Who is responsible for preparing and submitting an RMP for a leased stationary source?
The "owner or operator" of a stationary source with covered processes is required to comply with the risk management program requirements in 40 CFR Part 68. If a stationary source owner leases the source to an operator, who is responsible for submitting the risk management plan (RMP)?
Both the owner and the operator of a stationary source are responsible for compliance with the risk management program regulations of 40 CFR part 68, including developing and implementing a risk management program and preparing and submitting the RMP. As a practical matter, the operator may be more likely to have the necessary documentation for the RMP, but both the owner and operator can be held liable for failure to comply with the risk management program regulations.