For SAFTENG clients and members, I have updated my PSM/RMP audit checklist (the old OSHA PQV checklist) with EPA’s most recent amendment regarding the Emergency Response requirements for Responding and Non-Responding facilities. Keep in mind that these new requirements are “officially” ONLY required when the facility is an RMP facility; if the process(s) is ONLY covered by OSHA’s PSM standard, these requirements would not officially be required – although I highly recommend they be used as a baseline for all PSM/RMP covered facilities. Breaking these requirements down and converting them to questions for checklist documentation was an eye-opening exercise! I hope it helps make these requirements more clear for everyone…