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About CalARP
Any business that handles more than the threshold quantities of a Regulated Substance (RS) is required to develop a Risk Management Plan (RMP). (The Regulated Substances listed in the Risk Management Program include 77 toxic chemicals and 63 flammable substances.) The RMP is implemented by the business to prevent or mitigate releases of regulated substances that could have off-site consequences.
[Mandated under the California Accidental Release Prevention Program (CalARP), part of the Orange County CUPA. CalARP was adapted from the Federal accidental release program established by the Clean Air Act Section 112 (r) and modified to meet California's needs.]
Regulated Substances and their threshold quantities can be found in Title 19, California Code of Regulations, in the following tables:
- Table 1: Federal list of Toxic Regulated Substances
- Table 2: Federal list of Flammable Regulated Substances
- Table 3: California list of Regulated Substances
The Orange County CUPA implements this program for all Orange County cities except for Anaheim and La Habra.
Public Notice – Risk Management Plans
Risk Management Plan (RMP) is required when a facility uses a CalARP listed regulated substance in excess of a threshold quantity. Upon submission of an RMP (new RMP or 5-Year RMP Update), OCHCA will review the plan and determine if any deficiencies are present. The facility has 60 days to respond and correct the deficiencies. Once the deficiencies (if any) are corrected, OCHCA posts a public notice indicating that the RMP is complete. Once posted, OCHCA will make the RMP available at our office for public review and comment for 45 days. After the 45-day review period, OCHCA will conduct a final evaluation of the RMP in which any public comments made are considered.
This notice is issued as part of the public review process for RMPs, in accordance with the California Code of Regulations (CCR), Title 19 Division 2 Chapter 4.5 Article 3 Section 2745.2.
CalARP requirements
Should I use E-Submit and CERS
No. Currently, there are no CalARP-specific E-Submit or CERS reporting requirements. Please do not submit your Risk Management Plan or other CalARP documents through either E-Submit or CERS. Contact your CUPA inspector regarding the acceptable reporting submission formats for your RMP.
Differences between the Federal EPA RMP Program and California’s CalARP Program
The EPA's Risk Management Program (RMP) regulates facilities that have a greater than a threshold quantity of a regulated substance in a process (see the link to the tables above). These regulated substances include 77 toxic chemicals and 63 flammable substances. A Federally regulated RMP site must have a plan that includes 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 designed to prevent an accidental release. They include operating procedures, mechanical integrity, training, incident investigation, and managing changes that may occur in the processes, similar to the OSHA Process Safety Management elements. Facilities are also required to have an emergency response program, including an emergency response plan. All sites are required to develop and submit (electronically) their programs to the EPA.
California’s Accidental Release Prevention (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's federal threshold quantity is 2500 pounds vs. California's threshold quantity is 100 pounds)
- Requires an external events analysis to be performed, including a seismic analysis
- More interaction with the public and agencies, including a Risk Management Plan
A facility could be simultaneously in the California CalARP Program and the EPA’s RMP program and be subject to inspection by both the CUPA and the Federal Inspectors. If you have any questions about your facility’s status, contact your local CUPA inspector.
For more information about the CalARP Program in Orange County, please contact Marco Escobedo at (714) 586-6185.
