Comments of the BlueGreen Alliance on EPA-HQ-OEM-2014-0328

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Comments submitted by the BlueGreen Alliance in response to Federal Register 

Notice Accidental Release Prevention Requirements: Risk Management Programs 

Under the Clean Air Act, Section 112(r)(7); Rule Modernization Under Executive 

Order 13650; Request for Information (July 31,2014) Docket Number EPA-HQ-OEM2014-0328

This document provides the recommendations of the BlueGreen Alliance in response to

the Environmental Protection Agency’s request for comments on potential revisions to 

its Risk Management Program regulations and related programs. The BlueGreen 

Alliance is a strategic partnership of 10 large unions and five national environmental 

organizations collectively representing 16 million members and supporters. 

Our comments follow the same general order as EPA’s Request for Information, but not 

commenting on every section of the RFI. The BlueGreen Alliance and many of its 

partners are members of the Coalition to Prevent Chemical Disasters and strongly 

support the comments submitted by that Coalition.

IIB. Potential Costs and Economic Effects of Regulatory and Policy Changes

The RFI asks for information on the potential costs of amending regulatory 

requirements. The BlueGreen Alliance recommends that EPA put more weight on the 

potential costs of not using the Executive Order to strengthen protections against 

chemical hazard. 

The story of Union Carbide’s methyl isocyanate gas tragedy in Bhopal, India is a 

warning against simple monetization of the costs of protective policies. The liability 

settlement payments of Union Carbide would have cost more than 10 billion dollars if 

victims of the 1984 Bhopal Disaster had been paid at the same rate as asbestosis victims 
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in the United States.

1 This sizable amount does not begin to cover the long-term costs of 

the 300,000 living victims of Bhopal nor the lasting damage to their respiratory, 

reproductive, ocular, genetic and neurological health.2

Preventing these environmental health costs must be the first priority of the EPA. When 

prevention strategies are likely to impact a substantial number of small entities, funding 

mechanisms can be created to assure that small businesses don’t pose outsized risks for 

their workers and surrounding communities. 

The U.S. chemical industry stands to benefit from rules that encourage innovation and 

new approaches to product design and production. In 2011, the BlueGreen Alliance 

released a report that showed how additional regulation can support job creation in the 

U.S. chemical industry while protecting public health and the environment. The study, 

produced by the Political Economy Research Institute (PERI) and commissioned by the 

BlueGreen Alliance, shows that innovation in sustainable chemistry can reverse the 

industry's job shedding trend in a market that increasingly requires cleaner, safer 

production.

The report - The Economic Benefits of a Green Chemical Industry in the United States: 

Renewing Manufacturing Jobs While Protecting Health and the Environment - demonstrated

that the U.S. chemical industry shed 300,000 jobs since 1992, despite production 

increasing by 4 percent per year. Under that scenario, the industry stands to lose 

approximately 230,000 jobs in the next 20 years. But contrary to arguments that 

regulatory reform will cost jobs and stifle innovation, the report demonstrates that 

innovation in sustainable chemistry presents new opportunities to reverse the job 

shedding trend. For example, if 20 percent of current production were to shift from 

petrochemical-based plastics to bio-based plastics, 104,000 additional jobs could be 

created in the U.S. economy.

IIC. Items in OSHA's RFI Relevant to EPA's RMP Regulation

 1c. BlueGreen Alliance Comments on Adding Agricultural Grade Ammonium 

 Nitrate (AN)

																																																												 1 Castleman B PP. Appendix: the Bhopal disaster as a case study in double standards. In: Ives J, editor. The exportof 

hazards: trans-national corporations and environmental control issues. London , Routledge and Kegan Paul; 1985. 

pp. 213–222. 2 Dhara VR, Dhara R. The Union Carbide disaster in Bhopal: a review of health effects. Arch Environ Health. 

2002;57:391–404. [PubMed]
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We recommend that:

• EPA list AN as an RMP chemical and require that distribution facilities, to the 

greatest extent feasible, substitute AN with inherently safer alternatives, or, as a 

minimum, conform to the requirements of the latest version of NFPA 400, 

Chapter 11 on AN.

• EPA and other agencies should systematically research the technical efficacy, 

costs, and trade-offs of the several reported AN substitutes or alterations (e.g., 

physical form, mixing with other salts, substitution by other sources of desired 

minerals) including any environmental and lifecycle impacts of such changes.

