Role of PSM in RMP Compliance Programs, 1997 Process Control, Electrical & Info. Conference Proceedings
For many pulp and paper facilities, the Environmental Protection Agency’s (EPA’s) risk management program (RMP) rule (40 CFR 68) applies to more processes than the Occupational Safety and Health Administration’s (OSHA’s) process safety management (PSM) standard (29 CFR 1910.119). Also, the RMP rule’s compliance requirements are more extensive (i.e., it requires more than just PSM). However, the EPA adopted (with modifications) OSHA’s PSM standard as the RMP’s prevention program for Program Level (PL) 3 processes. Because the majority of pulp and paper mill processes covered by RMP are considered PL 3 processes, effective PSM programs can provide the core of an RMP program by satisfying EPA’s prevention program requirements.
This discussion will address the role of existing PSM programs in the RMP compliance system. Comparisons between OSHA’s PSM standard and EPA RMP’s PL 2 and PL 3 prevention programs will be provided.
Role of PSM in RMP Compliance Programs, 1997 Process Control, Electrical & Info. Conference Proceedi