the last five-year update
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▸Emergency response plans that don’t reflect current operations
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▸Preparing for an RMP compliance audit or a five-year RMP*eSubmit resubmission
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▸Uncertainty about Safer Technology and Alternatives Analysis (STAA) obligations
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Our Approach
A Risk Management Plan built to actually reduce risk, not just satisfy the EPA.
A Risk Management Program is the accidental release prevention program EPA requires under Clean Air Act Section 112(r)(7) and 40 CFR Part 68 for any stationary source with more than a threshold quantity of a regulated substance in a process. It comprises a hazard assessment with worst-case and alternative release scenarios (Subpart B), prevention program requirements that scale with program level (Subpart C for Program 2, Subpart D for Program 3), and an emergency response program (Subpart E). The Risk Management Plan documents that program for submission to EPA and must be updated at least every five years under 40 CFR 68.190. Our RMP program development services help you determine applicability and program level, identify requirements, and build a practical framework that supports 40 CFR Part 68 compliance and protection of workers and surrounding communities.
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Step 01
Hazard Identification & Risk AssessmentWe confirm applicability and program level for each covered process, then conduct worst-case and alternative release scenario assessments, evaluating offsite consequence analysis (OCA) parameters and toxic and flammable endpoints to identify and quantify your facility’s real risk profile. |
Step 02
Emergency Response PlanningWe help you develop clear response procedures, train your team, and establish communication protocols so your facility is genuinely prepared to respond, not just documented as prepared. |
Step 03
RMP Implementation, Documentation & STAAWe support RMP documentation, prevention program procedures, implementation planning, and Risk Management Plan submissions. Where applicable, we assist with Safer Technology and Alternatives Analysis (STAA) and connect recommendations to your hazard analysis and action management process. |
Why Cognascents
Why choose Cognascents for EPA RMP compliance support
RMP SUPPORT SINCE 2010
Experience Across the Program Lifecycle
Cognascents has supported RMP compliance since its founding in 2010. Our work spans initial development, gap assessments, audits, procedures and policies, and ongoing maintenance across chemical manufacturing, refining, gas processing, LNG, and industrial gases. |
MULTIDISCIPLINARY EXPERTISE
Technical Depth Across the Risk Management Program
Cognascents brings together engineers across process safety, asset integrity, and process engineering. Our team includes Professional Engineers (PEs), Certified Safety Professionals (CSPs), Certified Process Safety Professionals (CCPSCs), and holders of API 510, 570, 571, 580, and 653 certifications. That breadth enables us to support the full program, from policies and procedures to hazard analysis and the engineering behind safeguards and equipment integrity. |
A PARTNERSHIP THROUGH IMPLEMENTATION
Practical Recommendations With Facility Ownership
We work with facility personnel to understand current practices, explain our methods, and develop feasible improvements. Feedback throughout the engagement helps your team understand the deliverables and take ownership of maintaining the program. |
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“A Risk Management Plan built for the filing deadline protects the paperwork. One built for your community protects people.”
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Standards & Codes We Work To
The regulatory frameworks that govern Risk Management Programs.
Clean Air Act Section 112(r)(7) — accidental release prevention (Risk Management Program)40 CFR 68.10 and 68.130 — RMP applicability, program level criteria, and regulated substance threshold quantities40 CFR Part 68, Subparts B, D, and E — hazard assessment, Program 3 prevention program, and emergency response40 CFR Part 68, Subpart G — Risk Management Plan content, submission, and five-year update under 68.190Clean Air Act Section 112(r)(1) — General Duty Clause, which applies regardless of threshold quantities
IS YOUR RMP KEEPING PACE WITH YOUR FACILITY?
Let’s talk about whether your current plan reflects how your facility actually operates today.
Our engineers will give you a direct read on where your RMP program has gaps.
Keep reading for what a well-built RMP delivers and the services that connect to it. ↓↓
What You Gain
An RMP that protects your community and holds up to EPA scrutiny.
An RMP should do more than satisfy a filing deadline. Cognascents builds programs meant to actually reduce risk to your community and your operation.
