This is a long time coming. OSHA referenced the use of EPCRA’s Tier II’s in this section; something that has been in place since 1986! For those of you who have stressed over my lengthy and detailed PSM/RMP audit findings regarding emergency planning and response – you’re welcome. Closing out those findings means you are well on your way to being compliant with these proposed regulations. For those questioning the need for PIPs, this has been a requirement in the existing HAZWOPER standard but is only explained in detail in OSHA’s CPL – 73 (starts on page 17).
Here is a breakdown of the proposed Pre-Incident Planning (PIP) requirements for both Workplace Emergency Response Employers (WERE) and Emergency Services Organizations (ESO).
Workplace Emergency Response Employers (WERE) Pre-Incident Planning