Auditing Elements: RMP Submit & Hazard Assessment (Part 11)

In this compliance audit blog series, we have decided to focus on each program element. If you plan to lead an audit, these lists will be instructional for you. But if you want to prepare for an upcoming audit, these lists will give you an idea of what to expect.

Auditing the RMP Submit and Hazard Assessment require far less engagement from the team and can largely be completed by the auditor alone. Here are some ways in which each of these elements can be audited.

RMP Submit

• Confirm all the necessary fields are provided in accordance with the RMP and CalARP regulations.
• Verify the appropriate program levels have been applied. Program applicability was previously covered here.
• Confirm the emergency contact listed is still employed with the company.
• Ensure RMP Submits are being completed at least every 5 years and more often to account for any necessary RMP Corrections or Updates.
• Compare the inventories listed in the RMP Submit against the amounts listed in the maximum intended inventory document of process safety information.
• Spot check dates and information provided within the document to verify it is accurate (e.g. the date of the most recent PHA).

Hazard Assessment

• Determine if the correct scenarios were chosen based on the EPA’s guidance document for offsite consequence analysis. For instance, was the largest vessel chosen for the worst case release scenario?
• Were the appropriate mitigation factors selected?
• Confirm the amount released in the worst case release scenario aligns with the information provided in process safety information.
• Are the affected public and environmental receptors listed?
• Was a plausible scenario chosen for the alternate case release scenario?
• Has the hazard assessment been updated at least every 5 years?
• Has the hazard assessment been updated to reflect changes as necessary? This is required if the chemical inventory is changing so much that the distance to endpoint would change by a factor of two or more.

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This concludes our series on compliance audits. You can access previous blogs in this series below:

• Part 1: Compliance Audit Overview
• Part 2: Compliance Audit Team & Sessions
• Part 3: Compliance Audit Documentation
• Part 4: Auditing Elements: Process Safety Information
• Part 5: Auditing Elements: PHA, Compliance Audit, & Employee Participation
• Part 6: Auditing Elements: Operating Procedures & Training
• Part 7: Auditing Elements: Mechanical Integrity
• Part 8: Auditing Elements: MOC & PSSR
• Part 9: Auditing Elements: Incident Investigation, Emergency Response, & IIPP
• Part 10: Auditing Elements: Contractor & Hot Work Permit