Yes, EPA has a General Duty Clause for RMP, much like OSHA’s General Duty Clause. However, EPA’s is much more detail. This month I came across a facility that used to be a RMP/PSM covered facility, but after much work they lowered their quantities below the RMP/PSM Thresholds. Once this was done, they literally threw away all their RMP/PSM programs (MOC, PSSR, MIP, etc.), purged their PM database of the MI PM’s. There was only a hotwork permit left over from their years in RMP/PSM. Although not why I was at the facility, PSM/RMP came up one night at dinner and I asked them if they were familiar with EPA’s version of the General Duty Clause for RMP. You could have heard a pin drop and the looks were priceless. They inquired what it was and what kind of impact it could have on their facility. It basically requires the exact same elements, but they are not as specific in their requirements. If you have a listed “Extremely Hazardous Substance” on site in any quantities, the General Duty Clause is in play for an inspector to use. Here are some of the requirements from EPA’s GD Audit Protocol as they relate to Standard Operation Procedures. Standard Operating Procedures: 1) responsible for ensuring that the process and equipment are operated within safe limits; 2) SOPs should be written for every aspect of the processes; 3) procedures should identify safe upper and lower limits for process variables and identify corrective measures and emergency situations; 4) procedures should be correct and accurate, clear, concise, and written at the appropriate reading level for the operator; 5) SOPs should include the various phases of operation, including pre-startup checks, startup, normal operations, temporary operations, normal shutdown and emergency shutdown; 6) SOPs should address receiving, storing, transferring and shipping of extremely hazardous substances to minimize the likelihood of a release from other than chemical process areas; 7) SOPs should clearly warn about conditions/practices likely to cause a release as identified in the PHA and steps that the employee/operator must take to prevent a release if these conditions are encountered. Look familiar? Pretty much the same thing if you were over the threshold. Again the only thing are the “specifics” such as there is no “annual certification” requirements. SOPs still have to be accurate and contain the same aspects as a “covered process”. This General Duty Clause goes on and covers most of the 14 elements of PSM, just minus the details found in the regulation. Click Here (.pdf) to see the entire EPA GD Audit Guide.