RMP Section 9: Navigating the Latest Emergency Response Requirements

What’s Changed in Section 9?

If you’ve submitted or resubmitted your RMP in 2025, you’ve encountered the new Section 9 structure. The EPA has activated new questions and added additional layers of reporting detail, especially for facilities with emergency response plans.

Facilities are now seeing questions 9.2 through 9.12 come online — with some available to all, and others specific to responding sites. While the layout of these fields may vary depending on your facility type, it’s important to know exactly what you’re required to answer.

Non-Responding Facilities: What You Need to Complete

Facilities that evacuate in the event of an emergency and do not have internal emergency response teams (covered under 29 CFR 1910.38) are considered non-responding.

Here’s what you need to complete:

• Answer 9.1.a only – Confirm your facility is included in your community’s emergency response plan. Contact your LEPC (Local Emergency Planning Committee) for verification.
• Do not answer 9.1.b through 9.6 – These fields should be left blank as they do not apply. In most cases, they will be automatically grayed out in CDX.

Note: In CDX, completing 9.1.a will typically disable questions 9.2 through 9.6, signaling that no further response is needed for this section.

Responding Facilities: Full Section Required

If your facility has an emergency response team and complies with 29 CFR 1910.120(q), you’re considered a responding facility.

Here’s what you need to complete:

• Answer all questions from 9.1 to 9.6.
• Ensure your answers reflect current emergency response protocols and coordination efforts with local agencies.

Failure to fully complete these fields could result in submission errors or future compliance issues.

What’s New in Section 9.7?

While 9.7.a and 9.7.b have been part of the RMP in the past, new subquestions have been added:

• 9.7.c.1 & 2
• 9.7.d.1 & 2

These updates apply to all facilities — responding and non-responding.

If your facility has not coordinated with your LEPC or local response agency, you are now required to provide a reason within the RMP Submit form.

Important: The CDX platform includes a “Help” menu for each RMP section, but as of this writing, the help content has not been updated for the new Section 9 questions. According to the RMP Reporting Center, updates are currently in progress.

Section 9.8: Know Your Regulatory References

Section 9.8 outlines emergency planning regulations applicable to your facility. Depending on your operations, you may need to reference one or more of the following:

• 9.8.a – 29 CFR 1910.38: Applies to non-responding facilities.
• 9.8.b – 29 CFR 1910.120: Applies to responding facilities.
• 9.8.c–g – May apply based on your site activities:
  • 9.8.c – EPA SPCC (Spill Prevention, Control, and Countermeasures)
  • 9.8.d – EPA solid waste permitting regulations
  • 9.8.e – Facility response plans (EPA, USCG, DOT, DOI)
  • 9.8.f – EPCRA (state emergency planning and right-to-know laws)
  • 9.8.g – Any additional regulations that apply to your site

Final Additions: Sections 9.9 to 9.12

These final sections are newly introduced, and some are not yet fully activated. Here’s how they break down:

• 9.9 – Applies to responding facilities
• 9.10 – Applies to both responding and non-responding
• 9.11 – Will apply to responding facilities but is not currently active
• 9.12 – Applies to both:
  • Responding facilities should answer Yes
  • Non-responding facilities should answer No

Questions? We’re Here to Help

Understanding Section 9 can be complex, but Clauger is here to support your compliance efforts. If you need assistance completing your RMP Submit or have questions about these updates, our team of regulatory experts is ready to assist.

Contact us today to ensure your facility is fully aligned with the latest EPA requirements.