How to Avoid OSHA and EPA Traps at Your Collision Center


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How to Avoid OSHA and EPA Traps at Your Collision Center

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  • Adequate documentation will include a statement about whether or not the waste is hazardous as well as copies of all documentation. Documentation isrequired for all wastes, both non-hazardous and hazardous. Some examples of documentation that may be included are:• Generator Knowledge Material Safety Data Sheets (MSDSs);• Analytical results from a state-certified laboratoryAnother document that is inadequate by itself is a Waste Profile from a contractor. These forms are often filled out by hazardous waste transporters and contractors through interviews with generators and frequently are not supported by any real investigation into the process generating the waste.Conducting an adequate determination for each waste stream will help facilities stay in compliance and avoid costly mistakes. These determinations are the foundation of any good hazardous waste management program and will help reduce management and disposal costs.How can it reduce your costs?
  • Every waste that you generate and dispose of must have a waste determination completed. For a material to be a hazardous waste, the material must first be classified as a solid waste. Generally speaking, a material is a waste when it can no longer be used for its intended purpose and will be disposed, reclaimed, or recycled. Hazardous wastes are wastes known to be harmful or potentially harmful to human health or the environment.There a few ways that you may come to this determination. Code of Federal Regulations states that a waste is solid waste if it is a solid or a liquid that is discarded, abandoned, recycled, or considered inherently waste-likeCan of paint example…is it a waste or will I reuse…If waste is it hazardous. We determine that by determining if it is a characteristic waste or listed.
  • How to Avoid OSHA and EPA Traps at Your Collision Center

