Under the risk management program regulations at 40 CFR Part 68, sources with Program 2 and Program 3 covered processes are required to develop prevention programs that include personnel training. Will compliance with the training requirements under OSHA's Process Safety Management standard (PSM) satisfy the training requirements under 40 CFR Sections 68.54 and 68.71?
Yes. The training requirements for Program 3 processes at 40 CFR §68.71 have been adopted verbatim from the OSHA PSM with minor wording changes to address statutory differences (61 FR 31712; June 20, 1996). EPA anticipates that sources whose processes are already in compliance with OSHA PSM will not need to take any additional steps to comply with the Program 3 Prevention program (61 FR 31673; June 20, 1996). The training requirements for Program 2 processes at 40 CFR Section 68.54 is a streamlined version of the OSHA PSM training requirements. The primary difference is that the OSHA documentation requirements have been omitted from the Program 2 training requirements (61 FR 31711; June 20, 1996). Additionally, training conducted to comply with other Federal or state rules or industry-specific standards or codes may be used to demonstrate compliance with the Program 2 training requirements (40 CFR Section 68.54(c)).