Do you have everything you need on file?

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Do you have everything
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Do you have everything you need on file?

  1. 1. Required OSHA / EPA Paperwork Glorianna L. Cooley, REM, CSP EHS Engineer April 25, 2013 Do you have everything you need on file?
  2. 2. Presenter Glorianna L. Cooley, REM, CSP • EHS Engineer • 8+ years in the EHS field • gcooley@kpaonline.com • (614) 432-5044
  3. 3. Regulatory Agencies Requiring Paperwork
  4. 4. Agenda • Regulatory Site Visit Overview • OSHA Paperwork • EPA Paperwork • DOT Paperwork – PHMSA Paperwork • Local City/State Paperwork
  5. 5. Regulatory Site Visit Overview • Introduce inspectors to applicable managers • Find out the purpose of the inspection • Have safety/environmental records ready • Escort them through the appropriate area • Have a closing conference
  6. 6. OSHA Paperwork • Emergency Response – Required Written Program – Annual Required Training – Evacuation Maps Do you have what you need on file? Yes No
  7. 7. OSHA Paperwork • Hazard Communication – Required Written Program – Annual Required Training – Material Safety Data Sheets (MSDS) Do you have what you need on file? Yes No
  8. 8. OSHA Paperwork • Forklift Safety – Required Written Program – 3 Year Required Training – Equipment Inspections – Manufacturer Written Approval for Attachments Do you have what you need on file? Yes No
  9. 9. OSHA Paperwork • Respiratory Protection – Required Written Program – Annual Required Fit Testing & Training – Medical Evaluations – Voluntary Use App D Forms • http://www.osha.gov/SLTC/etools/respiratory/voluntaryuses.html Do you have what you need on file? Yes No
  10. 10. OSHA Paperwork • Required Paperwork – Bloodborne Pathogens Program – OSHA 300 Log • http://www.osha.gov/recordkeeping/new-osha300form1-1-04.pdf – PPE Hazard Assessments Do you have what you need on file? Yes No
  11. 11. OSHA Paperwork • Required Monthly Inspections – Fire Extinguishers – First Aid Kits – Eye Wash Stations – Exit Signs – Oil Water Separators • Required Annual Inspections – Fire Suppression Systems – Automotive Lifts – Overhead Cranes – Forklifts Do you have what you need on file? Yes No
  12. 12. OSHA Paperwork • Additional Required Training – Automotive Lift Safety – Personal Protective Equipment Do you have what you need on file? Yes No
  13. 13. EPA Paperwork • Refrigerant Recovery & Recycling – Register all AC Machines with the EPA • http://www.epa.gov/ozone/title6/609/mvac_cert_form.pdf – All Technician AC Cards on file Do you have what you need on file? Yes No
  14. 14. EPA Paperwork • 6H Area Source Rule – Notification of Compliance to the EPA – 6H Painter Training – 98% Efficiency Filter Documentation Do you have what you need on file? Yes No
  15. 15. EPA Paperwork • Waste Disposal – Tires – Batteries – Used Oil – Used Oil Filters – Antifreeze – Waste Paint – Paint Booth Filters – Waste Solvents – Oil Water Separator Clean Out – Lead Weights – Brake Dust – Aerosol Cans – Light Bulbs – Parts Washer Skimmer Do you have what you need on file? Yes No
  16. 16. EPA Paperwork • TCLP Test Results – Oil Water Separator – Water Based Paint – Paint Booth Filters Do you have what you need on file? Yes No
  17. 17. EPA Paperwork • SPCC Plan – Required if more than 1320 gallons – Requires secondary containment – Requires SPCC training – Requires tank testing Do you have what you need on file? Yes No
  18. 18. EPA Paperwork • UST Compliance – Class A, B, C Operator Training – Required Maintenance – Required Testing Do you have what you need on file? Yes No
  19. 19. EPA Paperwork • EPA ID # • Hazardous Waste Generator Status – CESQG – SQG – LQG Do you have what you need on file? Yes No
  20. 20. EPA Paperwork • Tier II Reporting – 10,000 lbs of any chemical – 500 lbs of any extremely hazardous chemical – Must by filed by March 1st every year to 3 places: • SERC • LEPC • Local Fire Dept Do you have what you need on file? Yes No
  21. 21. DOT Paperwork • Hazmat Shipping – 3-Year DOT Training – 24-Hr Emergency Response Phone # • PHMSA – 1000 lbs of hazmat in transit requires a Placard – Must register with PHMSA – Must carry DOT Emergency Response Guidebook or MSDS with shipment Do you have what you need on file? Yes No
  22. 22. Local City/State Paperwork • Air Permits – Body Shops – Gas Dispensing Facilities Do you have what you need on file? Yes No
  23. 23. Facility Inspections • Now that the inspector has reviewed your paperwork – let’s take a look in your shop!
  24. 24. Questions….. Glorianna L. Cooley, REM, CSP EHS Engineer 614-432-5044 gcooley@kpaonline.com

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