To:             Environmental Health and Safety CoordinatorFrom:        Sam Celly, BChE MChE JD CSPDate:         October 30, 2025Ref:           Electronic Verification Questionnaire (eVQ) CALIFORNIA BUSINESS ONLYWhat is eVQ?State of California EPA requires each Hazmat generator (producer of waste) to complete the Electronic Verification Questionnaire (eVQ) annually starting January 30, 2026. There are no fees involved to submit the eVQ, however, starting in 2026 the State will issue “late reporting penalties” for submissions made after March 31, 2026. For more information, visit https://dtsc.ca.gov/evq-penalties/If you have stopped operations involving hazardous waste, you can deactivate your EPA ID by filing DTSC Form 1358. Deactivation of the unused number can occur during the eVQ filing process as well.  Clients of Celly Services: Please complete the form below and email to accounts@cellyservices.com prior to January 31, 2026.Username: __________________________Password: ___________________________o  If Celly Services has completed eVQ for the dealer prior, please disregard question 1 & 2.Total Number of Employees1: ________________________________California Department of Tax & Fee Administration (CDTFA) Hazardous Waste Generation and Handling (G&H) Fee account number2: ________________________________Amount of Universal Waste generated (in tons): ________________________________1The total number of individuals employed by your entire company or organization throughout California during the 2025 calendar year. Include all employees who worked 500 hours or more, including those who worked at locations that did not generate hazardous waste.2 Sample Haz Waste Gen acct# 123-456789 – It will be a 9-digit number.3 Universal waste includes: Light bulbs, batteries (alkaline, lithium), non-empty aerosol canisters, CRT glass, mercury waste, and electronic devices: Computers, monitors, printers, cell phones, and any electronic equipment with a circuit board. For more detail visit universal-waste-fact-sheet.NotificationIf you have not received any notification, chances are it is going into a manager’s email box that is not being attended to or the manager is no longer at the company.  So, if you have no notification and your eVQ has not been completed, log into your eVQ (reset password if needed) and set up new user name and password; an override of the old one will be required.What happens if you do not file eVQ?The dealership’s EPA ID number will be made INACTIVE and penalties will follow. EPA sends an email that for failure to complete the eVQ, the number is getting inactivated.  Unfortunately, the dealership staff receiving the email fails to respond to the email or the email goes to an email account that is not being attended.  The hazardous waste hauler will stop picking up the hazardous waste as the EPA number has become inactive. Your hazardous waste oil tanks, drums and buckets will start to overflow! Only after completion of a new EPA ID application for reactivation of the EPA ID number and upon the completion of the eVQ, will the EPA ID number get reactivated. This whole process can take three weeks and can be demanding. Good news is that SB 158 eliminated the Manifest Fee & the EPA verification fee (the fees associated with eVQ). Other Useful Links·     Verification Questionnaire Step by Step Guide·     Check My ID Number Status

To:          Environmental Health and Safety CoordinatorFrom:     Sam Celly, BChE MChE JD CSPDate:      December 16, 2025Ref:        CALIFORNIA ONLY: Training Documentation Requirements Effective January 1, 2026 OverviewWhen an employee leaves a place of employment, the traning records are left behind.  Request by an ex-employee for traning records may go unanswered. CA state arrives to the rescue!  Beginning January 1, 2026, California is implementing requirements related to employee access to training records. They affect how dealerships record, maintain, and provide access to training programs. Regulatory agencies are also increasing expectations for annual safety training, particularly for operations involving hazardous materials, spill prevention, and environmental compliance. Proactive alignment now will reduce audit risk and improve readiness going into 2026.What Are the Changes in 2026Employers who maintain training or education records must ensure these records include:Employee nameTraining providerDate and duration of trainingCore competencies or subjects covered (e.g., Heat Illness Prevention, Hazmat, Emergency Response, etc.)Certification or qualification issued, if applicable.Celly Services has created an effortless pathway to obtain employee training records.Login to CSI E-Learn portalClick TRAINING RECORDS tab on the left menu.Type employee email or name on the top and Search.Click “Print Certificate” to obtain training certificate. Under the new law, employees have the right to request and receive copies of their training records.Recommended Actions for DealershipsTo prepare, before January 1, 2026, all dealerships should:Enroll employees onto Celly Services’ E-Learn portal for training modules and recordkeeping.Use this excel spreadsheet to enroll employees onto E-Learn.Once completed, email spreadsheet to elearn@cellyservices.comReview current training files for required documentation elements.Standardized training record templates across all departments.Sign-in-sheets on E-Learn will be updated to reflect the 2026 changes.Retain records in an accessible format (digital format recommended via uploading on E-Learn portal).Provide employees with access upon request within required time limits.Update written training policies to reflect these changes.Why This MattersIncreased regulatory scrutiny and audit frequency.Reduced liability exposure during incidentsStrengthened compliance posture for 2026 and beyond.Consistency across dealership locations and departmentsThank you for your attention to this important update.DISCLAIMER: The contents of this newsletter are merely for informational purposes only and are not to be considered as legal advice.   Employers must consult their lawyer for legal matters and EPA/OSHA consultants for matters related to Environmental, Health & Safety. The article was authored by Sam Celly of Celly Services, Inc. who has been helping automobile dealers comply with EPA and OSHA regulations since 1987.  Sam received his BE (1984) and MS (1986) in Chemical Engineering, followed by a J.D. from Southwestern University School of Law (1997).  Our newsletters can be accessed at www.epaoshablog.com.  Your comments/questions are always welcome.  Please send them to sam@cellyservices.com.

To:       Environmental Health and Safety Coordinator

From:  Sam Celly, BChE, MChE, JD, CSP

Ref:     Labor Law Posters

Date:   November 25, 2025

Background
Employers are required to maintain designated employee areas, such as breakrooms, that promote awareness of labor laws, safety responsibilities, and workplace rights. In addition to providing a clean and sanitary space, the breakroom often serves as a central posting location for mandated notices and company safety materials.

POSTER FOR ALL STATES

State and Federal Labor Law Posters.

• Source for: AZ, CA, CO, FL, GA, IL, NJ, NV, NY, OR, TX, UT, WA, & Federal labor law posters.
  CalChamber Store Labor Law Posters (Preorders for 2026 posters are available and will begin shipping out on December 22, 2025)

Heat Illness Prevention Posters: Recommended to educate employees on heat Illness. OSHA Heat Illness Prevention Poster

QR Code
OSHA’s recommended practices for safety and health programs include elements to encourage worker engagement and safety suggestions. Use the QR Code to print and place the safety suggestion poster on the Notice Board.  Available to Celly Services clients on the client login page.

