Environmental and Safety Concerns
by Sue Schauls - The Coordinating Committee for Automotive Repair (CCAR)
Automotive Waste Management
Every business must determine whether its wastes are hazardous or non-hazardous. Proper waste characterization is essential in determining applicable waste handling and disposal regulations.
The United States Environmental Protection Agency (EPA) establishes and enforces hazardous waste regulations through the resource Conservation and Recovery Act (RCRA 40 CFR 260). To implement an effective waste management program, an automotive facility must determine if its wastes are hazardous or non-hazardous. Wastes are defined as hazardous by specific EPA listing or by demonstrating one or more of the following characteristics:
Ignitability - A waste is considered an ignitable hazardous waste if it has a flash point less than 140 degrees Fahrenheit (EPA hazardous waste number D001). Material Safety Data Sheets (MSDS) may be referenced for flash point information. An example of ignitable hazardous waste is spent parts cleaning solvent.
Corrosivity - A waste is considered hazardous because of its ability to corrode if it has a pH less than or equal to 2 or greater than or equal to 12.5 (D002). MSDS will provide information regarding a product’s ability to corrode. Battery acid is corrosive.
Reactivity - A waste that reacts violently with water; explode or generate toxic gases, vapors or fumes when mixed with water or air; or is capable of detonation or exploding is considered reactive hazardous (D003). These wastes are not common in an automotive shop.
Toxicity - A waste is considered hazardous if it contains one or more toxin at concentration levels equal to or greater than the corresponding regulatory thresholds. Toxicity is determined by a specific laboratory analytical procedure identified as Toxicity Characteristic Leaching Procedure (TCLP). A waste that exhibits the characteristic of toxicity has an EPA hazardous waste number that corresponds to the specific TCLP contaminant(s) that cause it to be hazardous. Reducing toxicity is possible through good housekeeping, equipment installation or product substitution.
Many automotive wastes are exempt from hazardous waste management standards as long as they are recycled. Some wastes, such as antifreeze, oil absorbent, sump sludge and paint-related waste, require TCLP analysis to determine if the waste is hazardous. Some states may exempt these wastes if recycled too.
Once the facility determines which of the waste generated is hazardous, then the amount of waste generated must be quantified. A hazardous waste inventory of the amount of hazardous waste generated each month and kept on-site at any given time is how a facility determines which set of waste management rules pertain to the business.
Generator Category Regulatory Requirements
Three hazardous waste generator categories have been established by the EPA. These include: (1) Conditionally Exempt Small Quantity Generator (CESQG); (2) Small Quantity Generator (SQG); and (3) Large Quantity Generator (LQG). The appropriate generator category for a facility is determined from monthly hazardous waste generation rates and the total weight of hazardous waste stored at the facility at any one time. Some states have slightly different category designation but the underlying process is the same.
CESQG Category - The Conditionally Exempt Small Quantity Generator category is the least restrictive regulatory category. Facilities that generate less than 220 pounds (approximately 25 gallons of spent solvent or 100 kilograms [kg]) of hazardous waste per calendar month and never accumulate more than 2,200 pounds (approximately 250 gallons) of hazardous waste at any given time fall within the CESQG category. Although current regulations do not require CESQGs to obtain an EPA identification number, many hazardous waste transporters are requesting that companies have a number regardless of their generator category.
SQG Category - The Small Quantity Generator category pertains to facilities that generate more than 220 pounds but less than 2,200 pounds of hazardous waste per calendar month on either a regular or intermittent basis. Also, an SQG may not accumulate more than 13,200 pounds (approximately 1,500 gallons or 6,000 kg) of hazardous waste on site at any given time. An SQG cannot store hazardous waste for more than 180 days. A waste is considered “stored” from the day the first drop of hazardous waste enters the container.
An SQG is required to obtain an EPA identification number used in preparation of a hazardous waste manifest. A hazardous waste manifest is necessary to track the movement of hazardous waste from the point of origin to the point of the ultimate treatment, storage or disposal facility (TSDF). Only EPA-permitted transporters and TSD facilities are allowed to remove hazardous waste from a facility.
