What’s Inside a CalARP/RMP Submittal: The Required Elements
Clients describe a CalARP/RMP plan the same way on a regular basis: “It’s a 10-inch binder with many different components.”
Clients describe a CalARP/RMP plan the same way on a regular basis: “It’s a 10-inch binder with many different components. There’s no way I could send the whole thing.” The plan is one of the most document-heavy compliance deliverables a California facility maintains. If you’re staring at a renewal, a violation letter, or a new threshold trigger and wondering what you’re actually on the hook for, here’s what a submittal contains, who reviews it, and what your facility supplies versus what CDMS prepares.
For a complete overview of the program, who it covers, and how California’s CalARP rules layer on top of federal RMP, see our CalARP and Risk Management Plan compliance in California guide.
What the Agency Expects to Receive
A complete CalARP/RMP submittal is a single bound plan plus appendices, submitted to your local administering agency. In California, that agency may be a CUPA, a fire department hazardous materials program, a county environmental health or hazmat division, or a local air district, depending on the jurisdiction. Administering agencies review the plan against the structure laid out in Title 19, California Code of Regulations, Chapter 4.5. The plan must also satisfy federal Clean Air Act Section 112(r) and 40 CFR Part 68 requirements where the triggering substance appears on the federal lists (Table 1 or Table 2 under Title 19 CCR §5130.6).
Plan size depends on your program level. Program 1 plans can run a few dozen pages. Program 3 plans regularly run 200+ pages with appendices. The required sections are consistent across program levels. The depth and detail change, not the structure. If you’re not sure yet whether your facility crosses a threshold, start with does your facility need a CalARP plan? regulated substances and threshold quantities.
The Required Elements
When CDMS assembles a CalARP/RMP plan, every submittal contains the following sections, in the order they typically appear in the bound plan:
Executive Summary.
Brief description of the facility, the regulated substances on site, accidental-release prevention and emergency-response policies, worst-case and alternative release scenarios with mitigation measures, the general prevention program, a five-year accident-history summary, and any planned safety improvements.
Facility Description.
Identification of the stationary source, covered processes, regulated substances and maximum quantities, SIC/NAICS codes, and the administering agency.
Registration.
Federal RMP registration information submitted to EPA, mirrored in the CalARP submittal to the local administering agency.
Offsite Consequence Analysis (OCA).
Worst-case release scenarios for regulated toxic and flammable substances above threshold, plus alternative release scenarios. This requires air-dispersion modeling. CDMS performs this work in-house and includes the modeling outputs as an appendix.
Five-Year Accident History.
Documentation of every accidental release from a covered process in the past five years, with ten data points per incident (date, substance, quantity released, release type, weather conditions, on- and offsite impacts, contributing factors, corrective actions). The client supplies the history. CDMS organizes and formats it.
Prevention Program.
For Program 2 plans this is a streamlined prevention section. For Program 3 plans this expands into the full process-safety program: process safety information, process hazard analysis, operating procedures, employee training, mechanical integrity, management of change, pre-startup safety review, compliance audits, incident investigation, employee participation, hot-work permits, and contractor safety. See CalARP Program Levels 1, 2, and 3 explained for which prevention elements apply at your level.
Process Hazard Analysis (PHA).
For Program 3 plans, a documented team-based hazard analysis using a recognized methodology (What-If, Checklist, HAZOP, FMEA, or Fault Tree). It addresses process hazards, prior incidents, engineering and administrative controls, human factors, and external events including seismic where applicable.
Emergency Response Program.
Facilities that respond to accidental releases with their own personnel need a full written emergency response program covering specific response actions, equipment, training, and drills. Non-responding facilities need documented coordination with local responders and notification procedures. Both require public and agency notification procedures and emergency medical-care information.
Seismic Analysis (where required).
California’s earthquake exposure means many administering agencies require a seismic study of process equipment containing regulated substances. CDMS performs this analysis and includes it as a supporting appendix.
Supporting Documentation.
Site maps showing storage and process locations, P&IDs (piping and instrumentation diagrams) for all covered processes, equipment lists, SDS (Safety Data Sheets), dispersion-modeling outputs, seismic study, population estimation for offsite endpoints, and the federal RMP submission record.
Certification.
CDMS prepares the plan and supporting documentation. The owner/operator or responsible facility official certifies the submittal as true, accurate, and complete. If the local administering agency requires a separate preparer signature block, that is handled separately from the owner/operator certification.
What You Supply Versus What We Prepare
The biggest source of client anxiety with a CalARP/RMP submittal is “I don’t know how to write half of this.” You don’t need to. The submittal is a technical document we assemble from a defined set of inputs. Most of those inputs are operational records you already maintain.
| What you supply | What CDMS prepares |
|---|---|
| Chemical inventory and maximum quantities in each process | Regulated-substance applicability evaluation against the three tables under Title 19 CCR §5130.6 (Table 1 federal toxics, Table 2 federal flammables, Table 3 California state-regulated substances) |
| Five-year accident history (incidents, releases, near-misses) | Accident-history section formatted to the ten-data-point standard |
| P&IDs and process descriptions for covered processes | Process safety information, PHA, mechanical-integrity sections |
| Existing operating procedures, training records, MOC records | Prevention program write-ups (Program 2 or 3) |
| Site maps, equipment lists, SDS | Worst-case and alternative-scenario air-dispersion modeling |
| Facility official’s certification signature | Seismic analysis, executive summary, plan assembly and binding, final submittal |
When we walk a facility for the first time, the first thing we ask for is the previous CalARP plan (if one exists), the current chemical inventory, and the P&IDs. Most of what an agency reviewer flags as a completeness gap traces back to one of those three documents being out of date.
What the Agency Does With It
Once submitted, the administering agency reviews the plan against a completeness checklist tied to Title 19 CCR §§2745.3 through 2745.9. Reviewers check that each required element is present, that the offsite consequence analysis modeling assumptions are documented, that the accident history matches what’s been reported through release-notification channels, and that the plan reflects current operations rather than a five-year-old snapshot. If sections are missing or thin, the agency issues a deficiency notice and asks for a revised submittal.
After Submittal: Maintenance and Renewal
A CalARP/RMP plan isn’t a one-time submittal. Once the agency accepts it, the plan must stay current as the facility changes (new chemicals, process modifications, equipment swaps, accident events) and must be renewed every five years. The five-year renewal isn’t a light touch. It’s a full re-examination of every section against current operations. For what that cycle looks like, see CalARP 5-year updates: renewing your risk management 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.
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