How to Implement the CalARP
Senior Hazardous Materials Specialist
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Help Administrating Agencies in
establishing and implementing the
Guidance to develop a strategy to
adequately implement the CalARP
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Definition of AA
Administrating Agencies (AA) are the local
agency authorized by OES to implement
and enforce the CalARP program in
California. AAs also known as Certified
Unified Program Agency (CUPA),
Participating Agency, or Designated
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Federal Risk Management program (FEDRMP)
–Title 40 of CFR, Part 68
Federal OSHA Process Safety management
Program (OSHA PSM)-Title 29 of the CFR Part
California Accidental Release Prevention
Program (CalARP) – California Code of
Regulations, Title 19, Division 2, Chapter 4.5,
Article 1 through 11.
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Any buildings, structures, equipment,
installations, or substances emitting
stationery activities which belongs to the
same industrial group, which are located
on one or more contiguous properties,
which are under the control of the same
person (or persons under common
control), and from which an accidential
release may occur.
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Risk Management Plan
Risk Management Plan (RMP) is a document that must
be a true and accurate reflection of a facility’s
compliance with the elements of the CalARP Program.
It summarizes the facility’s accidental release prevention
program implementation activities. Each facility with one
or more covered processes, must prepare and submit a
single RMP that includes all covered processes.
(Note: If an RMP is required by the FedARP Program,
the “single” RMP may need to be crafted to meet AA
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Process means any activity involving a
regulated substance including any use, storage,
manufacturing, handling, or on-site movement of
such substances, or combination of these
activities. A process can be as simple as a
single storage vessel or a group of drums or
cylinders in one location or as complicated as a
system of interconnected reactor vessels,
distillation columns, receivers, pumps, piping,
and storage vessels
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The program consists of two major
1. The Risk management Plan (RMP)
2. The audits-inspections of the program
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There are 4 major steps that need to be
considered in establishing the CalARP
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-Initial Public Notice
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Send an initial notification letter to Stationary Source
(SS) with more than the threshold of a regulated
substance. A business plan inventory information, Air
Districts , Building departments, or other permit issuing
agencies might be helpful in identifying RMP facilities.
Note in the initial notification letter that the SS will have
one year from the initial notification letter to submit the
You can suggest a date for the orientation meeting or
you can call the SS to schedule one.
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Orientation meeting might be helpful in opening a dialogue between
the SS and the agency.
Some of the items that need to be discussed at the orientation
Description of the RMP process
The description of the covered process(es)
Timeline for the RMP process
During the meeting, make sure to :
Bring a copy of the Guidance, County or OES
Request that the facility will inform you of their HAZOP meeting
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SS will submit the RMP to the AA for review
AA will do the the Initial Review to determine that all the
required elements pursuant to sections 2745.3 through
2745.9 are documented in the RMP plan and it contains
appropriate level of detail.
written notice or verbal notice should be provided to the
SS if deficiencies were found.
Always keep copies of the checklist in the facility's file.
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Initial Public Notice
After the initial review is completed, the AA will publish a notice
in a local newspaper of general circulation that the RMP has
been submitted and the AA has initiated the process for
government and Public review.
Always keep a copy of the initial public notice in the facility file.
Wording in the Initial Public Notice can be very simple such as:
“Pursuant to the California Code of Regulations, Title 19, Division 2,
Risk Management Plan(s) RMP have been submitted to “Name of AA”
by the following (Name of companies) . The department has initiated
the process for government and public review.”
A letter will be sent out to SS verifying the receipt of their RMP
plan and the date of when the public notice will be published.
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Informal Review/ Completeness Review
AA will start the informal review to determine
that the RMP is complete. During the informal
review, the SS is allowed to receive a feedback
from the AA prior to the completeness review. If
there are deficiencies, then the AA will notify the
SS and a 60 days (facility may request a one-
time 30 days extension) time frame will be given
to correct those deficiencies.
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Type of Deficiencies
There are two types of deficiencies:
1. Omission Deficiencies- Is the result of the
exclusion of a local, State , and Federal
requirement or failure to submit detailed
2. Error of Fact- Is a result of misstatement by the
SS. Vagueness, or insufficient evidence may be
misleading to the RMP reviewer.
AA may provide a verbal notice to the SS of any deficiencies.
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If deficiencies are identified, a letter will be sent out to
the SS notifying them of the deficiencies and assigning a
date to correct the deficiencies. Typically 60 days will be
given , however, the SS may request a one-time
Failure to correct deficiencies during specified time frame shall be
subject the owner/operator of a stationary source to to the penalties
specified in Section 25540 and 25541 of HSC
Once all the deficiencies are corrected, the RMP should
be accepted as complete. If the SS fails to submit the
revised RMP, then enforcement action must be
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Formal Public Review
Within 15 days after the RMP is accepted as
complete, RMP should be made available to the
public for review and comments.
A Public Notice will be published in the local
45 days must be given for public to review and
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Public Notice must describe the RMP and
state the location where it may be
Be posted in a local newspaper for a
period specified by the AA.
Must notify anyone that has specifically
requested to be notified.
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Example of Public Notice
“Pursuant to the California Health and Safety Code, Division 20, Chapter
6.95, Section 25535.2, facilities that handle regulated substances above
certain thresholds are required to prepare risk management plans. The
goal of a risk management program is to prevent chemical accidents that
could cause harm to the public and the environment and to reduce the
potential impact of accidental releases. The risk management plan
contains an off-site consequence analysis that evaluates specific potential
release scenarios including worst-case and alternative scenarios; a history
of accidental releases; an integrated prevention program to manage risk; an
emergency response program; and a management system to oversee the
implementation of the risk management program. The risk management
plans for the following facilities are available for public review and comment
at the Stanislaus County Department of Environmental Resources, 3800
Cornucopia Way, Suite C, Modesto until March 17, 2000.“
List companies names and addresses…….
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RMP auditing is the chief administrative control through
which implementation and enforcement are ensured.
Audits are periodically performed on the RMP to review
its adequacy and it can be accompanied by inspection.
When is determined that an audit is necessary then:
Provide advance notice to the SS, SS need to make all
the necessary documentation available for review and
verification at the time of auditing.
Send the audit-inspection checklist via e-mail to the
person in charge of the RMP implementation.
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Based on the checklist, the AA will send a “Preliminary
determination of Necessary RMP Revisions”, it shall
include the basis for the revisions and include a
timetable for the implementation.
The AA will expect to receive a written response within
90 days. Upon consultation with the SS, the AA will
issue the final determination of necessary RMP
Failure to make the revisions within 30 days after the
final determination was received, the SS is in violation of
Article 3, Chapter 4.5, and Division 2 of 19CCR.
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Inspection are site visits to check the accuracy of the RMP data and
implementation of the CalARP Program elements. Inspections are
performed every 3 years and are for the purpose of ensuring facility
compliance with the CalARP Program. The following are some
steps that need to be taken by the inspector:
Set up an appointment with the facility at least 5 days in
Review the RMP prior to the inspection.
Complete the RMP Formal Evaluation Review, using the
Evaluation Review checklist.
Upon arrival at the site, identify yourself and ask for the RMP
coordinator or the designated alternate.
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Hold an opening conference, describe how the inspection will
The inspector should have a simple sketch of the process to be
able to identify all equipment and operational controls listed in
the RMP plan.
The inspector should ask any questions that may pertain to
accidental release risk.
Note discrepancies on the CalARP/RMP inspection form or
violations of the Uniform Fire Code and other applicable
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