RI Auto Body Repair Facilities Certification RI Auto Body Repair Facilities Certification ProgramProgram

“Environmental and Occupational Health Compliance”“Environmental and Occupational Health Compliance”

RI Department of Environmental ManagementRI Department of Environmental Management

Office of Technical & Customer AssistanceOffice of Technical & Customer Assistance

Certification/Environmental Results ProgramCertification/Environmental Results Program

• Best applied in sectors where uniform Best applied in sectors where uniform

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

- Auto body industry- Auto body industry

- Auto salvage yard facilities- Auto salvage yard facilities

- Exterior lead paint removal - Exterior lead paint removal

contractorscontractors

- Underground storage tanks- Underground storage tanks

Auto Body IndustryAuto Body Industry

Fewer than 350 shops in Rhode Island (2006); 1,600 tons VOCsFewer than 350 shops in Rhode Island (2006); 1,600 tons VOCs

Mostly small business: Mostly small business: Average of 5 employees; 60% of shops employ Average of 5 employees; 60% of shops employ ≤ ≤ 4 people4 people

Average of 5 vehicles per weekAverage of 5 vehicles per week

Under-regulatedUnder-regulated

* National Estimates* National Estimates ~60,000 facilities nationwide~60,000 facilities nationwide $26 billion industry$26 billion industry >450,000 people>450,000 people 286,000 tons of VOC’s286,000 tons of VOC’s

RI Auto Body Repair Facilities Certification RI Auto Body Repair Facilities Certification ProgramProgram• Participation in program is voluntary Participation in program is voluntary

• First round of certification checklists submitted First round of certification checklists submitted in 2003, second round submitted in 2006in 2003, second round submitted in 2006

• Shops Shops self-certifyself-certify to RIDEM/OTCA that they are to RIDEM/OTCA that they are complying with environmental and occupational complying with environmental and occupational health protection requirementshealth protection requirements

• All auto body facilities operating in the State of All auto body facilities operating in the State of Rhode Island Rhode Island mustmust comply with the standards, comply with the standards, whether or not they self-certifywhether or not they self-certify

RI Auto Body Repair Facilities Certification RI Auto Body Repair Facilities Certification ProgramProgram

Incentives to participate:Incentives to participate:

- Reduced inspection priority for participants - Reduced inspection priority for participants

- Opportunity to come into compliance - Opportunity to come into compliance without without

fear of enforcement action and gravity fear of enforcement action and gravity based based penalties penalties

- RIDEM/URI/RIDOH technical & compliance - RIDEM/URI/RIDOH technical & compliance assistanceassistance

- Random regulatory inspections for - Random regulatory inspections for non-participantsnon-participants

RI Auto Body Repair Facilities Certification RI Auto Body Repair Facilities Certification ProgramProgram

Three Major Components:Three Major Components:

1.1. Compliance CertificationCompliance Certification

- clear standards, accountability, self-evaluation- clear standards, accountability, self-evaluation

2. Performance Measurement2. Performance Measurement

- statistically-based, inspections & enforcement- statistically-based, inspections & enforcement

3. Technical/Compliance Assistance3. Technical/Compliance Assistance

RI Auto Body Repair Facilities Certification RI Auto Body Repair Facilities Certification ProgramProgram

1. Compliance Certification:1. Compliance Certification:

Components:Components:

Certification WorkbookCertification Workbook

Self-Certification ChecklistSelf-Certification Checklist

Auto Body Certification WorkbookAuto Body Certification Workbook

• Explains regulations Explains regulations (in plain language)(in plain language)

• 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

Auto Body Certification WorkbookAuto Body Certification Workbook

Major Contents:

• Air Issues

• Water Pollution Control

• Hazardous Waste

• Pollution Prevention

• Worker Health and Safety

• Sample Plans

Certification ChecklistCertification Checklist

• The checklist The checklist contains a series contains a series of compliance of compliance questions, which questions, which generally require generally require “yes” or “no” “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 occupational health and safety health and safety requirementsrequirements

Certification ChecklistCertification Checklist

• Checklist confirms Checklist confirms compliance statuscompliance status

• Self survey - used to Self survey - used to determine where to determine where to make improvementsmake improvements

• Required to submit Required to submit checklist and RTCs checklist and RTCs to RIDEM/OTCAto RIDEM/OTCA

• Failure to submit by Failure to submit by a designated date a designated date may result in may result in inspectioninspection

Auto Body Industry - CertificationAuto Body Industry - CertificationExample of checklist questions:Example of checklist questions:

• Statistics used to measure changeStatistics used to measure change

• Baseline - 40 out of 400 shops randomly Baseline - 40 out of 400 shops randomly selected and visited; average compliance selected and visited; average compliance rates determinedrates determined

