EH&S Compliance, Training and Data Management Solutions

Hazardous Materials Business Plans (HMBPs) due March 1

By: Arthur Mahoney, M.S., CHMM

January 16, 2015

If you haven't already done so in the last few months, you will likely need to update or certify your HMBP soon as part of the annual reporting requirement. 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 change in the quantity of a previously reported hazardous material, or a change in business name or ownership

HMBP Basics

Per California law (H&SC 25507), 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

Recent changes to California law might affect your facility. Changes include new exceptions and revised reporting requirements for materials such as: consumer products in a retail establishment, refrigerants in closed systems, specified medical gases, small propane tanks, inert asphyxiate gases and more.

Depending on your regulator, you may have lower reporting thresholds.

San Mateo County Environmental Health Services Division, requires reporting of any amount of extremely hazardous substance (including chloroform, sulfuric acid, nitric acid) or radioactive material.
City of Berkeley requires reporting all hazardous materials and hazardous wastes if at any time during a year the combined total exceeds 500 pounds (solid); 55 gallons (liquids); or 200 cubic feet (gases)
Livermore -Pleasanton Fire requires reporting any amount of highly toxic, toxic, and moderately toxic gases
San Leandro and Los Angeles Fire requires reporting any hazardous materials which exceed a Fire Code permit amount.
San Francisco City and County reporting requirements for laboratories are 100 milliliters for liquids, 25 grams for solids and 10 cubic feet for gases.

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

Businesses are now required to submit their HMBP electronically to the California Environmental Reporting System (CERS) or to another local system.

If you have tried to upload an inventory into CERS yourself, then you know first hand how time-consuming it can be. Each chemical item requires 70 fields of data! We can assist in this process and save you a lot of time and headaches.

HMBP, CERS and Associated Services

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.

Related Services:

We can assist with all aspects of laboratory safety, including: lab safety audits, chemical safety training (done by chemists), storage assistance, protocol development, PPE selection, spill cleanup material selection and other safety related topics.

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
Hazardous Waste Operations and Emergency Response (HazWOPER)
General Safety
Laser Safety
Biological Safety
Radiation Safety
Many others, please contact me

Served by an Expert

Arthur Mahoney, Principal Consultant

MS, CHMM

For over 20 years, he has been assisting public and private companies to comply with safety, hazardous material management, transportation and safety concerns. He currently serves on the California HMBP Technical Advisory Group, which evaluates and suggests environmental laws impacting hazardous material handling. He has trained hundreds of employees on hazardous materials shipping and safety topics and also trains safety professionals preparing for the CHMM credential exam.

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.