What is a Risk Management Plan (RMP) in the PPLP context?

The RMP is a formal document of an operator handling plastic pellets (resin producer, recycler, distributor, haulier) containing the identification of pellet leakage risk points and the operational, training, and control procedures minimising that risk. A requirement of Regulation (EU) 2025/2365, Articles 6–8. Mandatory for operators handling >5 tonnes/year; at >1,500 tonnes/year, independent verification of compliance is required.

When must the RMP be ready?

Selected PPLP provisions apply from 16 December 2025 — formally, operators should already have started preparing their RMP. Full requirements (including certification for >1,500 tonnes) apply from around December 2027. In practice: 2026 is the RMP implementation year for most companies, 2027 — external audits, from 2028 — full reporting to supervisory authorities.

How long should an RMP be?

It depends on scale. A small operator (5–100 tonnes/year, one location): 15–30 pages. A medium operator (100–1,500 tonnes/year, several locations): 50–100 pages. A large operator (>1,500 tonnes/year, a network of sites): 150–300+ pages, with separate annexes per location. Document format: structured, auditable, with numbered points for the auditor.

Is the RMP the same as an OCS certificate?

No. The RMP is the operator's operational document. OCS is a certification scheme confirming (via an independent third party) that the RMP exists, is implemented, and actually works. An operator may have an RMP without an OCS certificate (self-implementation) — but under the PPLP, operators handling >1,500 tonnes/year must have both: the document and the certificate.

Who should write the RMP?

Most often an internal team: the H&S/quality coordinator, the operations manager, the warehouse manager, the transport coordinator, and a legal compliance expert. External support (a consultant) — for companies without prior experience of ISO 9001 or another quality management system. Drafting time: 2–6 months depending on scale.

Is the RMP a static document?

No. The RMP requires updating at every significant operational change (a new location, new material, new fleet, new sub-process) and a cyclical review — typically annual. Updates are verified by the auditor during OCS surveillance audits.

Are there ready-made RMP templates?

Plastics Europe and EuPC provide model documents within Operation Clean Sweep Europe. There are also templates offered by auditing organisations (DNV, DQS, TÜV) as audit preparation aids. Directly copying a template is not enough — the RMP must reflect the company's actual operations.

regulacje operacje 15.08.2024 PHS Magnum

Risk Management Plan for Pellet Operators >1,500 t/year

Name: PHS Magnum
Address: ul. Kościelna 9, Chorula, Opolskie, 47-316, PL
Telephone: +48 602 716 551
Price range: $$

Silo trailer under renovation — implementing Risk Management Plan procedures under the PPLP, PHS Magnum

In short

The Risk Management Plan (RMP) is a mandatory document for every operator handling more than 5 tonnes of plastic pellets per year under Regulation (EU) 2025/2365 (PPLP). Above the 1,500 tonnes/year threshold, independent certification of compliance (Operation Clean Sweep Europe) is required. The document identifies leakage risk points at every operational stage (loading, transport, warehousing, unloading, cleaning), and describes control procedures, staff training, and an incident reporting system. Implementation time: 6–12 months depending on the starting baseline. Updates: annually and at every significant operational change.

The structure of a standard RMP

A full Risk Management Plan compliant with the PPLP and OCS Europe contains seven chapters:

1. Scope and policy

Identification of the company and the locations covered by the plan
A pellet loss management policy (a board declaration)
Responsibility (people and roles, who answers for what)
Internal and external communication

2. Hazard identification

A full map of the company’s processes with identification of leakage risk points (LRPs). For a typical silo trailer haulier:

Point 1: Loading at the shipper

The loading pipe disconnected from the silo trailer → pellet residue falls
The top manhole not closed properly → leakage en route
A leaking discharge valve → leakage en route
The shipper’s operator does not notice spills around the silo trailer

Point 2: Transport en route

Vibration loosens valves or manholes
Shocks (e.g. potholes) squeeze out small quantities of pellets
Cracked aeration pads
Collision, accident

Point 3: Unloading at the recipient

Opening the valve generates air fountains — airborne pellets can spread
Pipe connections — tightness
Load residue after discharge is finished (a few kilograms in the chamber)

Point 4: Cleaning the silo trailer

Blow-through — pellets blown out as pneumatic waste
Wet washing — pellets remain in the water
Drying

Point 5: Warehousing (if the operator stores pellets)

Big-bags of pellets damaged in transit
Opening a big-bag in the warehouse — minor spillage
Palletised bags of pellets

For each LRP: an assessment of probability of occurrence (low/medium/high) × severity of consequence (small spills / medium / large).

3. Operational procedures

For each LRP — a detailed procedure reducing the risk. An example for the “Loading at the shipper” point:

PROCEDURE OP-001: Loading a silo trailer at the shipper
Purpose: Prevent pellet spills when disconnecting the loading pipe.
Responsibility: Silo trailer driver + the shipper's loading operator.
Steps:
1. Before loading — visual check of the silo trailer's condition.
2. After connecting the pipe — check the clamp for tightness.
3. Loading supervised by the driver or the operator.
4. After loading is complete — close the silo trailer valves.
5. Disconnect the loading pipe with a collector guard underneath it.
6. Check the area under the silo trailer — collect any spills.
7. Entry in the cycle register.
Documentation: Cleanliness certificate, CMR with a photo, register entry.

