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Compliance Assurance Programs @ RCP
Because I said so!
Your mother
The compliance programs for most facilities exist primarily between the ears of their regulatory compliance specialist.
Who knows exactly what permit conditions apply to a certain facility operation? Who remembers the "special conditions" that only kick in if a certain pipe is exposed, or a certain incident occurs? The person who got the permit, or who was there when that rule was passed. And if that person quits, retires, or is just reassigned, that special knowledge is frequently lost forever. Until the next agency inspection or audit. Do your facility personnel know what they need to do, and why they need to do it? A well designed compliance program can help avoid that dependence on any one individual, and can help ensure that the facility remains in compliance in spite of personnel turnover, corporate transitions, and normal human forgetfulness. In this age of personal, criminal liability for environmental non-compliance, isn't a well designed and professional compliance program worth the cost?
So how can RCP partner with me?
Web-Based Regulatory Compliance Management Systems
Isn't the Internet great? The Internet is coming to regulatory compliance and RCP is on the cutting edge.
Combine RCP's vast experience with developing comprehensive regulatory compliance programs with the cutting edge capabilities of the Internet and you get a WORLD-CLASS COMPLIANCE MANAGEMENT SYSTEM, (CMS).
This comprehensive system can neatly manage virtually any and all of your regulatory management requirements, including DOT, EPA, OSHA, USCG, as well as local & state-specific air, wastewater, hazardous waste, and safety requirements.
Because RCP incorporates web-based technology, there are no IT issues to struggle through while getting started.
With recent advances and new PDA technology emerging every day, direct wireless connectivity can also be integrated into this system.
The CMS creates an institutional memory of the compliance history and ongoing compliance requirements, despite personnel or corporate turnover.
If key personnel leave and other corporate changes take place, the system will still be in place and functioning.
Records are maintained electronically and are accessible by any designated personnel in case of an agency inspection.
The CMS is completely scalable, so RCP can manage a small division’s regulatory compliance and easily expand to handle the entire corporation’s regulatory management needs.
Some of the features of the web-based compliance management system include:
COMPLIANCE MANAGER used to define and manage entire facilities, operating units, specific systems & assets, and related requirements. Calculations for numeric requirements are easily managed with the powerful calculation engine.
DATA MANAGER allows data points to be recorded on a monthly, weekly, daily or hourly basis – perfect for air emissions and wastewater reporting. Information about the data collector and time of data collection is also gathered, creating a history of compliance activities.
TASK MANAGER enables designated users to assign compliance tasks to others, track task progress, and collect other information such as time and cost required to complete tasks. The Task Manager component also generates automatic reminders and emails to notify users of important task deadlines.
REPORT MANAGER allows RCP and other designated users to build standard reports required by local, state, and federal regulatory bodies. Routine agency reports are easily generated with this powerful component. The System also allows RCP and designated users to design custom reports to fulfill internal corporate reporting requirements. Custom reports can be generated on any data point in the System, numeric or non-numeric. Compliance data can then be compiled into HTML or Excel formatted reports.
DOCUMENT MANAGER lets users store and track multiple versions of key compliance documents. Whether it's a spreadsheet, PDF, or word processing document, users will be able to share or attach documents to any system object, including tasks. This tool is especially helpful in storing MSDSs, operating procedures, and inspection checklists.
COMPLIANCE CALENDAR is integrated with all System components providing a comprehensive view of compliance activities, ensuring that users are kept informed of task due dates. Tasks are highlighted on the calendar and overdue tasks are clearly denoted in red.
MESSAGE CENTER is where all exceedance notices and messages are posted and retained in a searchable library.
SECURITY MANAGER maintains a log of authorized users and provides them with the clearance to perform specific duties within the System. The Security Manager safeguards data by ensuring that only designated users with the appropriate security clearance can change or update the database.
Let RCP know if you are interested in a demonstration. RCP’s experienced professionals would be happy to show your team the power of web-based regulatory compliance.
