Most Cited CUPA Violations in California, 2020–2025
California's local hazardous materials agencies, the CUPAs, recorded 624,254 violations at 94,628 sites from 2020 through 2025. The four most cited are paperwork from the hazardous materials business plan: a site map, the annual certification under two code sections, and the employee training record. Together they are 30% of all violations and reach 70% of the sites that were cited. The typical violation was fixed in 41 days.
Every hazardous materials inspection in California by a local Certified Unified Program Agency, a CUPA, is recorded in the state’s reporting system, and CalEPA publishes the record through its Regulated Site Portal. CalEPA publishes per-county evaluation reports, but no statewide count of what gets cited. This page is that count: 624,254 violations cited at 94,628 California sites from January 2020 through December 2025, computed from the portal’s export as cut on September 10, 2026.
A CUPA inspects for the Unified Program: the hazardous materials business plan, hazardous waste generation, underground and above-ground fuel tanks, and accidental release prevention. This page covers those inspections. Cal/OSHA inspects the same shops for worker safety under a separate law, and that record is at Most Cited Cal/OSHA Violations in Auto Repair and the other industry pages.
The totals, 2020–2025
| Measure | 2020–2025 |
|---|---|
| Inspection records | 693,697 |
| Inspection records with at least one violation | 264,695 (38%) |
| Distinct site visits | 484,645 |
| Sites inspected | 138,006 |
| Violations cited | 624,254 |
| Sites with at least one violation | 94,628 |
| Sites in the portal file | 264,785 |
An inspection record is one inspection under one program, so a single visit that covers both the business plan and hazardous waste appears twice. Distinct site visits count each site and date once.
| Year | Inspection records | With violations | Violations |
|---|---|---|---|
| 2020 | 97,168 | 34,243 (35%) | 84,164 |
| 2021 | 111,384 | 41,578 (37%) | 97,012 |
| 2022 | 119,254 | 45,919 (39%) | 110,728 |
| 2023 | 119,714 | 46,675 (39%) | 107,359 |
| 2024 | 123,225 | 47,733 (39%) | 111,814 |
| 2025 | 122,952 | 48,547 (39%) | 113,177 |
The most cited violations
Citations are the code sections as the portal records them, with the portal’s own description of each. The program column is the Unified Program element the citation falls under.
| # | Citation, as recorded | Program | What the portal says was missing | Violations | Sites | Share |
|---|---|---|---|---|---|---|
| 1 | HSC §25508(a)(3) | Business plan | A site map with all required content, electronically submitted | 88,280 | 39,449 | 14% |
| 2 | HSC §25508(a)(1) | Business plan | The annual review and electronic certification that the plan is complete and accurate | 34,387 | 22,669 | 6% |
| 3 | HSC §25505(a)(4) | Business plan | Initial and annual employee training in release response procedures | 31,445 | 24,554 | 5% |
| 4 | HSC §25508.2 | Business plan | The annual review and electronic certification, under the newer section | 30,256 | 22,196 | 5% |
| 5 | HSC §25270.4.5(a) | Petroleum tanks | A spill prevention, control and countermeasure plan | 26,917 | 7,755 | 4% |
| 6 | 22 CCR §66262.34(f) | Hazardous waste | The “hazardous waste” label and accumulation start date on a waste tank | 26,092 | 21,521 | 4% |
| 7 | Unspecified | Petroleum tanks | No section recorded | 22,963 | 11,317 | 4% |
| 8 | 22 CCR §66262.40(a) | Hazardous waste | A copy of each signed manifest, kept three years | 13,420 | 11,745 | 2% |
| 9 | 23 CCR §2716(e) | Underground tanks | Designated operator monthly inspections | 12,667 | 5,830 | 2% |
| 10 | 23 CCR §2641(h) | Underground tanks | An approved tank monitoring plan | 12,025 | 5,143 | 2% |
| 11 | HSC §25292.2(a) | Underground tanks | Certification of financial responsibility | 11,865 | 5,651 | 2% |
| 12 | HSC §25123.3(h)(1) | Hazardous waste | Sending waste offsite within the accumulation time limit | 11,761 | 10,001 | 2% |
| 13 | HSC §25508.1(a)–(f) | Business plan | A business plan update within 30 days of a change | 10,911 | 9,615 | 2% |
| 14 | HSC §25507 | Business plan | A business plan at all, where a material is handled at or above the threshold | 10,406 | 8,781 | 2% |
| 15 | HSC §25284.2 | Underground tanks | Spill container and overfill equipment | 10,333 | 5,801 | 2% |
| Fifteen most cited | 353,728 | 57% | ||||
| All 783 distinct citations | 624,254 | 94,628 | 100% |
The four most cited CUPA violations in California from 2020 through 2025 are all parts of the hazardous materials business plan: the site map, the annual certification, and the training record. Together they are 184,368 violations, 30% of the total, cited at 66,535 sites, which is 70% of every site that was cited. No chemical, tank, or waste handling item ranks above them.
