Audits and Analyses
Regulatory Compliance Audits
Compliance Audit Requirements
- US EPA RMP:
- Program 2: Code of Federal Regulations, Title 40, Chapter I, Subchapter C, Part 68, Subpart C, Section 68.58
- Program 3: Code of Federal Regulations, Title 40, Chapter I, Subchapter C, Part 68, Subpart D, Section 68.79
- OSHA PSM: Code of Federal Reguations, Title 29, Subtitle B, Chapter XVII, Part 1910, Subpart H, Section 1910.119 (o)
- CalARP
- Program 2: California Code of Regulations, Title 19, Division 2, Chapter 4.5, Article 5, Section 2755.6
- Program 3: California Code of Regulations, Title 19, Division 2, Chapter 4.5, Article 6, Section 2760.8
- Program 4: California Code of Regulations, Title 19, Division 2, Chapter 4.5, Article 6.5, Section 2762.8
Risk Management Professonals' Services
An effective Compliance Audit is reliant on skills Risk Management Professionals team members have honed in its practice, including:
- A mastery knowledge of the regulations and requirements
- Industry application of the requirements
- Experience and knowledge of common deficiencies (including implementation)
- Ability to work with personnel to develop reasonable solutions
RMP/PSM/CalARP Gap Analysis
A gap analysis is a comparison of current operating conditions and engineering practices to the regulatory requirements. The goal is to identify gaps and areas in need of improvement for unregulated facilities or facilities needing an additional analysis. The analysis is a means to identify and correct gaps between desired levels and actual levels of compliance and are not required to be a part of the program documentation. As a result, these analyses are not subject to regulatory inspection.
How are Gap Analyses different than Compliance Audits?
Similar to Compliance Audits, gap analyses review a facility’s current prevention program to achieve the same standard as is required by the regulations. However, a gap analysis is NOT meant to satisfy any regulatory requirements and is not intended to exempt the facility from any applicable regulatory requirements. The analysis is voluntarily conducted to identify and correct gaps outside of regulatory requirements.
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 assess facilities compliance with other state regulations, such as New Jersey’s Toxic Catastrophe Prevention Act (TCPA) Program and Nevada’s Chemical Accident Prevention Program (CAPP).
RAGAGEP Gap Analysis for Ammonia Facilities
OSHA first introduced the concept of Recognized and Generally Accepted Good Engineering Practices (RAGAGEP) in the PSM regulations. The intention is for facilities to follow established good engineering practices when designing and maintaining process equipment. A RAGAGEP Gap Analysis analyzes the as-built process conditions and suggests potential additional mitigation measures based on current applicable industry best practices, codes and standards. The RAGAGEP Gap Analysis may use established codes and standards from organizations such as:
- IIAR,
- American National Standards Institute (ANSI),
- American Petroleum Institute (API),
- American Society of Mechanical Engineers (ASME), and
- American Society of Testing Materials (ASTM).
RAGAGEP Gap Analyses do not directly satisfy regulatory requirements, unless it is used to satisfy the RAGAGEP portion of regulatory requirements, in which case it would be subject to regulatory scrutiny at the discretion of the regulating agency.