What’s In Your Dumpster? Make Sure It’s NOT Hazardous or Universal Waste, March 2018

ENFORCEMENT OF HAZARDOUS WASTE DISPOSAL REGULATIONS:  Reportedly, local inspectors (Environmental Compliance Officers) have gone into dumpsters at auto service facilities to determine the occurrence of illegal waste disposal. They have cited heavy fines for violations when hazardous waste and universal waste are found in the dumpster.  Alameda and Santa Clara counties sued an auto dealership chain and recently obtained a settlement of $3.38 million. See link.

Continue reading

Top 10 OSHA Citations of 2017, December 2017

The Department of Labor’s Occupational Safety and Health Administration has released a list of the 10 most frequently cited safety and health violations for the fiscal year of 2017; compiled from thousands of inspections of workplaces by federal OSHA staff. One remarkable thing about the list is that it rarely changes. Year after year, thousands of the same on-the-job hazards are cited, any one of which could result in a fatality or severe injury.

Continue reading

California Requires Auto Dealers to Keep Log 300 Similar to Federal Requirements, December 2017

LOG 300, 300A & 301 REQUIRED FOR AUTO DEALERS

Background:  Cal/OSHA and Fed-OSHA now requires auto dealers and other employers to keep a record of occupational injuries and illnesses using OSHA Log 300 and post summary on employee notice board from February 1 to April 30, 2018.

Continue reading

News & Views, July 2017

HFO-1234yf REFRIGERANT IS A FLAMMABLE GAS

Automobiles have been using refrigerant gases in their AC systems for decades.  The refrigerant gases have generally been inert gases, such as Freon-12 and R-134.  Recently, many auto manufacturers have started to use HFO-1234yf as the refrigerant gas in their AC systems.  This gas is expensive, about $80/lb., and the recycling machine costs another $5000.  The bigger issue is that it is a flammable gas.  Flammable gases pose special hazards and dealers should take steps to address this concern.

Continue reading

Old Rules Relaxed & New Rules Added (CALIFORNIA ONLY), January 2017

TO MIX OR NOT TO MIX – OLD RULE

SEPARATION OF PAPER & METAL:  In 2016, California EPA started to enforce hazardous waste regulations regarding used oil filters.  While crushed metal oil filters could be recycled as scrap metal, paper cartridge filters and metal oil filters (with free flowing used oil upon puncture) were to be disposed of as hazardous waste.  Dealers started to separate the two types of oil filters and dispose of them as two different streams.

Continue reading

Top 10 OSHA Citations of 2016, October 2016

Every October, the Department of Labor’s Occupational Safety and Health Administration releases a preliminary list of the 10 most frequently cited safety and health violations for the fiscal year, compiled from nearly 32,000 inspections of workplaces by federal OSHA staff.  One remarkable thing about the list is that it rarely changes. Year after year, thousands of the same on-the-job hazards are cited, any one of which could result in a fatality or severe injury.

Continue reading

Injury Log Requirements & Accident Reporting to Fed-OSHA, September 2016

LOG 300, 300A & 301 REQUIRED FOR AUTO DEALERS

Background: Cal/OSHA now requires auto dealers and other employers to keep a record of occupational injuries and illnesses using OSHA Log 300. We note that Fed-OSHA had issued these requirements to auto dealers in 2015.

Continue reading

Used Oil Filters – The Other Shoe Drops (CA ONLY), August 2016

BACKGROUND:  Used oil filters may exhibit hazardous characteristics and are hence, classified as hazardous waste in California. To encourage recycling of used oil filters, California DTSC adopted reduced handling requirements for drained used oil filters that are sent for recycling as scrap metal. We wrote about that in July 2016 stating that you should drain the filter properly.  Now the DTSC (Cal/EPA) has started to classify all used oil filters, with a flapper valve that prevents oil from being drained out, as hazardous waste. 

Continue reading

Brouhaha Over Paper or Metal – Management of Used Oil & Fuel Filters (CA ONLY), July 2016

BACKGROUND:  Used Oil Filters may exhibit hazardous characteristics and hence are classified as hazardous waste in California. To encourage recycling of used oil filters, California DTSC adopted reduced handling requirements for drained used oil filters that are sent for recycling as scrap metal. Used oil filters must not be disposed in trash cans or at nonhazardous waste landfills.  Legislation was enacted in 2004 (AB 2254, Aghazarian) that allowed spent fuel filters from automobiles be added to spent oil filters for disposal.

Continue reading

July 1, 2018 Deadline to Upgrade Booth (For Some) & July 1, 2019 Deadline for All, July 2016

South Coast Air Quality Management District (SCAQMD) is the regulating agency for air quality in the LA basin and has implemented emission limits on NOx that require paint booth burner upgrades.  We last wrote to you in 2014 regarding these rules that apply to body shops concerning booth maintenance and documentation of NOx emissions limits for equipment burning natural gas, such as dryers, ovens, and afterburners, located at your collision center paint booth.  The deadline for compliance was July 1, 2014 to upgrade your booth.

Continue reading