A client recently underwent an RMP inspection by the US EPA. One of the issues the inspector took issue with was that the facility did not “certify” their 3-year audit. This stems from the following: (emphasis by me)
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EPA RMP ยง 68.79 Compliance audits OSHA PSM 1910.119(o)(1) Employers shall CERTIFY that they have evaluated compliance with the provisions of this section at least every three years to verify that the procedures and practices developed under the standard are adequate and are being followed. |
This leads me to ask: Should we STAMP and Sign each official PSM/RMP report?
This would include PHAs, 3-year audits, MI inspections, and investigation reports. Just get one of those big stamps we see in the old movies with a template for the “certifier” to sign their name and date their signature to “officially” accept the report.