Frequent Questions

How will the RMP rule impact changes to OSHA’s PSM update?

It won’t.  Both the OSHA PSM standard and the EPA RMP rule aim to prevent or minimize the consequences of accidental chemical releases through implementation of management program elements that integrate technologies, procedures, and management practices.  In addition to requiring implementation of management program elements, the RMP rule requires covered sources to submit (to EPA) a document summarizing the source’s risk management program – called a Risk Management Plan (or RMP).  The OSHA PSM standard and EPA RMP regulation are closely aligned in content, policy interpretations, Agency guidance, and enforcement.  Since the inception of these regulations, EPA and OSHA have coordinated closely on their implementation in order to minimize regulatory burden and avoid conflicting requirements for regulated facilities.  This coordination has continued throughout the development of this rule and on OSHA’s initial steps toward proposing potential changes to the PSM standard.  The preamble to the final rule describes topics where EPA’s approach was specifically coordinated with other agencies including OSHA, such as the regulation of AN and the use of the term “practicability” in lieu of “feasibility” for the STAA provision.

EPA received several comments requesting that EPA withdraw its rulemaking and coordinate more closely with OSHA.  EPA has coordinated with OSHA in the development of the proposed and final rules, in which OSHA participated in EPA’s Small Business Advocacy Review (SBAR) panel and EPA participated in OSHA’s SBAR panel.  OSHA has completed this SBAR panel as an initial step toward proposing potential changes to the PSM standard, which may include some changes that are similar to those in the final RMP rule.  However, EPA does not believe it is necessary to conduct its rulemaking on exactly the same timeline as OSHA.  The 1990 CAA Amendments contained separate timelines for the initial OSHA and EPA rulemakings and has no provisions restricting timeframes for either agency amending its rules.

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