One note on the citation numbers. The portal records site-map violations under §25508(a)(3), and the text of that subdivision today is the deficiency-notice procedure. The site map requirement itself is in §25505(a)(2), which lists what a site map must show. The two certification rows are two sections that say the same thing: §25508(a)(1) requires the plan to be submitted and certified, and §25508.2 requires an annual review and certification that the information in the state system is complete and accurate. What a hazardous materials business plan is explains each item.
By program
| Program | Violations | Share | Sites |
|---|---|---|---|
| Hazardous materials business plan | 239,537 | 38% | 73,965 |
| Underground storage tanks | 182,714 | 29% | 12,897 |
| Hazardous waste generator | 153,518 | 25% | 48,165 |
| Above-ground petroleum storage | 34,173 | 5% | 8,867 |
| Accidental release prevention | 6,483 | 1% | 1,236 |
| Other program codes | 7,829 | 1% | |
| Total | 624,254 | 100% |
Underground tank violations are concentrated: 182,714 violations at 12,897 sites, against 239,537 business plan violations at 73,965 sites.
The annual certification repeats
Of the 38,544 sites cited for the annual certification from 2020 through 2025, 10,227, or 27%, were cited for it in two or more different years, and 2,185 in three or more. The certification is due every year under §25508.2, on the date the local agency sets or by March 1.
How long a fix takes
The portal’s notes record a return-to-compliance date for 90% of violations. Across the 562,760 violations with a usable date:
| Time from citation to return to compliance | Share of violations |
|---|---|
| Same day | 16% |
| Within 30 days | 43% |
| Within 90 days | 66% |
| Typical violation | 41 days |
| Average | 151 days |
| Citation | Violations with a date | Typical time to fix | Average |
|---|---|---|---|
| Site map, §25508(a)(3) | 77,465 | 38 days | 124 days |
| Certification, §25508(a)(1) | 31,229 | 37 days | 151 days |
| Training, §25505(a)(4) | 27,842 | 37 days | 122 days |
| Certification, §25508.2 | 27,468 | 28 days | 99 days |
| Waste tank label, 22 CCR §66262.34(f) | 24,603 | 22 days | 92 days |
| Spill prevention plan, §25270.4.5(a) | 23,903 | 51 days | 160 days |
The gap between the typical and the average is a small number of violations that stayed open for a year or more.
By county
County is assigned from the site’s zip code; 94% of sites map. The share with violations is the share of inspection records in the county that recorded at least one violation.
| County | Violations | Sites with a violation | Inspection records | Share with violations |
|---|---|---|---|---|
| Los Angeles | 175,444 | 22,816 | 195,999 | 33% |
| Riverside | 56,084 | 5,930 | 38,161 | 58% |
| Santa Clara | 32,048 | 4,539 | 23,228 | 51% |
| San Bernardino | 31,487 | 5,457 | 34,899 | 45% |
| Alameda | 28,462 | 3,929 | 25,105 | 44% |
| San Diego | 28,408 | 7,310 | 41,589 | 39% |
| Orange | 26,684 | 6,327 | 62,840 | 27% |
| Sacramento | 26,417 | 3,242 | 15,728 | 58% |
| San Joaquin | 21,254 | 2,087 | 6,129 | 83% |
| Ventura | 16,743 | 2,692 | 20,137 | 44% |
| Kern | 14,380 | 2,647 | 26,752 | 30% |
| San Mateo | 13,664 | 2,061 | 26,484 | 24% |
Orange County recorded 62,840 inspection records and 26,684 violations from 2020 through 2025; Sacramento County recorded 15,728 inspection records and 26,417 violations. The share of inspections with a violation ranges from 24% to 83% across these twelve counties. The portal records the outcome, not the inspection policy that produced it.
