March 03, 2010

Often the "safety person" is also tasked with covering environmental issues for a facility. If you're a safety professional in California who also wears an environmental hat, then it's important that you understand what "CUPA" means.

CUPA is the acronym for a Certified Unified Program Agency. Through CUPAs, six programs are consolidated and coordinated at a local level regarding administrative requirements for permits, inspections, and enforcement activities. This allows facilities to deal with one regulatory entity for all six programs — the local CUPA — rather than multiple entities.

Oil is a hazardous material. If you handle or store quantities of oil at your facility, you may be subject to a number of environmental regulations. Are you in compliance? Join us on March 18 for an in-depth webinar designed to help you navigate the state and federal regulations for aboveground petroleum.

Register Now »

Learn More »

The six programs implemented by CUPAs are:

• Hazardous Materials Release Response Plans and Inventories: This program requires facilities to develop and provide to first responders (generally via the CUPA) hazardous materials business plans (HMBPs). California requires that an owner or operator of a facility complete and submit an HMBP if the facility handles a hazardous material or a mixture containing a hazardous material (which includes both hazardous substances and hazardous wastes) in excess of regulatory quantities. Some hazardous materials (such as chlorine, nitrogen, and nitrous oxide) used in specific settings are exempt.
• Hazardous Material Management Plans and Hazardous Material Inventory Statements: This program is a requirement of the California Uniform Fire Code (CFC), and the plans are the equivalent HMBPs. The difference is that when quantities present at a facility do not exceed the state HMBP thresholds but do exceed CFC thresholds (some of which are below HMBP levels), the local fire agency can require a facility to submit an HMBP. Note that under this program, the local fire agency can require that information beyond the state requirements for HMBPs be included in the HMBP.
• California Accidental Release Prevention (CalARP) Program: CalARP is a chemical risk management program. The reporting requirements for CalARP are separate from those under the Hazardous Materials Release Response Plans and Inventories program. There is a separate list of regulated substances, and the risk management requirements include hazard assessment, a prevention program, an emergency response program, and a management system.
• Underground Storage Tank (UST) Program: The purpose of the UST program is to protect people and the environment from releases of petroleum and other hazardous substances from underground storage tanks. The four elements of the program are leak prevention (through requirements governing tank installation, construction, testing, leak detection, spill containment, and overfill protection), cleanup of soil and groundwater when there has been a leak, enforcement, and tank tester licensing--testing of tank integrity must be conducted by state-licensed tank testers.
• Aboveground Petroleum Storage Act (APSA) Program: APSA governs the reporting of spills and releases of petroleum products into the environment. It also requires owners and operators of tank facilities that meet regulatory levels for storing these materials to prepare and implement a spill prevention countermeasure and control (SPCC) plan.
• Hazardous Waste Generator and Onsite Hazardous Waste Treatment (tiered permitting) Programs: These set forth requirements for reporting, storage, and permitting for those facilities that generate hazardous waste.

Oil Spills: What California Facilities Must Know To Comply with State and Federal Rules

California facilities face high enforcement hurdles when it comes to oil storage and spill prevention rules. Not only are you required to prepare Spill Prevention, Control, and Countermeasure (SPCC) plans, but you must also deliver and document extensive oil-handling and emergency response training.

Additionally, if your company has a petroleum storage capacity of 1,320 gallons or more, or stores oil in containers of 55 gallons or more, you're subject to the requirements of the Aboveground Petroleum Storage Tank (APST) Program. This requires both periodic inspections and the submission of an annual Tank Facility Statement to the applicable Certified Unified Program Agency (CUPA).

And don't forget — lurking beneath all the acronyms are severe, costly penalties for noncompliance. Don't get caught short. Join us on March 18 for an in-depth webinar designed to help you navigate the state and federal regulations for aboveground petroleum. You'll learn:

• What CUPAs are, and why they represent the latest regulatory challenge for California businesses
• How to prepare SPCC plans in accordance with the regulations
• The petroleum storage thresholds that trigger CUPA compliance rules
• How to ensure you're in compliance with the state and federal rules that apply to your facility
• How to satisfy the extensive annual oil-handling employee training requirements
• The emergency response planning and training that is required of you, and how frequently it needs to be delivered

Register Now »

Learn More »