Hazardous Materials Inventory Reporting Guidance
The list below was developed to help you determine how changes in the law or local ordinance affect your facility's inventory reporting requirements in the Health & Safety Code (HSC), Chapter 6.95, Article 1, §25507.
The San Diego County Code (SDCC) contains additional exemptions or higher reporting thresholds for specified hazardous materials.
When applicable, a facility must update the hazardous materials inventory electronically using the California Environmental Reporting System (CERS) and submit the changes for review and acceptance by the inspector. State law requires changes or updates to a facility’s reportable inventory be submitted in CERS within 30 days [Cal.HSC §25508.1]
Please be advised that facility permit fees are based on the inventory reported in CERS; therefore, if a facility does not routinely review and submit their inventory changes in CERS based on the law it may result in incorrect fees on your annual facility permit invoice.
Visit our CERS Information page to learn more about CERS electronic reporting, or to make an appointment online for someone to help you with CERS.
Hazardous Materials Reporting Chart
- > 55 gallons (for liquids)
- > 500 pounds (for solids)
- > 200 cubic feet (for gases)
- or at the threshold planning quantity for extremely hazardous substances (EHS)
- Lower reporting thresholds may apply - click on the items below
Carbon Dioxide (CO2) Used for Beverage Carbonation
Report in CERS if either apply [SDCC §68.1116]
a) > 6000 cubic feet (or 686 pounds, or 81 gallons, or 307 liters in tank capacity) for non-cryogenic compressed gas OR,
b) > 3500 cubic feet (or 400 pounds, or 47 gallons, or 179 liters in tank capacity) for cryogenic/liquefied compressed gas.
Carbon Dioxide (CO2)
Report in CERS if facility handles at any one time during the reporting year cryogenic, refrigerated, or compressed gas in quantities >1,000 cubic feet at standard temperature and pressure. [HSC §25507(a)(5)(C)]
Compressed Air used in Emergency Response
No requirement to report in CERS compressed air in cylinders and tanks used by fire departments and other emergency response organizations (public agency) for the purpose of emergency response and safety. [HSC §25507(b)(2)]
Consumer Products at a Retail Establishment
No requirement to report in CERS if all specified conditions are met. [HSC §25507(b)(5)]
Retail/Consumer Products Information:
- Retail establishment means a business that sells consumer products prepackaged for distribution to, and intended for use by, the general public. A retail establishment may include storage areas or storerooms in establishments, which are separated from shelves for display areas, but maintained within the physical confines of the retail establishment. A retail establishment does not include a pest control dealer, as defined in Section 11407 of the Food and Agricultural Code. [HSC §25501(q)]
- Hazardous material contained solely in a consumer product, handled at, and found in, a retail establishment and intended for sale to, and for use by, the public. The exemption provided for in this paragraph shall NOT apply to a consumer product handled at the facility which manufactures that product, or a separate warehouse or distribution center of that facility, or where a product is dispensed on the retail premises. [HSC §25507(b)(5)]
- Consumer product means a commodity used for personal, family, or household purposes, or is present in the same form, concentration, and quantity as a product prepackaged for distribution to and use by the general public. [HSC §25501(j)]
Closed Fire Suppression System Exemption
No requirement to report in CERS. [SDCC §68.1119]
Fluid in a Hydraulic System
Report in CERS if the combined storage capacity of oils (including used oil) at the facility is ≥1,320 gallons. [HSC §25507(b)(4)]
Gases – Refrigerants
Report in CERS if >1,000 cubic feet for non-flammable refrigerant gases, as defined in the California Fire Code, that are used in refrigeration systems. [HSC §25507(a)(5)(D)]
For Computer Rooms: No requirement to report in CERS the refrigerant gases, other than ammonia or flammable gas in a closed cooling system, that are used for comfort or space cooling for a computer room. [HSC §25507(b)(1)]
Inert Gas Classified as Simple Asphyxiatant or Pressure Release Only
Report in CERS if facility handles at any one time during the reporting year cryogenic, refrigerated, or compressed gas in quantities ≥1,000 cubic feet at standard temperature and pressure. [HSC §25507(a)(5)(A)]
This applies for a hazardous material that is a compressed gas, at standard temperature and pressure, for which the only health and physical hazards are simple asphyxiation and the release of pressure. Cal/EPA has developed guidance to determine if a material qualifies for this reporting threshold.
Materials Classified as Irritant or Sensitizer Only
The reporting quantity in CERS is >5,000 pounds for solids or >550 gallons for liquids. [HSC §25507(a)(4)]
This applies for a solid or liquid hazardous material that is classified as a hazard solely as an irritant or sensitizer. Cal/EPA developed guidance to determine if a material qualifies for this reporting threshold.
Report lubricating oil in CERS if volume of each type exceeds 55 gallons OR the total volume of all types exceeds 275 gallons. [HSC §25507(b)(3)]
NOTE: Used oil is subject to additional reporting requirements for hazardous waste and is thus reportable in any amount.
Specified Medical Gases
Report in CERS at >200 cubic feet unless the conditions below apply.
