RMP Tabletop Exercise Deadline
40 CFR 68.96(b)(1) requires Program 2 and Program 3 stationary sources to conduct a tabletop exercise before December 21, 2026, then at minimum once every three years thereafter.
What the Rule Requires
Coordinate with local emergency response officials to establish a schedule. Develop scenarios consistent with the facility emergency response plan. Conduct the exercise. Document findings and corrective actions. Maintain records that hold up to a federal inspector.
What Satisfies the Requirement
A documented tabletop exercise covering the facility emergency response plan, with appropriate command and coordination roles, scenarios consistent with the hazard profile, and an After-Action Report. Coordination with local emergency response officials must be part of the planning.
What Northline Delivers
Northline ICS Tabletop System is an instructor-led operational simulation built around real constraints: finite resources, real time pressure, asymmetric information between agencies. The After-Action Report is generated from what happened in the exercise, not reconstructed after.