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

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Collision Repair and Service Center Compliance …

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

Published in Business , Technology
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  • 1. – KPA CONFIDENTIAL – Collision Repair and Service Center Compliance DOT, OSHA and EPA Compliance Priorities for Automotive Service and Collision Repair Centers
  • 2. Speakers Moderator Presenter Becky Ross Marketing Manager 303-228-8753 bross@kpaonline.com Chuck Elliott SE District Manager 404-626-6310 celliott@kpaonline.com
  • 3. Safety and Environmental Requirements 3– KPA CONFIDENTIAL –
  • 4. DOT HazMat Requirements 4– KPA CONFIDENTIAL –
  • 5. 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.
  • 6. DOT HazMat Requirements
  • 7. DOT HazMat Requirements 7– KPA CONFIDENTIAL – 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.
  • 8. 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.)
  • 9. Safety and Environmental Requirements
  • 10. Safety and Environmental Requirements
  • 11. Safety and Environmental Requirements
  • 12. Safety and Environmental Requirements
  • 13. Safety and Environmental Requirements
  • 14. Workplace Safety
  • 15. Written Programs and Training for: Emergency Response Plan OSHA Minimum Requirements
  • 16. Written Programs and Training for: Right to Know Program  Hazard Communication  Personal Protective Equipment  MSDS for all Hazardous Materials  Chemical Inventory OSHA Minimum Requirements
  • 17. • Written Programs and Training for: Forklift Safety Program  Required Every 3 Years  Requires Classroom and Driving Test OSHA Minimum Requirements
  • 18. • 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
  • 19. Injury Illness and Prevention Program  Written Program  OSHA 300 Logs  OSHA 301  OSHA 300A Posting OSHA Minimum Requirements
  • 20. 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
  • 21. GRINDERS OSHA Minimum Requirements
  • 22. Strippers and Cleaners Containing Methylene Chloride OSHA Minimum Requirements
  • 23. OSHA Minimum Requirements
  • 24. Environmental Protection Agency Environmental Compliance
  • 25. 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
  • 26. 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
  • 27. Environmental Protection Agency • Land • Air • Water Environmental Compliance
  • 28. Environmental Protection Agency • Land – Wastes and USTs • Air – Refrigerants and Painting • Water – Oil Spills Environmental Compliance
  • 29. Environmental Protection Agency • Land – Wastes and USTs • Air – Refrigerants and Painting • Water – Oil Spills Environmental Compliance
  • 30. 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.
  • 31. 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?
  • 32. www.epa.gov/enviro/facts/rcrainfo/search.html HW Generator Status?
  • 33. HW Generator Status?
  • 34. HW Generator Status?
  • 35. 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?
  • 36. GREEN Shop Practices
  • 37. 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
  • 38. 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.
  • 39. 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).
  • 40. 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.
  • 41. Keep Waste Containers Closed • Keep all hazardous waste containers closed at all times except when adding waste to the container. Air Compliance
  • 42. 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
  • 43. • 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
  • 44. • Needed if you have more than 1320 gallons of petroleum storage capacity on one site. – KPA CONFIDENTIAL – Water Compliance
  • 45. 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
  • 46. 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.
  • 47. Contact Information 47– KPA CONFIDENTIAL – www.kpaonline.com bross@kpaonline.com 866-356-1735