For several editions, the IFC has incorporated a “Performance-Based Design Alternative” to comply with the requirements of Part V—Hazardous Materials (Chapters 50-67). This was initially added so that facilities already doing PSM/RMP could show compliance with the state fire code without any additional work. In the 2021 edition of the IFC, this alternative has been expanded to include some new management system elements that, in my professional opinion, puts this SMS over and above PSM/RMP. If only OSHA or EPA would recognize this alternative SMS. Here are the elements and their requirements (FREE ACCESS):