EHS Compliance Audit Checklist for California Facilities

If you’re responsible for EHS compliance at a California industrial or commercial facility, this checklist covers the regulatory programs that apply to most operations. Some are required for every California employer. Others depend on what your facility does, what materials you handle, and what permits you hold.

Use it as a self-assessment. If you’re not sure whether a program applies to your facility, or you know it applies but aren’t sure it’s current, that’s exactly the kind of question a gap assessment answers.

Core Programs: Most California Facilities Need These

These programs apply broadly to industrial and commercial operations in California. If your facility handles chemicals, generates waste, or employs people in any hands-on capacity, most of these will apply to you.

Injury and Illness Prevention Program (IIPP)
Required for every California employer under Cal/OSHA. Your IIPP must be written, site-specific, and actively implemented, not a template filed in a binder. It covers hazard identification, employee training, workplace inspections, incident investigation, and recordkeeping. This is the foundational safety document that Cal/OSHA inspectors ask for first.

• [ ] Written IIPP exists and is tailored to your facility
• [ ] Named responsible person is still at the facility and in that role
• [ ] Periodic review has been documented, with updates reflecting any changes to operations, hazards, or staffing
• [ ] Employees have received documented training on the plan

Hazardous Materials Business Plan (HMBP) / CERS
If your facility stores hazardous materials above threshold quantities, you’re required to have a Hazardous Materials Business Plan filed with your local CUPA (which may be a county environmental health department, fire department, or another local agency depending on jurisdiction) through California’s online reporting system, CERS. The plan includes your chemical inventory, site maps, emergency procedures, and emergency contacts.

• [ ] HMBP has been submitted to CERS and is current
• [ ] Chemical inventory matches what’s actually stored on site
• [ ] Site map reflects current facility layout (storage areas, exits, fire extinguishers)
• [ ] Emergency contacts listed are still at the facility and in those roles
• [ ] Annual certification has been completed

Hazard Communication / Safety Data Sheets (SDS)
If employees handle hazardous chemicals (which covers most industrial and commercial facilities), you need a Hazard Communication program. This includes maintaining current SDS for every chemical on site, labeling, and employee training on the specific chemicals they work with.

• [ ] SDS are on file for every chemical currently in use
• [ ] SDS inventory doesn’t include chemicals no longer on site
• [ ] Employees have received HazCom training specific to your chemicals
• [ ] Training has been delivered in a language your workforce understands

Training Records
California requires documented training for every EHS program that applies to your facility. This includes hazard communication, chemical handling, emergency procedures, and any program-specific training (lockout/tagout, forklift, respiratory protection, etc.).

• [ ] Training records exist for all required programs
• [ ] Records are current, not listing employees who have left
• [ ] Training content is specific to your site, not generic material
• [ ] New employees have been trained within required timeframes

Hazardous Waste / RCRA (Resource Conservation and Recovery Act)
If your facility generates hazardous waste (and most industrial and commercial operations do), you need proper handling, labeling, storage, and shipping practices. This is regulated by DTSC (the Department of Toxic Substances Control) at the state level and EPA at the federal level.

• [ ] Waste containers are properly labeled with contents and accumulation start dates
• [ ] Satellite accumulation areas comply with quantity limits
• [ ] Waste is being shipped within required timeframes for your generator status
• [ ] Manifests are complete, signed, and copies retained and filed with DTSC
• [ ] Waste has been properly characterized (tested if necessary)
• [ ] EPA ID number is current and associated with the correct facility name

Safety Programs (Cal/OSHA)
Beyond the IIPP, Cal/OSHA requires specific safety programs based on your operations. Common programs include the Emergency Action Plan, Fire Prevention Plan, Personal Protective Equipment assessments, and Code of Safe Practices. These must be written for your specific facility and actively followed.

• [ ] Emergency Action Plan is current with correct evacuation routes and contacts
• [ ] PPE hazard assessments have been completed for each job classification
• [ ] Required safety programs are written, site-specific, and implemented

Facility-Dependent Programs: These Depend on Your Operations

The programs below apply based on what your facility does, what equipment you operate, and what materials you handle. Not every facility needs all of them, but many facilities need more of them than they realize.

