PSM ● RMP ● CalARPRegulatory Framework Update & Implementation Strategies

Jordan M. Schultz &Steven T. Maher, PE CSP

Risk Management ProfessionalsU.S. (877) 532-0806 ♦ www.RMPCorp.com

Key Topics• Catalyst for Change / Refinery Focus• Addressing Key Elements of CalARP

& CalPSM-R Regulatory Expansion/Modernization Efforts (with Implementation Tips)

• General ImplementationStrategies &Resources

Catalyst for Change /Refinery Focus

Key CSB Recommendations• From CSB 17Apr13 Interim Investigation Report –

Recommendation Series 2012-03-I– Additional PHA Requirements Regarding Safeguards &

Effectiveness (CA-3, CA-6, CA-12)– Additional Inherently Safer Systems Requirements (CA-4,

CA-7, CA-13)– Damage Mechanism Hazard Reviews for Refineries (CA-1,

CA-5, CA-8, CA-9, CA-14, CA-15)– Joint/Coordinated Regulatory Programs (CA-16, CA-17, CA-

18, CA-19, CA-20)– Reporting of Leading and Lagging Process Safety Indicators

(CA-2, CA-10)– Establishment of a Multi-Agency Process Safety Regulatory

Program for all California Oil Refineries (CA-11)

Key CSB Recommendations• From CSB 10Nov14 Final “Regulatory Report –

Chevron Richmond Refinery Pipe Rupture and Fire” –Recommendation Series 2012-03-I– Restructure California PSM Regulations (CA-R21)

• Augment PHA:HCA/ISSDMRMOC Trigger of ISS Analysis

• Technically-Competent Regulatory Personnel PHA Review

• PHA Audits/Inspections by Regulator• Minimum Requirements for Codes & Standards Utilized• Workforce Participation• Reporting of Information to the Public• Implementation of New/Improved Industry Standards &

Practices• Regulator Funding

Key CSB Recommendations

• From CSB 10Nov14 Final “Regulatory Report –Chevron Richmond Refinery Pipe Rupture and Fire” – Recommendation Series 2012-03-I– Monitor and Analyze Leading and Lagging

Process Safety Indicators (CA-R23)– Regulator Compensation/Funding (CA-R22, CA-

R24, CA-R25)

Key CSB Recommendations• From CSB 28Jan15 “Final Investigation Report” –

Chevron Richmond Refinery Pipe Rupture and Fire” – Recommendation Series 2012-03-I– Updates to API Standards/Guidelines to Address

Sulfidation Corrosion and Increased Susceptibility of Low-Silicon Carbon Steel (CA-R26, CA-R27, CA-R28, CA-R29, CA-R30)

• Standards/Guidelines API RP 939-C, “Guidelines for Avoiding Sulfidation

(Sulfidic) Corrosion Failures in Oil Refineries” (CA-R26) API RP 571, “Damage Mechanisms Affecting Fixed

Equipment in the Refining Industry” (CA-R27) API 570, “Piping Inspection Code: In-service Inspection,

Rating, Repair, and Alteration of Piping Systems” (CA-R28)

API RP 578, “Material Verification Program for New and Existing Alloy Piping Systems” (CA-R29)

API RP 574, “Inspection Practices for Piping System Components” (CA-R30)

Key CSB Recommendations

• Focal PointsDescribe Low-Silicon Carbon Steel Sensitivity to

Sulfidation Corrosion and Locations of Enhanced Sensitivity

Terminology Improvements Identify Low-Silicon Carbon Steel Piping CircuitsFor Low-Silicon Carbon Steel Piping Circuits –

100% Inspection, or Replacement with a Steel Alloy More Resistant to Sulfidation Corrosion

If Accelerated Corrosion Identified, Designate as Condition Monitoring Locations (CMLs)

Cross-Reference API Standards and Guidelines, Including Leak Response Protocols Established in API RP 2001

