1. 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 in meeting their
Environmental Health & Safety (EHS) needs
Environmental Health and Safety Management
for New York Automobile Dealerships
EHS Inspection: Potential Violations

2. Walden Associates
EHS Inspection
Potential Violations
1. Petroleum Bulk Storage (PBS)
and Chemical Bulk Storage
(CBS)
2. HAZCOM
3. Record keeping
4. Electrical
5. Personal Protective
Equipment (PPE)
6. Fire Extinguishers
7. Respiratory Protection
8. Abrasive Wheel Machinery
9. Welding
10. Power Industrial Trucks
11. Car Wash Station
12. Exit Signs

3. Walden Associates
Potential EHS Violation #1 - PBS and CBS (NYCRR Part 612, 613 & 614)
• Lack of posted registration permit.
• AST not UL listing.
• Lack of components such as leak
detection, vents, etc.
Potential EHS Violation #2 – HAZCOM (OSHA Part 1910.1200)
• Lack of written HAZCOM Plan.
• Lack of employee training records.
• Unlabeled containers in the shop.
EHS Inspection
Potential Violations

4. Walden Associates
Potential EHS Violation #3 – Recordkeeping (OSHA Part 1904 )
OSHA Inspector asks: show me your records and notes
• Lack of records of serious occupational injuries, using OSHA 300 Log.
• Lack of OSHA required plans such as Emergency Action Plan, etc.
Potential EHS Violation #4 – Electrical (OSHA Part 1910)
• Cut and taped extension cords.
• Overloaded extension cords.
EHS Inspection
Potential Violations

5. Walden Associates
Potential EHS Violation #5 – PPE (OSHA Part 1910 Subpart I)
• Employer not providing adequate
personal protective equipment (PPE) such
as proper gloves, goggles, etc.
Potential EHS Violation #6 – Fire Extinguishers (OSHA Part 1910.157)
• Lack of fire extinguishers inspection tags
• Fire extinguishers not spaced
uniformly, readily accessible
and not identified correctly.
EHS Inspection
Potential Violations

6. Walden Associates
Potential EHS Violation #7 – Respiratory Protection (OSHA Part 1910.134)
• Lack of written respiratory protection plan,
medical evaluation of employees, respirators fit
testing, training, etc.
Potential EHS Violation #8 – Abrasive Wheel Machinery (OSHA Part 1910.215)
• Incorrect distance between
abrasive wheel and safety
guard.
EHS Inspection
Potential Violations

7. Walden Associates
Potential EHS Violation #9 – Welding (OSHA Part 1910.252)
Potential EHS Violation #10 – Power Industrial Trucks (OSHA Part 1910.178)
• Welding gas cylinders not chained
or strapped when not in use.
• Fork lift operated by employees
without valid certificate to
operate.
EHS Inspection
Potential Violations

8. Walden Associates
• Illegal discharge to on-site drywell,
potential contamination with heavy
metals.
Potential EHS Violation #11 – Car Wash Station (6 NYCRR Part 750 – SPDES Permit)
Potential EHS Violation #12 – Exit Signs (OSHA Part 1910.37)
• Lack, broken or not sufficient
quantity of exit signs.
EHS Inspection
Potential Violations

9. Walden Associates
What to do to avoid OSHA and environmental penalties:
1. Register your tanks with NYSDEC or other governing agency.
2. Conduct annual HAZCOM training.
3. Prepare OSHA/ Environmental required plans such as HAZCOM Plan, Emergency
Action Plan (EAP), etc.
4. Provide your employees with necessary PPE.
5. Assure that your employees have necessary certification (i.e. to operate power
industrial trucks).
6. Engage a professional to conduct EHS inspection – there might be many more
potential violations in your shop!
EHS Inspection
Conclusions

10. 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