Title V Air Permit Compliance Manuals
Title V air permits are complex documents that contain many indirect requirements through references to industry specifications, other regulations, even the permit application itself. Many times, the personnel who are responsible for permit compliance do not have these documents available and / or do not have time to thoroughly review and understand them. Meanwhile, the issuing agency requires company management to sign certification statements that the facility is in compliance with all the applicable requirements. How does a company ensure that these complex and overlapping requirements are clearly understood, and that the programs in place are addressing all the requirements?
RCP can develop a permit compliance manual that considers all of the applicable requirements from all applicable sources and presents the information in an organized and logical fashion. Facility personnel save time because they know exactly what to do and when to do it. Regulatory specialists will have a concise reference manual that explains the requirements applicable to each facility, with regulatory citations, rule excerpts, and permit application summary data. Appropriate data will be gathered all year long, so end of year reporting will be easier. And management personnel can base their certification statements upon a clearly defined program with clearly defined requirements.
Success Story: Title V Air Permit Site Compliance Manual
Water Discharge Permit Compliance Manuals
Water discharge permits can be just as complex as air permits, with specialized monitoring, reporting, and record keeping requirements, some of which vary depending upon the volumes discharged over time. Record keeping and data analysis can be a real chore. Interim exceedance reports may be desirable, even when not required, to minimize potential fines and penalties when the annual report is submitted. RCP can provide clear guidance, while organizing and simplifying the entire record keeping and monitoring program, to help the facility stay in compliance.
Site-Specific Compliance Manuals
Perhaps you have a site with multiple regulatory requirements from numerous agencies (and what site doesn't, these days?). RCP can develop a compliance manual that is tailored to your specific site. One comprehensive system will capture the appropriate requirements - whether from an air permit, water permit, OSHA regulation, state or federal regulation, or applicable industry standard. All compliance activities will be coordinated with each other, record keeping will be consistently organized, and employee training will be simplified.
Company-Wide Regulations Reference Manuals
A regulations reference manual that is customized to your company's specific operations and facilities can be a real time saver. It is useful in responding to audits, in determining the applicability of new or revised rules, in answering questions from management and field operations, and in training new personnel in the regulatory group. It also simplifies and improves the ability of the regulatory specialists in a group to backfill one another. Each applicable regulation is summarized, including its impacts on your operations. All the applicable compliance guidance documents and interpretations are organized for future reference. All permits, consent orders, and other requirements are clearly identified. And the entire program can be published on the company LAN or Intranet, to make the information available to all interested parties.
Success Story: Nationwide Regulations Reference Manual
PSM-RMP
Phase 1 - Conduct PSM/RMP Assessment
RCP’s regulatory compliance specialists will team with your personnel to conduct a PSM/RMP
assessment at your facility. These site visits typically are completed within 2 - 5 days
depending upon the complexity of the covered processes. While at your facility, RCP specialists
will:
- Meet with the appropriate site personnel
- Review and evaluate existing policies, procedures, and related information sources for
PSM/RMP compliance
- Develop site-specific recommendations to bring the facility within compliance and improve
the effectiveness of the facility's PSM/RMP programs.
Soon after the site visit is complete, RCP will submit a written assessment, including improvement
opportunities as well as recommendations for implementation strategy.
Phase 2 - Develop/Update Selected PSM/RMP Program Elements
Based upon the results of the Phase I assessment, you may request that RCP develop and/or update
selected PSM/RMP program elements. RCP will deliver new/updated programs of the selected PSM/RMP
program elements for your final approval. RCP will take full advantage of specific client input,
any existing programs, OSHA/EPA guidance, and industry practices to develop effective programs
for your covered processes.
Phase 3 - Lead/Assist Selected PSM/RMP Activities
RCP regulatory specialists will facilitate or assist with the implementation of the activities
identified in the newly developed/updated PSM/RMP programs. This may include:
- Leading and documenting process hazard analysis
- Developing management of change processes
- Reviewing operation and maintenance procedures
- Optimizing mechanical integrity programs
- Conducting incident investigations
- Conducting compliance audits
- Training for site personnel
USCG Facility / Vessel Inspection Programs
RCP will assist you in developing streamlined inspection programs (SIPs) that meet current USCG policies.
