Submittal Process when Claiming Confidential Business Information (CBI)
Pursuant to the risk management program regulations, facilities may make a claim of confidential business information (CBI) unless otherwise stated in 40 CFR §68.151. How does a facility that is claiming CBI submit its RMP?
For a facility to claim information as CBI, the facility must submit to EPA a sanitized RMP, a Substantiation Form (explaining why the information meets the criteria of CBI), and an Unsanitized Data Elements Form. The sanitized RMP should not include any CBI and can be completed using the RMP*eSubmit software. Once in RMP*eSubmit, the facility should click the button after the question “Are you claiming Confidential Business Information (CBI) in this Section?” at the top of each section and leave all fields blank that are being claimed as CBI. The facility must send to EPA separately a paper copy of the Substantiation Form and the Unstanitized Data Elements Form. These forms can be found in Appendices C and D of the Risk Management Plan RMP*eSubmit Users’ Manual (EPA540-B-14-001).