SCAQMD RULE: ANNUAL REPORTING OF GASOLINE USAGE (AST AND UST)
All dealerships with aboveground storage tanks (AST) and/or underground storage tanks (UST) must report monthly throughput data for each month of 2015 to the SCAMQD by fax to (909) 396-3761. Deadline for reporting is March 1, 2016. Click here for the form.
CAL-EPA REGULATIONS EFFECTIVE 1/1/16
90-Day Storage Limit: Automobile dealerships generating more than 1,000 kg of hazardous waste per month must dispose of hazardous waste within 90 days (otherwise the facility must obtain a storage permit, an arduous process). Almost all dealerships generate more than 1,000 kg (about 300 gallons) of used oil and used coolant per month and hence, must limit storage to 90 days. In the past, local enforcement agencies excluded used oil from these calculations so all dealers fell below the 1,000 kg/mo. level. The new law, SB 612, clarifies the fact that all hazardous waste generated at the facility are counted towards the 1,000 kg/mo. calculation. For facilities generating less than 1,000 kg/mo. of hazardous waste (Federal Term: Small Quantity Generator), the maximum accumulation time is 180 days or 270 days if the waste must be transported more than 200 miles for treatment and disposal.
In summary, each hazardous waste storage container must have a proper date of accumulation marked on each container along with EPA required waste labeling and secondary containment requirements. The waste must be disposed of within 90 days of the start date. Almost all facilities have used oil pickup on a 30-day or more frequent cycle. However, other smaller waste streams, such as used coolant or contaminated fuel, are not on the radar screen. Dealers must ensure that these wastes are now on a 90-day pickup cycle through a licensed and registered hazardous waste hauler. Contact your hauler to set up a required pickup schedule immediately.
BACKGROUND: Safety inspections of the shop, parts, and car wash area have revealed that many employees are not wearing appropriate footwear that will protect them from foot injuries caused by crushing or falling objects, such as a rotor or a battery. Penetrating actions may happen from a sharp object left on the shop floor. Also, footwear in the shop area must be slip resistant when employees are working on slippery surfaces, since slip hazards are common due to accidental spills of lubricants in the shop. The porters in car wash are also subject to slip and fall hazards created by water and/or soap on the floor, and as such, their shoes must provide traction.
Introduction: Workers’ Compensation (WC) insurance costs to the dealership are increasing more than other costs and much faster than inflation. In this newsletter, we explain:
- How WC Insurance Premium is calculated based on payroll
- How manual premium rates are based on risks of the worker, e.g., the office worker has a lower manual rate compared to an auto service technician due to hazards on the job
- How employers with greater injury rates have a higher Experience Modifier (ex-mod)
- How a higher ex-mod results in higher premiums
- How WC rates have climbed over the years
- How Medical Indemnity has more than doubled over 15 years
- How Allocated Loss Adjustment Expense (ALAE) per Indemnity Claim has tripled over 15 years
Background: California has regulations on virtually everything, including what to look for when you are fixing the AC in a car. The AC regulations have been around since 2003 with relative low compliance. Last year, California Bureau of Automotive Repair (BAR) issued six-figure fines and ordered temporary suspensions of BAR license for failure to comply with California regulations, indicating that this is serious business. The awareness in the California dealer community on this issue is lacking so we have taken this step to inform dealers of this regulation and possible compliance steps.
Accident investigation should be the cornerstone of any safety program. Many safety programs concentrate on safety inspections and training, but omit accident investigation. Investigating accidents is not only a good idea, but also a requirement. Below, we provide some guidance and tools to complete an accident investigation.
RECORDABLE: Federal-OSHA requires auto dealers to keep a record of occupational injuries and illnesses using Log of Work-Related Injuries & Illnesses (OSHA Form 300). We discussed this in great detail in our October 2014 Newsletter. We note that first-aid is not recordable on OSHA Log 300. The federal legal definition of first-aid is as follows: