Is a source in compliance with OSHA's PSM already in compliance with Part 68?
If a stationary source includes processes that are subject to both the OSHA process safety management (PSM) standard and the Program 3 risk management program requirements, what must the owner or operator of the stationary source do to demonstrate compliance under 40 CFR Part 68?
A source owner or operator responsible for a process in compliance with the OSHA PSM standard should already be in compliance with the Program 3 prevention program requirements of 40 CFR Part 68, Subpart D (61 FR 31687; June 20 1996). The owner or operator must demonstrate such compliance by providing the information required under 40 CFR §68.175 in the Risk Management Plan for each Program 3 process. In addition, the owner or operator must complete the hazard assessment and emergency response program requirements of 40 CFR part 68.