Posts Tagged ‘EPA’

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.

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

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.

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

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.

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.