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Do a Safety Checkup for your Facility OSHA/EPA/DOT Minimum Program and Training Requirements for Dealerships
- 1. – KPA CONFIDENTIAL – Do a Safety Checkup for your Facility OSHA/EPA/DOT Minimum Program and Training Requirements for Dealerships
- 2. 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
- 3. Speaker Glorianna L. Cooley, REM, ASP Environmental Health & Safety Engineer Cell: 614-432-5044 Fax: 614-539-8916 gcooley@kpaonline.com
- 4. Agenda • Illness & Injury Prevention Programs • Environmental Documentation • Forklift Safety Programs • Respirator Protection Programs • Hazard Communication • And much more…. • Questions
- 5. OSHA Required Programs • Illness & Injury Prevention Program • Emergency Response Program • Hazard Communication Program • Personal Protective Equipment • Forklift Safety Program • Respiratory Protection Program • Lockout / Tagout Program • Fall Protection Program • Confined Space Program • Hearing Conservation Program
- 6. • SAFETY & HEALTH PROGRAM • Management commitment • Employee involvement • Hazard recognition and control • Safety training agenda Injury & Illness Prevention Programs
- 7. • ACCIDENT ANALYSIS • Documentation • Timelines • Information gathering • Corrective action • Follow-up Injury & Illness Prevention Programs
- 8. • RECORDKEEPING • OSHA 300 • OSHA 300a - Posted Feb 1 to Apr 30 • OSHA 301 • Reviewed and signed by top company official Injury & Illness Prevention Programs
- 9. • EMERGENCY ACTION PLAN • Posted Evacuation Maps • Accountability procedures • Weather • Drills • Training Emergency Response Programs
- 10. • FIRE PREVENTION PLAN • Fire extinguisher locations • Annual inspections by service company • Monthly inspections in-house • Fire extinguisher training Emergency Response Programs
- 11. • Written Program • Chemical Inventory • Container Labeling • Material Safety Data Sheets (MSDS) • Training Hazard Communication Programs
- 12. • Hazard assessment • Selection • Use (required vs. voluntary) • Care and maintenance • Training • Who pays for it? Personal Protective Equipment
- 13. • POWERED INDUSTRIAL TRUCKS • Classroom safety training • Hands-on evaluation • 3 year requirement • Certified by the employer Forklift Safety Programs
- 14. Respiratory Protection Programs • Selection • Use (required vs. voluntary) • Medical Evaluations • Annual Fit Testing • Respiratory Protection training • Review MSDS!
- 15. • Inventory of energy sources • Written procedures for source control • Specific training for authorized persons • General training for all employees • Annual inspection of program Lockout / Tagout Programs
- 16. Fall Protection Programs • Determination of requirement • 4 ft for General Industry • 6 ft for Construction • Annual training
- 17. Confined Space Programs • Determination of requirement • PPE required • Testing / Monitoring Space • Entry and Rescue Procedures • On-site Training
- 18. Hearing Conservation Program • Required if at or > 85 dBA over 8 hr TWA • Monitoring Program • Audiometric Testing Program • Hearing Protection Devices • Employee Training and Education • Recordkeeping
- 19. Next Section • Could be more regulations depending on your facility operations. • Brief overview – know the details! • Know your state and local business requirements! • Next up…. DOT
- 20. DOT Requirements • DOT Hazmat Certifications – Hazmat Employees including shippers, packagers, drivers, hazardous waste generators, etc. • Training required every 3 years • 24 Hr phone number required on shipping papers
- 22. Next Section • Could be more regulations depending on your facility operations. • Brief overview – know the details! • Know your state and local business requirements! • Next up…. EPA
- 23. EPA Required Programs • Waste Management • Tier II Requirements • AC Compliance • UST Requirements • Spill Prevention, Control, & Countermeasures (SPCC) Plan • Air Compliance • 6H Rules - NESHAP
- 24. Waste Determination • Hazardous waste determination must be made on EVERY waste! • Generator Knowledge • MSDS review • TCLP Test (RCRA Metals, VOC…) – Toxicity characteristic leaching procedure
- 25. Common Waste Streams at Dealerships • Used Oil, ATF, and Antifreeze • Used Oil and Fuel Filters • Used Oil Dry and Used Rags • Parts Washer Solvent • Waste Paint and Recycler ‘Pucks’ • Paint Booth Filters • Waste Batteries • Waste Tires • Fluorescent Bulbs • Wheel Weights • Oil/Water Separator Sludge • Brake Dust • Aerosol Cans • Disposal documentation needed for each waste stream • Storage areas clean and separated • Storage containers labeled
- 26. Paperwork • Hazardous waste signers must have DOT Hazardous Materials certification • Hazardous waste manifests must be kept for a minimum of 3 years • Cradle-to-grave • Double-check your papers, know your vendors!
