Today, OSHA issued their revised policy on their “retail exemption” and this change in OSHA enforcement will actually impact thousands of businesses who have submitted a Risk Management Plan. It all comes down to how EPA instituted their “Program Levels” when they implemented their RMP Rule. EPA has always said that if your process was already covered by OSHA’s PSM standard you automatically fall into Program 3. But if your process was not covered by PSM, then your program was eligible to be in Program 1 or 2; which require MUCH LESS than the full blown Program 3. Here is how EPA lays out their Program Levels…
How does OSHA’s revised PSM “retail exemption” policy impact my RMP?