LQG Category - The Large Quantity Generator category is the most stringent regulatory level. Facilities generating hazardous waste in excess of 2,200 pounds per calendar month on either a regular or intermittent basis are considered LQGs.
Facility personnel should record the weight of all hazardous waste generated each month. At the end of the month, a monthly total should be determined. This information should then be used to determine the appropriate set of regulations (i.e., CESQG or SQG).
Record keeping is an important part of maintaining regulatory compliance. Maintain all environmental and waste management records in a centralized file at the facility. These records should be readily available in the event regulatory personnel inspect the facility. Documents such as laboratory reports, hazardous waste manifests, and hazardous waste inventory logs should be included among these records. Hazardous waste manifests should be maintained for a minimum of three years to document compliance.
Many automotive wastes are exempt from hazardous wastes management standards if recycled. These recycling exemptions make managing automotive wastes less cumbersome. With some equipment installations and good housekeeping practices an automotive shop may be able to eliminate or reduce waste streams that require hazardous waste management at the facility.
Spent petroleum-based parts cleaning solvent is hazardous waste.
Waste solvent generated from the cleaning of parts often exhibits the characteristic of ignitability (flash point <140oF) and toxicity from contaminants such as lead or benzene. Reducing the amount of spent solvent is an automotive shop’s greatest opportunity for reducing hazardous waste generation rates.
Alternative equipment such as oil skimmers and solvent filtration can keep solvent free of grease and grime for a longer period of time thus extend the useful life of the solvent and thereby reducing the amount of waste generated.
OIL SKIMMER FOR SOLVENT PARTS WASHER
Water-based parts cleaning can eliminate solvent from the shop.
Alternative to solvents such as aqueous-based cleansers are available which have the cleaning speed of the traditional petroleum-based solvents. Often these parts washers contain microbes that digest the grease and grime therefore leaving a non-hazardous wastewater to be disposed. These bioremediation parts washers are pleasant to work with too since the wash water is heated to about 104oF, about the temperature of a hot tub.
BIOREMEDIATION PARTS WASHER
More traditional water-based cleaning such as an enclosed wash cabinet is also an option to reduce solvent cleaning. It may not replace all small parts cleaning processes but could be used as an initial or “pre-wash” measure to remove the gross amount of grease and grime from the part prior to solvent cleaning. An aqueous wash cabinet can also reduce technician time spent cleaning parts.
AQUEOUS PARTS WASHER
Wash bay and power washing wastewater is often discharged to the shop floor drains. Closed-loop wash systems can recycle the wash water and detergent to reduce or eliminate industrial wastewater discharge.
All methods of industrial or commercial wastewater discharge are subject to some type of permit, approval or contaminant restriction. Shops that are serviced by the local publicly owned treatment works (POTW) should verify that the discharge is allowable in their service area and report to the POTW the type of discharge from the facility (i.e., wash bay wastewater from car wash).
Discharge of industrial wastewater is generally not allowed at facilities on sanitary septic systems. If industrial wastewater discharge is not allowed at the facility’s location then an evaporator system may be required to manage the wastewater on-site.
Floor drain sump sludge may be hazardous because of contaminants such as metal particulate or solvents and should be classified as hazardous or non-hazardous waste, through the TCLP testing procedure, prior to identifying disposal options. Sump sludge that is non-hazardous may be disposed of by any reputable septic sludge hauler.
Sump sludge from the floor drain sump pit in the shop area is more likely to be non-hazardous if good housekeeping habits are implemented at the automotive shop. The most important habit to acquire is to eliminate the use of chlorinated cleaners in the shop. The use of telescoping drain trays will also prevent pollution from hitting the floor. Studies have shown that shops that do not use chlorinated cleaners and take steps to pollution prevention steps frequently have non-hazardous sump sludge.
TELESCOPING DRAIN TRAY
Antifreeze may be recycled on-site.
Used Oil including brake, transmission and hydraulic fluids require good storage.
On-Site Storage of used oil must be clearly marked “USED OIL” and containers/aboveground storage tanks must be in good condition and not leaking.
OIL STORAGE TANKS
Oily waste such as used oil filters and spent oil absorbents require disposal.
