Recent Blog Posts

Compliance Audit Documentation (Part 3)

July 20th, 2021

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 […]

Compliance Audit Team & Sessions (Part 2)

July 6th, 2021

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 […]

Compliance Audit Overview (Part 1)

June 22nd, 2021

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 […]

Common PHA Findings (Part 9)

February 16th, 2021

We have chosen to end this blog series by providing examples of findings that are commonly identified during PHAs. Use this information to address any issues prior to your PHA and thus reduce the number of recommendations that are made. Common findings include: Pipe and valves that are susceptible to physical damage from being stepped […]

PHA Documentation (Part 8)

February 2nd, 2021

We all know the mantra “if it wasn’t documented, it didn’t happen.” With this in mind, upon completion of the activity, a report must be prepared to document the PHA study. Inevitably, the PHA report will contain recommendations that must be tracked to completion. Recommendation due dates should be determined by the PHA team and […]