The black box is made available to you to retain EPA and OSHA related paperwork so that is readily available in the event of a regulatory agency audit. Since the inspector arrives with no notice, having EPA/OSHA related records readily accessible can make the audit go smoothly and quickly. Additional benefits keeping the paperwork organized and handy are:

• Tangible evidence of the organization being committed to EHS. Inspectors are usually accommodating for facilities with immaculate recordkeeping.
• Faster audits when CSI consultants visit to audit your EHS compliance.
• Ease in calculating and paying taxes on hazardous waste generated.
• Calculate reimbursement for used oil from haulers (if any).
• Calculate and file used oil claim (only state of CA).
• Dealerships have turnover. Box provides incoming manager with records.

EPA DOCUMENTATION (Yellow folders)

EPA requires hazardous waste disposal paperwork to be maintained for all hazardous wastes. These should be filed in the yellow folders as marked. Yellow folders have instructions related to the specific disposal paperwork requirements for each of the following streams:

• Used Oil
• Used Oil Filters
• Used Antifreeze
• Cleaning Solvents (parts washer)
• Used Batteries
• Clarifier Sludge
• Used Tires
• Universal Wastes

Other environmental related paperwork is as follows:

• Storage Tanks
• Fees and Permits
• Air Pollution
• Hazardous Waste Management & Manifest Procedures
• DOT Shipping & Receiving (Certificates)
• California Environmental Reporting System

NOTE: All hazardous waste disposal documents must be retained in files for 3 years. Certain wastes need a Uniform Hazardous Waste Manifest for disposal. You must follow proper procedures for completion of manifests. The Business Office maintains the paperwork only from an accounts payable standpoint–dollars to pay or dollars to receive.

Accurate and complete disposal paperwork is to be maintained by the Service Manager or his/her designee, and ensure:

• All wastes are being disposed of via authorized haulers; and
• Paperwork as required by the EPA is being maintained.

Tank File Must Retain:

1. Tank Inspection Logs for the last three years.
2. Spill Prevention Containment & Countermeasures Plan (SPCC).
3. Waste tank assessments from a Professional Engineer.

Note: SPCC and tank assessment reports must be renewed every 5 years.

Examples of Fees & Permits File Retained in file are:

1. Air compressors
2. Hoists (City of LA only)
3. Elevators (Human & freight)
4. Tire Program ID (TPID) number
5. EPA ID number
6. Environmental Verification Questionnaire (EVQ)

Note: EPA ID number and the TPID number should be posted on the notice board.

CERS File:  Copy of annual submission of CERS.

OSHA DOCUMENTATION (Red folders)

OSHA requires each facility to maintain documentation of all compliance activities. Organize and Retain documents in the following folders for ease of retrieval.

• Safety Inspections
• Safety Committee Meeting Minutes
• Employee Safety Training Records
• Accident Investigation
• Safety Counseling
• Miscellaneous
• Safety Topics (monthly)
• Safety Data Sheets (SDS)
• Newsletters
• Hazard Assessments

Note:  Safety Inspections and SDS for the facility may be retained on the web portal. Accident investigation and safety counseling documents for the facility/corporation may be retained by HR.

“Miscellaneous” is the mother of all folders. If you get something in the mail or email and need to discuss with CSI rep, save it for the next visit. If the matter cannot wait, email a copy to your rep. SDS for newly added chemicals can be saved in the file or emailed to Celly Services, Inc. for posting on the portal.

QUESTIONS:  If you need to have any questions regarding the Black Box or any other EHS matters, contact sam@cellyervices.com for guidance.

Black Box: In science, computing, and engineering, a black box is a device, system, or object which produces useful information without revealing any information about its internal workings.

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. Our newsletters can be accessed at www.epaoshablog.com. Your comments/questions are always welcome. Please send them to sam@cellyservices.com.