Although PSM and RMP currently only apply to a limited number of facilities (i.e., those that have more than a threshold amount in a process), both OSHA and the Clean Air Act have "General Duty" clauses that extend the requirements of both rules to otherwise unaffected facilities. A recent USEPA enforcement initiative under the RMP regulation illustrates the seriousness with which the agencies view process safety and risk management as everyone's responsibility.
What you will learn
- Overview of the proposed changes to RMP rules and PSM's implementing guidance
- Discussion of the General Duty clauses under both acts and the link to corporate EHS responsibilities
- Review of USEPA's recent RMP enforcement initiative (centered around anhydrous ammonia systems) and how those results, when viewed through recent case studies, may shape compliance with these regulations