Environmental Safety and Your Oil Water Separator

Wednesday, November 21st, 2012

Oil/water separators used by automotive repair or fleet maintenance businesses to pre-treat waste water usually rely on flow-through, gravity fed systems.  Inside the separator, oil gets trapped in a layer over the top of the waste water. As dirt, sand and sweepings fall out of the waste water stream, they form a layer of thick sludge along the bottom of the separator. Once these layers reach sufficient amounts, they need to be removed by skimmers, pumps, or other methods.

Generally, separators should be monitored on a routine schedule and collected oil should be removed as appropriate, so that it operates properly. The required oil/water separator capacity should always be available (i.e., oil should not continually accumulate in the separator over a period of time that would compromise required storage capacity if an oil release were to occur within the drainage area).



Want to know more about OWS compliance? Checkout these resources:

Best Environmental Practices for Auto Repair and Fleet Maintenance

EPA Guidance Chapter 5: Oil/Water Separators

How to Manage Hazardous Waste at Your Dealership

Monday, November 5th, 2012

Hazardous waste regulations vary slightly across the country depending on if your dealership is regulated by a state or federal office of the EPA.  However, there are some common hazardous wastes generated by the vehicle service and repair industry that your business is responsible for handling properly and tracking, regardless of your location.

Watch this quick video for tips on how to identify several common hazardous waste streams, how to dispose of them, and your responsibility as an individual when you sign a waste manifest.

Here are few other helpful links about managing hazardous wastes in the automotive industry:

Get Rid of It: Waste Management for Dealerships [Webinar]

Hazardous Waste Cost Recovery Program for Automotive Industry

Dealer Fined for Fluorescent Tube Disposal – Are You Properly Managing Your Universal Wastes?

Sorting game: How Well Can You Clean Out the Service Bay?

September Update on How to Handle Airbag Disposal

Thursday, September 13th, 2012

Hazardous Waste SignAuto dealers find the disposal of undeployed airbags to be a significant challenge, because they can be considered “reactive hazardous waste” if they are not recycled. For many years, dealers have opted to deploy the airbags and then send them to disposal sites like traditional landfills or incinerators. However, the Federal Environmental Protection Agency (EPA) recently cited a dealer for doing so.

So what’s the best approach for disposing of undeployed airbags? Till now, dealers’ options have included:

  1. Recycling the undeployed airbag.
  2. Disposing the undeployed airbags as hazardous waste.
  3. Deploying the airbags and then sending them to disposal.

Since the EPA recently cited a dealer for “treatment of hazardous waste without a permit” for deploying airbags, disposal of such items has become more problematic. Every dealer needs to weigh a variety of pros and cons, such as long-term liabilities and shipping costs.

Bottom line: If you’re not sure about the best approach for disposing undeployed airbags in your state, or if you’re using option 3 above, it’s time to reconsider your approach.

KPA Environment & Safety clients can contact their engineer for more information. Or, you can review the airbag page on our website.

Respiratory Protection for Undercoating Operations

Friday, April 27th, 2012

If your business offers, or is considering offering undercoating and rustproofing services, then it is important to remember that the chemicals involved in the process generally require the use of a respirator- or even a full supplied air system.

Information about safe product application, respirators and other forms of required PPE, is available on the product’s Material Safety Data Sheet (MSDS) for the undercoating or rustproofing product. It is a great resource that should always be referenced before allowing employees to apply the product to vehicles. Using this information keeps the employee safe, and it insulates your business from regulatory fines, workers’ compensation claims, and lawsuits.

If you are a KPA client, you can access the Automotive Industry MSDS database including many undercoating and rustproofing products by logging in your mykpaonline account.

Read more about respiratory protection for undercoating operations.

What You Need to Know About EPA’s NESHAP 6C

Friday, April 13th, 2012

NESHAP 6C applies to all gasoline dispensing facilities in the US and businesses that own and operate gasoline dispensing equipment. Its goal is to reduce air pollutants that escape during storage tank loading. This is a federal rule that applies in addition to state and local laws. NESHAP 6C sets parameters for equipment, record keeping, reporting, and required performance testing.

EPA published an official instructional video (embedded below) about acceptable methods for controlling gas vapors during the loading of underground storage tanks (stage 1 vapor recovery), along with compliance guidance for different levels of the rule’s requirements.

EPA Stage 1 Vapor Recovery – Gasoline Dispensing Facilities – YouTube.

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?