Don’t Get Stuck: Practical Tips To Avoid OSHA Process Safety Management Citations(PPT)

摘要

1.Review lists of available questions and most often cited regulations to ensure compliance 2.Get your PSM-related documents ready 3.Verify implementation of PSM elements (i.e., is actual program consistent with writte program?) 4.Consider independent gap analysis with special focus on operating procedures, mechanical integrity, process hazard analysis, compliance audits process safety information, and management of change 4.1 Perform gap analysis so it is protected by legal privilege 4.2 Develop plan to close (AND THEN PROMPTLY CLOSE) identified gaps 4.3If gap closure will take time - IMPLEMENT INTERIM MEASURES to mitigate hazard 5.AT A MINIMUM - Review status of recommendations from previous compliance audits, PHAs, incident investigations