Trinity serves a broad cross-section of industries with Process Safety Management (PSM) and Risk Management Program (RMP) support. We work with clients to determine whether the facility uses any of the listed chemicals in quantities that exceed program applicability thresholds. If so, we evaluate options to modify processes in order to opt out of the applicable program or step down to a less rigorous level (in the case of RMP). Once program applicability is determined, we can assist with the development of the PSM/RMP applicable components - Hazard Assessment, Prevention Program, Emergency Response, and the RMPlan.
RMP Hazard Assessment
The primary element of the Hazard Assessment is an off-site consequence analysis to determine the potential impact of “worst case” and “more likely” accidental release scenarios. The worst-case analysis determines which program level is required under the rule. Trinity’s modeling and regulatory compliance experience is invaluable in helping clients determine the appropriate program level.
Depending upon the results of the worst case analysis, alternative scenario analyses may be required.
The first step in the Hazard Assessment is to identify the appropriate release scenarios based on a facility’s process safety information. An experienced risk assessor then reviews the site’s operations and layout. The scenarios should be selected by balancing the likelihood of an incident, the estimated distance to a predicted endpoint, and effective communication of actual plant risks. Using realistic, credible analytical methods helps prevent public miscommunication. Whatever the local concerns and type of hazards, Trinity can assist in the development of scenarios that are representative and reasonable.
Prevention Program Development and Review
The Prevention Program includes the most technically demanding and labor-intensive elements in a PSM/RMP program. All of the following elements may be required in a Prevention Program:
- Process safety information
- Process hazard analysis
- Operating procedures
- Mechanical integrity
- Management of change
- Pre-startup review
- Compliance audits
- Incident investigation
- Employee participation
- Hot work permit
- Contractor safety
- Emergency response (PSM)
- Trade Secrets (PSM only)
Trinity’s staff has participated in the development, review, and implementation of all elements of the Prevention Program. With client staff, Trinity conducts safety reviews and hazards analyses, identifies weaknesses, and makes recommendations. If a facility has an existing program, Trinity reviews the program to ensure that it meets all legal requirements and is consistent with good engineering and management practices. Trinity also works with the client to develop an effective, grass-roots accident prevention program if needed.
Risk Management Plan and Community Relations
Once the necessary analyses have been performed and programs developed, Trinity can assist with documentation and communication of the plan, which includes completing EPA’s checklist, submitting the plan, documenting the assumptions behind the analysis and program development, and communicating the results to the public. Our experience teaching technical material, along with our experience providing expert testimony, help us communicate complex technical issues, implement public communication programs, and prepare a timely and accurate response to any issues raised as a result of the assessment.
Trinity also helps facilities ensure that they meet their requirements under the General Duty clause to provide employees with an environment that is free from recognized hazards that cause or are likely to cause death or serious physical harm.
Finally, Trinity offers turnkey chemical safety program services for industrial clients in the following areas:
- Tracking applicable regulatory developments
- PSM/RMP applicability determinations
- Assisting with preparation and implementation of prevention program elements
- Conducting program audits including required triennial regulatory compliance audits
- Facilitating Process Hazard Analyses (PHAs) for existing and new operations
- Conducting off-site consequence analysis (OCA) modeling
- Preparing the Risk Management Plan, updates and submittals
- Training personnel on PSM/RMP elements and program execution
- Assisting clients during agency inspections and meetings
For assistance, please contact Natalie VanLiew at firstname.lastname@example.org.