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ACSEngGroup is Licensed by the Texas Board of Professional Engineers
ACS Engineering Group prepares site specific EPA 40 CFR Part 68 Risk Management Plans (RMP) and/or OSHA 29 CFR 1910.119 Process Safety Management (PSM) Procedures that are required as part of an RMP or PSM program at regulated facilities.
Why Choose Us?
ACS Engineering Group environmental consultants research your applicability and can help mitigate the impact of having to comply with the RMP/PSM programs. ACS Engineering Group 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. ACS Engineering Group can help you determine changes and the effects of changes to your RMP system relative to the RMP Submit process. ACS Engineering Group is experienced in developing, preparing, and submitting initial and successive RMP Submits.
ACS Engineering Group 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 walk through, and equipment/process studies.
What is RMP?
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.
RMP is comprised of three levels of programs, 1, 2, and 3, each having their own applicability and impact on operations.
RMP Program Levels
- Program 1 – Facilities have the least amount of regulations to follow, but in most cases, the least amount of resources to develop, train, and implement a fully functional program. We can help fill the gap and deliver you a program that is livable as well as compliant. Program 1 facilities are not subject to PSM requirements.
- Program 2 – Facilities have to follow similar regulations as Program 1 with the inclusion of a few more pieces to the program. Program 2 facilities are not subject to PSM requirements.
- Program 3 – Facilities have the most restrictions, most standards, and must also comply with OSHA’s Process Safety Management (PSM) Program. The RMP Program 3 and OSHA PSM programs are virtually identical with the exception of few requirements such as worse case scenario modeling and RMP Submit.
Applicability
ACS Engineering Group’s environmental consultants will 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 to a non-regulated chemical in processes, 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 audit-able compliance?
- 4. What steps can I take to mitigate the RMP/PSM impact on operations and the process?
Program Development
ACS Engineering Group will build your facility a site specific RMP and/or PSM compliance administration program and manual.
Operating and Administrative Procedures
Procedures are required as part of an RMP or PSM program and considered a regulated document. ACS Engineering Group 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 walk through, and equipment/process studies. We believe in utilizing as many of the site existing procedures to help maintain familiarity with staff, reliability of the equipment, and keeping costs down.
RMP Submit
ACS Engineering Group’s environmental consultants can help you determine changes and the effects of changes to your RMP system relative to the RMP submit process. ACS Engineering Group can also develop, prepare and submit intial and successive RMP submits for your site. RMP Submits are due every 5 years from the date of the intial submit.
Management of Change (MOC) Program
ACS Engineering Group can help simplify your MOC program with a hard copy system, an online document control system, or a combination of the two.
If you currently have an RMP or PSM program and would like to speak with ACS Engineering Group concerning program compliance options, call to setup an site consultation. We will review your existing program, records, and compliance methods to provide you with a detailed gap analysis and risk mitigation plan. Talk to us about our methods for maintaining a positive compliance track record.
Our environmental consultants have over 20 years of industry experience working with clients, regulatory agencies, and writing permits. You can count on ACS Engineering Group to deliver you the best services, permits and plans for your facility.
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Featured RMP and PSM consulting services:
- RMP and PSM Program Development
- Site Specific Operational Procedures
- Mechanical Integrity Program Development
- Compliance Audits
- Process Hazard Analysis
- RMP Submit Preparation and Submittal
- RMP Audit Preparation>
Regulatory Drivers:
- 40 CFR Part 68 – Chemical Accident Prevention Provisions
- Process safety management of highly hazardous chemicals.
External Resources:
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Contact us today for an evaluation and tailored proposal for your RMP or PSM needs.