• After self-certification completed, another After self-certification completed, another 40 shops randomly selected and audited 40 shops randomly selected and audited or inspected for compliance statusor inspected for compliance status

• ““Before” and “After” comparisons made Before” and “After” comparisons made to determine program effectivenessto determine program effectiveness

2. Performance Measurement2. Performance Measurement

3. Technical Assistance3. Technical Assistance

Participating shops may need assistance to Participating shops may need assistance to comply with regulations (on-site, telephone, comply with regulations (on-site, telephone, email)email)

• URI and RIDEM/OTCA provide free URI and RIDEM/OTCA provide free consultation to help correct problems, such consultation to help correct problems, such as:as:

– Facility modification for wash waterFacility modification for wash water

– Drum labeling and managementDrum labeling and management

• Companies still need to spend time and Companies still need to spend time and money, but costs can be minimized with money, but costs can be minimized with technical assistancetechnical assistance

Example of a Example of a “Return-to- “Return-to- Compliance Compliance

Plan”Plan”

(RTC)(RTC) SubmittedSubmitted

(Authorized (Authorized Agents)Agents)

Example of a Example of a “Return-to- “Return-to- Compliance Compliance

Plan”Plan”(RTC) (RTC)

SubmittedSubmitted

(Employee (Employee Medical Medical Exams)Exams)

2003 Results2003 Results

• 367 RI DBR auto body shop licensees367 RI DBR auto body shop licensees

• 171 completed checklists returned171 completed checklists returned

• 15 businesses filed “Facility Non-15 businesses filed “Facility Non-Applicability Statement”Applicability Statement”

• 51% response rate51% response rate

• 282 Return-to-Compliance Plans w/ 282 Return-to-Compliance Plans w/ checklists filed with RIDEM/OTCAchecklists filed with RIDEM/OTCA

Table IV. Summary of baseline and post-ERP implementation filed audit data.

EBPI Baseline% Compliance % Compliance % Improvement

1 Manifest tracking 55 89 342 Accumulation label 25 55** 30**3 Secure area 75 98 234 Authorized agents 28 63** 35**5 Methylene chloride usage 68 95 276 Enclosed gun cleaners 83 100** 17**7 Unpermitted floor drains 24 67** 43**8 Wash water runoff 30 64 349 Discharge signage 0 47 4710 Safety/health poster 44 82 3811 Haz Com program 9 46 3712 PPE program 19 63 4413 Respiratory protection program 25 62 3714 Lockout/tagout program 12 56 44

% Compliance = proportion of shops in compliance at baseline or post-ERP implementation

* OTCA + OC&I post-ERP participant and non-participant data for statistically significant EBPIs combined.

** Statistically significant OTCA ERP participant data only (i.e., combined data did not achieve statistical significance).

Post-ERP*

RI Auto Body Repair Facilities Certification RI Auto Body Repair Facilities Certification ProgramProgram

2006 Results2006 Results

• 336 RI DBR auto body shop licensees336 RI DBR auto body shop licensees

• 140 completed checklists returned140 completed checklists returned

• 5 businesses filed “Facility Non-5 businesses filed “Facility Non-Applicability Statement”Applicability Statement”

• 43% response rate43% response rate

• 94 Return-to-Compliance Plans w/ 94 Return-to-Compliance Plans w/ checklists filed with RIDEM/OTCAchecklists filed with RIDEM/OTCA

RI Auto Body Repair Facilities Certification RI Auto Body Repair Facilities Certification ProgramProgram

• Underground Storage TanksUnderground Storage Tanks

• Auto Salvage Yard FacilitiesAuto Salvage Yard Facilities

• Exterior Lead Paint Removal Contractors Exterior Lead Paint Removal Contractors

• Hospitality Green CertificationHospitality Green Certification

Other industry sectors being pursued:Other industry sectors being pursued:

Contact InformationContact Information

RI Department of Environmental ManagementRI Department of Environmental ManagementOffice of Technical & Customer AssistanceOffice of Technical & Customer Assistance235 Promenade Street235 Promenade StreetProvidence, RI 02908-5767Providence, RI 02908-5767

Tom ArmstrongTom Armstrong Telephone: (401) 222-4700, Ext. 4412Telephone: (401) 222-4700, Ext. 4412Email: Email:

thomas.armstrong@dem.ri.govthomas.armstrong@dem.ri.gov Fax:Fax: (401) 222-3810(401) 222-3810

RIDEM Auto Body Web Address:RIDEM Auto Body Web Address:http://www.dem.ri.gov/programs/benviron/assist/abdycert/abdycert.htmhttp://www.dem.ri.gov/programs/benviron/assist/abdycert/abdycert.htm