

Regulatory Updates
California Program 4 Updates:
California Program 4 requirements should be evaluated using current 2026 agency guidance and each facility's actual process interconnections.
Additional Program 4 Elements: Additional elements (e.g., HCA, DMR, MOOC, SPA, etc.) are now required for refineries in California. Refer to our California State Requirements for additional details.
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Hazard Mitigation Plans – Regulatory Policy Updates:
FEMA's current hazard mitigation planning policies and guidance are available through its Hazard Mitigation Planning portal. State, local, tribal, and territorial plans must be updated and resubmitted for FEMA approval every five years to maintain eligibility for certain assistance.


PHA Facilitation Services
“Getting the Most Out of the PHA” — Watch our webinar for tips on streamlining the HAZOP/LOPA process. Topics include PHA planning, organization, implementation, and follow-through to optimize the process.
The webinar provides insight on common topic inquiries received over the years such as utilizing a scribe, study duration, how to integrate LOPA during the HAZOP process, PHA Redo vs. Revalidation, rejecting PHA recommendations, PHA Team composition, MI integration into the PHA, and more.
PSM/RMP Plans and Submittals
Nebula Safety & Environmental develops regulatory-compliant EPA Risk Management Plans, OSHA Process Safety Management programs, and applicable state process safety plans, including CalARP and related programs.
All of our process safety plans and submittals are coordinated with the locally mandated Administering Authority (AA) to ensure that all auditable regulatory requirements are achieved.


