CalARP & Risk Management Plan (RMP) Compliance in California
If a California facility stores or uses certain hazardous chemicals above threshold quantities, it needs a Risk Management Plan.
If a California facility stores or uses certain hazardous chemicals above threshold quantities, it needs a Risk Management Plan. In California, facilities build and maintain that plan under the California Accidental Release Prevention program, the state version of the federal RMP requirement. The two terms get used almost interchangeably. Most clients hear the words from their fire department or in a violation letter, then start searching.
If you already know you need a CalARP or RMP plan and want a California consultant to build, update, or audit it, that is what CDMS does. If you are still trying to figure out whether the program applies to your facility, what level you fall into, or what an actual submittal contains, this page covers it. CDMS has worked CalARP, process hazard analysis, air dispersion modeling, and seismic projects across California since 1988. The team comes to your facility, gathers the data, builds the plan, and supports you through agency review.
Why Facilities Call CDMS for CalARP Work
Most CalARP and RMP calls come in around one of seven situations. If any of these match what is happening at your site, this service is the one you are looking for:
Your five-year renewal is due.
CalARP and RMP plans require renewal on a five-year cycle. Municipalities often start the procurement process six to twelve months ahead of the due date.
A CUPA reviewed your plan and failed it.
Your local CUPA (Certified Unified Program Agency, which may be a county environmental health department, fire department, or another local agency depending on jurisdiction) sent the plan back with deficiencies. You need someone to read it, fix what is wrong, and get it accepted.
You received a violation letter or settlement notice.
Often the letter references training on specific sections of the existing plan. The first step is reading the plan and identifying every item the agency flagged.
A chemical inventory increase pushed you over a threshold.
A new tank, a process change, or quiet growth in usage moved a regulated substance above its threshold quantity. CalARP now applies and a plan is needed.
Your previous consultant raised prices significantly.
CalARP work is infrequent for most facilities, and rates from incumbent providers have risen sharply. Municipal procurement policies typically require three competitive bids.
You added or replaced equipment.
A new ammonia tank, a process unit, or a redesigned piping run requires the plan to reflect the actual current configuration before submittal.
You are bidding a public-sector project.
Water and wastewater treatment plants that use chlorine gas, ammonia, or sulfur dioxide above threshold typically need CalARP coverage as part of operations.
Does CalARP Apply to Your Facility?
The trigger is threshold quantity: the maximum amount of a regulated substance present at any one time in any one process. Title 19 CCR §5130.6 (formerly §2770.5) organizes regulated substances into three tables:
- Table 1: Federal regulated toxic substances (from 40 CFR Part 68).
- Table 2: Federal regulated flammable substances (from 40 CFR Part 68).
- Table 3: California state-regulated substances, which add chemicals or set lower thresholds than the federal program.
If the maximum amount in any one process exceeds the threshold for any listed substance, the facility is covered. If the substance appears on Table 1 or Table 2, federal RMP requirements may also apply. If coverage is triggered only by a Table 3 substance or a California-specific lower threshold, the facility may be subject to CalARP without being federally covered for that substance. A facility can also trigger federal RMP without triggering CalARP.
Common chemicals that pull California facilities into the program:
| Chemical category | Typical industries |
|---|---|
| Anhydrous and aqueous ammonia | Cold storage, food processing, refrigerated warehouses, water and wastewater treatment |
| Chlorine | Water and wastewater treatment, pool chemical handling |
| Acids and reactives (nitric, sulfuric, certain mineral acids) | Metal finishing, plating, electronics, ceramics |
| Cyanide compounds | Plating, metal recovery |
| Flammable gases and liquids | Industrial gas users, specialty chemical operations |
Some chemicals count only under specific conditions (acid concentration, temperature, presence of certain reactants). This is where applicability questions get nuanced, and where a documented determination matters. For the chemical-by-chemical detail, see our companion piece on CalARP regulated substances and threshold quantities.
