Argent Consulting Services, Inc.

Argent Consulting Services, Inc.

RMP/PSM

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The Risk Management Plan (RMP) is intended to prevent serious chemical accidents that could harm staff and public health and the environment and to reduce the potential impact of accidental releases. A facility is required to submit an RMP if it stores or uses a chemical in quantities greater than their threshold amounts as defined by the EPA.

An RMP consists of a hazard assessment of chemicals involved in a process at a facility, a prevention program to prevent a release, and an emergency response program of procedures in case of a release.

Argent environmental consultants research your applicability and can help mitigate the impact of having to comply with the RMP/PSM programs. Argent develops a detailed site analysis report to determine the chemicals, locations, and quantities that trigger the RMP/PSM requirement.

In some cases, our consulting team discovers applicability may be eliminated by simply switching to a different chemical, moving a chemical to another location, or reducing the quantity of a chemical stored in a system. Argent can help you determine changes and the effects of changes to your RMP system relative to the RMP Submit process. Argent is experienced in developing, preparing, and submitting initial and successive RMP Submits.

Argent prepares site specific RMP and/or Process Safety Management (PSM) Procedures that are required as part of an RMP or PSM program and considered a regulated document. Argent has an audit-proven format to provide a user-friendly process for existing facility procedures. We also create new procedures by using an extensive personnel interview process, thorough walkthrough, and equipment/process studies.

Risk Management Plan (RMP) 40 CFR 68 Process Safety Management (PSM) 29 CFR 1910.119

RMP is comprised of three levels of programs, 1, 2, and 3, each having their own applicability and impact on operations.

Program 1 clients have the least amount of regulations to follow, but usually the least amount of resources to develop, train, and implement a fully functional program. We can help fill the gap with and deliver you a program that is livable as well as compliant. Program 1 clients are not subject to PSM requirements.

Program 2 clients follow similar regulations as Program 1 with the inclusion of a few more pieces to the program. Program 2 clients are not subject to PSM requirements.

Program 3 clients have the most restrictions and must also comply with OSHA’s Process Safety Management Program.

Argent’s environmental consultants can research your applicability and help mitigate the impact of having to comply with the RMP/PSM programs. We will give you a detailed site analysis report to determine the chemicals, locations, and quantities that trigger the RMP/PSM requirement. In some cases, we find we can recommend eliminating applicability altogether by simply switching a chemical, moving a chemical to another location, or reducing the quantity of a chemical in a system. Before we leave your site, you will have answers to the following questions:

  1. Why is RMP/PSM required at our facility?
  2. Where are the locations and boundaries of my regulated chemicals and systems?
  3. What steps do I need to take to bring our facility into auditable compliance?
  4. What steps can I take to mitigate the RMP/PSM impact on operations and the process?

Argent can help build your facility a site specific RMP and/or PSM compliance administration program and manual.

Procedures are required as part of an RMP or PSM program and considered a regulated document. Argent has an audit-proven format for procedures that can be easily implemented across existing facility procedures. We also create new procedures by using an extensive personnel interview process, thorough walkthrough, and equipment/process studies.

Argent’s environmental consultants can help you determine changes and the effects of changes to your RMP system relative to the RMP submit process. Argent can also develop, prepare and submit intial and successive RMP submits for your site.

Argent can help simplify your MOC program with a hard copy system, an online document control system, or a combination of the two.

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