EPA

Quick Take: 6H Rule Explained for Autobody Shops

Thursday, November 17th, 2011


This video by KPA Field Engineer, Lori Matthews explains what the EPA’s 6H rule means for autobody shops. The rule is intended to reduce the public’s exposure of HAP’s that are generated from paint stripping and/or surface coating operations.  There are six parts to the rule:

  • Training
  • Paint gun selection
  • Spray gun cleaning
  • Spray enclosures
  • Notification to the EPA
  • Recordkeeping

The point:

Compliance with the 6H law is manageable. There are six parts to remember, and some important deadlines to keep. Contact your KPA field engineer if you have any questions, and check your progress with this helpful 6H Rule Compliance Checklist.

SPCC 101: What You Need to Know About SPCC Plans

Monday, October 17th, 2011

SPCC stands for Spill Prevention, Control, and Countermeasure. At this point, the SPCC is expected to become required for businesses on November 10, 2011. The SPCC rule is complicated, and has implications for many industries. This post focuses on what the rule means for dealerships and automotive service centers.

Who Needs an SPCC Plan?
The EPA requires that all facilities with total above-ground petroleum storage capacity of at least 1320 gallons stored in 55 gallon containers or greater need an SPCC plan. This is regardless of actual petroleum quantity stored on site.

What Goes in an SPCC Plan
Your plan is required to describe
•    oil handling operations
•    spill prevention practices, discharge or drainage controls
•    personnel, equipment and resources at the facility that are used to prevent oil spills from reaching navigable waters or adjoining shorelines
•    countermeasures to contain, cleanup, and mitigate the effects of an oil spill that would impact navigable waters or adjoining shorelines

How to Get an SPCC Plan
Businesses can either have a Professional  Engineer create and certify an SPCC plan for their facility, or they can self-certify (see details here). If a business chooses to self-certify, only an owner or operator of the facility can certify the plan.  If you certify the plan, ultimately you are responsible for all the information in it. That is one benefit of having a Professional Engineer look it over. When they stamp your plan, they are putting their credentials behind the plan.

Evict Your Tire Mosquitoes

Monday, May 23rd, 2011

Looking through the rain across the back lot, a pile of waste tires catches my eye. As I get closer to the pile, a buzzy little mosquito lands softly on my arm. I brush her away only to be attacked moments later by a hungry mob of blood suckers.

State Health Departments and the Environmental Protection Agency are also looking for places like this tire pile. News sources across the Midwest and Southeast report that the departments are on a mission against disease-carrying mosquitoes. As part of this effort, they are targeting mosquito breeding grounds, including dealerships and similar businesses with tire storage areas. Given the population explosion of mosquitoes this year, here are some guidelines to effectively address mosquito pools inside the tires.

Sheltered Storage: Drain tires of water and store them under a roof or well maintained waterproof enclosure to prevent water accumulation.

Exposed Storage of Waste Tires: Cut, slice, poke holes, or otherwise do what it takes to guarantee efficient drainage routes in each tire to prevent water accumulation inside the tires.

Pesticide Alternatives: If you can’t store the tires in a way to prevent water accumulation, then treat the tires with an appropriate pesticide according to manufacturer’s directions. Repeat as necessary.

Reminder: tires must be stored individually or stacked so each tire is accessible for spraying.

Maintain a written record of tire treatments that includes:

  • Name of the business
  • Date of spraying
  • Type of spray used
  • Person doing the spraying

Workplace Dangers in DETAIL: The Wash Bay Connection

Friday, March 25th, 2011

On a busy day, the floor can be covered in soaps, “engine juices,” oils, chemicals,  and solvents. Flammable liquids in 55 gallon drums line the wall, with a high risk of explosion from any ignition source.

This is where the safety culture at your dealership gets the road test. In the detail department, where staff is usually subcontracted, and not normally a part of the safety committee. How do you measure the risk of workplace hazards and compliance liabilities in this work area?

