Process Safety Management/Risk Management Program Support
Trinity serves a broad cross-section of industries with Process Safety Management (PSM) and Risk Management Program (RMP) support. With the acquisition of PSM specialty firm Provenance Consulting, Trinity provides expertise in all 14 elements of PSM and RMP enabling us to deliver comprehensive and efficient solutions that are custom tailored to a facility's individual need. We understand how the pieces fit together!
Trinity Chemical Compliance: PSM/RMP Services
- Jurisdictional Boundaries - We can determine if your facility is PSM or RMP covered and to what extent the coverage applies.
- Process Safety Information (PSI)- We implement proven methods to ensure and maintain the accuracy and consistency of PSI.
- PHA & Risk Assessment - Our team facilitates a variety of Process Hazard Analysis methodologies and other comprehensive risk studies.
- Mechanical Integrity - We provide full support for implementing and executing a comprehensive and accurate fixed equipment Mechanical Integrity and Inspection program.
- IPL Lifecycle Support - We assist with any IPL tasks related to documentation, design, and maintenance that are required during the IPL lifecycle, for both new and existing IPLs.
- Relief System Services - We provide complete relief system lifecycle support including design revalidations and correction, detailed design, installation, flare evaluation, and process simulation.
- Software Solutions - We deliver custom software applications that can replace or improve your current solutions and help you meet PSM objectives.
- Custom PSM/RMP Training - We can present standard or customized trainings to your employees to ensure a successful implementation of your PSM/RMP program.
- Offsite Consequence Analysis (OCA) and Onsite Best Practices Modeling - Trinity's experts develop, update, and review OCA modeling to meet RMP requirements and best practice reviews. These modeling studies can be used to evaluate toxic releases and fire/explosion scenarios, including building damage assessment.
- Risk Management Plan - We assist clients to prepare and submit Risk Management Plan initial submissions, corrections, and resubmissions via the EPA RMP*eSubmit database.
- Management of Change (MOC) - We are able to assist you to implement, steward, and audit MOC processes to ensure long-term maintainability and success.
- Pre-startup Review (PSSR) - We facilitate and support PSSRs including redlining as built PSI, procedures, and ensuring proper completion and documentation.
- Compliance Audits - Our team provides support in developing and implementing successful compliance audit programs.
- Incident Investigation - We facilitate investigation methodologies including Root Cause Analysis, Fault-tree, and Five Why.
- Contractors - We help develop programs that ensure contractors stay informed and have input into PSM/RMP programs.
- Emergency Response - We develop, prepare, and implement strategies to effectively and safely manage highly hazardous chemical release. We develop Emergency Action or Emergency Response Plans specific to the actions your employees will take in response to releases.
- Employee Participation - We develop programs that lay the foundation for enhanced employee involvement and input into PSM programs.
- Hot Work Permit - We develop and audit Hot Work programs to ensure compliance.
- Trade Secrets- We address trade secret requirements for PSM-covered processes and provide appropriate Confidential Business Information (CBI) protection in Risk Management Plan updates.
Every 5 Years - Risk Management Plans must be revised and resubmitted to EPA
Every 5 Years - Offsite Consequence Analysis modeling must be reviewed and resubmitted to EPA
Every 5 Years - Process Hazard Analysis must be revalidated or redone
Every 3 Years - PSM and RMP Compliance Audits must be completed
Every 3 Years - Refresher training must be provided for personnel (Operators and Contractors) involved in operating a process
Annually - Operating procedures must be certified
What is PSM?
The Process Safety Management of Highly Hazardous Chemicals (29 CFR 1910.119) is a performance based OSHA program developed jointly with industry and is designed to prevent or minimize the consequences of catastrophic releases of highly hazardous chemicals. Facilities that have inventories of flammables (flash point less than 100°F) in excess of 10,000 lbs and/or have chemicals in excess of the quantities of 1910.119 Appendix A are subject to PSM requirements.
What is RMP?
The Risk Management Program (RMP) Rule was created by EPA to protect the environment and community. Section 112(r) of the Clean Air Act Amendments requires EPA to release regulations and guidance for chemical accident prevention at facilities that use certain hazardous substances. The regulated substances and their respective threshold quantities can be found at 40 CFR 68.130.