First impressions can mean everything especially when dealing with a regulatory inspection. If your manifests and documentation are orderly, the impression given to an Inspector is that the rest of your business is also in order. It also indicates that you pay close attention to the details involved in maintaining a safe and environmentally compliant business. Proper documentation also gives evidence of compliance as it is often stated that “if it isn’t documented, it didn’t happen.”
The Yellow Box is a one stop shop, simple way of compiling all the documentation of a vibrant Safety and Environmental Program. Unfortunately, it often becomes a foot rest or is forgotten in the recesses of the Parts Department, when the documentation contained may be the difference between huge fines and penalties or proof of compliance. Your KPA Engineer will periodically review your documentation but it is especially important that you, as the ultimate owner of your Environmental and Safety Program, are well aware of what documents are housed in the Yellow Box. The Yellow Box should, (at the very least), contain the following:
- Waste Documentation
- Air Conditioning (Clean Air Act) Recovery Information
- Inspection logs & results
- NESHAP 6H
- Toxicity Characteristic Leaching Procedure (TCLP) test results
- Other Regulatory Information
Depending on your facility not all of these may apply, but if it is related to your program, and isn’t stored in myKPAonline, it should be kept at your fingertips in the Yellow Box. If you are uncertain if something should be filed in your Yellow Box, save it for your next KPA Engineer visit.
Waste documentation should be kept for:
- Used Oil
- Used Oil and Fuel Filters
- Waste Fuel
- Waste Paint and Solvents
- Paint Booth Filters
- Oil-Water Separator Sludge
- Lead Wheel Weights
- Aerosol Cans
- Light Bulbs
- Parts Washers
- Shop Towels
- In some states there are additional waste streams
As a business that generates these wastes you are required to document that they are being properly disposed of or recycled. This becomes especially important when dealing with Hazardous Waste. It is much easier when an inspector requests documentation of the last three years of Used Oil recycling and to simply pull a folder out of the Yellow Box including all the manifests requested. Your Yellow Box should include:
Air Conditioning Recovery Information: Equipment Registration and Technician Certifications are included in this category. The burden of proof is on the employer to ensure that anyone recovering refrigerant is trained to do so. The easiest way to accomplish this is to keep copies of the certificates. A good business practice is to immediately obtain a copy upon hire as you may have to prove an employee certification while they’re employed by you or long after.
Training: Specific training is required for every employee at your dealership or body shop. myKPAonline is an easily accessible system for capturing KPA training, but other training should also be documented. For example, if an employee completed DOT HazMat training through another vendor, a copy of that certificate should be kept in the Yellow Box. This is also a good place for safekeeping of Forklift Practical Evaluations and Respiratory Program documents, including Voluntary Use Forms. The more training completed and documented the better. KPA experience shows that training violations can be reduced or completely eliminated with proper documentation.
Inspection Logs & Results: Documentation of all completed inspections must be kept. Lists of all required inspections are available from your KPA Engineer. Logs must be kept whether completed in-house or inspected by an outside vendor. Additionally, no matter the frequency, all inspection logs must be kept, whether the logs were Daily, Prior to Use, Weekly, Monthly, Quarterly, or Annual. Equipment inspection documentation becomes particularly relevant when an accident claim involves a piece of equipment. Keep in mind that many times, a vendor will simply place a sticker on an automotive lift as proof of an inspection, but a full checklist for each lift should be retained.
Regulatory Information: This can be a wide array of “other” information, which is usually local and state specific or based upon the special regulatory requirements of your facility. Documentation includes permits, UST (short for Underground Storage Tanks) information, reports, and regulatory agency communications. USTs have their own list of required documents and some states require additional business plans and cost recovery documents. Also, if your facility requires a Spill Plan, the Professional Engineer stamped original should be kept in the Yellow Box. Remember, if you are uncertain if something should be filed in your Yellow Box, save it for your KPA Engineer at the next visit.
NESHAP 6H and TCLP: These topics are spray coating application specific and include: painter training, filter efficiency, generator status specific inspections, and TCLP results. It is particularly important that any waste manifests (paint and solvent) are matched properly and retained even if your generator status does not dictate this as compulsory. You are responsible from “cradle to grave” and those fines can be particularly burdensome. Complete maintenance records for spray booths are also a good offense for the current OSHA National Emphasis Isocyanate Program. Organized and thorough documentation for Body Shops is especially crucial.
Your KPA Engineer is always here to help and your Yellow Box is the perfect place to keep everything organized. Just remember that the best defense is a good offense and your best offense starts with good documentation.