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.

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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.

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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. 

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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.

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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.

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California Tow Drop-Off Regulations, July 2016

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.

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Heat Illness Prevention Program Training, May 2016

BackgroundCal/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.

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