Overview of Federal and California Process Safety Regulations (Part 2 of 3)
This is a continuation of our blog series titled Overview of Federal and California Process Safety Regulations. Part 1 can be accessed here.
Fed/OSHA PSM vs. Cal/OSHA PSM
- Compliance Audit – Fed/OSHA explicitly requires a facility to perform a compliance audit every three (3) years, while Cal/OSHA’s PSM regulation does not even mention the word “audit“. The explanation of this can be found in §5189(o) which addresses the topic of Injury and Illness Prevention Program (IIPP). Since California requires all businesses to prepare IIPPs which include provision for “scheduled and periodic inspections of facilities“, no additional requirement was included within the Cal/OSHA PSM regulation.
- Oil Refineries – Cal/OSHA is in the final stages of publishing Title 8 CCR §5189.1 which includes new PSM requirements for oil refineries. This introduces substantial changes to the PSM regulations for facilities subject to the proposed new rules.
The table below provides a summary of the elements required by Cal/OSHA and Fed/OSHA PSM programs:
|Fed/OSHA Title 29 CFR §1910.119||Cal/OSHA Title 8 CCR §5189|
|Employee Participation||Employee Participation|
|Process Safety Information||Process Safety Information|
|Process Hazard Analysis||Process Hazard Analysis|
|Operating Procedures||Operating Procedures|
|Pre-Startup Safety Review||Pre-Startup Safety Review|
|Mechanical Integrity||Mechanical Integrity|
|Hot Work Permit||Hot Work Permit|
|Management of Change||Management of Change|
|Incident Investigation||Incident Investigation|
|Emergency Planning and Response||Emergency Planning and Response|
|Compliance Audits||Injury and Illness Prevention Program|