Walden Associates

Walden Associates In business for over 17 years

Allied Member of the GNYADA for over 10 years

Walden has history of aiding member dealerships with meeting their

Environmental Health & Safety (EHS) needs.

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Environmental Health and Safety Management

for New York Automobile Dealerships

HAZCOM

Walden Associates

Top Ten OSHA Violations

1. HAZCOM (Part 1910.1200)

2. Respiratory protection (Part 1910.134)

3. Abrasive wheel machinery (Part 1910.215)

4. Wiring methods and equipment for general use (Part 1910.305)

5. General requirements (Part 1910)

6. Powered industrial trucks (fork lifts) (Part 1910.178)

7. Portable fire extinguishers (Part 1910.157)

8. Maintenance, safeguard, and operational features for exit routes (Part 1910.37)

9. Hearing conservation (Part 1910.95)

10. Personal Protective Equipment (PPE) (Part 1910 Subpart I)

Walden Associates

HAZCOM 29 CFR 1910.1200

Hazard Communication Standard

Ensure that information regarding all hazards is transmitted to managers/employees in a consistent manner.

(This includes showroom employees!)

A HAZCOM Plan includes:

• Written HAZCOM Plan • Chemical Labeling

• Inventory of Chemicals • SDS Sheets Available

• Training Bottom Line: Develop and Implement a HAZCOM program with training, and keep records on file.

Walden Associates

Employees must receive training when:

• Hired on the job

• Job requires working with chemicals

• New hazard is introduced into the work area

• Annually (HAZCOM awareness training)

HAZCOM 29 CFR 1910.1200

Walden Associates

Obtain copy of HAZCOM standard (Provided in Handbook)

Read and understand the requirements

Assign responsibility for tasks

Prepare inventory of hazardous chemicals

Ensure containers of hazardous chemicals are labeled

Obtain SDS for each hazardous chemical stored on-site

Prepare written program

Make SDSs available to workers

Conduct awareness training of workers

Establish procedures to maintain current program

Establish procedures to evaluate effectiveness

HAZCOM 29 CFR 1910.1200

Checklist for Compliance

Walden Associates

On May 26, 2012 OSHA introduced changes to HAZCOM rule to coordinate it with Globalized Harmonized System (GHS):

Labels – must include a signal word, pictogram, hazard statement and precautionary statement for each

hazard and category.

Safety Data Sheets (SDS) – the new format requires 16 specific sections.

Information and Training - employees must be trained on new labels and SDS by December 1, 2013.

Hazard Classification – chemical manufacturers and importers are required to determine the hazards of

the chemicals they produce or import.

HAZCOM 29 CFR 1910.1200

Flame Health Hazard Gas Cylinder

Walden Associates

WHAT IS HAZARDOUS WASTE?

• Ignitability (flash point < 140 F)

• Toxicity (fails TCLP test)

• Corrosivity (pH less than 2 and more than 12.5)

• Reactivity (unstable, violent reactions with water, typically not stored in repair shops)

Does YOUR Facility Generate more than

220 lbs. of Hazardous Waste per month?

Hazardous Wastes

Walden Associates

HAZARDOUS WASTE IN THE DEALERSHIPS:

• Tires

• Used/Waste Oil

• Used Antifreeze

• Batteries

• Air Bags

• Rags

• Mercury Switches

• Used/Spent Solvents

• Used Oil Filters

• Absorbents

Hazardous Wastes

Walden Associates

Conditionally Exempt Small Quantity Generators

(CESQG)

Small Quantity Generators (SQG)

Large Quantity Generators (LQG)

Conditionally Exempt Small Quantity Generators

(CESQG) meet any of the following conditions:

•Generate no more than 220 pounds per month of

the listed and/or characteristic hazardous waste

•Generate no more than 2.2 pounds per month of

acute hazardous waste

•Store no more than 2,200 pounds of listed and/or

characteristics hazardous waste

•Store no more than 2.2 pounds of acutely hazardous

waste

SQG do not meet CESQG conditions but meet all of the

following conditions:

Generate between than 220 pounds and 2,200 pounds per

month of the listed and/or characteristic hazardous waste

Generate no more than 2.2 pounds per month of acute

hazardous waste

Store no more than 13,200 pounds of listed and/or

characteristics hazardous waste

Store no more than 2.2pounds of acutely hazardous waste

LQG meet any of the following conditions:

Generate more than 2,200 pounds per

month of the listed and/or

characteristic hazardous waste

Generate more than 2.2 pounds per

month of acute hazardous waste

Store more than 2.2 pounds of acutely

hazardous waste

Hazardous Wastes

Walden Associates

Walden Associates Environmental Health & Safety (EHS)

Consulting Services

Health and Safety related:

• Conduct HAZCOM Training

• Written HAZCOM Plans

• Respiratory Protection Plans

• Respirator Fit Test & Training

• Emergency Response Plans

• Indoor Air Monitoring

• Forklift Safety Training

• Hearing Conservation Plans

• OSHA Consulting Auditing and Advice

Environmental related:

• AST Design Permitting and As-Built Registration

• NYC DEP Community Right-to-Know Filings, Right-to-Know

Training

• Environmental Investigations & Site Closures

• Dealership Pre-purchase / Sale (Phase I & II Environmental

Site Assessments)

• UST Upgrades / Design Permitting

• Environmental Compliance Consulting