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COMPLIANCE AUDITS – OSHA PSM / EPA RMP

PSM is an OSHA Program intended to protect workers and the community, while RMP is an EPA Rule intended to protect the environment.

A violation of the OSHA 1910.119 standard is considered serious in nature, and therefore can result in a fine ranging from $13,260 to $132,598 each.

A violation of the EPA section 112(r) of the 1990 Clean Air Act standard can result in a penalty as much as $37,500 per each violation, per day.

Process & Safety Solutions LLC is a Veteran Owned Small Business located in Pearland, TX. Our extensive industry and regulatory knowledge are essential for evaluating PSM and RMP programs. Our lead auditor brings this knowledge and experience as an OSHA PSM compliance specialist who has conducted over 200 Chemical and Refinery National Emphasis Compliance Audits and inspections. Our unique background allows us to conduct compliance evaluations and provide solutions resulting in continuous improvement within process safety with an emphasis on program implementation. Understanding and addressing gaps in your process safety programs lead to safer facilities, high morale, and the retention of highly skilled and trained personnel.

The Process Safety Management (PSM) standard mandates that all employers complete a Compliance Audit every three years. The Compliance Audit is the thirteenth element of OSHA’s PSM standard. If an employer has had a hazardous release, the schedule of your Compliance Audit may differ from the normal three-year plan. Compliance Audits ensure all policies and protocols for each process developed under the standard are being followed and maintained if any changes occur. One thing to remember is your Compliance Audit date is based on the initial audit date of your facility.

The Risk Management Plan Rule requires all employers that use hazardous chemicals to develop a Risk Management Plan (RMP). The EPA requires these plans to be updated and resubmitted every five years.

As the employer, you are responsible to identify, reduce and/or mitigate potential chemical hazards. The PSM/RMP standards do not specify how to complete the Compliance Audit / RMP but provides a guideline in order to achieve a successful outcome to meet PSM/RMP compliance requirements.

Does your facility utilize internal certified auditors to complete your Compliance Audits? Have you ever thought about utilizing a third-party external auditor? By utilizing a third-party external auditor, you gain valuable knowledge of additional industry leaders while enhancing your internal team’s perspective. When you introduce a third-party to a process they are not directly involved in daily, the lead auditor provides an unbiased outlook allowing for a deeper dive into the process. This is achieved through various methods that include but are not limited to: interviews of operators and engineers, facility tours, and P&ID walk downs.

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