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Process Safety Management and Risk Management Plan Regulatory Requirements

During stakeholder outreach as part of EO 13650 and during OSHA's PSM SBREFA (Small Business Regulatory Enforcement Fairness Act), OSHA and EPA received multiple comments from stakeholders expressing confusion on the applicability and overlap between OSHA's Process Safety Management (PSM) standard and EPA's Risk Management Plan (RMP) regulation. In the Clean Air Act Amendments of 1990, Congress required OSHA to adopt the PSM standard to protect workers and required EPA to protect the community and environment by issuing the Risk Management Plan Rule (RMP). PSM and RMP were written to complement each other in accomplishing these Congressional goals.

PSM requires a program with 14 specified management system elements. The RMP rule is broken into three programs with requirements based on the threat they pose to the community and environment. Most facilities that fall under the scope of both PSM and RMP fall into RMP Program 3. Many of the requirements in RMP Programs are identical to PSM's requirements. The overlap in coverage between the two standards is close but not complete. The Working Group on Chemical Safety and Security developed the tool below to help facilities understand the requirements when they are covered by both regulations.

Each column lists all of the elements that employers must comply with when a process falls under PSM and that specific RMP program in the column header. By clicking on an element listed in that column, employers can view the regulatory text of both PSM and the RMP program for that element. As described at the bottom of each of those links, OSHA requirements are in bold, EPA requirements are in italics, and regular font shows areas where the regulatory requirements are identical.

At the far right column titled "CCPS Risk Based Process Safety Elements" employers can also find reference to the elements that are a part of the Center for Chemical Process Safety (CCPS) Risk Based Process Safety Guidelines. CCPS Risk Based Process Safety is not a regulatory requirement, however it does provide helpful guidance for process safety programs. For more information on the CCPS Risk Based Process Safety best practices, please visit: http://www.aiche.org/ccps/resources/publications/summaries/summary-guidelines-risk-based-process-safety

Below is a table that compares the threshold quantities of chemicals, listed under both standards Jump to Table

Note: The text in the details windows is a combination of both PSM language and RMP language. For clarity, PSM-only language is in bold, while RMP-only language is in italics.

PSM and RMP requirements, by RMP Plan

Regulatory Requirements Non-Regulatory Best Practices
PSM & RMP Program 1 PSM & RMP Program 2 PSM & RMP Program 3 CCPS Risk Based Process Safety Elements*
Employee Participation Employee Participation Employee Participation Workforce Involvement
Process Safety Information Process Safety Information Process Safety Information Compliance with Standards
Process Knowledge Management
Process Hazards Analysis Process Hazards Analysis Process Hazards Analysis Hazard Identification and Risk Analysis
Operating Procedures Operating Procedures Operating Procedures Operating Procedures
Safe Work Practices
Training Training Training Training and Performance Assurance
Contractors Contractors Contractors Contractor Management
Pre-startup Safety Review Pre-startup Safety Review Pre-startup Safety Review Operational Readiness
Mechanical Integrity Mechanical Integrity Mechanical Integrity Asset Integrity and Reliability
Hot Work Permit Hot Work Permit Hot Work Permit see Safe Work Practices
Management of Change Management of Change Management of Change Management of Change
Incident Investigation Incident Investigation Incident Investigation Incident Investigation
Emergency Planning and Response Emergency Planning and Response Emergency Planning and Response Emergency Management
Compliance Audits Compliance Audits Compliance Audits Auditing
Worst-Case Release Analysis Worst-Case Release Analysis Worst-Case Release Analysis N/A
N/A Alternative Release Analysis Alternative Release Analysis N/A
5-year Accident History 5-year Accident History 5-year Accident History N/A
N/A Document Management System Document Management System N/A

*CCPS Risk Based Process Safety program includes additional management systems that are not displayed in this table -- specifically: Process Safety Culture; Process Safety Competency; Stakeholder Outreach; Conduct of Operations; Measurement and Metrics; Management Review and Continuous Improvement. These management systems omitted for clarity, as the PSM and RMP regulations do not have correlating requirements.

Below is a table of PSM and RMP covered chemicals and their respective threshold quantities (TQ). It should be noted that OSHA's PSM standard also has coverage requirements for the manufacturing of explosives and facilities with more than 10,000 pounds of flammable chemicals (for specific coverage details, please refer to the PSM standard).