- 27. Haz Waste Generator Status • Conditionally Exempt Small Quantity Generator (CESQG) - Less than 220 pounds a month (about ½ 55 gal drum) • Small Quantity Generator (SQG) - 220-2,200 pounds a month (about 5 55 gal drums) - Stricter requirements • Large Quantity Generator (LQG)
- 28. Tier II Compliance • 10,000 lbs of any chemical onsite • 500 lbs of any hazardous chemical – At any given time, not related to tank capacity • Must file annual Tier II report by March 1st!
- 29. AC Compliance • AC machines must be registered with the EPA – One time event – No fees involved – Keep documentation on file • All technicians must be trained – Certificate must say Refrigerant, Recovery, Recycling, compliant with EPA Section 609 – Not basic HVAC – Keep records on file
- 30. UST Compliance • State Permits and Insurance • Inspections • Testing Requirements • EPA Operator Training – Provision of the UST amendments – Energy Policy Act of 2005 – Class A-Primary responsibility to operate and maintain the UST system – Class B-Implement applicable UST regulatory requirements and standards in the field – Class C-An employee at the UST site (e.g., clerk) that has been trained on UST Emergency Response Issues • Deadline of 8/8/2012
- 31. SPCC Compliance • If you have capacity onsite for 1,320 gallons – Whether or not tanks are full – New oil, used oil, ATF, gasoline, diesel fuel, brake clean (anything petroleum based) • Must have SPCC Plan • Must have secondary containment around all sources 55 gallons and up • Training
- 32. Air Compliance • Know your state regulations! • Common Air Pollution Violations: – Operating without a Permit (if required) – Not keeping the required paperwork – Being a nuisance (causing odors, dust, etc)
- 33. 6H Rules - NESHAP • March 11, 2011 Deadline • Notification to the EPA • Compliant Paint Booths / Prep Stations • HVLP Spray Guns • 6H Trained Technicians • Documented 98% Efficient Filters
- 34. That’s It! • Could be more regulations depending on your facility operations. • Brief overview – know the details! • Know your state and local business requirements! • Next up…. Q&A
- 35. Reference Documents • EHS Compliance Checklist • Training Requirements
- 36. Questions and Answers 36– KPA CONFIDENTIAL – Glorianna L. Cooley, REM, ASP Environmental Health & Safety Engineer Cell: 614-432-5044 Fax: 614-539-8916 gcooley@kpaonline.com
Notas do Editor
- MUCH MORE DEPENDING ON YOUR INDUSTRY – ONLY HAVE SO MUCH TIME TO COVER. ASK QUESTIONS! KNOW YOUR REQUIREMENTS!
- Less than 10 employee exemption. Reporting deaths to OSHA – even if heart attack.
- Mention recalls and certain chemicals.
- A confined space has limited openings for entry or exit, is large enough for entering and working, and is not designed for continuous worker occupancy.
- Whether you ship hazardous materials once or twice a year, or every day, the hazards of that material are the same. Whether you carry a hazmat loaddown the street or across the country, regulations apply. Whether you are shipping a barely regulated amount, or a container-load, the HazardousMaterials Regulations, found in Title 49 of the Code of Federal Regulations (49 CFR, Parts 171-180), can not be ignored.Every employee who may affect the safety of hazardous materials in transportation is a hazmat employee, and must be trained. Classification, packaging,marking, labeling, and placarding requirements may be in force even for what seem like “small” or “minor” shipments. Before you ship or carry hazmat,make sure your operations are in compliance with the hazardous materials regulations.
- Whether you ship hazardous materials once or twice a year, or every day, the hazards of that material are the same. Whether you carry a hazmat loaddown the street or across the country, regulations apply. Whether you are shipping a barely regulated amount, or a container-load, the HazardousMaterials Regulations, found in Title 49 of the Code of Federal Regulations (49 CFR, Parts 171-180), can not be ignored.Every employee who may affect the safety of hazardous materials in transportation is a hazmat employee, and must be trained. Classification, packaging,marking, labeling, and placarding requirements may be in force even for what seem like “small” or “minor” shipments. Before you ship or carry hazmat,make sure your operations are in compliance with the hazardous materials regulations.
- MUCH MORE DEPENDING ON YOUR INDUSTRY – ONLY HAVE SO MUCH TIME TO COVER. ASK QUESTIONS! KNOW YOUR REQUIREMENTS!
- 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?
- Recycle vs. Trash
- There are three generator statuses that you may fall into. The more hazardous waste you generate, the more requirements apply to you. If you generate less than 220pounds of hazardous waste each month, you are a Conditionally Exempt Small Quantity Generator (CESQG).CESQGs do not need an EPA Hazardous waste ID number but they still must send all hazardous waste to apermitted hazardous waste facility for treatment and disposal. As you can imagine it is in your best interests to eliminate or minimize your waste generation so that you fall into the CESQG status. By doing so you will exempt yourself from many of the states regulations.½ a drum equals 220 lbs. Most shops without BS should be able to get themselves into the conditionally exempt status. More stringent requirements for SQG such as weekly inspections and labeling.
- 1600 gal gas, 1400 gal diesel, 100 used batteries, 1075 gal antifreeze, 1550 gal new oil, 1000 gal paint, 1550 used oil if burn in furnace
- National Emissions Standards for Hazardous Air Pollutants