Paper 396953, presented at the 2015 Global Congress on Process Safety, provided a snapshot of "Changes in the PSM/RMP Regulatory Framework (California and National)". Post-publication, additional significant changes have been proposed by the agencies involved in the previous initiatives. On May 26, 2015, Cal/OSHA issued a comprehensive update to its proposed regulation for "Process Safety Management for Refineries," and CalEPA/CalOES issued an update to the California Accidental Release Prevention (CalARP) Program, creating a new program level "Program 4" that applies only to petroleum refineries. Both of these regulations coalesced as part of an overall initiative resulting from the efforts of the California Interagency Refinery Task Force. Subsequently, on September 24, Cal/OSHA made some minor changes and released its updated "PSM for Refineries" for public comment.
The final language for both of these new California petroleum refinery requirements is anticipated by December 2015, and promulgation is anticipated for Summer 2016. In parallel, Federal OSHA and U.S. EPA are creating updates to Process Safety Management (PSM) and Risk Management Plan (RMP) requirements as part of the PSM/RMP Modernization/Expansion Programs designed to address significant accidents that occurred in the past few years.
The changes being proposed for these programs are extensive, currently being formulated, and are not synchronized between the various agencies. The focus of this paper will be to provide relevant background information, a summary of the proposed changes, and tips for addressing key technical and regulatory challenges, as well as providing the reader with a "roadmap" for effective implementation.
The timing of GCPS-2016 is ideal for unveiling the final regulatory requirements in California and for identifying strategies for addressing these desynchronized requirements. The content of this paper will be important to communicate to GCPS attendees in the April 2016 time frame, and key topics include:
- Background – Pre-2012 PSM/RMP Universe
- Overview of Key Safety Management System Program Modernization Initiatives
- Key Elements of the Various SMS Regulatory Initiatives
- SMS Modernization Status and Potential SMS Program Impact
- What Should I Be Doing Now?