Aggie Safety's process safety work is led by Sumit Anand, PE, a Texas-licensed Professional Engineer and the company's Chief Technical Officer. Sumit holds bachelor's and master's degrees in chemical engineering with a research focus on process safety, and brings 19 years of industry experience from CITGO, KBR, and BASF. He specializes in Process Safety Management (PSM), Risk Management Plan (RMP) compliance, Process Hazards Analysis, Pressure Relief Systems, and Explosion Protection, the exact disciplines covered by OSHA's 14 PSM elements and EPA's RMP rule.
This isn't a generalist safety consultant reviewing PSM as one service among many, it's engineering-led compliance work from someone whose career has centered on high-hazard process safety at major energy and petrochemical companies.
Aggie Safety supports PSM and RMP compliance for facilities across Houston's industrial corridor, from the Energy Corridor in west Houston, home to companies like Lotte Chemical, to the Ship Channel-adjacent operations in La Porte and Pasadena, where clients like Gas Innovations manage high-purity hydrocarbon processing.
We also work with facilities throughout Baytown, Texas City, and the broader Gulf Coast refinery corridor, where OSHA PSM and EPA RMP requirements carry some of the highest compliance stakes in the country.
| S.No | Element | PSM/RMP Elements — Requirement Summaries | Aggie Safety Support | Code of Federal Regulations / Review Cycle |
|---|---|---|---|---|
| 1 | Compliance Audits | Periodically evaluate whether PSM/RMP prevention program elements are implemented and effective; document audit findings, assign and track corrective actions to completion, and retain audit reports for the required timeframe to demonstrate continuous compliance and improvement. | AGGIE SAFETY can support conducting compliance audits with: - Review of documentation - Field walkthroughs - Employee interviews Our report includes: - Findings and recommended actions - Recommendations for GAPs/findings identified during the audit |
40 CFR 68.79, 40 CFR 68.83 & 29 CFR 1910.119(o) - Audits must be conducted every 3 years |
| 2 | Employee Participation | Develop a written plan describing how employees participate in PSM activities (including PHAs and procedure development), consult with employees and their representatives as required, and provide access to relevant PSM information so the workforce can contribute to hazard identification, control, and safe operations. | AGGIE SAFETY can assess the complete employee participation plan by spot-checking: - Employee orientations/trainings - Employee involvement in PHAs, Mechanical Integrity, MOCs, PSSRs, and Process Safety Information development and maintenance - Ensuring employees have access to all relevant information |
40 CFR 68.79, 40 CFR 68.83 & 29 CFR 1910.119(o) |
| 3 | Contractors | Select and manage contractors to ensure contract work is performed safely, including providing process hazard information and emergency actions, evaluating contractor safety performance, ensuring contractor training and supervision, maintaining injury/illness logs as required, and coordinating safe work practices between host facility and contractors. | AGGIE SAFETY can review contractor programs to ensure contractors are informed of: - Process hazards - Provisions of the emergency plan We can also suggest appropriate actions to correct deficiencies and monitor contractor performance. |
29 CFR 1910.119 (h), (f), 40 CFR 68.87(a), 40 CFR 68.87(b) |
| 4 | Training | Provide initial and refresher training for operators and others as needed on process overview, operating procedures, hazards, and emergency operations; verify and document understanding/competency, keep training records, and ensure refresher training occurs at the required interval or when changes indicate a need. | AGGIE SAFETY can evaluate existing training programs for all facility employees. Training elements include (but are not limited to): - Process overview - Operating procedures - Safety and health hazards - Emergency procedures - Safe work practices |
29 CFR 1910.119(g), 40 CFR 68.71(a), (b), (c), 40 CFR 68.54(a), (b), (c) - Training must be conducted every 3 years for all employees & contractors |
| 5 | Hot Work | Implement a permit system for hot work (e.g., welding, cutting, brazing) conducted on or near covered processes to verify fire prevention and other precautions are in place before work begins; issue, document, and retain permits per requirements and align with recognized fire protection practices. | AGGIE SAFETY can develop or review hot work programs for facilities, including critical documentation such as: - Authorization forms and signatures - Documentation of all hot work requirements This helps meet citation requirements listed in the regulations. |
29 CFR 1910.252(a), 40 CFR 68.85(a), (b), 29 CFR 1910.119(k) |
| 6 | Hazards Analysis | Systematically identify, evaluate, and control process hazards using an appropriate methodology (e.g., HAZOP, What-If, FMEA), document findings and recommendations, assign owners and due dates, and ensure timely resolution; revalidate PHAs at the required frequency and retain documentation. | AGGIE SAFETY can assess hazard analyses using applicable methodologies and document: - Identified hazards and risks - Corrective measures - Applicable Management of Changes (MOCs) - Related incident learnings |
29 CFR 1910.119(e), 40 CFR 68.67 - Revalidation required every 5 years |
| 7 | Management of Change (MOC) | Review and authorize changes (other than replacement in kind) to chemicals, technology, equipment, procedures, and facilities before implementation; evaluate safety/health/environmental impacts, update PSI/procedures/training as needed, and ensure affected employees and contractors are informed and trained on the change. | AGGIE SAFETY can evaluate MOC procedures that control changes to: - Equipment - Procedures - Raw materials - Process conditions (other than "replacement in kind") We can also coach facilities on improving specific MOCs. |
29 CFR 1910.119(l), 40 CFR 68.75(a)–(e) |
