RMP/PSM/CalARP Gap Analysis
What is an RMP/PSM/CalARP Gap Analysis?
EPA’s Risk Management Plan (RMP), Cal/OSHA’s Process Safety Management (PSM) and the California Accidental Release Prevention (CalARP) Programs require that facilities containing more than the listed threshold quantities shall implement steps and procedures to prevent the potential for accidental releases. As part of these requirements, facilities must verify that the Prevention Program Elements, including procedures, training, maintenance, etc., are being adequately implemented and applicable codes and standards are being followed. A Gap Analysis is a way to analyze current operating conditions and engineering practices of the implemented program in order to identify gaps and areas in need of improvement in regards to compliance with RMP/PSM/CalARP standards. A Gap Analysis provides a means to identify and correct gaps between desired levels and actual levels of compliance and, unlike Compliance Audits, they are not required to be a part of the program binder, and therefore, are not subject to regulatory inspection. Similar to Compliance Audits, Gap Analyses review a facility’s current prevention program in order to achieve the following:
- comply with applicable portions of the RMP/PSM/CalARP program regulations;
- identify deficiencies in program documentation or implementation; and
- suggest methods or improvements that might be implemented to assist the facility with addressing documentation requirements and appropriate implementation.
How are Gap Analyses different than Compliance Audits?
A Gap Analysis does not fulfill the triennial Compliance Audit requirement outlined in RMP/PSM/CalARP regulations. The Gap Analysis is NOT meant to satisfy any regulatory requirements and is not intended to exempt the facility from any applicable regulatory requirements. Gap Analyses are voluntarily conducted to identify and correct gaps in the RMP/PSM/CalARP program. They are more of a high-level overview in nature and can be beneficial if the auditors are seasoned as they can impart their experience of common best practices at similar facilities. An advantage of Gap Analyses is that they may be conducted offsite, whereas Compliance Audits are usually performed onsite to verify personnel awareness of program requirements. This cuts travel costs and lessens meeting time for personnel, decreasing the total cost of a Gap Analysis when compared to a Compliance Audit. Furthermore, as Gap Analyses are internal documents that are not part of the RMP/PSM/CalARP regulations, they are not subject to regulatory inspection.
Can Gap Analyses be performed on facilities outside of California to verify compliance with other state regulations?
Yes, Risk Management Professionals offers Gap Analysis services to ensure facilities are compliant with New Jersey’s Toxic Catastrophe Prevention Act (TCPA) Program and Nevada’s Chemical Accident Prevention Program (CAPP). It should be noted that Gap Analyses can be performed on any EPA RMP federally regulated facility as well as those subject to OSHA’s PSM Program; however, conducting a Gap Analysis does not necessarily satisfy any regulatory requirements, it serves as a tool to identify potential gaps within a facility’s compliance, prior to any regulatory compliance reviews.