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Do Program Level 1 processes need to do five-year accident histories?

What is the relationship between the accident history criteria for Program 1 and the five-year accident history? If my process is eligible for Program 1, do I still need to do a five-year accident history?

The five-year accident history is an information collection requirement that is designed to provide data on all serious accidents involving release of a regulated substance from a covered process. In contrast, the Program 1 accident history criteria focus on accidents causing off-site harm of the most serious kind: death or injury of persons or significant harm to a public receptor. Onsite effects, shelterings-in-place, and evacuations that have occurred must be reported in the five-year accident history, but they are not considered in determining Program 1 eligibility. Therefore, it is possible for process to be eligible for Program 1 and still have experienced a release that must be reported in the accident history for the source.