If CalARP does not apply, CDMS can issue a written applicability letter that documents the evaluation and the rationale. It is useful evidence if an inspector later questions the determination or if regulations change.
The Four CDMS CalARP and RMP Services
CDMS handles four distinct types of CalARP and RMP work. Most engagements are one of these:
Applicability determination.
Evaluating whether your facility exceeds threshold quantities for any listed substance. Bundled into Comprehensive Compliance Management as an ongoing determination checked against the chemical inventory the team maintains for you.
Applicability letter.
A documented confirmation and rationale for when CalARP does not apply, kept on file for future regulatory proof.
Plan development or update.
Full preparation of a new plan, or a five-year renewal of an existing one. This is the core CalARP service.
Compliance audit.
Reviewing your facility against what your own CalARP plan documents. Required at defined intervals under the regulation and frequently requested by CUPAs after a deficient submittal.
CalARP Program Levels, at a Glance
The single biggest scoping factor is program level. The regulation assigns a level based on chemical quantities, past accident history, and the operations involved.
| Program level | When it applies | What it requires | Complexity |
|---|---|---|---|
| Program 1 | No off-site accident history; release scenarios do not impact public receptors; emergency response coordinated with local agencies | Basic prevention and response documentation | Significantly simpler |
| Program 2 | Mid-tier facilities; not Program 1, not Program 3 | Prevention program (including hazard review), emergency response coordination or program, compliance audits | Moderate |
| Program 3 | Higher-hazard processes, often tied to specific NAICS codes or covered under Cal/OSHA’s PSM standard | Full process safety management, PHA/HAZOP, operating procedures, mechanical integrity, management of change, pre-startup review, incident investigation | Most complex; 200+ page submittals common |
| Program 4 | California-only tier covering petroleum refineries | Hierarchy of hazard controls, damage mechanism reviews, safeguard protection analysis, human factors, and other refinery-specific requirements | Highest |
Determining your program level early is the difference between a manageable scoping conversation and a budget surprise. The detail behind each tier is broken out in CalARP program levels 1, 2, and 3 explained.
What Is Actually in a CalARP/RMP Submittal
A complete plan is a binder, often several inches thick. Clients regularly describe their previous submittal as “a 10-inch binder with many different components.” That is accurate. The agency-submittable plan includes:
- Executive summary. Brief description of the facility, regulated substances, prevention program, accident history, and emergency response.
- Facility description. Stationary source, processes, regulated substances, and quantities.
- Hazard review or process hazard analysis. Program 2 requires a hazard review of each covered process. Program 3 requires a formal process hazard analysis (PHA) using an accepted methodology such as HAZOP, What-If, or Checklist, covering each covered process including external events (natural and human-caused).
- Offsite consequence analysis. Worst-case and alternative release scenarios, modeled using ALOHA air dispersion modeling and MARPLOT mapping. Endpoints, distances to receptors, and population estimates.
- Five-year accident history. Every accidental release from a covered process, with ten data points per incident.
- Prevention program (Program 2 and 3). Process safety information, operating procedures, training, mechanical integrity, management of change, pre-startup review, compliance audits, incident investigation, employee participation, hot work permits, contractor safety.
- Emergency response program. Facilities that respond to releases with their own personnel need a full written emergency response program with procedures, training, and equipment. Non-responding facilities need documented coordination with local responders and notification procedures.
- Management system and registration.
- Program 3 certification statement signed by the owner or operator.
- Appendices. Dispersion modeling output, seismic study, site maps, P&IDs (piping and instrumentation diagrams), SDS (Safety Data Sheets), population estimation, federal RMP submission proof.
The client supplies chemical inventory, accident history, P&IDs, and process descriptions. CDMS does the rest, including air dispersion modeling in-house. A full breakdown is in what’s inside a CalARP/RMP submittal.
How the CDMS Process Works
The build follows a structured sequence. The quote covers one draft, one client revision, and a second revision after agency review comments.
Regulatory determination.
Confirm which chemicals trigger the program and what program level applies. Identify the local administering agency and any agency-specific requirements.
