Code and Regulatory Compliance

Volume 3, Chapter 4

INTRODUCTION

The University is the Authority Having Jurisdiction (AHJ) for matters of code regulations on University projects. The University complies with the Title 24 California Building Standards Code, Parts 1-12 and all amendments (CBC). Each Facility acts as a "local jurisdiction" complete with its own Building Official and local administered code compliance program (similar to building officials in city or county jurisdictions). The primary Building Official requirements are defined below.

All facilities owned, leased, designed, constructed, altered, or renovated with intent, or future intent, to support the mission of the University are under the jurisdiction and responsibility of the University and local Facility administration. Each Facility shall have a code compliance program to design, approve, construct, alter, renovate, inspect, and maintain its facilities in accordance with all applicable codes and regulations, and University policies. Codes and regulations include the California Building Standards Code as adopted by the University, as well as any applicable federal, state, and local agency regulations and legislation. The code compliance program applies to all activities at the above described facilities that are subject to building codes and other related regulatory compliance, regardless of funding source, party overseeing construction, or the ownership status of the improvements.

This chapter describes codes and regulations that typically apply to University projects, although some projects may have additional special requirements. The Designated Campus Building Official, Lead Designated Campus Fire Marshal, Environmental Health & Safety office, and the funding agency should be consulted to determine whether other codes and regulations may apply. Some projects may require the University to duplicate or share authority with local, state, or federal jurisdictions.

When the University leases property to a separate entity and/or enters into ground leases or public private partnership agreements, the University continues to act as the AHJ with enforcement authority consistent with University mission, policies and obligations to state and federal law. Facilities must identify the Authority Having Jurisdiction in such agreements and contracts. For further information consult with the Office of the President, Real Estate Services & Strategies, and the Office of the General Counsel.

Each Facility’s program shall include an appointed Campus Building Official (CBO/A), Certified Building Official (CBO), Lead Designated Campus Fire Marshal (Lead DCFM), and Environmental Health & Safety Office. The program shall have effective processes for code and regulatory consultation, plan review, permitting, inspection and final acceptance in accordance with requirements of this volume.

 

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4.1 CODE COMPLIANCE PROGRAM AND ADMINISTRATION

 

Designated Campus Building Official, Campus Architect (DCBO). The DCBO is a University employee, appointed as the University professional responsible for administering the Facility’s architecture, engineering, and construction building program, including the enforcement of the CBC and related University policies. The DCBO is responsible for the administration and management of campus facility design, construction, renovation, and other Facility design and construction related obligations to support effective enforcement of the building program obligations. Additional obligations include, but are not limited to, compliance with applicable accessibility laws and policy, UC Seismic Safety Policy, Sustainable Practices Policy, adhering to the Long Range Development Plan (FM2:3), the Physical Design Framework (FM2:7.4), and local Facility adopted policies and guidelines (e.g. Gender Inclusive Facilities). The DCBO may also receive delegated authority to procure and enter into contracts for design, construction, and related services. (See FM4, FM5.) The DCBO shall be a licensed architect, registered professional engineer, licensed land surveyor, or certified industry professional with substantial expertise in, and understanding of, the architecture, engineering, and construction industry. The DCBO is the University’s AHJ for the Facility.  The DCBO may delegate responsibilities to a Certified Building Official, or if meeting the CBC qualifications, the DCBO may satisfy the role of Certified Building Official.

 

References:

  • California Code of Regulations, Title 24, Part 2, Volume 1, Chapter 1, California Building Code.
    • Division I,  Section 1.2
    • Division II, Section 104
    • Appendix A102 Employee Qualifications

Resources:

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4.1.1 Certified Building Official (CBO).

Each Facility shall employ a qualified University employee as a Certified Building Official. The authority of the CBO may not be re-delegated to any person or entity regardless of their qualifications and/or expertise. The Certified Building Official shall establish procedures to perform the responsibilities and duties of "Building Official" defined in the CBC. The Certified Building Official enforces compliance with all applicable local, state, and federal regulations, by appropriate reviews and inspection as required therein.  Consistent with California Health and Safety Code, the CBO shall obtain certification from a recognized state, national, or international association within one year of hire. The CBO is responsible for ensuring that all construction projects comply with Title 24, including the administration of the functional building department, interpretation of code requirements, and direction of the code process.

