The recent change in OSHA’s PSM definition of a “retail facility” is having a large ripple effect all the way across EPA’s RMP rule. As I wrote about in “How does OSHA’s revised PSM “retail exemption” policy impact my RMP?” this change, thought by many as minor – thus the six-month compliance window for these facilities, is actually quite large and in my opinion IMPOSSIBLE to achieve over six months. In this article I breakdown what actually has to happen to move from an RMP Program Level 2 to an RMP Program Level 3. Here we go …
What it looks like to go from a Level 2 RMP to a Level 3 RMP
