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Planning EPA RMP Exercises for Compliance and Real-World Readiness

For facilities subject to the United States (US) Environmental Protection Agency’s (EPA) Risk Management Program (RMP), conducting exercises is more than a regulatory requirement. It is an opportunity to validate plans, strengthen coordination, and build confidence in emergency response capabilities. However, many organizations face challenges translating regulatory expectations into practical, compliant, and operationally meaningful exercises.

Limited internal capacity, competing priorities, and uncertainty around compliance obligations often make exercise planning challenging. With key deadlines approaching—tabletop exercises (TTX) due by December 21, 2026, and field drills due by March 15, 2027—organizations are seeking efficient, defensible ways to meet expectations without sacrificing operational value.

That is where experienced exercise support makes a measurable difference.

Turning Requirements into Actionable Exercises

Meeting RMP exercise requirements involves more than scheduling a TTX or coordinating a drill. Scenarios must reflect realistic hazards, engage appropriate personnel and response partners, and generate documentation that demonstrates compliance with EPA program standards.

At Hagerty, we help utilities and regulated facilities translate those expectations into structured, executable exercise programs. With deep experience supporting water, wastewater, and other critical infrastructure partners, we understand both the regulatory landscape and the operational realities facilities face.

We design exercises that go beyond theory—evaluating decision-making, testing communication pathways, and strengthening coordination across agencies. Whether facilitating TTXs or coordinating operations-based field drills, our approach ensures exercises are both compliant and operationally relevant.

A Structured Approach to RMP Exercise Support

Effective RMP exercises require thoughtful planning, realistic scenarios, and defensible documentation. Our team delivers end-to-end support designed to meet EPA requirements while strengthening response capabilities.

We design and conduct both TTXs and field drills in alignment with EPA RMP regulations and industry best practices, including the Homeland Security Exercise Evaluation Program (HSEEP). Each exercise is tailored to your facility’s specific hazards, operational structure, and response environment.

Tabletop Exercise (TTX) Development

We develop discussion-based exercises that:

  • Evaluate emergency response procedures and decision-making
  • Involve appropriate facility personnel and response partners
  • Address realistic release scenarios based on facility-specific hazards
  • Identify gaps in coordination, communication, and response actions

Field Drill Planning and Execution

Our team plans and facilitates operations-based exercises that:

  • Test emergency response functions such as notification, evacuation, and incident command
  • Coordinate with local emergency responders, as required
  • Simulate realistic conditions to validate operational readiness
  • Demonstrate implementation of the facility’s emergency response plan

Coordination, Evaluation, and Compliance Documentation

Hagerty engages with Local Emergency Planning Committees (LEPCs), fire departments, and other response partners to meet coordination expectations while strengthening interagency relationships. Following each exercise, we document outcomes, identify corrective actions, and develop structured Action-Action Reports (AARs) and Improvement Plans that support continuous compliance and operational readiness.

This process culminates in complete, audit-ready documentation that demonstrates adherence to EPA RMP requirements—providing clear evidence of performance, regulatory alignment, and long-term program defensibility.

Experience That Strengthens Real-World Preparedness

Organizations benefit most when exercise support is grounded in real-world experience. Hagerty has a proven track record of planning and executing complex exercises that strengthen preparedness and build organizational resilience.

Our recent experience includes:

  • Leading a large-scale, multi-jurisdictional hazardous materials (HazMat) full-scale exercise (FSE) involving multiple response agencies and operational components
  • Supporting county agencies with HazMat assessments and regional preparedness initiatives to strengthen coordination and response readiness
  • Designing and facilitating compliance-focused exercises that align objectives and documentation with regulatory expectations
  • Supporting utilities and organizations during real-world hazardous spill responses across the US, including water and wastewater systems

Additionally, in 2025 alone, Hagerty supported 31 discussion-based exercises and nine operations-based exercises, many of which required coordination across multiple jurisdictions and response organizations. This breadth of experience enables us to anticipate challenges, streamline planning, and deliver exercises that are both efficient and impactful.

Start Planning Now for Stronger RMP Exercises

RMP exercises should do more than satisfy regulatory requirements—they should strengthen your facility’s ability to respond to real-world incidents. Organizations that take a proactive, structured approach to exercise planning are better positioned to build confidence across personnel, response partners, and regulators.

With 2026–2027 RMP exercise deadlines approaching, now is the time to begin planning. Early coordination gives your team the opportunity to design exercises that are not only compliant but also practical, realistic, and aligned with your unique operational risks.

Hagerty helps organizations move beyond check-the-box compliance by developing exercises that validate response procedures, enhance coordination with partners, and produce audit-ready documentation.

Connect with our team today to start planning your upcoming RMP TTXs and field drills, and turn regulatory requirements into meaningful, measurable readiness.

  • Mallory Buys-Brown Senior Managing Associate Mallory is an emergency management leader specializing in critical infrastructure resilience across water, energy, and public-sector networks. She has led the creation of preparedness frameworks and continuity programs that both meet regulatory requirements and strengthen operational resilience. Her cross-sector work has shaped statewide initiatives and earned her recognition on the International Association of Emergency Managers (IAEM) “Top 40 Under 40” list.

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