Benefits of Consolidating your PSM and RMP Programs

Although they are enforced by different regulatory agencies, OSHA’s Process Safety Management (PSM) and EPA’s Chemical Accident Prevention Provisions – also known as Risk Management Plan (RMP) – work in tandem to mitigate potentially catastrophic onsite and offsite incidents involving fires, explosions, and toxic vapor releases. From a regulatory standpoint, the PSM standard (29 CFR 1910.119) is comprised of 14 elements that protect onsite employees and contractors, while the RMP standard (40 CFR 68) incorporates similar elements that protect the community beyond the fence line of a site.

Although the applicability of the two standards differs depending on chemical type, quantity, and use type, there can be benefits to consolidating PSM and RMP into a single program that holistically works to mitigate the potential for a catastrophic incident.

The PSM standard generally applies to processes involving flammable liquids and gases in excess of 10,000 lbs, and toxic and highly reactive chemicals above the threshold quantities outlined in Appendix A of 29 CFR 1910.119. The RMP standard applies to processes involving regulated toxic and flammable substances under section 112(r) of the Clean Air Act in excess of the threshold quantities specified in 40 CFR 68.130.

Because the applicability criteria are different, a process may be RMP-covered but PSM-exempt, or vice versa. However, the two regulatory standards have significant overlap in their elements that allows for a site to develop a single program that covers both PSM and RMP, with additional emergency response and offsite consequence analysis requirements for RMP.

Because of the numerous overlaps between PSM and RMP, there can be benefits to updating the programs in unison. An RMP submittal is required by EPA every five years at a minimum, and also after changes to the process or chemicals used that affect the process hazard analysis or offsite consequence analysis. This periodic re-submittal requires sites to review a detailed inventory of their chemical types and quantities to confirm the boundaries of the RMP-covered process and update the off-site consequence analysis.  In some cases, this exercise can uncover portions of the process that were erroneously classified as non-RMP in previous submittals.

For example, a mixture containing an RMP-covered chemical below the threshold quantity can still be regulated under RMP if the mixture meets the NFPA-4 criteria for flammability (i.e. flash point below 73 °F and boiling point below 100 °F). This assessment may trigger a review of the boundaries of the PSM process as well, especially as chemicals are added and removed from the site between RMP submittals. Additionally, compliance audits are required for both PSM and RMP every three years, so performing the audits simultaneously helps maintain consistency while saving time and money.

Another potential benefit of consolidating PSM and RMP is the development of a robust emergency response program. While the PSM standard references OSHA’s Emergency Action Plan (29 CFR 1910.38) and Hazardous Waste Operations and Emergency Response (29 CFR 1910.120) standards, there are limited references in those standards regarding cooperation with local emergency response organizations, which many sites rely on in lieu of in-house response teams. The RMP standard specifically calls for sites to coordinate with local emergency response officials to communicate chemical hazards and quantities, release scenarios, and onsite response capabilities – which are all used to plan joint emergency response field and tabletop exercises. For sites that rely on offsite emergency response teams, the emphasis that the RMP standard places on coordination with those groups can improve their ability to respond to an onsite incident as well.

Reach out to our experts with your questions about PSM or RMP applicability, program development, or compliance support. Or tune into our complimentary summer educational series specifically for the chemical industry.

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