The BakerRisk process safety staff has considerable experience in managing and conducting compliance audits for OSHA PSM and EPA RMP standards. PSM compliance audits are completed focusing on all fourteen (14) elements of OSHA’s Process Safety Management regulation 40 CFR 1910.119 including the management system requirement of EPA’s RMP Rule.
BakerRisk has developed an audit protocol that considers all applicable regulatory requirements as well as current industry practice, as covered in the following:
- OSHA 29 CFR 1910.119 Process Safety Management Standard and Paragraph (o) of the OSHA Standard
- Section 68.79 of the EPA Risk Management Process (RMP) Rule, 40 CFR Part 68
- Compliance Guidelines and Enforcement Procedures, CPL2-2.45A issued by OSHA
- Guidance for Auditing Risk Management Plans/Programs under the Clean Air Act Section 112®, EPA 550-B99-008
- OSHA Petroleum Refinery National Emphasis Program
- CCPS and API Guidelines and Standards
BakerRisk also conducts CCPS Risk Based Process Safety (RBPS) audits. RBPS has additional elements such as safety culture, conduct of operations, etc. that are not found in the OSHA PSM. These audits can be especially relevant and useful for countries where the process safety regulations are in their early stages. BakerRisk has performed RBPS audits in around the world. An extension of RBPS is BakerRisk’s ability to address human factors in Culture, Leadership and Accountability (CLA) audits.