By inspecting agency
101 agencies recorded inspections from 2020 through 2025. The ten largest by inspection records:
| Agency | Inspection records | Share with violations |
|---|---|---|
| Los Angeles County Fire Department | 110,099 | 28% |
| Los Angeles City Fire Department | 53,253 | 34% |
| Orange County Environmental Health | 51,237 | 24% |
| San Diego County Department of Environmental Health | 40,794 | 40% |
| San Bernardino County Fire Department | 35,250 | 45% |
| Riverside County Department of Environmental Health | 30,630 | 56% |
| San Mateo County Environmental Health | 27,143 | 24% |
| Contra Costa County Health Services Department | 20,699 | 33% |
| Sacramento County Environmental Management Department | 15,709 | 58% |
| Kern County Environmental Health Services Department | 14,558 | 30% |
Among agencies with at least 5,000 inspection records, the share with violations ranges from 20% at Roseville City Fire Department to 83% at San Joaquin County Environmental Health. What a CUPA is explains how these agencies are organized.
Formal enforcement
Most violations are handled in the inspection report. Formal actions recorded from 2020 through 2025: 21,316 notices of violation at 8,841 sites, 1,887 administrative enforcement orders at 1,499 sites, 167 referrals to a district attorney, and 52 referrals to a county counsel or city attorney. The portal records the action, not any penalty amount.
Hazardous materials in California
- What a hazardous materials business plan is
- What CERS is
- What a CUPA is
- The CalEPA Regulated Site Portal
Methodology
Computed by CompliantCA from the CalEPA Regulated Site Portal exports of sites, evaluations, violations, and enforcement actions, downloaded September 10, 2026. Scope: records whose source is the California Environmental Reporting System, which holds the Unified Program inspections by the local CUPAs and participating agencies; records from the Water Boards’ systems (CIWQS and SMARTS) are in the export and are excluded here. Window: violation dates, inspection dates, and enforcement dates from January 1, 2020 through December 31, 2025. A violation is one cited section on one inspection, as the portal records it; the citation string and description are the portal’s, and descriptions are shortened in the table. An inspection record is one row in the portal’s evaluation export, which lists an inspection once per program; “distinct site visits” counts each site-and-date pair once. “Sites” are the portal’s site identifiers. County is assigned from the first five digits of the site’s zip code through the Census Bureau’s 2020 ZCTA-to-county file, taking the county with the largest share of the zip code’s land; 6% of sites have a zip code not in that file and are omitted from the county table only. Time to fix is the difference between the violation date and the “returned to compliance on” date that the portal’s notes carry for 90% of violations; gaps below zero or above 2,000 days are excluded, and “typical” is the median. The portal does not record penalty amounts or the business’s industry.
A violation count says what inspectors recorded, not what any business must do. The Health and Safety Code sections linked above say that.
Frequently asked questions
What is the most common CUPA violation in California?
A missing or incomplete site map for the hazardous materials business plan. It was cited 88,280 times at 39,449 sites from 2020 through 2025, 14% of all Unified Program violations in the CalEPA Regulated Site Portal. The business plan's annual certification is next, cited 64,643 times under two code sections at 38,544 sites.
How often does a CUPA inspection find a violation?
38% of Unified Program inspection records from 2020 through 2025 recorded at least one violation, per the CalEPA Regulated Site Portal. The share varies by agency: among agencies with at least 5,000 inspection records, it ranges from 20% at Roseville City Fire Department to 83% at San Joaquin County Environmental Health.
How long does it take to fix a CUPA violation?
The typical violation from 2020 through 2025 was recorded as returned to compliance 41 days after it was cited, per the return-to-compliance dates in the CalEPA Regulated Site Portal. 16% were fixed the same day, 43% within 30 days, and 66% within 90 days. The annual certification was fastest among the top items, with a typical time of 28 days.
How many businesses were cited by a CUPA in California?
94,628 distinct sites had at least one Unified Program violation from 2020 through 2025, out of 138,006 sites inspected and 264,785 sites in the CalEPA Regulated Site Portal file, computed by CompliantCA from the portal's export.