OSHA PSM/EPA RMP Program Development
NGE developed the PSM Manual for the storage and use of a PSM-covered process at their client’s manufacturing facility.
NGE also conducted the process hazard analysis (PHA) for the PSM-covered process operation with appropriate facility personnel (i.e., facility management, operators, and maintenance personnel). The methodology used was a What-If/Checklist process.
Following completion of the on-site PHA, NGE prepared a detailed report documenting the process and findings. The report included text detailing the PHA process, a table with the findings, and referenced attachments, including the process notes. A manual outlining compliance methods for all PSM/RMP elements was developed for the covered processes and included; operating procedures, mechanical integrity, management of change, contractor management and incident investigation.
As part of the RMP, NGE also conducted an off-site consequence analysis (OCA) for the covered process to evaluate potential off-site impacts from an accidental release.
NGE prepared all of the training materials to be used as part of the required on-site training, including general PSM awareness and specific operator training. NGE conducted the on-site training at their client’s facility.