POSTERS FOR CALIFORNIA

State and Federal Labor Law Posters.

• Source for CA & Federal labor law posters.
  CalChamber Store Labor Law Posters (Preorders for 2026 posters are available and will begin shipping out on December 22, 2025)

Heat Illness Prevention Posters: Recommended to educate employees on heat Illness. OSHA Heat Illness Prevention Poster

California Mercantile Wage and Hour Poster can be downloaded from the state website Wage and Hour Poster English & Wage and Hour Poster Spanish

California Prop 65 signs

California Prop 65 signs summary

Injury and Illness Prevention Program (IIPP) Policy Statement: Cal/OSHA under the IIPP program that employees be notified of the location of the IIPP.

Note
The following fillable sections on labor law posters MUST befilled out completely.

• Emergency contacts (hospital, physician, police, fire dept, and ambulance)
• Medical Provider Network (California only)
• See the poster from your state for other mandatory information

CALIFORNIA The Workplace Know Your Rights Act (Posters Required)

SB294 was signed into California law by Governor Newson on October 12, 2025. The Workplace Know Your Rights Act takes effect on January 1, 2026 and requires California employers to provide a stand-alone notice informing all employees of various workplace rights, including those related to workers’ compensation, immigration practices, notices of inspection, organizing, and constitutional rights during law enforcement actions in the workplace (Fourth Amendment to the United States Constitution to be free from unreasonable searches and seizures and rights under the Fifth Amendment to the United States Constitution to due process and against self-incrimination).

• The California Labor Commissioner will publish a stand-alone notice template by January 1, 2026 for employers to use in, and will update the notice must annually.By July 1, California Labor Commissioner will publish a video that informs employees of their rights (in English and Spanish), and a separate video informing employers of their responsibilities. Employers should prepare to comply with the new requirements and monitor the California Labor Commissioner’s Office website for the notice and videos from the Labor Commissioner.
• By March 30, 2026, employers must allow current employees, and new employees upon hire, to designate an emergency contact in case of arrest or detention at work. HR manager must update employee records.
• Employers who violate the Act face civil penalties of $500 per employee, per violation. Specifically for violations of the emergency contact requirements, employers face civil penalties of $500 per employee for each day the violation occurs, up to a maximum of $10,000 per employee.

Legalese
California SB 294 has a list of legal rights for employees and obligations for the employer.  Employers are well served to consult their labor lawyer to stay compliant.  The labor law poster list provided is for guidance purposes and the employer should contact their labor counsel for a complete list of notifications.

DISCLAIMER: The contents of this newsletter are for informational purposes only and are not to be considered legal advice. Employers must consult their lawyer for legal matters and EPA/OSHA consultants for matters related to Environmental, Health & Safety. The article was authored by Sam Celly of Celly Services, Inc. who has been helping automobile dealers in Arizona, California, Hawaii, Idaho, Nevada, New Mexico, New York, Texas, and Virginia comply with EPA and OSHA regulations for over 35 years. Sam is a Certified Safety Professional (No. 16515) certified by the National Board of Certified Safety Professionals. Sam received his BE (1984) and MS (1986) in Chemical Engineering, followed by a J.D. from Southwestern University School of Law (1997). Sam is a member of the American Chemical Society (No. 31176063), American Industrial Hygiene Association (No. 124715), and National Association of Dealer Counsel (NADC). Sam also serves on the Board of Orange County American Industrial Hygiene Association and on CA Industrial Hygiene Council (CIHC). Our newsletters can be accessed at www.epaoshablog.com. We welcome your comments/questions. Please send them to sam@cellyservices.com.

To: Environmental Health and Safety Coordinator

From: Sam Celly, BChE MChE JD CSP

Date: November 24, 2025

Ref: SB 1215 requires California retailers to register with CDTFA and collect a new recycling fee on products containing non-removable (embedded) batteries starting January 1, 2026.

Introduction & Purpose
Effective January 1, 2026, retailers doing business in California—including automotive dealerships—must comply with the newly established Covered Battery-Embedded Products (“CBE”) Waste Recycling Fee, administered under Senate Bill (SB) 1215. Retailers must register with the California Department of Tax and Fee Administration (CDTFA) and collect the CBEP fee at the point of sale or lease of applicable products. 

The program is jointly overseen by CDTFA, CalRecycle, and the Department of Toxic Substances Control (DTSC). It is intended to support statewide recycling of electronic products containing non-removable batteries. The new law expands the existing Electronic Waste Recycling Act of 2003 to include these “covered battery-embedded products.”

What Is a Covered Battery-Embedded Product?
Covered battery-embedded product means “a product containing a battery or battery pack that is not designed to be removed from the product by the consumer.”(California Public Resources Code 42464(d)(1), as amended by SB 1215, 2022.)

Examples of CBE at dealerships

• Consumer electronics
• EV-related accessories
• Diagnostic or programming devices
• Electronic tools or service accessories
• TPMS-Tire Pressure Monitoring Systems
• Smartphones, tablets, and similar sealed battery devices

Note:  Key fobs are not considered CBE because it contains a battery that is designed to be easily removed by the user with common household tools.

TPMS Sensors – Possible Inclusion
Many Tire Pressure Monitoring System (TPMS) sensors contain sealed lithium batteries that are not easily user replaceable. This design places TPMS within the scope of a CBE. As of the date of this memo, no TPMS manufacturer has released official SB 1215 guidance. Dealerships should prepare for potential inclusion and monitor manufacturer updates closely.

Exclusions
The following are not classified as CBE.

• Certain medical devices
• Covered electronic devices (already subject to California’s e-Waste fee)
• Certain energy storage systems
• Certain electronic nicotine delivery systems

The following transactions are not subject to the CBE waste recycling fee.

• A sale for resale
• A sale to Native Americans on Indian country
• Sale of CBE products the retailer ships directly to a location outside California when the transaction is not subject to California sales or use tax. The fee will apply if the buyer takes possession of the CBE products in California

CBE Fee Rates
CalRecycle has now finalized the 2026 fee structure.  This will be revised annually in October and will take effect January 1 of the following year.

• 1.5% of the retail sales price
• Capped at $15 per product
• Effective January 1, 2026
• Dealership POS systems will need to incorporate the percentage-based calculation and the per-item cap. They may retain three percent of the CBE waste recycling fee collected as reimbursement for all fee collection costs.

