Avoid CUPA Violations

Blog, Env Newsletter

By Mabelle Wongsanguan

In California, governmental agencies designated as a Certified Unified Program Agency (CUPA) are authorized to apply statewide standards to each facility within its jurisdiction that treats on site or generates hazardous waste, stores hazardous materials, or operates underground storage tanks. These facilities are considered regulated businesses and must submit a Hazardous Materials Business Plan (HMBP) annually by March 1st on the California Environmental Reporting System (CERS). HMBPs assist emergency responders in planning and handling emergencies that involve hazardous materials. Accurate HMBPs help reduce the risks of harm and injury for emergency responders and minimize property loss.

Common Mistakes that lead to violations include (but are not limited to):

  1. Exceeding the Reportable Threshold for Hazardous Materials
    It is important to keep track of inventory at your facility, particularly those that are hazardous. Reportable thresholds for hazardous materials (which includes hazardous waste storage) are:
    Solid: 500 pounds
    Liquid: 55 gallons
    Gas: 200 cubic feet
    If any material stored, handled, or used at the facility exceeds the reportable thresholds at any time throughout the year, the facility must obtain a CUPA permit and submit a HMBP.
  2. Improper Storage of Hazardous Materials
    All hazardous materials stored at a facility must be kept on or within a secondary containment to avoid releases. Containers storing hazardous materials must be in good condition with the contents clearly legible.
  3. Improper Labeling of Hazardous Wastes
    All hazardous wastes stored at the facility must be labelled with the yellow hazardous waste sticker. Ensure that the contents of the sticker are filled out accurately. The most common mistake is not putting an accumulation start date.
  4. No EPA Identification Number
    Facilities that treat, store, dispose, or transport hazardous waste must obtain an EPA ID. The EPA ID is also needed for the hazardous waste label.

There are multiple violations CUPAs can cite facilities for. Our services include performing site inspections to ensure your facility is compliant with the rules and regulations as well as preparing HMBPs for submittal. If your facility requires assistance with this process, please do not hesitate to contact us.