Threshold Quantities, in pounds for PSM/RMP covered substances

Acetaldehyde 2500 10000
Acetylene N/A 10000
Acrolein [2-Propenal] 150 5000
Acrylonitrile [2-Propenenitrile] N/A 20000
Acrylyl chloride [2-Propenoyl chloride] 250 5000
Allyl alcohol [2-Prooen-ol] N/A 15000
Allyl Chloride 1000 N/A
Allylamine [2-Propen-l-amine] 1000 10000
Alkylaluminum 5,000 N/A
Ammonia (anhydrous) 10000 10000
Ammonia (conc 20% or greater) N/A 20000
Ammonia solutions (greater than 440% ammonia by weight) 15000 N/A
Ammonium Perchlorate 7500 N/A
Ammonium Permanganate 7500 N/A
Arsenous trichloride N/A 15000
Arsine (also called Arsenic Hydride) 100 1000
Bis (Chloromethyl) Ether 100 N/A
Boron trichloride [Borane, trichloro-] 2500 5000
Boron trifluoride [Borane, trifluoro-] 250 5000
Boron trifluoride compound with methyl ether (1:1) [Boron, trifluoro [oxybis [metane]]-, T-4- N/A 15000
Bromine 1500 10000
Bromine Chloride 1500 N/A
Bromine Pentafluoride 2500 N/A
Bromine Trifluoride 15000 N/A
3-Bromopropyne (also called Propargyl Bromide) 100 N/A
Bromotrifluorethylene [Ethene, bromotrifluoro-] N/A 10000
1,3-Butadiene N/A 10000
Butane N/A 10000
1-Butene N/A 10000
2-Butene N/A 10000
Butene N/A 10000
2-Butene-cis N/A 10000
2-Butene-trans [2-Butene, (E)] N/A 10000
Butyl Hydroperoxide (Tertiary) 5000 N/A
Butyl Perbenzoate (Tertiary) 7500 N/A
Carbonyl Chloride (see Phosgene) 100 N/A
Carbon disulfide N/A 20000
Carbonyl Fluoride 2500 N/A
Chlorine monoxide [Chlorine oxide] N/A 10000
Cellulose Nitrate (concentration greater than 12.6% nitrogen) 2,500 N/A
Carbon oxysulfide [Carbon oxide sulfide (COS)] N/A 10000
Chlorine 1500 2500
Chlorine dioxide [Chlorine oxide (ClO2)] 1000 1000
Chlorine monoxide [Chlorine oxide] N/A 10000
Chlorine Pentrafluoride 1000 N/A
Chlorine Trifluoride 1000 N/A
Chlorodiethylaluminum (also called diethylaluminum Chloride) 5000 N/A
1-Chloro-2,4-Dinitrobenzene 5000 N/A
Chloroform [Methane, trichloro-] N/A 20000
Chloromethyl ether [Methane, oxybis[chloro-] N/A 1000
Chloromethyl methyl ether [Methane, chloromethoxy-] 500 5000
Chloropicrin 500 N/A
Chloropricin and Methyl Bromide mixture 1500 N/A
Chloropicrin and Methyl Chloride mixture 1500 N/A
Crotonaldehyde [2-Butenal] N/A 20000
Crotonaldehyde, (E)- [2-Butenal, (E)-] N/A 20000
Cumene Hydroperoxide 5000 N/A
Cyanogen 2500 N/A
Cyanogen Chloride 500 10000
Cyanogen [Ethanedinitrile] N/A 10000
Cyanuric Fluoride 100 N/A
Cyclohexylamine [Cyclohexanamine] N/A 15000
Cyclopropane N/A 10000
Diacetyl Peroxide (concentration greater than 70%) 5000 N/A
Diazomethane 500 N/A
Dibenzoyl Peroxide 7500 N/A
Diborane 100 2500
Dibutyl Peroxide (Tertiary) 5000 N/A
Dichloro Acetylene 250 N/A
Dichlorosilane [Silane,dichloro-] 2500 10000
Difluoroethane [Ethane, 1,1-difluoro-] N/A 10000
Diethylzinc 10000 N/A
Diisopropyl Peroxydicarbonate 7500 N/A
Dilauroyl Peroxide 7500 N/A
Dimethyldichlorosilane [Silane, dichlorodimethyl-] 1000 5000
1,1-Dimethylhydrazine [Hydrazine, 1,1-dimethyl-] 1000 15000
Dimethylamine, Anhydrous 2500 N/A
Dimethylamine [Methanamine, N-methyl-] N/A 10000
2,2-Dimethylpropane [Propane, 2,2-dimethyl-] N/A 10000
2,4-Dinitroaniline 5000 N/A
