• Regulatory Applicability and Exemption Analysis
• PSM Program Development
• PSM Program Implementation
• Enforcement Representation and Regulatory Negotiation
In 1992, the OSHA standard “Process Safety Management of Highly Hazardous Chemicals” (OSHA PSM) was issued in the Federal Register and includes a list of 137 toxic, reactive, flammable, or explosive chemicals. The purpose of PSM is to prevent or minimize the consequences of catastrophic releases of these chemicals by employing engineering and administrative controls to protect the worker. Elements that are addressed in PSM include:
While applicability is primarily driven by exceeding a regulatory Threshold Quantity(TQ) of a listed chemical, other nuances in the OSHA PSM rule may trigger applicability to processes that do not contain chemicals exceeding a TQ (e.g. Mobile Pipe Reactor).
RME has developed a Process Safety Management Program Template that can be adopted as is, or modified to meet the Corporate-specific Policies. The RME PSM is designed for easy reference and to facilitate external and internal compliance audits.
RME provides PSM services to a variety of clients and industries in more than 30 states across the U.S. RME services are tailored to the Client needs and include program development through implementation, or customized to specific accident prevention elements, including:
Regulatory Applicability and Exemption Analysis
Site Inspection and Data Collection
EPA RMP Registration (Preparer)
Process Design and Construction Management
Process Safety Information Development
Written Operating Procedures
Code relevant Process Hazard Analysis with Risk Analysis
Training
Mechanical Integrity Programs Meeting Relevant Industry and Code Standards
Management of Change Implementation
Pre-Startup Review Post Construction or Major Modification
Compliance Audits -3rd Party or Representation During Agency Audits
Incident Investigations
Contractor Management
Emergency Planning, Coordination, and Response Excercises