Risk Mitigation Plan - Section 1.0 - Purpose of the Risk Mitigation Plan (OAC 3745-300-11(G)(1)(a))

Sep 1, 2026

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Template content for drafting a Risk Mitigation Plan (RMP) under Ohio’s Voluntary Action Program when required by OAC 3745-300-11, and for inclusion in the NFA letter issued for the property. The plan’s purpose is to outline measures that mitigate or eliminate human exposure to contamination from construction activities, including excavation below the point of compliance, both during work and after completion. It specifies protection objectives for construction workers, non-construction workers during construction through site controls, and non-construction workers after completion via soil management and restoration. It also notes preparation under OAC 3745-300-11 and that it is not intended to satisfy other applicable legal requirements, with instructions to remove bracketed or parenthesized drafting examples.

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Pages8

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Section 1.0 – Purpose of the Risk Mitigation Plan (OAC 3745-300-11(G)(1)(a))

Section 2.0 – Implementing the Risk Mitigation Plan (OAC 3745-300-11(G)(1)(e) and (f))

Section 3.0 – Potential Health Risks

Section 4.0 – Precautions Against Exposures

Section 5.0 – Actions to Take if Significant Exposures Occur

Section 6.0 – Handling Contaminated Environmental Media

Section 7.0 – Notice to Contractors and Workers

Section 8.0 – Annual Notification to Ohio EPA

Section 9.0 – Termination Criteria

***REMOVE THIS INSTRUCTION PARAGRAPH PRIOR TO SUBMITTAL*** The following template provides a format for drafting a risk mitigation plan under Ohio’s Voluntary Action Program when one is required by OAC 3745-300-11. The NFA letter that is issued for the property would include the risk mitigation plan, as required by OAC 3745-300-13(E)(12). This template contains sections based on the minimum plan components described by OAC 3745-300-11(G)(1). Each section of the risk mitigation plan should, at a minimum, provide the information indicated below, as outlined in OAC 3745-300-11(G). No sections should be omitted. Please indicate when relevant information is not applicable for a certain section. The risk mitigation plan should be updated and resubmitted under an addendum to the NFA letter when responding to Ohio EPA NFA letter review comments. Fill in all [bracketed] text with the corresponding property-specific information, and remove the brackets prior to submittal. Remove all parenthesized and italicized instructional or bracketed example text prior to submittal. ***REMOVE THIS INSTRUCTION PARAGRAPH PRIOR TO SUBMITTAL*** Risk Mitigation Plan for the [Property Name] Property [Property Street Address] [Property City], [Property County], Ohio [Zip Code] [Volunteer(s) Name(s)], Volunteer [Volunteer(s) Address(es)] [Property Owner(s) Name(s)], Property Owner [Property Owner(s) Address(es)] (If different from Volunteer, otherwise delete and specify above that the Volunteer is also the property owner) NFA Letter Issued by: VAP Certified Professional [CP Name], [CP Number] with [CP Firm/Company], [Address of CP Firm/Company address], [CP Work Phone Number] [Date of RMP] (Add additional dates as needed) Table of Contents Section Page Number TOC \o "1-3" \h \z \u HYPERLINK \l "_Toc328387000" Section 1.0 Purpose of the Risk Mitigation Plan PAGEREF _Toc328387000 \h 3 HYPERLINK \l "_Toc328387001" Section 2.0 Implementing the Risk Mitigation Plan PAGEREF _Toc328387001 \h 4 HYPERLINK \l "_Toc328387002" Section 3.0 Potential Health Risks PAGEREF _Toc328387002 \h 4 HYPERLINK \l "_Toc328387003" Section 4.0 Precautions Against Exposures PAGEREF _Toc328387003 \h 5 HYPERLINK \l "_Toc328387004" Section 5.0 Actions to Take if Significant Exposures Occur PAGEREF _Toc328387004 \h 6 HYPERLINK \l "_Toc328387005" Section 6.0 Handling Contaminated Environmental Media PAGEREF _Toc328387005 \h 6 HYPERLINK \l "_Toc328387006" Section 7.0 Notice to Contractors and Workers PAGEREF _Toc328387006 \h 7 HYPERLINK \l "_Toc328387007" Section 8.0 Annual Notification to Ohio EPA PAGEREF _Toc328387007 \h 8 HYPERLINK \l "_Toc328387008" Section 9.0 Termination Criteria PAGEREF _Toc328387008 \h 8 List of Figures Property Map (depicting portions of property subject to RMP as required by OAC 3745-300-11(G)(1)(g)) (Additional figures as needed) List of Appendices (If applicable, otherwise delete from table of contents) Section 1.0 – Purpose of the Risk Mitigation Plan (OAC 3745-300-11(G)(1)(a)) The purpose of this risk mitigation plan (RMP) is to provide the risk mitigation measures that mitigate or eliminate human exposure to contamination as a result of construction activities. Construction activities include any excavation activities below the point of compliance (e.g., two feet below ground surface). Concerns for potential exposure to contaminated soil includes both during the construction activities and after completion of the construction activities. Therefore, the RMP has three main purposes: Risk mitigation measures to protect construction workers from contamination that exceed applicable standards for construction activities. Risk mitigation measures to protect non-construction workers from exposure to contamination during the construction activities, which can be

FAQs

What is the purpose of the Risk Mitigation Plan (RMP) under Ohio’s VAP?

The RMP defines risk mitigation measures that mitigate or eliminate human exposure to contamination caused by construction activities. It addresses exposure concerns both during construction (including excavation below the point of compliance) and after construction completion.

How does the RMP protect construction workers versus non-construction workers?

It includes measures to protect construction workers from contamination that exceeds applicable construction-activity standards, and measures to protect non-construction workers through site control during construction. After completion, it focuses on protecting non-construction workers through proper soil management and restoration of clean soils within the point of compliance.

What regulatory basis governs preparation and what limitations apply?

The RMP is prepared in accordance with Ohio Administrative Code rule 3745-300-11 and is intended to support compliance with VAP standards applicable to construction activities. It is not intended to fulfill requirements of other laws that may apply to construction or excavation activities.

Sep 1, 2026

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