Key CSB Recommendations• Additional Recommendations

– Revise API RP 2001, “Fire Protection in Refineries,” to Require Development of a Process Fluid Leak Response Protocol (CA-R31)

• Establish IC Structure• Conduct a Pre-Response Meeting• Establish a Hot Zone & Limit Site Access Around Leak

Location• Isolation and Shutdown Protocol

– Revise ASME PCC-2-2011, “Repair of Pressure Equipment and Piping,” to Require Adherence to API RP 2001 for Process Fluid Leaks (CA-R32)

– Increased Accountability at Chevron for Adherence to Industry Guidance and Best Practices (CA-R33)

Key CSB Recommendations– Develop an Auditable Review Process at Chevron for

Validating the Acceptability of Any Deferred Turnaround Actions Addressing Mechanical Integrity Deficiencies (CA-R34)

– Develop an Approval Process at Chevron for Resetting the Minimum Alert Thickness to a Lower Value (CA-R35)

– For Richmond and Contra Costa County, Require a “Process Safety Culture Continuous Improvement Program” with an Oversight Committee Composed of Regulatory, Company, Workforce Representatives, and Community (CA-R36, CA-R37) – Oversight Committee to:

• Select a Third-Party to Administer a Periodic Survey• Review/Comment on Survey Report• Oversee Development/Implementation of Survey Action Items• Develop Process Safety Culture Indicators

Key CA Interagency Refinery Task Force (IRTF) Recommendations

• Reference – "Improving Public and Worker Safety at Oil Refineries – Report of the Interagency Working Group on Refinery Safety," California, February 2014 – Key Actions:

• Establishment of an Interagency Refinery Task Force

• Agency Emergency Response and Preparedness• CalARP and PSM Program Refinery Requirements

– Implement Inherently Safer Systems– Perform Periodic Safety Culture Assessments– Conduct Damage Mechanism Hazard Reviews– Root Cause Analysis after Significant Accidents or

Releases– Explicitly Account for Human Factors– Structured Methods to Ensure Safeguards in Process

Hazard Analysis

Key CA Interagency Refinery Task Force (IRTF) Recommendations

• CalARP Program Refinery Requirements– Annual Compliance Audits– Increased Frequency of CUPA Inspections– Triennial Independent Evaluation of Each

Refinery’s Risk Management Plan• Agency Enforcement Capacity and Reporting

for Refineries• Community Education and Alerts • Recommendations for Further Study

– Process Safety Leading and Lagging Indicators– Worker and Community Involvement– Safety Case Approach

Addressing Key Elements of CalARP & CalPSM-R Regulatory

Expansion/Modernization Efforts (with

Implementation Tips)

Key Changes for theOil & Gas Industry

• Regulatory Updates: – Fed/OSHA PSM

• Processing Comments (Comment Period ended 31Mar2014)

– U.S. EPA RMP• Processing Comments (Comment Period ended

29Oct2014)– Cal/OSHA

• PSM for Petroleum Refineries (CalPSM-R, 8 CCR §5189.1)• 24Sep15 – Latest Draft

– CalARP• January 1, 2015 – Minor amendments implemented• Program 4 requirements in response to CalPSM-R,

Interagency Refinery Task Force (IRTF) Recommendations, and CSB Recommendations from the 06Aug12 Richmond Refinery Fire

• 24Sep15 – Latest Draft

Impact Categories

• Following table follows 5189.1 Draft Regulation Table of Contents

• Three Main Categories* indicates minimal changes to regulation or minimal effort needed for compliance** indicates moderate changes to regulation or moderate effort needed for compliance*** indicates new element or significant effort needed for compliance

Current Cal/OSHA & CalARP InitiativesProgram Element Cal/OSHA

(Draft)CalARP (Draft)

Process Safety Information (PSI) * 5189.1(d) 2762.1

Process Hazard Analysis (PHA) *Safeguard Protection Analysis (SPA) *** 5189.1(e) 2762.2