CBOs enforce code compliance for all campus or campus-related projects.  CBOs also ensure that fire and life safety requirements are reviewed by a Designated Campus Fire Marshal (DCFM), and that Disabled Access requirements are reviewed by the Division of the State Architect-Access Compliance (DSA-AC) when required. CBOs shall enforce OSHPD's "licensed clinic" regulations referred to in the Building Code as "OSHPD 3".

CBOs issue building permits and work closely with the DCFM on the issuance of a Certificate of Occupancy, Beneficial Occupancy, and Temporary Occupancy in accordance with the contract documents and permit requirements, and after verification of code compliance and review by other officials, as appropriate. (See 4.1.4 below)

In the administration of these duties, the CBOs may use in-house staff or consultant plans examiners and construction inspectors. All plans examiners and construction inspectors must meet qualifications and requirements for either performing required inspections or for plan review to verify code compliance with the CBC.

(See RD2.2: State Agencies with Plan Approval Authority over University Projects)

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4.1.2 Designated Campus Fire Marshal (DCFM)

The University of California has a Memorandum of Understanding (MOU) with the California Department of Forestry and Fire Protection (CAL FIRE) - Office of the State Fire Marshal (OSFM). Through this MOU, the OSFM delegates responsibility for compliance with fire and life safety regulation to Lead Designated Campus Fire Marshals (Lead DCFM) for all University campuses and properties administered or occupied by the University. Each Facility must appoint one University employee as the Lead DCFM. Other qualified University employees may be appointed as Designated Campus Fire Marshals (DCFMs) in support of the Lead DCFM.

The Lead DCFM is responsible for Title 19 and Title 24 responsibilities for fire and life safety and will coordinate with the appropriate OSFM Division Chief regarding various administrative matters, training, quality control, program evaluation, and technical guidance. The Lead DCFM is responsible for oversight of all DCFMs. The Lead DCFM manages and directs plan review, permitting, construction observation, occupancy, and uses related to the fire and life safety at all facilities owned and/or occupied by University students, faculty, staff, and personnel.

The UC Office of the President administers the MOU and oversees the Designated Campus Fire Marshal Program. On behalf of a Facility, UCOP requests OSFM review and approval of Designated Campus Fire Marsh (DCFM) candidates. In accordance with the MOU, OSFM must provide a final review and determination regarding the acceptability of the candidate’s qualifications for recognition as a DCFM or Lead DCFM.

Facilities shall submit projects to the Designated Campus Fire Marshal in lieu of the Office of the State Fire Marshal. Designated Campus Fire Marshals also have the authority to perform "Existing Facility Inspections" and/or Title 19 Inspections.

A DCFM is the responsible enforcement authority for State Fire Marshal regulations, including granting "fire clearance" before a facility may be occupied. Certified Building Officials work closely with the Designated Campus Fire Marshal, jointly issuing permits, Certificates of Occupancy, Beneficial Occupancy, and/or Temporary Occupancy in accordance with the contract documents, permit requirements, the requirements of this Facilities Manual, including verification of code compliance and review by other officials, as appropriate. (See section 4.1.4)

Reference:

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4.1.3 Office of Environmental Health and Safety

to be added

4.1.4 Occupancy and Ancillary Documents

References (and ancillary documents for authority of enforcement):

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4.2 STATE CODES, REGULATIONS, AND AGENCIES

Three state agencies have plan approval authority for code compliance for most University projects: Office of the State Fire Marshal (OSFM) (see 4.1.2) via DCFM, Division of the State Architect- Access Compliance (DSA-AC) (see 4.2.5), Office of Statewide Health Planning and Development (OSHPD) (see 4.2.6). Construction documents and supporting data are submitted to these code enforcement agencies for final approval (see RD2.2, State Agencies with Plan Approval Authority) as required. Agency reviews result in document approvals and the necessary permits for funding release (state-funded projects), bidding, and construction. Each Facility is responsible for meeting the code requirements of these agencies and obtaining the necessary project approvals from these agencies.

4.2.1 Effective Code Date

By agreement with the OSFM, the effective code compliance date for a University project is the date of the first submittal of Preliminary Drawings (at the end of the Design Development Phase) to the Designated Campus Fire Marshal (DCFM). The project must be designed, reviewed, and constructed to comply with the edition of the California Building Standards Code (CBC) and all applicable local, state, and federal agency codes and regulations in effect at the time of the first submittal. (FM3:1.3.2)

In the event that Preliminary Drawings are not submitted to the DCFM, the date of submittal of the completed Construction Documents to the DCFM shall be the effective code compliance date.

