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

[email protected]

Chuck ElliottSE District Manager

404-626-6310

[email protected]

Safety and Environmental Requirements

3– KPA CONFIDENTIAL –

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.



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

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


• Written Programs and Training for:

Forklift Safety Program

Required Every 3 Years

Requires Classroom and Driving Test


• Written Programs and Training for:

Respiratory Protection Program

Written Program

Medical Evaluation

Annual Training

Annual Fit-Testing

Maintain a Change-Out Log


Injury Illness and Prevention Program

Written Program

OSHA 300 Logs

OSHA 301

OSHA 300A Posting


To Review, OSHA Requires a Written Program

and Current Training for:

Personal Protective Equipment

Emergency Response

Hazard Communication

Respiratory Protection

Forklift Safety Training


GRINDERS


Strippers and Cleaners

Containing Methylene Chloride


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.


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.



• Land

• Air

• Water



• Land – Wastes and USTs

• Air – Refrigerants and Painting

• Water – Oil Spills


Land – Wastes– Non-Hazardous Wastes

– Hazardous Wastes

• Resource Conservation and Recovery Act (RCRA)


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?

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

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


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


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.


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).


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.


Air Compliance

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


Water 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


www.kpaonline.com

[email protected]

866-356-1735

http://www.kpaonline.com/

Collision Repair and Service Center Compliance DOT, OSHA and EPA Compliance Priorities for...

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