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Monday, 04 April 2016 16:16

KPA Teaches GCIA Members about OSHA and EPA Compliance

On Thursday, March 24, the Georgia Collision Industry Association (GCIA) hosted a member meeting at the Wyndham Hotel in Atlanta, GA. Over 25 attendees learned about OSHA and EPA regulations from Lori Matthews, Risk Management Consultant III for KPA, who was assisted in her presentation by Chuck Elliott, KPA District Manager, and Richard Baldwin, KPA Senior Sales Associate.

Matthews' presentation began with a regulatory update which explained that, due to a provision in the Bipartisan Budget Act of 2015, OSHA fines are set to increase 75-80 percent. Thie purpose of this is to bring them in line with inflation over the past 25 years. This means that the maximum penalty for serious violations is set to increase from $7500 to approximately $12,500 per incident with the maximum fine for repeat violations increasing from $70,000 to $125,000 per incident.

Initial penalty increases will become effective by August 1, 2016, and from there on out, OSHA's penalties will be permitted to increase yearly based on CPI. Additional OSHA changes will require dealerships with collision centers to complete certain injury and illness forms for their records as well as alterations to the way accidents are reported to OSHA. Fatalities must be reported within eight hours, while reports must be made within 24 hours if a work-related incident causes an employee to receive in-patient hospitalization, amputation or lose an eye. Events must also be reported to OSHA if a fatality occurs within 30 days of the work-related incident or if any of the aforementioned injuries occur within 24 hours after the work-related accident.

Looking at body shop compliance, Matthews informed attendees EPA 6H training is required every five years and advised everyone to check their initial training date to ensure it hasn't expired. Matthews next turned to OSHA's National Emphasis Program on Isocyanate exposure; required PPE now includes a fresh air respirator with grade D breathable air, non-permeable painter suits, gloves and eye protection, as well as air monitoring.

In order to be compliant in regards to safety regulations, the Emergency Response Plan must be written to include evacuation, fire response, spills response, inclement weather and first aid. Shops must also train employees on the plan and provide maps with evacuation plans. Hazards also require a written plan and employee training in addition to SDS, product labeling and compliance with the Global Harmonization System.

Compliance with personal protective equipment regulations require the completion of a hazard assessment and use of gloves, non-specialty footwear, paint suits and a welding helmet shade, with special requirements when repairing hybrid vehicles. Respiratory protection compliance requires a written program, employee training and medical evaluations. It also dictates respirator selection along with a change out schedule, respirator fit testing, and a care and maintenance routine.

OSHA has also developed a Diisocyanate Emphasis Program. Diisocyanates are used in flexible and rigid forming coatings, and Toluene Diisocyanate is found in most body shop hardening products. This substance reacts with hydrogen atoms to form Polyurethane, and these toxic and reactive chemicals enter your body through your respiratory system or by skin contact and can pass through latex gloves to make contact with skin. In addition to being a leading cause of work-related asthma, they can cause allergic reactions and increase a person's immune system's sensitivity to react to lower concentrations. Shops can protect painters by conducting air monitoring, supplying air respiratory protection, nitrile gloves, resistant paint suits, boot covers and enclosed eye protection, and by ensuring that PPE stays in the paint area.

Safety compliance regulations also extend to the shop. For a powered industrial truck, requirements include a written program, classroom training, operator evaluations, daily pre-trip inspections, a seat belt, horn, lights and a clear roof. Paint booths require permits, fire suppression, Class 1 Division 1 lighting and switches, a functioning manometer and air flow which are dependent on the size of the booth but typically requires six complete changes in 60 minutes.

Mixing rooms require ventilation with in and out flows, Class 1 Division 1 lighting, switches and outlets, a door that remains closed, a spill catch, post-emergency contact numbers, and closed containers, including a waste tunnel. It also mandates that all recyclers, gun cleaners, flammable liquid storage and dispensing drums are grounded.

Environmental compliance for air covers NESHAP 6H regulations, requirements on refrigerants, and state and local VOC regulations. The NESHAP 6H regulations mandate four walls and a roof on paint booths, and three walls and a curtain on prep stations. It also requires HVLP guns, 98% efficient filters, employee training, minimized overspray techniques, gun cleaning without atomizing and notification of compliance.

Refrigerant compliance includes A/C recovery equipment registration with the EPA, A/C recovery technicians trained in Section 609 of the CAA and HFO 1234yf which deals with global warming and flammability issues. State and local VOC regulations focus on volatile organize compounds and typically involves requirements for the following: cleaning equipment, parts washers, state notification of compliance, training, written procedures and maintenance of painting materials.

Next, Matthews discussed land-related environmental compliance. Waste is categorized as hazardous or non-hazardous based on generator knowledge and lab testing. Conditionally exempt generators produce less than 220 pounds of hazardous waste in a calendar month which precludes them from needing an EPA ID number or producing annual reports, plus they have no limit on storage of hazardous waste. Small quantity generators, producing between 220-2200 pounds of hazardous waste in a month, require an EPA ID number, can hold hazardous waste on-site for less than 180 days, and may be required to produce annual reporting, dependent on the state. Producing over 2200 pounds of hazardous waste in a month, large quantity generators require EPA ID numbers, federal reporting and fees and written emergency plans; hazardous waste can be held on-site for no more than 90 days.

Waste paint and thinner accumulation must follow a specified process which includes a steel drum with a closed top which is grounded, flammable liquid label, a closed funnel lid, a completed hazardous waste label with the start date of accumulation, and emergency contact information. Containers must be inspected weekly.

Disposal of hazardous waste requires a trained DOT hazardous waste shipper, package and label container. Matthews taught attendees to research their waste hauler, review the manifest, receive land disposal restrictions, sign and retain the "Generator Initial Copy," receive "Designated TSDF to Generator Copy," and retain matched manifests for three years.

Matthews concluded her presentation with photos of OSHA and EPA concerns to help attendees identify potential issues.

In business since 1986, KPA offers environmental, health and safety compliance services, HR management tools, and sales and finance compliance services online or on-site. Their goal is to help clients achieve regulatory compliance.

GCIA members also discussed the association's upcoming 20th Annual Golf Tournament, scheduled to be held on Wednesday, October 5 at Bear's Best in Suwannee, GA. Registration and sponsor information is available at www.gcia.org 

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