Program 1 eligibility under 40 CFR §68.10(b) is contingent upon the process NOT having had an accidental release of a regulated substance that led to offsite death, injury, or response and restoration activities at an environmental receptor within five years prior to the risk management plan submission. Additionally, as part of the hazard assessment required under 40 CFR §68.42(a), sources are required to document ALL accidental releases from covered processes that resulted in onsite or offsite deaths, injuries, property damage, evacuations, sheltering in place, or environmental damage.
Why are there differences in the accident history elements required for determining Program 1 eligibility and the hazard assessment?