Diversified CPC - Engineering and Regulatory Services

Regulatory & Environmental Services

Our Regulatory and Environmental Services Staff are available to assist you in developing Regulatory Compliance Programs for:

EPA Risk Management Plan (RMP)
OSHA Process Safety Management (PSM) including Process Hazard Analysis (PHA)
OSHA Hazard Communication Standard
Basic Propellant Training, and Tank Farm, Operator, Maintenance Training
Fire Safety Analysis
Fire Training for the local fire department
Department of Homeland Security (DHS) CSAT Top-Screen

For help with any of these topics, or for additional information, click here.

EPA Risk Management Plan (RMP) and OSHA Process Safety Management (PSM)

If more than 10,000 lbs of a listed substance are stored on site then a Risk Management Plan (RMP) needs to be filed with the USEPA and OSHA Process Safety Management (PSM) procedures need to be in place.

Risk Management came into effect in 1999. If a filing was completed, renewal is required every five (5) years.

RMP contains the Worst Case Scenario that was so widely publicized. The areas surrounding certain industries had large areas of impact when a catastrophic event occurred.

All employees are protected under the OSHA General Duty Clause even if the 10,000 lb criterion is not satisfied for the RMP. Employers are responsible for protection of their employees.

OSHA PSM Procedures Include:

Employee Participation
Mechanical Integrity
Hot Work
Incident Investigation
Management of Change
Prestart-up Review
Process Hazard Analysis
Training
Contractors, and
Audits

OSHA PSM requires an Internal Audit every three years

The internal audit is verification that the PSM program is current, utilized, and understood. Several areas are covered by the audit:

The PSM procedures are audited for completeness and content
Documentation of mechanical integrity
Training is current, complete, and documented for employees and contractors
Plant changes are completely complete, including Process Hazard Analysis
Any incidents are documented and actions taken to resolve any issues noted

Training must be completed for employees that are new to the job, transferred to a new job, and when job performance shows a need for review. Plant and process changes require a training review. If retraining is completed on a yearly basis, all line changes, new equipment, and procedural changes can be incorporated into the retraining.

OSHA Training Review Topics for each employee	Reference	Required Review
HAZWOPER	29 CFR 1910.120	Yearly
Respiratory Protection	29 CFR 1910.134	Yearly
Blood Borne Pathogens	29 CFR 1910.1030	Yearly
Hearing Conservation	29 CFR 1910.95	Yearly
Basic Confined Space Rescue	29 CFR 1910.146	Yearly
Fire Training - Extinguisher	29 CFR 1910.157	Yearly
Fork Truck	29 CFR 1910.178	Every 3 years
		Recommended Review
Lockout/Tagout	29 CFR 1910.147	Yearly
Confined Space	29 CFR 1910.146	Yearly
Hot Work/Cold Work	29 CFR 1910.252	Yearly
Hazard Communication	29 CFR 1910.1200	Yearly
PPE	29 CFR 1910.132	Yearly
Fall Protection	29 CFR 1910.67	Yearly
Emergency Action Plans	29 CFR 1910.38	Yearly

Basic Propellant Training, and Tank Farm, Operator, and Maintenance Training

Basic propellant properties, hazards, emergency situations, normal/day-to-day procedures, breakdown procedures, and at-risk behaviors are training issues. Training improves plant operations and profits via information exchanged with the employees.

Fire Safety Analysis

NFPA 58 required a Fire Safety Analysis to be completed by 2004. This is completed on a tank farm installation both new and existing.

Fire Training for the local fire department

Get the department comfortable to come onto your site and mitigate the fire rather than setting up a post a mile away and waiting for the fire to go out.

If the fire department is not comfortable with your plant and products, they will act conservatively and the plant becomes a salvage operation and an insurance claim.

Department of Homeland Security (DHS) CSAT Top-Screen

January 19, 2008 the DHS needed to have on file the evaluation questionnaire to determine if a facility needed additional areas of security to protect the facility, the raw material/product integrity, and the adjacent area near a facility.

Diversified CPC will assist in filling out Top-Screen and any topics generated by the evaluation.

For help with any of these topics, or for additional information, click here.