Process Safety Management & Risk Management Plan Programs
OSHA's Process Safety Management (PSM) standard, 29 CFR 1910.119, and EPA's Risk Management Plan (RMP) rule, 40 CFR Part 68, apply to facilities that handle highly hazardous chemicals at or above specified threshold quantities.
To assist facilities that must comply with these regulations, Amplify offers overall review, strategy, development, and implementation support for both PSM and RMP programs. Our consultants will provide support at the plant or corporate level to help your organization apply the most “fit for purpose” practices while complying with PSM and RMP regulations. Whether you are seeking improvement of specific elements or are looking for a complete program overhaul, our solutions are tailored to your needs. Amplify will create a PSM/RMP Compliance Roadmap for you and guide you along the way to compliance.
Process Safety Information (PSI) Review
Written Process Safety Information (PSI) must be compiled before any process hazard analysis is conducted and allows both the employer and employees involved in operating the process to detect and better understand hazards associated with the highly hazardous chemicals involved in the process. The Process Safety Management (PSM) standard requires PSI to include information regarding the hazards of the highly hazardous chemicals used or produced by the process, the technology of the process, and the equipment of the process.
Our consultants will carry out a full review of the PSI at your facility, complete with references to potential gaps in PSM and RMP regulation compliance, or with industry recognized and generally accepted good engineering practices (RAGAGEP). We can help you locate and organize the necessary information which may be buried in past project documentation or other management systems at the facility. Amplify can also help field verify and update your Piping and Instrument Diagrams (P&IDs) to include the PSI necessary for effective Process Hazard Analyses (PHAs).
Mechanical Integrity (MI) Programs
An effective and compliant Mechanical Integrity (MI) program includes written procedures, training for process maintenance activities, inspection and testing, a system for correcting equipment deficiencies, and quality assurance.
Amplify offers development of site‐specific MI programs at your facility. Our consultants will build an accurate equipment list using a combination of PSI review and field verification, assign industry specific inspection, testing, and preventative maintenance (ITPM) tasks to each piece of equipment, identify required or recommended frequency of each ITPM task, and assist your organization in solutions for overall program execution.
PSM/RMP Project Compliance
Whether you’re building a new facility or handling a major expansion of an existing facility, our consultants will help assure your project meets the regulatory requirements for PSM/RMP compliance.
A full plan, customized to your project, will be put in place to ensure that needed documentation (QA/QC and PSI) is assembled, completed, and provided during all phases of construction. Amplify can facilitate a project PHA to provide a baseline for the project and help you manage any subsequent changes to the project scope to stay in compliance with Management of Change (MOC).
Process Hazard Analysis (PHA) Studies
A Process Hazard Analysis (PHA) helps identify, evaluate, and control the hazards involved in your process. The PSM standard requires that PHAs be updated and revalidated every 5 years after the completion of the initial PHA.
Amplify’s certified PHA team leaders will facilitate PHA studies during the conceptual or design phase of a project, as an initial PHA at a facility, or as a PHA revalidation. With many years of experience conducting PHAs using various methodologies including what-if/checklist, hazard and operability (HAZOP), and layers of protection analysis (LOPA), you can rest assured that your PHA will be completed using a methodology appropriate to the complexity of your covered process(es).
Operating procedures must include steps for each operating phase, including initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown, and startup following a turnaround, or after an emergency shutdown.
Our consultants offer both review of existing procedures with suggested improvements or development of new operating procedures that meet the regulatory requirements of PSM/RMP.
All plant personnel, not just Operators, require some level of process safety training to maintain a robust PSM/RMP program. To facilitate an effective Employee Participation Plan, everyone needs to understand the requirements and their role in compliance.
Amplify provides custom, on-site or virtual training to meet your needs. We offer on-line training courses for PHA Leadership and Cornerstones of Practical Process Safety Management. Additionally, we will work with you to customize a training program tailored to your needs, whether it is for new engineers and managers, site leadership, or hourly personnel. These training sessions range from a short Computer-Based Training (CBT) PSM overview to a 5-day hands-on training with focused workshops for PHA Facilitation or basics of PSM/RMP Compliance. These tailored training packages allow us to incorporate your company’s approach to compliance and priorities.
