Have You Reviewed Your Risk Management Plan/Process Safety Management Program Lately? Reply

In accordance with US Environmental Protection Agency (EPA) regulations at 40 CFR 68.79, facilities required to maintain Risk Management Plans (RMP) must audit their programs at least once every three years. Similarly, in accordance with Occupational Safety and Health Administration (OSHA) regulations at 29 CFR 1910.119(o), facilities required to maintain Process Safety Management (PSM) programs must also conduct program audits every three years.

Some important points:
• Audits must be completed by a team, with at least one team member who is knowledgeable
about the process
• All findings must be documented
• All actions to address audit findings must be documented
• The audit must contain a certification that the audit evaluated the program

Some common audit findings include:
• Inadequate development of one or more program elements
• Inadequate documentation of program activities (particularly mechanical integrity programs)
• Hazard assessments are not adequate or not available, or no documentation of follow-up
activities exists
• Operating procedures not certified annually
• Management of change program not implemented
• Contractor safety program not implemented

EPA and OSHA are routinely conducting audits – be ready. CAPACCIO has experience developing and auditing RMP and PSM programs for a variety of different industries. If you would like to find out more, please contact Chris Walton, PE, BCEE, at (508) 970-0033 ext. 139 or at cwalton@capaccio.com.

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