rhode island’s erp experience: automotive refinishing sector richard t. enander, ph.d. bureau of...

Rhode Island’s ERP Experience:Rhode Island’s ERP Experience: Automotive Refinishing SectorAutomotive Refinishing Sector

Richard T. Enander, Ph.D. Richard T. Enander, Ph.D.

Bureau of Environmental Protection/OTCABureau of Environmental Protection/OTCA

RI Department of Environmental ManagementRI Department of Environmental Management

2007 National Environmental Partnership Summit

What We Liked About the MAERPWhat We Liked About the MAERP

RI 1RI 1stst state to adopt MADEP model + health state to adopt MADEP model + health Statistically Based Performance Measurement Statistically Based Performance Measurement Self-evaluation and accountability through Self-evaluation and accountability through

comprehensive certificationcomprehensive certification Accommodates multimedia pollution and worker healthAccommodates multimedia pollution and worker health Capable of reaching larger segment of the regulated Capable of reaching larger segment of the regulated

community than traditional enforcement programscommunity than traditional enforcement programs SupplementsSupplements traditional inspection programs and traditional inspection programs and

does does notnot replace existing regulatory structures replace existing regulatory structures

Environmental Results ProgramEnvironmental Results Program RI experience--best applied where uniform RI experience--best applied where uniform

enforcement is difficult to achieve:enforcement is difficult to achieve:

• Auto body industryAuto body industry

Est. 4 RIDEM Divisions (Air, Water, Waste, OC&I) and Est. 4 RIDEM Divisions (Air, Water, Waste, OC&I) and

OSHA inspected OSHA inspected <5%<5% of all licensed shops (n=367)of all licensed shops (n=367) in in

any given yrany given yr

Probability of multimedia inspection = Probability of multimedia inspection = 00

• Auto salvage yards, exterior lead paint removal contractors, Auto salvage yards, exterior lead paint removal contractors,

underground storage tanks, hospitality industry (future)underground storage tanks, hospitality industry (future)

Why the Auto Body Sector?Why the Auto Body Sector? Environment-Health ConcernsEnvironment-Health Concerns:: EnvironmentalEnvironmental

Avg. size shop 5 people; <5 cars per weekAvg. size shop 5 people; <5 cars per week Chemicals used/released diverse & variable:Chemicals used/released diverse & variable:

- VOCs (1,600 tons), MeCl strippers (1/5 shops)- VOCs (1,600 tons), MeCl strippers (1/5 shops) Hazardous Waste ~ 3-55 gal drums per shop per yr.Hazardous Waste ~ 3-55 gal drums per shop per yr. RIDEM received neighbor complaintsRIDEM received neighbor complaints Fugitive sanding dust emissions (toxic metals)Fugitive sanding dust emissions (toxic metals)

-15 cars/wk > 100 lbs./yr-15 cars/wk > 100 lbs./yr Take-home toxicsTake-home toxics

Environment-Health ConcernsEnvironment-Health Concerns: : RI Auto Body IndustryRI Auto Body Industry

Worker HealthWorker Health Documented workplace exp: isocyanates, paint solvents,Documented workplace exp: isocyanates, paint solvents,

MeCl strippersMeCl strippers Lead exposureLead exposure Work clothesWork clothes Lead Screening: RI Department of Health

Blood Pb Data (ug/dl)Office/Painter 3-6Bodymen 28, 38

17 Avg.Nat’l Avg. <3

Work shirt Work shirt (ug/8in(ug/8in22) ) (fd=4/5)(fd=4/5) MinMin Med Med MaxMax

PbPb 2266 4545

Hand wipesHand wipes (total ug)(total ug)

(fd=6/6)(fd=6/6) Min Min MedMed MaxMax

PbPb 33 104104 211211

Results Published in Peer-Reviewed Literature:Results Published in Peer-Reviewed Literature:

American Journal of Industrial Medicine 44:312-320 (2003) American Industrial Hygiene Association Journal 63:741.749 (2002) American Industrial Hygiene Association Journal 59:478-489 (1998)

Abstracts available at RIDEM website: http://www.dem.ri.gov/programs/benviron/assist/pdf/peer.pdf

RI Autobody ERPRI Autobody ERP

Voluntary program Voluntary program

Shops Shops self-certifyself-certify to RIDEM that they to RIDEM that they were complying with environmental were complying with environmental and occupational health protection and occupational health protection requirementsrequirements

IncentivesIncentives

Incentives to participateIncentives to participate

- Reduced inspection priority - Reduced inspection priority

- Opportunity to come into compliance - Opportunity to come into compliance without fear of enforcement action without fear of enforcement action

- RIDEM/DOH technical & compliance - RIDEM/DOH technical & compliance assistanceassistance

