Provide PSM program Gap Analyses at various plant sites to assist in improvement overall PSM program effectiveness and compliance.
PROCESS SAFETY MANAGEMENT (PSM) GAP ANALYSIS
The client, a major chemicals concern, contracted Process Engineering Associates, LLC (PROCESS) to provide Process Safety Management (PSM) Gap Analyses at multiple U.S. sites. PROCESS provided engineers and technicians experienced in OSHA’s PSM regulation (29 CFR 1910.119) and EPA’s Risk Management Program (RMP) regulation (40 CFR 68) to perform Gap Analyses of the client’s sites in order to identify the gaps in compliance with the PSM and RMP regulations. For each facility, the Gap Analysis team initially determined if the facility was covered by the regulations and the extent of coverage. For sites covered by the regulations, the Gap Analysis team reviewed the implementation of all elements of the requirements of the PSM and RMP regulations. In so doing, the Gap Analysis for each site addressed:
- The written PSM/RMP program
- Implementation of the PSM/RMP program
- Documentation produced as a result of the PSM/RMP program requirements.
As part of the Gap Analysis, the team performed a comprehensive review of the process safety information at each site to identify what information needed to be updated or developed. The deliverable for the Gap Analysis at each site was a letter report explaining the extent of coverage, regulatory deficiencies, recommendations for correcting the deficiencies, and estimates for manpower, costs, and schedule for addressing the deficiencies.
Some of the client sites PROCESS has performed Gap Analyses for include the following plants:
- Chemical Manufacturing Plants (2) in Oklahoma
- Chemical Manufacturing Plant in Texas
- Chemical Blend Plant in Texas
- Explosives Manufacturing Plant in Texas
- Acrolein Manufacturing Plant in California
- Chemical Blend Plant in California
- Explosives Manufacturing Plant in Arkansas
- Hazardous chemical manufacturing
- PSM program compliance support