If I need to revise a PHA to consider off-site consequences, when do I have to do that?
In general, for a PHA originally completed to meet the requirements of OSHA PSM that did not consider offsite consequences, you should revise the PHA to consider offsite consequences when you update that PHA. Any PHA for an RMP- covered process completed or updated after August 19, 1996, when part 68 was effective, should examine offsite consequences.