Hazardous Material Inspections
In our last post, we discussed environmental agencies you will commonly interact with if your business participates in regulated activities in California. This post provides more detail on what to expect when your local CUPA inspects your facility for compliance with hazardous material regulations.
Inspection Frequency and Authority:
Your CUPA is required to inspect your site every three years, unless you have an underground storage tank. In which case, inspections will be yearly and will usually co-occur with the UST monitoring system certification test. If you have a UST, you should be ready to have a complete facility inspection every year. Also, be aware that these are minimum inspection frequencies. Agencies can choose to inspect more frequently for whatever reason, if they so choose.
You are required to provide access for CUPA inspectors. Inspection authority is granted by various sections of the California Health and Safety Code and the California Code of Regulations.
Hazardous Material Storage Facility Requirements:
Here is a list of documents you should have available and posted to your California Environmental Reporting System (CERS) account:
Disclosure of business activities that are regulated by the CUPA
Hazardous Materials Business Plan that includes:
Records of training program implementation (three years of annual training records)
Safety Data Sheets for all items on the chemical inventory. (Do not post to CERS.)
Bonus points if you post, by the phone, a one page version of the emergency response plan with contact numbers and the site.
In addition, the inspector will physically inspect your site and compare your written chemical inventory and site map to what is on-site. If there are discrepancies, you will be asked to correct them and may be issued a citation. In addition, chemicals must be stored in labeled containers that are compatible with their contents. Chemicals with the potential to react with one another should be stored separately.
Hazardous materials are also regulated by other agencies, like the fire marshal. You should be familiar and compliant with those requirements as well.
Next, Part 2: Hazardous Waste Facility Requirements