s Process Safety Management standard (PSM) satisfy the training requirements under 40 CFR Sections 68.54 and 68.71?
Yes. The training requirements for Program 3 processes at 40 CFR 68.71 have been adopted verbatim from the OSHA PSM with minor wording changes to address statutory differences (61 FR 31712; June 20, 1996). EPA anticipates that sources whose processes are already in compliance with OSHA PSM will not need to take any additional steps to comply with the Program 3 Prevention program (61 FR 31673; June 20, 1996). The training requirements for Program 2 processes at 40 CFR Section 68.54 is a streamlined version of the OSHA PSM training requirements. The primary difference is that the OSHA documentation requirements have been omitted from the Program 2 training requirements (61 FR 31711; June 20, 1996). Additionally, training conducted to comply with other Federal or state rules or industry-specific standards or codes may be used to demonstrate compliance with the Program 2 training requirements (40 CFR Section 68.54(c)).
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