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OSHA 1910.119Free PSM Resource
California runs its own process safety programs. Worker safety falls under Cal/OSHA's PSM regulation (Title 8, §5189, and §5189.1 for refineries). Community protection falls under the California Accidental Release Prevention (CalARP) program, enforced by your local Unified Program Agency. Knowing only the federal rules leaves gaps. Here is how the California programs are built, with every point linked to the official text.
Many California facilities fall under both programs at once. One protects workers inside the fence; the other protects the community and environment outside it.
| Cal/OSHA PSM | CalARP | |
|---|---|---|
| Regulation | Title 8 CCR §5189 (general industry); §5189.1 (petroleum refineries, operative Oct 1, 2017) | Title 19 CCR, Division 5, Chapter 2, §§5050.1–5160.1; Health & Safety Code §§25531–25543.3 |
| Protects | Employees | The public and the environment |
| Who enforces | Cal/OSHA (Department of Industrial Relations) | Overseen by CalEPA (transferred from Cal OES in July 2021); implemented locally by Unified Program Agencies (CUPAs) |
| Federal counterpart | OSHA 29 CFR 1910.119 (California is a state-plan state) | EPA RMP, 40 CFR Part 68. If a federally listed substance exceeds its threshold, the RMP goes to both EPA and the local UPA |
§5189 covers the same core elements as 29 CFR 1910.119, but several requirements are worded differently. These are the differences most likely to trip up a program written to the federal standard.
After the 2012 Chevron Richmond refinery fire, California adopted §5189.1, which replaces §5189 for petroleum refineries. It goes well beyond federal PSM.
| Requirement | What it adds |
|---|---|
| Damage Mechanism Review (DMR) | For each process where a damage mechanism exists; revalidated at least every 5 years and reviewed for major changes. [§5189.1(k)] |
| Hierarchy of Hazard Controls Analysis (HCA) | A standalone analysis using the hierarchy: first-order inherent safety, second-order inherent safety, then passive, active, and procedural protection layers. Also required for PHA recommendations on major-incident scenarios and for major-incident investigation recommendations. Revalidated every 5 years. [§5189.1(c), (l)] |
| Safeguard Protection Analysis (SPA) | For every PHA scenario with major-incident potential, a written quantitative or semi-quantitative analysis (such as LOPA) of how effective each safeguard is, completed within 6 months of the PHA. [§5189.1(e)(5)] |
| Process Safety Culture Assessment | A written assessment at least every 5 years, by a team including an employee representative. [§5189.1(r)] |
| Human Factors program | Written analysis in major changes, incident investigations, PHAs, MOOCs, and HCAs; assessment of operating and maintenance procedures. [§5189.1(s)] |
| Management of Organizational Change (MOOC) | Required before reducing staffing or classification levels, changing shift duration, or increasing responsibilities by 15% or more, for changes over 90 days. [§5189.1(t)] |
| Stop Work authority | Including contractor employees, as part of the employee participation program. [§5189.1(q)] |
| Root cause analysis | Incident investigations use root cause analysis. [§5189.1(o)] |
| Corrective action program | Team recommendations may be rejected only for documented reasons: material factual errors, not relevant to process safety, or infeasible ("not based solely on cost"). Changes and rejections go back to the team for comment. [§5189.1(x)] |
| Compliance audits | Every 3 years, with documented operator consultation and a written response to comments within 60 days. [§5189.1(u)] |
SafeGuard PSM helps California facilities line up federal PSM, Cal/OSHA §5189, and CalARP. We facilitate PHAs and HAZOPs, run gap assessments against the California-specific requirements, and support compliance audits.
Talk to Us See a HAZOP Worked Example Free PSM AssessmentTitle 8 CCR §5189, Process Safety Management of Acutely Hazardous Materials: dir.ca.gov
Title 8 CCR §5189.1, Process Safety Management for Petroleum Refineries: dir.ca.gov
CalARP regulations, Title 19 CCR Division 5 Chapter 2 (CalEPA compilation, Sept 2026): calepa.ca.gov (PDF)
CalARP Program Levels, Program 4, FAQ, Program Updates, and Resources: calepa.ca.gov/california-accidental-release-prevention
CalARP Program 4 amendments, Notice of Exemption, March 2, 2026: ceqanet.lci.ca.gov
Federal comparisons: 29 CFR 1910.119 and 40 CFR Part 68.