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ENHANCED SAFETY & COMPLIANCE
Risk proactively identified and mitigatedWorst-case and alternative release scenarios and offsite consequence analysis provide a traceable basis for understanding potential impacts and informing emergency planning. |
REGULATORY COMPLIANCE
A program that satisfies 40 CFR Part 68 requirementsAn applicability review and program gap assessment help you understand the 40 CFR Part 68 requirements relevant to your covered processes and prioritize the work needed to address them. |
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COMMUNITY PROTECTION
Emergency response plans your team can actually executeDefined responsibilities, response or action procedures, and coordination with local responders help your facility prepare for accidental releases and strengthen community protection. |
EFFICIENCY & COST SAVINGS
Reduced risk of costly incidents and regulatory penaltiesA well-built RMP program helps you avoid the downtime, legal exposure, and reputational damage that follow a poorly managed release. |
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Related Services
Supporting services that strengthen your RMP program
Cognascents connects RMP development to the audits and analysis it depends on.
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THE AUDIT THAT TESTS YOUR RMP
PSM/RMP Compliance AuditsOnce your RMP is built, an independent audit confirms it holds up under EPA scrutiny. |
THE PSM PROGRAM RMP OFTEN PAIRS WITH
PSM Program Development and SupportMany RMP-covered facilities are also PSM-covered. We help you build both programs so they work together. |
THE ANALYSIS BEHIND YOUR HAZARD ASSESSMENT
Process Hazard Analysis (PHA)RMP hazard assessments and PHA findings should tell a consistent story. We keep them aligned. |
Related Content
Risk management program articles and case studies
Case studies and technical articles from the engineers who lead these engagements.
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ARTICLE | PROCESS SAFETY
Developing a Robust PSM Program: A Practical RoadmapMany of the same planning principles that apply to PSM program development apply directly to RMP program build-out. |
CASE STUDY | LITHIUM-ION BATTERY MANUFACTURER
Fortifying Critical PSM Program Elements for a Lithium-Ion Battery ManufacturerStrengthening process safety program elements for a facility handling flammable and reactive chemicals under both PSM and RMP. |
ARTICLE | AI & ENGINEERING
AI-Accelerated Engineering Services: What does that really mean?How Cognascents applies AI across compliance-heavy engineering disciplines without stepping back from engineer accountability. |
RISK MANAGEMENT PROGRAM QUESTIONS, ANSWERED DIRECTLY
Frequently asked questions about EPA RMP compliance
Which facilities must comply with EPA’s RMP rule?
Under 40 CFR 68.10, any stationary source with more than a threshold quantity of a regulated substance in a process must comply; the substances and thresholds are listed in 40 CFR 68.130. Each covered process is then assigned to Program 1, 2, or 3 based on its accident history, public receptors within the worst-case endpoint, and whether it is subject to OSHA PSM or in a listed NAICS code. Below-threshold facilities still owe the General Duty Clause under Section 112(r)(1).
What is an offsite consequence analysis?
The offsite consequence analysis (OCA) under 40 CFR 68.20–68.39 models a worst-case release scenario for covered processes, and alternative release scenarios for Program 2 and 3, to determine the distance to toxic or flammable endpoints and the public and environmental receptors within it. EPA’s RMP*Comp tool supports screening, but refined dispersion modeling is often warranted where the footprint drives program level or emergency planning decisions.
How often must a Risk Management Plan be updated?
At least once every five years from the most recent full submission under 40 CFR 68.190(b)(1), and within six months of a change that requires a revised PHA or hazard review, a revised offsite consequence analysis, or a change in program level. A new regulated substance above threshold requires an updated plan by the date it is first present in a process. Updates are filed through EPA’s RMP*eSubmit system.
Is a Safer Technology and Alternatives Analysis (STAA) still required?
The 2024 Safer Communities rule added STAA to the Program 3 PHA under 40 CFR 68.67(c)(9) for processes in NAICS codes 324 and 325, with a compliance date of May 10, 2027. In February 2026, EPA proposed eliminating STAA for existing processes; until that rule is finalized, the 2024 requirement remains in effect. Covered refiners and chemical manufacturers should plan to the current rule while tracking the final action.
How does RMP relate to OSHA PSM?
The Program 3 prevention program in 40 CFR 68.65–68.87 mirrors OSHA’s PSM standard element for element, so a sound PSM program carries most of that load. RMP’s distinct obligations point outward: the offsite consequence analysis, the five-year accident history, the emergency response program, coordination with local responders under 68.93, and the Risk Management Plan itself. Our PSM Program Development and Support service builds both so they reinforce each other.
Talk to an engineer about your risk management program
Tell us about your RMP program and where you think it needs to catch up. One of our engineers will give you a straight answer about what it would take to bring it current.