What’s in a Hazardous Materials Business Plan (HMBP)?

Most people who ask us what a Hazardous Materials Business Plan includes are trying to decide whether they can do it themselves. The form looks like a few fields and a chemical list. How hard can it be?

The answer is that an HMBP is not one document. It is a set of connected components that have to agree with each other and with your actual facility. The chemical inventory has to match the site map. The site map has to match what an inspector sees when they walk the floor. The emergency plan has to name real people and real equipment. When one piece is wrong, the whole submittal is exposed.

This page breaks down what each component requires, where facilities trip up, and what the preparation actually involves. For a broader overview of the requirement and how it gets filed, start with our Hazardous Materials Business Plan (HMBP) and CERS submittal services guide. Here we go component by component.

One terminology note before we start. The state and your CUPA call the report a Hazardous Materials Business Plan, or HMBP. CDMS delivers it as a Hazardous Materials Management Plan (HMMP): the full plan that satisfies the HMBP requirement plus the supporting documentation California and federal rules require you to keep on hand. We use “HMBP” throughout below, since that is the term you will see on CERS and from your inspector.

What You Submit Through CERS

Your HMBP is filed electronically through CERS, the state’s online environmental reporting portal, and reviewed by your local CUPA (which may be a county environmental health department, fire department, or another local agency depending on jurisdiction). The submittal is built from a set of required parts under California Health and Safety Code Chapter 6.95, Section 25500 and following. These are the components that make up the plan:

• Facility and business information. Legal business name, site address, mailing address, owner and operator contacts, and the people responsible for the plan.
• Business activities. A short profile of what the facility does, employee counts, operating hours, and which reporting programs apply to you (hazardous materials handling, hazardous waste generation, tanks, and so on).
• Hazardous materials inventory. Every reportable material on site, in the CERS format.
• Site map. A facility drawing showing where materials are stored and where emergency features are located.
• Emergency response and contingency plan. What happens, and who is called, when there is a release.
• Employee training program. How your people are trained to handle materials and respond to incidents.

The rest of this page walks through the four components that cause the most trouble: the inventory, the site map, the emergency plan, and training.

The Chemical Inventory

The inventory is the core of the HMBP and the single biggest source of work. Each reportable material gets its own entry in the CERS format, and each entry has more than a dozen required fields: the chemical or product name, the CAS number, whether it is a pure substance, mixture, or waste, the physical state, the hazard classes, the maximum and average daily quantities, the unit of measure, the type of container, and the specific location where it is stored.

The detail is where facilities get caught. Quantities have to be reported in the right units: liquids in gallons, solids in pounds, compressed gases in cubic feet. That sounds simple until you are holding a 450-pound drum of a liquid and have to convert it to gallons for the filing. The reportable thresholds are 55 gallons of a liquid, 500 pounds of a solid, 200 cubic feet of compressed gas, or any amount of an extremely hazardous substance above its threshold. Hazardous waste stored on site counts toward the same thresholds as any other hazardous material, and separate hazardous waste generator reporting in CERS may also apply. Some CUPAs want every material reported, not just those over threshold.

When we take over a facility’s CERS account, the most common thing we find is an inventory that looks complete and is not. The chemical names are there, but the hazard class and quantity fields are blank or years out of date. One college campus we inventoried had nearly 300 line items in CERS with the detail fields effectively empty. The list existed. The reportable data did not. For a deeper look at this component, see our guide to chemical inventory for CERS.

The Site Map

The site map is a scaled facility drawing that tells emergency responders where the hazards are before they go in. It has to show hazardous material storage locations, entrances and exits, evacuation routes, emergency equipment, and utility shutoffs. The locations on the map have to match the locations in the inventory, and both have to match the building.

That last point is what inspectors check. A map drawn from memory, or carried over from a layout that changed two reorganizations ago, is a finding waiting to happen. When we prepare a map, our consultant measures and verifies storage areas during the site visit rather than working from an old drawing. For what the map must show in detail, see HMBP site map requirements.

The Emergency Response and Contingency Plan

This component spells out what your facility does when a hazardous material is released or threatens to be. California requires it to cover immediate notification to local responders, your CUPA, and the Governor’s Office of Emergency Services; procedures to contain and clean up a release; and evacuation plans for the site.

The CERS emergency response form is detailed. It asks for a directory of more than a dozen emergency and agency contacts, a long checklist of the emergency equipment kept on site (safety gear, fire fighting equipment, spill control, communications), and, in California, an assessment of how an earthquake could affect your hazardous materials. Generic plans do not hold up here. The named coordinators have to be people who still work at the facility, and the listed equipment has to actually be on site. For the full breakdown, see our guide to HMBP emergency response plan requirements.

The Employee Training Program

Every facility with an HMBP has to train its employees on safe handling and on what to do in a release. The training has to be appropriate to your size and the materials you handle, and the records have to document the topics covered, the dates, and the names of the employees trained. California requires those records to be kept on site for at least three years and produced on request. For who needs training, how often, and what records inspectors expect, see our guide to HMBP training requirements.

HMBP Components at a Glance

Beyond the CERS Submittal: The Full Plan

The CERS filing is what your CUPA sees. The full plan you keep on site covers more. A complete HMBP program also includes your hazardous materials handling and storage procedures, your labeling program (NFPA, Proposition 65, container and tank labels, hazardous waste signage), your monitoring and inspection schedules, and your written Hazard Communication program under Cal/OSHA Title 8, Section 5194. These pieces are required by state and federal law even though they are not all uploaded to CERS, and an inspector can ask to see them when they walk the site.

This is why “the CERS fields are filled in” and “the facility is compliant” are not the same statement. The submittal is the visible part. The plan is the whole thing.

What Preparing It Actually Involves for You

Clients are often surprised by how little they have to do once the process starts. The work on your side is mostly handing over information: your previous HMBP if you have one, your Safety Data Sheets, a current list of chemicals with quantities and locations, your emergency coordinator contacts, facility drawings if any exist, and basic owner and billing details.

From there, our consultant comes to your facility. We verify the chemical inventory against what is actually on the shelves, map storage locations, and look for materials or conditions that change what you owe, such as a chemical that triggers a separate reporting program. We build the inventory and the map, develop the emergency plan around your actual people and equipment, prepare the full plan, and upload everything to CERS. The last step is yours: you log in and certify the submittal.

The reason professional preparation matters is not difficulty for its own sake. It is that the components have to be consistent and accurate, because that consistency is exactly what an inspection tests. An inventory that does not match the map, a map that does not match the floor, an emergency plan naming someone who left last year: each is a finding, and one finding usually invites a closer look at the rest. Getting the parts right the first time is what keeps an HMBP from turning into a violation later.