CUPA Electronic Reporting

Q01:  What is electronic reporting?

A01:  In 2008 a new California law took effect that requires all regulated facilities and all Certified Unified Program Agencies (CUPAs) to use computers to enter Unified Program data into a Statewide information system by January 1, 2013. This includes facility data regarding hazardous material regulatory activities including Hazardous Material Plans (HMPs) and underground storage tank (UST) information.

For businesses that have completed an HMP in the past, you will notice the majority of the information requested is the same, but many of the forms have been turned into fill-in-the-blank pages on the internet. Once an initial plan has been completed, any changes can be made to the appropriate field (e.g. – phone number change, environmental contact change) and the plan can be submitted again without having to fill out fields that remained the same.

Q02:  Does submittal of electronic files such as PDFs via email constitute electronic reporting?

A02:  No, it does not. For businesses, Electronic Reporting means that a business uses the CERS (California Environmental Reporting System) Portal to fulfill your reporting requirement or the Tulare County Portal.

Q03:  When will I have to file electronically?

A03:  All regulated facilities and Certified Unified Program Agencies (CUPAs) in the State of California must be filing and accepting all included data completely by January 1, 2013. 

Q04:  Does Tulare County CUPA have its own local portal?

A04:  Yes. Tulare County Portal

Q05:  If I use CERS to file, does this meet all of my filing requirements?

A05:  Not necessarily. The data item has to be defined in the data dictionary in CCR Title 27 in order for it to be a required part of the Statewide data management system. There are a number of business plan requirements other than filling out forms. For example:

    • While the inventory portion of the business plan has owner/operator and chemical inventory forms included in the data dictionary, the Emergency Response Plans and Procedures and Training parts of the plan do not have a specific form and are not included. However, some documents such as site maps and locally collected information forms will be able to be scanned and uploaded.
    • Risk Management Plans (RMPs) do have specific required data elements in CCR Title 19. However they are not defined in CCR Title 27; therefore RMPs are not included in CERS.
    • Records maintained onsite to demonstrate compliance are not included.
    • The Statewide system does not manage local agency billing, acceptance of payments, or issuance of permits. The extent to which additional billing information is required is dependent on local fee structures and the use of limited locally collected inventory information in the Statewide information system.

Our CUPA staff will help you identify how to file or maintain that required compliance documentation which is not part of the CCR Title 27 data dictionary and therefore not part of the Statewide information system.

Q06:  How will electronic reporting help businesses and agencies?

A06:  The Statewide data system will allow:

    • Regulated facilities to more easily update existing information.
    • Multi-jurisdictional businesses to file their data using one system location.
    • Emergency response agencies access to current data.
    • Federal, State, and local regulators to have more efficient access to current data.
    • Saving of space, paper, and time involved in physical processing and reentering of data already typed into a form by the business.

 

Q07:  How do I get started?

A07:  If you are a new business please visit the CERS website at http://cers.calepa.ca.gov/ to get started or to the Tulare County  Portal. 

Q08:  How do I get started if I have businesses in multiple jurisdictions?

A08:   Each individual jurisdiction has its own unique manual, automated, and emergency information systems.

Some jurisdictions, including Tulare County, have developed their own portals that will also enable the agency to conduct related e-commerce or provide other electronic services. Therefore, if you have facilities in more than one jurisdiction, you will need to check the reporting requirement of each jurisdiction. If you have a large number of sites, we suggest that you contact CalEPA about multi-jurisdiction filing options prior to manually entering your data for each site. If you have just a few sites but they are scattered among jurisdictions, you will want to contact each jurisdiction. CalEPA does not have a specific interested party list for e-reporting, but they use their more general Unified Program listserv.

To join the listserv, you can go to: https://calepa.ca.gov/calepa-listservs/subscribe-to-the-unified-program-listserv/

Q09:  Can I get help in using the CERS reporting system?

A09:  Tulare County Environmental Health staff is also able to assist businesses by appointment. Call us at (559) 624-7400 to set up an appointment.

Q11:  What happens after I submit my plan and it is accepted as completed?

A11:  Once your Hazardous Materials Plan (HMP) is submitted, it goes into a queue until it is reviewed by a member of our team. If it is found to be complete, you will receive an email with a notification that the HMP has been found to be complete and has been accepted. 

You will be sent a letter notifying you when your next annual certification is due, generally one year from when your previous HMP was due. If you have changes to your business that you need to report on your HMP, such as change in chemical inventory, facility layout, personnel changes, etc., you can report changes to your plan at any time by logging into  CERS , making the necessary updates, and re-submitting the HMP. Please not that this does not change your annual submittal due date.

Q12:  What if my plan submitted is considered to be incomplete?

A12:  Once your Hazardous Materials Plan (HMP) is submitted, it goes into a queue until it is reviewed by a member of our team. If is found to be incomplete and there are corrections that need to be made, you  will receive an email notification. You can also log into CERS at any time to see the status of your HMP submission.

If the HMP was declined, you must make the required corrections and resubmit the HMP. 

Your reporting requirements are not fulfilled until you submit a fully completed HMP that is accepted by our division. NOTE: Failure to submit a completed HMP or annual HMP re-certification will result in enforcement action and penalties.

Q13:  Further Questions?

A13:  You may call the Environmental Health Division at 559-624-7400.