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Risk Management Program (RMP) Compliance Audits
by Capaccio Environmental Engineering, Inc.
Facilities classified as
Program 2 or Program 3 facilities under the Chemical
Accident Prevention Provisions of 40 CFR Part 68 (EPA’s
Risk Management Program: RMP) are required to conduct
compliance audits of their RMP program every three years.
For facilities that filed their RMP on or before the
initial filing deadline of June 21, 1999 the next three
year audit is due no later than June 21, 2008 (or three
years from your last audit if completed sooner). For all
other facilities the first three year audit was due three
years from the post mark date of your RMP submittal.
RMP audits are required to demonstrate
compliance with EPA RMP regulations. The regulations
require audits every three years to identify areas that
are deficient as well as recommend potential program
improvements. The RMP audit focuses on the three main
sections of the RMP (process hazards assessment,
prevention program, and emergency response program) as
well as the underlying safety programs. Audits consist of
a document review and on-site visit. Auditor(s) will
review your RMP for completeness and compliance with the
regulations. Most auditors will follow the EPA document
Guidance for Auditing Risk Management Plans/Programs under
Clean Air Act 112(r), issued by EPA. This guidance
contains recommended actions and procedures that will be
followed during an RMP audit and was designed for use by
EPA auditors. The EPA has been conducting audits of
selected facility RMPs the last few years. To make sure
your facility is prepared for such an audit, download our
free guidance document.
The Table
below lists the provisions that must be included in the
audit. It is noted that the requirements for Program 3
facilities are modeled after OSHA’s Process Safety
Management Program (PSM). If your facility has a PSM/RMP
combined program then you can conduct a single audit to
meet both programs requirements for a three year audit.
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Applicable Provision to be Covered in Audit, by
Program |
|
Provision |
RMP Program |
OSHA
PSM |
|
2 |
3 |
| Safety
Information |
X |
|
|
| Hazard
Review |
X |
|
|
| Operating
Procedures |
X |
X |
X |
| Training |
X |
X |
X |
| Maintenance |
X |
X |
X |
| Compliance
Audit Reports |
X |
X |
X |
| Incident
Investigation |
X |
X |
X |
| Emergency
Planning / Response |
X |
X |
X |
| Process
Safety Information |
|
X |
X |
| Process
Hazards Analysis (PHA) |
|
X |
X |
| Mechanical
Integrity |
|
X |
X |
| Management
of Change (MOC) |
|
X |
X |
| Pre-Startup
Safety Review (PSSR) |
|
X |
X |
| Employee
Participation |
|
X |
X |
| Hot
Work Permit |
|
X |
X |
| Contractors |
|
X |
X |
| Mechanical
Integrity |
|
X |
X |
Need Assistance?
CAPACCIO can provide trained and
knowledgeable auditors and team members to conduct a
thorough audit of your PSM/RMP program. CAPACCIO has
extensive experience auditing compliance programs at
industrial facilities. Our experienced lead auditors and
audit team members can work independently or with your
in-house teams in completing full PSM/RMP audits.
If
you have any questions regarding the PSM/RMP regulations
or need assistance in setting up an audit, please contact:
David Cotter
Senior Environmental Engineer
(508) 970-0033 ext 133 |
Chuck
Hardenstine
Senior Environmental Health and Safety Scientist
(508) 970-0033 ext 113 |
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