Registration Timeline
CDTFA opens online registration for the CBEP Waste Recycling Fee account today, November 19, 2025.
Dealerships without CDTFA credentials (username, password, or seller’s permit) must create them using the “Sign Up Now” feature in the CDTFA Online Services Portal.

Filing Requirements & Due Dates
Returns and payments are due the last day of the month following each calendar quarter. For example, the first required reporting period is for the first quarter, January 1 through March 31. The return and fee payment are due on or before April 30th. The return is due on either a quarterly or yearly filing basis, and filing frequency is assigned when you register. You are required to file a return even if you did not have any reportable activity or do not owe an amount during the reporting period.

Dealership Responsibilities

• Fee collection at POS (including leases)
• Filing CBE returns, at assigned frequency
• Timely remittance of fees to CDTFA
• Retain 3% of fees as reimbursement for all fee collection costs
• Inventory review and system updates

Non-compliance may result in CDTFA penalties, interest, and enforcement action.

For More Information
CDTFA – CBE Waste Recycling Fee Guide
Provides instructions for registration, filing, and fee remittance.

CDTFA Customer Service Center
1-800-400-7115 (TTY: 711)
Monday–Friday, 7:30 a.m.–5:00 p.m. Pacific
Select: Special Taxes and Fees

CSI Client Testimonials
https://cellyservices.com/testimonials/

DISCLAIMER: The contents of this newsletter are merely for informational purposes only and are not to be considered as legal advice.  Employers must consult their lawyer for legal matters and EPA/OSHA consultants for matters related to Environmental, Health & Safety. The article was authored by Sam Celly of Celly Services, Inc. who has been helping automobile dealers comply with EPA and OSHA regulations since 1987.  Sam received his BE (1984) and MS (1986) in Chemical Engineering, followed by a J.D. from Southwestern University School of Law (1997).  Our newsletters can be accessed at www.epaoshablog.com.  Your comments/questions are always welcome.  Please send them to sam@cellyservices.com.

TO:               Environmental Health and Safety (EHS) CoordinatorFROM:         Sam Celly, BChE MChE, JD CSPSUBJECT:    Accident Investigation: Who? What? Where? When? How?DATE:          October 17, 2025 Accident investigation should be the cornerstone of any safety program.  Many safety programs concentrate on safety inspections and training but miss out on accident investigation.  They do so at their own peril.  Investigating accidents is not only a good idea, but also a requirement.  Here, we provide some guidance and tools to complete an accident investigation. OSHA strongly encourages employers to investigate all incidents in which a worker was hurt, as well as close calls (sometimes called “near misses”), in which a worker might have been hurt if circumstances had been slightly different.  National Safety Council defines accident as an undesired event that causes injury or property damage.  An incident, on the other hand, is an unplanned, undesired event that adversely affects the completion of the task.  Near misses are events with no injury or loss, but with a slight shift in time or location, an injury would have easily happened. To many, “accident” suggests an event that was random, and could not have been prevented. Since nearly all worksite fatalities, injuries, and illnesses are preventable, OSHA suggests using the term “incident” investigation.  OSHA needs to be notified regarding serious accidents within a specific timeframe.  The timeframe varies between CA state and federal regulations.  For fatalities and serious injuries such as amputations, the dealership should seek legal counsel right away. Accident InvestigationAccident investigations should be conducted by trained individuals with the primary focus of understanding why the accident or near miss occurred and what actions can be taken to preclude recurrence. In smaller organizations, the responsibility may lie directly with the supervisor responsible for the affected area or employee. Questions to ask in an accident investigation include: 1.     What happened?Describe what took place to prompt the investigation: an injury to an employee, an incident that caused a delay in production, damaged material or any other conditions recognized as having potential for losses or delays. 2.     Why did the incident happen?Obtain all the facts surrounding the occurrence: what caused the situation to occur; who was involved; was/were the employee(s) qualified to perform the functions involved in the accident or near miss; were they properly trained; were proper operating procedures established for the task involved; were procedures followed, and if not, why not; where else does this or a similar situation exist, and how can it be corrected? 3.     What should be done?The person conducting the investigation must determine which aspects of the operation or processes require additional attention. It is important to note that the purpose here is not to establish blame, but to determine what type of constructive action can eliminate the cause(s) of the accident or near miss. 4.     What action has been taken?Action already taken to reduce or eliminate the exposures being investigated should be noted, along with those remaining to be addressed. Any interim or temporary precautions should also be noted. Pending corrective action and reason for delaying its implementation should be identified.Corrective action should be identified in terms of how it will prevent a recurrence of the accident or near miss and how it will improve the overall operation. This will assist in selling solutions to management. The solution should be a means of achieving accident control and total operation control.The safety committee should review investigations of all accidents and near miss incidents to assist in recommending appropriate corrective actions to prevent a similar recurrence.  Thorough investigation of all accidents and near misses will help you identify causes and needed corrections, and can help you determine why accidents occur, where they happen, and any accident trends. Such information is critical to preventing and controlling hazards and potential accidents. Accident Investigation Form (Form Attached)Fraud Prevention Tool: Keep in mind that properly completed investigations can later serve as tools in fraud prevention as well.  At the time of the accident, it is not apparent which case will be considered fraud, and which one will end up in litigation.  Statements noted at the scene of the accident carry sufficient evidentiary weight in legal situations.  Forms that are normally and customarily completed by corporations are admissible evidence and statements given immediately after an accident or incident are admissible as well.  Questions to ask in an accident investigation include:Age: Noting the age, at times, help us determine if the injury occurred to an aged person involved strenuous work activity.  You may have to provide training, engineering controls to prevent the injury from reoccurrence.  At times, you may need to reassign the person to another job function temporarily.  Do not discriminate on the basis of the injured employees’ age.Accident Time/Date v. Reported Time/Date: Normally, accidents are visible to other employees in the work area.  However, many times the employee reports an accident much later than its occurrence.  It could be genuine, i.e., the back sprain really started hurting the next day.  Or it may be that a personal injury at home or during recreational activities is being attributed to workplace injury.  Record the facts now; it may help your case later.  You may also document the date/time the employee sought medical assistance on the form.Equipment Being Operated: Was the employee trained in its use?  Is the equipment new?  Was the equipment damaged or in need of repair? Is the equipment being used for the task it has been provided for?Part of Body Injured: Document on the part of the body injured and the extent of injury and loss of motion etc.  Sometimes the employee reports injury to one part of the body.  However, the employee may later (and when lawyers arrive) decide to list a whole lot of other body parts with injuries.  Your document cannot refute all other injuries alleged by the employee, but it definitely gives guidance to your counsel as to what the employee reported at the time of the injury.Description of Accident: Be careful in stating your case.  Just state the facts.  Remember this document may go in the hands of people litigating the case against you.  If the injury involves a serious accident, such as amputation or fatality, ask your lawyer to help you with the forms.  OSHA will use this document to weave penalties that can reach into the thousands, so a word of caution here.Primary Causes: The trio that is the root cause of most accidents is improper tools, improper procedures, or the employee was in a hurry.  Whatever the cause, write it down. It is your possible solution to prevent the injury from reoccurring.Corrective Measures: Generally, the corrective action may be obvious and the action you intend to take is clear.  If not, you may discuss options and actions with others and complete another form for documenting steps taken to prevent such accidents.  It may involve safety training, providing personal protective equipment or its use thereof, purchasing new equipment, or good old-fashioned counseling of the employee.  Equipment LOTO must be noted if the equipment was defective or damaged.Witnesses: Document witness statements.  The sooner, the better.  Memory begins to fade with the passage of time.  Some people avoid this, stating that the nature and severity of accident does not require one.  We believe good practice is good practice for a reason.  Document all who saw and what they saw in each accident you document.  If the accident involves a serious injury or a fatality, ask your lawyer to take witness statements.Witness statement taken immediately following an accident are clearly admissible.  Statements taken months after the accident and after litigation ensues may not be admissible.Third Party Causation: Interact with third party to eliminate such accidents in future.  Inform your insurance company to follow up with subrogation. Safety Counseling Form (Form Attached)Once you have found the root cause of the accident, it is important to counsel the employee.  If the accident involves carelessness as a cause, state that the employee may face disciplinary actions consistent with the employer’s policy on such matters up to and including suspension or termination.  Lack of action on part of management may implicate the manager for not taking preventive action that could have prevented future accidents.  California statutes carry jail term for managers of sites where employees were killed or seriously injured. Employee Statement of Injury (Form Attached)Employees shall use this form to report all work-related injuries, illnesses, or “near miss” events (which could have caused an injury or illness) – no matter how minor. This helps us identify and correct hazards before they cause serious injuries. This form shall be completed by employees as soon as possible and given to a supervisor for further action. Declination of Immediate Medical Care (Form Attached)The nature of certain injuries may be such that the employee declines treatment from a clinic even though the employer provided the option.  In certain instances, you may not give the employee the option to decline treatment.  Use your judgement.  The law says that you must provide employee treatment when you have knowledge of workplace injury!  Forms for documenting the employee declining medical treatment are attached and may be used as necessary. DISCLAIMER: The contents of this newsletter are merely for informational purposes only and are not to be considered as legal advice.   Employers must consult their lawyer for legal matters and EPA/OSHA consultants for matters related to Environmental, Health & Safety. The article was authored by Sam Celly of Celly Services, Inc. who has been helping automobile dealers comply with EPA and OSHA regulations since 1987.  Sam received his BE (1984) and MS (1986) in Chemical Engineering, followed by a J.D. from Southwestern University School of Law (1997).  Our newsletters can be accessed at www.epaoshablog.com.  Your comments/questions are always welcome.  Please send them to sam@cellyservices.com.

