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Proactively Managing Your Hazardous Materials Business Plan

March 1 may be the end of the submission period for Hazardous Materials Business Plans (HMBPs) in California, but it is merely the start of your hazardous materials compliance journey.

Continuous tracking and inspections are required to fulfill the purpose of these disclosures, which are intended to support fire authorities’ emergency response strategies at your facility. In this article, learn about best management practices for implementing your Hazardous Materials Business Plan (HMBP) and steps for success for your retail or hospitality business.

Regulations for Hazardous Waste and Materials

Submitting an effective HMBP in California is more than a box checking exercise; it serves to mitigate risks for emergency response and creates awareness for potential hazards. HMBPs are a legal requirement for all California businesses handling hazardous materials above a specific threshold (55 gal. for liquids, 500 lbs for solids, and 200 ft3 for compressed gases) to submit detailed hazardous materials inventories, and emergency response plans; implement employee training; and more.

According to Assembly Bill 1429, all business owners and operators must annually review and certify that HMBP information in California Environmental Reporting System (CERS) is complete, accurate, and compliant with Emergency Planning and Community Right-to-Know Act reporting requirements (if applicable) or within 30 days of any of the following changes:

  • 100% increase of previously disclosed hazardous materials (except in San Francisco, where the threshold is 50%)
  • Previously undisclosed hazardous materials
  • Change of business information/name
  • Substantial change in handler’s operation

Failing to update plans or overlooking critical changes to materials or procedures can lead to severe penalties and, more importantly, increase risk to the environment and human safety.

Best Management Practices for Hospitality and Retail

For the hospitality and retail sectors, the constant flux of material inventory, high-employee turnover, as well as numerous locations in different jurisdictions, create unique challenges. Similar to the fast-paced, dynamic nature of these industries, these plans must evolve in tandem to reflect current business realities.

Creating an effective, comprehensive HMBP not only satisfies legal and regulatory requirements but also promotes a culture of safety and responsibility within your business. Consider these additional steps to ensure your HMBP is up to date and accurately reflects the operations of your facility:

  • Regular Reviews: Hazardous materials and waste covered by HMBPs include personal care products, cleaning and disinfectant products, laundry supplies, diesel fuel for emergency generators, batteries for battery-powered equipment, and more. Routine self-audits and inspections are a useful way to assess the level of compliance with HMBP requirements for these materials and identify any changes or updates that need to be made.
  • Employee Training and Accountability: Implementing environmental, health, and safety programs around hazardous waste and materials may require a shift in internal culture and practices. Appoint and train an HMBP coordinator who can understand and communicate the plan’s details to relevant employees. Employee responsibilities may include identifying hazards, spill reporting protocols, emergency response procedures, etc.
  • Collaborate for Compliance: Seek feedback from employees and local authorities on your HMBP and consider joining industry groups to share best practices for managing hazardous materials. These groups may have valuable insights or suggestions for improvement that can enhance the effectiveness of your hazardous materials management plan.
  • Stay Informed: Keep up to date with changes in regulations and requirements related to hazardous materials management. Attend workshops, seminars, and training sessions to stay informed and ensure your plan remains compliant.

Ensure Your Compliance with APTIM

Moving forward from the submission of your HMBP, it is important to bridge the gap between written intentions and on-ground reality. With APTIM’s 30+ years of experience supporting clients on environmental, health, and safety, our environmental compliance team can support stringent safety measures and efficient response protocols, including:

  • Data Tracking: Maintain critical hazardous materials and hazardous waste data and verify that information is up to date.
  • Audits: Complete weekly hazardous waste storage area audits and correct areas of noncompliance.
  • Recordkeeping: Organize manifests, audits, and inspections physically and electronically in compliance with local CUPA requirements.
  • Training: Verify employees have completed all required trainings for hazardous materials and waste management.

Learn more about APTIM’s environmental compliance and consulting services.

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