California’s Hazardous Materials Business Plan (HMBP)
• The State of California has issues unique to the state that justify an innovative approach far beyond the U.S. EPA’s SARA Title III reporting requirements for all other states. Some of those reasons are population, the density of industry in those populated areas, climate zones, coastal issues and the need for emergency response with a localized flavor. In addition, thresholds assigned to chemical hazards in inventory in California facilities are very low. They can go as low as l lb. in some cities, but generally start at 500 lbs. for solids; 55 gals for liquids; and 200 cu. ft. for gases. California’s thresholds are 20 times more stringent than Federal thresholds. Also, the Aggregate Total Ruling is applied to this reporting law. But rather than reporting to several agencies, each company must report to only one agency…the Certified Unified Program Agency, or CUPA. The CUPA is typically housed within each local fire department for a quick, localized emergency response.
• In California, a ‘hazardous substance’ is any substance listed on the “Director’s List” under the “Hazardous Substances Information & Training Act of 1984.” To be in compliance, companies must adhere to the Uniform Fire Code. Deadlines can vary from one CUPA to another, but generally, are March 1st, annually in most locations.