To:       ClientsFrom:  Sam CellySub:     Workers Compensation, Experience-Modifier, and How Litigation is Adding to Our ClaimsDate:   September 18, 2025 Introduction. Dealerships Workers Compensation (WC) insurance costs have increased effective September 1, 2025 with the California Department of Insurance approving a rate increase of about 9%. Background.  Workers Compensation (WC) insurance is mandatory in the United States and many other countries. It ensures employees receive medical treatment and disability benefits for workplace injuries, while protecting employers by providing immunity from employee lawsuits for alleged negligence. WC premiums are paid entirely by employers and represent a significant, manageable business expense. Steady over nearly a decade, rate increases are attributed to rising medical and claims costs, more cumulative trauma claims, and increased claim adjustment expenses.                                                                                                                                                                                                            Cost Containment. WC premiums are calculated using a base rate that reflects job duties, payroll size, and the number of employees. This base rate is then adjusted by an experience modifier (X-Mod) tied directly to the frequency and severity of workplace injuries. Losses are calculated from claims paid by the insurance company, so every claim impacts your premium for multiple years. Preventing injuries is the most effective cost-control strategy. Being Proactive. Reducing both injuries and claims, starts with a proactive approach to safety and claims management. Employers should:Form and maintain an active Safety CommitteeDesignate an approved medical clinicEncourage open communicationDocument thoroughly Accident Investigation, Employee Statement of Injury, Employee Counseling, Declination of treatment by employeeVerify coverage for contractors working on your premises and others Post-Claim. Promptly report all claims to the carrier even declinations with signed forms. In California, the 90-day rule for workers’ compensation claims means that if the insurance carrier fails to accept or deny a claim within 90 days of it being submitted to the employer, the claim is presumed accepted.Ensure supervisors investigate each claim and notify your carrier if legitimacy is in question. If a third party is at fault, pursue subrogation. Offer modified duty, when possible, to reduce costs, and work closely with your claims adjuster by providing requested information quickly for efficient claim handling. Managing Your Claims. Stay actively engaged in the claims process ask for updates frequently. Open claims with high reserves are a major reason X-Mods increase. Remember that legal expenses do not affect your X-Mod, but illegitimate claims should always be challenged. Sometimes settling quickly is more cost-effective than allowing claims to linger. For litigated cases, voluntary resignations may be part of the settlement strategy. Ultimately, the best claim is one that is prevented, and the next best is one that is promptly closed. Calculating Costs.  In California, payroll data and incurred losses over a four-year period are used to calculate an employer s workers compensation premium. For example, the 2025 X-Mod basis for policy renewal on January 1, 2025 are WC claims from 2021, 2022, and 2023.  While 2024, most recent year s claims are excluded from the X-Mod calculation, it remains critical for underwriting. Even with a favorable or credit X-Mod, a dealership with multiple recent claims may be viewed by carriers as having a weak safety culture, leading to fewer quotes and/or higher premiums. Checklist before submitting your data.Are payroll data correct?Are X-Mods calculated correctly?  Per insurance brokers 75% of all X-Mods are incorrect.Are subrograted & joint claims included or missing? Cost Savings. Two employers with identical payrolls (Table A) show how injury rates drive costs. Employer II had four more injuries than Employer I, resulting in $282,500 in losses versus $45,004. This difference raised Employer II s annual premium by $174,540 in 2015. Because claims affect premiums for three years, preventing injuries saves money while also improving morale, productivity, and competitiveness.Table A:  Payroll Data (both Employer I & II)EmployeeAnnual PayrollNo. of EmployeesPayroll Year 1Payroll Year 2Payroll Year 3Clerical/Office Staff (code 8810)$ 50,000.0020$ 1,000,000.00$ 1,000,000.00$ 1,000,000.00Sales Staff(Code 8748)$ 80,000.0020$ 1,600,000.00$ 1,600,000.00$1,600,000.00Technicians(Code 8391)$ 80,000.0023$ 1,840,000.00$ 1,840,000.00$1,840,000.00Service Writers, Parts Counter, Parts and Service Managers(Code 8391B)$ 85,700.007$ 600,000.00$ 600,000.00$600,000.000Total 70$ 5,040,000.00$ 5,040,000.00$5,040,000.00Table B:  Injury Data & Losses Paid per Injury  Employer IEmployer IIYearClaim #Type of InjuryIncurred LossesType of InjuryIncurred LossesYear 11Cut Finger$ 1Back Injury$   50,000.00Year 12Cut Finger$ 1Back Injury$     7,500.00Year 13Broken Finger$ 10,000.00Broken Finger$   10,000.00Year 14Cut Finger$ 1Elbow Sprain$     5,000.00Year 15Head Injury$ 5,000.00Head Injury$     5,000.00Year 26Arm Rash$ 1Fatality*$ 175,000.00Year 37Back Injury/Cumulative Trauma$ 25,000.00Back Injury/Cumulative Trauma$   25,000.00Year 38Arm Rash$   5,000.00Arm Rash$     5,000.00Total  $ 45,004.00 $ 282,500.00*Death benefits are statutorily limited in certain states.  For California, death benefits are capped at $320,000. Only $175,000 is used in this sample calculation.                                                                         Table C:  Estimated Premium Costs Premium Based on Employee Count & PayrollExperience ModificationTotal 2025 Premiums(before credits) Employer I$ 264,500.000.85$ 224,825.00Employer II$ 264,500.001.51$ 399,395.00DISCLAIMER: Employers must consult with their WC Insurance brokers for a better understanding of their WC premiums and safety consultants for matters related to safety.  The contents of this newsletter are for informational purposes only and not to be considered as legal advice.   The premium numbers are for discussion purposes and actual numbers for X-Mod and premium calculations may vary on a case-by-case basis. The article was authored by Sam Celly of Celly Services, Inc. who has been helping automobile dealers comply with EPA & OSHA regulations since 1987.  Sam received his BE (1984) and MS (1986) in Chemical Engineering followed by a J.D. from Southwestern University School of Law (1997).  Our newsletters can be accessed at www.epaoshablog.com.  Your comments/questions are always welcome.  Please send them to sam@cellyservices.com.

