(142b) PSM/RMP Modernization Programs in California - 2016 Developments and Correlation to Evolution at the Federal Level

Paper 441463, presented at the 2016 Global Congress on Process Safety, provided a snapshot of the significant changes being made to the PSM/RMP Regulatory Framework in California and at the federal level. Post-publication, additional changes have been proposed by Cal/OSHA (July 2016), CalEPA/CalOES (July 2016), and U.S. EPA (March 2016). Cal/OSHA's requirements will include a separate PSM regulation focused on petroleum refineries, and CalEPA/CalOES requirements will introduce a new program level (Program 4), initially applying to petroleum refineries. These two California requirements are very similar, and differences will be identified in the paper. The proposed changes to the U.S. EPA's Risk Management Program (RMP) Rule are distinct from the California requirements, but apply to a wider range of facilities.

The final language for both of these new California petroleum refinery requirements is anticipated in late-2016, and promulgation is anticipated for Spring/Summer 2017. 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-2017 is important 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 March 2017 time frame, and key topics include:
- Background - Pre-2012 PSM/RMP Universe
- Brief Overview of Key Safety Management System Program Modernization Initiatives, Focused on 2016 Changes
- Key Elements of the Various SMS Regulatory Initiatives
- SMS Modernization Status and Potential SMS Program Impact
- What Should I Be Doing Now?