California HMBPs and Encamp

As a diverse industrial hub, California is host to numerous businesses that manage and utilize hazardous materials. While these materials are integral to the operations of many industries, from manufacturing and construction to oil, gas, and healthcare, they also present potential risks to public health, safety, and the environment.

To manage these risks, California has implemented the Hazardous Materials Business Plan (HMBP) program. This comprehensive state-mandated initiative is designed to ensure that businesses dealing with hazardous materials have robust emergency response and training plans in place.

This article provides an extensive overview of the HMBP program, discussing the thresholds for hazardous materials, the essential elements of an HMBP, the nuances from various jurisdictions, and the role Encamp plays in facilitating HMBP compliance for businesses.

The HMBP Program is an integral part of California's approach to protecting public health, safety, and the environment from the risks associated with hazardous materials. The program mandates that businesses have thorough plans in place that detail how hazardous materials are stored, handled, and disposed of. These plans also serve as essential information guides for first responders in case of emergencies, enabling them to respond in the safest and most effective manner.

The California Environmental Reporting System (CERS) acts as the central hub for HMBPs, allowing businesses to electronically submit their HMBP information. The Certified Unified Program Agencies (CUPAs) are responsible for the implementation and enforcement of the HMBP program at the local level.

While the HMBP does collect information about a facility's hazardous materials inventory (similar to other Tier II reports), it additionally collects other information, including:

For the HMBP program, reporting thresholds for hazardous materials are lower than the federal Tier II thresholds and those in many other states. To be required to submit an HMBP, a business must handle:

Additionally, many CUPAs require the inclusion of hazardous wastes in the HMBP. Generally, the threshold for reporting hazardous waste is the same as for standard hazardous materials, but some CUPAs require the inclusion of any amount of hazardous waste.

Compliance with HMBP does present several challenges to organizations. These include keeping up with regulatory changes, accurate identification and inventory management of hazardous materials, development and maintenance of a comprehensive HMBP, ensuring employee training, and navigating the variations in the implementation and enforcement of the HMBP Program by local CUPAs.

To make things even more challenging, every CUPA may have their own specific requirements, including:

Encamp is built to accommodate boilerplate HMBP requirements, as well as the various CUPA nuances seamlessly. The platform accounts for the different reporting deadlines and thresholds, as well as the requirements to report waste.

After submission, Encamp will manage any revisions and changes requested by CUPAs, ensuring your HMBP is accepted and compliant.

During the onboarding process, Encamp will request access to your CERS ID so that we can submit reports on your behalf.

Once access is requested, an email will be sent to the "Lead User" on the account. The "Lead User" will need to:

1. Log into CERS and hover over My Business and click on Manage People.

2. The lead user will see a menu similar to what is shown below. Encamp users will need access as an Approver in order to submit on the facility's behalf. Once Approver is selected, click Save.