To:          Environmental Health and Safety Coordinator From:     Sam Celly, BChE MChE JD CSP Ref:        Iceberg Effect: The Hidden Costs of Accidents Date:      June 4, 2025 Workplace accidents can be expensive for any corporation. Management often can brush away accidents and injuries by stating that it is just part of doing business. Some may look at accidents in terms of the dollar costs of treating injured employees, replacing injured employees, replacing broken machinery, etc. Accident-related expenses often go much deeper than what meets the eye. Hence the iceberg effect. The visible tip of an iceberg represents only a tiny fraction of its true impact, just like the immediate costs of an accident. Managers understand the acute impact of workplace injuries—medical bills, damaged equipment, and downtime—but the hidden costs lurking beneath the surface are even more devastating.   Accidents come with substantial costs that often go unnoticed until they start piling up. Here are some common ones. Loss in Productivity. When an accident happens, work slows down or stops entirely, resulting in delays and inefficiencies. For example, your only transmission mechanic breaks an arm and is gone temporarily for 6 weeks on disability. You must find a substitute. For calculation purposes, the tech was paid $40/hr. Your labor rate is $240/hour. The $200 differential at 40hrs/week is $8000 weekly. For six weeks of down time, you lost $48,000. Lost time is serious money! Employee Replacement Costs. If the employee is permanently disabled, you need to hire another mechanic. Lube techs may come easy; a master mechanic is likely more difficult to lure to your store. According to the 2023 NADA Dealership Workforce Study, average cost to recruit and onboard a hire is $5,000. Time to fill is another factor, impacting overall costs. According to DHI Group’s Hiring Indicators 2017 Report, retail industry had a time to fill average of 25 days. That’s 25 days of customers waiting for a specialist to repair their vehicle. Training Costs. Companies spend significant time and money training new hires to company standards and their way of conducting business. According to the NADA Study, the average training cost for dealership employees is $1200. These can spin upward to $10,000 per employee depending on their skill level and job according to CBTNews! Legal Fees & Fines. Companies may face lawsuits, regulatory fines, or settlements, which can be financially draining. OSHA fines and penalties are $16,500 per violation and $165,000 for willful violation. With nearly 40 years’ experience in workplace safety, I am confident that OSHA will find a code violation for serious accident, roping you into a regulatory morass of appeals, hearings and penalties. Trial lawyers are lurking in the waters too.  If they smell employer culpability that caused serious accident or harm, they will bypass the Workers Comp Judge under some novel theory and head to Superior Court. Equipment & Property Damage. Repairs and replacements for damaged tools, machinery, or infrastructure can be costly. Downtime for equipment can create backlog and loss of productivity. If a customer’s vehicle is damaged during the incident, associated cost may follow, such as providing a loaner until repairs are made. Increased Insurance Premiums. Insurance costs often rise after an accident, adding immediate and long-term financial strain to the dealer. Emotional & Psychological Impact. Accidents can lower morale, increase stress, and lead to long-term emotional effects on employees. Reputation Damage. A serious accident can hurt a company’s public image, making it harder to attract employees and even customers. Customers may demand buyback if a vehicle is damaged during an accident at the dealership. This is an excellent framework for understanding why proactive workplace safety measures are a financial necessity and not merely compliance. Preventative measures like rigorous safety training, regular equipment maintenance, and fostering a safety-conscious workplace culture can significantly reduce these risks. Companies that invest in safety upfront often find that their return on investment (ROI) outweighs the costs of handling accidents after they occur. DISCLAIMER: The contents of this newsletter are merely for informational purposes only and are not to be considered as legal advice.   Employers must consult their lawyer for legal matters and EPA/OSHA consultants for matters related to Environmental, Health & Safety. The article was authored by Sam Celly of Celly Services, Inc. who has been helping automobile dealers comply with EPA and OSHA regulations since 1987.  Sam received his BE (1984) and MS (1986) in Chemical Engineering, followed by a J.D. from Southwestern University School of Law (1997).  Our newsletters can be accessed at www.epaoshablog.com.  Your comments/questions are always welcome.  Please send them to sam@cellyservices.com.

