We are often questioned about our audit methology and techniques. Clients ask… “How did you know to ask me about that?” or “Why in the world do you want to see that for in a PSM/RMP audit?” Well, here is one way I learned what gets asked for; attached is an official EPA RMP Inspection report from a four (4) day inspection at a large refinery complex. The US EPA inspection team comprised of three (3) inspectors: one lead inspector and two others. A look into this inspection will demonstrate how much ground a well-trained audit team can cover and how they can easily identify potential problem areas for further auditing. There was some “low hanging fruit” they found that eventually tallied up to a civil penalty of $326,000 to settle nine violations of the Risk Management Program and the facility has agreed to install a fence-line monitoring system, Supplemental Environmental Project (SEP), with a value of at least $248,000. So three inspectors spent four days looking at a Program 3 RMP facility that had a history of releases/fire and the damage was over $500,000 to EPA rather than spending it on process safety! This inspection report is a MUST READ for any process safety professional that wants to better understand what EPA (and OSHA) will be asking for during an inspection. I have posted the actual citations/NOVs below, but the notes and documentation in this report are where the real learnings come from. The issues they found: