Program Determination and Elements of the Programs
TABLE 1 – PROGRAM LEVEL DETERMINATION
EPA RMP and CalARP Program Eligibility
Program 1
Program 2
Program 3
No offsite accident history
No public sensitive receptors in worst-case circle
Emergency response coordinated with local responders
The process is not eligible for Program 1 or 3
Process is subject to OSHA PSM
Process is in SIC code 2611, 2812, 2819, 2821, 2865, 2869, 2873, 2879, or 2911.
TABLE 2 - COMPARISON OF PROGRAM REQUIREMENTS
CalARP/EPA RMP Program 1
CalARP/EPA RMP PROGRAM 2
CalARP/EPA RMP Program 3
Hazard Assessment:
Worst-case analysis
Document nearest public receptor is beyond the distance to a toxic or flammable endpoint defined in Section 2750.2(a)
5-year accident history
Hazard Assessment:
Worst-case analysis
Alternative releases
5-year accident history
Hazard Assessment:
Worst-case analysis
Alternative releases
5-year accident history
Management Program:
Not Applicable
Management Program:
Document management system
Management Program:
Document management system
Prevention Program:
Certify no additional steps needed
Prevention Program:
Safety Information
Hazard Review
Operating Procedures
Training
Maintenance
Compliance Audits
Incident Investigation
OSHA PSM & EPA RMP/CalARP Prevention Program:
Process Safety Information
Process Hazard Analysis
Operating Procedures
Training
Mechanical Integrity
Management of Change
Pre-startup Safety Review
Compliance Audits
Incident Investigation
Employee Participation
Hot Work Permits
Contractors
Emergency Response Program:
Coordinate with local responders
Emergency Response Program:
Determine emergency response program applicability
Develop plan and program
Emergency Response Program:
Determine emergency response program applicability
Develop plan and program
Risk Management Plan Contents
Executive Summary
Registration
Worst-case data
5-year accident history
Certification
Risk Management Plan Contents
Executive Summary
Registration
Worst-case data
Alternative release data
5-year accident history
Prevention program data
Emergency response data
Certification
Risk Management Plan Contents
Executive Summary
Registration
Worst-case data
Alternative release data
5-year accident history
Prevention program data
Emergency response data
Certification
TABLE 3 – CalARP/ RMP/ PSM / Cal OSHA Program Overlap Compliance Matrix
