do a safety checkup for your facility osha/epa/dot minimum program and training requirements for...
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Do a Safety Checkup for your Facility OSHA/EPA/DOT Minimum Program and Training Requirements for DealershipsTRANSCRIPT
– KPA CONFIDENTIAL –
Do a Safety Checkup for your FacilityOSHA/EPA/DOT Minimum Program and Training Requirements for Dealerships
QuestionsQuestions
• If you have questions during the presentation, please submit them using the “Questions” feature
• Questions will be answered at the end of the webinar
SpeakerSpeaker
Glorianna L. Cooley, REM, ASPEnvironmental Health & Safety Engineer
Cell: 614-432-5044Fax: 614-539-8916
AgendaAgenda
• Illness & Injury Prevention Programs
• Environmental Documentation• Forklift Safety Programs• Respirator Protection
Programs• Hazard Communication• And much more….• Questions
OSHA Required ProgramsOSHA Required Programs
• Illness & Injury Prevention Program• Emergency Response Program• Hazard Communication Program• Personal Protective Equipment• Forklift Safety Program• Respiratory Protection Program• Lockout / Tagout Program• Fall Protection Program• Confined Space Program• Hearing Conservation Program
• SAFETY & HEALTH PROGRAM
• Management commitment• Employee involvement• Hazard recognition and control• Safety training agenda
Injury & Illness Prevention ProgramsInjury & Illness Prevention Programs
• ACCIDENT ANALYSIS
• Documentation• Timelines• Information gathering• Corrective action• Follow-up
Injury & Illness Prevention ProgramsInjury & Illness Prevention Programs
• RECORDKEEPING
• OSHA 300• OSHA 300a - Posted Feb 1
to Apr 30 • OSHA 301• Reviewed and signed by
top company official
Injury & Illness Prevention ProgramsInjury & Illness Prevention Programs
• EMERGENCY ACTION PLAN
• Posted Evacuation Maps• Accountability procedures• Weather• Drills• Training
Emergency Response ProgramsEmergency Response Programs
• FIRE PREVENTION PLAN
• Fire extinguisher locations• Annual inspections by service company• Monthly inspections in-house• Fire extinguisher training
Emergency Response ProgramsEmergency Response Programs
• Written Program• Chemical Inventory• Container Labeling• Material Safety Data Sheets (MSDS)• Training
Hazard Communication ProgramsHazard Communication Programs
• Hazard assessment• Selection• Use (required vs. voluntary)• Care and maintenance• Training
• Who pays for it?
Personal Protective EquipmentPersonal Protective Equipment
• POWERED INDUSTRIAL TRUCKS
• Classroom safety training• Hands-on evaluation• 3 year requirement• Certified by the employer
Forklift Safety ProgramsForklift Safety Programs
Respiratory Protection ProgramsRespiratory Protection Programs
• Selection• Use (required vs. voluntary)• Medical Evaluations• Annual Fit Testing• Respiratory Protection training
• Review MSDS!
• Inventory of energy sources• Written procedures for source control• Specific training for authorized persons• General training for all employees• Annual inspection of program
Lockout / Tagout ProgramsLockout / Tagout Programs
Fall Protection ProgramsFall Protection Programs
• Determination of requirement• 4 ft for General Industry• 6 ft for Construction• Annual training
Confined Space ProgramsConfined Space Programs
• Determination of requirement• PPE required• Testing / Monitoring Space• Entry and Rescue Procedures• On-site Training
Hearing Conservation ProgramHearing Conservation Program
• Required if at or > 85 dBA over 8 hr TWA
• Monitoring Program• Audiometric Testing Program• Hearing Protection Devices• Employee Training and Education• Recordkeeping
Next SectionNext Section
• Could be more regulations depending on your facility operations.
• Brief overview – know the details!• Know your state and local business
requirements!
• Next up…. DOT
DOT RequirementsDOT Requirements
• DOT Hazmat Certifications– Hazmat Employees including shippers,
packagers, drivers, hazardous waste generators, etc.
