Compliance Audit for Program 2 Facilities

• Audit Title

• Client / Site

• RMP ID #

• Regulated Substance(s):

• Anhydrous Ammonia

• Aqua Ammonia

• Conducted on

  Date

• Prepared by

• Location
  Address

• Personnel

• Document No.

Safety Information (68.48

• 1. Is current safety information available at this facility for the regulated substance(s)?

  Yes

  No

  N/A

• 2. Are current Safety Data Sheets (SDS) available at this facility for the regulated substance(s)?

  Yes

  No

  N/A

• 3. Has the maximum inventory of the regulated substance stored at this facility been defined?

  Yes

  No

  N/A

• 4. Are established safe upper/lower temperatures, flows, pressures and compositions available at this site for the regulated substance(s)?

  Yes

  No

  N/A

• 5. Are current equipment specifications available at this facility for use in handling regulated substance(s)?

  Yes

  No

  N/A

• 6. Are the codes/standards used to design, build, or operate the process available at this facility?

  Yes

  No

  N/A

• 7. Has the facility been designed and constructed in accordance with industry-accepted engineering practices?

  Yes

  No

  N/A

• 8. Is there a mechanism to update on a periodic basis, any changes to the RMP for this facility?

  Yes

  No

  N/A

Hazard Review (68.50)

• 9. Has a hazard review been performed for the regulated substance(s), process and procedures at this facility?

  Yes

  No

  N/A

• 10. Did the hazard review identify the hazards associated with the process and regulated substance(s)?

  Yes

  No

  N/A

• 11. Did the hazard review identify opportunities for equipment malfunctions or human error?

  Yes

  No

  N/A

• 12. Did the hazard review identify the safeguards used or needed to control to control the hazards or prevent equipment malfunctions or human error?

  Yes

  No

  N/A

• 13. Did the hazard review identify any steps used or needed to detect or monitor releases?

  Yes

  No

  N/A

• 14. Has the operator of this facility inspected all equipment and determined it is operated in accordance with all applicable standards and rules?

  Yes

  No

  N/A

• 15. Has the operator of this facility documented the results of the hazard review?

  Yes

  No

  N/A

• 16. Is there a mechanism to insure that problems identified in an inspection are corrected in a timely manner?

  Yes

  No

  N/A

• 17. Has the operator of this facility updated the inspection or review at least once every five years?

  Yes

  No

  N/A

• 18. Is there a mechanism to recognize new technology or equipment that would increase safety?

  Yes

  No

  N/A

Operating Procedures (68.52)

• 19. Have all issues identified in the hazard review been resolved prior to startup of the changed processes?

  Yes

  No

  N/A

• 20. Has the operator prepared written operating procedures that provide clear instructions or steps for safely conducting activities associated with each covered process? Operating procedures provided by equipment manufacturers or developed by organizations knowledgeable about the process and equipment may be used as a basis.

  Yes

  No

  N/A

• 21. Does the written operating procedures address normal initial startup and shutdown?

  Yes

  No

  N/A

• 22. Does the written operating procedures address normal operations?

  Yes

  No

  N/A

• 23. Does the written operating procedures address temporary operations?

  Yes

  No

  N/A

• 24. Does the written operating procedures address emergency shutdown and operations?

  Yes

  No

  N/A

• 25. Does the written operating procedures address startup following a major change that requires a hazard review?

  Yes

  No

  N/A

• 26. Does the written operating procedures address the consequences of deviations and steps required to correct or avoid deviations?

  Yes

  No

  N/A

• 27. Does the written operating procedures address equipment inspections?

  Yes

  No

  N/A

• 28. Is there a mechanism to insure the written operating procedures are updated?

  Yes

  No

  N/A

Training (68.52)

• 29. Has the operator of this facility provided training and tested to be competent each employee in operating a covered process?

  Yes

  No

  N/A

• 30. Has the operator of this facility provided refresher training at least every three years?

  Yes

  No

  N/A

• 31. Has the operator of this facility consulted with the employees to determine if the frequency of refresher training is appropriate?

  Yes

  No

  N/A

• 32. Does the operator of this facility provide training and testing to be competent for each employee on any new or updated process?

