Once your facility is covered by CalARP, the next question is which program level applies: 1, 2, or 3. The level decides how much plan you actually have to write. A Program 1 plan can be a thin document focused on a worst-case release and an accident history. A Program 3 plan is a full process safety management program, often running 200 pages or more before appendices. The chemicals, the quantities, and the accident history don’t change between the levels. The compliance burden does.

For a complete overview of who CalARP applies to and what triggers coverage in the first place, see our CalARP and Risk Management Plan compliance in California guide. This page goes deeper on the level distinction itself: who lands where, what each level requires, and how the determination gets made.

Program 1: The Lightest Track

Program 1 is reserved for covered processes that, in plain terms, can’t hurt anyone offsite if the worst-case release happens, and haven’t had a release with offsite consequences in the past five years. The qualifying criteria are spelled out in 40 CFR §68.10 and adopted into California’s CalARP regulations. The distance from the release point to a toxic or flammable endpoint must be less than the distance to the nearest public receptor (homes, schools, businesses, parks). There must be no accidental release with offsite consequences in the past five years. And emergency response must be coordinated with local responders.

When we walk a facility that thinks it might be Program 1, the first thing we check is the actual distance from the chemical to the property line, and then the distance to the nearest public receptor beyond that. Worst-case modeling decides this, not assumption. A facility with anhydrous ammonia 100 feet from a residential street rarely qualifies, even if the inventory is modest. A small, well-buffered industrial site with the same inventory often does.

A Program 1 plan still has to be written, submitted, and certified. It just doesn’t have a prevention program attached. For facilities that legitimately qualify, this is the difference between a manageable compliance task and a multi-month project.

Program 3: The Heaviest Track

Program 3 applies when the covered process either falls within a listed NAICS code (petroleum refineries, certain chemical and pesticide manufacturing categories among them) or is subject to Cal/OSHA Process Safety Management under California Code of Regulations Title 8, Section 5189. Most California ammonia-refrigeration operations at refrigerated warehouses, cold storage facilities, and food processors land in Program 3 because of the PSM trigger.

A Program 3 plan carries all of Program 2’s elements and adds the full PSM framework: written process safety information including P&IDs (piping and instrumentation diagrams) and chemical-specific data, a formal Process Hazard Analysis (typically a HAZOP for continuous processes), written operating procedures with annual certification, training with competency verification, mechanical integrity inspections on a defined schedule, management of change procedures, pre-startup safety review, contractor safety, hot work permits, incident investigation, employee participation, compliance audits at defined intervals, and emergency response.

The most common deficiency we find on existing Program 3 plans during an update is mechanical integrity. The plan describes inspection intervals on paper, but the records don’t match. The second most common is management of change: the facility installed a new pump, replaced a relief valve, or added a tank, and the plan was never updated. Program 3 isn’t a document you finish; it’s a program you run, and the plan has to track what’s actually happening on the floor.

The CalARP plan itself for a Program 3 facility is typically 200+ pages before the appendices, which add P&IDs, the seismic assessment if required by the local administering agency, the dispersion modeling output, SDS sheets, and population estimation. CDMS handles the air dispersion modeling (ALOHA and MARPLOT) and seismic analysis in-house. The client supplies chemical inventory, accident history, P&IDs, and process descriptions.

How Program Level Gets Determined (and Changes)

Program level is determined for each covered process, not for the facility as a whole. A site can have a Program 1 process and a Program 3 process under the same CalARP submittal. The determination starts with the regulated-substance inventory, runs through the worst-case modeling for any process that might qualify for Program 1, checks the NAICS codes against the listed industries, and confirms PSM coverage under Cal/OSHA Title 8 §5189.

The level can also shift. A process upgraded from a few hundred pounds of chlorine to several thousand can move from Program 1 to Program 2 or 3. A facility that takes its inventory below threshold can drop out of CalARP entirely. An accidental release with offsite consequences can disqualify a process from Program 1 even if nothing else changed. This is why CDMS treats applicability and program level as an ongoing determination for clients on our Comprehensive Compliance Management, rather than a one-time scoping exercise.

For facilities that also need to understand how CalARP overlaps with the federal RMP rule and Cal/OSHA PSM, see CalARP vs. Federal RMP vs. Cal/OSHA PSM: How the Programs Fit Together. The programs share most of their content but the enforcement, deadlines, and California-specific add-ons matter.