Full text of "Massachusetts CRASH course project manual : (collision repair auto shop help) [workbook]"

See other formats

Project Man

b"ijijji-i

r1-

312Dbb DE7D 13fl2 1

ollision Repair Auto S

ijujj IJyJjj)

GOVERNMFNT
COL

DOCUMEAI

i g

University of Massachusetts
Depository C,py

Executive Office of
Environmental Affairs

♦ Office of Technical Assistance
for Toxics Use Reduction

SEPA

Massachusetts

Office of the Attorney General
Department of Labor and
Workforce Development
Division of Occupational Safety

ACKNOWLEDGMENTS

This Collision Repair Auto Shop Help (CRASH) Course manual was jointly sponsored and created
by the Massachusetts Office of Technical Assistance for Toxics Use Reduction (OTA), the
Massachusetts Department of Environmental Protection (DEP), the Massachusetts Office of the
Attorney General (AG), EPA Region 1 New England (EPA), and the Massachusetts Auto Body
Association (MABA) - with significant help and input from other organizations listed below. In addition,
numerous representatives of the auto body collision repair industry and other organizations have
contributed significantly to this project. Management of the project has been provided by Rick
Reibstein and George Frantz of OTA with the support of Barbara Kelley, Director of OTA, and EPA
project officer, Mary Dever. Other individuals who have contributed to the project by attending
project meetings, clarifying regulatory requirements, providing input to the manual, supporting
communication, and/or reviewing text include the following:

OTA - Stephen George and Susan Leite

DEP - Paul Reilly, Salvador Resurreccion, Nancy Wrenn, and Kim Kreiton (formerly of DEP)

AG - Mary Griffin, Margaret Van Deusen, and Ann Berwick (formerly of the AG)

EPA - Tom Jouvantis, Anne Leiby, Molly Magoon, Tom Olivier, and Fred Weeks

Massachusetts Department of Labor and Workforce Development, Division of Occupational Safety
- Nancy Comeau

U.S. Occupational Safety and Health Administration - Fred Malaby

MABA - Evangelos "Lucky" Papageorg

Massachusetts Division of Standards (DOS) - Steve Berard

Northeast Waste Management Officials' Association (NEWMOA) - Susan Green and Andy Bray

Boston Police Department - Steve Vermette

Boston Public Health Commission - Jack Tracy

This manual would not have been possible without the help of the partner organizations and the
dedication and care of participating individuals. This manual and its contents are public information.
Attribution to this source is appreciated. For copies of this manual, call OTA at (617) 727-3260.
Phone numbers for other participating organizations and additional resources are provided in Section
3 of this manual's Toolbox (Resources, Forms, and Other Tools) . CRASH Course project funding was
provided through grant No. 20000162 from EPA. This manual was prepared by Tetra Tech EM Inc.,
under the direction of OTA. The Bowdoin Street Health Center is supporting OTA in evaluating
project results.

This manual is printed on recycled paper stock (20% post consumer) using soy-based inks and
alcohol-free fountain solution.

Collision Repair Auto Shop Welp

ACRONYMS

This section defines acronyms (abbreviations) that are used in the rest of this manual.

ABC

AST

BEST

BMP

CEA

CFC-12

CFR

CMR

CRASH

DEP

DOR

DOS

EHS

EPA

EPCRA

HAP

HEPA

HSO

HVAC

HVLP

ISD

Fire Extinguisher Rating for A, B, and C Class Fires

Massachusetts Office of the Attorney General

Aboveground Storage Tank

Boston Environmental Strike Team

Best Management Practice

Code Enforcement Agency

Chlorofluorocarbon-12 (also known as Freon™)

