Industrial Compliance
Condor provides compliance documents for many State and Federal programs.
- Risk Management Plans and updates
- Environmental Audits
RMP/PSM
5-Year Risk Management Plan (RMP) Update Requirement
If you are the owner or operator of an RMP-covered facility, EPA's Chemical Accident Prevention regulations require that you fully update and resubmit your RMP at least once every 5 years. If certain process changes occur at your facility prior to the 5-year anniversary of your RMP, you must update and resubmit your RMP before those changes are made. The 5-year anniversary date is reset whenever you fully update and resubmit your RMP. The majority of facilities submitted their initial RMPs by the original June 21, 1999 deadline. This means that most RMPs should have been updated, and PHAs (Process Hazard Analyses) revalidated by June 21, 2004. Further, additions to the EPA requirements for RMPs made it necessary for all RMPs to be modified and resubmitted by June 2004. A second 5-year anniversary will be coming up in June of 2009.
CalARP
The California Accidental Release Prevention (CalARP) Program is in many respects quite similar to the federal RMP/PSM programs. However the CalARP hazardous chemicals list and threshold quantities differ from the federal programs. For example the federal threshold quantity for anhydrous ammonia is 10,000 pounds; the California threshold is 500 pounds. Thus, many facilities that are not covered under the federal RMP/PSM program are covered under the CalARP program and are required to develop a risk management program.
Is Your RMP Current?
Your RMP, PSM or CalARP program contains many ongoing compliance activities. An advertised objective of the resubmittal requirement is to make sure a formal update of your plan is made. A subtler element of resubmittal is that of monitoring the commitment and follow-up of facilities regarding chemical risk management programs. Consider your status of the following:
- Follow-up / completion of PHA recommendations
- Re-validation of your PHA every 5 years
- Compliance audits (required every 3 years)
- Follow-up / completion of compliance audit recommendations
- Annual review and certification of operating procedures
- Employee training
- Updates related to system modifications, inventory changes, operational changes
- Off-site consequence analysis
- EPA's changes to RMP requirements
Condor Services
Condor can assist you with the development and resubmittal of your RMP/PSM/CalARP program. Whether you are new to the requirements of these regulatory compliance programs, are a seasoned professional and have been managing RMP/PSM or CalARP compliance at your facility, or somewhere in between, Condor can provide services to help you through this process. Condor can facilitate and document your PHA, develop or revise your off-site consequence analysis, develop prevention program elements, perform compliance audits, prepare your written program, and provide electronic submittal files. Local administering agencies (CUPAs) and California OSHA have conducted audits at several facilities with Condor-developed RMP/PSM/CalARP programs. As a result of sound program development by facility staff and Condor, and commitment by the facilities to comply with the regulatory requirements, few corrective action notices or citations have been issued.
— San Joaquin Regional Rail Commission
Contact
Vice President, Consulting Services
21663 Brian Ln., Sonora, CA 95370
(800) 800-0490, (209) 532-0361,
Fax: (209) 532-0773
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