collision repair and service center compliance dot, osha and epa compliance priorities for...

– KPA CONFIDENTIAL –

Collision Repair and Service Center Compliance

DOT, OSHA and EPA Compliance Priorities for Automotive Service and Collision Repair Centers

Speakers

Moderator Presenter

Becky RossMarketing Manager

303-228-8753

bross@kpaonline.com

Chuck ElliottSE District Manager

404-626-6310

celliott@kpaonline.com

Safety and Environmental Requirements

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DOT HazMat Requirements

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DOT HazMat Requirements

ValuJet Flight 592, en route from Miami to Atlanta,

crashed in the Florida Everglades on May 11, 1996,

all of the 109 people aboard died.

DOT HazMat Requirements

DOT HazMat Requirements

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Employees Needing Hazmat Training:

Anyone involved in the shipment of HazMat

must be trained:

Parts Department Employees

Shipping and Receiving Clerks, Drivers and Supervisors

Service Department Employees

Anyone who signs a Hazardous Materials Manifest for waste

removal.

Collision Center Employees

Painters or anyone who signs a Hazardous Materials Manifest for

waste removal.

Department of Transportation

Hazardous Materials Shipping Compliance

•Ensure that all employees involved in the transportation of hazardous

materials are trained every 3 years.

•Anyone shipping hazardous wastes in an amount that requires placards

(typically more than 2 drums of paint waste) is required to register with the

DOT as hazardous materials shipper and pay additional fees.

•A 24 Hour emergency response telephone number must be listed on

hazardous material shipping papers. (Any person who ships a hazardous

material must provide a 24 hour emergency response telephone number for

use in the event of an emergency and write in this # on the shipping

papers.)

Safety and Environmental Requirements

Safety and Environmental Requirements

Safety and Environmental Requirements

Safety and Environmental Requirements

Safety and Environmental Requirements

Workplace Safety

Written Programs and Training for:

Emergency Response Plan

OSHA Minimum Requirements

Written Programs and Training for:

Right to Know Program

Hazard Communication

Personal Protective Equipment

MSDS for all Hazardous Materials

Chemical Inventory

OSHA Minimum Requirements

• Written Programs and Training for:

Forklift Safety Program

Required Every 3 Years

Requires Classroom and Driving Test

OSHA Minimum Requirements

• Written Programs and Training for:

Respiratory Protection Program

Written Program

Medical Evaluation

Annual Training

Annual Fit-Testing

Maintain a Change-Out Log

OSHA Minimum Requirements

Injury Illness and Prevention Program

Written Program

OSHA 300 Logs

OSHA 301

OSHA 300A Posting

OSHA Minimum Requirements

To Review, OSHA Requires a Written Program

and Current Training for:

Personal Protective Equipment

Emergency Response

Hazard Communication

Respiratory Protection

Forklift Safety Training

OSHA Minimum Requirements

GRINDERS

OSHA Minimum Requirements

Strippers and Cleaners

Containing Methylene Chloride

OSHA Minimum Requirements

OSHA Minimum Requirements

Environmental Protection Agency

Environmental Compliance

Why do we need to concentrate on environmental compliance?

• The EPA typically has the authority to issue much larger fines.

• If you knowingly or intentionally violated a regulation, you can be sent to prison.

Environmental Compliance

Why More Difficult?

1. The rules are much more complicated.– Safety Issues based on Common Sense

– Environmental Issues based on Science

2. Each State has their own EPA enforcement agency.

3. Audits are much more random and unpredictable.

Environmental Compliance

Environmental Protection Agency

• Land

• Air

• Water

Environmental Compliance

Environmental Protection Agency

• Land – Wastes and USTs

• Air – Refrigerants and Painting

• Water – Oil Spills

Environmental Compliance

Environmental Protection Agency

• Land – Wastes and USTs

• Air – Refrigerants and Painting

• Water – Oil Spills

Environmental Compliance

Land – Wastes– Non-Hazardous Wastes

– Hazardous Wastes

• Resource Conservation and Recovery Act (RCRA)

Environmental Compliance

You need to be able to prove to the EPA that

you are disposing of all of your waste streams

in the proper manner.

Large Quantity

Generator (LQG)

Small Quantity Generator

(SQG)

Conditionally Exempt Small

Quantity Generator (CESQG)

Hazardous Waste Generator Status

How much

Hazardous Waste

do you actually

generate?

How much

Hazardous Waste

does the EPA think

you generate?

www.epa.gov/enviro/facts/rcrainfo/search.html

HW Generator Status?

HW Generator Status?

HW Generator Status?

Determine if the EPA has you classified as a LQG, SQG or CESQG.

If you are not registered properly, make sure you correct this.

HW Generator Status?

GREEN Shop Practices

Large Quantity Generator

(LQG)

Generates > 2200 lbs/month

> 4

55 gal Drums

You should not be in this category (most regulated)

Small Quantity Generator (SQG)

Generates 220 – 2200 lbs/month

½ - 4

55 gal Drums

Only for very large paint shops (moderately regulated)

Conditionally Exempt Small

Quantity Generator (CESQG)

Generates < 220 lbs/month

< ½

55 gal Drum

Most Service Centers and Body Shops (minimal regulations)

EPA Hazardous Waste Generator Status

Environmental Compliance

No Liquids in the Trash.

All paint related wastes must be run through the distiller.

Paint splashes on trash cans and dumpsters indicate that liquids are being thrown in the trash and have not completely dried out.

Environmental Compliance

Spray Cans

Prior to placing spray cans in the trash you must be sure they are actually empty (no more air or paint will come out of the can).

Environmental Compliance

Label All Waste Containers

•All containers of hazardous waste must be labeled with the yellow “Hazardous Waste” label.

•All Universal Wastes must be properly labeled.

Keep Waste Containers Closed

• Keep all hazardous waste containers closed at all times except when adding waste to the container.

Air Compliance

Paint Mixing Room

The door to the paint mixing room must remain closed except when entering or exiting the room.

Use the Paint Booth

The only painting allowed outside of the paint booth must be done with 3 oz or smaller cups.

Air Compliance

• Ensure dealership has copies of all technicians’ 609 certifications on file.

• Ensure the dealership can prove they have registered their A/C equipment with the EPA.

• Fines for 1 uncertified technician start at @ $15,000.

– KPA CONFIDENTIAL –

Air Compliance

• Needed if you have more than 1320 gallons of petroleum storage capacity on one site.

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Water Compliance

Environmental Compliance

Required Training

Ensure that all employees involved with the respective activities are properly trained and that you can document the training:

Annual Respiratory Protection Training and Fit-Testing

Annual EPA Hazardous Waste Training

DOT Hazardous Materials Shipping (every 3 years)

New 6H Paint Spray Training (every 5 years)

Forklift Training (every 3 years)

Refrigerant Recovery and Recycling

Regulatory Visit Protocol

• Designate a facility representative to handle regulators.

• Notify facility manager and your consultant.

• Find out:

Why they are here?

What specifically do they want to see?

• Be cordial, do not treat them as the enemy.

• DO NOT Volunteer Information that they are not asking about.

• Never admit guilt.

• Most fines are appealable.

• Inspectors frequently make mistakes.

Contact Information

47– KPA CONFIDENTIAL –

www.kpaonline.com

bross@kpaonline.com

866-356-1735