  Yes

  No

  N/A

Maintenance (68.56)

• 33. Has the operator prepared and implemented written maintenance procedures for insuring the on-going mechanical integrity of the process equipment?

  Yes

  No

  N/A

• 34. Has the operator of this facility provided training to those employees responsible for performing maintenance?

  Yes

  No

  N/A

• 35. Has every contractor providing employees for the purpose of performing maintenance on process equipment been trained on the written maintenance procedures?

  Yes

  No

  N/A

• 36. Has the operator of this facility inspected all equipment and determined it is maintained in accordance with all generally accepted engineering practices?

  Yes

  No

  N/A

Compliance Audits (68.58)

• 37. Has the operator performed and certified a compliance audit has been performed at least every three years?

  Yes

  No

  N/A

• 38. Has the compliance audit for this facility been conducted by a person knowledgeable of the process?

  Yes

  No

  N/A

• 39. Has the person conducting the compliance audit generated a written report of the audit findings?

  Yes

  No

  N/A

• 40. Has the operator of this facility promptly determined and documented an appropriate response to each of the findings of this audit and documented that any deficiencies had been corrected?

  Yes

  No

  N/A

• 41. Have the two most recent compliance audits and findings been maintained on file?

  Yes

  No

  N/A

Incident Investigation

• 42. Has the operator investigated each incident that resulted in, or could have resulted in an accidental release?

  Yes

  No

  N/A

• 43. We're all incident investigations initiated within 48 hours following the incident?

  Yes

  No

  N/A

• 44. Did the incident investigation include the date and description of the incident?

  Yes

  No

  N/A

• 45. Did the incident investigation include the date the investigation of the incident began?

  Yes

  No

  N/A

• 46. Did the incident investigation include the factors that contributed to the incident?

  Yes

  No

  N/A

• 47. Did the incident investigation include any recommendations resulting from the investigation?

  Yes

  No

  N/A

• 48. Has the operator of this facility promptly addressed any incident investigation findings or recommendations?

  Yes

  No

  N/A

• 49. Has the investigation documentation been maintained on file at the facility?

  Yes

  No

  N/A

• 50. Has the operator reviewed the findings with all affected personnel whose jobs are affected by the findings?

  Yes

  No

  N/A

• 51. Has the operator maintained investigation summaries on file at this facility for five years?

  Yes

  No

  N/A

• 52. Site-specific Question

• 53. Site-specific Question

• 54. Site-specific Question

• 55. Site-specific Question

• 56. Site-specific Question

• Compliance Audits 40 CFR 68.58 - (the rule)
  (a) The owner or operator shall certify that they have evaluated compliance with the provisions of this subpart at least every three years to verify that the procedures and practices developed under the rule are adequate and are being followed.
  
  (b) The compliance audit shall be conducted by at least one person knowledgeable in the process.
  
  (c) The owner or operator shall develop a report of the audit findings.
  
  (d) The owner or operator shall promptly determine and document an appropriate response to each of the findings of the compliance audit and document that deficiencies have been corrected.
  
  (e) The owner or operator shall retain the two (2) most recent compliance audit reports. This requirement does not apply to any compliance audit report that is more than five years old.

• Corrective Actions

Issue

• Item #

• Corrective Action

• Person Responsible

• Date

  Date

Record of Findings

• IMPORTANT: Mark the statement that properly describes the results of this compliance audit or use the provided space to write in your own conclusion. Each person performing a compliance audit must form an opinion after completing this assessment and record their findings. Any deficiencies found as a result of performing the compliance audit must be corrected and documented on the Corrective Action page.

• No deficiencies were found as a result of the compliance audit performed for this facility

• Deficiencies were found as a result of the compliance audit performed for this facility and have been corrected.

• Deficiencies were found as the result of the compliance audit performed for this facility and will be corrected soon

• Deficiencies will be corrected within_______ days

• Use this space for any other findings or conclusions:

Notes

• Notes

Certification

• Printed name:

• I am knowledgeable of the covered process and have to the best of my knowledge, information, and belief performed, after reasonable inquiry, this compliance audit.

  Sign

• Date:

  Date