System implementation
How the system is implemented
A structured, facilitated process — from scope definition through close-out — producing defensible, actionable outputs.
Appendix A Applicability & Covered-Process Boundary
Determine Appendix A threshold-quantity applicability per regulated HHC list; map covered-process boundaries including all interconnected equipment, pressure-relief routing, and shared utilities; identify co-located processes and exclusions (retail, atmospheric-storage); document Threshold Quantity inventory register.
14-Element Gap Assessment (NEP-Aligned)
Conduct element-by-element PSM compliance audit against the OSHA NEP inspection checklist (CPL 03-00-021 / 03-00-014); score each element for documentary evidence, programme execution quality, and finding traceability; identify Willful, Serious, and OTI-class citation exposures.
PSI Re-accuracy & MOC Backlog Clearance
Audit P&ID-as-built accuracy, MOC backlog register, and PSI document-control history; implement accelerated MOC backlog review with risk-ranking; re-issue affected P&IDs, equipment datasheets, and MAWP records; establish PSI change-management procedure preventing future backlog accumulation.
PHA Revalidation & Action Close-out Programme
Establish 5-year PHA revalidation and interim-trigger programme; issue action register with risk-rank gating, ownership, and completion date; build CSB-recommendation-aligned close-out tracker; integrate HAZOP findings into MI, MOC, and PSSR workflows with evidence-based close-out status.
Mechanical Integrity, PSSR & Contractor Management
Implement MI programme per API RP 580 RBI with damage-mechanism register, inspection frequency risk-ranking, and NDE specification; deploy PSSR line-item discipline covering mechanical, ESD, SIS, and ATEX pre-start items; build contractor pre-qualification, training, audit, and performance-review programme per OSHA Appendix C.
Compliance Audit Protocol & Corrective-Action Register
Design 3-year compliance audit per OSHA (o) using structured interview guides, document review matrices, and field-observation protocols; build corrective-action register with risk-rank gating and management-of-record sign-off; produce re-audit readiness pack including evidence library and interview preparation guide.
