Am I required to have an Emergency Action Plan?

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In the world of process safety, this is a no-brainer; but in normal manufacturing facilities, the answer can be quite confusing.  Bottom line… if your facility has a PSM-covered process (even an RMP Program 2 or 3 process) we are REQUIRED to have an EAP that complies with 1910.38.  But when we are not a PSM/RMP facility the answer is much harder to come by…

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