Hazardous Material Business Plans
What is a Hazardous Materials Business Plan?
Hazardous Materials Business Plans (HMBP's) exist in order to provide the public, emergency responding agencies, and local government agencies information regarding the potential for hazardous chemical situations in the community. HMBP's aid in:
Emergency planning
Emergency release notification
Chemical storage reporting
Toxic chemical release inventory reporting.
A business is required to have an HMBP if its inventory of hazardous materials exceeds any of these threshold quantities:
Solids - 500 lbs. or more
Liquids - 55 gallons or more
Compressed Gasses - 200 Cubic Feet or more
Extremely Hazardous Substances - Applicable Federal threshold quantities for extremely hazardous substances are specified in 40 CFR Part 355, Appendix A or B
Radiological Materials - Quantities for which an emergency plan is required are specified in 10 CFR Parts 30, 40, and 70 .
The HMBP contains detailed information on the storage of hazardous materials at regulated facilities. The purpose of the HMBP is to prevent or minimize damage to public health, safety, and the environment, from a release or threatened release of a hazardous material. The HMBP also provides emergency response personnel with adequate information to help them better prepare and respond to chemical-related incidents at regulated facilities. When completed, your HMBP will become a valuable tool, aiding you and your employees to manage emergencies at your facility.
On-line Submittals and CERS
In California, HMBPs are submitted online using the California Environmental Reporting System (CERS). The online system requires that the following elements be uploaded to complete your HMBP.
Emergency Response and Training Plans (Emergency Response Contingency Plan and Employee Training Plan)
Hazardous Materials Inventory (Spreadsheet of Chemicals with quantity, location, and hazard identification as well as a site map)
Facility Information (Business Activities and Business Owner/Operator Identification)
CERS encourages businesses to utilize the instructions and templates on their website to develop the HMBP documents that you will have to upload into the CERS web application. There may be additional local requirements, check with your CUPA.
As of 2015, the entire Hazardous Materials Business Plan (HMBP) is required to be submitted annually pursuant to California Health and Safety Code (HSC) Chapter 6.95 section 25508(a)(1)(A). CUPAs can set the business annual reporting anniversary date; however, if they do not the default reporting date is on or before March 1. Failure to electronically report as required may result in administrative, civil, and criminal penalties.
New Updates to CERS and HMBPs
Effective December 28, 2017, CalEPA is replacing the existing five (5) federal hazard categories available in CERS used for the completion of chemical inventories as part of the annual hazardous materials business plan submittal with twenty-four (24) new federal hazard categories adopted by the United States Environmental Protection Agency (U.S. EPA) as a result of changes to the Occupational Safety and Health Administration (OSHA) Hazard Communication Standard (HCS). These new categories are easily located on the Safety Data Sheet for each chemical in your HMBP that should already be maintained by your company.
Contact Brianne Archer at Waterstone Environmental if you need any assistance submitting or updating your HMBP.
