Chemical Accident Prevention Program (CAPP) - Program Guidance

This site is in its initial development phase. Information that has been published to date is posted. Ultimately, there will be three sections to this guidance: the Program Audit Checklists, the Program Audit Data Forms, and Program Audit Examples. Currently, select audit checklists and data forms are available.

Program Audit Checklists

The audit checklists provide detailed criteria that is used by CAPP inspectors to determine compliance with each of the prevention program and emergency response program elements. With the exception of checklist number I, these checklists are patterned after OSHA's Compliance Directive CPL 2-2.45A, used for conducting Process Safety Management audits. Checklist number I is completed by the CAPP inspector upon each compliance audit and is intended to cover numerous state program issues and to facilitate followup to previous open inspection issues.

The remaining checklists are comprised of three parts: Records / Audit Review, On-Site Inspection and Interviews. Under the Records / Audit Review, inspectors focus upon development of policies, procedures and programs associated with each of the program elements. Under the On-Site Inspection, inspectors focus upon implementation of the program element. Inspectors will look for evidence that the policies, procedures and programs are in place in the plant and that records are being maintained. Under the Interview, inspectors focus again, upon element implementation and upon employee understanding of the program element. Inspectors look to validate the records reviewed under the On-Site Inspection portion of the checklist.

The checklists are intended to be comprehensive. CAPP inspectors do not review each checklist annually, but attempt to review each checklist at least once every five years, with two exceptions. Management of Change and Incident Investigation records are reviewed annually.

Compliance Audits
Contractors
Emergency Action Plan
Emergency Response Plan
Employee Participation
Facility & Substance Information
Incident Investigation
Initial Inspection
Management Of Change (MOC)
Pre-Startup Safety Review (PSSR)
Preventive Maintenance/Mechanical Integrity
Process Hazards Analysis (PHA)
Process Safety Information (PSI)
Standard Operating Procedures (SOP's)
Training

Program Audit Data Forms

The audit data forms are used by CAPP inspectors to help structure various program data, thus facilitating review. Frequently, the inspectors ask the facility to complete these forms in advance of an inspection.

Compliance Audits
Contractors
Emergency Action Plan
Emergency Response Plan
Employee Participation
Incident Investigation
Management Of Change (MOC)
Pre-Startup Safety Review (PSSR)
Preventive Maintenance/Mechanical Integrity
Process Hazards Analysis (PHA)
Process Safety Information (PSI)
Standard Operating Procedures (SOP's)
Training