Recently EPA issued a Consent Decree in response to a company that had two (2) facilities inspected under the Risk Management Plan Rule (40 CFR Part 68). The document was much like the many others I have posted here; however, this agreement contained a lengthy audit plan that EPA and the company agreed to as part of the resolution of the inspections. This material could be viewed as an inside look at what EPA expects from 3-year audits. I thought it was worth passing on, as we still see way too many 3-year audits being done that do not even scratch the surface! It should be noted, that EPA took a two prong approach with this audit plan, as this company managed RMP from a corporate office with “pass down” to the two facilities in this agreement. The audit plan included an audit of the Corporate Office for its role in RMP compliance, as well the two facilities involved in these inspections. This company has more than these two facilities involved in these inspections. Here is EPA’s audit plan…