One of the things that EPA learned from OSHA’s roll-out of their PSM standard was that not everyone recognized the standard as a 14-element management system. So when it came time for EPA to roll out its RMP, they made a “management system” part of its requirements. However, EPA quickly disappointed when they said all that was needed was an organizational chart showing who was responsible for each element. And sadly, many facilities have yet even to do this. But we see more often than not a “written PSM program,” and 9 out of 10 times, this “program” is simply a cut and paste of the PSM standard, which causes many issues for facilities that fall under both PSM and RMP. In this article, I want to explain how we can use the framework of these standards to create a functioning SMS which goes a long way in defining key roles for management personnel.