Hazardous Materials Management / CUPA
Unified Program
Hazardous Materials Management / CUPA
The Livermore-Pleasanton Fire Department serves as the Certified Unified Program Agency (CUPA) for both Cities of Livermore and Pleasanton. Our Unified Program ensures that hazardous materials, underground and aboveground storage tanks, hazardous waste, and related risks are managed safely, in compliance with state laws, to protect public health, the environment, and our community.
What is the Unified Program?
The Unified Program (UP) is a California state initiative under CalEPA that combines and standardizes multiple environmental, safety, and hazardous materials regulations. As the local CUPA, LPFD regulates the following six program components:
- Hazardous Materials Business Plan (HMBP) – Businesses must report inventories of hazardous substances, emergency plans, and employee training.
- Underground Storage Tank Program (UST) – Standards for installation, maintenance, leak detection and closure of tanks buried underground.
- Aboveground Petroleum Storage Act (APSA) – Rules for safe storage of petroleum-based liquids in aboveground tanks to prevent leaks and spills.
- Hazardous Waste Generator (HWG) – Guidance and regulation for businesses generating chemical or hazardous wastes (e.g., solvents, used oils).
- Tiered Permitting (On-Site Treatment) – For facilities that treat hazardous waste on-site under certain conditions.
- California Accidental Release Prevention (CalARP) – For high-risk facilities handling large quantities of very hazardous materials that could affect off-site areas in the event of an accidental release.
Why it Matters
- Community Safety: Proper hazardous materials controls reduce the risks of fires, spills, leaks, and accidental releases.
- Environmental Protection: Ensures potential pollutants don’t harm soil, water, or air.
- Legal Compliance: Helps businesses meet their obligations under state law. Non-compliance can result in penalties.
- Preparedness: Businesses with up-to-date plans are better equipped to respond in emergencies.
What Businesses Must Do
If your business uses, stores, or handles chemicals, hazardous materials, or petroleum products, here’s what may apply to you under the Unified Program:
| Requirement | What You Need To Do |
| Register with CERS | Create and maintain a business profile in CERS; update annually or when major changes occur. |
| Submit the HMBP / CalARP Plan | If required, report inventories, emergency response plans, and employee training. |
| Maintain Storage Tanks | Follow regulations for USTs and APSA; perform inspections, testing, leak detection. |
| Manage Hazardous Waste | Properly label, store, dispose of hazardous waste; comply with generator rules. |
| On-site Treatment (if applicable) | If equipment treats hazardous waste, ensure permitted and operated under approved conditions. |
| Accept Inspections & Enforcement | Cooperate with regular inspections; correct violations as required. |
Inspection, Fees, & Enforcement
- LPFD conducts periodic inspections of regulated businesses under all six program elements listed above.
- Inspections include assessment of compliance with fire codes where applicable.
- There are fees, permits, and sometimes penalties associated with non-compliance. LPFD will provide guidance on what’s required.
- Enforcement actions may be taken if violations aren’t corrected. LPFD works to help businesses understand standards and meet them before enforcement becomes necessary.
How to Get Started
If you believe your facility may be regulated under CUPA, here are the first steps:
- Visit CERS and check whether your business is already registered.
- Determine which program(s) apply based on what materials you handle, how much, and where you store or treat them.
- Submit the required plans (e.g. HMBP, CalARP) via CERS or LPFD guidance forms.
- Keep records of training, maintenance, waste disposal, and inspections.
- If you need assistance or aren’t sure which requirements apply, contact LPFD’s Fire Prevention Division.
Frequently Asked Questions
Do I need a CUPA permit if I just use small amounts of hazardous substances?
It depends. Many businesses using small amounts may be exempt from some requirements, but you may still need to register and report if materials are above certain thresholds. LPFD can help you determine this.
How often are inspections performed?
Inspections are periodic. Frequency depends on the risk level of your facility, the materials you store, and your compliance history.
Where can I find forms or guides?
All required forms, guides, and resources are available through the LPFD Fire Prevention Division and via the CERS portal.
Contact Us
If you have questions or need help complying with the CUPA Unified Program, reach out:
Phone: (925) 454-2361
Email: [email protected] (for Unified Program inquiries)
Address: LPFD Fire Prevention Division, 3560 Nevada Street, Pleasanton, CA