those with catastrophic consequences in the workplace as required by the PSM Rule. Facilities
are expected to have fewer incidents to consider under the EPA RMP Rule, because some
potential incidents will not have offsite impacts.
Another EPA requirement, which is not included in the OSHA PSM rule, is that a facility define
its management system. Facilities are required to identify the person (by name) or the position
responsible for implementing the prevention program.
Emergency Response Program
An emergency response program also must be developed. The applicable emergency response
program requirements are much more stringent under the proposed EPA RMP than those under
OSHA's PSM rule. OSHA's emergency action plan regulation basically requires an evacuation
plan. Whereas, under the EPA rule, facilities will need to develop a more extensive emergency
response plan. This emergency response plan must detail how the facility would respond to a
release to limit offsite consequences. Coordination of plans with the Local Emergency Planning
Committee (LEPC) is also required. Coordination with the LEPC is not required by OSHA
although many facilities do so currently.
RMP and Documentation
The RMP Rule requires facilities to submit the RMP to the LEPC and have it available for the
public, the State, and the Chemical Safety and Hazard Investigation Board. The RMP would
include the results of the risk management program elements, a copy of the registration,
description of the management system, and certification of the accuracy and completeness of the
information. Facilities would be required to maintain the documentation supporting the
implementation of the risk management plan for inspection by EPA and other agencies.
The RMP Rule requires facilities to register with the EPA if they have a regulated substance in a
quantity greater than the threshold quantity. The content of the registration would include the
name and address of the facility, the facility's Dun and Bradstreet number, the regulated
substances on site and the quantities, and the facility's North American Industry Classification
System Code (NAICS) that apply to the use of each regulated substance. Most of these
registration requirements are already reported under the SARA Title III.
If the information on registration changes (e.g., a change that requires a revised offsite
consequence analysis or a revised process hazard analysis or hazard review) after the submittal
of the registration or most recent update, facilities would be required to file an amended
registration form within six (6) months.