Lockout/Tagout (LOTO)
If employees service or maintain machines or equipment with hazardous energy sources (electrical, mechanical, hydraulic, pneumatic, thermal), you need written energy control procedures for each piece of equipment, not just a general policy.

• [ ] Written LOTO program exists with machine-specific procedures
• [ ] Authorized and affected employees have received documented training
• [ ] Annual periodic inspections of each procedure have been conducted

Stormwater / SWPPP
If your facility has industrial activities with exposure to stormwater, you may need enrollment under the Industrial General Permit through the State Water Board’s SMARTS system and a Storm Water Pollution Prevention Plan.

• [ ] Facility has determined whether the Industrial General Permit applies
• [ ] If enrolled: SWPPP is current, sampling is on schedule, annual report filed in SMARTS
• [ ] If not enrolled: a documented evaluation supports why enrollment isn’t required

Air Quality Permits
Operations that generate emissions (paint booths, solvent use, grinding, welding, combustion equipment) may require permits from the local Air District (AQMD or equivalent).

• [ ] Required permits to operate are in place and current
• [ ] Permit conditions are being met (emission limits, operating hours, recordkeeping)
• [ ] Any equipment changes or process modifications have been evaluated for permit requirements

SPCC (Spill Prevention, Control, and Countermeasure)
If your facility stores oil above federal threshold quantities, a SPCC plan is required. The plan must be current and the version kept on site must be the most recent.

• [ ] SPCC plan exists and reflects current operations
• [ ] The on-site copy is the current version (not an older revision)
• [ ] Required inspections and integrity testing are being performed and documented

Confined Space
If your facility has permit-required confined spaces, you need a written program covering entry procedures, atmospheric monitoring, rescue provisions, and employee training.

• [ ] Confined spaces have been identified and evaluated
• [ ] Written entry procedures exist for each permit-required space
• [ ] Entrants, attendants, and supervisors have received documented training

Respiratory Protection
If employees use respirators, whether required by the job or voluntarily, you need a written program including medical evaluations, fit testing, and training.

• [ ] Written respiratory protection program exists
• [ ] Medical evaluations and fit testing are current for all respirator users
• [ ] Employees have received documented training on use, limitations, and maintenance

Hearing Conservation / Sound Monitoring
If noise levels in your facility meet or exceed 85 dBA as an 8-hour time-weighted average, you need a hearing conservation program with exposure monitoring, audiometric testing, and hearing protection.

• [ ] Noise exposure assessment has been conducted
• [ ] If exposures exceed action levels: hearing conservation program is in place with annual audiometric testing

Wastewater Discharge Permit
Facilities that discharge to a sewer system may need an industrial wastewater discharge permit from the local sanitation district or regional water board.

• [ ] Facility has determined whether a discharge permit is required
• [ ] If permitted: self-monitoring reports are being submitted on schedule
• [ ] Permit conditions match current operations and discharge characteristics

Tiered Permitting
California’s tiered permitting system applies to facilities that treat hazardous waste on site. Requirements range from Conditionally Exempt to a full permit depending on the type and volume of treatment.

• [ ] Facility has evaluated whether any on-site activities constitute hazardous waste treatment
• [ ] If applicable: appropriate tier authorization is in place and conditions are being met

Additional Programs That May Apply

Depending on your operations, your facility may also need programs for carcinogen use, Form R / TRI reporting (EPCRA), chemical hygiene (for labs), Proposition 65 notifications, or industry-specific regulations. The list of what applies depends entirely on what your facility does, and part of a gap assessment is identifying requirements you may not know about.

Using This Checklist

This list covers the programs that CDMS evaluates most frequently across California industrial and commercial facilities. It’s not exhaustive. California’s regulatory landscape includes industry-specific and locality-specific requirements that go beyond what any checklist can capture. See the programs California facilities get cited for most →

California also enforces safety requirements beyond federal OSHA. See what makes Cal/OSHA different →

If your next step is preparing for a CUPA or fire department inspection, here’s what to expect →.

If you found yourself checking “not sure” on several items, or if you know a program exists but aren’t confident it’s current and implemented, that’s the gap between having documentation and having compliance. Read more about that distinction →

A gap assessment evaluates your facility against every regulatory program that applies to your specific operations, including ones that don’t appear on a general checklist. It’s the most efficient way to find out where you stand across the full picture.

← Back to EHS Gap Assessment & Compliance Audit Services