– KPA CONFIDENTIAL –
Recordkeeping 101: EPA and OSHA Required Paperwork
Thank you for joining the webinar.
We will begin a...
– KPA CONFIDENTIAL –
Recordkeeping 101: EPA and OSHA Required Paperwork
Thank you for joining the webinar.
We will begin a...
Presenter
Nick Bujeaud
District Manager
(860) 995-8023
nbujeaud@kpaonline.com
Questions
• If you have questions
during the
presentation, please
submit them using the
“Questions” feature
• Questions wi...
KPA – Company Profile
• Nationwide
compliance expert on
Safety, Environmental,
HR
• Colorado
Headquarters
• 23 Years Exper...
So you think you’re covered?
– KPA CONFIDENTIAL –
This Week’s Headlines
“US Department of Labor's OSHA takes action to protect America„s
workers with severe violator progra...
Outline
• Training
• Best Management Practices
– KPA CONFIDENTIAL –
EPA
• Waste Determinations*
- Current
• Waste Manifests
- 3 years
- 2 year bill of lading
- Copy #6, Copy #3
– KPA CONFIDE...
EPA
10– KPA CONFIDENTIAL –
DOT HazMat
Training Needed
Hazardous Waste
Training Needed
EPA
– KPA CONFIDENTIAL –
Refrigerant Recovery and Recycling
609 AC Folder, to include:
- Technician Certifications
- Equip...
EPA
– KPA CONFIDENTIAL –
Spill
Prevention, Control, and
Countermeasures Plan
(SPCCP)
A facility starting
operation…
Must.....
EPA
• UST
A. Corrosion Prevention
B. Leak Detection*
C. Financial Responsibility*
D. Closure Records
• Tier II: greater th...
EPA’S NEW 6H RULES
• Notification
• 1/11/2010
• Painter Training
• Spray Gun Selection
• Spray Gun Cleaning
• Spray Booths...
OSHA
• Hazard Communication Plan
Written Plan, current
Chemical Inventory, annual update + 30 year archive
MSDS, current, ...
OSHA
• Emergency Response Plan
current, updated as changes occur
- Fire Response
- Spill Response
- Natural Disasters
– KP...
OSHA
– KPA CONFIDENTIAL –
Hazard Assessment/ PPE Selection*
- current
- updated as new hazards are introduced to the work ...
OSHA
• Respiratory Protection Program
Written Program, current
Respirator Change-Out log
Appendix D for Voluntary use, 1 t...
OSHA
• Forklift
Written Program, current
Employee Certification, 3 years
Daily Inspection
OSHA
• OSHA logs (SIC 5500 exempt)
301: Not Required
300: Current
300A: Post from February 1 through April 30 for
the prev...
Training
• Emergency Response
- ALL employees
- Upon initial employment and annual refresher
- Archive current only
• Haza...
Training
– KPA CONFIDENTIAL –
• DOT Hazardous Materials
- Haz Mat employees
- Within 90 days of initial assignment if ship...
Training
• Forklift
- Forklift Operators
- Upon initial assignment, whenever an incident occurs, and 3 year refresher
- Ar...
Best Management Practices
• Hiring process to include all EHS training in
new EE orientation
• Centralize and organize all...
BMPs
• Clearly identify responsibility and empower
that employee
• Internal Audit Schedule
• Obtain Certificates of Insura...
Nick’s “Do it Now” Top 5
1. If you have over 1,320 gallons of petroleum, start
on that SPCCP!
2. Hazard Assessment and PPE...
Questions and Answers
– KPA CONFIDENTIAL –
QUESTIONS?
Contact Information
– KPA CONFIDENTIAL –
The recorded webinar and presentation slides will be emailed to
you today includi...
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Recordkeeping 101: EPA and OSHA Required Paperwork

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Recordkeeping 101: EPA and OSHA Required Paperwork

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  • The current maximum penalty for a serious violation, one capable of causing death or serious physical harm, is $7,000 and the maximum penalty for a willful violation is $70,000. These will change to $12,000 and $250,000, respectively.
