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.
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.
Investigate Accidents: Save Money & Fight Fraud
A prompt, accurate and thoughtful accident investigation can, simply stated, save money and fight fraud. First, it is state law that mandates that an employer investigate each accident and take corrective measures to prevent repetition of accidents. Secondly, a written investigation report can be reviewed by senior management or the safety committee to undertake steps that would prevent such accidents in the future. Last and not the least, such reports can be useful ammo in fighting the 3F–Fictitious, Fraudulent or Frivolous claims. In summary, as an employer, it is your duty to provide a safe workplace and also to ensure that any worker’s compensation claim is legitimate and preventable in the future.
Civil & Criminal Penalties Increased for OSHA Violations
On October 5, 1999, Governor Davis signed into law a bill which increases the civil and criminal penalties for willful, serious and repeat violations of occupational safety and health (Cal-OSHA) standards. The law goes into effect on January 1, 2000, which gives the district attorneys more flexibility to prosecute as either a misdemeanor or a felony, willful violations of safety standards which result in a death or permanent/prolonged impairment.