EPA RMP, OSHA PSM, and CalARP Three-Year Compliance Audits
Compliance Audit Requirements
- Certify evaluation of compliance (3 years)
- The audit shall be conducted by at least one person knowledgeable in the process
- Document findings in a written report
- Promptly address the findings and document the correction of deficiencies
- Retain two most recent audit reports
Common Industry Questions
“The regulator visited my facility and audited me. He/she already told me what my violations were.”
An audit by a regulator or outside agency does not count towards your Three-Year Compliance Audit. The regulator also often does not have time to evaluate all aspects and requirements of the program. The facility is expected to be participating in the Program Life Cycle in which the effectiveness of the regulatory programs is constantly being evaluated and improved. Furthermore, the facility must have a report of the findings to demonstrate this.
“I did an update and submitted.”
The document submitted to the EPA and/or to your CUPA summarizes the program requirements, provides recent dates of activity, and certifies that the facility maintains the complete program documentation onsite. Unless there is a separate report kept onsite that documents an in-depth evaluation, the update and submittal documents do not count towards the Three-Year Compliance Audit requirements.
Risk Management Professionals’ Services
An effective Compliance Audit is reliant on:
- Mastery knowledge of the regulations and requirements
- Industry application of the Program Requirements to the covered process
- Experience and knowledge of common breakdowns in Program implementation for the covered process
- Ability to work with personnel to develop reasonable solutions to deficiencies that are the easiest and most efficient to fold into the day-to-day operations of the covered process.
Risk Management Professionals specializes in the development of Regulatory Programs for a wide variety of industrial applications and utilizes this knowledge to provide high-value compliance audits to our clients. RMP is committed to providing high-quality compliance audits that serve both the interests of the facility, and the safety of the public and employees.