(54br) October 1, 2017 – Paradigm Shift in PSM/Calarp Requirements for California Refineries – What Are the Requirements and What Does Management Need to Know?

Paper 479475, presented at the 2017 Global Congress on Process Safety, provided a snapshot of the significant changes being made to the PSM/RMP Regulatory Framework in California and the beginnings of a rescheduling and reprioritization of federal PSM/RMP initiatives. Post-publication, State-PSM and State-RMP (CalARP) requirements applicable to California refineries were finalized and made effective on October 1, 2017. Cal/OSHA's requirements are driven by a separate PSM regulation focused on petroleum refineries, and CalEPA/CalOES requirements include a new program level (Program 4), initially applying primarily to petroleum refineries. These two California requirements are very similar, and minor differences will be identified in the paper. Whereas the pendulum has swung towards increased PSM/RMP regulatory requirements for California refineries, the Federal OSHA and U.S. EPA updates to Process Safety Management (PSM) and Risk Management Plan (RMP) requirements as part of the PSM/RMP Modernization/Expansion Programs have been rescheduled and reprioritized.

The changes associated with the Cal/OSHA and CalEPA/CalOES programs are extensive and are not entirely synchronized between the agencies. The focus of this paper will be to provide relevant background information, a summary of the 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-2018 and the update provided in this proposed paper is important for:

- Unveiling the Final Regulatory Requirements in California

- Identifying Strategies for Addressing these Requirements with Minor Differences

- Providing the Entire GCPS Audience with an Understanding of Why These Changes, Initially Focused on California Refineries Could Become Important for All U.S. Refineries

- Providing an Update of U.S. EPA and Federal OSHA Initiatives

The contents of this paper will be important to communicate to GCPS attendees in the April 2018 time frame, and key topics include:

- Background – Pre-2012 PSM/RMP Universe

- Brief Overview and Key Elements within the PSM/RMP Program Modernization Initiatives

- Initiative Status and Potential Impact on Plant PSM/RMP Programs

- Compliance with Different Scheduler Requirements

- Potential Impact on Smaller Refineries

- Strategies for Effective Implementation

As part of the paper and the April 2018 presentation, select tips to streamline/focus the application of some of the more challenging new elements, as well as a comprehensive Summary Matrix of the more complex scheduler requirements for the new California regulations, will also be provided.