AVOID A VIOLATION - 10 EASY STEPS TO ENSURE YOUR FACILITY IS READY FOR THE CUPA INSPECTOR

If you store hazardous materials and/or hazardous waste on your site and/or operate underground storage tanks, you can plan on receiving an annual visit by CUPA inspectors.  A “CUPA” is a Certified Unified Program Agency, which is authorized to carry out several of the various hazardous materials regulatory programs administered by the State and City or County.   The California State laws and regulations covered by the CUPA include:

• Underground Tanks
• Community Right to Know and Spill Notification
• Accidental Release Program (Risk Assessment and Control of Extremely Hazardous Substances)
• Above Ground Tanks
• Hazardous Materials Inventory Reporting
• Hazardous Waste Generator and Tiered Permits

We help our clients resolve notices of violation.   We see a common pattern of easy to spot and readily avoidable violations cited by the CUPA inspectors with nearly all of our clients.  These are the top 10 things to do routinely at your facility to ensure you avoid simple CUPA violations.

1. Make sure your hazardous waste containers are properly labeled. The accumulation date on the label cannot exceed your accumulation time limit.
2. Hazardous waste containers are inspected weekly – document those inspections in an inspection log.
3. Ensure your hazardous waste containers are in good condition.  It is a good practice and demonstrates good housekeeping to have secondary contaminant for your hazardous waste containers and spill kits close at hand.
4. Hazardous waste tanks must be marked with what is inside the tank.
5. Hazardous waste tanks must be certified by a professional engineer every 5 years.
6. Ensure that no liquid would spill if the container were to tip over, for example in an earthquake or by a truck.
7. Hazardous waste tanks must be located within clean secondary containment.
8. Keep secondary containment clean. If they are dirty or oily, clean them up.
9. Hazardous waste tanks must be inspected daily and documented in an inspection log.
10. Keep all records in order, neatly organized, and readily available.  Review prior inspections and ensure corrective actions have been taken and documented.  

These 10 are the most readily visible for a CUPA inspector.  They are a starting point for good housekeeping and a smooth CUPA visit.  We understand how many competing priorities the EHS Professional has at a facility and we can provide you support to ensure your team is prepared.   We offer random site audits to ensure you are ready for inspection and help you correct problems so you don’t receive a notice of violation.   We are always available to work with you to resolve your NOVs, but prevention can be less costly over the long run.   For more information contact us at (562) 495-5777.