New regulations require California Haz Waste generators to report critical waste related information to regulatory agencies including first responders.  The requirements are: Add Quick Reference Guide to annual CERS: CSI will complete on your behalf.Label hazards on hazardous waste containers: Your haz waste hauler will provide them.Provide 3 emergency response contacts: Complete attached doc. Email to us ASAP.

Introduction

The California Department of Toxic Substance Control (DTSC) has adopted the federal Generator Improvements Rule (GIR) to provide additional environmental protections and to gain swift access to critical facility information. Generally, the GIR applies to all businesses who generate hazardous waste, regardless of the waste quantity generated. GIR requires the submission of a Quick Reference Guide (QRG) that contains three emergency contacts, waste generated onsite, and facility maps with special requirements (Large Quantity Generators only).  See definitions on page 2.

California Environmental Reporting System (CERS) requires all businesses that handle hazardous materials in quantities equal to or greater than 55 gallons of liquids, 500 pounds of solids, or 200 cubic feet of gas at standard temperature and pressure or quantities of extremely hazardous substances above the threshold planning quantity to:

• Inventory their hazardous materials,
• Develop a site map,
• Develop an emergency plan,
• Implement a training program for employees, and
• Submit a CERS report annually.

The CERS annual report includes: Business owner/operator details, hazardous materials and waste inventory matrix, facility identification and operations overview, emergency communication phone number, notifications emergency containment, cleanup procedures, facility evaluation, and arrangement of emergency services, emergency equipment, earthquake vulnerability, employee training details and list of other attachments.  The attachments this year include the GIR.

GIR Hazardous Waste Labeling and Marking Requirement

Key GIR requirements for labeling and recordkeeping of hazardous waste tanks/containers are:

1. Generators must mark or label their tanks with an indication of the hazards of the contents.  Labels from DOT OR OSHA Haz-Com OR NFPA are acceptable.

Your waste hauler may provide warning labels for waste tanks.

Example of NFPA labels: Used Oil Placard:   Used Coolant Placard:

Some sources to buy NFPA labels: NFPA Used Oil Label Blank NFPA Diamond Label

• Generators must use inventory logs, monitoring equipment, or other records to demonstrate that hazardous waste has been emptied within the applicable time period of first entering the tank/container. Your waste haulers will provide labels highlighting dates of accumulation. Dealers must ensure hazardous waste is not stored past the applicable time period. Contact waste hauler if labels are missing or past the storage time limit.
• Generators must keep inventory logs or records on site and readily available for inspection. Pick-up receipts/manifests related to environmental matters must be kept in Black Box provided by Celly Services for ready access when the facility is inspected.

WHAT WE NEED FROM YOU RIGHT AWAY Names of three emergency coordinators and a 7-day/24-hour emergency telephone number. Please use the attached form to provide names and numbers for your dealership. Note on how to select emergency contacts for your facility. The contacts should: Have knowledge of the location and type of haz wastes and haz materials.Have managerial level decision making capability.Live relatively close by in order to respond to an after-hour emergency quickly.

Large Quantity Generator (LQG): “Generators of 1,000 kg or more of hazardous waste per calendar month (excluding universal wastes).” About a total of 300 gallons/month of used oil, used coolant etc. will place you above the 1,000 kg threshold. Small Quantity Generators generate less than 1,000 kg of hazardous waste/mo.

Ref: Frequently Asked Questions for the Adoption of Generator Improvements Rule (GIR) in California | Department of Toxic Substances Control

CERS Portal

DISCLAIMER: The contents of this newsletter are for informational purposes only and are not to be considered as legal advice. Employers must consult their lawyer for legal matters and EPA/OSHA consultants for matters related to Environmental, Health & Safety. The article was authored by Sam Celly of Celly Services, Inc. who has been helping automobile dealers in Arizona, California, Hawaii, Idaho, Nevada, New Mexico, New York, Texas, and Virginia comply with EPA and OSHA regulations for over 35 years. Sam is a Certified Safety Professional (No. 16515) certified by the National Board of Certified Safety Professionals. Sam received his BE (1984) and MS (1986) in Chemical Engineering, followed by a J.D. from Southwestern University School of Law (1997). Sam is a member of the American Chemical Society (No. 31176063), American Industrial Hygiene Association (No. 124715), and National Association of Dealer Counsel (NADC). Sam also serves on the Board of Orange County American Industrial Hygiene Association and on CA Industrial Hygiene Council (CIHC). Our newsletters can be accessed at www.epaoshablog.com. Your comments/questions are always welcome. Please send them to sam@cellyservices.com.

COMPLETE THE FORM BELOW AND EMAIL TO SUPPORT@CELLYSERVICES.COM Facility Name ______________________________________________________________________________   Street Address _____________________________________________________________________________   City, State, Zip _____________________________________________________________________________   NOTE 1: How to select emergency contacts for your facility.  The contacts should: Have knowledge of the location and type of haz waste and haz material.Have managerial level decision making capabilityLive relatively close by to respond to an after-hour emergency quickly NOTE 2: Following guidance in Note 1 above, preferably select your Service Manager, Parts Manager, and General Manager.  For bigger stores or multiple dealerships select your Director of Fixed Operations. Facility Emergency Contacts: Primary Emergency Coordinator: Name: _____________________________________________________ Title: _____________________________________________________ 24/7 Emergency Phone Number: _____________________________________________________ Email: _____________________________________________________ Secondary Emergency Coordinator and phone number: Name: _____________________________________________________ Title: _____________________________________________________ 24/7 Emergency Phone Number: _____________________________________________________ Email: _____________________________________________________ Tertiary Emergency Coordinator and phone number: Name: _____________________________________________________ Title: _____________________________________________________ 24/7 Emergency Phone Number: _____________________________________________________ Email: _____________________________________________________ Important: Facility contacts must be updated within 30 days when there is a change. Email your Celly Services representative with the updated Facility Contact list.

