EHS Compliance Checklist for California Industrial Facilities

Most facilities don’t realize how many separate programs they’re responsible for until something forces them to count. A change of ownership. An inspector who arrives with a clipboard. A new HR person who pulls open the binder and finds half of it missing. This checklist is the list we ask new facilities to walk through with us during setup. It covers the documents, plans, logs, and submittals that a California industrial facility typically needs to have in place, organized by regulatory area.

It’s not a substitute for an assessment. It’s a tool for self-identifying which programs apply to your operation, which are documented, and where the gaps are. For a complete overview of the service that maintains all of this on an ongoing basis, see our ongoing EHS compliance management guide.

How to Use This Checklist

Walk through it once with the people who would actually produce each document if an inspector asked. The plant manager, the EHS lead if you have one, the office person who keeps the permits. Mark each item: in place and current, in place but outdated, missing, or “not sure if this applies.”

The “not sure if this applies” answers usually outnumber the missing ones. That’s the most common pattern we see when we walk a facility for the first time, and it’s the most important pile to work through. Programs that don’t apply to your operation can be set aside. Programs that do apply but aren’t documented are where the inspection risk lives.

Hazardous Materials (CUPA Programs)

Your local CUPA, which may be a county environmental health department, fire department, or another local agency depending on jurisdiction, oversees most of the items in this section. Filings happen through CERS, the state’s online environmental reporting portal.

• [ ] Hazardous Materials Business Plan (HMBP) filed in CERS and current
• [ ] Chemical inventory matches what’s actually on site
• [ ] Site map shows current chemical storage locations, fire extinguisher placements, and emergency exits
• [ ] Emergency contacts list reflects current personnel (not someone who left)
• [ ] Employee training documentation for hazmat awareness on file
• [ ] Tiered permitting documentation if you conduct on-site treatment (PBR, CA, CESQT)
• [ ] CUPA fees paid and receipt on file

Hazardous Waste

Hazardous waste generation falls under DTSC (the Department of Toxic Substances Control) at the state level. Your CUPA inspects the storage areas.

• [ ] EPA ID number assigned and current (transferred if ownership changed)
• [ ] Generator status correctly classified (VSQG, SQG, LQG)
• [ ] Uniform Hazardous Waste Manifests on file for every shipment, signed copies
• [ ] Weekly hazardous waste storage area inspection log posted and completed
• [ ] Accumulation start dates marked on every container
• [ ] Container labels list contents, hazard class, and accumulation date
• [ ] Hazardous waste handler training records for required personnel
• [ ] Biennial Report submitted (LQGs and applicable SQGs, by March 1 of even-numbered years)
• [ ] DTSC hazardous waste generator fees paid
• [ ] Universal waste handling procedures and storage logs (batteries, lamps, electronics)
• [ ] SB14 Source Reduction documents if you’re a qualifying generator

Workplace Safety (Cal/OSHA)

California Cal/OSHA enforces Title 8 of the California Code of Regulations. The written programs below are the ones inspectors most often ask to see first.

• [ ] Injury and Illness Prevention Program (IIPP) written, current, accessible
• [ ] Workplace Violence Prevention Plan (WVPP) under SB553, with annual review and training
• [ ] Heat Illness Prevention Plan if employees work outdoors or in heat-exposed areas
• [ ] Hazard Communication Program with current SDSs for every chemical on site
• [ ] Lockout/Tagout (LOTO) procedures, written and equipment-specific
• [ ] Confined Space Entry program if applicable, with permit logs
• [ ] Respiratory Protection Program if respirators are required
• [ ] Forklift operator certifications current, daily inspection log posted
• [ ] Annual training records for each required topic, signed and dated
• [ ] First aid and emergency procedures posted and current

Stormwater

Industrial facilities subject to the General Industrial Activity Stormwater Permit file and report through SMARTS, the state’s online stormwater portal.

• [ ] Notice of Intent (NOI) or No Exposure Certification on file
• [ ] Stormwater Pollution Prevention Plan (SWPPP) written and current
• [ ] Quarterly visual observations logged
• [ ] Rain event sampling completed during the wet season
• [ ] Annual report filed in SMARTS by July 15
• [ ] BMP inspection logs posted and completed
• [ ] SWPPP team and responsibilities documented

Air Quality

Your local air district (AQMD, BAAQMD, SCAQMD, or the equivalent for your region) issues permits and collects emissions reports.

• [ ] Permits to operate on file for every regulated source (boilers, generators, paint booths, abrasive blasters)
• [ ] Permit renewal dates tracked, fees paid
• [ ] Annual Emissions Report (AER) filed for the applicable inventory year
• [ ] AB 2588 toxic emissions inventory updated on the district’s cycle
• [ ] Permit-specific record-keeping logs (hours of operation, fuel usage)

Wastewater Discharge

If you discharge industrial wastewater to the sewer, your Regional Water Quality Control Board or local sewer authority sets the rules.

• [ ] Industrial wastewater discharge permit on file
• [ ] Monitoring and sampling records per permit terms
• [ ] Slug discharge control plan if required by your permit
• [ ] Pretreatment system maintenance and inspection records

Tanks

Aboveground storage tanks fall under APSA (the Aboveground Petroleum Storage Act); underground storage tanks have their own program. Both are inspected by your CUPA.

• [ ] SPCC plan written and certified if your aggregate AST capacity exceeds the threshold
• [ ] Tank list (capacity, contents, age, construction) current
• [ ] Monthly visual tank inspections logged
• [ ] Annual integrity inspections completed where required
• [ ] UST monitoring records, leak detection, and Designated Operator inspections if you have underground tanks
• [ ] Tank registrations updated in CERS

New to this? What EHS compliance management actually covers →

Cross-Program Records

Some documents apply across multiple programs. These are the ones inspectors from any agency will often ask for.

• [ ] Facility drawings showing current layout, storage areas, drains, and emergency equipment
• [ ] Emergency coordinator and after-hours contact list, current
• [ ] All employee training records consolidated and accessible
• [ ] Inspection logs posted at the work area (not stored in a filing cabinet)
• [ ] Permit and registration fees paid, receipts on file
• [ ] DOT hazardous materials registration if you ship or transport hazmat

What to Do When You Find Gaps

A blank checklist isn’t a failure. It’s a baseline. The question is what to do with the missing items.

Three patterns we see most often:

You have most of it, but pieces are outdated. Plans are on file, but the chemical inventory is two years stale, the IIPP names a safety coordinator who left, and the SWPPP map doesn’t match the current site layout. This is the most fixable category and the most common.

You have a few programs in place and don’t know which others apply. Common after an acquisition or a build-out. The path forward is an assessment that documents which programs your operation actually triggers and which you can stop worrying about. See our EHS gap assessment for the structured version of this conversation.

You have plans, but no one is tracking the deadlines. A current IIPP is worthless if the annual training didn’t get scheduled. A filed HMBP doesn’t help if the resubmittal date passed. This is where a managed compliance calendar does the work that a checklist alone can’t.

The checklist surfaces what’s missing. Closing the gaps is the work that follows.

Next Steps

If this checklist showed you more open boxes than closed ones, the practical next step is a conversation. Tell us what your operation looks like and what came up on the list. We’ll help you figure out whether what you need is a project to close specific gaps, a structured assessment to map the full landscape, or an ongoing engagement to keep all of it current.

Run a manufacturing facility? EHS compliance for California manufacturers →