• EPA should develop a vigorous compliance assistance and education campaign 

to reach the newly regulated parties with the relevant guidance.

 1d. BlueGreen Alliance Comments on Adding Reactive Substances 

There are several actions that the agency should take towards this goal, as 

follows:

• Implement the 2002 recommendations issued the US Chemical Safety Board, 

following its study of reactive hazards 

(http://www.csb.gov/assets/1/19/ReactiveHazardInvestigationReport.pdf). 

These recommendations were wide-ranging, including the development of a 

publicly available database of reactivity information, with the collaboration of 

the National Institute of Standards and Technology, and relying on data that are 

now largely held by industry (with the appropriate controls to address potential 

liability and confidentiality); the adoption of a broader list of reactive substances; 

and the consideration of reactive chemistry potential for mixtures or specific 

process conditions. It may also be advisable to adopt requirements that would 

trigger reactivity hazard analyses when certain conditions exist (e.g., certain 

mixtures of chemicals, the presence of certain potentially reactive chemical 

moieties, certain process conditions or other relevant factors that may suggest 

potential reactive chemistry risks).

• Investigate the effectiveness, and the possible adoption of all or parts of the 

approach towards the management of reactive hazards of the New Jersey Toxic 

Catastrophe Prevention Act (http://www.nj.gov/dep/rpp/brp/tcpa/), which is 

based on the presence of certain reactive moieties in the substances in the 

process, as well as other factors. These or other factors could serve to trigger 

obligations for the conduct of reactivity hazard analyses with tools such as the 
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Reactivity Evaluation Software Tool developed by the Center for Chemical 

Process Safety

• (http://www.aiche.org/ccps/resources/chemeondemand/conferencepresentations/ccps-reactivity-evaluation-software-tool), or the closely related 

Chemical Reactivity Worksheet of the National Oceanic and Atmospheric 

Administration (http://response.restoration.noaa.gov/oil-and-chemicalspills/chemical-spills/response-tools/downloading-chemical-reactivityworksheet.html).

2. through 6. Additional Risk Management Program Elements, RAGAGEP, 

Mechanical Integrity Requirements, MOCs and Third Party Audits

Approximately two decades have passed since OSHA’s PSM standard and EPA’s RMP 

rules went into effect, and a great deal of experience and knowledge have accumulated 

in that time. Yet neither rule has been materially updated. The evidence is abundant 

that best practices to prevent chemical accidents have evolved a great deal since the 

Clean Air Amendments that triggered these two standards as evidenced. Center for 

Process Safety of the American Institute of Chemical Engineers 

(http://www.aiche.org/ccps), to cite only one example, has published dozens of books 

and other specialized publications that contain new best practices. Much has also been 

learned from the investigation of catastrophic incidents by the US Chemical Safety 

Board, the British Health Safety Executive and similar agencies, as well as from the 

enforcement experience of OSHA and EPA. This experience needs to be incorporated 

into the modernized standards. Both rules are therefore due for major review and 

modernization. 

The following recommendations address twenty-six major areas where the BlueGreen 

Alliance believes there should be fundamental changes made to the OSHA PSM 

standard and the EPA’s RMP rules:

A. Explicitly include the basic management system principle of continual 

improvement towards the goal of reducing risks associated with any process 

to the greatest extent feasible. This principle is at the core of all management 

system standards, including ISO quality and environmental management 

system standards, as well as health and safety management system standards 

by AIHA/ANSI in the U.S., the International Labor Organizations (ILO), and 

the British Standards Institute (BSI).
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B. Explicitly require, to the greatest extent feasible, the maximum use of 

inherently safer chemicals, technologies and processes. As proposed in the 

California Process Safety Management proposed regulation (9/9/2014 draft) 

the revised RMP should require that: 

i. Facility owners and operators identify, characterize and prioritize each

process safety risk against the objective of preventing major incidents and

eliminating to the greatest extent feasible, health and safety risks to which

employees or fenceline communities may be exposed.

ii. Owners and operators identify and evaluate relevant inherent safety

measures and safeguards (or where appropriate, combinations of measures

and safeguards) in an iterative manner to reduce each risk to the greatest

extent feasible.

iii. Where facility owners and operators do not implement an inherent safety

measure, the employer shall document and justify in writing: (a) why that 

measure is not feasible; and (b) why the measures it has implemented are

the most protective alternative measures feasible.

