If so, RCP can assist with all aspects of PSM and RMP compliance assurance. RCP services range from single-process program assessments to complete program development for the entire facility. A common approach that many clients prefer can be separated into three-phases:
Phase 1 – Conduct PSM/RMP Assessment
RCP’s regulatory compliance specialists will team with your personnel to conduct a PSM/RMP assessment at your facility. These site visits typically are completed within 2 – 5 days depending upon the complexity of the covered processes. While at your facility, RCP specialists will:
- Meet with the appropriate site personnel
- Review and evaluate existing policies, procedures, and related information sources for PSM/RMP compliance
- Develop site-specific recommendations to bring the facility within compliance and improve the effectiveness of the facility’s PSM/RMP programs.
Soon after the site visit is complete, RCP will submit a written assessment, including improvement opportunities as well as recommendations for implementation strategy.
Phase 2 – Develop/Update Selected PSM/RMP Program Elements
Based upon the results of the Phase I assessment, you may request that RCP develop and/or update selected PSM/RMP program elements. RCP will deliver new/updated programs of the selected PSM/RMP program elements for your final approval. RCP will take full advantage of specific client input, any existing programs, OSHA/EPA guidance, and industry practices to develop effective programs for your covered processes.
Phase 3 – Lead/Assist Selected PSM/RMP Activities
RCP regulatory specialists will facilitate or assist with the implementation of the activities identified in the newly developed/updated PSM/RMP programs. This may include:
- Leading and documenting process hazard analysis
- Developing management of change processes
- Reviewing operation and maintenance procedures
- Optimizing mechanical integrity programs
- Conducting incident investigations
- Conducting compliance audits
- Training for site personnel
For additional information, contact Chris Foley @ (713) 655-8080