RMP vs. PSM: A Quick Guide to Chemical Safety Regulations

Process Safety Management (PSM)

Administered by the Occupational Safety and Health Administration (OSHA), PSM applies to processes involving specific quantities of hazardous chemicals listed in Appendix A of the PSM standard. It also covers flammable gases or liquids with low flashpoints, as well as specific activities such as the manufacture of explosives or pyrotechnics.

There are exceptions to the standard, including retail facilities, some on-site fuel use, storage in atmospheric tanks, oil or gas well operations, and remote, typically unoccupied sites. As of June 2024, OSHA is actively working on updates to the PSM standard through its ongoing rulemaking process.

Risk Management Program (RMP)

The Environmental Protection Agency (EPA) enforces the Risk Management Program under 40 CFR Part 68. This rule is designed to prevent chemical accidents at facilities handling hazardous substances and requires detailed planning and coordination with local emergency response teams.

RMPs must include critical information to support fire, police, and emergency response planning. Public access to RMPs enhances transparency and promotes community preparedness.

RMP vs. PSM: Key Differences

Both PSM and RMP are mandated under the Clean Air Act, but they serve different primary purposes:

• PSM is focused on protecting workers inside the facility.
• RMP aims to protect the public and the environment outside the facility.

OSHA oversees PSM, while the EPA administers RMP. While both programs have similar requirements, RMPs also require submission to the EPA and local emergency responders to ensure they are informed of risks in the event of a release.

Does Your Facility Need an RMP?

If your facility uses any chemical listed in the List of Regulated Substances (40 CFR 68.130) above a designated threshold, you are required to comply with the EPA’s RMP regulations. This includes developing a risk management program and submitting an RMP to the EPA. These plans must b e reviewed and resubmitted every five years to remain in compliance.

Which Chemicals Must Be Reported?

Facilities must report chemicals that are:

• Listed under the EPA’s RMP Regulated Substances (40 CFR 68.130), and
• Present in quantities exceeding the threshold limits.

Many of these substances also appear in OSHA’s PSM Appendix A list of Highly Hazardous Chemicals, indicating potential regulatory overlap.

Final Takeaway

Both the RMP and PSM programs share a common goal: reducing the risk of chemical accidents through structured planning, training, and communication. However, their areas of focus—external vs. internal protection—differ.

Creating and maintaining either program requires:

• Sufficient resources,
• Facility-specific documentation, and
• Internal oversight and external coordination.

Employers should determine if both standards apply to their operations and ensure all requirements are met to safeguard employees, the public, and the environment.

Key to Remember

Under the Clean Air Act, RMPs protect the community, while PSM safeguards workers. Understanding your obligations, particularly when both programs apply, is essential for ensuring safety and regulatory compliance.