• Training required every 3 years• 24 Hr phone number required on shipping
papers
Hazardous MaterialsHazardous Materials
Next SectionNext Section
• Could be more regulations depending on your facility operations.
• Brief overview – know the details!• Know your state and local business
requirements!
• Next up…. EPA
EPA Required ProgramsEPA Required Programs
• Waste Management• Tier II Requirements• AC Compliance• UST Requirements• Spill Prevention, Control, & Countermeasures
(SPCC) Plan• Air Compliance• 6H Rules - NESHAP
Waste DeterminationWaste Determination
• Hazardous waste determination must be made on EVERY waste!
• Generator Knowledge• MSDS review• TCLP Test (RCRA Metals, VOC…)
– Toxicity characteristic leaching procedure
Common Waste Streams at DealershipsCommon Waste Streams at Dealerships
• Used Oil, ATF, and Antifreeze• Used Oil and Fuel Filters• Used Oil Dry and Used Rags• Parts Washer Solvent• Waste Paint and Recycler ‘Pucks’• Paint Booth Filters• Waste Batteries• Waste Tires• Fluorescent Bulbs• Wheel Weights• Oil/Water Separator Sludge• Brake Dust• Aerosol Cans
• Disposal documentation needed for each waste stream
• Storage areas clean and separated
• Storage containers labeled
PaperworkPaperwork
• Hazardous waste signers must have DOT Hazardous Materials certification
• Hazardous waste manifests must be kept for a minimum of 3 years
• Cradle-to-grave• Double-check your papers,
know your vendors!
Haz Waste Generator StatusHaz Waste Generator Status
• Conditionally Exempt Small Quantity Generator (CESQG)- Less than 220 pounds a
month (about ½ 55 gal drum)
• Small Quantity Generator (SQG)- 220-2,200 pounds a month
(about 5 55 gal drums)- Stricter requirements
• Large Quantity Generator (LQG)
Tier II ComplianceTier II Compliance
• 10,000 lbs of any chemical onsite• 500 lbs of any hazardous chemical
– At any given time, not related to tank capacity• Must file annual Tier II report by March 1st!
AC ComplianceAC Compliance
• AC machines must be registered with the EPA
– One time event– No fees involved– Keep documentation on file
• All technicians must be trained – Certificate must say Refrigerant, Recovery,
Recycling, compliant with EPA Section 609– Not basic HVAC– Keep records on file
UST ComplianceUST Compliance
• State Permits and Insurance• Inspections• Testing Requirements
• EPA Operator Training – Provision of the UST amendments – Energy Policy Act of 2005– Class A-Primary responsibility to operate and maintain the UST
system– Class B-Implement applicable UST regulatory requirements and
standards in the field – Class C-An employee at the UST site (e.g., clerk) that has been
trained on UST Emergency Response Issues
• Deadline of 8/8/2012
SPCC ComplianceSPCC Compliance
• If you have capacity onsite for 1,320 gallons – Whether or not tanks are full– New oil, used oil, ATF, gasoline, diesel fuel,
brake clean (anything petroleum based)• Must have SPCC Plan• Must have secondary containment around
all sources 55 gallons and up• Training
Air ComplianceAir Compliance
• Know your state regulations!
• Common Air Pollution Violations:– Operating without a Permit (if required)– Not keeping the required paperwork– Being a nuisance (causing odors, dust, etc)
6H Rules - NESHAP6H Rules - NESHAP
• March 11, 2011 Deadline• Notification to the EPA• Compliant Paint Booths / Prep Stations• HVLP Spray Guns• 6H Trained Technicians• Documented 98% Efficient Filters
That’s It!That’s It!
• Could be more regulations depending on your facility operations.
• Brief overview – know the details!• Know your state and local business
requirements!
• Next up…. Q&A
Reference DocumentsReference Documents
• EHS Compliance Checklist• Training Requirements
36
Questions and AnswersQuestions and Answers
– KPA CONFIDENTIAL –
Glorianna L. Cooley, REM, ASPEnvironmental Health & Safety Engineer
Cell: 614-432-5044Fax: 614-539-8916