Emergency Response Program (ERP) requirements differ for PSM and RMP

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Details: Written by Bryan Haywood; Parent Category: Safety Info Posts; Category: Chemical Process Safety (PSM/RMP); Published: 26 July 2013

Although the RMP Prevention Plan requirements for Program 2 and 3 very much mirror OSHA's PSM requirements, the emergency response program requirements found in 68.95 Emergency Response Program go above and beyond the requirements of 1910.119(n) Emergency planning and response. OSHA's 1910.119(n) Emergency planning and response directs us to comply with 1910.38 and 1910.120. And although EPA enforces 1910.120 on those not covered by OSHA, the RMP emergency response program section (68.95) has a couple of requirements that we will NOT find in 1910.120(q)(2). Here is what 68.95 states and what our Emergency Response Plan (ERP) may be missing if we use ONLY 1910.120(q)(2) as our guidance for our emergency response plan:

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