Regulatory Developments

Will RMP and PSM Revisions Create More Overlap?

EPA’s Chemical Accident Prevention Program, more commonly referred to as the Risk Management Program (RMP), and the Occupational Safety and Health Administration’s (OSHA) Process Safety Management (PSM) program will always go hand in hand, as both seek to prevent chemical process accidents and protect workers and the public from the sometimes devastating consequences of such accidents. To enhance that protection, Executive Order 13650 prompted a review of the regulations for both the RMP and the PSM program.

Much has been written on the impending revisions to the U.S. Environmental Protection Agency’s (EPA) RMP regulations. However, OSHA is quietly progressing on its own PSM revisions, as the agency convened a Small Business Review Panel (SBRP) earlier this summer to review some of the changes being considered.

There has always been some overlap in the requirements of the RMP and PSM program, but will the upcoming revisions bring these programs further into lockstep or send them on divergent paths requiring more effort to comply with both? In general, the members of OSHA’s SBRP indicated that preparing one set of documents to comply with both the RMP and the PSM program is not difficult but urged the agency to consider greater harmonization of the standards, language, and interpretations going forward.

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