Changes in the PSM/RMP Regulatory Framework – California and National

Since August 2012, significant changes have been proposed by a number of agencies to Safety Management Systems Programs, e.g., Process Safety Management (PSM), Risk Management Programs (RMP), and related programs.  Many of these are framed within OSHA's and EPA's PSM/RMP Modernization/Expansion Programs, and key technical and regulatory changes are being proposed by Federal OSHA, U.S. EPA, Chemical Safety Board (CSB), California Office of Emergency Services (OES), and other agencies.  In addition, on 10Sep14, Cal/OSHA issued its proposed regulation for "Process Safety Management for Refineries" in response to a report from the California Interagency Working Group on Refinery Safety.

Although the implementation of these new requirements may appear quite ominous, due to the large degree of overlap of the proposed requirements between the programs, one can develop strategies for effective implementation.

The focus of this paper will be to provide tips for addressing key technical and regulatory challenges, as well as providing the reader with an overview of these proposed requirements and a reference "roadmap" for effective implementation.  Key topics include:
 - Overview of Various Safety Management System Program Modernization Initiatives
 - Key Elements of the Various Initiatives
 - Potential Impact on Your PSM/RMP Programs
 - Tips for Managing Your Current Efforts in the Face of These Changes