Several times year we upset a client who has hired us to do a “wall-to-wall” compliance audit with their PSM/RMP programs. These audits are our most intense audits in which we leave no rock unturned. One of the items we audit in this level of auditing is the RMP submittal and all of the supporting documentation for the Off-Site Consequence analyzes. This comes as a not so happy movement for some of these clients and they actually will shut us down and claim that is outside the scope of a Program 3 Prevention Program audit. We suggest that “wouldn’t it be best if we found an issue rather than letting EPA find it” and not no avail the attorneys usually lasso us back in and we move on to other elements. Here is the proof that EPA actually requires the supporting documentation be with the ARS and WCS; although not an expensive NOV, none-the-less it is proof that EPA does include this documentation in their inspections.