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If your facility has a Spill Prevention, Control and Countermeasure (SPCC) plan in place, it’s likely you also have a Hazardous Materials Business Plan (HMBP).

In California, any business that handles or stores hazardous materials in quantities equal to or greater than the minimum reportable amounts is required to have an HMBP in place. Having a well-documented HMBP ensures that everyone in your facility knows their responsibilities, understands proper procedures and is prepared to respond effectively in case of an emergency. The minimum reportable amounts are as follows:

• 55 gallons for liquids

• 500 pounds for solids

• 200 cubic feet (at standard temperature and pressure) for compressed gases

However, one of the biggest concerns we’ve encountered this year isn’t whether facilities have a completed HMBP in place, but whether employees have received the required training on hazardous materials and hazardous waste handling under the HMBP. Regulators are placing increasing emphasis on employee training. For operations that store liquids or solids above the limit, the training is not optional; it is a core requirement for compliance.

Just within six months, two different facilities experienced surprise inspections, and in both cases, inspectors asked for one key thing beyond the plan itself: training records. With the increase in inspections and these requests, it makes it clear that operations should review training programs, ensure refresher courses are being offered and maintain accurate records to be prepared when inspectors arrive.

Documentation and Annual Certification
In addition to providing the required training, businesses must now ensure that documentation is complete, accurate and readily available during inspections. This includes maintaining sign-in sheets, training outlines and evidence that employees understand their responsibilities under the HMBP. Another requirement that facilities often overlook is the need to certify their entire HMBP submittal annually through CERS by March 3, 2026. Even if nothing at your facility has changed, the system requires you to review and recertify the plan each year. Failing to keep training records updated or forgetting the annual certification can lead to violations, even when the physical plan itself is complete.

So, it’s worth asking: Do you have the plan and the documented training to support it?

Some of the key elements of an HMBP should include the following:

An effective plan doesn’t just meet the minimum requirements; it helps keep your team and community safe. Below are the key elements every plan should include:

• Business Activities and Owner Identification – Provide basic information about the business, including the owner/operator details and the types of activities conducted at the facility.

• Hazardous Material Inventory – List all hazardous substances present at the site, including materials stored in underground tanks. This ensures proper documentation and accountability for all substances handled or stored.

• Site Map – A clear and detailed site map helps emergency personnel quickly locate hazardous materials and key areas if an emergency occurs. Your map should include:

Emergency Response and Training
The emergency response section is a critical piece of an HMBP to protect both employees and operations. It ensures that everyone in your facility knows how to act quickly and safely if an emergency occurs. The plan should clearly outline the facility’s emergency procedures and include a training program to keep employees informed and prepared.

Employee Training Requirements
Training must be provided to all appropriate personnel, both initially and as a refresher on a regular basis. At a minimum, training should include:

• Safe handling practices for hazardous materials.

• Identification of vulnerable areas or systems that may need inspection or isolation after an earthquake or similar event.

• Evacuation plans and notification procedures to ensure quick and safe responses.

• Identification of local emergency medical assistance appropriate for potential accidents or exposure scenarios.

• Notification procedures for local emergency response agencies, including the Unified Program Agency and Cal OES, as well as key facility personnel.

• Emergency response and safety procedures to prevent, mitigate or control releases that could harm people, property or the environment.

• Proper use of emergency response equipment and supplies.

• Coordination procedures with local emergency response organizations.

• Familiarity with the facility’s emergency response plan and overall procedures.

Training records must be kept for a minimum of three years and should be available for review when requested.

Get Help if Needed
If you need additional support, the Western Tree Nut Association (WTNA) can assist with program development and conduct training specifically to meet the requirements for the HMBP. Contact our team to schedule a review or training session and ensure your facility remains compliant and prepared.