Used oil filters must be hot drained for twelve (12) hours or crushed to remove the majority of the residual oil. Even after the used oil filter has been drained for many hours, more than an ounce of oil remain trapped in the filter. Oil may leach out and contaminate ground or surface water if improperly disposed or even legally landfilled. Some states have banned landfill disposal of used oil filters. Use of a drum-top tray for used oil filter draining can help keep the shop floor clean and capture oil for recycling.
An oil filter crusher can remove most of the oil from the spent filter and reclaim that oil for use in the used oil furnace. An oil filter crusher can also make the crushed canister more likely to be accepted as recyclable steel or at least reduce the cost of the disposal of a drum of used oil filters by placing more filters in the drum.
OIL FILTER DRUM TOP TRAY
Oily wastes such as used oil absorbent like clay granules, kitty litter, oil mats or socks can be hazardous due to the contaminants that were absorbed. These wastes must be categorized as hazardous or non-hazardous waste to determine acceptable on and off-site management practices. A representative sample of oily waste should be sent to an analytical laboratory for testing using the TCLP methodology for the parameters likely to be present. The use of oily waste for dust suppression purposes is specifically banned. Oily wastes can have a detrimental effect on the environment if improperly disposed or exposed to the weather elements.
Spill Prevention Control and Countermeasures
Facilities with oil storage capacity of 1320 gallons or more are required to prepare and implement a Spill Prevention Control and Countermeasures (SPCC) plan to ensure that the appropriate measures have been taken to reduce the risk of oil reaching navigable waters in the event of spill.
Recent changes to the SPCC rules have allowed facilities with less than 10,000 gallons of on-site storage capacity to self prepare a written spill prevention plan. The new rules are less stringent but have also created a sense of urgency as all applicable facilities are required to have written plans by November 2010.
Qualified Facilities with less than 10,000 gallons of oil storage capacity have the option to prepare a self-certified SPCC Plan. An essential part of preparing and implementing an SPCC is having storage of good integrity with secondary containment with the appropriate valve lock system and signage to alert operators. Absorbent material also should be made available in the event of a spill.
Spent Lead-Acid Batteries
Lead-acid batteries contain lead and corrosive acid that may contaminate soil and groundwater if not managed properly. Spent lead-acid batteries cannot be disposed of in a landfill but are exempt from hazardous waste regulations if they are recycled. The waste generator is still responsible for contamination caused by batteries transported off site as well as stored on site. Spent lead acid batteries do not need to be included in the facility’s hazardous waste inventory.
Batteries should be stored safely and only reputable recyclers should be used. New and used batteries should be stored in a safe manner to prevent leaks and subsequent ground contamination. Indoor storage on an acid-resistant rack or tub is preferable.
Batteries stored outdoors should be stored on an impermeable surface such as concrete with secondary containment, and sheltered from rain to prevent acid run-off. To further prevent pollution, keep a neutralizing agent such as baking soda nearby in case of a spill, do not stack batteries more than two high since that may cause them to fall and crack, and store batteries and battery acid away from flammable liquids, ignition sources and drains. Keep dated receipts including the name and location of the recycler and number of batteries sent
Refrigerant recovery equipment must be MAC certified.
The Clean Air Act Amendments of 1990 prohibit service related releases of all refrigerants (i.e., R-12 and R-134a). The venting ban became effective January 1, 1993. In addition to the release ban, facilities performing AC repair work must use EPA-approved refrigerant recovery/recycling equipment and certified AC service technicians must complete all work. Assure proof of technician certification is readily available onsite.
Maintain records of off-site refrigerant disposal/reclamation including the amount of refrigerant, the date sent, and the facility that received the refrigerant. The waste refrigerant does not need to be included in the facility’s hazardous waste generation total.
REFRIGERANT RECOVERY MACHINE
Automotive body shop waste can be challenging to manage.
Waste paint/thinner is hazardous waste because of specific listing, ignitability and/or toxicity. Hazardous waste must be included in the facility’s hazardous waste inventory and removed by an EPA-permitted hazardous waste management company. The waste paint/thinner drum must remain closed except when adding waste.
