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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:

40 CFR 68

Requirement: Program 1: Program 2: Program 3:
Hazard assessmentWorst-case analysisWorst-case analysis
Alternative releases
Worst-case analysis
Alternative releases
5-year accident history5-year accident history5-year accident history5-year accident history
Management programDocument management systemDocument management system
Prevention programCertify no additional steps neededSafety 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 programCoordinate with local respondersDevelop plan and programDevelop plan and program
RMP contentsConfidential 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