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Emergency Response Program (ERP) requirements differ for PSM and RMP  

Safety Info Posts - Chemical Process Safety (PSM/RMP)

Written by Bryan Haywood

Friday, 26 July 2013 16:50

Although the RMP Prevention Plan requirements for Program 2 and 3 very much mirror OSHA's PSM requirements,

the emergency response program requirements found in 68.95 Emergency Response Program go above and beyond

the requirements of 1910.119(n) Emergency planning and response. OSHA's 1910.119(n) Emergency planning and 

response directs us to comply with 1910.38 and 1910.120. And although EPA enforces 1910.120 on those not

covered by OSHA, the RMP emergency response program section (68.95) has a couple of requirements that we will

NOT find in 1910.120(q)(2). Here is what 68.95 states and what our Emergency Response Plan (ERP) may be

missing if we use ONLY 1910.120(q)(2) as our guidance for our emergency response plan:

 § 68.95 Emergency response program. 

(a) The owner or operator shall develop and implement an emergency response program for the purpose of 

 protecting public health and the environment. Such program shall include the following elements: 

(1) An emergency response plan, which shall be maintained at the stationary source and contain at least 

the following elements: 

(i) Procedures for informing the public and local emergency response agencies about accidental 

releases;

(ii) Documentation of proper first-aid and emergency medical treatment necessary to treat accidental 

human exposures; and 

(iii) Procedures and measures for emergency response after an accidental release of a regulated 

substance; 

(2) Procedures for the use of emergency response equipment and for its inspection, testing, and 

maintenance; 

(3) Training for all employees in relevant procedures; and  

(4) Procedures to review and update, as appropriate, the emergency response plan to reflect changes at 

the stationary source and ensure that employees are informed of changes. 

Notice that those who fall under RMP must have "procedures for informin g the publ ic and local emergency 

response agencies abo ut accidental releases ". Now most can just dial 911 to inform their "local emergency 

response agencies", but how many facilities have " procedures for informing the public... about accidental releases"? I

know the fall back for most facilities is that "we let the local emergency response agencies do those notifications".

This may be all well and good, but unless this is SPELLED OUT in the emergency response plan (ERP), then there

are no "procedures" in place for this requirement. And a word of caution, MAKE CERTAIN the "local emergency 

response agencies" know without a doubt it is their role and responsibility to make these notifications. Of course this

means that for ALL releases, your plan will call for the "local emergency response agencies" to be involved, which

may not be the actual desire of the business!

The next specific ERP requirement that we will NOT find in 1910.120(q)(2) is "Docum entation o f proper f i rs t -aid 

and emergency medical t reatment necessary to treat accidental human expo sures ". This ERP requirement

begins with " proper first-aid and emergency medical treatment " for those chemicals used in the covered process. Isuggest cutting and pasting information from WISER or the CDC on emergency care for your covered chemical(s).

But then of course, those who will be providing care to those who came into contact MUST be trained on these

medical care procedures! And don't forget to have procedures to treat burns, especially if your covered process

contains flammable liquids/gases!!!

The next one is the biggest problem for most ERPs... "Procedures for the use of emergency respons e equipment 

and for i ts inspect ion, test ing, and m aintenance ". Yes, this is requiring our plans to have written procedures for

the use, inspection, testing, and maintenance of all our response equipment. This includes EVERYTHING our ER

teams would use, as well as any fixed active and passive mitigation that we claim will mitigate a release. Most

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already have those fixed mitigation system(s) that we use to mitigate a release in the MI program; however, very few

will have written procedures for the use, inspection, testing and maintenance for the following items:

  Level A Suits,

  SCBAs,

  Color Metric Tubes and Pumps,  Firefighting Turn Out Gear,

  Wind Socks,

  Decon Equipment,

  Hand-held meters, etc.

Click HERE to see my article "Emergency Response Equipment Maintenance" for more equipment that would fall

under this ERP requirement.

For example, does our plan call out the pressure test frequency established by the maker of the Level A suit used by

the ERT? Does our plan contain (or even reference) the pressure testing procedures to be used? Each manufacturer

may have some different aspects to testing their suits, from the frequencies of the tests to the pressures used during

testing. Our ERP is required to contain these procedures, then we would need documentation to demonstrate we are

following the procedures and meeting the frequencies. Here is a trick question for you... if you change the brand ofLEVEL A suit does this require an MOC? This is a fun debate to have with fellow PSM Managers, as I would say

without hesitation that if the brand had a different inspection frequency and different test procedures and this required

us to revise our ERP (and possible our CMMS) I would argue that YES an MOC is need to manage this change (e.g.

update the ER procedures and the PM system for the Work Order schedules for the new suits). In fact some

manufacturers REQUIRE their testing system be used, which would require some additional updates and equipment.

How about our SCBAs? Many facilities will have an inspection form, but a form is just a form and is NOT a

"procedure". How many actually have written procedures on how to inspect the SCBAs? These written procedures

should meet or exceed the manufacturers requirements and for that I always just cut and paste the procedures from

the owner’s manual into my ERP. But keep in mind if I have two different brands or types of Supplied Air Respirators

that are used for "emergencies" then I will need procedures for each brand AND type. Most response teams will use

SCBAs, but many facilities that have a response team also have "Escape Packs" for non-responders to use. These

10-minute escape packs MUST also have procedures for their use, inspection, testing, and maintenance. Again,

those who utilize these use, inspection, testing, and maintenance procedures MUST be trained on them and weMUST verify their knowledge of this training. As for those emergency escape packs that are available for everyone to

use... ANNUAL TRAINING is required for these respirators, including those office personnel who we always say are

NOT in our respiratory protection program!!!!!

Last but not least, 68.95 requires us to have "procedu res to review and up date, as appropr iate, the emergency 

response plan to ref lect changes at the stationary source and ens ure that employees are informed o f 

changes ". This one is really tricky as almost all facilities state, "we use our MOC process to inform employees of

changes to our EAP/ERP". Unfortunately, although a great plan, most facilities do NOT do an MOC when they update

their EAP/ERP, so claiming the MOC program as the means to "ensure that employees are informed of changes"

falls flat on its face. Many plans we review do NOT contain " procedures to review and update, as appropriate, the

emergency response plan". In order to comply we need to establish the EAP/ERP as a document that falls under

MOC (just like SOPs and Maintenance Procedures) and establish a frequency for the plan to be reviewed, regardless

of any changes that may have occurred. Who will perform this review? Keep in mind this plan must ALSO comply

with 1910.120(q), which requires us to list our PPE inventory. So any change to our PPE inventory numbers, brands,styles, make/model of respirator face pieces, would need to go through an MOC. Think about the ramifications of

changing to a multi use respirator face piece (one that can be used with SCBA and as an APR). This simple change

would impact the respirator program, the ERP; as well as require ERT members to be fit tested again. This needs an

MOC to manage this change as it can impact many different users, different programs which di fferent people who are

in different departments, etc manage.

So as we can see, there is some significant differences between the "emergency response plan" requirements found

in 1910.120(q)(2) and 68.95. If our process falls under BOTH PSM and RMP, we need to ensure that our plan meets

the requirements of BOTH standards. Although 1910.120 has been around MUCH longer and is a "baseline" for

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many ERPs, we can not overlook these specific RMP requirements for our Emergency Response Plan.