Regulatory Updates
California Program 4 Updates:
Inclusion of Utilities as Part of Covered Process: A court decision was made on October 27th, 2020 by the US Court of Appeals 10th circuit where it was determined that a boiler was part of the covered process due to interconnectivity despite the fact that it did not contain any highly hazardous chemicals.
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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PHA Facilitation Services
Getting the Most Out of the PHA” - Watch our webinar for tips on streamlining our HAZOP/LOPA process. Topics include PHA planning, organization, implementation, and follow-through all aimed 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/ Submittal
Nebula Safety & Environmental has 20+ years of combined experience deploying regulatory compliant EPA Risk Management plans, OSHA Process Safety Management plans, and various statewide chemical process safety plans (CalARP, TCPA, HSE, WISHA).
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.
