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Comparison of RMP program tiers
The RMP rule defines the activities sources must undertake to address the risks posed by regulated substances in covered processes. To ensure that individual processes are subject to appropriate requirements that match their size and the risks they may pose, EPA has classified them into three categories or programs. This chart compares the different program tiers and the compliance obligations in each program.
Federal regulatory citations:
Requirement: | Program 1: | Program 2: | Program 3: |
---|---|---|---|
Hazard assessment | Worst-case analysis | Worst-case analysis Alternative releases | Worst-case analysis Alternative releases |
5-year accident history | 5-year accident history | 5-year accident history | 5-year accident history |
Management program | Document management system | Document management system | |
Prevention program | Certify no additional steps needed | Safety information Hazard review Operating procedures Training Maintenance Incident investigation Compliance audit | Process safety information Process hazard analysis Operating procedures Training Mechanical integrity Incident investigation Compliance audit Management of change Pre-startup review Contractors Employee participation Hot work permits |
Emergency response program | Coordinate with local responders | Develop plan and program | Develop plan and program |
RMP contents | Confidential business information (CBI) Document(s) supporting any CBI Executive summary Registration Worst-case data 5-year accident history Certification | Confidential business information (CBI) Document(s) supporting any CBI Executive summary Registration Worst-case data Alternative release data 5-year accident history Prevention program data Emergency response data Certification | Confidential business information (CBI) Document(s) supporting any CBI Executive summary Registration Worst-case data Alternative release data 5-year accident history Prevention program data Emergency response data Certification |