Employers must investigate incidents which resulted in or could have reasonably resulted in a catastrophic release of a highly hazardous chemical and must begin the incident investigation no later than 48 hours after the incident.
Amplify consultants will take the lead on investigations related to process safety incidents and issue a report to include findings and recommendations, as well as provide a summary to inform all affected personnel about the incident. Following the investigation, our consultants will hold a closing meeting, review investigation findings, and collect your final comments before issuing a report to include an executive summary and a findings/recommendations list.
Compliance Audits & Assessments
While compliance audits are required to be completed at least every three years, compliance assessments can also be useful tools in verifying whether existing procedures are compliant and adhered to in practice.
Our consultants will complete a thorough review of your plant’s adherence to PSM/RMP regulatory requirements, applicable industry recognized and generally accepted good engineering practices (RAGAGEP), and any written company work practices (policies, standards, or similar conformance documents). A combination of plant walkthrough, documentation review, and employee interviews will be utilized to ensure a well-rounded audit is completed. Following the audit, our consultants will hold a closing meeting, review draft findings/recommendations, and collect your final comments before issuing a report to include an executive summary and a findings/recommendations list. As an alternative to a compliance audit, an assessment can be completed to highlight potential areas of improvement. Amplify can also provide additional assistance in developing strategies to address any identified gaps in your programs.
Risk Management Plan (RMP) Compliance
Compliance with EPA’s Risk Management Program requires development and submission of a Risk Management Plan to the EPA via the on-line CDX system.
For initial submissions, Amplify will assist in your risk management plan (RMP) development and submittal to the EPA as your registered agent. Our consultants will help identify worst case and alternative case scenarios required by the regulation.
For updates and corrections to your RMP, we will review your worst case and alternate case scenarios, updates to your incident history, and changes to your plan, and update your previous RMP submittal information. A final report with all supporting information will also be provided.
Combustible Dust Compliance Assistance
Facilities with combustible dusts must comply with various NFPA codes to ensure that dust is properly managed to prevent dust cloud explosions and other scenarios which could harm personnel or property. Additionally, the NFPA codes also require management programs that closely resemble elements of a PSM program, such as Management of Change, and Incident Investigation.
Amplify can assist facilities with all parts of combustible dust management, including Dust Hazard Analyses (DHAs), and housekeeping programs. If you are uncertain about the risks posed by the particulates that you are handling, we can help you develop a testing plan to obtain the necessary data to implement appropriate safeguards. Our consultants can assist you in addressing recommendations resulting from a DHA or NFPA Code review. We can also provide hazard awareness training for any personnel working with combustible dusts. If you don’t already have the necessary management program in place to comply with NFPA requirements, Amplify can work with you to establish them.
Industry Consensus Codes Expertise
Amplify’s consultants can provide compliance expertise related to industry consensus codes (e.g. NFPA, API, ASME, International Building and Fire Codes, etc.) in support of day-to-day management of facilities, capital projects small and large, and Mechanical Integrity program development.
OSHA/EPA Violations Assistance
For facilities that are undergoing agency audits or have received a Notice of Violation from OSHA, EPA, or similar state agency, Amplify can help you to respond to Agency findings, address inspection violations, and provide subject matter expertise for any communications with Enforcement personnel.
Acquisition Due Diligence
To assist with the acquisition process, our consultants will complete a thorough review of your potential purchase with regard to adherence to PSM/RMP regulatory requirements, including applicable industry recognized and generally accepted good engineering practices (RAGAGEP).
Pressure Relief Design and Documentation
The documentation for pressure relief design to comply with PSM/RMP is extensive, and includes the design basis, sizing calculations, and hydraulic assessment of the installation.
Amplify can provide the engineering expertise to evaluate the pressure relief needs to properly protect your equipment in accordance with the RAGAGEP (ASME VIII, API 520/521, API 2000, NFPA 30, etc.). We will review and document which causes of over pressure are applicable or not, and why. For all applicable scenarios we will provide calculations to document the required relief rate and evaluate the existing relief devices for adequacy. The review will include an assessment of the hydraulics of the inlet and outlet lines in accordance with the RAGAGEP.