Service area: Available in California, Nevada, Arizona, Oregon, Washington, Idaho, Montana, Utah, Wyoming, Colorado, New Mexico, North Dakota and South Dakota.
McNeil Safety Consulting supports oil and gas operations and battery energy storage (BESS) projects in California and the Western United States. Call (626) 546-9384.
Scope of Work
- Process Safety Management — program development, PHA support, mechanical integrity, management of change and compliance audits.
- California Accidental Release Prevention (CalARP) — program level determination, risk management plan support.
- Hazardous Materials Business Plan and CERS filing — inventory, site map, training and emergency response elements.
- BESS emergency response and emergency action plans — prepared with the local fire agency, unified program agency and county.
- Thermal runaway and off-gas response planning — detection, deflagration venting, isolation and re-entry criteria.
- Arc flash and electrical safe work practices — NFPA 70E program, boundaries, PPE categories, energized work permits.
- Industrial hygiene monitoring — hydrogen sulfide, benzene, welding fume, noise, heat.
- Confined space and hot work programs — entry permits, attendants, rescue provisions.
- Incident investigation and Cal/OSHA response — root cause, corrective action, citation defense.
Standards and Statutes That Apply
- Process Safety Management — 8 CCR §5189; federal counterpart 29 CFR §1910.119.
- Refinery PSM — 8 CCR §5189.1, including hierarchy of hazard controls, damage mechanism review and safeguard protection analysis.
- CalARP — 19 CCR §2735 et seq.
- Hazardous Materials Business Plan — Health and Safety Code §25500 et seq., reported through CERS.
- HAZWOPER and emergency response — 8 CCR §5192.
- Permit-required confined space — 8 CCR §5157.
- Control of hazardous energy — 8 CCR §3314.
- Airborne contaminant PELs — 8 CCR §5155, Table AC-1.
- Electrical Safety Orders — 8 CCR §2299 et seq.; arc flash analysis to NFPA 70E.
- Stationary energy storage installation — NFPA 855, adopted through the California Fire Code.
- BESS emergency plans — Public Utilities Code §761.3, added by SB 38, Chapter 377, Statutes of 2023. The owner or operator develops the plan with local emergency management, the unified program agency and local first response agencies, and submits it to the county and the city.
Reporting Deadlines
- Serious injury, illness or death — report to Cal/OSHA immediately, and in no event more than 8 hours after the employer knows or should have known. Labor Code §6409.1(b).
- Hazardous materials release — immediate report to the unified program agency and the State Warning Center. Health and Safety Code §25507.
- Citation appeal — 15 working days from receipt. Labor Code §6600.
Registrations
Michael Karl McNeil, REP, RIH, EPP, QSD. See Credentials.
Questions
Does a BESS project need an emergency response plan before it operates?
Public Utilities Code §761.3 requires an emergency response and emergency action plan covering the premises, developed in consultation with local emergency management agencies, the unified program agency and local first response agencies, and submitted to the county and applicable city.
When does PSM apply to a facility?
8 CCR §5189 applies at or above the listed threshold quantity for a covered highly hazardous chemical, and to processes involving 10,000 pounds or more of a flammable liquid or gas held on site in one location.
Is a Hazardous Materials Business Plan the same as a CalARP program?
No. The HMBP is filed under Health and Safety Code §25500 et seq. based on quantity on hand. CalARP, at 19 CCR §2735 et seq., applies to regulated substances above threshold and requires a risk management plan.
Contact
McNeil Safety Consulting, 9163 Arcadia Ave, San Gabriel, CA 91775. (626) 546-9384 · mike@mcneilsafetyconsulting.com
States We Serve
McNeil Safety Consulting provides this service to clients in the following states:
- California
- Nevada
- Arizona
- Oregon
- Washington
- Idaho
- Montana
- Utah
- Wyoming
- Colorado
- New Mexico
- North Dakota
- South Dakota
To confirm coverage for your site, call (626) 546-9384.