Process Safety Management

PSM and Risk Management Plan Consultation To Help Achieve Compliance

Wenck professional inspecting a chemical storage facility during a compliance audit

In order to remain in compliance with the OSHA’s 29 CFR 1910.119 and EPA’s 40 CFR 68 rules, facilities that store, process or use a highly hazardous or flammable substance above the threshold quantity are subject to Process Safety Management (PSM) and Risk Management Plan (RMP) requirements. These facilities must regularly re-evaluate safety and program implementation. All PSM-subject facilities must perform a full compliance audit every three years and the facility Process Hazard Analysis (PHA) must be revalidated every five years.

These programs have broad requirements, which the EPA and/or OSHA updates from time to time. Failure to comply could lead to penalties, fines, or even forced temporary closure. The best way to comply with PSM and RMP standards is for your PSM/RMP coordinator to involve a third party who provides comprehensive PSM/RMP compliance services. Wenck can be that third party.

Wenck’s PSM/RMP compliance team has over four years of PSM consultation experience specializing in Ammonia refrigeration PSM/RMP programs. Wenck has a thorough working knowledge of the PSM /RMP standards and understands Recognized and Generally Accepted Good Engineering Practice (RAGAGEP) for ammonia and a variety of industries. We have helped over 50 individual facilities with ammonia refrigeration, chlorine, and other flammables and chemicals to develop and update program materials, and maintain compliance with required activities. Whatever your Process Safety Management or Risk Management Plan problems, Wenck is the solution.

Which Compliance Services Does Wenck Offer?

Wencks’ PSM/RMP team has the experience and resources to help you with compliance audits, PSM plan creation, or PHA revalidation no matter where you are in the process. If you need help with any of the following Process Safety Management program requirements, Wenck has a plan to help you:

  • Process Safety Management Program Development: Wenck can assist with the initial development of a PSM program for any new facility. Our team will help you ensure your Program fulfills all PSM and RMP standards from the start, so you don’t have to worry about being out of compliance later.
     
  • Risk Management Plan Initiation: Wenck’s PSM/RMP team are designated RMP “preparers” ready to assist with the initial development and submission of a Risk Management Plan in a new facility. Wenck can also assist with a 5-year RMP re-submission as a designated preparer.
     
  • Three Year Compliance Audits: Wenck conducts roughly 17 PSM/RMP compliance audits per year. We conduct the audit to fulfill the requirements of 29 CFR 1910.119 (o) and 40 CFR 68.79. The Wenck PSM team has consulted on many different programs and can provide “best practice” recommendations to help you streamline and enhance management of your program.
     
  • Process Hazard Analysis for New Facilities: Wenck conducts an average of 12 PHAs per year. During our PHA, Wenck follows the requirements in 29 CFR 1910.119 (e) and 40 CFR 68.67 to comprehensively check each sub-system, piece of equipment, work process, and environment. The Wenck team has had formal training in PHA techniques and has experience facilitating several types of PHAs.
     
  • Five Year Revalidation of Process Hazard Analysis: PSM protocols stipulate that facilities revalidate their PHAs in accordance with 29 CFR 1910.119 (e) and 40 CFR 68.67 every five years. Wenck can help facilitate your PHA revalidation to ensure your PHA is up-to-date and fully compliant.
     
  • Project Hazard Review to Fulfill Management of Change and Pre-Startup Safety Reviews (MOC/PSSR) Requirements: Per 29 CFR 1910.119 (l)(2)(ii) and 40 CFR 68.75 (b)(2), a project-centered (MOC/PSSR) PHA is required whenever a PSM-subject facility makes a major potential change to their process. Wenck’s teams can focus on this MOC/PSSR review to complete it quickly to minimize operational delays.
     
  • Five Year Mechanical Integrity Inspections for Ammonia Refrigeration systems: As part of RAGAGEP for ammonia refrigeration systems now required under ANSI/IIAR 6 – 2019 (5.4.2), facilities with ammonia refrigeration must have a third-party independent mechanical integrity inspection. Wenck is qualified to perform your independent inspection and has had formal training in MI inspections.

Have more questions about our PSM/RMP capabilities or experience? Contact Project Lead Carl Enzenauer at cenzenauer@wenck.com or 763-479-4282.

Which Industries Can Wenck Provide PSM/RMP Compliances Services For?

The outside of an ammonia refrigeration plant

Wenck’s team specializes in Ammonia Refrigeration. We also have a great deal of experience conducting compliance audits, creating or modifying PSM programs, and conducting PHAs for a wide variety of other facilities. Some of the industries Wenck’s team provides PSM/RMP support to most frequently include (but are not limited to):

  • Ammonia refrigeration
  • Chemical specialty users/producers
  • Alcohols processing
  • Hexane extraction
  • Production facilities that use chemicals or flammable materials

Why Should I Use a Third Party for PSM Compliance Auditing?

Third-party involvement is not required of PSM/RMP facility programs, but getting an outside expert’s opinion still provides several invaluable benefits including:

1. Our third-party team won’t be biased toward or against your pre-existing programs. We can accurately identify risks and non-compliant elements without fear of repercussion or pride in the existing program.

2. As experienced experts, our team may find ways to streamline and improve your PSM program or PHA facilitation, reducing redundancies and identifying time and resource-saving efficiency improvements. You could be safer, fully-compliant, and more efficient all at once!

3. Most importantly, our team maintains professional knowledge of the contemporary EPA and OSHA PSM/RMP rules and requirements. Wenck’s PSM team also has a strong working knowledge of Ammonia, Chlorine, and flammables related RAGAGEP to help ensure your facility is up to speed with specialized industry standards.

When it comes to improving your PSM and RMP standards, the specialists at Wenck are the way to go.

How Does Wenck PSM Consultation Work?

Wenck professional inspecting an ammonia refrigeration plant during a process safety management compliance audit

When you hire Wenck for PSM consultation, PHA, or a compliance audit, we start by meeting your team and getting to know your company and how we can help. Then, we’ll take a tour of your facility to see the equipment and processes under consideration.

During an audit, our compliance auditor walks through each of the 14 PSM elements and RMP elements as applicable. We use several checklists (by OSHA, EPA, and others) to ensure the program contains the required elements. We also interview team members involved in the PSM/RMP element under review. Wenck will provide a compliance audit report listing all findings and detailing the audit protocol.

When conducting a PHA, we typically follow a hazard and operability study HAZOP or a “What-if” style of analysis, comprehensively checking each sub-system and piece of equipment and reviewing employee procedures. Most importantly, we document every step of this process to provide a completed PHA report and electronic files for future use.

Why Should I Choose Wenck for PSM Services?

When you work with Wenck, we make sure you know and understand what we’re doing every step of the way. You communicate directly with our team lead, Carl Enzenauer. When we’re finished, you receive a comprehensive report and tracking log detailing what we found. When you choose Wenck for Process Safety Management or Risk Management Plan help, you get a partner ready to ensure your facility’s compliance, solve problems, and improve safety.

What Are My Next Steps?

If you’re interested in Wenck’s Process Safety Management services, contact our project manager Carl Enzenauer at cenzenauer@wenck.com or call him at 763-479-4282. All you need to have ready is a brief status of the state of your PSM/RMP program. Wenck will handle the rest. We look forward to working with you!

We Look Forward to Helping You Achieve PSM/RMP Compliance.

Request Consultation