Do you include your Fire Extinguisher company under your PSM/RMP Contractor Safety Program?
If your covered process is included in PSM/RMP because of the HHC’s flammability, then the answer is YES. Most facilities will list their fire extinguishers as a “safe guard” in their PHA’s and this makes the link even stronger for them to be included in the PSM/RMP Contractor Safety Program. As noted in my earlier Emergency Response Post on Fire Extinguisher inspection and maintenance, these devices can be a hazard if they are not managed properly. Fire Extinguishers require an annual maintenance test and a hydrostatic test per a set schedule. Just like when we hire contractors to do our mechanical integrity inspections on our vessels, we put them through the contractor evaluation program to ensure they have the skills and training to do the work properly and safely. The same logic needs to be applied to our fire extinguisher contractor(s). Not doing so opens the facility up to un-necessary risk and compliance issues.
NOTE: even if your process is NOT covered under PSM/RMP because of flammability issues with your HHC, but you have listed them as safeguards in your PHA for some scenarios, then I would argue that the listing them in your PHA safeguards pulls them into your PSM/RMP mechanical integrity program. Not everyone would agree with this, but it is my position.