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Risk Management Program, CalARP & ISO differences

In 1986, the California legislature passed Assembly Bill 3777 that established the Risk Management and Prevention Program. This program was a predecessor to the Federal EPA's and California's Accidental Release Prevention Programs. Similar programs were established in Delaware and New Jersey.

Congress established the Federal Accidental Release Prevention Program as part of the Clean Air Act Amendments in 1990. This created OSHA's Process Safety Management Program as well as the EPA's Accidental Release Prevention Program commonly referred to as the Risk Management Program. OSHA established regulations for Process Safety Management in 1992 and the EPA established regulations in 1996 for the Risk Management Program.

The EPA's Risk Management Program regulates facilities that have a greater than a threshold quantity of a regulated substance in a process. The regulated substances that are listed in the Risk Management Program include 77 toxic chemicals and 63 flammable substances. This program requires a facility to develop the following: a Hazard Assessment, Prevention Elements, a Management System, and an Emergency Response Program. The Hazard Assessment includes "worst case scenarios", "alternate release scenarios", and an accident history. The Prevention Elements are elements that are in place to prevent an accidental release, such as operating procedures, mechanical integrity, training, incident investigation, and managing change that may occur in the processes. The facilities are required to have a management system in place to ensure that all of the prevention elements are being implemented and a feedback process to improve on the different prevention elements. The facilities are required to have an emergency response program, including an emergency response plan. The facilities are required to develop and submit a Risk Management Plan that is a public document and that is submitted to the EPA.

California replaced the Risk Management and Prevention Program with the California Accidental Release Prevention (CalARP) Program on January 1, 1997. The CalARP Program is very similar to the EPA's Risk Management Program with the following differences:

  • The list of toxic chemicals is larger 276 vs. 77
  • The threshold quantities of the chemicals is smaller (e.g., chlorine federal threshold quantity is 2500 pounds vs. California's threshold quantity is 100 pounds)
  • Requires an external events analysis be performed, including a seismic analysis
  • More interaction with the public and agencies, including a Risk Management Plan

Contra Costa County established the Industrial Safety Ordinance in December 1998. The ordinance expands on the CalARP Program requirements. The facilities that are subject to the Industrial Safety Ordinance are in the unincorporated areas of the County, must be a chemical facility or a petroleum refinery and a Program Level 3 facility under the CalARP Program. The Industrial Safety Ordinance expands on the CalARP Program by requiring the following:

  • The whole facility is covered, not just process(es) that have a regulated substance over a threshold quantity
  • A Safety Plan, which is a public document, is required to be submitted to Contra Costa Health Services
  • A Human Factors Program is required for the following elements: Process Hazard Analysis, Operating Procedures, Incident Investigation, training employees on the basics of the human factors and on the facility's human factors program, and managing change to the emergency response and operations organizations
  • The facility is required to perform a root cause analysis as part of their incident investigations for Major Chemical Accidents or Releases and to submit a root cause analysis report to Contra Costa Health Services
  • The County can do their own incident investigation, including a root cause analysis
  • Inherently Safer Technologies and Systems are to be considered
  • Public Meetings are required

Six facilities are covered by the County's Industrial Safety Ordinance:

  • Phillips 66 Rodeo Refinery
  • Shell Oil Martinez Refinery
  • Tesoro Golden Eagle Refinery
  • Air Products at Shell Refinery
  • Air Products at Tesoro Refinery
  • Air Liquide - Rodeo Hydrogen Plant

Two facilities are covered by the City of Richmond's Industrial Safety Ordinance:

  • Chevron Richmond Refinery
  • Chemtrade West Richmond Works