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Do Program 1 processes have to complete a process hazard analysis?

Do owners or operators of Program 1 processes have to complete a process hazard analysis?

No. The Program 1 requirements do not include a process hazard analysis (40 CFR §68.12(b)). Program 3 processes require completion of a process hazard analysis (40 CFR §68.12(d)(3)) while Program 2 processes must complete a hazard review which is similar to a process hazard analysis.

Do Program 1 processes have to complete a process hazard analysis?

Risk Management Program (RMP) Rule