Since EPA published their final amendments last month, some in the process safety profession have been in a tizzy over the 3rd Party Audit Requirements. This little revision is going over about as well as OSHA’s revised Hazard Categories. This week I have fielded many calls, emails, and texts from people panicking over this new 3rd Party Audit requirement. For the record, as if EPA has not stated this already, the 3rd Party Audit requirements do NOT apply to the “normal” 3-year audit(s), EXCEPT for specific situations…
- There has been a reportable accident, or
- If an implementing agency determines that a third-party audit is necessary, based on information about the facility or about a prior third-party audit at the facility.
The amended rule does NOT change the requirement that RMP facilities regularly conduct RMP compliance audits. It does, however, specify that in specific situations, those audits be performed by a 3rd party or a team led by a 3rd party (pursuant to the schedule in §68.58(h) and/or 68.79(h) of the rule).
So this means that facilities can continue doing their own internal audits and when they choose to use an external auditor(s), the external auditors are NOT limited from doing other work for the client.
See this Posts from EPA backing this up