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Hazardous Material Management Plan & CERS Submittal

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Hazardous Material Management Plan & CERS Submittal

A Hazardous Material Management Plan (HMMP) is a document containing detailed information on the storage of hazardous materials at a facility. Chapter 6.95 of the California Health & Safety Code (H&SC) requires that facilities that use or store such materials at or above reporting thresholds submit this information.

The owner/operator of a facility must complete and submit a Hazardous Material Business Plan for each site where any individual hazardous material or mixture containing a hazardous material is present at or above its reporting threshold at any time during the reporting year. Reporting thresholds are:

  1. 500 pounds or more of any solid hazardous material. [HSC §25503.5(a)]
  2. For liquid hazardous materials:
    -More than 55 gallons of any type or 275 gallons aggregate quantity on site for lubricating oils as defined by HSC §25503.5(b)(2)(B). [HSC §25503.5(b)(2)(A)]
    -55 gallons or more of any other liquid, including waste oil. [HSC §25503.5(a)]
  3. For hazardous material gases:
    -More than 1,000 cubic feet (at standard temperature and pressure) of Oxygen, Nitrogen, or Nitrous Oxide stored/handled at a physician, dentist, podiatrist, veterinarian, or pharmacist’s place of business. [HSC §25503.5(b)(1)]
    -More than 300 gallons of Propane used for the sole purpose of heating the employee working areas within the facility. [HSC §25503.5(d)]
    -200 cubic feet or more of any other gas. [HSC §25503.5(a)]
  4. Amounts of radioactive materials requiring an emergency plan under Parts 30, 40, or 70 of Title 10 Code of Federal Regulations or applicable quantities specified in items 1, 2, or 3, above, whichever amount is smaller. [HSC §25503.5(a)]

CDMS has trained specialist that can assist companies with the preparation of these reports.

Regulatory bodies
  • CalEPA (California Environmental Protection Agency).
  • DTSC (Department of Toxic Substances Control).
  • CERS (California Environmental Reporting System).
  • Cal OSHA (California Division of Occupational Safety and Health).
  • Local CUPAs (Certified Unified Program Agencies).
Who needs it

The State of California’s EPA has mandated that all businesses that have hazardous materials on their site must prepare a Hazardous Material Management Plan (HMMP). In addition to the local agency HMMP submittal, state and additional regulations require documentation to supplement the HMMP submittal. Some major requirements of this document include:

  • An Emergency Response Plan that describes emergency procedures to follow in the event of a fire, earthquake, or hazardous material spill.
  • An Inventory of Hazardous Materials, which meets local, State, and Federal reporting requirements, as well as Employee Right-to-Know communications requirements.
  • Proper Handling Procedures for hazardous materials and waste.
  • Employee Training Programs, which educate employees in the proper use and handling of hazardous materials.
  • Site Drawings of the plant layout indicating locations of key areas, safety items, evacuation routes, etc.

CDMS prepares these documents and programs for its clients and cooperates with the regulatory agencies to ensure that the Hazardous Material Management Plan meets all local, State, and Federal regulations.

Regulation reference
  • Title 19 CCR, Division 2, Chapter 4.
  • Title 22 CCR, Division 4.5.
  • Title 27 CCR, Division 1, Subdivision 4.
  • Health and Safety Code Chapter 6.95, Article 1.
  • Health and Safety Code Chapter 6.11.
  • 19 CCR, Division 2, Chapter 3.
  • Multiple CCR Titles (8, 17, 19, 22, 23, 26, 27).
  • Local/municipal fire codes.
What our service provides:

CDMS will develop a Hazardous Material Management Plan (HMMP) that will integrate local, state and some federal requirements into one concise document. This will enable the Client to have easy access to key documents for both internal and regulatory review. In preparing the Plan, CDMS will:

  • Comply with Chapter 6.95 (Section 25500 et seq.) of the Health and Safety Code.
  • Integrate the existing programs and reports that the Client has already prepared. This will be done at CDMS’s discretion.
  • Prepare and update the submittal of the local Hazardous Material Business Plan into the California Electronic Reporting System (CERS).

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Contact us

What facilities need to submit a Hazardous Materials Business Plan (HMBP) via CERS?
Facilities that handle hazardous materials above certain thresholds set by California law must submit an HMBP. This includes hazardous waste generators, treatment facilities, storage facilities, and certain transportation entities.

What hazardous materials need to be reported in CERS?
Businesses must report hazardous materials inventory above certain thresholds. This includes chemicals, fuels, batteries, compressed gases, radioactive materials, medical waste, and more.

How do I register and create an account on CERS?
Go to https://cers.calepa.ca.gov. Select “Register” to create an account. You’ll need your business information and chemical inventory.

What sections must the Hazardous Materials Business Plan (HMBP) contain?
Emergency response plans and procedures, employee training details, business owner/operator identification, and hazardous materials inventory records.

How often do I need to review and certify my Hazardous Materials Business Plan (HMBP)?
You must review and certify your plan at least once every 12 months. Updates must be submitted within 30 days.

What information must be included in the emergency response plan?
Emergency notifications, response methods, evacuation plans, water runoff prevention, responder PPE and training, site layout diagram, etc.

How do I update my existing Hazardous Materials Business Plan (HMBP) submissions on CERS?
Login to CERS, find your existing plan, and select the “Modify” button to update and submit changes.

What if I exceed the reporting thresholds for the first time – how do I submit my first HMBP?
If this is your facility’s first Hazardous Materials Business Plan (HMBP), select “Add new plan” on CERS and choose the appropriate plan type to submit.

Are there fees associated with submitting a Hazardous Materials Business Plan (HMBP) via CERS?
Yes, there are generally administrative fees charged by DTSC and your local CUPA ranging from $50-$500+ per submission.

How do I obtain an Environmental Protection Agency (EPA) hazardous waste generator ID number?
Submit a completed EPA Form 8700-12 to DTSC. The form is on the DTSC website.

Are there specific labeling, signage, or storage requirements?
Yes, detailed hazard communication and storage requirements are defined in Title 22, CCR. Consult these regulations for specifics.

What employee training records must be kept?
Training procedures, topics covered, trainer names, employee names and job titles, training dates must be documented and maintained on file.

What are the penalties for non-compliance?
Fines up to $2,000 per day, permit restrictions, and even criminal prosecution for egregious violations.

How long do I need to keep my Hazardous Materials Business Plan (HMBP) records?
At least 3 years. Retaining records for 5 years or more is recommended.

Can I submit a consolidated, multi-facility Hazardous Materials Business Plan (HMBP)?
Yes, under certain circumstances and ownership structures a single consolidated plan can be filed for multiple facilities.

Do I need to report and include permits for underground storage tanks?
Yes, permits and records for any underground tanks storing hazardous materials or waste must be included.

Are any materials exempt from hazardous materials reporting?
Yes, some exemptions exist for food/drugs, livestock drugs, fertilizers, household cleaning products. See regulations for all exemptions.

Where can I get copies of Title 22 CCR and other DTSC regulations?
All DTSC/CalEPA regulations are available on their website at https://dtsc.ca.gov or by contacting DTSC directly.

Can CERS submissions be completed by a third-party consultant?
Yes, a qualified environmental consultant can be contracted to prepare and submit HMBPs on behalf of your company. Please Contact Us to get support or request a complimentary facility walkthrough & compliance assessment. Our skilled team of EH&S specialists is ready to assist you.