For those who fall under EPA’s RMP rule, you are familiar with the three (3) program levels your process(s) will fall under and each of these program levels has varying degrees of hazard recognition requirements. Many professionals involved in process safety are familiar with the term Process Hazards Analysis (PHA), but an RMP Program 2 process is NOT required to conduct a PHA. A process that meets the definition of a Program 2 process is REQUIRED to conduct what EPA calls a “Hazard Review”, which is a different and less demanding type of hazard review. EPA indicates this in a recent FAQ…