Applicability of compliance audit provisions to emergency response programs

I have a Program 2 covered process and a Program 3 covered process at my stationary source, and I am required to conduct compliance audits certifying that I have evaluated compliance with my prevention program requirements at least every three years (40 CFR Sections 68.58 and 68.79). Do these provisions require me to audit my emergency response program as well?

No, the audit provisions in the prevention programs refer only to the prevention program. However, section 68.95(a)(4) provides that the Emergency Response program must include "[p]rocedures to review and update, as appropriate, the emergency response plan to reflect changes at the stationary source and ensure that employees are informed of changes" (40 CFR §68.95(a)(4)). Each facility must determine what is needed for this review and how often it will be carried out.