Hazardous Materials Business Plans (HMBPs)
due March 1
By: Arthur Mahoney, M.S., CHMM, REA
January 16, 2013
Hazardous
Materials
Business Plans
(HMBPs) due
March 1
Many of you will
likely need to
update or
certify your
HMBP soon (March
1 for
most
regulators). As
a reminder, the
HMBP must be
updated
within 30 days
of a significant
change in
operation, which
includes
handling of a
new
unreported
hazardous
material,
a
significant
changein the
quantity
of a previously
reported
hazardous
material, or a
change in
business name or
ownership.
For many of you
this will may
also be your
first experience
to
electronically
submit your HMBP
into the
California
Environmental
Reporting System
(CERS) or to
another
electronic
system operated
by your CUPA.
HMBP
Basics
Per
California
law
(H&SC
25503.5),
businesses
are
required
to
prepare
a HMBP
if they
meet any
of the
following
reporting
thresholds
at any
one time
during
the
year:
Hazardous
materials
at or
above
55 gallons
(liquids),
500 pounds
(solids),
and/or
200 cubic
feet
(compressed
gases)
Extremely
hazardous
substance
at a
threshold
planning
quantity
Radioactive
material
at a
quantity
requiring
an
emergency
response
plan
There
are some
exceptions,
for
example:
consumer
products,
gases
used by
medical
practitioners, small
propane
tanks.
Depending
on your
CUPA,
you may
have
lower
reporting
thresholds.
For
example,
San
Mateo
County
Environmental
Health
Services
Division,
require
a HMBP
for
any
amount
of
extremely
hazardous
substance
(including
chloroform,
sulfuric
acid,
nitric
acid)
or radioactive
material.
Additionally,
the City
of Palo
Alto
has no
thresholds
for
inventorying
hazardous
chemicals
(meaning
irregardless
of the
container
size it
must be
accounted
for).
Annually
HMBPs
are
required
to be
updated
or
certified
accurate.
As a
reminder,
if your
business
is
located
on
leased
or
rented
property,
you are
required
to
notify
the
property
owner
that your
business
is
subject
to the
HMBP
requirements
and has
prepared
a HMBP.
You must
also
provide
the
property
owner a
copy
within
five
working
days if
requested
to do
so.
Electronic
Reporting/
CERS
Also you
may have heard
that starting
in
January
1, 2013,
businesses
will be
required
to
submit
their
HMBP
electronically
to the
California
Environmental
Reporting
System
(CERS)
or to
another
local
system.
Even
uploading
an
existing inventory
into CERS
can be a
very
time-consuming
project.
Each
chemical
item
requires
70
fields
of data!
HMBP,
CERS and
Associated Services
HMBP
Preparation:
We
can
assist
you
by
preparing
all
of
the
required HMBP
materials:
Site
and
Storage
maps
(which
include
a grid
system
on
the
maps,
which
most
regulators
now
request)
Chemical
and
waste
information
Emergency emergency
response
plan
(tailored
to
your
facility
and
operations)
Employee
training
plan
Inspection
checklists
We
can
also upload
your HMBP
and
chemical
inventories
into
online
databases
(e.g.,
CERS)
-making
your
facility
information
more
accessible
to
your
emergency
responders.
Chemical
Inventory
Collection
and
Bar
Coding
Services:
As
part
of
our services, we
can
collect
your chemical
inventory
and
even
attach
barcodes
to containers
if
so
desired. A
physical
collection
of
your
inventory should
be
obtained
at
least
every
year
or
two
(possibly
more
frequently
if
your
inventory
has
changed
significantly). As
you
may
know
from personal
experience,
inventory
collection can
be a
time-consuming process
and
often
requires
the
help
of outside
resources
-this
is
where
we
can
help.
Included
in
this
service
we
can
even
identify
expired
chemicals
that
may
become
very
dangerous (e.g.,
peroxide
formers)
and
exceedingly
expensive
to
discard.
EH&S
Manager
Software
/
Seamless
Integration
into
CERS:
We
use
and
also license
our
proprietary
chemical
inventory
database
software
-
EH&S
Manager.
We
can either
import
existing
chemical
inventories
(e.g.,
from
an
Excel
spreadsheet
or
other
database
programs)
into EH&S
Manager
or
enter
your
inventory
into
our
product
as
it
is
collected.
An
added
benefit
of
EH&S
Manager
is
the
seamless
integration
into
CERS. Files
are
exported
into
CERS
from
our
database
without
hassle. We
have
assigned
hazard
classes
to
over
12,000
substances-saving
you
countless
hours
of
staff
or
consultant
time
doing
this
important,
but
time-consuming
step.
Additionally, EH&S
Manager
allows
you
to identify
regulated
chemicals
in
your
inventory. The
following
is a
list
of
some
of
the
regulated
chemicals
in
our
database.
Proposition
65
chemicals
OSHA-regulated
carcinogens
Extremely
hazardous
substances
(EHS)
Department
of
Homeland
Security
Chemicals
of
Concern
DEA
controlled
substances
and
precursors
California
controlled
substances
and
precursors
Select
agents
and
toxins
Related Services:
We can assist with chemical safety audits, storage assist, spill cleanup material selection and other chemical safety related topics.
EH&S
Manager
evens
provides
access
to
electronic
Material
Safety
Data
Sheets
(MSDSs)
which
are
directly
linked
to
chemicals
in
your
inventory.
Other
products
provide
these
services,
but
at a
much
higher
cost.
An Easy
Way to Act
Contact
me and I
would be happy
to provide you a
quotation for
any of our
services.
Other
commonly
requested
services
include:
EHS
training (in
person, live
webinar, or
hosted
learning
management
system)
Onsite
support at a
frequency to
meet your
needs
IATA and
DOT
hazardous
materials
shipping
compliance
assistance
and training
Chemical
safety
audits
Hazardous
waste
auditing,
minimization
and
reporting
Bloodborne
Pathogens
(annual
requirement)
Hazard
Communication
Chemical
Hygiene
Plan
General
Safety
Laser
Safety
Biological
Safety
Radiation
Safety
Many
others,
please
contact me
Served
by an Expert
Arthur Mahoney,
Principal
Consultant
MS, CHMM,
REA
For over 20
years, he
has
been assisting
public and
private
companies to
comply with
safety,
hazardous
material
management,
transportation
and safety
concerns. He
has trained
hundreds of
employees on
hazardous
materials
shipping and
safety
topics and
also trains
safety
professionals
preparing
for the CHMM
credential
exam. He
also
provides
chemical
inventory
database
services.
Feel free to
contact
me at
650-347-0417
or by
email.
Sincerely,
Arthur Mahoney
Hazard Solutions
LLC
Disclaimer:
The
information
presented
in this
email
should
not be
construed
in any
way as
legal
advice
or an
interpretation
of the
regulations.
It is
meant to
provide
basic
information
about
topics
that may
affect
clients
and
colleagues.
