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.
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.
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.
CALIFORNIA LAW ON TOWING
California enacted AB 1222 earlier this year mandating certain recordkeeping provisions for tow truck companies amongst other statutory requirements. If the dealer is in the towing business, then we recommend that you consult and implement all provisions of AB 1222 (Bloom). Since dealers with tow truck ownership are very few, we will not discuss in detail the tow truck company operational issues and recordkeeping requirements, but rather the dealer obligations under the new law as they receive automobiles from independent tow truck companies.
Background: Cal/OSHA heat illness prevention regulation (T8CCR3395) became effective on May 1, 2015. This standard applies to outdoor areas of employment. When porters are parking cars and salespersons are showing automobiles on display to customers or taking them on test drives, they are considered to be working outdoors. Fed-OSHA also requires that employees be trained in heat illness prevention under a general injury prevention standard. Cal/OSHA enforcement details are at http://www.dir.ca.gov/dosh/heatillnessqa.html.
CALIFORNIA LAW ON LOG 300
As of the start of 2016, the California Occupation Health & Safety Standards Board has not approved of the changes to the recordkeeping guidelines. This process can take up to six months, essentially pushing the compliance date to January 1, 2017.
In summary, auto dealers in California are currently exempt from Log 300 requirements. See https://www.dir.ca.gov/dosh/DoshReg/FinalEmpRec.html. Cal/OSHA has inspected dealers for regulatory violations and has not requested to see the Log 300 as they are exempt per state regulations.
Accident 1: On the afternoon of February 22, 2016, a test drive of a Corvette from a dealership in Ontario, CA became a tragedy. Reportedly, the driver was driving at 70 MPH before the crash took place, which resulted in the salesperson losing his life. LA Times reported that the customer was treated for injuries at a local hospital and arrested on suspicion of vehicular manslaughter and driving under the influence of drugs.
Solution 1: While it may be difficult to recognize a customer being under the influence of drugs, salespersons should remain attentive to inebriated customers and decline any test drive in which drugs or alcohol may become a factor. Also, the dealership must constantly reiterate: “All test drives must be safe and within posted speed limits.”