Under California law, businesses that handle hazardous materials above certain thresholds must annually prepare and submit a Hazardous Materials Business Plan (“HMBP”) to the appropriate local Certified Unified Program Agency (“CUPA”).
By default, regulated businesses must submit HMBPs annually on or before March 1. However, the March 1 deadline is, like many other aspects of the HMBP program, subject to your local CUPA’s modification. For example, Monterey County Health Department’s due date is January 1, San Joaquin County Environmental Health Department’s is January 15, Los Angeles County’s is (usually) March 15, and several other CUPAs require submission within 365 days of your last submission, no matter the date.
The administrative penalties for a late submission can reach up to two thousand dollars ($2,000) per day or five thousand dollars ($5,000) per day for “knowing” violations.
Having prepared hundreds of HMBPs for clients throughout California, we appreciate the challenges businesses face in understanding and addressing the requirements established by over 80 CUPAs and numerous participating agencies throughout the state. If you would like to know more about the state’s HMBP program and how it may affect your business, please feel free to contact us.
© 2018 – Hartman King PC. All rights reserved. The information in this article has been prepared by Hartman King PC for informational purposes only and does not constitute legal advice.