A client recently underwent an RMP inspection by the US EPA. One of the issues the inspector took issue with was that the facility did not “certify” their 3-year audit. This stems from the following: (emphasis by me)
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EPA RMP ยง 68.79 Compliance audits OSHA PSM 1910.119(o)(1) Employers shall CERTIFY that they have evaluated compliance with the provisions of this section at least every three years to verify that the procedures and practices developed under the standard are adequate and are being followed. |
This leads me to ask: Should we STAMP and Sign each official PSM/RMP report?
This would include PHAs, 3-year audits, MI inspections, and investigation reports. Just get one of those big stamps we see in the old movies with a template for the “certifier” to sign their name and date their signature to “officially” accept the report.
I find value in this approach, as it forces senior management to put their name on the PSMS and to own the contents of the report(s). This would be HUGELY beneficial regarding the MI inspection/test reports so many facilities receive from their party inspectors. I can not recall an assessment/audit I have done in 20 years where we did not find a pipe, vessel, or PRD inspection report with some severe issues to resolve that just got “filed” on someone’s shelf. At one of my facilities, the company had a practice of stamping the report’s cover, and the appropriate manager had to sign and date the report. This meant they OWNED the report’s contents and thus were responsible for the generation of the Corrective Action Plan (CAP) to address the findings within the report.
This all goes back to having that Management System document that clearly defines the owners of the PSM/RMP elements, broken down by each of the covered processes on site. This approach to driving OWNERSHIP may be a bit of a stretch, but I liked it as the facility safety director. I was the gatekeeper of the reports, so the management system stated they had to be addressed to the facility PS Manager (not allowing reports to fall through the cracks). Then, I would stamp it and hand deliver it to the responsible party at the next weekly staff meeting (or sooner if some items demanded immediate attention).
OWNERSHIP matters in any management system, and this approach forces the owner to accept the report and all its contents officially and then address those issues requiring some action on their part. My team and I were the back-stop to this process as we, too, reviewed the report(s), and we were the “gatekeepers” of the Corrective Action Plan (CAP) system, so we knew what and when to expect a plan from the said report. If we do not get one within several weeks, we will give a nudge to the manager(s). These managers had to have their CAPs approved by the PM, as he/she was the ultimate owner of PS. They had to be the balancing act of resources and $’s, based on a risk assessment the EHS team would provide when asked.
This drives a TEAM APPROACH to managing PS!