If requested by the Facility, and if approved by both the Certified Building Official and the Designated Campus Fire Marshal, the newest code edition may be used during the 180-day period prior to the effective date of the new code.

Exception for medical projects: acute care hospital projects, skilled nursing facilities, or intermediate care facilities subject to (OSHPD) jurisdiction shall be designed to the latest edition of the California Building Code in effect at the time of filing an application for a permit with OSHPD's office. Verify with your Lead DCFM. (Refer to 4.2.6 for further information on OSHPD Lead DCFM.)

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4.2.2. California Code of Regulations

All Facility design and construction projects must comply with all applicable state building code requirements and all applicable local, state, and federal agency regulations. Several other titles of the California Code of Regulations (CCR) apply to different aspects of University projects. These titles may include operational or construction provisions. Use of these titles depends on the type of project. They include, but are not limited to, the following:

  • California Code of Regulations, Title 8, Industrial Relations (contains requirements for elevators, Cal/OSHA, Construction Safety Orders, and hazardous substances such as asbestos and carcinogens).
  • California Code of Regulations, Title 13, Motor Vehicles.- Hazardous Materials Transportation.
  • California Code of Regulations, Title 14, Natural Resources.
  • California Code of Regulations, Title 17, Public Health - Radiation Safety.
  • California Code of Regulations, Title 19, Public Safety (outlines the Office of the State Fire Marshal authority and regulations).
  • California Code of Regulations, Title 20, Public Utilities and Energy.
  • California Code of Regulations, Title 21, Public Works.
  • California Code of Regulations, Title 23, Waters (contains compliance information for water handling and treatment, Underground Storage Tank Regulations, Storm Water Program sets development standards on landscape, paving, roofing and other impervious surface changes).
  • California Code of Regulations, Title 24, California Building Standards Codes. (See 4.2.3).
  • California Code of Regulations, Title 25, Housing and Community Development. – Modular Buildings (trailers).
  • California Code of Regulations, Title 26, Toxics.
  • California Code of Regulations, Title 27, Environmental Protection.

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4.2.3 California Building Code

The University has adopted the California Code of Regulations, Title 24, California Building Standards Code, for code compliance. Some codes are based on nationally recognized model codes, while others are California's codes. California adds its requirements, called "amendments," to the model codes. Codes also reference national standards developed by organizations such as the National Fire Protection Association (NFPA), the American Society of Civil Engineers (ASCE), etc.

California Code of Regulations, Title 24, California Building Standards Code, consists of the following parts:

 

4.2.4 California Energy Code

The University uses the energy efficiency requirements of Title 24, Part 6, California Energy Code, for its projects. The University Sustainable Practices Policy requires Green Building design and clean energy standards. Responsible design professionals, as selected by the Facility, are required to submit specific certification (as required by the California Energy Code) to the Building Official for inclusion in the permanent project record documents file. Copies of the Title 24 compliance forms for both residential and nonresidential construction are available from the California Energy Commission.

Additional References:

-California Energy Commission-Energy Efficiency Standards.
-Blueprint Newsletter of the California Energy Commission/Energy Efficiency Division's Efficiency Standards Office.

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4.2.5 Division of State Architect, Access Compliance

The University is responsible for enforcing compliance with the California accessibility standards. For University projects funded in whole or in part with state funds, the Division of the State Architect (DSA-AC) has plan approval authority for disabled access code compliance. For University projects with no state funding, the Facility may elect to use a Certified Access Specialist (CASp) for plan review in lieu of the DSA-AC. Each Facility is also responsible for compliance with the American Disabilities Act (ADA) (see 4.4.1). DSA-AC does not review for compliance with ADA. Furthermore, State and local officials do not have the authority to enforce the ADA on behalf of the Federal government. (See 4.4.1, see also ADA Certification of State Accessibility Requirements.)

4.2.6 Office of Statewide Health Planning and Development (OSHPD)

The Office of Statewide Health Planning and Development (OSHPD) performs plan reviews and construction inspection of hospital and acute health care facilities including Acute Care Hospitals, Acute Psychiatric Hospitals, and Skilled Nursing Facilities (excluding certain licensed clinics). (See OSHPD website.)