Hazardous waste storage containers must remain closed and be clearly labeled “Hazardous Waste.” For SQGs, up to 55 gallons of hazardous waste may be accumulated at the point of generation and under the supervision of the individual generating the waste for an indefinite period of time. The container must be labeled “Satellite Accumulation.” When 55 gallons has accumulated, the satellite accumulation container must be moved to a permanent hazardous waste storage area within 3 days and relabeled “Hazardous Waste.” Hazardous waste containers must be marked with the date they first received waste or the date when moved from the satellite accumulation area to the permanent hazardous waste storage.
To reduce the cost of disposal for waste thinners consider using a solvent distillation unit to dramatically reduce the disposal and product purchase costs.
THINNER DISTILLATION UNIT
Reuse reclaimed thinner to remove the excess paint from the spray gun cup prior to placing it in the gun wash unit to extend the life of the solvent in the gun wash. Reuse the reclaimed thinner in the gun wash unit.
Paint-related waste includes wastes such as masking, paper, booth filters, disposable shop rags, and floor sweeping. Paint-related waste must be classified as hazardous or non-hazardous waste through the TCLP testing procedure.
New regulations for auto body painting recommend some specific equipment for full compliance by March 2011. This rule will impact automotive body shops & manufacturers/facilities that conduct painting operations that use paint that contain Hazardous Air Pollutants (HAPs). This rule will not regulate hobbyists or facilities that are using paints that do not contain the listed HAPs.
On January 9, 2008, the US EPA issued the final rule for 40CFR63 Subpart HHHHHH of the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources. The purpose of this rule is to reduce emissions of lead, nickel, cadmium, chromium and manganese. These chemicals are designated hazardous air pollutants known or suspected to cause cancer and other adverse health effects and can be found in paint used in the automotive refinishing industry.
This new rule impacts many facets of a regulated facility, including where painting takes place, the filters used, the paint guns that are used, how paint guns are cleaned, and the training of painters. The rule requires all spray-applied painting to be conducted in a paint booth. Spray-applied painting outside of a paint booth will be prohibited. This may impact how a company moves product through its facility. All exhaust filters used in the paint booths will have to be at least 98% efficient and will be required to have documentation that they meet this efficiency.
All coatings will be required to be applied using the following approved paint gun technologies:
• High volume, low pressure (HVLP)
Paint guns will be required to be cleaned by hand or in a fully-enclosed gun wash. Atomizing solvent through the paint gun for cleaning purposes is not allowed.
The one requirement that may have the most long-term impact is that all painters will be required to go through a specific training program every five years. This training must cover:
• Spray gun equipment selection, set up, and operation
For a facility to be in compliance, it must meet all these requirements and must document compliance with training records, filter and paint gun documentation, and copies of regulatory reports. Existing facilities are required to submit notification of compliance status by March 11, 2011. New facilities are required to complete an initial notification form and a notification of compliance status within 180 days after startup.
GreenLink Shop Recognition Program
The Coordinating Committee for Automotive Repair (CCAR) offers a GreenLink Shop recognition program for shops that are in compliance with the environmental health and safety regulation pertaining to the industry.
The GreenLink Shop program recognizes automotive professionals adhering to the highest standards of excellence in the industry. The process is an intensive review of the practices at individual shops through a self certification checklist process that is then reviewed by the experts at CCAR. Shops struggling with regulatory issues can receive assistance through CCAR to make the necessary changes in waste management practices to become compliant and then be recognized as a GreenLink Shop.
What is Coordinating Committee for Automotive Repair?
What Does CCAR Do?
Safety Compliance for Automotive
Many standards promulgated by the Occupational Safety and Health Administration (OSHA) explicitly require the employer to train employees in the safety and health aspects of their jobs. Other OSHA standards make it the employer’s responsibility to limit certain job assignments to employees who are “certified,” “competent,” or “qualified”undefinedmeaning that they have had special previous training, in or out of the workplace.
These requirements reflect OSHA’s belief that training is an essential part of every employer’s safety and health program for protecting workers from injuries and illnesses. Many researchers conclude that those who are new on the job have a higher rate of accidents and injuries than more experienced workers.
OSHA concluded that effective management of worker safety and health protection is a decisive factor in reducing the extent and the severity of work-related injuries and illnesses. Effective management addresses all work-related hazards, whether or not they are regulated by government standards.