  • The requirements of this rule cover 7 areas; Notification, Painter Training, Spray Gun Selection, Spray Gun Cleaning, Spray Booths, Re-Notification and finally Recordkeeping.
  • Recordkeeping 101: EPA and OSHA Required Paperwork

    1. 1. – KPA CONFIDENTIAL – Recordkeeping 101: EPA and OSHA Required Paperwork Thank you for joining the webinar. We will begin at 10am Mountain Standard Time.
    2. 2. – KPA CONFIDENTIAL – Recordkeeping 101: EPA and OSHA Required Paperwork Thank you for joining the webinar. We will begin at 10am Mountain Standard Time.
    3. 3. Presenter Nick Bujeaud District Manager (860) 995-8023 nbujeaud@kpaonline.com
    4. 4. Questions • If you have questions during the presentation, please submit them using the “Questions” feature • Questions will be answered at the end of the webinar
    5. 5. KPA – Company Profile • Nationwide compliance expert on Safety, Environmental, HR • Colorado Headquarters • 23 Years Experience • 3000 + Clients – Dealerships, Service, Repair • 20 Offices Serving 41 States • Compliance products and services – OSHA – DOT – EPA – Workers’ Comp – Background checking – Onboarding – Harassment – Red Flags – Onsite inspections – Online and onsite training and tracking – And many more…
    6. 6. So you think you’re covered? – KPA CONFIDENTIAL –
    7. 7. This Week’s Headlines “US Department of Labor's OSHA takes action to protect America„s workers with severe violator program and increased penalties” “US Department of Labor's OSHA proposes nearly $136,000 in penalties against Sewon America Inc. for willful and serious safety violations” FAA proposes $53,000 fine against Stewart & Stevenson, LLC for shipping a box containing touch-up paint to FedEx Corp. for transportation by air... “Nebraska firm pays $150,000 fine for waste problems” “EPA fines Iowa battery maker over pollution”
    8. 8. Outline • Training • Best Management Practices – KPA CONFIDENTIAL –
    9. 9. EPA • Waste Determinations* - Current • Waste Manifests - 3 years - 2 year bill of lading - Copy #6, Copy #3 – KPA CONFIDENTIAL –
    10. 10. EPA 10– KPA CONFIDENTIAL – DOT HazMat Training Needed Hazardous Waste Training Needed
    11. 11. EPA – KPA CONFIDENTIAL – Refrigerant Recovery and Recycling 609 AC Folder, to include: - Technician Certifications - Equipment Registrations - Refrigerant Purchasing Records
    12. 12. EPA – KPA CONFIDENTIAL – Spill Prevention, Control, and Countermeasures Plan (SPCCP) A facility starting operation… Must... On or before August 16, 2002 Continue to maintain its existing SPCC Plan in accordance with the SPCC rule. Amend and implement that Plan no later than November 10, 2010 After August 16, 2002, through November 10, 2010 Prepare and implement an SPCC Plan no later than November 10, 2010 After November 10, 2010 Prepare and implement an SPCC Plan before beginning operations Fact Sheets - New Plan when elements of the Plan change - 5 year re- certification - Tank Inspections, monthl y
    13. 13. EPA • UST A. Corrosion Prevention B. Leak Detection* C. Financial Responsibility* D. Closure Records • Tier II: greater than 10,000 lbs. of storage, annual submission, due by March 1 Gasoline: 1,600 gal. Diesel Fuel: 1,399 gal. Battery Acid: approx. 100 used batteries Fuel Oil: 1,282 gal. Antifreeze: 1,111 gal. Motor Oil: 1,389 gal. – KPA CONFIDENTIAL –
    14. 14. EPA’S NEW 6H RULES • Notification • 1/11/2010 • Painter Training • Spray Gun Selection • Spray Gun Cleaning • Spray Booths • Re-Notification • 3/11/2011 • Recordkeeping • Mobile Operations
    15. 15. OSHA • Hazard Communication Plan Written Plan, current Chemical Inventory, annual update + 30 year archive MSDS, current, accessed in under 10 minutes – KPA CONFIDENTIAL –
    16. 16. OSHA • Emergency Response Plan current, updated as changes occur - Fire Response - Spill Response - Natural Disasters – KPA CONFIDENTIAL –