Code of Federal Regulations

Code of Massachusetts Regulations

Collision Repair Auto Shop Help

Decibel

Massachusetts Department of Environmental Protection

Massachusetts Department of Revenue

Massachusetts Division of Standards

Environmental, Health, and Safety

U.S. Environmental Protection Agency

Emergency Planning and Community Right-to-Know Act

Hazardous Air Pollutant

High Efficiency Particulate Air

Health and Safety Officer

Heating, Ventilation, and Air Conditioning

High Volume Low Pressure

Inspectional Services Division

Collision Repair huto Shop Welp

lbs/gal. Pounds Per Gallon

LVLP Low Volume Low Pressure

LQG Large Quantity Generator

MABA Massachusetts Auto Body Association

MOBD Massachusetts Office of Business Development

MSDS Material Safety Data Sheet

MVAC Motor Vehicle Air Conditioning

NEEAT New England Environmental Assistance Team

NEWMOA Northeast Waste Management Officials' Association

NFPA National Fire Protection Association

OSHA U.S. Occupational Safety and Health Administration [or Act]

OTA Massachusetts Office of Technical Assistance for Toxics Use Reduction

POTW Publicly Owned Treatment Works

PPE Personal Protective Equipment

psi Pounds Per Square Inch

P2 Pollution Prevention

SQG Small Quantity Generator

TCLP Toxicity Characteristic Leaching Procedure

UST Underground Storage Tank

VOC Volatile Organic Compound

VSQG Very Small Quantity Generator

Table Of Contents

ACKNOWLEDGMENTS i

ACRONYM LIST Mi

PART 1: WORKBOOK - The Workbook describes regulations, good operating
practices, and compliance tips for the auto body repair shops. You should work
through this part of the manual to evaluate, document, and improve your
compliance with basic environmental, health and safety (EHS) requirements and
implement pollution prevention tips.

SECTION 1: INTRODUCTION 1-1

1.1 Why is this CRASH Course Important? 1-1

1.2 CRASH Course Background and Organization 1-2

1.2.1 CRASH Course Background 1-2

A. Sponsoring Organizations

B. Additional Resources

1.2.2 CRASH Course Manual Organization 1-3

SECTION 2: REGULATORY AND POLLUTION PREVENTION OVERVIEW 2-1

2.1 Regulatory Overview 2-1

2.1 .1 Commercial Permit, License, and Registration Requirements 2-1

A. Occupancy Permit

B. Flammable Storage

C. Towing Services

D. Vehicle Storage

2.1 .1 Enviromental Requirements 2-4

A. Air Requirements

Air Permits and Source Registration Requirements - VOCs

Spray Enclosure (Spray Booth or Spray Room) and Stack Height Requirements

Coating and Equipment Requirements -- VOCs

Motor Vehicle Air Conditioning Requirement - CFCs

B. Water Requirements
Wastewater Discharges to a City Sewer Line
Vehicle Washing Concerns

C. Hazardous Waste Requirements

Collision Repair Auto Shop Welp

TABLE OF CONTENTS

2.1.3 Health Protection and Fire Prevention Requirements 2-16

2.2 Pollution Prevention Overview 2-17

SECTION 3: SELF-ASSESSMENT CHECKLIST 3-1

3.1 Permits, Licenses and Registrations 3-3

3.2 Air Requirements 3-4

3.3 Water Requirements 3-6

3.4 Hazardous Waste Requirements 3-7

3.5 Health Protection and Fire Prevention Requirements 3-12

PART 2 TOOLBOX: The Toolbox is designed to provide you with additional
resources that you can use to comply with regulatory requirements and implement
best management practices now and in the future.

