Absolutely it can, and allow me to explain how. We start our Risk Management Plan (RMP) program(s) level assessment with Program 1, then if our process(s) does not qualify for Program 1 we ask ourselves if our process(s) would be a Program 3, and then if the process does NOT qualify for Program 1 or 3, then our process(s) will fall into Program 2 by default. So we look at Program 1 first, then Program 3 and if neither fit then we are Program 2 by “default”. But somewhere a nasty rumor got started and many facilities began to believe that if the process was already covered under OSHA’s Process Safety Management standard there was no need to perform this Program Level Assessment and that the process would automatically be a RMP Program 3 process – this just is NOT how it works.
Can my PSM covered process be a RMP Program 1 process?
