Recent Blog Posts

Calculating Threshold Quantity for Chemicals with Concentration Qualifiers

November 30th, 2021

Title 40 CFR ยง68.130 contains the table of RMP chemicals and their corresponding threshold quantities. Of the seventy-seven substances listed, four contain a concentration qualifier: Ammonia (conc 20% or greater) Hydrochloric acid (conc 37% or greater) Hydrogen fluoride/Hydrofluoric acid (conc 50% or greater) Nitric acid (conc 80% or greater) What does the concentration qualifier mean? […]

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

November 16th, 2021

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 […]

Auditing Elements: Contractor & Hot Work Permit (Part 10)

October 26th, 2021

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. Contractor Auditing the contractor element […]

Auditing Elements: Incident Investigation, Emergency Response, & IIPP (Part 9)

October 12th, 2021

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. There is much disagreement in […]

Auditing Elements: MOC & PSSR (Part 8)

September 28th, 2021

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. Management of Change Auditing the […]