SECTION 1 : AUTO BODY REPAIR ACTIVITIES 1 -1

1.1 Vehicle Washing 1-3

1.2 Frame Work and Structural Work 1-7

1.3 Cutting and Welding 1-11

1.4 Vehicle Dismantling 1-15

1.5 Grinding, Sanding, Filling 1-19

1.6 Spray Painting 1-23

SECTION 2: HEALTH PROTECTION AND FIRE PREVENTION TOOLS 2-1

2. 1 Health Protection Requirements 2-1

2.1.1 Hazard Communication Program 2-1

2.1.2 Personal Protective Equipment 2-5

A. Hazard Assessment

B. Training

2.1.3 Respiratory Protection Program 2-9

A. Written Respiratory Protection Program

B. Qualitative Fit Tests and Fit Checks

2.1.4 Hearing Protection Program 2-11

2.1.5 Eye and Skin Protection 2-12

2.2 Fire Prevention Requirements 2-13

Collision Repair Auto Shop Welp

2.2.1 Spray Painting Areas 2-13

2.2.2 Flammable Storage 2-13

2.2.3 Construction of Paint Storage and Mixing Rooms 2-13

2.2.4 Equipment and Electrical Requirements 2-13

2.2.5 Other Fire Prevention Requirements 2-14

2.2.6 Fire Prevention, Emergency and Contingency Planning Requirements
2-14

SECTION 3: RESOURCES, FORMS, AND OTHER TOOLS 3-1

3.1 Hotlines 3-1

3.2 Permit, License, and Registration Contacts 3-2

A. Local Town or City Hall

B. State Agencies

3.3 Crash Course Manual Sponsor Contacts 3-5

3.4 Other Resources 3-7

A. National Resources

B. Regional and Local Resources

3.5 Vendor Contacts 3-8

3.5.1 Coating Material Vendors 3-8

3.5.2 Painting Spray Gun Vendors 3-9

3.5.3 Spray Gun Washer Vendors 3-10

3.6 Forms, Labels, and Examples 3-11

SECTION 4: FINANCIAL TOOLS AND POSITIVE POLICIES 4-1

4.1 Financial Assistance for Small Businesses 4-1

4.1.1 Financial Analysis for Environmental Projects 4-1

A. Compliance Projects

B. Pollution Prevention Projects

4.1.2 Financial Strategies for Environmental Projects 4-3

4. 2 EPA and DEP Small Business Compliance Incentives Policies 4-4

4.2.1 EPA Small Business Compliance Incentives Policy 4-5

4.2.2 DEP Small Business Compliance Incentives Policy 4-6

4.3 DEP Environmental Audit Policy 4-8

SECTION 5: GLOSSARY TOOL 5-1

TABLE OF CONTENTS

Massachusetts Crash* Course

Project Manual

"(Collision Repair Auto Shop Help)

■v-

»■■■■■
»

Introduction

iiiiiiiiimnn

The Collision Repair Auto Shop Help {CRASH) Course was developed for auto body shops like
yours. It was designed to help you:

O understand and achieve compliance with environmental, health and safety (EHS)
requirements; and

Z> learn about and implement pollution prevention and other best management practices.

The project includes this manual and a series of free workshops that will be available to shops like
yours in the fall of 1998. This manual also provides resources that you can contact to get answers
to your questions.

EHS requirements are designed to help protect our land, water, and air quality,
as well as the health and safety of everyone in and around your shop. By
complying with these requirements, you can help protect your shop from severe
penalties, other legal liabilities, and lost labor hours associated with worker injuries.
If you take the additional steps to prevent pollution and operate your shop
according to best management practices (as described in this manual), you

can help reduce your operating costs by cutting down on the use of hazardous materials and the

generation of waste.

1.1 WHY IS THIS CRASH COURSE IMPORTANT?

Enforcement agencies want to see that you are taking steps to avoid EHS problems. They helped
develop this CRASH Course to assist your shop in (1) complying with EHS requirements, (2)
implementing pollution prevention efforts, and (3) documenting your efforts. If an inspector identifies
an area of non-compliance at your shop, you may qualify for a waiver or a reduction of penalties
under the Massachusetts Small Business Compliance Incentive Policy or Small Business Audit
Policy (see Sections 4.2 and 4.3 of the Toolbox, respectively) . To qualify you must clearly demonstrate
the steps that you have taken to comply with the law and prevent pollution. This is commonly
referred to as showing a good faith effort to comply with legal requirements.

