The real, and CRITICAL, date of your PSM/RMP Audit(s)

I get about a dozen calls a year from folks asking me about their PSM/RMP due dates.  I try to explain that of course OSHA or EPA can cite the facility if the audit is past due.  For example, the last audit was done the 2nd week of February 2020, it is expected that the 3-year audit will be conducted BEFORE the 2nd week of February 2023.  That is easy math, but the CRITICAL DATE regarding these audits is NOT the week the audit was done, but rather the really important date is

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