    1. 1. October 18, 2012 Zach Pucillo CSP
    2. 2. Moderator Becky Ross Marketing Manager Office: (303) 228-8753
    3. 3. Presenter Zach Pucillo Engineer III KPA (317) 201-2335
    4. 4. If you have questions during the presentation, please submit them using the “Questions” feature Questions will be answered at the end of the webinar Copyright © 2012 TK Carsites. All rights reserved. Questions
    5. 5. Interact During the Webinar! #DealerWeb Becky Ross @kpaonline
    6. 6. Overview -Hazard Communication -Emergency Response -Personal Protective Equipment -Respiratory Protection -Paint Booth Compliance -Air Regulations -Land Compliance -Recordkeeping
    7. 7. Hazard Communication -Written program -Chemical inventory -Material Safety Data Sheets (MSDS) -Container labeling -Employee training
    8. 8. Emergency Response -Written Program – Fire Response – Evacuation Procedures – Spill Response – Natural Disaster Response -Employee Training -Evacuation Map
    9. 9. Personal Protective Equipment -Written Hazard Assessment – Each Department – Certified by Manager -Written Program -Selection of PPE -Employee Training
    10. 10. Personal Protective Equipment Equipment for a Collision Center -Welding Helmets -Welding Gloves -Hybrid Vehicle Gloves -Anti Vibration Gloves -Respirators -Ear Plugs/Muffs -Face Shield -Cut Resistant Gloves
    11. 11. Respiratory Protection -Written Program -Employee Training -Medical Evaluations by a PLHCP -Respirator Fit Testing -Change out log
    12. 12. Respiratory Protection Is there a need? Isocyanates Organic Vapors Air borne particulates Metals
    13. 13. Respiratory Protection Written Respiratory Protection Program The Program Must Include the Following: -Procedures for selecting respirators for use in the workplace -Medical evaluations of employees required to use respirators -Fit testing procedures for tight-fitting respirators -Procedures for use of respirators in emergency situations -Procedures and schedules for cleaning and maintaining respirators -Procedures to ensure adequate air quality for atmos-supplying respirators -Training of employees in the respiratory hazards -Training of employees in the proper use of respirators (donning) -Procedures for regularly evaluating the effectiveness of the program The program must be available to employees at any time
    14. 14. Respiratory Protection Respiratory Protection Training -Why the respirator is necessary and how one could be compromised -What the limitations and capabilities of the respirator are -How to use the respirator effectively in emergency situations -How to inspect, put on and remove, use, and check the seals of the respirator -What the procedures are for maintenance and storage of the respirator -How to recognize medical signs and symptoms that the respirator is defective
    15. 15. Respiratory Protection Medical Evaluations -Is the employee able to wear a respirator? -Must be completed by a PLHCP -Typically a survey filled out by the employee -Online Med Evals -Spirometer Test -How Often -Questionnaire is found at p_id=9783
    16. 16. Respiratory Protection Fit Testing -Required before going into operation with respirator -Required Annually -Qualitative vs Quantitative Portacounts Smoke – Saccharine – Banana Oil - Bitrex -Seal Checks
    17. 17. Respiratory Protection Selection: Supplied Air -Must for bed liners -Best protection against Isocyanates -Change the air filter -Compressor must supply at least “Grade D” breathing air
    18. 18. Respiratory Protection Selection: Dual Cartridge Full/Half Face Respirator Cartridge Selection Storage Seal Check
    19. 19. Respiratory Protection Selection: N95 Dust Mask
    20. 20. Respiratory Protection Change Out Schedule How often should the cartridges be changed out? Lab Analysis Manufacturer’s Recommendation Advisor Genius Program
    21. 21. Respiratory Protection Voluntary Use What if an employee wants to voluntarily wear a respirator? Appendix D of CFR 29 1910.134
    22. 22. Paint Booth Compliance -Constructed of non-combustible materials -Must have a means of egress -NFPA 33 Chapter 9 section 1requires an automatic fire protection system -Lights are to be guarded by laminated, heat treated, or hammered wired glass -Minimum distance from other operations of 3 feet -Local building codes could require a permit or certificate of occupancy -IFC chapter 15 requires spray area permit
    23. 23. Paint Booth Compliance Ventilation -Air Make = 3 changes in 1 hour -Top down is better than cross draft for employee health -Fan output reading must meet the range found in table G10 of next slide -NFPA also requires ventilation to maintain a maximum concentration of flammable vapors to 25% of the Lower Flammability Limit (obtain assistance from the paint booth ventilation installer in calculating this)
    24. 24. Paint Booth Compliance Ventilation Fan Speed Example -Using an air operated gun and have a cross draft up to 100fpm -Booth face is 8ft across and 10ft tall -Booth face = 8ftx10ft = 80ft2 125fpm x 80ft2 = 10,000cfm minimum must be pushed by fans
    25. 25. Paint Booth Compliance Mixing Room -Contain a spill 4 inch sill or pit -Max area of 150ft2 -Approved Automatic Fire Protection System -Portable Fire Extinguishers -The max amount of liquid that can be stored is 300 gallons -Electrical outlets, scales, and computers are rated for Class 1 Division 1 locations -Ventilation on at all times and flow at 150cfm
    26. 26. Air Regulations Air Permits Title V - area source that emits a large amount of chemicals into the atmosphere Non Title V – permit created by states and federally for Native American Reservations, typically smaller sources Permits By Rule – example of exemption for collision centers De Minimis Sources – sources that are exempt from any source and typically requires daily emissions recordkeeping
    27. 27. Air Regulations 6H -1/9/2008 – 40 CFR Part 63 Subpart HHHHHH -Reduces the amount HAPs in the atmosphere -HAPs include the following: Cadmium - Cd Chromium - Cr Lead - Pb Nickel - Ni Manganese – Mn Methylene Chloride
    28. 28. Air Regulations 6H -Paint Booth 4 walls and roof -Prep station 3 walls and a curtains -HVLP Guns -Filters that are 98% efficient -Employee training -Gun cleaning without atomizing -Notification of compliance Checklist is available – contact Becky or Zach
    29. 29. Air Regulations 6H Exemptions -Less than 2 cars/year -Applications cannot contain: Cadmium - Cd Chromium - Cr Lead - Pb Nickel - Ni Manganese – Mn 3 oz Cup exemption/loophole?
    30. 30. Air Regulations State VOC regulations -Enforced by the states (spray application/gun cleaners) -Focuses on Volatile Organic Compounds -Typically involves requirements for the following: Cleaning Equipment State Notification of Compliance Training Written Procedures
    31. 31. Land Compliance Typical Items that could be wastes for a Collision Center -Paint -Paint Booth Filters -Paint Pucks from Solvent Recycler -Solvent Soaked Rags -Paint Cups (dripping factor) -Solvent -Antifreeze -Absorbent -Fluorescent Bulbs -Tires -Oil Water Separator Recycle, Reclaim, Reuse
    32. 32. Land Compliance RCRA Waste Determination Hazardous or Non Hazardous -Generator Knowledge -MSDS review -TCLP (RCRA Metals, VOC…) – Toxicity characteristic leaching procedure
    33. 33. Land Compliance Waste Determinations Characteristic: -Ignitable -Corrosive -Reactive -Toxic Listed: -F-Listed -D-Listed
    34. 34. Land Compliance Generator Status Conditionally Exempt (CESQG) Generates < 220lbs of hazardous waste in a calendar month Small Quantity Generator (SQG) Generates >220lbs but <2200lbs of hazardous waste in a calendar month Large Quantity Generator (LQG) Generates <2200lbs of hazardous waste in a calendar month
    35. 35. Land Compliance CESQG No EPA ID Number No annual reporting No limit on storage for hazardous waste SQG Requires EPA ID Number Some states require annual reporting Can hold hazardous waste onsite for no more than 180 days LQG Requires EPA ID number Federally require reporting and fees Requires written emergency plans Can hold hazardous waste onsite for no more than 90 days
    36. 36. Land Compliance
    37. 37. Recordkeeping Emergency Response -Written Program -Training Rosters -Evacuation Maps Hazard Communication -Written Program -Training Rosters
    38. 38. Recordkeeping Personal Protective Equipment -Hazard Assessment -Training Rosters Respiratory Protection -Written Program -Medical Evaluations -Fit Testing Records -Training Rosters -Respirator Change Out Schedules -Appendix D form (if necessary)
    39. 39. Recordkeeping Paint Booths -Spray and building permit* Air Compliance -Air permit* -6H Notification Form or Exemption Notice -6H Training Certifications -Paint Booth Filter Efficiency Rating -State required solvent recovery notifications*
    40. 40. Recordkeeping Land Compliance -Waste Determinations -Notification of Hazardous Waste Activity -Annual Reports (if required) -Hazardous Waste Manifests Match the Following in waste manifests -Generator Initial Copy -Land Disposal Restriction Form -Designated Copy Sent Back From TSDF Retain these for a minimum of 5 years
    41. 41. Free Consulting Time!