Recent Blog Posts
The RMP, PSM, and CalARP regulations have very few requirements for compliance audit reports: Title 29 CFR §1910.119(o)(3) A report of the findings of the audit shall be developed. In theory, an audit report could simply list out the recommendations from the activity. In practice, regulators do not accept this type of documentation. Just like […]
When it comes to compliance audits, “the more the merrier” holds true. One or two people auditing a program will discover far less than a team working together. That being said, the minimum regulatory requirements for compliance audits are low: Title 29 CFR §1910.119(o)(2) The compliance audit shall be conducted by at least one person […]
A Compliance Audit is a thermometer for PSM Programs. This blog series will provide an overview of compliance audits as well as provide highlights for what auditors look for in each program element. What is a Compliance Audit? Facilities subject to the RMP, PSM, and CalARP regulations are required to conduct internal audits of their […]
A great way to maintain P&ID accuracy is to implement an effective management of change (MOC) program. If used correctly, an MOC will initiate modifications to PSM elements that require attention when a facility or process change takes place. Assuming the scope of an MOC includes process equipment, the P&IDs will require amendment. Here is […]
We advocate that P&IDs be included in the training program for operators of PSM processes. Due to the complexity of diagrams, it is important for operators to regularly interact with P&IDs to improve their ability to use them. Here are some suggestions on how to incorporate P&IDs into operator training: Operator Sketch – Give an […]