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Thursday, February 12, 2015

Hazardous Materials Business Plans 101

The Hazardous Materials Business Plan program was established in 1986 by legislation at both the federal level (Code of FederalRegulations Title 40, Chapter I, Subchapter J, Part 370 and Title 42, Chapter116, Subchapter I, Section 11002) and the state level in California (Health andSafety Code Sections 25500 – 25519 and California Code of Regulations, Title 19, Division 2, Chapter 4, Article4).  It’s primary purpose is to reduce the risk of a hazardous materials release that would harm public health and safety or the environment, while at the same time satisfying public right-to-know laws.  Any business that stores hazardous materials in amounts equal to or greater than the following limits must have a hazardous materials business plan (HMBP):
  • 55 gallons of a liquid; 
  • 500 pounds of a solid;
  • 200 cubic feet of a compressed gas.

Also included would be any extremely hazardous substance over its threshold planning quantity as described in 40 CFR, Part 355, AppendixA.  This last list would not be as applicable to water related businesses, except that it does include chlorine.  So if you use chlorine gas that would certainly apply to you. 
So what is a hazardous material?  The California Health and Safety Code lists a hazardous material as anything that, “because of its quantity, concentration, or physical or chemical characteristics, poses a significant present or potential hazard to human health and safety or to the environment if released into the workplace or the environment, or a material specified in an ordinance.”  That’s a pretty all encompassing definition that could make anything hazardous.  Thankfully, there are some more definitive lists that you can turn to such as:

An HMBP is the document which contains detailed information on the storage of those hazardous materials.  One is required for each location where hazardous materials are stored.  If a business has multiple locations where hazardous materials in excess of the storage limits listed above are stored or used, then a separate HMBP must be completed for each of those sites.  The HMBP must contain:
Business Activities – this section details what activities are engaged in at the site that involves hazardous materials.
Business Owner / Operator Identification – identifies the owner/operator of the facility along with emergency contact information.
Hazardous Materials Inventory – a one page document required for each hazardous material stored at that individual location.
Site Map – A map of the site showing specifically where the hazardous materials are stored, including:
  • the outline of any buildings
  • site orientation (North arrow)
  • loading areas and parking lots
  •  internal roads
  • storm and sewer drains
  •  adjacent property uses
  • adjacent streets, alleys, or other access
  • access and egress points
  • evacuation routes
  • staging areas
  • fire hydrants. 
  • fire extinguishers
  • emergency shut-down systems for electrical and other equipment
  • the storage location for the HMBP

 Emergency Response Plan – includes the action to take in case of emergency; local utility information; local medical provider information; emergency equipment available on-site; and emergency contact information.
Employee Training Plan – describes the training provided to facility personel to make them aware of the hazardous materials being stored and used on-site, as well as the training provided for emergency response.
Other documents may also be included depending upon the type of material being stored, such as if you have underground fuel storage tanks.

For those Certified Unified Program Agency’s (CUPAs) utilizing the California Environmental Reporting System (CERS), all of these forms and the information needed to help you fill them out is located at www.cers.org.  For those few CUPAs that utilize their own electronic reporting system, you can obtain all the required forms from them.  Check with your CUPA to see if they are participating in CERS.
An HMBP must be updated within 30 days of any changes being made to any of the information contained in the various sections.  An annual certification must also be made that the HMBP is current and up to date.  These certification can be made through the CERS website, or you local CUPAs electronic portal.

There is a great deal of valuable information contained in a hazardous materials business plan that can help prevent hazardous materials releases or mitigate their impacts, as well as being of help to first responders on the scene of an emergency at a facility that stores hazardous materials.  But like anything else, they are only any good if the information they contain is up to date and accurate.  If you need any help with HMBPs or dealing with hazardous materials in general, please contact me at Patrick.vowell@wework4water.com, and I’d be happy to help.
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