| Preface | p. xi |
| About the Authors | p. xiii |
| Acknowledgments | p. xv |
| Introduction | p. 1 |
| Understanding the Regulations | p. 3 |
| Background | p. 3 |
| Applicability | p. 7 |
| Auditing PSM and RMP Programs | p. 11 |
| Techniques for Internal Auditors | p. 11 |
| Document Reviews | p. 12 |
| Personal Interviews | p. 15 |
| Developing an Audit Report | p. 16 |
| Process Safety Management Audit: Employee Participation | p. 19 |
| Process Safety Management Audit: Process Safety Information | p. 23 |
| Process Safety Management Audit: Process Hazard Analysis | p. 31 |
| Process Safety Management Audit: Operating Procedures | p. 39 |
| Process Safety Management Audit: Training | p. 45 |
| Process Safety Management Audit: Contractors | p. 49 |
| Process Safety Management Audit: Pre-Startup Safety Review | p. 57 |
| Process Safety Management Audit: Mechanical Integrity | p. 61 |
| Process Safety Management Audit: Hot Work Permit | p. 71 |
| Process Safety Management Audit: Management of Change | p. 79 |
| Process Safety Management Audit: Incident Investigations | p. 83 |
| Process Safety Management Audit: Emergency Planning and Response | p. 87 |
| Process Safety Management Audit: Compliance Audits | p. 97 |
| Process Safety Management Audit: Trade Secrets | p. 101 |
| Risk Management Program Audit: Applicability | p. 105 |
| Verification of Facility Liability for 40 CFR Part 68 | p. 105 |
| Verification of Process(es) Eligibility for Selected RMP Program Level | p. 106 |
| Evaluation of the Submitted RMP | p. 108 |
| Verification of the Worst-Case Release Scenario Analysis | p. 111 |
| Verification of Offsite Consequence Analysis Parameters for Worst-Case Release Scenario | p. 112 |
| Verification of Offsite Impacts Definitions | p. 113 |
| Verification of the Analysis Review and Update | p. 113 |
| Five-Year Accident History Verification | p. 114 |
| Risk Management Program Audit: Program 1 Processes | p. 115 |
| Verification of Submitted RMP | p. 115 |
| Verification of Offsite Consequence Analysis Parameters | p. 116 |
| Documentation Verification | p. 119 |
| Risk Management Program Audit: Program 2 Processes | p. 121 |
| Evaluation of Submitted RMP | p. 121 |
| Verification of Implemented Management System | p. 125 |
| Verification of Process Hazard Review | p. 126 |
| Verification of Alternative Release Scenarios Analysis | p. 126 |
| Verification of Offsite Consequence Analysis Parameters | p. 127 |
| Documentation Verification | p. 129 |
| Verification of Safety Information | p. 129 |
| Verification of Operating Procedures | p. 130 |
| Verification of Employee Training | p. 131 |
| Verification of Equipment Maintenance | p. 131 |
| Verification of Compliance Audits | p. 132 |
| Verification of Incident Investigation | p. 132 |
| Verification of Conditions That Relieve Facility of Need to Develop an Emergency Response Program | p. 133 |
| Verification of Emergency Response Program | p. 133 |
| Verification of Material Safety Data Sheets (MSDS) | p. 134 |
| Risk Management Program Audit: Program 3 Processes | p. 139 |
| Evaluation of Submitted RMP | p. 139 |
| Verification of Implemented Management System | p. 143 |
| Verification of Process Hazard Assessment | p. 144 |
| Verification of Alternative Release Scenarios Analysis | p. 146 |
| Verification of Offsite Consequence Analysis Parameters | p. 146 |
| Documentation Verification | p. 148 |
| Verification of a Compilation of Written Process Safety Information | p. 148 |
| Verification of Operating Procedures | p. 149 |
| Verification of Employee Training | p. 151 |
| Verification of Mechanical Integrity Maintenance | p. 152 |
| Verification of Management of Change | p. 153 |
| Verification of Pre-Startup Review | p. 154 |
| Verification of Compliance Audits | p. 155 |
| Verification of Incident Investigation | p. 155 |
| Verification of Employee Participation | p. 156 |
| Verification of Hot Work Permits | p. 156 |
| Verification of Contractors' Work Compliance with Rules | p. 157 |
| Verification of Conditions That Relieve Facility of Need to Develop an Emergency Response Program | p. 158 |
| Verification of Emergency Response Program | p. 158 |
| 29 CFR 1910.119 | p. 161 |
| 40 CFR 68 | p. 183 |
| Document Request Form | p. 219 |
| OSHA CPL 2-2.59A | p. 221 |
| National Response Team's Integrated Contingency Plan Guidance | p. 301 |
| Endnotes | p. 325 |
| Bibliography | p. 333 |
| Index | p. 335 |
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