On May 30, 2018, the Environmental Protection Agency (EPA) published proposed revisions to the Risk Management Program (RMP) rules that would largely undo changes to the (stayed) final rule published on January 13, 2017. See 83 Fed. Reg. 24850 (May 30, 2018). Although not a complete one hundred eighty degree U-turn, the revised proposed
RMP was promulgated a few years after PSM and kept the same list of PSI developed by OSHA. See 29 CFR 1910.119(d) and 40 CFR 68.65. Although basically the same list, EPA’s list dropped reference to the health and safety of employees (as they lack authority to regulate the workplace). See 61 Fed. Reg. 31668,
Process safety information (“PSI”) is the foundation on which the rest of the PSM and RMP elements are built. Process safety information is that information that is needed to make sound safety decisions and it includes descriptions of the hazardous chemicals, the technology of the process, and the equipment in the process. Both