Ever heard anyone say, “PSM and RMP are identical except for the off-site consequence requirements”? There are a lot of similarities between the two chemical safety regulations, but the two are very much different in more ways than just the “off-site consequence requirements.” Most similarities are between RMP “Program 3 Prevention Program” and OSHA’s PSM requirement; however, there are actually substantive differences between these requirements.
First, OSHA requires no reporting of a facility’s Process Safety Management (PSM) program. Still, EPA does require a facility to submit its Risk Management Plan (online using “e-Submit” software). The other major difference is the EPA’s “off-site consequence analysis” (OCA) required for each “covered process” in order to determine the facility’s “Worst Case Release Scenario” and their “Alternative Release Scenario.” But the obvious differences stop there, and unfortunately, there are several other significant requirements that can cause some serious compliance issues for facilities that must comply with the RMP rule.