C. Strengthen the involvement of employees and their representatives. As 

proposed in the California Process Safety Management proposed regulation 

(9/9/2014 draft), facility owners and operators must be required to develop,

implement and maintain a written plan to ensure employee participation in 

Process Safety Management. The plan shall include provisions that provide

for the following:

i. Consultation with employees and their representatives on the

development, implementation and maintenance of all elements of

Process Safety Management;

ii. Access by employees and their representatives to all information

developed on process safety management including information that

might be subject to protection as a trade secret.

iii. A requirement that all employees who serve on any committee or in an

advisory capacity be selected by employees or employee

representatives.

iv. The development, implementation and maintenance of an effective Stop

Work Authority and Hazard Reporting Program that ensures at a
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minimum:

a. The right of all employees, including employees of contractors, to

refuse work based on safety or health concerns and

anonymously report hazards.

b. The right of all employees, including employees of contractors, to

recommend to the operator in charge of a unit that an operation 

or process be stopped or shut down based on safety or health

concerns; and

c. The authority of the operator in charge of a unit to stop or shut

down an operation or process based on safety or health

concerns.

D. The EPA should investigate the possible establishment of one or more systems 

of anonymous reporting of safety problems similar to the Federal Aviation 

Administration’s Aviation Safety Action Program 

(http://www.faa.gov/about/initiatives/asap/). The system encourages the 

reporting of safety-related events anonymously in the aviation industry, even 

when they may involve mistakes on the part of the reporting employee. 

E. The EPA and its Working Group partners should establish a publicly available 

database repository of proven, promising and experimental inherently safer 

alternatives to hazardous chemicals, technologies and processes, in 

collaboration with private sector partners such as chemical industry trade and 

professional associations, labor, academia, and other interested stakeholders.

F. The BlueGreen Alliance recommends the initiation of two or more pilot projects 

to actively pursue and obtain the implementation of IST in specific processes 

where the economic and technical feasibility are reasonably well established. 

Some candidate projects are the elimination of Hydrogen Fluoride (HF) from 

alkylation processes in refineries, the substitution of chlorine by inherently safer 

substitutes in both municipal and industrial water treatment processes, and the 

substitution of the currently-used forms of ammonium nitrate by less hazardous 

substitutes.

G. We further suggest that EPA and the Working Group recommend the 

establishment and implementation of economic incentives to encourage firms 

to discover, test, and commercially deploy inherently safer alternatives to 
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hazardous chemical processes. These incentives may entail, for example, tax 

relief mechanisms, “rewards” for demonstrable risk reductions or others. 

H. These incentives could be paid for by substantially increasing penalties for 

serious violations so the fines reflect the true toll that chemical facilities take on 

the health and safety of the American people and their environment. 

I. Requirements should be established to collect and publicly report normalized 

and standardized process safety performance indicators that would be 

reported by regulated parties and made publicly available by EPA for the site, 

corporate and national levels. Indicators are an indispensable element for any 

effective health and safety management system. As the saying goes, “if you 

don’t measure it, you can’t manage it.” While much attention has been given to 

the difference between “leading” and “lagging” indicators, we believe that the 

full range of this spectrum of indicators must be utilized, and that an excessive 

emphasis on the distinction between them can detract attention from the 

essential characteristics of effective indicators, as follows:

i. Their primary goal and attribute must be their ability to continually drive 

improvements in safety performance. Indicators can drive improvements 

at the site, corporate, industry sector or national levels. Indicators will 

also help to target enforcement efforts to the worst hazards and worst 

violators, as well as permit the evaluation of the effectiveness of the 

regulatory and industry efforts to control chemical hazards.

ii. They must be predictive of the potential for serious incidents, so they can 

drive improved performance. Whether they are “leading” or “lagging” 

will depend on the time frame envisioned for the preventive actions. For 

example, a process failure that leads to an unplanned release which is in 

turn controlled by a properly-functioning flare is nominally a “lagging” 

indicator, because the unwanted event (the release) has already occurred. 