2762.2.1

Operating Procedures (OP) ** 5189.1(f) 2762.3

Training * 5189.1(g) 2762.4

Contractors (CON) * 5189.1(h) 2762.12Pre-Startup Safety Review (PSSR) * 5189.1(i) 2762.7

Mechanical Integrity (MI) **Damage Mechanism Review (DMR) ***

5189.(j)5189.1(k)

2762.5

Hierarchy of Hazard Control Analysis (HCA) *** 5189.1(l) 2762.13

Hot Work * 5189.1(m) 2762.11

Management of Change (MOC) ** 5189.1(n) 2762.6

Incident Investigation – Root Cause Analysis (II-RCA) ** 5189.1(o) 2762.9

Emergency Planning and Response * 5189.1(p) 2765.2

Employee Participation (EP) ** 5189.1(q) 2762.10

Process Safety Culture Assessment (PSCA) *** 5189.1(r) 2762.14

Human Factors *** 5189.1(s) 2762.15

Management of Organizational Change (MOOC) *** 5189.1(t) 2762.6

Compliance Audits (CA) * 5189.1(u) 2762.8

Management Program *** 5189.1(v) 2762.16

Operating Procedures(CalPSM-R §5189.1(f), CalARP §2762.3)

• Develop and implement effective written procedures

• Procedures shall address:– Same operating phases as listed in current

recommendations (Start-up, Shutdown, Normal Operation, etc.)

• Emergency shutdown must include conditions, provisions on authority to shut down the operation, assignment of responsibilities

• Emergency operations - only qualified operators may initiate operations and prior to allowing other employees in the vicinity:

– Shut down and depressurize operations in the leak area– Isolate the vessel/piping – Alternative procedures may be implemented if employer

can demonstrate an equivalent level of protection

Operating Procedures(continued)

• Procedures shall address (cont.):– Operating limits

• Consequences of deviation• Steps required to correct and/or avoid

deviation(s)– Safety and health considerations

• Properties and hazards of chemical(s)• Precautions (passive, active, and procedural

safeguards; PPE)• Protective measures• Safety procedures for opening process unit• Verification of composition and inventory levels• Special or unique hazards

– Safety systems and their functions

Operating Procedures(continued)

• Copy of procedures shall be readily accessible• Procedures shall be reviewed and

updated/certified:– As often as necessary– When changes occur (MOC or otherwise)– Annually

• Develop, implement, and maintain safe work practices to prevent or control hazards– Opening process equipment– LOTO– Confined space– Handling, controlling, and stopping leaks, spills,

releases and discharges– Control over entry into hazardous work areas by

maintenance, contractor, laboratory or other support personnel

Employee Participation(CalPSM-R §5189.1(q), CalARP §2762.10)

• Written plan shall provide:– Effective participation of operating &

maintenance employees/representatives:• To conduct PHAs, DMRs, HCAs, MOCs,

MOOCs, PSCAs, Incident Investigations, SPAs, & PSSRs

• Throughout all phases of development, training, implementation and maintenance of PSM elements

– Access to all documents or information developed or collected, including trade secret

– Employees/representatives shall be chosen to participate in overall PSM program development and implementation planning

Employee Participation(continued)

• Establish a Stop Work Authority [CalARP §2762.15(f)]– All employees may refuse work based on safety/health

concerns – All employees may recommend to the operator in charge

of the unit to implement a shutdown due to safety/health concerns

– Operator in charge of the unit may shut down an operation or process due to safety/health concerns.

• Implement an effective hazard reporting program [CalARP §2762.15(g)]– All employees may anonymously report hazards in

writing– Requires the employer to respond in writing within 30

days (immediately if there is potential for death/serious harm)

– Employer must effectively document work refusals, reports of safety/health hazards, shutdown recommendations, and actual shutdowns.

