February 13, 2004
Subject: California Accidental Release Prevention (CalARP) Program Risk Management Program (RMP) Update Letter #13
Welcome risk management professionals, it's time to update everyone on the latest news in the CalARP/RMP programs.
1. 5 Year Updates Due June 2004Many of you submitted your CalARP and Federal RMP on or before June 21st, 1999.
Both of these plans must be updated and resubmitted no more than 5 years from the
date you made the original
transmittal to OCFA or the electronic transmittal to the US EPA. Your process hazard analysis (PHA) or HazOp study needs
to be redone or revalidated by a team, and remember to send OCFA notification in advance so we can participate. The seismic
assessment also needs to be revalidated or redone by a responsible engineer, along with a new seismic walkdown. For all of
the details, see the latest version of this Guide on our website (also contact me at OCFA so we can participate in the seismic
assessment and/or walkdown). All CalARP program administration, management and oversight issues and questions should be addressed
to
robertdistaso@ocfa.org, who can be reached at: (714) 573-6253. US EPA has prepared
draft RMP re-submittal amendments, which can be found on their web site at
www.epa.gov.
The major proposed changes are 5-year accident history, emergency contact information, executive summary information, E-mail addresses,
contractor information, and uncontrolled/runaway reactions.
2. 2003 CalARP AwardOCFA is reviewing RMPs in preparation
for the 2004 Award for Excellence in Business Safety practices. The award will go to the owner/operator who demonstrates outstanding
elements of the risk management program, some of which include mechanical integrity of equipment through detailed preventative
maintenance/inspections, high quality safety training of employees and contract workers, early warning (fire and leak detection)
systems, and even state-of-the-art site security. The Award of Excellence is intended give formal recognition to businesses that
make our community safer. The award was presented last year to Ken Edwards of Albertson's Distribution in Irvine.
3.
Changes to your BusinessIf there is any change in your business operations or ownership, contact information, new equipment,
chemical inventory, or safety equipment out of service, etc., please notify our office as soon as possible. Generally, these changes
are required to be reported within 15 days. In addition, any accidental release or threatened release of hazardous materials must be
reported to us as soon as the hazard is abated.
4. Emergency ProceduresSection 2765.2 of the CalARP regulations
specifically states that you must have a procedure in place to inform and interface with the public about accidental releases. If
your RMP has identified any nearby/adjacent schools, hospitals, childcare, assisted living, etc., that could be affected by a release
from your facility, these neighbors could benefit from knowing some of your expertise in hazard recognition and early warning practices.
A meeting with your neighbors will provide you with the opportunity to demonstrate your ongoing excellence in accident
prevention. Additional related activities to consider are listed in the
OCFA CalARP
guidance on page 8-6 (or call Robert Distaso to ask for a hard copy of the guidance).
5. Keeping Up to DateThe
use of public forum meetings like OC CAER, IECOC, BAW, and LEPC are recommended to keep current on risk management issues. All of these
meetings are open to everyone and we encourage you to attend. These groups can provide safety and environmental training and discussions
of concerns of the public as well as regulatory agencies. Please call and ask us for schedules and contact information.
6.
RMP EnforcementRecently US EPA has settled an RMP enforcement case with a refinery in Southern California, for failure to
properly implement the risk management program. The US EPA worked with the local Fire Department (the Administering Agency) when
finalizing the several million dollar settlement. The main RMP violations were: Operating Procedures Not Current, P&IDs Not Accurate,
and Haz Op Recommendation Resolutions Not Documented Properly. This is certainly a good reminder for you to work closely with OCFA on
all areas of the Risk Management Plan, and consult with us whenever you have a question. Remember that just because you have prepared
your RMP and submitted it to all the proper authorities, your work isn't done. All your procedures, training, and documentation need
to be maintained in a current status, and any recommendations found in your RMP process need to be fully implemented. The RMP needs to
be more than just a notebook on a shelf--it needs to be the way you do business every day for the full safety measures to be effective.
Respectfully,
Robert Distaso PE, Fire Safety Engineer
Hazardous Materials Section - Fire Prevention