I wanted to end this series on preparing for an inspection by going over some more of that “low hanging fruit” we talked about earlier. Let’s say you find out an auditor is going to be onsite TOMORROW. What do you do? More importantly, what do you have time to do? You’re not going to be able to get a PHA or MI inspection knocked out, but I wanted to go over some easy updates you can make to your PSM program documentation. Here’s a simple checklist you can use:
Check the names and titles in your RMP/PSM policy document or documents. Some PSM programs have a separate policy document for each element and others consolidate them all into one. Regardless, give these documents a quick scan through to check for names of people who have left the company or titles which are no longer being used.
Sometimes the RMP/PSM policy document has an Organization Chart (Org Chart) – make sure it is updated to align with current names and titles.
Do the same thing for your Operations Procedures (SOPs). Oftentimes a contact person is listed on the SOPs – make sure that name is current.
Check your RMP Submit as well. If there has been a change in the emergency contact, this should have been updated within one month. Similarly, if there has been a change of ownership at your facility, the RMP should be updated. These changes can be made at cdx.epa.gov.
Check your Emergency Action Plan / Emergency Response Program (EAP/ERP). This policy very commonly has a lot of names, titles, and phone numbers listed throughout. Give this document a read-through to make sure all the information is current.
If you have a day to prepare, you should be able to make these quick updates and save yourself some headaches with the inspector.
Contact us if you need help updating or developing any of these records.
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