Hazardous Materials

What a CUPA Is

A CUPA is a Certified Unified Program Agency, the local department that inspects California businesses for hazardous materials. Health and Safety Code §25501(e) defines it as the agency CalEPA certifies to implement the Unified Program within a jurisdiction. It is usually a county environmental health department or a fire department. From 2020 through 2025, 101 such agencies recorded 693,697 inspection records in the state system, and 38% recorded at least one violation.

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A CUPA is a Certified Unified Program Agency. Health and Safety Code §25501(e)(1) defines the term as “the agency certified by the secretary to implement the unified program specified in Chapter 6.11 (commencing with Section 25404) within a jurisdiction.” The secretary is the Secretary for Environmental Protection, and the jurisdiction is a county or a city. In practice a CUPA is a county environmental health department or a fire department, and it is the inspector a California business meets about the chemicals it keeps.

What the Unified Program is

The Unified Program was created in 1993 by Senate Bill 1082 and consolidates six state programs under one local agency; CalEPA’s overview of the program says the local agencies took over work “previously handled by approximately 1,300 different state and local agencies.” The six elements, as CalEPA lists them:

  • Hazardous Materials Release Response Plan and Inventory, the business plan.
  • Hazardous Materials Management Plan and Hazardous Materials Inventory Statement, the fire code’s filings.
  • Underground Storage Tanks.
  • Hazardous Waste Generator and Hazardous Waste Treatment.
  • Aboveground Petroleum Storage Act.
  • California Accidental Release Prevention.

A CUPA may delegate elements to a participating agency, defined in §25501(e)(2) as an agency with a written agreement with the CUPA, approved by the secretary. A fire department might inspect for the business plan while the county health department inspects for hazardous waste. The statute calls the CUPA and its participating agencies together the unified program agencies, and after certification they “shall be the only local agencies authorized” to enforce these requirements (§25501(e)(4)).

What a CUPA inspection covers

The violations the CUPAs record show what an inspection covers. Under the hazardous materials business plan: the inventory, the site map, the emergency procedures, and the training records. Under hazardous waste: container labels and accumulation start dates, offsite shipment within the time limit, and manifest copies. Under fuel tanks: the monitoring plan, the designated operator’s monthly inspections, spill and overfill equipment, and the certificate of financial responsibility. Findings are recorded in CERS and published through the CalEPA Regulated Site Portal.

From 2020 through 2025, the business plan accounted for 239,537 of the 624,254 violations California CUPAs cited, 38%; underground tanks 182,714, 29%; and hazardous waste 153,518, 25%. The four most cited individual items are all business plan paperwork: the site map, the annual certification under two sections, and the training record. The most cited CUPA violations has the table.

How often an inspection finds something

38% of the 693,697 inspection records from 2020 through 2025 recorded at least one violation. The share differs by agency. The ten agencies with the most records:

Agency Inspection records, 2020–2025 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 the agencies with at least 5,000 records, the share ranged from 20% at Roseville City Fire Department to 83% at San Joaquin County Environmental Health. The portal records outcomes only. It does not record how each agency selects the facilities it visits or how it counts a finding.

What happens after a violation

Most violations are handled in the inspection report, with a date by which the business returns to compliance; the portal’s notes record that date for 90% of violations, and the typical violation was corrected in 41 days. Formal steps are less common. From 2020 through 2025 the CUPAs recorded 21,316 notices of violation at 8,841 sites, 1,887 administrative enforcement orders at 1,499 sites, and 167 referrals to a district attorney. §25508(a)(4) provides that if a handler fails, after reasonable notice, to submit a business plan, the agency “shall take appropriate action to enforce this article, including the imposition of administrative, civil, and criminal penalties.”

The Cal/OSHA inspection is a separate visit from a separate agency under a separate law, and its triggers are described at What triggers a Cal/OSHA inspection.

Hazardous materials in California

Sources

Definitions are quoted from Health and Safety Code §25501 and the enforcement provision from §25508, as published by the Legislature on September 10, 2026. The program elements are from CalEPA’s About the Unified Program. Inspection and violation counts are computed by CompliantCA from the CalEPA Regulated Site Portal export of September 10, 2026, for Unified Program records dated 2020 through 2025; an inspection record is one inspection under one program, so a visit covering two programs counts twice; the method is on the most cited violations page.

This page describes the agencies and what the record shows. The CUPA for a given address is listed in CalEPA’s directory, and it answers what applies to that facility.

Frequently asked questions

What does CUPA stand for?

Certified Unified Program Agency. Health and Safety Code §25501(e)(1) defines it as the agency certified by the Secretary of CalEPA to implement the Unified Program within a jurisdiction. The Unified Program consolidates six state hazardous materials programs under one local inspector: the hazardous materials business plan, hazardous waste generators, underground storage tanks, above-ground petroleum storage, accidental release prevention, and the fire code's hazardous materials provisions.

Who is my CUPA?

Usually the county environmental health department or a city or county fire department. Los Angeles County Fire Department, Los Angeles City Fire Department, Orange County Environmental Health, San Diego County Department of Environmental Health, and San Bernardino County Fire Department recorded the most inspections from 2020 through 2025. CalEPA keeps the directory of all CUPAs and participating agencies.

What does a CUPA inspect?

The hazardous materials business plan (inventory, site map, emergency procedures, training records), hazardous waste generation (container labels, accumulation dates, manifests), underground and above-ground fuel tanks, and accidental release prevention programs. From 2020 through 2025 the business plan accounted for 38% of violations cited, underground tanks 29%, and hazardous waste 25%, per the CalEPA Regulated Site Portal.

How often does a CUPA inspection find a violation?

38% of inspection records from 2020 through 2025 recorded at least one violation. Among agencies with at least 5,000 records, the share ranged from 20% at Roseville City Fire Department to 83% at San Joaquin County Environmental Health, per CompliantCA's computation from the CalEPA Regulated Site Portal.