Management program elements

The owner or operator of a stationary source shall develop a management system to oversee the implementation of the risk management program elements. 

In order to be able to carry out the hazards analysis, information from sources such as P lDs and material safety data sheet (MSDS) is needed. Much of this information is included in the Knowledge Management program (element 6). 

During each audit, at least 15% of the facilities operated, with a minimum of one facility, should be audited. The facilities included in the audit should not be the same as those included in the previous audit. When sufficient deficiencies are identified in the effectiveness of any safety and environmental management program elements, the test sample size shall be expanded for that program element. 

Audit of safety and environmental management program elements (Section 12). 

Safety inspections, observations, and walk-throughs are a core feature of the safety management program elements. Unfortunately, these walk-through tours can evolve or be perceived as a negative, fault-finding activity that becomes adversarial between the leadership team and employees. 

Auditof Safety and Environmental Management Program Elements... 

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