PSM/RMP
Compliance
Resource
Kit

Our Point of View: Impact of the Biden Administration

The differences between the new and old administrations couldn't be greater and likely so will the Biden administration impacts upon business-related environmental, health, safety, security and sustainability regulation, funding and enforcement. This summary chart predicts the timeline, financial impacts and probabilities of actions that will likely be taken including heightened pressure for climate risk disclosure, implementation of a national emergency standard and liability protection regarding Covid-19 (and related issues), environmental enforcement, mandatory vaccination, re-shoring tax incentives, health and safety enforcement and infrastructure spending on areas ranging from sustainability to workplace automation.

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Process Safety and Operational Resilience – Bringing PSM/RMP into the 21st Century

Listen to our webinar on PSM/RMP updates as we covered the concepts associated with improving your PSM/RMP program from being “compliance-ready” to experiencing operational resilience. An anticipated increase in enforcement activity between OSHA and EPA will bring PSM/RMP into sharper focus this year. Additionally, OSHA and EPA have been collaborating to enhance their inspector’s training on conducting PSM/RMP inspections. With highly trained inspectors asking tough questions, being “Compliance Ready” may not be enough. This webinar provided information on the following topics:

• • Correlations between operational resilience, process safety, and risk management
• • Effective strategies for going beyond regulatory compliance and achieving operational resilience
• • Tools for anticipating and responding to operational upsets that may occur within your organizations

Update: Expanded Areas Subject to OSHA Process Safety Management Rules

With the new administration will come a new focus on OSHA and EPA compliance, employee safety, and environmental protection. Which makes 2021 the perfect year for you to review your company’s Process Safety Management (PSM) and/or Risk Management Program (RMP) compliance efforts and evaluate whether changes in recent years may have pulled more of your facility under these regulations. This monograph discusses what may need to be added to your current PSM program.

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OSHA Instruction: PSM Covered Chemical Facilities National Emphasis Program

The purpose of this OSHA instruction is to describe an OSHA National Emphasis Program (NEP) for inspecting facilities with highly hazardous chemicals (HHCs) in amounts at or greater than the threshold quantities listed in 29 CFR 1910.119. The scope of this instruction applies OSHA-wide, covering both programmed and unprogrammed inspections that take place in all OSHA Regions.

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EPA Guidance on Risk Management Programs for Chemical Accident Prevention

The rule, “Chemical Accident Prevention Provisions” (part 68 of Title 40 of the CFR), applies to a wide variety of facilities that handle, manufacture, store, or use toxic substances. Covered facilities must develop and implement a risk management program and maintain documentation of the program at the site. This technical guidance document helps determine if you are covered by the rule, what level of requirements is applicable to covered process(es), what specific risk management program activities must be conducted, selecting an implementation strategy and understand the reporting, documentation, and risk communication rule components.

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EPA Enforcement Annual Results for 2020

In the first five months of fiscal year (FY) 2020, EPA was on track to significantly exceed traditional numeric metrics in many categories with more compliance monitoring activities in the first five months than in any year since 2013, more in assessed penalties the first five months than in seven out of the previous ten years, more injunctive relief in the first five months than in FY 2019, and more concluded cases in the first five months than in either FY 2018 or FY 2019. This increased enforcement profile is set to continue under the Biden Administration. Read the EPA's report on last year's actions to understand the likely increasing emphasis on enforcement in the coming years.

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Process Safety/Risk Management Services

BSI EHS Services and Solutions delivers a full range of Process Safety Management (PSM) / Risk Management Program (RMP) consulting and support services to assist companies with identifying and mitigating hazards associated with operating processes using highly hazardous chemicals and regulated substances. This brief explains our service categories including compliance strategies and planning, hazard assessments, mechanical integrity testing, contractor safety services, training, incident investigation, compliance audits and more.

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Immersive Consulting Solutions for EPA Compliance

The world is changing and a new area of consulting is immersive technologies, where the on-site portion of support for compliance reporting can be handled remotely through on site cameras and shared vision devices. These devices can be operated by individuals or through remotely-controlled drones. Review this webinar segment to see how immersive technologies could lower costs and increase accuracy for EPA-mandated reporting in areas ranging from solid/hazardous wastes to EPCRA/TRI reporting and in between.

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Building the Business Case for a Total Worker Health Approach

As mandated in President Biden's Executive Order on Protecting Worker Health and Safety, more worker protections for Covid 19 exposure are being targeted for enforcement. This should cause organizations to review not only pandemic protections but something that is increasingly being categorized as Total Worker Health. This paper outlines what the scope of this type of program is, what its benefits are and how it can be implemented.

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Create Cultural Change with a Best in Class Environmental Compliance Program

Creating a best in class environmental compliance program does not need to cost a lot of money, or take up a lot of time, and, best of all, the payoffs can lead to immediate and important impacts to your organization such as: better staff morale, higher profits, improved productivity, greater safety, and a commitment to sustainable practices that help improve the health of our planet. This paper presents models and guidelines developed by industry experts to better focus this type of effort.

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Guidance to Business Continuity Planning and Emergency Response

There is a solid process for understanding gaps or weaknesses in an organization’s abilities to plan for business continuity during emergencies. This paper outlines the successful elements of this process including determining what it means for the organization to be resilient, adapting and managing expectations by building in flexibility, communication keys, using short, medium and long-term evaluation tools and using a crisis aftermath to plan for the future.

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