(57bp) Efficient Compliance Audits - Balancing Time and Resources

Federal US EPA RMP (Program 2: 40 CFR 68.58, Program 3: 40 CFR 68.79), Safety Environmental Management System (SEMS), and OSHA PSM (29 CFR 1910.119(o)) regulations, along with state regulations such as the California Accidental Release Prevention (CalARP) Program (Program 2: 19 CCR 2755.6, Program 3: 19 CCR 2760.8), Nevada Division of Environmental Protection (NDEP) Chemical Accident Prevention Program (CAPP), and the Toxic Catastrophe Prevention Act (TCPA) of New Jersey, require triennial compliance audits to certify that facilities adhere to applicable program elements. Compliance audits can be tedious, time consuming tasks, requiring auditors to spend considerable time inspecting documentation; however, there are numerous opportunities to streamline the tasks to improve the efficacy of the effort and increase value.

This paper outlines a methodology that was created to streamline the audit process, starting with segmenting the audit into three phases: preparation, implementation, and finalization. The preparation phase would be conducted prior to the site visit and would consist of a preliminary review of the RMP prevention program elements as implemented at the facility. The implementation phase, begins with a review of the Process Safety Information (PSI), Operating Procedures (OP), & Mechanical Integrity (MI) elements, followed by a walkdown of the covered process (to address P&ID’s, corroborate procedures with operations personnel, and review mechanical integrity implementation), followed by a review of the remaining program elements along with additional personnel interviews. During the finalization phase, generated findings are reviewed with management to ensure understanding and to assign actions and target dates, as appropriate. Tips to streamline each of the applicable program elements, including the use of sampling and specific interview questions, will be outlined within this paper.