The short answer is ABSOLUTELY WE CAN, but we need to be very careful about how we manage our hazardous materials. The purpose of this article is to clear the air about EPA’s use of our own Tier II reports against our facility… they can be an “indicator” of PSM/RMP covered processes but they are NOT an absolute. Let me explain…
Can we have more than the PSM or RMP thresholds on site and not be covered under PSM or RMP?
