California SB 14: Full Plan vs. Small Business Checklist
If your California facility generates more than 12,000 kg of hazardous waste per year (or more than 12 kg of extremely hazardous waste per year), you owe a Senate Bill 14 source reduction plan.
If your California facility generates more than 12,000 kg of hazardous waste per year (or more than 12 kg of extremely hazardous waste per year), you owe a Senate Bill 14 source reduction plan. But “the plan” is not one document. SB 14 has three different paths, and which one applies to your facility depends on your size, your generation profile, and whether the law applies in the first place.
This piece walks through the three options, what each one includes, and what to expect if you have already drafted something yourself and just need a review and certification.
For the broader regulatory background (cycle years, deadlines, what gets retained on site, who enforces), see our SB 14 waste minimization plan guide.
The Three Paths
| Full Plan | Small Business Checklist | “NO” Determination | |
|---|---|---|---|
| Who qualifies | Generator over the SB 14 threshold | Small business per California Government Code §11342 over the SB 14 threshold | Generator below the SB 14 threshold |
| Source Reduction Evaluation Review and Plan (SRERP) | Required | Replaced by a Compliance Checklist | Not required |
| Hazardous Waste Management Performance Report | Required | Required (may substitute most recent Biennial Report) | Not required |
| Summary Progress Report (SPR) | Required | Required | Not required |
| Environmental Professional certification | Required | Required | Recommended on a signed “NO” determination letter |
| Where it lives | Retained on site, available on CUPA inspection | Retained on site, available on CUPA inspection | Retained on site in the same binder your plan would occupy |
| Submitted to DTSC | No | No | No |
CUPA (your local hazardous waste regulator, which may be a county environmental health department, fire department, or another local agency depending on jurisdiction) and DTSC (the state Department of Toxic Substances Control) can ask to see whichever document applies to your facility. The plan or letter does not get filed. It gets produced.
When the Small Business Checklist Applies
California Government Code §11342 defines a small business as one that is:
- Independently owned and operated
- Not dominant in its field of operation
- Manufacturing with fewer than 250 employees, or
- Services with under $2 million in annual gross receipts
If you cross the SB 14 threshold (over 12,000 kg/year hazardous waste, or over 12 kg/year extremely hazardous waste) and you also meet the small business definition, you can use the abbreviated Compliance Checklist in place of the full Source Reduction Evaluation Review and Plan. You still prepare a Performance Report and a Summary Progress Report, but the Checklist replaces what is otherwise the most labor-intensive piece of the package.
One useful detail: the Checklist allows you to substitute your most recent California Biennial Hazardous Waste Report for the Performance Report. If you have already filed a biennial, much of the underlying data is reusable.
The Checklist is still certified by an Environmental Professional and retained on site for CUPA inspection. It is not submitted to DTSC.
When You Need the Full Plan
If you are over the SB 14 threshold and do not meet the small business definition, you owe a Full Plan. The package has three documents:
Source Reduction Evaluation Review and Plan (SRERP):
process block diagrams, waste stream identification (every stream over 5% of your total hazardous waste volume gets detailed evaluation), evaluation of source reduction measures across five approaches (input changes, operational improvements, production process changes, product reformulation, administrative steps), an implementation timetable, and a numerical reduction goal.
Hazardous Waste Management Performance Report:
measures generation against the baseline year set in your prior plan.
Summary Progress Report (SPR):
summarizes progress against the goals set in the previous cycle’s plan.
All three are certified by a qualified Environmental Professional. None are submitted. They live in a binder on your site, available when CUPA or DTSC asks.
When SB 14 Does Not Apply: The “NO” Letter
If your facility generates under the SB 14 threshold, you do not owe a plan. But “we don’t think we generate enough” is not a defensible answer if DTSC asks. The defensible answer is documentation that you ran the numbers correctly, including the parts of your operation that most facilities forget to count.
When CDMS handles a not-applicable determination, the output is a signed “NO” letter that walks through the calculation and confirms SB 14 does not apply. That letter goes in the same binder where your plan would otherwise live. If a CUPA inspector or DTSC asks for your SB 14 plan, you hand them the letter.
The most common reason facilities miscalculate the threshold is wastewater. SB 14 measures hazardous waste at the starting point, before any on-site treatment, recycling, or discharge. Hazardous wastewater counts even if it is treated to non-hazardous before discharge. Aqueous hazardous waste undergoing on-site treatment counts if you generate over 3,100 gallons per year. Many generators undercount because they only count what leaves the facility on a manifest.
The Review Engagement: When You Have Already Drafted Something
A common scenario: a facility’s EHS or operations contact prepares the plan internally, runs the calculations, drafts the documents, and then realizes the technical and financial certifications need to be signed by a qualified Environmental Professional. The request that comes in usually sounds like: “I prepared everything. I just need someone to verify my calculations and sign the certifications.”
This is a legitimate path, but it is not a paperwork exercise. The Environmental Professional certifying the plan has to verify the calculations and walk the processes described in the document. We do not sign plans we have not checked.
CDMS handles these engagements in two stages so you only pay for what you actually need:
Stage 1: review and deficiency list.
We request the editable Word version of your draft (not a PDF), perform a desk review against the SB 14 requirements and DTSC’s Source Reduction Guidance Manual, walk your facility to verify the processes described in your block diagrams and waste stream calculations, and deliver a written deficiency list. If your plan is solid, the list is short and the path to certification is clear. If it has substantive gaps, you know what those gaps are before deciding how to spend the next dollar.
Stage 2: corrections and certification.
Under a separately scoped engagement, we make the corrections, finalize the documents, and certify the plan. You only commit to Stage 2 after you have seen what came out of Stage 1.
Deficiencies We See Most Often in Self-Prepared Plans
When we walk a self-prepared SB 14 plan, the issues are usually the same handful:
- Wastewater excluded from the generation total. The most common one. Plans that count only manifested waste understate generation and sometimes claim the wrong status (Small Business Checklist when a Full Plan applies, or a “NO” determination when the threshold is actually crossed). For facilities with significant process water, the wastewater discharge and waste determination decision often drives the SB 14 calculation too.
- Major waste streams aggregated in ways that hide individual contributors. The 5% rule (any stream over 5% of total generation must be evaluated in detail) gets misapplied when similar streams are lumped together.
- A source reduction evaluation that does not actually evaluate. The plan lists candidate measures but never runs them through the seven evaluation criteria from the DTSC guidance manual. The evaluation is the plan, not an appendix to it.
- No clear baseline year, numerical goal, or implementation timetable. The plan describes what could be done but never commits to measurables or dates. A generator can amend the implementation schedule later without penalty, but the plan has to set one in the first place.
- PDF instead of editable Word. Standard CDMS policy on any review: we cannot meaningfully redline or correct what we cannot edit. Send the Word version.
The status decision (Full Plan vs. Checklist vs. “NO”) often hinges on whether the generator qualifies as a Large Quantity Generator under California rules. If you have not worked through that question yet, our Do You Have to File a Biennial Report? Understanding LQG Status piece walks through the threshold logic and ties back to SB 14 applicability.
For the full picture of where SB 14 sits in the broader California hazardous waste management lifecycle (EPA ID, biennial, training, storage, shipping, minimization), start at the pillar.
Trusted throughout California
BSY started working with CDMS last year after our in-house EHS person departed the company. CDMS reviewed our existing operational permits as well as any additional Federal, State and Local regulations that could apply and helped us to create a comprehensive compliance calendar to track regulatory deadlines and submittal due dates. The CDMS team does an excellent job of tracking everything and can be relied upon to complete the forms accurately and assist with submittals, allowing me to focus on our business.
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