UPDATE 08/12/12 – Region 10 EPA has now publicly stated they are now aware of how this OR-OSHA change has impacted “ammonia retail businesses” (in the state of Oregon) RMP submittals! If you are an “anhydrous ammonia retail business” in the state of Oregon and had submitted an RMP, beware EPA may be paying you a visit if your RMP submittal was not updated in 2010 to reflect a change in Program Level (e.g. from Program 1 or 2 to a Program 3). Here is my newsletter article from December 2010 explaining how this change in the OR-OSHA state plan PSM exemption impacted these businesses in a HUGE way regarding their RMPs….
OR-OSHA changes their PSM applicability to NH3 Fertilizer and the impact it will have on RMP
