Risk Management Program (RMP) Auditing

The EPA's Risk Management Program (40 CFR Part 68) requires facilities that use, store, or handle listed toxic and flammable substances above specified threshold quantities to develop and implement a comprehensive Risk Management Plan. This plan must include a hazard assessment, prevention program, and emergency response program. The RMP Amendments Rule has strengthened requirements in several areas, including third-party auditing, safer technology and alternatives analysis, and enhanced emergency coordination. Our RMP audits address both the original rule requirements and these recent amendments.

• Process Hazard Assessment: We verify your worst-case and alternative release scenarios, ensuring they're current and accurately reflect your facility's risk profile. • Prevention Program: For Program 2 and Program 3 processes, we evaluate safety information, hazard reviews, operating procedures, training, maintenance, compliance audits, and incident investigation processes. • Emergency Response Program: We assess your emergency response plan including coordination with local emergency services, equipment maintenance, and training and drill programs. • Five-Year Accident History: We review your reportable incident history and verify that lessons learned have been incorporated into your prevention and response programs.

For many chemical facilities, both OSHA's PSM standard and EPA's RMP rule apply to the same processes. While the two regulations have significant overlap, there are important differences in scope, applicability, and specific requirements. Our auditors are experts in both regulations and can conduct integrated PSM/RMP audits that address both sets of requirements efficiently, saving you time and money while ensuring comprehensive compliance.