The Alfred E. Alquist Hospital Facilities Seismic Safety Act (HSSA) passed in 1973, ensures robust construction standards for health care facilities. The HSSA established the Office of Statewide Health Planning and Development (OSHPD). OSHPD is the Authority Having Jurisdiction for construction and renovations of health care facilities including Acute Care Hospitals, Acute Psychiatric Hospitals, and Skilled Nursing Facilities (excluding certain licensed clinics). These requirements are located in Title 24, of the California Code of Regulations. OSHPD′s responsibilities for code compliance are carried out by its Facilities Development Division (FDD). Some of FDD’s responsibilities include: establishing building standards, plan review, seismic compliance, post-earthquake evaluations, and construction observations.  

Each University medical center has a Memorandum of Understanding (MOU) with OSHPD. The MOU authorizes qualified DCFMs to act as OSHPD Fire Life and Safety Officers (FLSO) on behalf of the FDD. A University OSHPD Lead DCFM manages and directs health facility plan review and construction observation related to the fire and life safety at the University's medical centers. OSHPD will serve as the building official for architectural, electrical, mechanical, and structural systems and coordinate with the OSHPD Compliance Officer and District Structural Engineer to conduct construction observation along with the OSHPD Lead DCFM.

Contact the Lead Designated Campus Fire Marshal to verify whether a Medical Center is enrolled in the program.

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4.2.7 California Coastal Commission

Any University project within the boundary of the coastal zone shall be reviewed and approved by the California Coastal Commission. (See California Coastal Commission website.)

4.2.8 Division of Industrial Safety and Health, Elevator Unit

The Elevator Unit of the Division of Industrial Safety and Health reviews the construction or alteration of elevators. Cal/OSHA-ES requirements are located in Title 8, Elevator Safety Orders and other applicable code sections. (See Elevator Unit website.)

 

4.3.1 LOCAL JURISDICTIONS

All Facilities owned, leased, designed, constructed, altered, or renovated with intent or future intent to support the mission of the University are under the jurisdiction and responsibility of the University and delegated Facility administration. Some rare exceptions may apply. Consult with Office of General Counsel for exceptions. Both Facility and local fire departments shall review a Facility's emergency access plans. The local agency may analyze road location, configuration, turning radius, width, and location of fire hydrants.

With the exception of emergency access plans, local jurisdictions typically neither review nor approve University Projects, but a Facility may want or need to consult with local jurisdictions in many circumstances, particularly with respect to utilities. Considerations include system impacts, access and right-of-way, easements, utility consumption, and conditions for service.  Also, some local fire departments may have delegated authority from the State Fire Marshal for fire and life safety issues.  For queries, contact the Lead DCFM.  Other common authorities include:

  • Water districts
  • Sewer (sanitary) districts (may have enforcement authority for waste water control)
  • Electrical power companies
  • Natural gas companies
  • Telephone companies

When the University leases property to a separate entity, and/or enters into privatized agreements, the University typically continues to act as the Authority Having Jurisdiction (AHJ) with enforcement authority consistent with University policies and obligations to State and Federal Law. Facilities must identify the AHJ in such agreements and contracts. For further information contact the Office of General Counsel or the Office of the President.

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4.3.1 Air Quality Management Districts

Facilities are subject to both the federal and state Clean Air Acts, which are implemented through regional air quality management districts. Each air quality management district's regulations depend upon its clean air plan to address air quality in that district. Each Facility is responsible for meeting the requirements of these districts as they relate to capital improvement projects. See the California Local Air District Directory and section 4.5.2 below and consult with Facility Environmental Health and Safety offices for additional information regarding district regulations which may apply to the project.  It is essential that the Facility Environmental Health and Safety Office be contacted to determine all such district regulations that apply to a project.

4.3.2 Storm Water Programs

California Code of Regulations Title 23 Waters.  Title 23 established a Storm Water Program setting development standards on all landscape, paving or roofing changes where the original size is increased by 2,500 square feet or more in area for treating stormwater runoff under the Phase II MS4 Permit (Municipal Separate Storm Sewer Systems).

