39138 Road 56

Dinuba, CA 93618

Tel. (559) 591-8874

Fax. (559) 591-8896

CLN 481142

Risk Management and Process Safety Management

We have assisted many of our customers in establishing and maintaining Risk & Process Safety Management Programs (RMP) that comply with:

• Federal RMP - CFR, Title 40, Ch. 1, Part 68

• CalARP - CCR, Title 19, Division 2, Chapter 4.5

• Federal OSHA PSM - CFR, Title 29, Subtitle B, Ch. 17, §1910.119

• Cal OSHA PSM - CCR, Title 8, Division 1, Ch. 4, Subchapter 7, Group 16, Article 109, §5189

In order to understand the Risk & Process Safety Management Regulations, it is necessary to briefly compare and contrast the EPA’s Risk Management Program (RMP) versus OSHA’s Process Safety Management (PSM) Program. The EPA’s RMP and OSHA’s PSM program are very similar, but not identical.  In general, the EPA’s focus is the environment, while OSHA’s focus is the employee.  To confuse matters worse, Cal EPA has more stringent regulations (CalARP) than Fed EPA (Rule 40 CFR 68).  CalARP has three (3) different program levels.  Program 3, is the most stringent and applies to facilities containing more than the federal threshold of10,000 lbs of ammonia.  Program 2 applies to facilities with greater than CalARP threshold of 500 lbs of ammonia, but less than 10,000 lbs.  Program 1 covers facilities that have more than 500 lbs of ammonia, but less than 10,000 lbs and no public receptors within their worst case toxic endpoint.  OSHA’s PSM has a single threshold of 10,000 lbs of ammonia.  Consequently, OSHA’s PSM and CalARP's Program 3 RMP are nearly identical.  Be aware that the penalty for not complying with these laws can be up to $25,000 per day of violation.

The table below summarizes the differences between Programs 1-3.