Epichlorohydrin [Oxirane, (chloromethyl)-] N/A 20000
Ethane 10000 N/A
Ethyl acetylene [1-Butyne] N/A 10,000
Ethylamine [Ethanamine] 7500 10000
Ethyl chloride [Ethane, chloro-] N/A 10000
Ethylene [Ethene] N/A 10000
Ethylenediamine [1,2-Ethanediamine] N/A 20000
Ethyleneimine [Aziridine] 1000 10000
Ethyl ether [Ethane, 1,1'-oxybis-] N/A 10000
Ethylene Fluorohydrin 100 N/A
Ethyl mercaptan [Ethanethiol] N/A 10000
Ethyl Methyl Ketone Peroxide (also Methyl Ethyl Ketone Peroxide; concentration greater than 60%) 5000 N/A
Ethyl nitrite [Nitrous acid, ethyl ester] 5000 10000
Ethylene oxide [Oxirane] 5000 10000
Fluorine 1000 1000
Formaldehyde (solution)(Formalin) 1000 15000
Furan 500 5000
Hexafluoroacetone 5000 N/A
Hydrazine N/A 15000
Hydrochloric acid (conc 37% or greater) N/A 15000
Hydrochloric Acid, Anhydrous 5000 N/A
Hydrocyanic acid N/A 2500
Hydrofluoric Acid, Anhydrous 1000 N/A
Hydrogen N/A 10000
Hydrogen Bromide 5000 N/A
Hydrogen chloride (anhydrous) [Hydrochloric acid] 5000 5000
Hydrogen Cyanide, Anhydrous 1000 N/A
Hydrogen Fluoride/Hydrofluoric acid (conc 50% or greater) [Hydrofluoric acid] 1000 1000
Hydrogen Peroxide (52% by weight or greater) 7500 N/A
Hydrogen Selenide 150 500
Hydrogen Sulfide 1500 10000
Hydroxylamine 2500 N/A
Iron, Pentacarbonyl- [Iron carbonyl (Fe(CO)5), (TB-5-11)-] 250 2500
Isobutane [Propane, 2-methyl] N/A 10000
Isobutyronitrile [Propanenitrile, 2-methyl-] N/A 20000
Isopentane [Butane, 2-methyl-] N/A 10000
Isoprene [1,3-Butadinene, 2-methyl-] N/A 10000
Isopropylamine [2-Propanamine] 5000 10000
Isopropyl chloride [Propane, 2-chloro-] N/A 10000
Isopropyl chloroformate [Carbonochloridic acid, 1-methylethyl ester] N/A 15000
Ketene 100 N/A
Methacrylaldehyde 1000 N/A
Methacrylonitrile [2-Propenenitrile, 2-methyl-] N/A 10000
Methacryloyl Chloride 150 N/A
Methacryloyloxyethyl Isocyanate 100 N/A
Methane N/A 10000
Methyl Acrylonitrile 250 N/A
Methylamine [Methanamine], Anhydrous 1000 10000
3-Methyl-1-butene N/A 10000
2-Methyl-1-butene N/A 10000
Methyl Bromide 2500 N/A
Methyl Chloride [Methane, chloro-] 15000 10000
Methyl Chloroformate [Carbonochloridic acid, methylester] 500 5000
Methyl ether [Methane, oxybis-] N/A 10000
Methyl Ethyl Ketone Peroxide (concentration greater than 60%) 5000 N/A
Methyl Fluoroacetate 100 N/A
Methyl Fluorosulfate 100 N/A
Methyl formate [Formic acid, methyl ester] 10000 N/A
Methyl Hydrazine [Hydrazine, methyl-] 100 15000
Methyl Iodide 7500 N/A
Methyl Isocyanate [Methane, isocyanato-] 250 10000
Methyl Mercaptan [Methanethiol] 5000 10000
2-Methylpropene [1-Propene, 2-methyl-] N/A 10000
Methyl thiocyanate [Thiocyanic acid, methyl ester] N/A 20000
Methyltrichlorosilane [Silane, trichloromethyl-] 500 5000
Methyl Vinyl Ketone 100 N/A
Nickel carbonyl (Nickel Tetracarbonyl) 150 1000
Nitric acid (conc 80% or greater)(94.5% by weight, or greater) 500 15000
Nitric oxide [Nitrogen oxide (NO)] 250 10000
Nitroaniline (para Nitroaniline) 5000 N/A
Nitrogen Dioxide 250 N/A
Nitrogen Oxides (NO; NO(2); N204; N203) 250 N/A
Nitromethane 2500 N/A
Nitrogen Tetroxide (also called Nitrogen Peroxide) 250 N/A
Nitrogen Trifluoride 5000 N/A
Nitrogen Trioxide 250 N/A
