FREE Checklist to Prepare You for ANY Audit (Avoid 6-figure fines!) | Blog No. 24

Failing to complete these recurring PSM activities often results in SIX-FIGURE fines from the EPA. I wanted to share this checklist so you can ensure you’re staying on top of the high priority items. These requirements are so fundamental that even a brand-new inspector will cite you if you’re out of compliance:

• Process Hazard Analysis (PHA)

  • The PHA needs to be completed initially and updated every 5 years. Is yours current?

  • Do you have all your PHA reports, even the old ones? These reports have to be maintained for the life of the process.

• Compliance Audit

  • The Compliance Audit needs to be completed every 3 years. Is your current?

  • You need to retain the two (2) most recent compliance audits. The older ones can be deleted or archived based on your company’s document retention policies.

• RMP Submit

  • The RMP Submit needs to be completed initially and updated every 5 years. Is yours current?

  • If you can’t find it, you can print it off from cdx.epa.gov.

• Hazard Assessment / Offsite Consequence Analysis

  • The Hazard Assessment (AKA: Offsite Consequence Analysis) needs to be completed initially and updated every 5 years.

  • The Hazard Assessment, RMP Submit, and PHA are oftentimes completed around the same time since they share the same 5-year cycle.

• Operating Procedures (SOPs)

  • The Operating Procedures (SOPs) need to be certified annually. Have your SOPs been certified within the last year?

  • While a thorough review on an annual basis is a good best practice, that is not explicitly required by the regulation. It’s better to make sure you are current and then work on getting an SOP training/review on the books.

Here’s a bonus one for ammonia refrigeration facilities only:

• Minimum System Safety Evaluation (MSSE)

  • The MSSE is a new activity required by ANSI/IIAR 9-2020.

  • If your system was built in the last 5-10 years, this doesn’t apply.

  • All pre-existing systems need to complete the IIAR 9 MSSE before January 1, 2026 or else they will be out of compliance. (This date should be reflected in Addendum A to IIAR 9 per a personal conversation I had with Tony Lundell, IIAR Senior Director of Standards and Safety.)

  • The activity clarifies which code requirements do or do not apply to an older facility.

I hope this simple checklist serves you as you manage your PSM program. Contact us if you need help with any of these activities.