Document and data request.
Chemical inventory, previous plan (if any), accident history, P&IDs, SDS, site maps, training records.
Site walkthrough.
Our team comes to your facility, walks the processes with your operations staff, photographs covered equipment, and confirms what is on paper matches what is on the floor.
Process hazard analysis.
PHA or HAZOP for each covered process, working with your operators. We cover hazards, previous incidents, engineering and administrative controls, human factors, and external events including seismic where the agency requires it. The technical detail is in process hazard analysis (PHA/HAZOP) for CalARP & RMP.
Offsite consequence analysis and air modeling.
Worst-case and alternative scenarios modeled in ALOHA with MARPLOT mapping. See offsite consequence analysis and air dispersion modeling explained.
Prevention program build (Program 2 and 3).
Process safety information, operating procedures, training documentation, mechanical integrity, management of change, pre-startup review.
Emergency response program.
Seismic analysis where the local agency requires it.
Draft assembly and internal QC.
Cross-checked against the agency’s completeness review structure (under Title 19 CCR §2745 and the local agency’s checklist).
Submittal and agency revision support.
When the CUPA or administering agency returns comments, CDMS handles the response and the revision cycle.
Soft timeline: a plan update typically runs several weeks. A new Program 3 plan with full PHA, OCA, and seismic runs longer. CDMS provides a written timeline with every quote.
CalARP, Federal RMP, and Cal/OSHA PSM
Three programs sit close together and get conflated in conversation. They are separate but overlapping:
- CalARP (California): California Health and Safety Code §§25531-25543.3 and Title 19 CCR Division 2 Chapter 4.5. Administered by local agencies, typically a CUPA, fire department hazardous materials program, county environmental health division, or air district, depending on the jurisdiction. Adds chemicals and lowers thresholds compared to the federal program.
- Federal RMP (EPA): Clean Air Act §112(r) and 40 CFR Part 68. The federal accidental release prevention requirement. If a facility exceeds a Table 1 or Table 2 threshold, federal RMP requirements also apply. If covered only under a Table 3 substance or a California-specific lower threshold, the facility may be subject to CalARP without being federally covered for that substance. Plans should be checked against current Part 68 requirements, including the 2024 EPA RMP amendments and any current EPA reconsideration status.
- Cal/OSHA Process Safety Management (Cal/OSHA): Title 8 CCR §5189. Worker-safety counterpart focused on covered processes. Many Program 3 facilities are also PSM-covered, and the prevention programs overlap heavily.
For California facilities, CalARP is usually the primary frame and the federal RMP submission rides along. The full side-by-side is in CalARP vs. federal RMP vs. Cal/OSHA PSM.
Who Enforces CalARP in California
CalARP is administered locally. The agency that reviews and accepts your plan depends on your county, and in many cases your city:
CUPAs and administering agencies
(Certified Unified Program Agencies). The CUPA runs the unified hazardous materials regulatory program for a jurisdiction. Depending on the jurisdiction, the CUPA may be a fire department hazardous materials program, a county environmental health or hazmat division, or another designated agency. They review plans, conduct inspections, and issue notices of violation.
Local air districts and participating agencies.
In some counties, the air district or a participating agency handles CalARP administration alongside or in place of the CUPA.
CalEPA.
State oversight and policy. CalEPA coordinates the unified program statewide.
EPA.
Federal RMP submissions go to EPA through the federal electronic submission system.
The agency that issues the violation is typically the agency that will accept the corrected plan. Common deficiencies, and how reviewers walk through a submittal, are covered in common CalARP plan deficiencies and how CUPAs review submittals.
Where CalARP Shows Up
Some industries hit CalARP thresholds more often than others. The largest verticals CDMS serves in this area:
- Cold storage, refrigerated warehousing, and food processing. Anhydrous ammonia refrigeration systems are the most common single trigger. See ammonia refrigeration and CalARP compliance in California for the IIAR overlap, mechanical integrity of NH3 vessels, and what an NH3-specific audit covers.
