Environment, Health, and Safety
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Spill Center’s drill system provides a comprehensive solution to keep facilities compliant with 40 CFR 68.96, Emergency Response Exercises. This is required by owners and operators of facilities with Program 2 or Program 3 regulated processes under the EPA’s Risk Management Program.
Annual notification exercises
- Each calendar year, facilities must conduct a notification exercise to test their emergency response notification mechanisms
- This must test the system under either:
- § 68.90(b)(3): non-responding facilities, which rely on external responders
- § 68.95(a)(1)(i): responding facilities, which have an internal emergency response system
- For responding facilities, this can be combined with tabletop or field exercises
- Written records of each notification exercise must be kept for five years
Everything you need to get up and running
There are significant fines and penalties for noncompliance with 40 CFR 68, such as a failure to:
- Submit or update a Risk Management Plan (RMP)
- Conduct and document required notification or field exercises
- Comply with emergency response planning and prevention program requirements
Civil penalties may apply per day and per violation if a facility fails to conduct an annual notification exercise or fails to register or update its RMP, potentially amounting to tens or hundreds of thousands of dollars in cumulative fines if the violation persists for several days.
In extreme cases, when violations are intentional or records are falsified, criminal penalties may apply. This can lead to fines, imprisonment for responsible parties, and enforcement actions.