I am always amazed at how far facilities will go to “exclude” contractors from their PSM/RMP contractor program. One that is a very common exclusion is “painting contractors”. Here is an example of how the WRONG painting contractor, provided with a bad scope of work, can cost you more than you bargained for…
40 C.F .R. ยง 68.48 Respondent failed to ensure the process is designed in compliance with recognized and generally accepted good engineering practices. Specifically, the 30,000-gallon storage vessel’s nameplate was painted over and, therefore, illegible.