One thing many dealership fixed ops departments are not ready for is a planned or surprise visit from local, state or federal environmental inspectors. Stephany Birkholz, 34, an environment, health and safety team supervisor at consulting and training firm KPA, discusses how service departments can maintain a safe and productive workplace. Here are edited excerpts.
Q: What important items should be covered during environmental training?
A: Proper hazardous waste disposal is one of the most important things that fixed ops departments need to know when it comes to EPA compliance. Federal law requires that hazardous waste is properly identified and disposed of — and all of this needs to be communicated to employees.
What are some common EPA violations that service departments commit?
One of the most common EPA violations in a service department is incomplete or missing hazardous waste determination on oil-water separator liquid.
A byproduct of this process is sludge, and service departments are required to properly dispose of it per their local authorities' requirements. Fines are issued when the service department can't provide documentation showing the waste has been properly categorized using a Toxicity Characteristic Leaching Procedure.
Parts washers are often cited, too. Service departments can get fined when they introduce an aerosol or an external product that's not part of the parts washer system. This can change the flashpoint or add toxicity to the process.
You never want to introduce any external chemicals to a parts washer process because it can create a snowball effect along the waste disposal chain, sometimes called the cradle-to-grave process. Improper labeling is another. Everything needs to be labeled — like used oil, used oil filters, used antifreeze, etc., so things don't end up in the trash that shouldn't be there (like an aerosol can). I also frequently see improper or incomplete paperwork. Facilities can have trouble managing the multiple layers of regulation at the local, state and federal level. Facilities are required to retain disposal receipts or manifests of all wastes for three years.
What are some EPA compliance areas that collision centers forget about?
Collision centers struggle with properly categorizing hazardous waste, also known as hazardous waste determination. We start to see large fines when a facility doesn't properly determine its hazardous waste or allows it to evaporate by leaving containers open. A common example of this is a paint shop leaving the funnel to the waste drum open or when solvent-based paint is left out to harden. If a facility doesn't notify the EPA they are operating as a small quantity generator, this is another area where fines will be steep. Lastly, try to stay away from chlorinated solvents. The days of using the chlorinated dip basket gun cleaners are no more. In fact, you probably aren't able to purchase chlorinated solvents anymore from paint suppliers. It's a liability and regulatory burden for them, too.
When an EPA compliance officer visits a service department, what are some tips for managers on how to handle the visit?
There are five things that managers need to know to best handle a visit:
1. Be kind and helpful to the inspector. Visits are typically unannounced, but you should do everything you can to make their job as easy as possible, and they'll likely do the same.
2. Ask [for] and verify the inspector's credentials and request an opening conference. The conference should explain the nature, purpose and scope of the inspection or visit. Before the visit begins, you should also ask which records need to be reviewed so someone can work on gathering those during the walkthrough.
3. Escort the inspector at all times. You are expected as a hazardous waste generator to have one person who can stop what they're doing at all times and assist the inspector during their walkthrough. Do not ever allow them to wander off by themselves. And anytime they take a photo, you should do the same.
4. Fix small issues on the spot. If something isn't labeled properly, doing so on the spot can show that you're willing to take action quickly and take the inspection seriously.
5. Ask for a closing conference. This should address any next steps, time frames or deadlines and identify anything the inspector wants you to follow up about.
At KPA, we equip our clients with a "Yellow Box," which includes all of the waste disposal documentation that an EPA compliance officer needs to conduct an inspection. I recommend that all service departments have some version of this to ensure a smooth inspection process.
If you work with an environment, health and safety consultant, they can help ensure you're ready for any planned or surprise EPA inspection.