It is also a “leading” indicator, however, in a longer and different time 

frame, in the sense that correcting the conditions that caused the 

unplanned flare event can prevent a future system disruption and 

potentially a more serious event.

iii. They must be frequent enough to possess sufficient statistical ability to be 

as quantitatively predictive as possible. For this purpose, indicators cannot 

rely on counts of major incidents alone (i.e., explosions, large fires, 

fatalities and serious injuries), because these events are too infrequent at 
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the establishment and often even at the company level to yield large 

enough numbers for meaningful statistical analysis, and thus permit 

preventive actions likely to have widespread impact, rather than largely 

“one-off” improvements.

iv. They must be based primarily on the failures of: 1) any of the multiple 

layers of protection that are part of the hazard control mechanisms for 

high hazard chemicals, or, 2) the systems that monitor and maintain these 

layers in proper operating order. These multiple layers nearly always 

exist to protect against the complex chain of events that typically lead to 

serious incidents. To take the example above, any unwanted flaring 

incident reflects a process upset or failure, and should be “counted” as an 

indicator event, even if the release is adequately controlled by a flare 

system and does not progress to a serious contaminant release. Another 

example would be the detection of thinning in piping in excess of 

predicted behavior under maintenance-monitoring protocols, even if the 

thinning has not yet resulted in a leak. The thinning should be recorded 

and “counted” as an indicator event because it can be preventive of a 

major future pipe failure, as well as indicative of a shortcoming in the 

monitoring protocol (i.e., too infrequent or otherwise inadequate). 

Arguably, this is a “more lagging” indicator than the earlier example. 

Other and even “more lagging” indicators can and should also be 

employed, such as maintenance and safety requests made and completed 

(or not) on time, corrective actions taken or not taken, number and rate of 

“out of range” measures of process conditions or controls, and many 

others, depending on the nature of the hazardous processes and the layers 

of control. In a nutshell, the indicators must be linked causally to harmful 

outcomes, so that they have predictive power, and they must be frequent 

enough to be useful for statistically meaningful analysis. 

v. The EPA, in collaboration with other members of the Working Group, 

industry and labor should agree upon one basic set of standardized 

indicators to be used by all regulated parties, to permit the collection of 

meaningful national statistical data and benchmarking. This core set of 

indicators must not exclude the use of other and more specific indicators 

by individual industry sectors, companies or establishments.
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vi. They must be reported at the site, company and aggregate (industry 

sector) levels to upper management, including Boards of Directors and 

owners/shareholders, to the workforce, and to the public, to permit 

benchmarking and encourage improvement. While the primary function 

of indicators is to drive continual improvement in performance; public 

reporting is a key tool to incentivize and help ensure that such 

improvements take place.

J. Revisions to the RMP should, as written in the California Draft Process Safety 

Management regulation, include a requirement that all covered facilities must 

develop, implement and maintain effective written procedures to ensure the

ongoing integrity of process equipment, controls, safeguards and

appurtenances. These procedures should:

 i. Include a method for employees to anonymously identify and report

potentially faulty or unsafe equipment, controls, safeguards and

appurtenances;

ii. Include a method for employees to record and report their observations

and recommendations to the employer in writing; and

iii. Require facility management to respond in writing within 60 calendar days

to observations and recommendations recorded and reported in writing by

employees pursuant to this subsection.

iv. The facility owners and operators shall develop and implement effective

written maintenance procedures, which shall provide clear instructions for

safely conducting maintenance activities on process equipment, controls,

safeguards and appurtenances, consistent with the Process Safety

Information.

v. Facility owners and operators shall provide employees and their

representatives access to the procedures developed and the inspection

documents generated by this process. 

K. The revised RMP should include an explicit requirement defining the roles 

and accountabilities of upper management in a health and safety management 

system (i.e., Board of Directors, owners of private businesses, etc.), as is the 

case in the United Kingdom, which has a “best practice” that applies to upper 
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management roles and accountabilities in a management system 

(http://www.hse.gov.uk/pubns/indg417.pdf).

L. EPA should include a new requirement that process management systems 

must incorporate concrete incentives for middle and upper managers to address 

safety effectively. This may require, for example, that bonuses, advancement and 

other rewards for middle and senior managers in the regulated chemical 

industry depend to a material extent on demonstrable safety performance of the 

activities under their authority. The incentives must be sufficient to balance the 

ever-present pressures for short-term productivity that can often be harmful to 

safety.

