SAFETY
                      DUSTY BOOKS: IMPLEMENTING 
                               YOUR RMP/PSM PROGRAM
           by Daniel Cuevas, SCS Engineers             themselves, but a structured system          While facilities are required to designate 
           By now, most ammonia refrigeration          is needed to ensure each program is          one person who is ultimately responsible 
           facilities have developed accidental        included in day-to-day activities.           for overall implementation of the 
           release prevention programs                 That all sounds great, but how do we go      programs [45 CFR §68.15(b)], this 
           for compliance with EPA’s Risk              about doing that?                            becomes much more manageable with a 
           Management Program and OSHA’s                                                            team that can split up the responsibility 
           Process Safety Management rules.            Create a PSM/RMP team and                    for each program element.  
           However, many facilities struggle           hold periodic meetings.                       
                                                                                                    Create a visual organizational  
           with the next step: turning the written     A good place to start is to select members   chart and assign programs to  
           policies in the programs into day-to-day    for a PSM/RMP team for the facility.         the right people. 
           tasks and activities.                       Consider including personnel from             
                                                       several departments (maintenance             “When responsibility for implementing 
           Once a program is developed, the                                                         individual requirements of this part 
           goal is to create a system that enables     supervisor, environmental compliance,        is assigned to persons other than the 
           your facility to break down each of the     safety coordinator, plant manager, etc.).    person identified under paragraph (b) 
           program elements into manageable tasks      Meetings of the PSM/RMP team should          of this section, the names or positions of 
           that you can document.                      be scheduled to discuss operations at        these people shall be documented and 
                                                       the facility. A well-rounded PSM/RMP         the lines of authority defined through an 
           “The owner or operator of a stationary      team that meets regularly is able to 
           source with processes subject to            plan for expected changes to the system      organization chart or similar document.” 
           Program 2 or Program 3 shall develop        (management of change), schedule mock        [45 CFR §68.15(c)]
           a management system to oversee the          evacuation drills (emergency action/         Facilities are also required to develop 
           implementation of the risk management       response plan), review refresher training    and include an organization chart that 
           program elements.” [45 CFR §68.15(a)]       schedules (training), and more. Inviting     delineates which parties are responsible 
           This section is vital, and easily           other employees to participate in the        for implementing each section of the 
           overlooked by even the most                 PSM/RMP team meetings also provides          programs. This chart should indicate 
           experienced RMP/PSM guru. Often             them an opportunity to communicate           the RMP responsible person, along with 
           a significant amount of effort is put       concerns or questions with management        boxes detailing key personnel, and the 
           into developing the program elements        per the Employee Participation Program       program elements they are responsible 
                                                       [40 CFR §68.83(b)].                          for implementing. 
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                                                        be done. This can seem intimidating at       recommendations generated from a 
             A good general philosophy                  first, but can be easily achieved with       Process Hazard Analysis and maintain 
               to adopt is if you do not                a brief review of each program and           records for the life of the process [29 CFR 
                                                        some organization:                           §1910.119(e)(7)]. 
               have a signed and dated                  • Consider creating a table, with each       • All incident investigation reports 
                record of a task being                  program listed;                              should be retained for five years [29 CFR 
               completed, it never was.                 • for each program, list all major tasks     §1910.119(m)(7)].
                                                        associated with it;                          • Facilities are also required to document 
                                                        • reference your program; and                that all deficiencies from a compliance 
           For example, the maintenance                                                              audit have been corrected [29 CFR 
           supervisor or lead refrigeration             • indicate when each of these tasks is       §1910.119(o)(4)] and must retain copies 
           technician would likely be listed as         required to be completed.                    of the two most recent audit reports [29 
           responsible for reviewing operating          The end result is a table listing all of     CFR §1910.119(o)(5)]. 
           procedures, completing maintenance           the programs that detail what needs to       • For all training conducted for 
           records, and training new technicians.       be done for each program and when.           employees operating the process, 
           A safety coordinator may be in charge        This is a great tool to reference during     facilities must prepare a record which 
           of updating the Emergency Action/            PSM/RMP meetings, as it gives us real        contains the identity of the employee, the 
           Response Plan, managing contractor           world action items that can be tracked       date of training, and the means used to 
           safety documents, and performing             and completed.                               verify that the employee understood the 
           ammonia awareness training.                                                               training [40 CFR §68.71(c)].
                                                        You can also take it a step farther, and 
           However you decide to assign the             create a compliance calendar. If we know     The general take-away is that for each 
           programs, this chart should be facility      the frequency of major tasks (three year     task completed at the facility, there 
           specific and up to date with current         compliance audits, annual operating          should be an associated documented 
           names and titles. A giveaway that the        procedure certification, semi-annual         record of that task stored somewhere 
           programs are gathering dust is a chart       maintenance, etc.) we can assign each        on-site. As records can start to pile up 
           showing programs assigned to a title         one to a date on a calendar. A dedicated     quickly and can easily become lost or 
           that no longer exists, or an individual      calendar complete with due dates for         scattered, consider storing PSM/RMP 
           who has long since left the company.         reports or submittals can help avoid         records for the facility in one place for 
           Remember: these programs are intended        missing a major deadline by mistake,         easy access. A good indicator of healthy 
           to be living documents that change           which would otherwise create holes in        PSM/RMP programs is a bread crumb 
           over time. If key players of the PSM/        your recordkeeping.                          trail of completed records that date back 
           RMP team retire, change roles, or                                                         for years. 
           leave the facility, ensure that this chart   Make sure to track and  
           detailing responsibilities is updated in                                                  Remember, PSM is a 13 (14 if you 
           a timely manner.                             document all completed                       include Trade Secrets) element program. 
                                                        PSM/RMP related tasks.                       Add in the extra components of the RMP 
                                                         
           Determine the frequency                      Last, it is crucial to document the          and you have a lot to deal with. Many 
           of required tasks for each                   completion of all completed PSM/RMP          sayings come to mind…you need to eat 
           program and organize.                        tasks. A good general philosophy to          the elephant one bite at a time…Rome 
                                                                                                     wasn’t built in a day…it takes a village. 
           Once the programs have been assigned         adopt is if you do not have a signed and 
                                                        dated record of a task being completed, it   Use the requirements set forth in the 
           to specific individuals, the next step is to                                              RMP regarding a management system to 
           determine what the major tasks are for       never was. 
                                                        • Facilities are required to track           build your PSM/RMP team.
           each program and when they need to 
                                                        and document the completed 
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