Part of demonstrating a "good faith effort" is keeping up to date with, and implementing, program
requirements and recommendations. The simplest way to do this is to make photocopies of the
Self-Assessment Checklist in Section 3 of this Workbook (that is, blank copies - before you complete
the checklist for the first time) and complete the checklist every quarter (four times per year). Keep
the completed checklists in a separate EHS file, together with all of your permits, hazardous waste
manifests, Material Safety Data Sheets (MSDS), health and safety training records, pollution
prevention documentation, and other EHS records.

!
it

i
!

Collision Repair Auto Shop Welp

WORKBOOK

The CRASH Course is important because several enforcement agencies have worked together to
identify and review EHS requirements for auto body shops. This manual represents their agreement
regarding what you can do to reduce your potential liabilities. It is the first time that this information
(1) has been pulled together for you in an easy-to-use format and (2) has included the support of all
the enforcement agencies.

To get more information about the material in this manual, a good starting point is the Massachusetts
Office of Technical Assistance for Toxics Use Reduction (OTA). You can reach OTA at (61 7) 727-3260.
More information about OTA is provided in section 1 .2.

1.2 CRASH COURSE BACKGROUND AND ORGANIZATION

This section describes the CRASH Course project's background and organization.

1.2.1 Crash Course Background

The Massachusetts Office of the Attorney General initially asked the Massachusetts Office of Technical
Assistance for Toxics Use Reduction (OTA) of the Executive Office of Environmental Affairs to develop
this project. In response to this request, OTA secured funding from the U.S. Environmental Protection
Agency (EPA) and the support of the Massachusetts Department of Environmental Protection (DEP).
Each of these entities agreed that the existing regulatory approach toward auto body shops could
be improved; a key concern was that many shops do not know or understand what they have to do
to comply with the law.

OTA then designed the basic approach for the CRASH Course project: produce a manual that
contains a plain language summary of the law, that is easy for shop owners and workers to understand,
and that serves as a guidance document to demonstrate basic environmental compliance. Along
with the above agencies, the Massachusetts Auto Body Association (MABA) and a number of
individuals with knowledge of auto body shop operations agreed to participate in the formation of
this manual.

No summary can be a complete explanation of everything that is required. This manual is a guide
to understanding the EHS rules that apply to the auto collision repair industry at the date that this
manual was prepared. This manual does not constitute an official rule, regulation, or law.

A. Sponsoring Organizations

Various agencies worked together to prepare this manual. The principal author of this manual is
OTA. OTA does not have any enforcement power. It provides free assistance to anyone using toxic
chemicals. OTA's help is confidential; its staff only will report imminent threats. OTA can help you
reduce toxics use and comply with environmental rules. It has helped hundreds of companies;
most of them have ended up saving money as well. The Office of the Attorney General has some
leeway (called enforcement discretion) in prosecuting violations, and will look favorably on a
company's efforts to comply with the laws and implement pollution prevention recommendations
laid out in this manual.

Collision Repair Auto Shop Welp

The Office of the Attorney General is charged with prosecuting violations of environmental law in
court. This project represents a recognition by this office that it is necessary not just to enforce the
law against those who disregard it; it also is necessary to help those who do not understand the
laws well enough to comply. The project has the support of the Office of the Attorney General
because it is expected to be an efficient method of improving compliance.

The regional office of EPA, responsible for the implementation of federal environmental laws, also
believes that it is important to use not just enforcement, but to develop educational tools and
regulatory mechanisms that are easy to follow. EPA's regional office has established a team just for \
helping people comply with the law. It is called the New England Environmental Assistance Team kj
(NEEAT); information on how to contact NEEAT is included in Section 3 of the Toolbox. The NEEAT
can provide you with a wide range of compliance information. You do not need to identify yourself
and the NEEAT staff will not try to find out your location.

