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At a Glance

Comparison of EPA’s RMP vs OSHA’s PSM at-a-glance

RegSenseProcess Safety ManagementAt-a-GlanceRisk Management ProgramRisk Management ProgramBest ResultsCAA ComplianceEnvironmentalHazardous Materials Safety - OSHAEnglishFocus AreaUSA
Comparison of EPA’s RMP vs OSHA’s PSM at-a-glance

The elements and language of the risk management rule are, to the maximum extent possible, identical to the parallel elements in OSHA’s Process Safety Management (PSM) standard. One important difference between PSM and RMP is that, under the Clean Air Act (CAA) amendments, OSHA, must protect workers from chemical incidents at facilities that use highly toxic, reactive, flammable, or explosive substances. EPA must protect public health and the environment. This chart compares the two programs to help you understand where there are differences. Keep in mind that most facilities that fall under the scope of both PSM and RMP fall into RMP Program 3.

Federal regulatory citations:

40 CFR 68

29 CFR 1910.119

Provision Risk Management Plan (RMP) 40 CFR 68 Process Safety Management (PSM) 29 CFR 1910.119
Safety and Compliance Audits X X
Pre-startup Safety Reviews X X
Mechanical Integrity X X
Operating Procedures X X
Process Safety Information X X
Management-of-Change X X
Incident Investigation X X
Emergency Planning and Response X X
Process Hazard Analysis X X
Training Programs X X
Employee Participation X X
Hot-work Permits X X
Contractor Requirements X X
Management Systems Requirements X
Off-site Analysis X
Five-year Incident History X
Worst-case Release Scenarios X
Coordinate Plans with LEPC X
Provide Information to the Public X
Facility Registration X
Risk Management Plan Requirement X
Recordkeeping Requirements X X
Reporting Requirements X
Response Drills and Exercises X
Regulatory Audit Requirements X
Trade Secrets Clause X
['Hazardous Materials Safety - OSHA', 'Risk Management Program']
['Process Safety Management', 'Risk Management Program']
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