- Random - Random regulatory inspectionsregulatory inspections for for

non-participantsnon-participants

Environmental Results ProgramEnvironmental Results Program

ERP Implementation Steps:ERP Implementation Steps:

1.1. Establish Industry Baseline PerformanceEstablish Industry Baseline Performance

2. Launch Environmental Results Program2. Launch Environmental Results Program

3. Receive/Tabulate Checklist & RTC Data3. Receive/Tabulate Checklist & RTC Data(A/B 6 mos. after launch)(A/B 6 mos. after launch)

4. Conduct Post-ERP Inspections and 4. Conduct Post-ERP Inspections and Statistical Analysis of Field DataStatistical Analysis of Field Data

Environmental Results ProgramEnvironmental Results Program

ERP Implementation Steps:ERP Implementation Steps:

1.1. Establish Industry Baseline PerformanceEstablish Industry Baseline Performance

- conduct random facility inspections - conduct random facility inspections

- # statistically pre-determined: n- # statistically pre-determined: n11 = 40; n = 40; n22=42=42

Idea is to use statistics used to measure Idea is to use statistics used to measure changechange

““Before” and “After” comparisons made to Before” and “After” comparisons made to determine program effectivenessdetermine program effectiveness

Performance MeasurementPerformance Measurement

Environmental Results ProgramEnvironmental Results Program

ERP Implementation Steps:ERP Implementation Steps:

2. Launch Environmental Results Program2. Launch Environmental Results Program

- mail certification workbook and checklists- mail certification workbook and checklists

- conduct workshops- conduct workshops

Autobody Certification WorkbookAutobody Certification Workbook

Explains regulations Explains regulations (in plain English)(in plain English)

Designed to be used Designed to be used in conjunction with in conjunction with the accompanying the accompanying self-certification self-certification checklist and to be checklist and to be used as a reference used as a reference in the facilityin the facility

Autobody Certification WorkbookAutobody Certification Workbook

Air Issues

Wastewater Issues

Hazardous Waste

Pollution Prevention

Worker Health and Safety

Example Plans

Certification ChecklistCertification Checklist

The checklist The checklist contains a series of contains a series of compliance questions, compliance questions, which generally which generally require “yes” or “no” require “yes” or “no” answers about answers about whether or not the whether or not the facility is following facility is following applicable applicable environmental and environmental and occupational health occupational health and safety and safety requirementsrequirements

Environmental Results ProgramEnvironmental Results Program

ERP Implementation Steps:ERP Implementation Steps:

3. Receive Self-cert. Checklist & RTC Data3. Receive Self-cert. Checklist & RTC Data

- 367 DBR licensed shops- 367 DBR licensed shops

-171 voluntary certifications/15 NA statements-171 voluntary certifications/15 NA statements

-49% participation rate-49% participation rate

-271 Return-to-Compliance Plans w/ checklists filed-271 Return-to-Compliance Plans w/ checklists filed

Examples of Examples of Return to Return to

Compliance Compliance Plan Plan

Submittals Submittals (Authorized (Authorized

Agents)Agents)

Return to Return to Compliance Compliance Plans (UIC)Plans (UIC)

Saw cuts for floor Saw cuts for floor trench systemtrench system

RTC RTC (wash (wash water water runoff runoff prevention )prevention )

Return to Return to Compliance Compliance

Plans Plans (Employee (Employee

Medical Medical Exams)Exams)

……body shop body shop work bench work bench area before area before

ERPERP(large, high (large, high

volume volume facility)facility)

……same shop before ERP and same shop before ERP and dustless vacuum systemdustless vacuum system

New booths and cleaner shop after ERPNew booths and cleaner shop after ERP

Environmental Results ProgramEnvironmental Results Program

ERP Implementation Steps:ERP Implementation Steps:

4. Conduct Post-ERP Inspections and Statistical 4. Conduct Post-ERP Inspections and Statistical

Analysis of Field DataAnalysis of Field Data

- random facility post-ERP inspections - random facility post-ERP inspections

- # statistically pre-determined: n- # statistically pre-determined: n11 = 40; = 40; nn22=42=42

Contact InformationContact Information

Richard Enander, richard.enander@dem.ri.govRichard Enander, richard.enander@dem.ri.gov

Office of Technical & Customer AssistanceOffice of Technical & Customer Assistance

RI Department of Environmental ManagementRI Department of Environmental Management

Tel. 401/222-4700 ext. 4411Tel. 401/222-4700 ext. 4411

RIDEM Auto Body Web Address:RIDEM Auto Body Web Address: www.state.ri.us/DEM/programs/benviron/assist/ www.state.ri.us/DEM/programs/benviron/assist/ index.htmindex.htm