EPA RMP consulting — the other half of ammonia compliance
If your ammonia refrigeration system is covered by OSHA PSM, it's almost certainly covered by EPA's Risk Management Program too. We build, file, and maintain RMPs under 40 CFR Part 68 — hazard assessment, offsite consequence analysis, and the five-year resubmission cycle — coordinated with your PSM program instead of duplicating it.
PSM protects your workers. RMP protects your neighbors.
OSHA PSM and EPA RMP share the same 10,000 lb ammonia threshold and most of the same prevention program elements — but they answer to different agencies, on different filing cycles, with different documentation.
RMP adds what PSM doesn't have: a hazard assessment quantifying how far a release would travel offsite, coordination with local emergency planners, and a formal filing with EPA that becomes part of the public record — and that regulators, insurers, and plaintiffs' attorneys can all read.
Facilities that treat RMP as a paperwork copy of their PSM program get burned in two places: consequence analysis assumptions that don't survive review, and missed resubmission deadlines. We handle both.
RMP program levels
No public receptor within worst-case distance; minimal requirements. Rare for refrigeration.
Streamlined prevention program. Uncommon for ammonia refrigeration.
Full prevention program mirroring OSHA PSM. Where most covered ammonia facilities land.
Your MII drives your RMP
The worst-case scenario in your RMP is built on your maximum intended inventory. If that number is wrong, your consequence distances are wrong — and correcting it later means amending a federal filing. Get the inventory right first.
Full RMP lifecycle — build, file, maintain
Utah, California, and nationwide
NH3Edge is headquartered in Salt Lake City, Utah, serving ammonia refrigeration facilities throughout Utah and California and across the United States. RMP development and filing work is largely performed remotely; site visits are scheduled where field verification or emergency response coordination requires them. California facilities should note that CalARP imposes additional state-level requirements beyond the federal RMP rule — we scope for both.
EPA RMP questions
Does EPA RMP apply to my ammonia refrigeration facility?
EPA's Risk Management Program (40 CFR Part 68) applies when a process contains more than 10,000 pounds of anhydrous ammonia — the same threshold quantity as OSHA PSM. Nearly every PSM-covered ammonia refrigeration facility must also maintain a Risk Management Program and file an RMP with EPA.
What RMP program level is an ammonia refrigeration facility?
Most PSM-covered ammonia refrigeration facilities fall under Program 3, which carries the most extensive prevention program requirements — essentially mirroring OSHA PSM. Program 1 is available only when a worst-case release would not reach a public receptor and there have been no qualifying accidents; few refrigeration facilities in populated areas qualify.
How often must the RMP be resubmitted?
A complete RMP must be resubmitted to EPA at least every five years. Certain changes trigger earlier updates — including a change in inventory that alters the worst-case scenario, a change in program level, or a reportable accident. Corrections to registration data have their own deadlines.
What is the difference between OSHA PSM and EPA RMP?
PSM protects workers inside the fence line; RMP protects the public and environment outside it. The prevention program elements largely overlap, which is why they should be built and audited together — but RMP adds hazard assessment (worst-case and alternative release scenarios), emergency response coordination with local agencies, and the public RMP filing itself.
When is your resubmission due?
If you don't know off the top of your head, that's the first thing we'll check. Send us your facility details and we'll review your RMP status.