| 8 | Mechanical Integrity | Establish and implement written programs to ensure the ongoing integrity of critical equipment (e.g., pressure vessels, piping, relief devices, controls, pumps), including inspection/testing frequencies, procedures, acceptance criteria, correction of deficiencies, quality assurance for parts/repairs, and documentation. | AGGIE SAFETY can review mechanical integrity programs, including: - Identification and categorization of equipment and instrumentation - Inspection and testing activities and frequencies - Testing criteria and documentation |
29 CFR 1910.119(j), 40 CFR 68.73(a)–(f) |
| 9 | Operating Procedures | Develop and maintain written procedures that clearly describe safe work practices for all phases of operation (startup, normal, temporary, shutdown, emergency), including operating limits, consequences of deviation, and steps to correct/avoid deviations; ensure procedures are current, readily available, and periodically reviewed and certified. | AGGIE SAFETY can assess operating procedures to ensure they cover: - All operating phases of the process - Safe operating limits - Safety and health considerations - Safety systems and their functions |
29 CFR 1910.119(f), 40 CFR 68.69(a)–(d), 40 CFR 68.52(a)–(c) - Procedures must be certified annually |
| 10 | Process Safety Information (PSI) | Compile, keep current, and make accessible written information needed to understand the hazards of the covered chemicals and the process, including chemical hazard data, technology of the process (e.g., safe operating limits, design basis), and equipment information (e.g., materials of construction, P&IDs, relief design). | AGGIE SAFETY can review PSI to ensure completeness and accuracy for: - Process chemicals - Process technology - Process equipment This includes: - Block flow diagrams / PFDs - Updated P&IDs - Pressure relief systems - Explosion Protection - Dust Hazard Evaluation - Applicable engineering codes and standards |
29 CFR 1910.119(d), 40 CFR 68.65(a)–(d) |
| 11 | Pre-Start Up Reviews (PSSR) | Before introducing hazardous chemicals to a new or significantly modified process, confirm construction/installation matches design, procedures are in place, training is completed, and PHA/MOC recommendations are resolved as appropriate; document the review to show the process is ready for safe startup. | AGGIE SAFETY can review and verify that pre-startup safety reviews ensure: - All construction and equipment are complete - PSI is updated - Operating procedures are in place - Training has been completed |
29 CFR 1910.119(i), 40 CFR 68.77(a), (b) |
| 12 | Incident Investigation | Investigate incidents and near-misses that resulted in, or could reasonably have resulted in, a catastrophic release; initiate investigations promptly, identify root and contributing causes, develop corrective actions with owners and due dates, communicate lessons learned, and retain investigation reports for the required period. | AGGIE SAFETY can evaluate incident investigation programs to ensure: - Incidents are documented within 48 hours - Root causes are identified - Corrective actions are defined and tracked - Reports are communicated to affected personnel - Records are retained for at least 5 years |
29 CFR 1910.119(m), 40 CFR 68.81(a)–(g) |
| 13 | Emergency Action & Response Plan | Establish and maintain an emergency action/response approach appropriate to the facility, including alarms and notification, evacuation/shelter procedures, response roles, coordination with local responders, training and drills as applicable, and ensuring emergency equipment and communications are available and functional. | AGGIE SAFETY can help develop or review emergency action and response plans that: - Define employee actions during releases/incidents - Coordinate with local responders - Cover evacuation, shelter-in-place, and communication procedures |
29 CFR 1910.38(a), 40 CFR 68.95 |
| 14 | Risk Management Plan (RMP) | Ensure that trade secret claims do not prevent employees, their representatives, or those performing PSM/RMP work from accessing the information necessary to comply with the standard; put confidentiality controls in place as needed while still providing full hazard and process information for safe operation. | AGGIE SAFETY can review and verify Risk Management Plans submitted to the EPA and their 5-year resubmissions, including: - Off-site consequence analysis and modeling - Impact assessment of toxic/flammable releases - Program documentation and updates |
40 CFR 68.36, 40 CFR 68.150, 40 CFR 68.15(a)–(c), 40 CFR 68.25 - RMP must be revalidated and resubmitted every 5 years |
Facilities in Houston that handle regulated substances above EPA threshold quantities must comply with the Risk Management Program rule under 40 CFR Part 68 — separate from, but often paired with, OSHA's Process Safety Management standard. Aggie Safety provides dedicated RMP support for Houston-area facilities, including:
RMP and PSM overlap significantly, but they aren't the same requirement — RMP is an EPA regulation focused on preventing and mitigating accidental chemical releases that could affect surrounding communities, while PSM is an OSHA standard focused on protecting employees. Houston facilities that trigger one often trigger both, and Aggie Safety supports Houston-area operations with full compliance across each independently or as a combined program.
Sumit was instrumental in helping us develop Process Management Safety Plans as well as Risk Management Plans for our facility. Sumit’s knowledge of the Code of Federal Regulations, as well as developing formats for our program, is insurmountable. I highly recommend Sumit and Aggie Safety to help you with your needs.
The professionals at Aggie Safety performed a requested OSHA-style walkthrough inspection of our facilities, highlighting our strengths and weaknesses. Their detailed inspection report gave us a tangible list of action items from which we could prioritize our efforts and elevate our entire HSE program. The walkthrough and debrief were just as much a coaching and advising activity as it was an inspection activity. We learned a great deal, reinforced some things we were already doing, and formulated a plan forward. Aggie Safety has a strong collaborative partnering aspect to advise and help clients, not simply inspect and grade. I’m confident we will build our relationship over time with more safety-related activities.