M. Two essential elements of the Safety Case should be incorporated in 

modernizing the RMP rule:

a. The financial resources that allow for the addition and maintenance of 

enough highly skilled and experienced, well-compensated government 

officials to engage on ongoing review of PSM and RMP plans and to 

engage and partner with employers and worker representatives in process 

safety. 

b. A tripartite decision-making structure in which employers, employees 

and the government equally share decision-making power in making 

safety decisions. In aviation, the Event Review Committees (ERCs) made 

up of equal numbers of representatives from management, labor and the 

FAA who review safety incident reports and recommend corrective 

actions, by consensus, provide one good model of such a structure. 

(http://www.faa.gov/about/initiatives/asap

N. Modernization of the RMP should include new requirements that ensure that 

contract labor who perform construction, maintenance and repair work have 

the necessary skills and health, safety and job protections and are properly 

trained in Process Safety Management.

O. Recognized and Generally Accepted Good Engineering Practices (RAGAGEPs) 

should be extended to all the components of PSM, not only to the few areas that 

are now explicitly covered by the RAGAGEP requirements. A fundamental 

principle of effective management systems and performance-oriented 

approaches to regulation is the need to continually improve performance, and 

this can only be done if regulated facilities employ recognized and up-to-date 

best practices for all elements of the required management system. RAGAGEP 
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can be defined as engineering, operation, or maintenance activities based on

established codes, standards, published technical reports or recommended

practices or similar documents. RAGAGEP should not be limited to activites or 

practices in the United States. 

P. The BlueGreen Alliance further recommends that a new requirement be added 

so the RAGAGEPs that underpin all elements of the standard be updated 

periodically. Best practices evolve with experience, and thus RAGAGEPs must 

not remain static. This would ensure, for example, that the most up-to-date best 

practices are serving as the basis for the 5-year required revisions of Process 

Hazard Analyses. There may also be instances when the RAGAGEPs would 

need to be updated more frequently, as when a major event or research reveals 

previously unknown or under-appreciated catastrophic dangers. The standard 

should also be revised to require that employers continually keep abreast of 

developments in the RAGAGEPs that are the basis of their process safety 

information and their process hazard analyses, by following developments in the 

consensus standard(s) and other activities from which their RAGAGEPs arise.

Q. Develop and implement funding mechanisms based on fees on the regulated 

parties to cover the costs of inspection and auditing functions, and to ensure 

an adequate regulatory workforce. Consider a system that rewards safety 

improvements and that ties fees to the extent of risk.

R. Ensure sufficient funding for the regulatory agency to sustain an adequate and 

competent cadre of field, scientific and technical experts, with competitive 

salaries to ensure a reasonable rate of retention.

S. Add a required element to the PSM standard to address human factors such as 

fatigue, worker-machine interactions (ergonomic design) and others.

T. Modify the PSM standard to require prompt corrective actions whenever 

shortcomings are identified under any element of the standard (e.g., through 

audits, inspections, MOC procedures, PHA revisions, etc.). Corrective actions 

should always follow the hierarchy of controls. 

U. Establish systems to collect and report to OSHA and EPA more information on 

process safety incidents especially coded information about the risk factors that 

lead to them. To this effect, EPA and OSHA should explore the potential 

adoption or adaptation of Storybuilder, a software developed in the 

Netherlands and tested to a significant extent both there and in the United 
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Kingdom as a tool to collect and analyze major hazard incidents and better focus 

prevention efforts on the most important risk factors 

(http://www.hse.gov.uk/research/rrpdf/rr778.pdf). The current information 

gathered through accidents currently reported to the RMP database provide only 

very crude and insufficient causal or risk factor information, and they need to be 

enhanced. 

V. Investigate the performance of PSM and RMP among small and medium 

establishments, and develop requirements, guidance and incentives to 

improve it. The chemical manufacturing sector includes a very large number of 

small and medium-sized establishments. These may be traditional 

manufacturers, but many are also “specialty” chemical firms, often operating 

under toll or “toll-like” arrangements (i.e., manufacturing for one or a very small 

number of customers) as part of a supply chain to larger firms that use their 

chemical products. Experience accumulated in the last decades strongly suggests 

that a sizable number of catastrophic incidents occur in such small and mediumsize establishments, and that their management and even their professional staff 

are often ill-informed about process safety regulations or principles. This effort 

should not focus narrowly on “highly hazardous chemicals that are not their 

facility’s primary products,” because the lack of understanding of PSM principles 

often exists equally for precursor chemicals or their finished products.