For a typical operator — 15–30 such procedures. Each numbered, with an assigned owner (responsible person) and the date of last update.

4. Equipment and infrastructure

A list of equipment at every location and on every vehicle:

Cleaning points at loading zones (pressure washers, water separators)
On-board equipment on silo trailers (scoops, bags, funnel, straps)
Wind protection in outdoor zones (collection gutters, grates)
Lighting systems (visual checks at night)

Plus an inspection and maintenance schedule for each item.

5. Staff and training

A list of positions handling pellets
Training requirements per position (content, frequency, knowledge verification)
A training register (dates, names, trainer and participant signatures)
An onboarding procedure for new employees (1–3 months of mentoring)

Example: a silo trailer driver must complete initial training (8 h theory + 4 h practice) and an annual refresher (4 h). A verification test — 80% required to pass.

6. The incident reporting system

Definition of reportable events (every spill ≥1 kg or ≥100 pellets)
The reporting procedure (from the driver → dispatcher → H&S coordinator → management)
Reporting deadlines (typically: immediately to the dispatcher, an electronic report within 24 h)
A report archive (5–10 years)
Systemic analysis — a cyclical review of reports, identification of recurring causes, procedure corrections

7. Review and continuous improvement

RMP review frequency (typically annual)
The RMP update procedure
Internal audits (quarterly or semi-annual)
External audit — OCS Europe (typically every 3 years, with annual surveillance audits)
Performance indicators (KPIs): incidents/year, quantity of spilled pellets/year, response time, training attendance

Critical RMP mistakes — what the auditor rejects

From the experience of the first OCS Europe audits (2025–2026):

1. The RMP as an unpersonalised template The auditor quickly sees the document is a copied template — no specific locations, no specific names, no specific numbers. Result: a non-conformity, rework required.

2. An RMP disconnected from operational reality Procedures exist on paper, but when the auditor enters the site — the driver does not know the procedures, the equipment is missing, the cycle register is empty. Result: a critical non-conformity.

3. No training register Procedures state that staff are trained, but there is no documented register. The auditor has no basis to verify — a non-conformity.

4. No systemic analysis of reports Incident reports are archived, but there is no periodic review and no conclusions drawn. The auditor asks: “What conclusions did you draw from the last 12 months of reports?” The answer “none” → a non-conformity.

5. Incomplete or missing on-board equipment The audit often includes checking several silo trailers from the fleet. Missing scoops, unavailable bags, illegible instructions → a non-conformity.

6. An RMP review cycle that is too long “Updated every 3–5 years” does not meet the PPLP requirement. The OCS Europe standard: at least annually, plus at every significant change.

An RMP implementation schedule — an example for a haulier

Assumptions: a company with ISO 9001 (DEKRA), 26 DAF tractor units, 31 silo trailers, pellet turnover of roughly 10–20 thousand tonnes/year (PHS Magnum).

Month	Actions
M1	Board decision, appointment of the implementation team
M2	Process mapping and LRP identification (a workshop with a consultant, optionally)
M3	Writing operational procedures for each LRP
M4	Purchase of missing on-board equipment (scoops and bags for the whole fleet)
M5	Training of all drivers (a 2-week cycle)
M6	Training registers, cycle registers, the incident reporting system
M7	Internal audit
M8	Corrections based on the internal audit
M9	Pre-audit by an external consultant
M10–11	Corrections based on the pre-audit
M12	OCS Europe certification audit
M13+	Cyclical surveillance audits (annual)

A 12-month implementation is realistic for a company with an ISO 9001 baseline. Without ISO — 15–18 months.

What PHS Magnum offers pellet shippers

For pellet shippers looking for a haulier ready for the PPLP era:

ISO 9001:2015 (DEKRA, certificate current) as the base of the quality management system
Risk Management Plan procedures being implemented in line with the PPLP and OCS Europe
On-board equipment on every silo trailer (scoops, bags, funnel)
Driver training in PPLP procedures (since 2025)
A cycle register system — documentation of every loading, transport, and unloading
OCS Europe certification in progress — first audit scheduled for Q3–Q4 2026

Certification status is available to counterparties on request: biuro@magnumchorula.pl , +48 602 716 551.

About the author

This content was prepared by the PHS Magnum team in cooperation with Aleksy Pasternak — Managing Partner of the company and a bulk material transport expert with 35 years of experience in trading plastic pellets, recyclates, and industrial minerals in the EU. Aleksy publishes industry analyses on the expert portal pasternak.me , covering regulatory topics (PPLP, PPWR, OCS), technical topics (silo trailers, TDT), and operations (big-bag transloading, contract packing).