Yes, I’m well aware that EPA has officially stated that an Org Chart showing who is responsible for the various elements is all that is need to “comply”. But in an actual functioning process safety management system, we will not only define who is responsible for each element but we will also explain HOW each element will be managed. 99.99% of the written programs we see for PSM/RMP are simply a cut and paste of the standard(s) and this does 99.9999% of the employees 0.0000% any good!