The Massachusetts DEP is the primary department responsible for the day-to-day enforcement of

environmental laws in the Commonwealth by means of inspections, orders, permits, and other |

regulatory operations. It exercises powers delegated by federal laws and it also has authority ■

under state laws. In addition, DEP provides compliance assistance services, from its headquarters \
in Boston and from each regional office.

Although this manual is not as detailed a guide of occupational safety rules as it is of environmental
rules, important safety requirements are noted. For further help, you can contact the Massachusetts
Division of Occupational Safety, Occupational Safety and Health Administration (OSHA) Consultation
Program. This program provides free consultation services on health and safety issues. Its staff
will work with you to correct violations and assist you in complying with OSHA regulations. Any
violations found during the course of the consultation are not reported to OSHA, as long as you work
to correct the most serious violations. J

B. Additional Resources

So that you can get more information and assistance, phone numbers and website addresses for all \

of the organizations involved in this project and for other resources are provided in Section 3 of the
Toolbox portion of the manual.

1.2.2 CRASH Course Manual Organization S

The sponsors wanted to provide you with a manual that is short and easy-to-use. They also wanted
to provide enough information for those that were interested or needed more help to comply with
the law and improve EHS performance. To do this, the manual was divided into two parts: (1) a
Workbook and (2) a Toolbox. These parts are described below. h

A. Workbook \t

The Workbook is designed to be a short and easy-to-use compliance and pollution prevention
resource. This part of the manual will help you understand the regulations and comply with them.

WORKBOOK

The Workbook includes this Introduction (Section 1), a Regulatory and Pollution Prevention Overview
(Section 2), and a Self-Assessment Checklist (Section 3). You should read Sections 1 and 2 and
use the checklist in Section 3 to evaluate, improve, and document your compliance. You also can
use the Workbook to learn about some best management practices and pollution prevention ideas
that can help you improve compliance and reduce your waste generation.

B. Toolbox

The Toolbox is designed to provide additional resources and information that auto body shop
representatives will find useful. Section 1 of the Toolbox, Auto Body Repair Step-By-Step, provides
activity-specific compliance and pollution prevention tips. Section 2 of the Toolbox provides Health
Protection and Fire Prevention Requirements that are important for all auto body shops. Section 3 of
the Toolbox provides Resources, Forms, and Other Tools; this section can be used to get phone
numbers for contacts that can provide compliance assistance, vendor information, necessary forms,
and other guidance materials. Section 4 of the Toolbox, Financial Tools and Positive Policies, provides
information on financial assistance tools and incentive programs which may be available to help
shops that need new pollution control or prevention technologies or that are found to be in violation
of the law. Section 5 of the Toolbox, Glossary Tool, provides definitions for technical and regulatory
words that are used in the manual.

2.1 REGULATORY OVERVIEW

Regulatory and Pollution 9

Prevention Overview %

Use this section to learn about environmental, health, and safety (EHS) requirements that
apply to your shop and why they are important. In addition, learn about the concept of pollution
prevention as a way to improve your compliance, reduce your waste generation, and reduce ki
your operating costs. \f

Then use Section 3 of this Workbook, the Self-Assessment Checklist, to see how well you comply \f
with regulatory requirements and use Section 1 of the Toolbox (Auto Body Repair Step-By-Step) to
learn more about compliance and pollution prevention tips for common auto body shop activities.

This section presents the basic commercial and EHS requirements that will apply to your shop, including: j

State and local permits, licenses, and registrations that you must obtain before you jj

can legally operate a business in Massachusetts - See Section 2.1 .1 .

Various State and Federal regulations that you must comply with to help protect your

business from damaging the environment - See Section 2.1.2.

Occupational safety and health and fire prevention requirements that you must comply

with in order to protect you and your employees from job-related accidents and injuries (^

- See Section 2.1.3. M

2.1.1 Commercial Permit, License, and Registration Requirements jjj

This section summarizes state and local permits, licenses, and registrations that you will
II q| need before you can run your shop as a registered, legal, commercial business. You
^se*^ should be aware that different towns call these requirements by different names. For
example, your town may refer to a permit described below as a "license" or "registration." Whatever
the requirement is called in your town, you will need to address all of the areas discussed below.

