There is only one level of PSM applicability; either you are in or out. Processes are subject to PSM if they contain the threshold amount of a Chemical found in Appendix A to the rule, or if it has more than 10,000 pounds of a flammable gas or liquid. See 29 CFR 1910.119(a). PSM applicability has five important exceptions: non-refrigerated storage of flammable liquids in atmospheric storage tanks, fuels used for workplace consumption, retail facilities, oil and gas well drilling or servicing operations, and normally unoccupied remote buildings.

A “covered process” under RMP is a process that contains more than a threshold quantity, as listed in 40 CFR 68.130, using calculation methods listed in §68.115. If a process is covered, requirements will be based on classification with one of three “program” levels. Program 3 applicability is the most demanding, the Program 2, with Program 1 being the least demanding. Applicability criteria for the three programs is found at 40 CFR 68.10.

For more information, contact Lee Vail.

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