Management System(CalPSM-R §5189.1(v), CalARP §2762.16)

• Reviewed and updated at least every 3 years– Develop annual goals to achieve continuous

improvement in all subsections– Written PSM Policies and Procedures– Track & document all changes to program– Develop, implement & maintain program to track

and document Process Safety Performance Indicators

– Annual report/certification containing information on all process safety performance indicators (PSPIs) for previous year

• CalARP – Stop Work Authority and Hazard Reporting

Management System: PSPIs

• Process Safety Performance Indicators (PSPIs)– From CSB 10Nov14 Final Report

• Monitor and Analyze Process Safety Indicators (CA-R23)

– Common PSPIs: Annual reporting begins 01/01/2017 • Past due inspections of process piping & components;• Past due inspections of pressure vessels;• Past due recommendation actions; • Each leak seal repair on utility systems and date(s) installed; • Number of major incidents that occurred in each calendar year.

– CalOES to place PSPIs on public website• Same indicators (past due items & repairs), and monthly

reporting/update as CalPSM-R

– Program 4 Indicators: Develop site-specific list• Annual report/certification by January 31 for the previous year• CCPS Process Safety Metrics and API RP 754

PHA-Related & MI-Related Elements

PHA MI

SPADMR

HCA

Process Hazard Analysis (PHA)(CalPSM-R §5189.1(e), CalARP §2762.2)

• 2762.05(b) – “All portions of the petroleum refinery are covered except” laboratories and low-hazard utilities.

• PHA must address:– DMRs and their recommendations– HCAs and their recommendations– External events– Incident investigation findings

• The Iterative HCA Method must be applied “for all PHA recommendations that result from a scenario that identifies the potential for a major incident.”

PHA Requirements(continued)

• Recommendation closure process & timing clarified:– Not requiring a process shutdown – within 30 months– Requiring a process shutdown – next scheduled

turnaround– Potential for death/serious physical harm – immediately

• PHAs must be retained for the life of the process.– Includes recommendations and their documented

resolutions• All new (i.e., not previously required) PHAs must be

completed within 3 years of CalARP/CalPSM-R promulgation.

Safeguard Protection Analysis (SPA)(CalPSM-R §5189.1(e), CalARP §2762.2.1)

• Objectives:– Assess the effectiveness of existing and combined safeguards for

each failure scenario identified in the PHA– Assure that safeguards are independent of the initiating event and

each other

• Evaluate:– Passive, Active, or Procedural Safeguards– Using LOPA or “equally effective method”

• Risk reductions achieved by existing safeguards and safeguards recommended in a PHA must be documented.

• Conduct SPA and complete report within 6 months of finalizing a PHA.

• The SPA report can be standalone or part of PHA.• SPA reports must be retained for the life of the process.

SPA Implementation Tips

• Challenges– “Blending Issues” is Human Nature– Common-Mode Failures Between Causes &

Safeguards– Over-crediting Operator Response Reliability

• Practical Implementation Guidance– Identify Root Transmitters for Causes & Safeguards– Facilitator to Frequently Train the Team on Risk-

Ranking– Facilitator to Frequently Challenge the Team on

Safeguard Effectiveness, Availability, & Reliability– Partition Safeguards as IPLs– Typically Group Alarms as a Single Safeguard– Apply Risk-Graph & LOPA to Provide Additional Insights– Apply Risk-Graph & LOPA for High Consequence/Risk

Scenarios to Validate that a SIF is Not Needed

SPA Implementation Tips

• More Tips – Operator Response to Alarms –Reliability & Timing– Present to Hear the Alarm– Alarm Prioritization & Diagnosis– Permission for Corrective Action– Initiating the Corrective Action– Time for the Corrective Action to Mitigate the Event

• Actions Prior to CalARP & CalPSM-RPromulgation– SPA is effectively addressed by implementation of

best PHA practices.– Implement best PHA practices.

