During stakeholder outreach as part of EO 13650 and during OSHA’s PSM SBREFA (Small Business Regulatory Enforcement Fairness Act), OSHA and EPA received multiple comments from stakeholders expressing confusion on the applicability and overlap between OSHA’s Process Safety Management (PSM) standard and EPA’s Risk Management Plan (RMP) regulation. In the Clean Air Act Amendments of 1990, Congress required OSHA to adopt the PSM standard to protect workers and required EPA to protect the community and environment by issuing the Risk Management Plan Rule (RMP). PSM and RMP were written to complement each other in accomplishing these Congressional goals.
PSM requires a program with 14 specified management system elements. The RMP rule is broken into three programs with requirements based on the threat they pose to the community and environment. Most facilities that fall under the scope of both PSM and RMP fall into RMP Program 3. Many of the requirements in RMP Programs are identical to PSM’s requirements. The overlap in coverage between the two standards is close but not complete. The Working Group on Chemical Safety and Security developed the tool below to help facilities understand the requirements when they are covered by both regulations.