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Changes to the CalARP & HMBP Regulations | Blog No. 32

Facilities in California with hazardous materials (especially covered processes) need to be aware of important regulatory changes.


On March 6, 2024, the Office of Administrative Law (OAL) approved updates to the Hazardous Materials Business Plan (HMBP) and California Accidental Release Prevention (CalARP) regulations. (Note: CalARP is California's stricter version of EPA's Risk Management Plan.) These updates, driven by Assembly Bill 148 (2021), transfer oversight from the California Governor’s Office of Emergency Services (CalOES) to the California Environmental Protection Agency (CalEPA).

Key Changes

  • Relocation of specific regulations within Title 19 (e.g., The program 3 PHA requirements used to be contained within Title 19 CCR §2760.2; this is now being relocated to Title 19 CCR §5100.2.)

  • Revisions of cross-references, additions, and deletions of definitions

  • No significant changes to existing regulatory requirements

Explanatory Documents


Unfortunately, for those of us having spent a lot of time working around the CalARP and HMBP regulations, the new code references will have to be relearned. Fortunately, while the enforcement is changing hands from CalOES to CalEPA, the substance of the regulations remains the same...for now. Time will tell what will happen with CalEPA behind the wheel of CalARP and HMBP.

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