As we are now 20+ years into the PSM standard (16 years for RMP) I think it may be time to revisit the reason for these standards and what OSHA and EPA are trying to drive us to achieve and how our HHC/EHS inventory management plays a HUGE role in this effort. This MII requirement has not received a lot of attention from OSHA or EPA so there is NOT a lot of literature for us to refer to, but their intent is VERY CLEAR.