EPA

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

BP has a dismal safety record, do you?

Friday, June 4th, 2010

760 violations at BP versus 1 at Exxon!

ABC News published an article recently about BP’s dismal safety record, citing that OSHA statistics show BP ran up 760 “egregious, willful” safety violations, while Sunoco and Conoco-Phillips each had eight, Citgo had two and Exxon had one comparable citation.

The article goes on: in two separate disasters prior to the Gulf oil rig explosion, 30 BP workers have been killed, and more than 200 seriously injured. In the last five years, investigators found, BP has admitted to breaking U.S. environmental and safety laws and committing outright fraud. BP paid $373 million in fines to avoid prosecution.

How does this story apply to dealerships? 760 violations at BP versus 1 at Exxon; does this happen at dealerships? Our engineers visit about 3,000 dealers annually, inspect them on potential OSHA violations, and develop a comprehensive safety program. While we don’t see such a sharp difference as between BP and Exxon, we unfortunately have to admit that we see very large differences between dealers that have a safety culture and those that don’t.  Regrettably the general answer is “yes, there are dismal safety records at certain dealerships.”

In our February newsletter we wrote an article about Group 1 Automotive and Penske Automotive Group taking the lead in compliance management. Though both groups consist of nearly 100 dealer rooftops, these groups have effectively managed their compliance scores to an unbelievable 97% to  98% and have held this level of compliance consistently. To put this in perspective, the average compliance score for a facility prior to getting started with KPA’s safety program is about 85%. Both Group 1 and Penske Automotive Group are not only reaching high level of compliance across one store, they are doing it for all stores, across all states, regardless of the management hierarchy. Essentially, Group 1 and Penske have managed their compliance program to virtually spot free facilities in less than one year.

Check your air conditioning service certificates

Tuesday, June 1st, 2010

With the summer approaching and temperatures rising, EPA representatives have been visiting dealerships asking to see training certification records for air conditioning service technicians. Those unable to produce their records are facing stiff fines. In brief, a dealership should take care of the following tasks:

  • Technician Training and Certification: Ensure all dealership air conditioning service technicians have successfully completed EPA approved training on refrigerant recovery, and that each holds a uniquely numbered proof of certification.
  • Training Records: Retain on-site a record of all certified air conditioning service technicians if you own refrigerant recycling/recovery equipment.
  • Equipment Certification: Certify in writing to U.S. EPA that the dealership has acquired (and is properly using) approved recovery/recycling equipment, and that each individual authorized to use the equipment has been properly trained.

New Underground Storage Tank Operator Training Requirements

Thursday, April 29th, 2010

The US Energy Policy Act requires all States that receive federal grant money for their UST programs to ensure that all operators of UST systems demonstrate competency on how to comply with UST rules so environmental releases can be prevented. These new rules have created a training and registration program requirement for underground storage tank operators.

Operator training will require owners and their designated employees to undergo training to become certified UST operators. Once the deadline has passed, refuelers will not be allowed to deliver to facilities that have not met the new requirements. The type of training an operator receives depends on the job functions they perform at their facilities.

The deadlines and specific requirements are going to vary from one state to another, but most states seem to be looking at a 2012 deadline. Some states, like California and Louisiana, already require UST Operators to meet similar training and certification requirements. Other states, like Florida, are choosing not to take the Federal money and may look at developing their own training requirements. For more information on the upcoming requirements you can review the Energy Policy Act, check with your state’s Environmental Protection Agency or contact your local KPA Representative.

A national UST operator training firm, PASS, has also prepared a summary of the latest regulations that can be used as a reference for your state.

Halogenated Solvent Cleaning Rule – How Does it impact me?

Friday, April 9th, 2010

The Federal Halogenated Solvent Cleaning Rule compliance deadline is coming up on May 3, 2010.    I’ve heard of some mis-information among clients using parts washers, and an incorrect interpretation that all parts washers now have to be aqueous. In fact, I hear there is a waste hauler trying to use this rule as a way to sell very expensive aqueous parts washers.  Please read below for a quick analysis or review the final rule

What does the rule say?

The rule is designed to limit the emissions of Halogenated Solvents from parts cleaning operations.  The rule sets the following limits for Halogenated Solvents:

Solvents emitted Emission limits in kg
PCE (Perchloroethlene aka Tetrachloroethylene) 4,800
TCE (Trichloroethylene) 14,100
MC (Methylene Chloride) 60,000

 

What does this mean to me?

