How many Program 2 RMPs like West Fertilizer are out here?

Today I was quoted in an article related to the catastrophe in West, TX and how a business like that one can become a Program 2 RMP and be exempted from OSHA’s PSM standard.  I had written an article two weeks ago explaining how this happens (How could the TX fertilizer plant be a Program 2 RMP?); this article I wish to defend my comment that this “retail exemption” is very wide spread (e.g. 39 states have businesses handling Anhydrous Ammonia that have Program 2 RMP facilities).  In all, I just looked at the NAICS that West Fertilizer stated on their RMP and the next NAICS very similar to West Fertilizer.  Here is the data to support my statements, and keep in mind I ONLY looked at two industry groups to come up with these numbers!

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