IN THIS NEWSLETTER WE DISCUSS: 1.      Top 10 OSHA Citations for Automobile Dealerships 2.      Common Injuries at Automobile Dealerships 3.      Increases in OSHA Penalties

TOP 10 OSHA CITATIONS FOR AUTO DEALERS (OCTOBER 2023 – SEPTEMBER 2024)

	Citation	Infraction
1	Hazard Communication	Employers are required to provide a written Hazard Communication Program, label hazardous chemicals, provide a Safety Data Sheet for each chemical, and document employee training.
2	Power industrial trucks	The high number of fatalities associated with forklifts and high number of violations associated with powered industrial trucks tell us that many workers are not properly trained to safely drive potentially hazardous equipment. OSHA compliance requires training in these specific activities: forklift operations, loading and unloading, and vehicle maintenance. Evaluating each operator every three years is also mandatory.
3	OSH Act General Duty	Each employer: shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees;shall comply with occupational safety and health standards promulgated under this Act.   Ref: OSHA’s General Duty Clause
4	Wiring methods, components, and equipment for general use	This regulation covers the general requirements for wiring methods, including the use of flexible cords and cables as permanent wiring. This also includes failure to remove nonconductive coatings from contact points (i.e. brake wash drums). These infractions can lead to serious electrical hazards, including electric shock, fire, and equipment damage. Ref: 29 CFR1910.305
5	Duty to have fall protection and falling object protection	Work-related fatalities due to slips, trips, and falls accounted for 865 fatalities in 2022. Any time a worker is at a height of 4 feet or more (in California the requirement is 30 inches or more), the worker is at risk and needs to be protected. Dealerships must protect employees working on 2nd floor of the parts department, especially while loading and unloading parts at the mezzanine edge.
6	Maintenance, safeguards, and operational features for exit routes	Auto dealers must ensure exit routes are free and unobstructed from materials at all times. All exit routes must be lighted and clearly marked with a sign reading “Exit.” Safeguards such as alarm systems, sprinkler systems, fire doors, and exit lights must be maintained and operational at all times.Ref: 29 CFR 1910.37
7	Respiratory Protection	Body shop employees need specific training both on written policies and on practices involving the use of respirators during auto refinishing operations. Training for respiratory protection, fit testing, user seal check, and respiratory cleaning procedures is mandatory, as is the OSHA Respirator Medical Evaluation Questionnaire. When an employee wears a respirator, information on proper usage, including limitations, must be provided even when it is not required under the regulation.
8	Abrasive wheel machinery	Moving machine parts have the potential to cause severe workplace injuries such as crushed fingers or hands, amputations, burns, or blindness. Safeguards, including anchoring machinery, are essential for protecting workers from these preventable injuries. Any machine part, function, or process that may cause injury must be safeguarded. When machine operation or accidental contact with the machine may injure the operator or others in the vicinity, hazards must be eliminated or controlled. Moving parts in automobiles, grinders, and brake lathes are all subject to this regulation.
9	Medical services and first aid	Auto dealers have inherent dangers associated with car repairs that can lead to negative health outcomes. Some minor, some major. This regulation requires employers to have adequate first aid kits for the worksite and access to medical facilities (clinic, hospitals, etc.) when warranted to reduce the negative health outcomes. Ref: 29 CFR 1910.151
10	Handling materials – general	Associated infractions for such citations include: obstructed aisles and passageways, insecure storage, poor housekeeping, lack of clearance signs, unprotected openings, and improper use of mechanical equipment. Ref: 29 CFR 1910.176

COMPLETE OSHA TRAINING ON THE WEB AT YOUR OWN PERIL OSHA has stated repeatedly and consistently in its training-related interpretation letters that online or computer-based training is acceptable as part of an overall training program that includes hands-on, site-specific information and work practices where it is needed to meet workplace safety goals.  Many online courses may not be legitimate. In many instances, the training company clearly states that the training does not meet any local, state, or federal standards. The awakening happens when OSHA audits the workplace and finds the employer lacking in hands-on, site-specific information and work practices.

COMMON INJURIES AT AUTOMOBILE DEALERSHIPS

• Burns: Hot engines, exhaust pipes, and welding equipment can cause burns. To prevent burns, you can provide heat-resistant gloves and clothing, require work boots, and be careful around hot surfaces. 
• Muscle sprains and strains: Working with heavy objects can overstretch or tear muscles and tendons. This can happen due to overuse, fatigue, or improper lifting technique. 
• Eye damage: Welding and grinding can expose mechanics to flying debris, sparks, and toxic chemicals. This can cause scratches, redness, irritation, and in severe cases, blindness.
• Falls: Falls from heights, slip and falls, and falls on uneven or slippery surfaces can occur.
• Getting caught in machinery: Hands or loose clothing can get caught in machinery.
• Repetitive motion injuries: Repetitive motion injuries can occur.
• Back injuries: Working at odd angles for long periods can lead to chronic back pain.
• Exposure to hazardous chemicals and materials: Solvents, asbestos, engine exhaust, welding fume, paint spray, cleaning products, and dust from sanding or abrasive blasting can be hazardous. 

OSHA PENALTIES*

Type of Violation	Penalty
Other-Than-Serious	$16,550 per violation
Serious	$16,550 violation
Failure to Abate	$16,550 per day beyond abatement date
Posting Requirements	$16,550 per violation
Willful or Repeated	$165,514 per violation

*Note: The penalties are automatically adjusted for inflation on an annual basis and based on the number of employees. Table above reflects penalty amounts as of 1/7/2025

Ref: Frequently Cited OSHA Standards NAICS Code 441DISCLAIMER: The contents of this newsletter are for informational purposes only and are not to be considered legal advice. Employers must consult their lawyer for legal matters and EPA/OSHA consultants for matters related to Environmental, Health & Safety. The article was authored by Sam Celly of Celly Services, Inc. who has been helping automobile dealers in Arizona, California, Hawaii, Idaho, Nevada, New Mexico, New York, Texas, and Virginia comply with EPA and OSHA regulations for over 35 years. Sam is a Certified Safety Professional (No. 16515) certified by the National Board of Certified Safety Professionals. Sam received his BE (1984) and MS (1986) in Chemical Engineering, followed by a J.D. from Southwestern University School of Law (1997). Sam is a member of the American Chemical Society (No. 31176063), American Industrial Hygiene Association (No. 124715), and National Association of Dealer Counsel (NADC). Sam also serves on the Board of Orange County American Industrial Hygiene Association and on CA Industrial Hygiene Council (CIHC). Our newsletters can be accessed at www.epaoshablog.com. We welcome your comments/questions. Please send them to sam@cellyservices.com

Effective January 1, 2022, the hazardous waste generation and handling (GH) fee is imposed as a flat rate per ton or fraction of a ton on generators of hazardous waste for each generator site that generates five or more tons of hazardous waste at a site in California within a calendar year. 