Mechanical Integrity (MI)(CalPSM-R §5189.1(j), CalARP §2762.5)

• No discontinuities with current industry best practices

• Minimal substantive changes• Clear instructions for safely conducting maintenance

activities to be included in Mechanical Integrity Procedures

• Additional specificity on required documentation• Clarification of records retention• Additional specificity on availability of Mechanical

Integrity Procedures and inspection documents• Additional cross-referencing to Process Safety

Information • Addition of references to RAGAGEP• For CalARP, DMR is located in 2762.5(f)

• Damage Mechanisms – mechanical, chemical, physical or other process that results in equipment or material degradation

• Damage Mechanism Review (DMR) Timing:– Prior to any PHA and prior to changes affecting

chemistry, metallurgy, or operating limits– Initial to take place at the earliest of the following:

• Initial DMR within 5 years (50% within 3 years of CalARP/CalPSM-R promulgation)

• Revalidated every 5 years or prior to a major change• Reviewed as part of an incident investigation

Damage Mechanism Review (DMR)(CalPSM-R §5189.1(k), CalARP §2762.5(f))

• At minimum, evaluate the following:– Mechanical Loading Failure – Ductile fracture, brittle

fracture, buckling, mechanical fatigue– Erosion – Abrasive wear, adhesive wear, fretting– Corrosion – Uniform corrosion, localized corrosion,

pitting– Thermal-Related Failure – Creep, thermal fatigue,

transformation – Cracking – Stress-corrosion cracking– Embrittlement – High Temperature

Hydrogen Attack (HTHA)• DMR reports must be retained

for the life of the process.

DMR Requirements(continued)

DMR Implementation Spectrum

EnhancedContemporary

BestPractices

PrioritizedDMR

ApproachiPHA

Less Effort Increased Effort, with Increased Insights

MI-CenteredRisk-BasedAssessment

DMR Implementation Tips

• Challenges– Ensure Regulatory Requirements are Met– Effective Use of Facility Resources– Minimizing Overlap with Other SMS Program

Elements– Maximizing Use of Efforts Completed for Other

SMS Elements

DMR Implementation Tips• Suggested Approaches

– Maintain your current SMS HAZOP/MI activities.– Initiate high-value DMR activities in the form of a Prioritized

DMR.– Apply quantitative risk techniques (e.g., API RP 581)

selectively.– Address high priority improvements and potential

vulnerabilities.– Initiate transition of SMS HAZOP/MI Program to maintain

progress towards long-term DMR objectives.– A Prioritized DMR is a minor increment to current PHA & MI

efforts, is easily expanded, and is expected to satisfy DMR objectives.

– Suggested actions Prior to CalARP &CalPSM-R Promulgation

• Migrate towards Prioritized DMR.• Evaluate need for more detailed analysis.

HCA(CalPSM-R §5189.1(l), CalARP §2762.13)

• Hierarchy of Hazard Control Analysis (HCA) – ranking of prevention and control measures prioritized as follows: – 1st Order Inherent Safety (e.g., safer chemicals) – prevents

incident– 2nd Order Inherent Safety (e.g., inventory reduction, lower

temperature) – reduces severity/likelihood of incident– Independent Protection Layer (IPL) – Safeguards (passive, active,

or procedural) • Conduct the HCA for:

– All existing processes (50% within 3 years and all within 5 years of CalARP/CalPSM-R promulgation), with a 5-year revalidation

– PHA recommendations addressing a “major incident potential”– Major changes (as part of MOC)– Major incidents– New processes (including making the HCA available to the public)– At the request of UPA

HCA Requirements(continued)

• Objective – “To reduce each risk to the greatest extent feasible”, Owner/Operator shall identify and evaluate all relevant inherent safety measures, e.g.:

• Control techniques or management systems that have been achieved in practice for petroleum refining or related industrial sectors

• Control techniques or management systems that have been required or recommended for petroleum refining and related industrial sectors

• Approach – Iterative HCA Method defined in 5189.1(z)

• Outcome – Employer shall “select and recommend” 1st & 2nd Order Inherent Safety Measures, unless documented as infeasible and the proposed alternatives are justified.