- Water and wastewater treatment. Chlorine gas, anhydrous ammonia, sulfur dioxide. Municipalities are heavy CalARP users.
- Metal finishing, plating, and electronics. Acids, reactives, cyanide compounds. Threshold counting can be nuanced because some substances count only under specific conditions.
- Specialty chemical and industrial gas users. Flammables and reactives.
Keeping Your Plan Current
A CalARP plan is not a one-time deliverable. Renewal is required every five years. Equipment changes, chemical inventory changes, and process changes between renewals require updates. The most cost-effective approach for many facilities is bundling the applicability check into ongoing compliance work, so a quiet threshold crossing is caught before the next CUPA inspection. The 5-year update process and the ongoing-determination model cover the maintenance side.
If your CUPA already returned a plan with deficiencies, the path forward is a CalARP compliance audit and corrective response. The audit checks your facility against what your own plan documents and identifies every gap a reviewer is likely to flag.
Frequently Asked Questions
What is CalARP?
CalARP (California Accidental Release Prevention) is California’s program requiring facilities that store or use regulated hazardous substances above threshold quantities to develop, submit, and maintain a Risk Management Plan. It is administered locally by CUPAs, fire department hazardous materials programs, county environmental health divisions, or other participating agencies, depending on the jurisdiction. The state authority sits under California Health and Safety Code §§25531-25543.3 and Title 19 CCR Division 2 Chapter 4.5.
What is the difference between RMP and CalARP?
RMP is the federal Risk Management Plan requirement under Clean Air Act §112(r) and 40 CFR Part 68. CalARP is California’s state program. CalARP includes the federal RMP chemicals and adds substances or lower thresholds on the California-specific lists. If a facility exceeds a Table 1 or Table 2 threshold under Title 19 CCR §5130.6, federal RMP requirements may also apply. If covered only because of a Table 3 substance or a California-specific lower threshold, the facility may be subject to CalARP without being federally covered for that substance. A facility can also trigger federal RMP without triggering CalARP. In day-to-day conversation the terms are used interchangeably.
Who needs a Risk Management Plan in California?
Any facility that stores or uses a regulated substance above its threshold quantity in any one process. Common examples: cold storage operations with anhydrous ammonia, water and wastewater plants using chlorine gas, metal finishers with cyanide or specific acid concentrations, food processors with ammonia refrigeration, and industrial gas users with flammables above threshold.
How often does a CalARP plan need to be updated?
The plan must be renewed every five years. It also needs updates when chemical inventory, processes, or equipment change in a way that affects covered processes. Many facilities tie the renewal to their annual compliance calendar so the work is scoped and budgeted before the deadline becomes urgent.
What program level applies to my facility?
Program level depends on chemical quantities, accident history, and the type of operations involved. Program 1 is for facilities with no off-site accident history where release scenarios do not reach public receptors. Program 2 covers mid-tier facilities. Program 3 covers higher-hazard processes, often those also covered under Cal/OSHA PSM. California also recognizes Program 4 for petroleum refineries. A documented program-level determination is part of every applicability evaluation.
What is an offsite consequence analysis?
An offsite consequence analysis (OCA) is the air dispersion modeling exercise that determines the distance to endpoint concentrations for a worst-case and alternative-case release of each regulated substance. CDMS performs OCAs using ALOHA modeling and MARPLOT mapping. The output drives population estimates, public receptor identification, and the alternative-scenario discussion in the plan.
Trusted throughout California
BSY started working with CDMS last year after our in-house EHS person departed the company. CDMS reviewed our existing operational permits as well as any additional Federal, State and Local regulations that could apply and helped us to create a comprehensive compliance calendar to track regulatory deadlines and submittal due dates. The CDMS team does an excellent job of tracking everything and can be relied upon to complete the forms accurately and assist with submittals, allowing me to focus on our business.
Speak with a CDMS EHS expert
Tell us about your facility and your deadline. You’ll get a clear read on what applies and a scoped plan to handle it.