California’s Certified Unified Program Agency (CUPA) System

Hazardous materials management and hazardous waste management in California can be an undertaking that spans multiple regulatory authorities across many levels of government, making it a daunting task. The California Environmental Protection Agency (Cal/EPA) seeks to simplifyy that process a bit by consolidating many of those functions under the umbrella of the Certified Unified Program Agencies (CUPA).

CUPAs are usually a county or city health department or fire department that has gone through the process of applying to and being approved by Cal/EPA for status as the CUPA.  These local government agencies are responsible for implementing the standards set by the state agencies responsible for the following six programs:

•  Hazardous Materials Release Response Plans and Inventories (Business Plans),
• California Accidental Release Prevention (CalARP) Program,
• Underground Storage Tank Program,
• Above-ground Petroleum Storage Act,
• Hazardous Waste Generator and Onsite Hazardous Waste Treatment (tiered permitting) Programs,
• California Uniform Fire Code: Hazardous Material Management Plans and Hazardous Material Inventory Statements.

One of the big benefits of this program is the need for only one permit to cover any and all of these programs, rather than having to track multiple permits.  Other benefits come from having one agency doing inspections, rather than multiple agencies that may have mutually exclusive perspectives for a given requirement; a single fee structure, which should end up being less expensive theoretically; and the need to only submit forms and other information one time to one agency, rather than submitting the same information to multiple entities.

You can learn a great deal more about CUPAs from the Cal/EPA Unified Program Home [http://www.calepa.ca.gov/cupa/ ].  You can also look up who the CUPA is for any location by using the Unified Program Regulator Directory.  Other good sources of information on the topic include the California CUPA Forum, and Unidocs , which is an extensive collection of information dealing with hazardous materials.

Next time we’ll take a look at the still relatively new reporting system for Unified Program required information, the California Environmental Reporting System, or CERS.