• Requirement for HCA to be a standalone analysis• Report to be completed within 90 days of HCA

completion

HCA Implementation Tips

• Effective Implementation– Briefing During PHA Synchronization Training– List of ISD Considerations in the PHA Quick

Reference:• Minimize• Substitute• Moderate• Simplify – More Robust• Simplify – Human Factors• Simplify – Facility Siting

– Document Inherently Safer SystemsReview as Separate Node

– Checklist for ISS Review onwww.CSB.gov and fromCCPS Guidebook

HCA Implementation Tips

• Timing– As Early As Possible During the Design Phase –

Minimize Capital Costs– As Early As Possible During Plant Operation –

Minimize Costs by Addressing Needs during Unit Turnarounds

• Actions Prior to CalARP & CalPSM-R Promulgation– Apply ISS checklists during PHA.– Ensure that technological advances are

discussed/considered during PHA.– Ensure that use of different metallurgy

is considered during Prioritized DMR.

HCA Implementation References

• Textbooks– CCPS Guidelines for Risk Based Process Safety– Inherently Safer Chemical Processes: A Life Cycle

Approach– Process Plants: A Handbook for Inherently Safer

Design– CCPS Guidelines for Engineering Design for Process

Safety• Regulatory Guidance/Requirements

– Contra Costa County HSD– NJ Toxic Catastrophe Prevention Act (TCPA)

• Checklists– Available Within Textbooks & Regulatory Guidance

Documents

Management of Organizational Change (CalPSM-R §5189.1(t), CalARP §2762.6(i))

• Include MOOC assessment to address:– Experience levels of employees before and after the proposed

change– Describe the change, team make-up, team rationale, and

actions required to make the change• Ensure job functions are up-to-date and accurate for

all affected positions• Document the following:

– Results of analysis– Team make up– What factors were considered– Decision to implement the change or not– Basis for decision– Necessary actions required to move forward with the change

• Shall include Human Factors analysis• Employees potentially affected by change shall be

given information prior to implementation

Human Factors(CalPSM-R §5189.1(s), CalARP §2762.16)

• Develop, implement & maintain written program• Program should evaluate:

– Staffing levels– Complexity of and length of time needed to complete

tasks– Level of training and expertise of employees– Human-machine interface and human-system interface – Physical challenges of the work environment – Employee fatigue and shiftwork/overtime – Communications– Understandability and clarity of SOPs and Maintenance

Procedures• Analysis of human factor controls on process

equipment in incident investigation, PHAs, MOOCs, SPA, or HCAs (e.g., error proof mechanisms, automatic alerts, automatic system shutdowns for critical operational errors)

Human Factors(continued)

• Assess human factors in new SOPs and maintenance procedures

• Assess human factors in existing SOPs and maintenance procedures– Revise procedures accordingly– 50% assessment complete within 2 years (following

effective date of regulation)– 100% assessment complete within 3 years

(following effective date of regulation)• Provide training to operations and

maintenance personnel• Ensure employee/representation in the

development, implementation, and maintenance of the Human Factors Program

Incident Investigation (CalPSM-R §5189.1(o), CalARP §2762.9)• Incident Investigation – Root Cause Analysis

– Implement an effective Root Cause Analysis (RCA)• Team must include a person with RCA expertise and

oversight– Team must investigate underlying management

system causes (including organizational and safety culture)

– Review results of HCA and DMR as part of II – Conduct DMR, PHA, HCA, and SPA (demonstrate if

an analysis is not applicable)– Developing recommendations – conduct DMR, PHA,

HCA, and SPA. Recommendations have same implementation requirements as PHA.