Oleum (Fuming Sulfuric acid) [Sulfuric acid, mixture with sulfur trioxide] (65% to 80% by weight; also called Fuming Sulfuric Acid) 1000 10000
Osmium Tetroxide 100 N/A
Oxygen Difluoride (Fluorine Monoxide) 100 N/A
Ozone 100 N/A
Pentaborane 100 N/A
1,3-Pentadinene N/A 10000
Pentane N/A 10000
1-Pentene N/A 10000
2-Pentene, (E)- N/A 10000
2-Pentene, (Z)- N/A 10000
Peracetic Acid (concentration greater 60% Acetic Acid; also Called Peroxyacetic Acid) 1000 N/A
Peracetic acid [Ethaneperoxoic acid] N/A 10000
Perchloric Acid (concentration greater than 60% by weight) 5000 N/A
Perchloromethyl Mercaptan [methanesulfenyl chloride, trichloro-] 150 10000
Perchloryl Fluoride 5000 N/A
Peroxyacetic Acid (concentration greater than 60% Acetic Acid; also called Peracetic Acid) 1000 N/A
Phosgene (also called Carbonyl Chloride) [Carbonic dichloride] 100 500
Phosphine (Hydrogen Phosphide) 100 5000
Phosphorus Oxychloride (also called Phosphoryl Chloride) 1000 5000
Phosphorus Trichloride 1000 15000
Piperidine N/A 15000
Propadiene [1,2-Propadiene] N/A 10000
Propane N/A 10000
Propargyl Bromide 100 N/A
Propionitrile [Propanenitrile] N/A 10000
Propyl chloroformate [Carbonochloridic acid, propylester] N/A 15000
Propylene [1-Propene] N/A 10000
Propyleneimine [Aziridine, 2-methyl-] N/A 10000
Propyl Nitrate 2500 N/A
Propylene oxide [Oxirane, methyl-] N/A 10000
Propyne [1-Propyne] N/A 10000
Sarin 100 N/A
Selenium Hexaflouride 1000 N/A
Silane N/A 10000
Stibine (Antimony Hydride) 500 N/A
Sulfur Dioxide (liquid) [anhydrous] 1000 5000
Sulfur Pentafluoride 250 N/A
Sulfur Tetrafluoride [Sulfur fluoride (SF4),(T-4)-] 250 2500
Sulfur trioxide (also called Sulfuric Anhydride) 1000 10000
Sulfuric Anhydride (also called Sulfur Trioxide) 1000 N/A
Tellurium Hexafluoride 250 N/A
Tetrafluoroethylene [Ethene, tetrafluoro-] 5000 10000
Tetrafluorohydrazine 5000 N/A
Tetramethyl Lead [Plumbane, tetramethyl-] 1000 10000
Tetramethylsilane [Silane, tetramethyl-] N/A 10000
Tetranitromethane [Methane, tetranitro-] N/A 10000
Thionyl Chloride 250 N/A
Titanium tetrachloride [Titanium chloride (TiCl4) (T-4)-] N/A 2500
Toluene 2,4-diisocyanate [Benzene, 2,4-diisocyanato-1-methyl-]1 N/A 10000
Toluene 2,6-diisocyanate [Benzene, 1,3-diisocyanato-2-methyl-]1 N/A 10000
Toluene diisocyanate (unspecified isomer) [Benzene, 1,3-diisocyanatomethyl-]1 N/A 10000
Trichloro (chloromethyl) Silane [Silane, trichloro-] 100 N/A
Trichloro (dichlorophenyl) Silane 2500 N/A
Trichlorosilane 5000 10,000
Trifluorochloroethylene [Ethene, chlorotrifluoro-] 10000 10000
Trimethylamine [Methanamine, N,N-dimethyl-] N/A 10000
Trimethylchlorosilane [Silane, chlorotrimethyl-] N/A 10000
Trimethyoxysilane 1500 N/A
Vinyl acetate monomer [Acetic acid ethenyl ester] N/A 15000
Vinyl acetylene [1-Buten-3-yne] N/A 10000
Vinyl chloride [Ethene, chloro-] N/A 10000
Vinyl ethyl ether [Ethene, ethoxy-] N/A 10000
Vinyl fluoride [Ethene, fluoro-] N/A 10000
Vinylidene chloride [Ethene, 1,1-dichloro-] N/A 10000
Vinylidene fluoride [Ethene, 1,1-difluoro-] N/A 10000
Vinyl methyl ether [Ethene, methoxy-] N/A 10000

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