    17. 17. OSHA – KPA CONFIDENTIAL – Hazard Assessment/ PPE Selection* - current - updated as new hazards are introduced to the work area
    18. 18. OSHA • Respiratory Protection Program Written Program, current Respirator Change-Out log Appendix D for Voluntary use, 1 time per employee, per respirator Fit-Test Records, current and required annually Medical Evaluations*, 30 years after employment – KPA CONFIDENTIAL –
    19. 19. OSHA • Forklift Written Program, current Employee Certification, 3 years Daily Inspection
    20. 20. OSHA • OSHA logs (SIC 5500 exempt) 301: Not Required 300: Current 300A: Post from February 1 through April 30 for the previous year • Inspections Fire Extinguishers*: Annual/ Monthly First Aid Kits*: Monthly Eye Wash Stations*: Monthly Facility Hazards*: Regularly – KPA CONFIDENTIAL –
    21. 21. Training • Emergency Response - ALL employees - Upon initial employment and annual refresher - Archive current only • Hazard Communication - EEs exposed to hazardous chemicals - Upon initial assignment and again when a new hazard in introduced - Archive current only • PPE - EEs required to use PPE - Upon initial assignment and when changes occur - Archive current only • Forklift - Forklift Operators upon initial assignment, when an incident occurs, and 3 yr refresher - Archive current only – KPA CONFIDENTIAL –
    22. 22. Training – KPA CONFIDENTIAL – • DOT Hazardous Materials - Haz Mat employees - Within 90 days of initial assignment if shipments are directly supervised by someone trained, refreshed every 3 years - Archive for 90 days after employment ends • Respiratory Protection - EEs required to use a respirator - Upon initial assignment, when changes occur, and annual refresher - Archive current only • Respirator Fit-Testing - EEs using a tight fitting respirator - Upon initial assignment and refreshed annually - Archive current only
    23. 23. Training • Forklift - Forklift Operators - Upon initial assignment, whenever an incident occurs, and 3 year refresher - Archive current only • Hazardous Waste Management - EEs of Small Quantity Generators (SQGs) of hazardous waste handling, storing, or managing hazardous waste - Upon initial assignment and annual refresher - Archive current only – KPA CONFIDENTIAL –
    24. 24. Best Management Practices • Hiring process to include all EHS training in new EE orientation • Centralize and organize all documents in Business Office or HR Department - Organize waste streams by type, group by year - Keep all training records behind an updated EE list with hire dates - Break down other folders by category discussed here: 609 AC, SPCCP, UST, written programs, etc. • Retain a copy of anything mailed to a regulatory agency and attach a certified mail receipt – KPA CONFIDENTIAL –
    25. 25. BMPs • Clearly identify responsibility and empower that employee • Internal Audit Schedule • Obtain Certificates of Insurance for all outside contractors • Seek counsel from EHS Professionals and attorneys in your area! – KPA CONFIDENTIAL –
    26. 26. Nick’s “Do it Now” Top 5 1. If you have over 1,320 gallons of petroleum, start on that SPCCP! 2. Hazard Assessment and PPE Selection/Provision! 3. Employee Training! 4. Organize all these documents in 1 central location! Empower someone at your facility to be responsible for this stuff! 5. Obtain certificates of insurance for all outside contractors! – KPA CONFIDENTIAL –
    27. 27. Questions and Answers – KPA CONFIDENTIAL – QUESTIONS?
    28. 28. Contact Information – KPA CONFIDENTIAL – The recorded webinar and presentation slides will be emailed to you today including your local representative‟s contact information. www.kpaonline.com bross@kpaonline.com 866-288-8765

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