We can help you:
- Develop a company action plan (CAP)
- Develop vessel action plans
- Identify appropriate Inspection Criteria References (ICRs) for your vessels
- Develop appropriate Inspection Schedule and Verification (ISV) forms for your vessels
- Develop vessel-specific examination checklists
- Draft correction reports
- Set up a record keeping and monitoring system
Even if you do not participate in the SIP, RCP, Inc. can assist you in determining applicability of vessel inspection regulations and assist you in monitoring your vessel inspection program.
Pipeline Integrity Management
Pipeline Integrity Management is the newest regulatory requirement for pipeline operators. The DOT rules covers operators having over five hundred miles of hazardous liquids pipelines while the rule from the Texas Railroad Commission covers operators of intrastate hazardous liquids and gas pipelines.
Whether you operate one pipeline or an extensive network, RCP, Inc. can assist you in developing your specific plan that satisfies your particular regulatory requirements. We have knowledge and experience to provide you the optimum solution in meeting the mandated deadlines.
Success Story: Pipeline Integrity Management
Give us a call and we can move forward on this important work.
Operator Qualification Programs
All DOT pipeline operators must have a written qualification program by April 27, 2001, and must complete the qualification of individuals performing covered tasks by October 28, 2002.
RCP, Inc. can help you by reviewing the tasks performed by your operators, to identify all "covered tasks," developing and/or modifying training programs, and establishing your written qualification program. We can also work with you to ensure that your contractors meet these requirements.
Success Story: Operator Qualification
Operations & Maintenance Procedures
Do you need to describe specifically how to operate every line segment in your system? Are you satisfied with the quality and scope of your abnormal operating procedures? Are your pigging procedures customized for the specific type of pig trap in use? What about special situations such as flooding, hurricanes, and other abnormal environmental conditions?
Let the experts at RCP, Inc. assist you in developing the comprehensive procedures that you need to protect your people, facilities, and the environment.
Complete DOT Pipeline Compliance Programs
Need a comprehensive solution to your DOT Pipeline compliance program? Our integrated pipeline compliance program may be the system you have been looking for. Designed for companies without in-house DOT expertise, it combines the required manuals, work orders, checklists, file systems, and training programs into one consistent package. Everything is cross-referenced and labeled for ease-of-use. All the necessary responsibilities are clearly defined and assigned to specific individuals. Routine activities are scheduled a year in advance, and organized so that a clerical person with no special regulatory knowledge can coordinate the whole program. This system has been audited and approved by state and federal pipeline safety agencies. And, it works so well, even companies that have in-house DOT pipeline expertise have chosen it for their pipeline systems. Give us a call and see for yourself if this solution is right for you.
Success Story: Chemical Plant Compliance for DOT Pipelines
Permit Compliance Systems
Modern permits require that the company management "certify" that they are operating in compliance with the permit conditions. An air permit is a complex document, incorporating a myriad of other requirements "by reference". How does a manager know that the facility is actually in compliance with these requirements? By developing a comprehensive permit compliance system, and training their employees on how to use it.
Success Story: Title V Air Permit Site Compliance Manual
Preparation and Updating of Plans/Manuals/Forms
Coast Guard regulations governing Marine Transportation-Related Facilities are rife with paperwork requirements. RCP can provide a very cost-effective solution to the problem of preparation and continuing update of regulatory documents. We have vast experience in the preparation of, among others:
- Dock Operations Manuals
- MARPOL NLS Instruction Manuals
- Marine Vapor Control System Operating Manuals
- Vessel Transfer Procedures
- Dock Emergency Manuals
- OPA 90 Plans for Facilities
- OPA 90 Plans for Vessels
- Declaration of Inspection Forms
- Applications for Exemption/Requests for Alternative Methods
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