Report in CERS if facility handles at any one time during the reporting year cryogenic, refrigerated, or compressed gas in quantities of >1000 cubic feet for oxygen, nitrogen, and nitrous oxide maintained by a physician, dentist, podiatrist, veterinarian, pharmacist, or emergency medical service provider. [HSC §25507(a)(5)(b)]
Oil-Filled Electrical Equipment (not contiguous to an electric facility)
Report in CERS if the aggregate storage capacity of oil (including used oil) at the facility is ≥1,320 gallons. [HSC 25507(b)(4)(B)]
Paint at an Authorized Paint Care Facility
Report in CERS paint >55 gallons or >500 pounds, unless the conditions below apply.
Report in CERS paint when the authorized Paint Care business handles at any one time during the reporting year a total weight of 10,000 pounds of solid hazardous materials or a total volume of 1,000 gallons of liquid hazardous materials. [HSC §25507(a)(4)(B)]
Propane Reporting Guidance
Report in CERS if storage capacity of propane is equal to or more than 23.7 lbs, or 5.6 gallons, or 200 cubic feet unless used on premises for heating, cooling, or cooking. (1 gallon = 4.24 lbs) [§25507(a)(1)(B)]
Report in CERS on premises use, storage, or both if more than 1,000 gallons that is for the sole purpose of cooking, cooling/heating the employee work areas, and heating water. [SDCC §68.1117]
Unstaffed Remote Facilities Reporting Guidance
Located in an isolated, sparsely populated area if the types & quantities are limited to one or more of the following:
- 1000 cubic feet of compressed gases (asphyxiation and pressure hazard only)
- 500 gallons of combustible liquids used as a fuel
- Corrosive liquids not to exceed 500 pounds of extremely hazardous substances, used as electrolytes, and in closed containers
- 500 gallons lubricating and hydraulic fluids
- 1,200 gallons of flammable (hydrocarbon) gas used as fuel
- Report quantity of mineral oil contained within electrical equipment, such as transformers, bushings, electrical switches, and voltage regulators, if the spill prevention control and countermeasure (SPCC) plan has been prepared for quantities that meet or exceed 1,320 gallon
Unstaffed Remote Facility Reporting Guidance: [HSC §25507.2]
- An unstaffed facility situated at least one-half mile from the nearest occupied structure.
- A one-time business plan submittal is completed in CERS, except for the emergency response plan and training elements specified in paragraphs (3) and (4) of subdivision (a) of HSC §25505.
- Submit facility changes in CERS within 30 days.
- The one-time business plan submittal is subject to a verification site inspection by the unified program agency.
- The facility is secured and not accessible to the public.
- Warning signs for the hazardous materials are prominently posted at the facility and maintained pursuant to the California Fire Code.
Extremely Hazardous Substance
Report in CERS at any one time during the reporting year an amount of a hazardous material that is equal to, or greater than the threshold planning quantity, under both of the following conditions:
- The hazardous material is an extremely hazardous substance, as defined in Section 355.61 of Title 40 of the Code of Federal Regulations.
- The threshold planning quantity for that extremely hazardous substance listed in Appendices A and B of Part 355 (commencing with Section 355.1) of Subchapter J of Chapter I of Title 40 of the Code of Federal Regulations is less than 500 pounds.
If the substance is an extremely hazardous substance as defined in Section 355.61 of Title 40 of the Code of Federal Regulations, all amounts shall be reported in pounds in CERS. [HSC §25507(a)(1)(B)].
Also, the EPA’s Consolidated List of Lists identifies EHS chemical substances that are reportable below 500 pounds in CERS. [HSC §25507(a)(3)(A)&(B)]
Combustible Metal or Metal Alloy
Report in CERS a combustible metal or metal alloy that:
- Is defined as a pyrophoric or water-reactive material in the California Fire Code, in any quantity in raw stock, scrap, or powder form at any time during the reporting year.
- Is defined as a combustible dust, flammable solid, or magnesium in the California Fire Code, in a quantity in raw stock, scrap, or powder form at any one time during the reporting year that is equal to, or greater than 100 pounds.
- Poses an explosive potential, when in molten form, in a quantity at any one time during the reporting year that is equal to, or greater than, 500 pounds.
- Additional guidance can be found here
Highly Toxic Compressed Gas
Report in CERS highly toxic compressed gases with a Threshold Limit Value of 10 parts per million or less as referenced by the ACGIH. Report these gases as part of the chemical inventory in any quantity. [SDCC §68.1113(a)]
Liquefied Compressed Gas - Physical State Reporting Guidance
For a liquefied compressed gas, when the gas is determined to meet or exceed threshold quantities at standard temperature and pressure, it shall be reported in the physical state at which it is stored. (For example, propane and liquefied nitrogen = report in gallons) [HSC §25507(a)(1)(B)]
|2018 New Federal Hazard Categories|
Chemical Inventory Reporting of the Annual 2018 Hazardous Materials Business Plan (HMBP) Submittals Must Reference the 24 New Federal Hazard Categories
December 28, 2017, CalEPA has replaced the existing five (5)
federal hazard categories available in CERS used for the
completion of chemical inventories as part of the annual
hazardous materials business plan submittal with twenty-four
(24) new federal hazard categories adopted by the United
States Environmental Protection Agency (U.S. EPA) as a
result of changes to the Occupational Safety and Health
Administration (OSHA) Hazard Communication Standard (HCS).