A. Occupancy Permit If

First, you will need an Occupancy Permit. This permit allows you to use a building to run an auto

body shop. Occupancy permits are issued by your local Code Enforcement Agencies (CEAs). In
a small town, the Occupancy Permit may be issued by separate local CEAs (such as the health
department, fire department, and building inspection department). Large towns may group all of

Collision Repair K.uto Shop Welp

WORKBOOK

these CEAs into one organization called the Inspectional Services Division (ISD). You should check
your local telephone directory to find out where the ISD in your area is located or ask your town hall
which agency or agencies are the CEAs in your area.

What will my CEA require before it issues an Occupancy Permit?

Before issuing an Occupancy Permit, your CEA will try to prevent hazards that may be associated
with solvents, paints, and other materials that may be used in your auto body shop. Your CEA will
require that your shop meets the requirements of the State Building Code and the Massachusetts
Board of Fire Prevention Regulations before it issues your occupancy permit.

To control the spread of flammable vapors, the State Building Code requires that your spray painting
area consist of one of the following:

O a spray booth - which has three walls and one open side, or
O a spray room - which has four walls with a door on one side.

How should my spray painting area be constructed?

In order to issue an Occupancy Permit, your CEA must approve your spray painting area. Your
CEA will require three main things in order to approve a spray painting area:

3 adequate ventilation — a system is needed to exhaust flammable vapors so that they
do not build up in the spray painting area (a Ventilation Permit from your local CEA will be
required to document adequate ventilation);

O proper wiring — any electrical equipment located in, or just outside, the spray painting
area must not produce any sparks;

O fire resistance — in case a fire starts in your shop or spray painting area, the spray
painting area must be made of materials that make it hard for a fire to spread.

The state, the National Fire Protection Association (NFPA), and the U.S. Occupational Safety and
Health Administration (OSHA) have additional requirements for the legal design and operation of
a spray room or spray booth. See Workbook Section 3 "Self-Assessment Checklist" for specific
requirements on the construction of spray painting areas.

In some areas, the Fire Department, in addition to the CEA, may require a permit for your spray
painting area. You should check with your local Fire Department to see if it requires an additional
permit for your shop's spray painting area.

Remember: You MUST have an approved spray painting area to obtain your Occupancy
Permit and legally operate your shop. If an inspector visits your shop and discovers that
you do not have an approved spray painting area, you will be given an order to STOP
WORK. This means that no painting may be done in your shop until this concern
is addressed.

Collision Repair Auto Shop Welp

B. Flammable Storage

A major concern for auto body shops is the safe storage of flammable materials. If
these materials are not managed properly, their storage and use can lead to fires,
health and safety hazards, and environmental damage.

You will need a Flammable Storage Permit or License to keep preparation solutions,
thinners, paints and other flammable materials (such as oxygen and acetylene cylinders) on site.
In some cities and towns, only one permit or license may be required for the storage of all the
flammable materials in your shop. In others, two may be required: (1) one for paints and (2) one
for other flammable materials.

The authority that issues Flammable Storage Permits or Licenses can vary, depending on where you
are located. In Boston, the Committee on Licenses issues Flammable Storage Permits or Licenses.
In other areas, the Fire Department may issue them. The state, NFPA, and OSHA have additional \
requirements for the legal design and operation of a spray painting area. Go to Workbook Section 3,
Self-Assessment Checklist, for specific requirements that apply to flammable materials storage. J

C. Towing Services

If your shop provides police-ordered towing services, you will need a Towing License from the
Massachusetts Division of Transportation. Contact this division at (61 7) 305-3559 for more information. \

D. Vehicle Storage \

Vehicle storage permits are issued by your local CEA or by another local or regional group, and \
address the following:

O Vehicles stored INSIDE require a Garage Permit. The Garage Permit typically will be issued I

for the number of cars that can reasonably fit inside your shop (including cars that are \

stored in preparation and spray painting areas). Check with your city or town hall to see if \
you need a Garage Permit.

