ACS Engineering implements an audit-proven process to prepare site-specific EPA Risk Management Plans (RMP) and OSHA Process Safety Management (PSM) compliance administration programs and manuals for regulated facilities.

We implement a systematic approach to evaluating the whole chemical process—maximizing the effectiveness of the compliance management programs and plans we create.

ACS Engineering implements an audit-proven process to prepare site-specific EPA Risk Management Plans (RMPs) and OSHA Process Safety Management (PSM) compliance administration programs and manuals for regulated facilities, so that you are covered every step of the way.

Both RMP and PSM have a common denominator involving compliance. Facilities cannot exceed the threshold quantity of a regulated substance. We begin by developing a detailed site analysis report to determine which chemicals, locations and quantities trigger an RMP/PSM requirement. Then we work to minimize your compliance burden by creating a series of recommendations. For example, we may recommend switching to a different chemical, moving a chemical to another location or reducing chemical’s quantity stored in a system.

RMP/PSM offers an excellent example of why our consultant services prove very valuable to customers. PSM is mutually exclusive of RMP; however, if you store, handle or manufacture more than the threshold quantity from EPA’s chemicals list (not the same as OSHA’s Highly Hazardous Chemical List), you may automatically be subject to complying with OSHA PSM because the other agency, EPA, tells you to.

As your compliance partner for RPM/PSM, we consider everything which could affect compliance – process design, process technology, operational and maintenance activities and procedures, non-routine activities and procedures, emergency preparedness plans and procedures, training programs, Change Management and other elements that affect the process.

Risk Management Program 40 CFR 68 (RMP)

We will readily assist you with complete RMP program development, site-specific operational procedures, employee and contractor compliance training, mechanical integrity program development, compliance audits, process hazard analysis, RMP preparation and submittal, regulatory audit preparation and implementation and management of a compliance tracking reminder system.

In developing your RMP program, along with determining which facilities must actually submit an RMP, frequency of submittals and which chemicals must be reported, we will ensure that it properly covers three key areas for each facility:

  • Hazard assessment detailing an accidental release’s potential effects, current 5-year accident history and evaluation of worst-case and alternative accidental releases
  • Prevention program including safety precautions and maintenance, monitoring and employee training
  • Emergency response program

Process Safety Management 29 CFR 1910.119 (PSM)

With OSHA’s PSM requirements becoming an especially challenging compliance issue, not only do our services mirror those for RMP, we fully address the reality that PSM audits do not give partial credit for incremental success. With up to 570 potential questions on an OSHA audit, nothing less than 100% compliance is acceptable and we will demonstrate that full commitment on your behalf.

As a result, the plan we custom-develop for you will cut right through the major issues in PSM compliance: resources, time and money. As your consultant, we will mitigate your risks by first preparing a realistic budget so that implementation of the plan will be successful and followed through by employees without overwhelming them with an overdose of PSM management.

Then we will develop a realistic and cost-effective solution. This will help you drive your compliance initiative, identify all requirements and ensure each are reviewed from time to time. Included also is a complete process to specifically comply with OSHA recommendations about addressing each deficiency and taking corrective action.

As a “bonus,” the Continuous Compliance Management System (CCMS) checklist has revolutionized how daily management of PSM can be upgraded to best achieve as close to 100% compliance as possible. CCMS works by indexing all PSM requirements, developing site-specific tasks to manage each requirement, routinely tracking requirements by emailing your PSM team and providing you with the power to report results directly to your team, management and OSHA. Cost-effective and easy to implement, CCMS makes every team member a PSM manager.

Contact ACS Engineering today to find out how our RMP/PSM services can help keep you both compliant and profitable without missing a beat in your daily operations.

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