The Phase II MS4 Permit requires the following items for each construction project to be deemed complete for State Water Resource Board reporting: 

  • Certification Statement from Engineer of record that treatment devices meet MS4 requirements,
  • Inspector of Record approval of installation,
  • Submittal to the University of Operations and Maintenance Manual for any and all stormwater devices.

Projects should include these requirements in the contract documents as needed.

Project sites greater than one acre are also obligated to file for the Construction General Permit (CGP) in the California State Water Resources Control Board's Storm Water Multiple Application and Report Tracking System (SMARTS) database. (See California State Water Resources Control Board website). Projects that are designing or adding industrial, commercial facilities, or shipping and warehouse operations may be subject to the State Water Board Industrial General Permit.

The SMARTS database provides a platform where dischargers, regulators, and the public can enter, manage, and view storm water data including permit registration documents, compliance, and monitoring data associated with California’s Storm Water General Permits.

Both the Phase II MS4 Permit and Construction General Permit require treatment of stormwater runoff when adding or modifying more than 2,500 square feet of impervious surfaces, including roofing and paving area. Common examples of stormwater treatment include bioswales, landscaping, rain collection/cisterns, tree planting, green roofs, etc. Projects must document these changes using the California State Water Resources Control Board’s Post Water Balance Calculator or by similar means. Each Facility maintains requirements for Best Management Practices (BMP's).  Consult with the campus EH&S Office and review the Division One specification.

Each Facility must review the Long Range Development Plan (LRDP) requirements and compare it to MS4 regulations when designing for stormwater treatment. The MS4 permit also requires the Facility to develop legal enforcement standards, which may have some direct involvement and impact to construction and development sites. Engagements with Facility Environmental, Health and Safety offices, agencies, and the public may include various levels of notices, violations, and fines.  Consult with campus planning for further assistance with the LRDP.

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4.4 FEDERAL REGULATIONS

Facilities are subject to the Americans with Disabilities Act, the Clean Air Act, the Clean Water Act, the Resource Conservation and Recovery Act, and the regulations pertaining to underground storage tanks. Specific projects may also be subject to numerous other Federal regulations not listed here. It is essential that the Facility Environmental Health and Safety Office be contacted to determine all such regulations that apply to any project.

4.4.1 Americans with Disabilities Act

Each Facility is responsible for compliance with current Americans with Disabilities Act (ADA) requirements.

The Americans with Disabilities Act became law on July 26, 1990. This civil rights law prohibits discrimination against any "qualified individual with a disability." Title II, Subpart A, applies to the University:

"No qualified individual with a disability shall, by reason of such disability, be excluded from participation in or be denied the benefits of the services, programs, or activities of a public entity or be subjected to discrimination by any such entity." (See ADA Title II.)

On July 15, 2016, the Department of Justice revised the ADA Title II and Title III regulations to implement the ADA Amendments Act of 2008 that further clarified a public accommodation to provide auxiliary aids and services for people with disabilities effective January 17, 2017.

The University is also required to comply with the accessibility requirements found in California law in Part 2 of the California Building Code.

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4.4.2 Clean Air Act

The Clean Air Act (CAA) regulates stationary and mobile sources of air pollutants through National Ambient Air Quality Standards (NAAQS) and National Emission Standards of Hazardous Air Pollutants (NESHAPs). Major sources of air emissions include combustion equipment, process units, material storage areas, and mobile vehicle fleets.

Title V Operating Permits Program. Title V is a permitting program for all major sources of regulated air pollutants. The definition of a major source depends on a particular air district. Generally, a major source is one that has the potential to emit more than 100 tons per year (tpy) of any criteria pollutant or 10 tpy of any hazardous air pollutant (HAP) or 25 tpy of HAPs in the aggregate. Boiler emissions have placed several facilities into the Title V program. Each local air district administers the Title V Permit Program. For further information, contact the Facility Environmental Health and Safety office.

Protection of Stratospheric Ozone; Refrigerant Recycling. These regulations under the CAA establish a recycling program for ozone-depleting refrigerants recovered during the servicing and disposal of air-conditioning or refrigeration equipment.

Facilities Compliance Guidelines. The Facility is responsible for ensuring that equipment complies with the Clean Air Act requirements and for obtaining necessary permits.

