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PSM/RMP Compliance Audits

JCL Risk Services consultants participated on several multi-disciplinary teams for management system audits to meet OSHA Process Safety Management (PSM) and EPA Risk Management Program (RMP) compliance. These audits covered all PSM/RMP elements and included verification through documents and records reviews, interviews of facilities personnel, and on-site observations. Each audit included documenting the findings and recommendations for achieving compliance with regulatory and/or company requirements.

Process Safety Management System & Risk Management Program Support

Our consultants performed a wide variety of development support services for management systems to meet OSHA Process Safety Management (PSM) and EPA Risk Management Program (RMP) compliance. Examples of services for Process Safety Information, Operating Procedures, and Emergency Planning & Response elements included:

• Performing facility walk-downs and red-lining piping & instrument diagrams (P&IDs).
• Updating electrical classification drawings.
• Developing and/or updating facility operating procedures.
• Developing lockout/tagout (LOTO) plans for critical equipment.
• Developing integrated contingency plans (“One Plan”) for OSHA, DOT, EPA, etc.

Process Hazard Analysis (PHA) Studies

JCL risk consultants facilitated multi-disciplinary teams for a series of Process Hazard Analysis (PHA) studies. These studies addressed hazard identification, human factors, facility siting, and risk ranking. Each study included recommendations for risk reduction measures to achieve acceptable levels of risk and to satisfy regulatory compliance requirements.

Risk Assessments

JCL managed teams for a series of risk assessments for refinery capital projects involving engineering design modifications to flare header systems, firewater systems, and various refinery processes as part of the Management of Change (MOC) process. The reviews included conducting Process Hazard Analysis (PHA) studies, Layer of Protection Analysis (LOPA) studies, Inherently Safer System (ISS) reviews for engineering design modifications for future operations. These studies addressed hazard identification, human factors, facility siting, and risk ranking. Each study included recommendations for risk reduction measures to achieve acceptable levels of risk and to satisfy regulatory compliance requirements.

Capital Project — Process Hazard Analysis Studies

This project required JCL to facilitate multi-disciplinary teams for a series of risk assessments for capital projects involving demolition and construction work activities on a product pipeline wharf, including marine and land-based operations. The reviews included conducting: Project Hazard Analysis (PHA) studies for occupational safety hazards for demolition and construction work activities. These studies addressed hazard identification, human factors, and facility siting. Each study included recommendations for risk reduction measures to achieve acceptable levels of risk.

Incident Investigations, Causal Factor Analyses & Root Cause Analyses

These major incident investigations involved a serious injury of a contractor employee and near-miss during construction work activities for a major capital project. JCL facilitated multi-disciplinary teams to conduct studies which involved multiple parties and support for regulatory compliance. Each investigation included Causal Factor Analyses and Root Cause Analyses to generate recommendations for correction of deficiencies, corrective actions to prevent recurrence, and preventive actions to prevent occurrences for future construction projects.