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
*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
CHEMICAL | PSM TQ (lbs) |
RMP TQ (lbs) |
---|---|---|
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 |