 

Here’s the short-list of what to consider in your wash bay risk assessment:

  • Hazard Communication:  All affected employees should be aware and regularly reminded of:
  • Primary Containers:  all primary containers must have specific hazard labeling requirements.  Primary container labels should consist of: manufacturer’s name and address/phone number, product name, and a specific hazard warning.  Contact the manufacturer immediately if this information is unavailable.
  • Secondary Containers: all secondary containers (spray bottles, etc) must be labeled to their contents and have appropriate hazard warnings.
  • Organization: all materials and chemicals should be kept organized.

  • Cleanliness: The wash bay should be regularly sprayed-down, swept, and cleaned.
  • Everything should be stored and sealed when not in active use.
  • Wash Bay attendants should wear protective gloves, and wash hands frequently.
  • Proper footwear: work boots are ideal. On a busy day, the floor is too slippery for sneakers or street shoes.
  • No smoking in the wash bay. No exceptions.

Subcontractors and Liability
Even if the work is subcontracted, the dealership could be liable for accidents or injuries. OSHA fines and financial liability both play a part. You should make sure that your subcontractor has adequate insurance. Get a certificate of insurance from your subcontractor, check that the coverage is adequate  and keep it on file at your dealership. As the primary employer at the dealership, OSHA may also find you responsible for your subcontractor’s omissions. Check up on all of your subcontractors to make sure they’re not cutting corners.

6H Rule Now In Effect, Are You Ready?

Tuesday, January 11th, 2011

The 6H Rule is now in effect and establishes two classes of painters – “certified” and “uncertified”.  Certified painters must have had training on use of certain paints commonly used in body shops and collision centers under the new rule.  The rule states “the spray application of surface coatings is prohibited by persons who are not certified as having completed the training described in paragraph (f) of Section 63.11173″.

Steven Schillinger, President of GRC-Pirk, the authorized registrar under the Certified Spray Coating program, states “most collision repair shop owners do their best to protect the environment and provide their employees with a safe and sound workplace …in this era of restricted state and federal budgets, the uniform response from government agencies and civil attorneys has been to increase enforcement activities”.    For more information on EPA rule 6H, see  KPA’s  6H Rule Overview and sign up for my free webinar ” EPA’s New 6H Emission Standards are in place, are you compliant?“ on January 20th at  http://forms.kpaonline.com/go/kpa/6hKPA

Join the converstation: Are you ready for 6H?

Free webinar on EPA’s 6H emission standard

Monday, January 10th, 2011

Have you signed up for the free 6H Emission Standards webinar on January 20, 2011? Peter Zaidel, product manager at KPA, will review the EPA-6H (40 Code of Federal Regulations 63, Subpart HHHHHH) requirements so you can be sure you’re fully compliant. Click here for the registration form.   You cannot make it on January 20? I’d highly recommend you still sign up as you will receive an email after the webinar with a link to the recording.

OMB Watch reports drastic increase in OSHA citations for 2010

Tuesday, December 28th, 2010

A new study by OMB Watch finds that the Obama administration has noticeably increased enforcement of workplace safety laws, and supporting data also showed that the administration was making consumer health and environmental regulations enforcement tougher.

In 2009, the Occupational Safety and Health Administration (OSHA) issued more than 68,000 citations – more than twice the amount of citations issued the previous year by the Bush administration. In 2010, the drastic trend upwards continued with citations skyrocketing at almost 114,000 by the middle of July.  You do the math and you can see how many citations might be issued in 2011 – maybe triple that amount and add a few more.

OMB Watch reported seeing similar trends at other agencies but none were quite as steep in comparison to the previous administration. The Environmental Protection Agency (EPA) increased the average amount for a fine against the Clean Water Act by nearly one-third during the Obama administration’s first 18 months; however, the penalties for serious violations were issued at a slightly slower rate compared to that of the preceding administration.

Please read more about OSHA safety compliance and how KPA can help you find a solution to support your dealership’s safety culture.

EPA intends to employ vigorous and targeted civil and criminal enforcement

Wednesday, November 24th, 2010

In order to provide effective and consistent enforcement of federal laws nationwide, the Environmental Protection Agency (EPA) is stepping up its civil and criminal enforcement by targeting the most serious hazards that relate to air, water, and chemicals. The EPA summarized the measures it will take on how it plans to use “vigorous and targeted” civil and criminal enforcement in the 2011-2015 EPA Strategic Plan. The plan outlines strategic measures for the criminal enforcement program by taking “aggressive action against pollution problems that make a difference in communities.”

