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Facility Response Plan Submittal Requirements for EPA, DOT and USCG

Posted on Fri, Nov 05, 2010

One of the most important aspects of maintaining your facility response plans is ensuring that plan revisions are submitted to regulatory agencies in a timely manner. The EPA, PHSMA, and the USCG have different requirements for when revisions need to be submitted.

  • EPA :  According to 40 CFR 112.20, each time there is a material change at a facility, the response plan must be resubmitted for approval within 60 days.
  • DOT/PHMSA:  According to 49 CFR Part 194.121, each operator shall review its response plan at least every 5 years from the date of submission and modify the plan to address new or different operating conditions or information included in the plan.
  • U.S. Coast Guard (USCG): According to 33 CFR Part 154.1065, facilities must review their plan annually. Any review should include revisions to the plan, including listings of fish and wildlife and sensitive environments identified in the Area Contingency Plan in effect 6 months prior to plan review. For an MTR facility identified in § 154.1015(b) as a “substantial harm facility” this review must occur within 1 month of the annual anniversary date of submission of the plan to the COTP. The COTP may require a facility owner or operator to revise a response plan at any time as a result of a compliance inspection if the COTP determines that the response plan does not meet the requirements or as a result of inadequacies noted in the response plan during an actual pollution incident at the facility.

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Tags: USCG, DOT, Emergency Preparedness, EPA, Emergency Management Program, Deadline Approaching