Syllabus for IIAR PSM RMP Certificate Course

Module 1 Applicability, Requirements, Management and Hazard Assessment
This introductory module kicks off the certificate course with a look at some important definitions contained in the OSHA PSM regulation and the EPA’s RMP Rule, including some important distinctions between the intent and terminology of the two programs. We move on to an examination of the criteria that determines which facilities must comply with the PSM and RMP statutes, and then follow that up with a review of the general requirements for the EPA “Program Levels” that affect all facilities with anhydrous ammonia inventory greater than 10,000 lbs. The module finishes up with a comprehensive exploration of the RMP Rule’s requirements for hazard assessment, including offsite consequences; worst-case release scenarios; alternative release scenarios; offsite impacts (population and environmental); RMP review and update; documentation; and compiling a five-year accident history. Presenter: 
Presenter: Trevor Hegg, EVAPCO, Inc. (Taneytown, MD)

Module 2 Employee Participation and Process Safety Information
The second module in our PSM/RMP certificate course focuses on two fundamental components of any safety program: employee participation and process safety information. This session offers a review of both OSHA and EPA requirements for employees involvement in a PSM or RMP program, including a compliance example that highlights awareness, involvement, access, and document management. The remainder of Module 2 concentrates on requirements for process safety information mandated by OSHA and EPA. Our instructor will guide participants through a detailed explanation of the information the agencies want in terms of the hazards of the highly hazardous chemical; information on the technology of the process; and information on the equipment in the process. Helpful tips for documentation of compliance are offered throughout the session.
Presenter:  Trevor Hegg, EVAPCO, Inc. (Taneytown, MD)

Module 3 Process Hazard Analysis and Operating Procedures
Module 3 begins with an examination of both OSHA’s and EPA’s requirements for process hazard analysis (PHA). We’ll highlight how the PHA exercise can be used to evaluate potential hazards and provide crucial information to guide decisions for improving safety and reducing the potential for a catastrophic release. This session includes an example of using and documenting a “What-if” PHA methodology, as well as a review of the importance of appropriately ranking risks and developing actionable recommendations for higher-ranked hazards. The second half of this lesson will cover requirements for operating procedures, which provide the foundation of operator training and ensure that jobs are carried out consistently and correctly by system operators. Topics to be covered in this area include which operating phases must have written procedures; information that must be included in the operating procedures; and documentation of  written operating procedures.
Presenter:  Peter Jordan, MBD Risk Management Services (Langhorne, PA)

Module 4 Training and Contractors
The first half of Module 4 is dedicated to a review of training requirements laid out by OSHA and EPA. We’ll go over exactly who needs to be trained, what kind of training must be offered, training frequency, and acceptable training formats. Training documentation checklists will be presented to help employers understand what steps they need to take in order to maintaining  compliance and to help employees recognize what will be expected of them in terms of required knowledge, skills, and abilities to safely carry out the duties and responsibilities as specified in the operating procedures. The second part of Module 4 focuses on owner/employer requirements for engaging contractors performing maintenance or repair, turnaround, major renovation, or specialty work on or adjacent to a covered process, as well as contractor employer responsibilities for firms that are hired to perform this work.
Presenter:  Ryan Murphy, Bassett Mechanical (KauKauna, WI)

Module 5 Pre-startup Safety Review
Module 5 examines OSHA and EPA requirements for pre-startup safety review (PSSR), including safety and environmental issues that must be resolved before startup, confirmation that equipment is in accordance with design specifications, and applicable procedures that must be ensured before an ammonia refrigeration system is brought online. This session also reviews PSSR sign-off and approval, and we finish up with some common problems and misconceptions associated with PSSR.
Presenter:  Jet Stiffler, JS Compliance, LLC (Spring, TX)

Module 6 Mechanical Integrity and Hot Work Permit
In Module 6, we review the requirements for OSHA’s PSM standard and the EPA’s RMP Risk Management Plan regulation specific to the Mechanical Integrity (MI) and Hot Work elements.  This module provides an overview of the requirements from OSHA and EPA, as well as provide compliance examples and documentation that can be used for documentation. Specific topics addressed include MI requirements for equipment, MI requirements for inspection and testing, compliance with MI requirements, and an overview of requirements for hot work permitting.
Presenter: Jeanna Emmons, PSM RMP Solutions (Mission Viejo, CA)

Module 7 focuses on the application and importance of the management of change (MOC) requirements mandated by OSHA and EPA. An overview of the processes covered under the MOC requirements will be offered, along with an explanation and of the “replacement in kind” exception. Participants will be given specific examples of modifications that are replacement in kind and therefore don’t require MOC documentation, as well as numerous examples of modifications that are not replacement kind and do require MOC documentation. We’ll look at requirements for written MOC procedures and the considerations that must be addressed prior to any covered change. Other topics to be addressed include applicable safe work practices for managing changes; quality assurance; and temporary changes. And finally, participants will be led through the elements of an MOC deliverables checklist that can be adapted for use in their own facilities.
Presenter:  Tony Lundell, IIAR (Alexandria, VA)

OSHA’s PSM regulation and the Hazard Prevention Element of EPA’s RMP rule require employers toinvestigate each incident that which resulted in, or could reasonably have resulted in, a catastrophic release of a highly hazardous chemical in the workplace. The first half of Module 8 examines the importance of the incident investigation element as a process; requirements for an investigation team to thoroughly investigate and analyze an incident; investigation report requirements; and recordkeeping requirements. The second half of Module 8 focuses on the OSHA and EPA requirement that employers establish and implement an emergency action plan for the entire plant in accordance with the provisions of OSHA rules [29 CFR 1910.38(a)]. Emergency planning and response (EP&R) is a critical element for emergency pre-planning and training to make personnel aware of, and able to execute, proper actions in the case of an unplanned incident. We will examine the importance of the EP&R element and the differences between an Emergency Action Plan (EAP) and an Emergency Response Plan.
Presenter:  Tony Lundell, IIAR (Alexandria, VA)

OSHA and EPA require employers to establish and implement processes for performing compliance audits and provisions for trade secrets. Compliance audits are required in order to ensure that an employer's PSM program and RMP are being followed and that they are correctly implemented. The first half of Module 9 examines the requirements for compliance audits and guides participants through development and implementation to show how the audit process and compliance audit team work together to produce the desired outcome, which is to identify the chain of events and causes that led to an incident and to implement corrective measures that prevent similar events from occurring. Module 9 finishes up with a look at requirements for trade secrets. Emphasis will be placed on the need to share necessary information with authorized personnel without regard to the trade secret status of that information, and also what steps OSHA allows for maintaining the privacy of sensitive materials.
Presenter:  Tony Lundell, IIAR (Alexandria, VA)