For the first time, the EPA has included the measures it plans to take to enforce these hazards in order to protect human health and the environment, as well as protecting the low-income, minority, and tribal communities which may be disproportionally impacted by these hazards.  The EPA states that in order to achieve these goals, they need both new strategies and compliance to the rules that they already have. This concentrated effort is meant to achieve “increased transparency” so that more of your business’s information will be accessible to the public and the best way to comply would be to become more involved in your facility’s operations.

Some of the specified enforcement maintenance that the EPA will take by 2015 includes:

  • Here are some of the enforcement actions EPA plans to take by 2015:
  • Conduct 105,000 federal inspections and evaluations (FY 2005-2009 baseline: 21,000 annually)
  • Initiate 19,500 civil judicial and administrative enforcement cases and bring 19,000 to a conclusion (FY 2005-2009 baseline: 3,900 )
  • Review overall compliance status of 100 percent of open consent decrees (FY 2009: 100 percent)
  • Increase the percentage of criminal cases with charges filed to 45 percent (FY 2009 baseline: 36 percent)
  • Maintain an 85 percent conviction rate for criminal defendants

For more information, check out the 2011-2015 EPA Strategic Plan.

Acetone – More than Nail Polish Remover

Tuesday, October 12th, 2010

Acetone has a low toxicity and is a good solvent, making it as useful for removing nail polish as it is for degreasing and paint cleanup on the shop floor, but it also highly flammable. The acetone vapor (remember that vapor causes burns – not liquid) is heavier than air, can travel a considerable distance and can also accumulate in a confined space. Unfortunately, two workers cleaning a paint booth were not aware of the proper precautions to take when dealing with this highly flammable liquid, and were severely injured. The two Evansville, Tennessee companies involved in this incident are to be fined more than $100,000 by Indiana’s OSHA due to their negligence. The Agency alleges that two workers were mopping a large paint booth with acetone when one of the workers accidentally knocked over a halogen light. As it hit the floor, it ignited the acetone fumes into a flash fire. A flash fire is an unexpected, instant, intense fire that is instigated by the reaction.

The Evansville Courier & Press reports that Guardian Automotive is being fined $22,500 for a set of penalties the state categorized as serious. Team Industrial Services Inc., the agency that supplied the workers and instructed them to use the lamp and the cleaner, faces a steeper $84,150 fine. Of that amount, $63,000 is for a violation which state inspectors categorized as “knowing” — the most serious classification, and one used only several times per year, said Jeff Carter, the deputy state OSHA commissioner. “Knowing” violations are those violations where death or serious physical harm can result from a hazard an employer knew or should have known exists.

When dealing with flammable substance, you simply cannot be too careful. Take a few minutes to review the following tips:

1)   Know your chemicals, read all labels, and consult the MSDS (material safety data sheet)

2)   Remember that vapor burns, not liquid, so always work with adequate ventilation and avoid confined spaces

3)   Eliminate potential ignition sources, any heat source is potential ignition source

4)   Bond and ground when transferring flammable liquids, it only takes one spark

5)   Practice good housekeeping by segregating flammable substances and keeping them covered in closed containers

6)   Always use appropriate equipment to apply, transfer and store flammable liquids

Additional Resources

  1. OHSA www.osha.gov
  2. EPA www.epa.gov
  3. National Fire Protection Association www.nfpa.com
  4. International Code Council www.iccsafe.org

Now is the time to prepare, evaluate, update and implement your SPCC Plan

Sunday, August 1st, 2010

Compliance Tip of the Month

This year brings the hottest climate to the current state of environmental issues, and with the current focus of disasters such as the BP oil spill, enforcement is increasing and the consequences of non-compliance are expensive and potentially devastating.

The SPCC Rule essentially requires specific facilities to prepare, amend, certify, and implement an SPCC plan, thereby ensuring containment and countermeasures that will prevent oil discharges. Some elements of an SPCC plan include ensuring staff has undergone SPCC specific training, preparation of monthly self-inspection procedures and documentation, and a Five-year Plan review.

For more information, please see http://www.epa.gov/emergencies/content/spcc/index.htm