Mandatory RMP refiling was due last year!                         Call PSM Compliance Inc. for more information 
RMP Refiling is Past Due
The mandatory five year refiling of the Environmental Protection Agencies (EPA) Risk Management Plan was due last year for nearly everyone in the ammonia industry. Penalties have been harsh for those who failed to file.

Email us today for more information or call us at 281-685-8348 



PSM GAP Analysis

At PSMCI we a offer a vast range of client service programs. Our goal is to assure that you achieve and maintain regulatory compliance under OSHA 29 CFR 1910.119 and the EPA’s 40 CFR Part 68.

The Process Safety Management (PSM) GAP Analysis program developed by PSM Compliance, Inc. is a comprehensive and detailed inspection and review process of your entire PSM program. All fourteen elements of PSM, as developed and implemented at your facility, are dissected to assure compliance issues have been addressed, documented, and meet regulatory compliance. The scope of the analysis will include: 

1)     A comprehensive review of your existing PSM Program to assure your written plan for achieving regulatory compliance meets both OSHA and EPA regulatory guidelines.

2)     A thorough examination of all support documentation developed and implemented by your facility to ensure ongoing compliance objectives are being maintained. Review includes;

a)    Employee Participation. How much do they know, how much are they involved?

b)    Employee and Contractor Training programs (is level of training equal to level of responsibility?).

c)    Operating Procedures (structure, content, and implementation).

d)    Management Of Change (structure, follow-through, Pre-Startup Review).

e)    Incident Investigations (do they include near-misses and root cause?).

f)     Process Hazard Analysis (quality and comprehensiveness of the study).

g)    Audits (thoroughness and follow-up of recommendations) .

h)    Mechanical Integrity (are you following “generally accepted good engineering practices” as mandated by the regulation?).

i)      Emergency Planning and Response (evacuations, alarm systems, first responders).

3)       Interviews with a representative sampling of employees and key operations personnel.

4)       Upon completion, a detailed summary report is generated which will detail non-compliance issues  along with purposed recommendations for meeting regulatory compliance.

 The PSM GAP Analysis program is a tool to help you recognize and correct regulatory issues that may exist at your facility. Unlike a formal PSM Audit, which requires a record retention of six years and must be made available to OSHA inspectors, the GAP Analysis is non-regulatory and any non-compliance issues identified or recommendations generated as a result of the analysis are not required to meet any federal record retention schedules and, unless volunteered, would not be subject to the OSHA inspection process.  





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