4.4.3 Clean Water Act

Wastewater (40 CFR parts 122 and 403). In general, Facilities discharge campus wastewater into municipal sanitary sewer systems for off-site treatment at local wastewater treatment plants (WWTPs). As "indirect dischargers," Facilities are governed by local wastewater pretreatment standards administered through industrial wastewater discharge permits issued to Facilities by local WWTPs. Local pretreatment standards vary widely depending upon the WWTP's capacity, condition, and effluent discharge limitations.

Facilities Compliance Guidelines. The Facility is responsible for compliance with local wastewater pretreatment standards and permit limitations, including any monitoring and reporting requirements.

Stormwater ("Industrial" facilities [40 CFR Part 122]). Under Phase I stormwater regulations, which are designed to control "non-point source" pollution from stormwater runoff, certain discrete facilities may be required to obtain NPDES stormwater discharge permits. These facilities include landfills, wastewater treatment plants, steam electric power generating facilities (possibly co-gen plants), and Facility bus maintenance facilities. Permit conditions include preparing a site-specific stormwater pollution prevention plan, and monitoring and recordkeeping requirements.

Facilities Compliance Guidelines. The Facility is responsible for obtaining discrete "industrial facility" stormwater discharge permits and complying with all permit conditions and requirements, including preparation of a Stormwater Pollution Prevention Plan (SWPPP) for discrete facilities.

Stormwater (Construction sites >1 acre in size [40 CFR Parts 122-124]). Phase II stormwater regulations require that all Facility construction sites greater than one acre in size obtain a NPDES stormwater discharge permit. Permit conditions include preparing a site-specific stormwater pollution prevention plan, and monitoring and record keeping requirements.

Facilities Compliance Guidelines – The Facility is responsible for obtaining discrete construction site stormwater discharge permits (for all sites larger than one acre) and complying with all permit conditions and requirements including preparation of a Stormwater Pollution Prevention Plan (SWPPP) and implementation of appropriate sediment and erosion controls on each site.

Stormwater (Facility-wide [Phase II regulations 40 CFR Parts 122-124]) - Phase II revisions to previous stormwater regulations require that all state Facilities obtain a stormwater discharge permit covering runoff from the entire Facility. Permit conditions include preparing a site-wide stormwater management plan, and monitoring and recordkeeping requirements.

Facilities Compliance Guidelines – The Facility is responsible for obtaining a Facility-wide stormwater discharge permit including those off-site facilities captured under the regulations. The Facility is responsible for complying with all permit conditions and requirements including preparation of a Facility-wide Stormwater Management Plan (SWMP) and implementation of selected Best Management Practices (BMPs).

Additional References:

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4.4.4 Hazardous Waste laws

Resource Conservation and Recovery Act. Resource Conservation and Recovery Act (RCRA) and its counterpart in the California hazardous waste control laws manage the generation, transportation, and disposal of hazardous waste from cradle to grave. Each Facility is regulated as a generator, typically because of chemical usage in laboratories. However, there are other Facility activities that generate hazardous waste such as: transformer oil, janitorial cleaning compounds, vehicle fluids, maintenance materials, print shop inks and dyes, and photography shop developing solutions. The hazardous waste generator permit program is administered by each county's Certified Unified Program Agency (CUPA) under a Memorandum of Agreement with the California Department of Toxic Substances Control. In addition, various federal state, and local regulations apply to the transport, storage, handling, and use of hazardous materials.

Regulations Pertaining to Underground Storage Tanks. Many petroleum products such as gasoline, diesel fuel, waste oil, heating oil, and vehicle fluids are often stored in underground tanks in order to comply with building and fire codes. Federal and state regulations require that all steel underground fuel tanks must be fitted with secondary containment or both interior lining and cathodic protection; all tanks must have tank level monitors, an overfill prevention system, and a spill container; and all underground pressurized piping installed before January 1, 1984 must be retrofitted with secondary containment. The permitting of underground storage tanks is administered by each county's Certified Unified Program Agency (CUPA) under a Memorandum of Agreement with the State Regional Water Quality Control Boards.

Facilities Compliance Guidelines. Each Facility is responsible for compliance with federal and state requirements and obtaining the necessary permits.

Caveat: This chapter sets out some, but not all, of the codes and regulations that might typically be applicable to a Facility project. This list is not exclusive. It is essential that project managers and planners contact the Designated Campus Building Official and the the Facility Environmental Health and Safety office to determine all such codes and regulations that apply to any project.

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Revision August 31, 2018 (Change # FM 18-005-P)

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