Today I learned of yet another SIGNIFICANT difference in complying with EPA’s RMP vs. OSHA’s PSM. Yes old dogs can learn new tricks and I am betting that I may not be the only old dog “out of compliance” with 68.200! We have been assisting a company with a US EPA RMP inspection and in doing so I have had the pleasure of working with a very sharp attorney. As we were working through some documentation items he/she indicated that 68.200 required that the facilities maintain their SOP annual certifications for 5 years. This was a new one on me, as I always applied 68.200 to my OCA supporting documentation, but never to my annual certifications of SOPs. I found our today how WRONG I have been!! At my former facilities we would have been able to produce this evidence as far back as 1992 as we always had our procedures in a control document management system; but we did this NOT because of 68.200, but rather that is the way you manage critical administrative controls! So I challenged the attorney and US EPA resources about this assertion that 68.200 applied to SOP annual certifications and this is what I learned today… and yes this old dog has his tail between his legs tonight!