RCP Inc.

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In This Issue

  1. OCS/State Water Pipelines Jurisdiction
  2. Are your processes covered by OSHA Process Safety Management (PSM), EPA Risk Management Plan (RMP), or similar state regulations?
  3. Pending Audits?
  4. Review Process for Projects Involving Historic Natural Gas Pipelines – Clarifications
  5. Acquiring a pipeline?
  6. Electronic Transmission and Storage of Drug Testing Information Federal Advisory Committee; Meeting
  7. DOT/OPS Progressing on Gas Integrity Management Rule
  8. Integrity Management FAQ
  9. ILTA Presentation on Pipeline Regulations
  10. Conference on Emergency Reallocation of Natural Gas
  11. Conference on Emergency Reconstruction of Interstate Natural Gas Infrastructure

Are your processes covered by OSHA Process Safety Management (PSM), EPA Risk Management Plan (RMP), or similar state regulations?

If so, RCP can assist with all aspects of PSM and RMP compliance assurance. RCP services range from single-process program assessments to complete program development for the entire facility. A common approach that many clients prefer can be separated into three-phases:

Phase 1 – Conduct PSM/RMP Assessment

RCP’s regulatory compliance specialists will team with your personnel to conduct a PSM/RMP assessment at your facility. These site visits typically are completed within 2 – 5 days depending upon the complexity of the covered processes. While at your facility, RCP specialists will:

  • Meet with the appropriate site personnel
  • Review and evaluate existing policies, procedures, and related information sources for PSM/RMP compliance
  • Develop site-specific recommendations to bring the facility within compliance and improve the effectiveness of the facility’s PSM/RMP programs.

Soon after the site visit is complete, RCP will submit a written assessment, including improvement opportunities as well as recommendations for implementation strategy.

Phase 2 – Develop/Update Selected PSM/RMP Program Elements

Based upon the results of the Phase I assessment, you may request that RCP develop and/or update selected PSM/RMP program elements. RCP will deliver new/updated programs of the selected PSM/RMP program elements for your final approval. RCP will take full advantage of specific client input, any existing programs, OSHA/EPA guidance, and industry practices to develop effective programs for your covered processes.

Phase 3 – Lead/Assist Selected PSM/RMP Activities

RCP regulatory specialists will facilitate or assist with the implementation of the activities identified in the newly developed/updated PSM/RMP programs. This may include:

  • Leading and documenting process hazard analysis
  • Developing management of change processes
  • Reviewing operation and maintenance procedures
  • Optimizing mechanical integrity programs
  • Conducting incident investigations
  • Conducting compliance audits
  • Training for site personnel

For additional information, contact Chris Foley @ (713) 655-8080