Establish and maintain a Material Safety Data Sheets (MSDS) program.
The Occupational Safety and Health Act standards (29 CFR PARTS 1910 and 1926) govern safety compliance in the U.S. This agency investigates safety and health complaints in construction and general industry, fatalities/catastrophes and performs general scheduled including a review of an employer’s MSDS program.
What is a Compliant MSDS Program?
MSDS must be readily accessible to employees when they are in their work areas during their work shifts. This may be accomplished in many different ways. Many employers keep the MSDSs in a loose-leaf binder in a central location at the facility. In workplaces with large numbers of chemicals, MSDS information is kept electronically and accessed through computer terminals. As long as employees can get the information when they need it, any approach may be used.
The employees must have access to an MSDS themselves - simply having a system where the information can be read to them over the phone is only permitted under the mobile work-site provision when employees must travel between workplaces during the shift. In this situation, they have access to an MSDS prior to leaving the primary work-site, and when they return, so the telephone system is simply an emergency arrangement.
Safety Supervisor and a Safety Program
A Safety Program will consist of guidelines for developing and maintaining safe operations within the facility. A designated Safety Manager will be responsible for overseeing the Safety Program.
Conduct monthly safety training as recommended by OSHA.
Safety training should not have a beginning and an end, but represent an ongoing effort that continually promotes a safe working environment.
Personal Protective Equipment
Personal protective equipment (PPE) can help complement other measures taken by employers and employees to minimize hazards and unsafe conditions. Recent OSHA revisions require the employer to complete a written hazard evaluation of the workplace to determine employee hazards and the PPE necessary to protect them.
Personal Protective Equipment (PPE) is specialized clothing or equipment worn by employees for protection against health and safety hazards. Personal protective equipment is designed to protect many parts of the body, including; eyes, head, face, hands, feet, and ears.
Complete Written PPE Hazard Evaluation
Employees at automotive shops are required to have and wear personal protective equipment such as safety goggles, foot protection, hard hats, gloves and other gear that will reasonably protect them from on the job hazards. Protecting employee’s feet, hands, and eyes are an important yet routine part of automotive work.
Employers routinely make items such as safety goggles and gloves available to employees. Fitted gear such as footwear, clothing and rain gear must be maintained by the employee as a condition of employment.
Eye Wash Station
Workers’ eyes may be damaged very quickly by exposure to contaminants in battery storage or vehicle processing areas. The first fifteen (15) seconds after an eye injury is critical. The American National Standards Institute (ANSI) suggests that eye wash stations be located within 25 feet, or a 10 second walk, of critical work areas.
Fires may be caused by welding or torching, fuel or fume explosions, electrical problems, or ignition of combustibles. Take preventive measures, learn how to recognize and respond to different types of fires, and properly handle and store chemicals and flammable liquids.
Fire extinguishers must be maintained in a fully charged and operable condition and kept in their designated places at all times except during use. Fire extinguishers for employee use should be selected and distributed based on the classes of anticipated workplace fires and on the size and degree of hazard which would affect their use. A multi-purpose ABC rated fire extinguisher is appropriate for an automotive shop.
Maintain a stocked first aid kit.
A first aid kit allows trained workers to respond to a minor injury or illness, and to provide temporary relief of a more serious injury until professional medical assistance is obtained.
OSHA recommendations do not include an automated external defibrillator (AED), but current emergency cardiac care guidelines from the American Heart Association recommend AEDs in most public places.
A spill kit allows workers to capture, contain, and clean up spills or leaks of fuel, new or used oils, antifreeze, solvents and other fluids.
Forklift training for employees
OSHA requires that any employee who operates a forklift be trained and certified. The training addresses forklift design and parts, operation, driving rules, and maintenance requirements. Operator’s performance must be evaluated at least every three years. Refresher training is also available.
Sue Schauls is the CCAR Technical Advisor and an expert in automotive environmental, health and safety. She holds a BA in Science: Environmental Planning from the University of Northern Iowa (1996) and has over 16 years experience in consulting with automotive professional on pollution prevention, regulatory compliance and safety issues.