W. Explore the use of possible mechanisms to apply principles from product 

stewardship “in reverse” to the supply chain in the chemical industry. These 

approaches would entail imposing responsibilities on purchasers of chemicals in 

the supply chain to ensure that their suppliers are using effective process safety 

practices. Third-party audit mechanisms could play a role in such schemes, as is 

the case in the auto industry, which requires that their supply chains meet certain 

minimum quality and environmental performance standards, as measured by 

conformance to ISO management system standards. 

X. Align PSM to the American National Standard for Occupational Health and 

Safety Management Systems (AIHA/ANSI Z10, 2013). The need for this 

alignment is twofold. First, the PSM modernization must be such that the 

required management system can be integrated not only with broader health and 

safety management systems, but also with business management systems (e.g., 

financial, quality). Z10 was developed with this type of integration very much in 

mind. Management systems focused narrowly on health and safety aspects alone 

cannot be successful unless they are fully integrated and part of the overall 
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business management systems of an establishment. Secondly, the alignment 

would help to identify relevant elements that are missing from PSM and help 

incorporate them explicitly (e.g., management commitment, adequate resourcing 

of the health and safety function, training on management system principles and 

operations, continual improvement, etc.).

Y. Conduct vigorous compliance assistance and education campaigns for all 

changes that are made to the RMP. 

Z. In principle, the BlueGreen Alliance supports the use of third party systems to 

conduct PSM audits with some important caveats. Before implementing such a 

system the agency must design and test the efficacy of mechanisms to ensure:

i. The competency and qualification or “certification” of the third-party 

auditors;

ii. The adequacy and uniformity of auditing criteria; and, 

iii. The prevention of any potential conflicts of interest affecting the 

individuals or firms conducting the audits (e.g., conflicts between auditing 

and consulting functions by the same parties).

Moreover, before engaging in any widespread use of third-party audits, we also 

recommend that the agency carefully research the successes and failures of 

comparable existing mechanisms in the private sector, including those in the 

chemical industry (e.g., Responsible Care and ChemStewards), as well as those in 

place for the supply industry to the major US automobile manufacturers, which 

are based on auditing against ISO quality and environmental management 

system standards.

Additional Items for Which EPA Requests Information

BlueGreen Alliance recommendations for the implementation of safer technology and 

alternatives analysis are discussed above. 

We further support a requirement for facility owner and operators to provide all the 

relevant information to local emergency response authorities in order to permit them to 

plan responses, ideally in coordination with those owners and operators, as well as the 

creation of mechanisms so that the establishments that create the catastrophic hazard 

risks bear the financial burden of planning, rehearsing, and conducting emergency 

response activities.
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The revised RMP should require improved coordination between fire brigades and 

facility fire departments including training and incident pre- planning including 

quarterly reporting to the public fire agency on all incidents that occurred on-site but 

were handled by plant personnel alone. This information should also be available to the 

public in a format that is easy-to-access and evaluate. Chemical facilities should provide 

financial support for public fire agencies, including for training purposes. Strategies 

should be evaluated to “pre-pay” public fire agencies for emergency response and 

equipment costs, including payments for overtime to back-fill positions for the duration 

of an incident, if necessary. 

In addition, a mechanism to measure the costs incurred for both immediate and longterm medical services for affected surrounding communities as a result of a chemical 

facility incident, and to transfer the burden of those costs to the facilities responsible for 

them. To do this, a system is needed to track and document both the short and longerterm health status of affected individuals, beginning with those who seek medical 

attention during—and in the immediate aftermath of—an incident. 

We support new requirements for systems to effectively monitor air contaminants 

during unusual events and to communicate this information to health care providers, 

emergency responders and the public through the full range of potential channels and 

media, as appropriate. Chemical facilities should bear the costs for the purchase and 

maintenance of state-of-the-art, real-time air monitoring equipment and 

communications systems. 

The modernized regulations should require an annual Clean Air and other 

environmental regulation compliance audit to be submitted to relevant state and federal 

agencies with easy to understand summary documents posted on the facility’s website 

and those of the relevant state and federal agencies. The EPA should develop user 

applications and other electronic tools to make data more accessible.

And last, to maximize scarce resources, A system mechanism should be developed so 

OSHA and EPA can conduct joint inspections of high hazard facilities, including joint 

prior review of RMPs submitted by those facilities under EPA rules.