– Timelines: • Assemble Team within 48 hours• Initial Report within 90 days• Final Report within 6 months

Process Safety Culture Assessment (PSCA) (CalPSM-R §2762.14, CalARP

§2762.14)• PSCA Program should address:

– Encouragement for reporting safety concerns– Rewards do not deter reporting safety concerns– Ensure safety is not compromised by production – Process Safety Leadership at all levels – Human Factors Program to be included for all

PSM elements• Written PSCA Program should include:

– Methods used to assess PSC – Conclusions from the PSCA– Rationale of the conclusions– Recommendations and action plan from PSCA– Report to be completed within 90 days of PSCA

end • Signed off by refinery manager

New Regulatory Updates• From OSHA

– Interpretation Letters (June-July 2015):• RAGAGEP Enforcement

– Guidance on how to document RAGAGEP• Retail Exemption

– If the facility does not fall under SIC 44 or 45, it is not eligible for the exemption

– Enforcement begins mid-July 2016 (12 months)• Covered Concentration

– Uses EPA’s 1% policy, rather than “commercial grade”

• Other Enforcement/Interpretation Letters are reported to follow

New Regulatory Updates

• From California:– SB-612:

• UPA General Duty Clause• New mapping requirements• Other changes to UPA Programs for UST/AST,

SPCC, hazardous waste• http://leginfo.legislature.ca.gov/faces/billNavClien

t.xhtml?bill_id=201520160SB612

General ImplementationStrategies & Resources

Overlap of Post-2016 CA SMS Programs (Onshore Petroleum Refineries)

Fed-RMP CalPSM-R (5189.1)

CalARP

EP

PSI PHA

OP

TRN

MIMOC

PSCA

II

EPR

HW

CON

HA

CA

DMRHCA

RCA

Schedule & Other “Minor”

Differences

HF

MOOC

PSMP

PSSR

Schedule & Other “Minor”

Differences

Resources for Handling Evolving Requirements

• HAZOP/LOPA Facilitation Webinar Series (Module 10) – Effective approaches to handling CSB recommendations and PSM and CalARP changes

– DMR– SPA– Inherently Safer Systems/Design (i.e., HCA)

• 2015 Global Congress on Process Safety – Papers– Maher, Nour, Schultz, “Effectively Addressing New PSM/RMP Damage Mechanism

Review Requirements with an Integrated PHA (iPHA)”– Maher, Schultz, “Changes in the PSM/RMP Regulatory Framework (California and

National)”• Webinars – Updates on the PSM/RMP Regulatory Modernization Programs

– 19Aug14– 25Sep14– 22Jan15– 09Apr15– 25Jun15– 30Jul15– 27Aug15

• Webinar – DMR and the Integrated PHA (iPHA) Approach – 26Mar15

• Links are provided on www.RMPCorp.com/SMS_Regulatory_Updates/

Summary & Conclusion

• Agencies have taken a fresh look at SMS Programs.• Current focus is California and Refineries.• Potential For:

– Later expansion to other highly-hazardous facilities in California

– Later expansion to non-California petroleum refineries & others

– Inference to new requirements as best practice– General Duty Clause Correlation – SB 612 clarifies

Owner/Operator responsibilities.• Initial promulgation will not be synchronized with federal

requirements, but plan to harmonize CalARP & CalPSM-R.• Potential for long-term movement

towards synchronization.• There are “easy“ steps to take now to

infuse some of the new requirementsinto your PSM/RMP/CalARP activities.

Summary & Conclusion

• Recommendation from a Key Regulator – Begin Applying “High-Value/Priority” Elements of CalPSM-R Now – Once promulgated, “schedule will be tight,” and if substantial progress has been made, selective-”grandfathering” may be allowed.

• Tight schedules could result in a resource shortage.• In addition, some elements (e.g., HCA) are significantly

more cost-effective in the design-phase, or at the earliest possible opportunity.

• Risk Management & Process Safety Professionals should:– Carefully monitor modernization programs.– Focus on charting the course for the

long-term success of your facility’s programs.– Develop a strategy for effective

implementation.

Jordan M. SchultzJordan.Schultz@RMPCorp.com

Steven T. Maher, PE CSPSteve.Maher@RMPCorp.com

(949) 282-0123(877) 532-0806

www.RMPCorp.com

Questions?