California Accidental Release Prevention (CalARP) is California’s state-level accidental release rule, codified in Title 19 of the California Code of Regulations, Division 2, Chapter 4.5. It rolls OSHA’s Process Safety Management (PSM) and EPA’s Risk Management Program (RMP) into a single regulation that covers both, then layers on stricter requirements. CalARP is administered by CalEPA and enforced locally by Certified Unified Program Agencies (CUPAs), which are typically county fire departments or environmental health offices.
CalARP applies only in California, and only inland and within California state waters out to 3 nautical miles.
The program has four tiers: Programs 1 through 3 mirror federal PSM and RMP coverage with lower thresholds and more listed substances, while Program 4 applies only to California’s ~11 petroleum refineries and adds Hierarchy of Controls Analysis (HCA), Damage Mechanism Review (DMR), Safer Technology and Alternatives Analysis (STAA), human factors analysis, third-party audits, annual process safety performance indicators, and root cause investigations after major incidents.
We at SIL Safe care about CalARP because it pulls more facilities into the regulatory net than PSM or RMP alone, and once a process is covered, the same RAGAGEP framework applies. IEC 61511 is therefore the de facto good engineering practice for any safety instrumented system at a CalARP-covered facility. Program 4’s STAA and HCA requirements essentially force a documented protection-layer analysis, which is exactly what the IEC 61511 lifecycle produces. If you operate a California refinery, you’re functionally in 61511 territory whether the regulation prints those words or not.
Key Points
- Applies only in California
- Combines worker-safety (PSM-style) and offsite-consequence (RMP-style) requirements into one rule administered by CalEPA and enforced by local CUPAs.
- Lower threshold quantities and more listed substances than federal PSM/RMP, so it can pull facilities into compliance that federal rules wouldn’t touch.
- Program 4 (refineries only) adds even more rules well beyond the federal baseline.
- IEC 61511 functions as the de facto RAGAGEP for any SIS at a CalARP-covered process.
Example
A California refinery undergoing a CalARP Program 4 compliance review must produce a documented Hierarchy of Controls Analysis showing why an SIS, rather than inherently safer design, was selected for a given hazard scenario. The supporting SIL determination, validation report, and proof-test records come straight out of the IEC 61511 lifecycle, and the CUPA auditor accepts that package as evidence of compliance with the STAA and accident prevention program requirements.
See Also: PSM, RMP, RAGAGEP, TQ, CalEPA
Cited Sources
- California Code of Regulations, Title 19, Division 2, Chapter 4.5 — California Accidental Release Prevention Program
- CalARP main page (CalEPA)
- CalARP Program 4 for Refineries (CalEPA)