In most cases… Nothing.  Unless you are actually using halogenated solvents in your parts washers, you will not be affected by this rule.  Most solvents in parts washers are mineral spirits/stoddard solvent and do not contain halogenated solvents.

For instance here are Safety Kleen’s listings

You may notice that their recycled 105 solvent does contain PCE, however it is .2% by volume, meaning in order to get to 10,500 lbs of emissions for the year would take A LOT of solvent (think cleaning off a cruise ship).

If you are in fact using halogenated solvents in your parts washers… Yikes! Complying with this particular rule is the least of your problems… It’s really time  to change your parts washer solvents as using these solvents is very harmful to your employees.

Secure Oil Distribution Pumps Daily to Avoid Slippery Situations

Monday, March 1st, 2010

Recently a dealership experienced a 500-gallon release of new lube oil when overnight one of the overhead lube oil distribution lines sprang a leak. The air powered pump at the oil tank detected a pressure drop and fired off. With no one around to see the oil spewing out of the broken line, it kept operating until the entire contents of the tank had been pumped out onto the shop floor, creating a tremendous mess. Many dealerships fail to secure the supply of compressed air to these pumps at the end of each workday. Thus any pipeline failure could result in a similar incident.

If your dealership operates these air driven oil distribution pumps it is important to ensure that, after hours, the supply of compressed air to these pumps is secured. A common way to achieve this is to shut off power to your air compressor and bleed your air lines. You may have other procedures that would work as well but the key is having an employee in charge of the process every day.

EPA 6H rule: 9 reasons not to file for an exemption

Thursday, January 7th, 2010

»Download the 6H Rule Compliance Checklist

Steven E. Schillinger, President of GRC-Pirk Management (http://www.recomply.com/) is a KPA partner serving the collision center industry and a specialist on the EPA 6H rule. Steven lists nine reasons why filing for an exemption is a bad idea:

  1. Exemption form is an application only, not immunity, and requires written acceptance from the EPA
  2. Guarantees EPA review and/or inspection
  3. Shops can’t be conditionally exempt, all or none – paint one-time with vibrant or pearl and they’re subject to the rule for the entire year
  4. Shops will have to prove an exemption each permit renewal period
  5. Shop assumes vicarious liability if they sign a false affidavit
  6. Prohibits use of ANY products containing Target HAPs, i.e., 3-M products, cleaners, strippers, any jobbers products, etc. – not just one manufacturers product-line
  7. Many Air districts have added the rest of the EPA 188 toxic HAPs to a local rule – Delegated Authorities can be more restrictive than the 6H Rule
  8. Inspectors are instructed to cut a sample of the booth filter for lab-testing – when ANY Target HAPs appear (and they do) shops will have to defend!
  9. Why file exemption? It’s easy to be compliant and most reputable shops are already in compliance!

Steven also wrote a great article in Auto Body News how this new 6H rule could benefit shop owners as it could eliminate illicit shops.

Body Shops should review KPA’s 6H Checklist to ensure that their paint spray operations are compliant. For more information on EPA rule 6H, see our 6H Rule Overview.

Tip of the month: check if you meet the new SPCC rule compliance dates

Friday, January 1st, 2010

Self Certification An Option Starting January 14th 2010

Compliance-TipAfter an 11 month delay for additional public comment the EPA has finalized the December 2008 amendments to the Spill Control and Countermeasures Plan (SPCC) rules. If you recall, last year’s amendments were to reduce some of the regulatory burden on smaller oil handling facilities such as yours. As it turns out, the changes resulting from the extended public comment period have not had any impact on the amendments in your business sector. As with the previous rules if your facility has an aggregate storage capacity of over 1,320 gallons (including 55 gallon drums) of petroleum products, these amendments will affect your facility.

For more information about this upcoming rule change, read more in our January newsletter or join our SPPC webinar on January 14.

What workshops do you want to see at NADA in Orlando?

Sunday, December 27th, 2009

NADA-2010What workshops would you be interested in, in addition to the NADA workshop schedule?

I can arrange a conference room and speakers on the following topics:

  1. HR: including wage and hour law, Department of Labor regulations and trends
  2. Environmental, Health, and Safety: including anything related to OSHA, EPA, DOT
  3. Internet marketing: including SEO, and social media.