What Changed: Before January 1, 2022, this was called Generator Fee. New legislation, Senate Bill 158, was written to simplify the fee structure and rename the fee to Hazardous Waste Generator & Handling fee. In the new fee structure, used oil that was earlier exempt from the fee was now subject to fee. With the omission of the line that took out exemption for used oil from fee structure, almost every auto dealer in the state of California became subject to the fee. Other wastes listed below were already subject to the fee and continue to do so.  Some dealers who were below the threshold of 5 tons (10,000 lbs) or roughly 1350 gallons of waste are now subject to the fee.

Hazardous wastes typically generated at an automobile dealership and subject to this fee are:

·   Recycled hazardous waste ·   Non-manifested universal waste ·   Waste sent outside California for disposal ·   Used motor oil (Except used oil collected from the public. See note below)

·  Waste coolant (CA code 134), ·  Oily water (CA Code 223), and ·   Waste paper filters (CA code 352 or 223) ·  Waste brake fluid ·   Contaminated fuel

If you are punching or crushing metal oil filters, under the Department of Toxic Substances Control (DTSC) guidelines you can dispose of them as scrap metal (through your hazardous waste hauler) and hence not be subject to this fee. If you decide to dispose of used metal oil filters as hazardous waste, those metal filters get added to your hazardous waste tonnage calculations. 

Don’t have a GH account?

The following should be completed to obtain a GH account number:

1. Log into your CDTFA account and select “Register a New Business Activity.”
2. Check off the box that says “. . . generates 5 or more tons of hazardous waste in a calendar year.”
3. Answer all the other required questions as prompted. You will need your EPA ID number and start date of waste generation (place January 1, 2021 if you have generated waste for longer than 3 years).
4. If you have any questions regarding the registration, please contact reps at CDTFA as follows: Thomas, Cathie Cathie.Thomas@cdtfa.ca.gov, Kevin McCarley Kevin.McCarley@cdtfa.ca.gov,
   Yatoba Godina Yatoba.Godina@cdtfa.ca.gov or 800-400-7115.

GH FEES & FEE RETURNS: HOW CALCULATED & WHEN DUE

The GH fee is calculated based on the total weight (measured in tons) of hazardous waste generated (produced or caused to be managed) from each site each calendar year. It is generally due regardless of the waste’s final disposition. Every generator that produces five tons or more of hazardous waste will pay the California Department of Toxic Substances Control (CDTFA) a GH Fee for each generator site for each calendar year, or portion thereof. Generators are required to report the amount of waste generated on a hazardous waste Generation and Handling Fee Return provided by CDTFA. Keep proper records to support tonnage of hazardous waste generated and handled at each site/location.

Don’t know your tonnage?

Please contact your dedicated waste hauler(s) to determine total tonnage. Once determined, please register online with CDTFA and complete the fee process. You are required to file your GH Fee Return electronically through the CDTFA online services. Maintain support documentation of fee completion for your records. Finally, we note that this is a tax/fee matter and you must consult your tax consultant on calculations and record retention requirements.

GH fee payments and GH fee returns are both due by February 28 each year. The fee is calculated based on waste generated in the prior calendar year. (HSC 25205.5).  All GH fees are due according to the schedule in the table below, along with the GH Fee rates in 2024-25 for hazardous waste generated in Calendar Year 2023.

Note 1: Beginning with FY 2024-25, the Board shall adjust the GH Fee for changes to the Consumer Price Index (CPI).

Note 2: Please contact your waste hauler(s) for technical guidance on conversion of gallons of waste to tons.
For example, 1 gallon of used oil is approximately 7.4 pounds. 10,000 gallons is 74,000 pounds. 2,000 pounds equals one ton.

74,000/2,000 = 37 tons.  In summary, 10,000 gallons of used motor oil weighs approximately 37 tons!
Note 3: GH Fees do not apply to used oil collected from the public by certified used oil collection centers.

Return Reporting Period	Report Based on Hazardous Waste Generated in Prior Reporting Period	Prepayment Due Date	Return & Final Payment Due Date
Fiscal Year 2024 – 2025 (July 1, 2024 – June 30, 2025)	Calendar Year 2023	November 30, 2024	February 28, 2025
Fiscal Year 2025 – 2026 (July 1, 2025 – June 30, 2026)	Calendar Year 2024	November 30, 2025	February 28, 2026
Fiscal Year 2026 – 2027 (July 1, 2026 – June 30, 2027)	Calendar Year 2025	November 30, 2026	February 28, 2027

Helpful Resources Online
California Department of Toxic Substances Control
CDTFA’s Hazardous Substances (Waste) Fee Guide
DTSC’s Manifest webpage
DTSC Fee Summary webpage
Law on Generation and Handling (GH) fee. Senate Bill 158; Stats. 2021, ch.73.
State of California December 2021 Notice. Hazardous Waste Generation and Handling Fee – Application of Fee, Payments, and New Rate Effective January 1, 2022
State of California August 2022 Special Notice on Filing requirements. L-863, Hazardous Waste Generation and Handling Fee Program Reminders and Online Filing Requirement).
State of California Guidance on the SB158 GH Fees. DTSC Generator Fee site.

DISCLAIMER: The contents of this newsletter are for informational purposes only and are not to be considered legal advice. Employers must consult their lawyer for legal matters and EPA/OSHA consultants for matters related to Environmental, Health & Safety. The article was authored by Sam Celly of Celly Services, Inc. who has been helping automobile dealers in Arizona, California, Hawaii, Idaho, Nevada, New Mexico, New York, Texas, and Virginia comply with EPA and OSHA regulations for over 35 years. Sam is a Certified Safety Professional (No. 16515) certified by the National Board of Certified Safety Professionals. Sam received his BE (1984) and MS (1986) in Chemical Engineering, followed by a J.D. from Southwestern University School of Law (1997). Sam is a member of the American Chemical Society (No. 31176063), American Industrial Hygiene Association (No. 124715), and National Association of Dealer Counsel (NADC). Sam also serves on the Board of Orange County American Industrial Hygiene Association and on CA Industrial Hygiene Council (CIHC). Our newsletters can be accessed at www.epaoshablog.com. We welcome your comments/questions. Please send them to sam@cellyservices.com.