O Generally, vehicles that are stored OUTSIDE for more than 30 days require a Use of
Premises Permit. Note: In some areas, storing vehicles outdoors for any length of time
may require an outdoor vehicle storage permit.

If you store vehicles inside and outside, you may require two permits. In Boston, the Committee on \
Licenses issues vehicle storage permits. In other areas, your local CEA should be able to direct
you to the proper authority for Garage and Use of Premises permits.

ii
w

WORKBOOK

Now That You Have The Basic Commercial Permits And Licenses Required to Operate an
Auto Body Shop...

1. You must register with the State Division of Standards (DOS). The DOS is a State agency
which ensures that businesses and professionals that provide a service meet certain
requirements. For auto body shops, the DOS requires:

a. A $10,000 Surety Bond - Your shop must have this bond to cover costs in the
event that a customer files a valid complaint for work that your shop has done on his
or her car.

b. Worker's Compensation Policy - You must have a Worker's Compensation Policy with
an accident insurance company if your shop employs more than one person or your
shop is incorporated.

c. An Appraiser's License - At least one person employed by your shop must be
registered with the State as an appraiser and obtain an appraiser's license to issue
and negotiate appraisals for auto repair.

2. You must obtain a Federal Tax Identification (ID) number from the State Department of
Revenue (DOR). You also must get a sales tax registration number from DOR because
your shop provides a service that the State considers taxable.

3. You must register your auto body shop as a business with your City or Town Hall.

Contact the DOS at the (617) 727-3480 for more information on the above requirements.

2.1.2 Environmental Requirements

The EPA and DEP implement requirements that address air pollution, water pollution, and hazardous
waste management at auto body repair shops. By complying with these requirements, you will
protect your community's air and drinking water quality, safeguard the health and safety of your
employees and yourself, and protect your business from the financial burden of environmental
liability or potential fines, penalties, and cease and desist orders.

A. Air Requirements1

Common auto body shop air pollutants that are regulated include: (1 ) volatile organic
compounds (VOCs) and (2) motor vehicle air conditioning refrigerants. Particulates,
from sanding or grinding operations, are even more of a health and safety concern
than an air pollution concern and are addressed as such in this manual.

Air Permit and Source Registration Requirements -- VOCs

VOCs are contained in paints, surface preparation solutions, and solvents and can be harmful to
human health and the environment. VOC requirements are designed to reduce the release of
VOCs and to ensure that materials that contain VOCs are properly managed.

'370 Code of Massachusetts Regulations (CMR) 7.00 and Clean Air Act Sections 608-612. Note: Massachusetts
regulations are designed to comply with a new VOC-rule that EPA has issued.

Collision Repair Auto Shop Welp

The state's air permit and source registration requirements are based on the amount of VOCs
emitted by your shop, as described below.

If your shop uses less than 670 gallons of VOC-containing materials per month, Massachusetts
law2 allows you to qualify for an air permit exemption if you also meet record keeping, spray
enclosure, stack height, coating and equipment requirements (see below). IMPORTANT: If you
claim this exemption, you must keep the last 12 months of your chemical purchase records to
document your usage rate.

If your shop uses more than 670 gallons of VOC-containing materials per month, or if you are i

otherwise unable to meet the record keeping, spray booth, and stack height requirements, you
must apply for an air permit. You should contact your regional DEP service center to apply for a
permit (see Section 3 of the Toolbox, Resources, Forms, and Other Tools).

If your shop uses only slightly more than 670 gallons of VOC-containing materials per month,

you should use the various pollution prevention tips provided in Section 1 of the Toolbox to reduce
your VOC levels to the point where you qualify for the permit exemption.

NOTE: If you receive a Source Registration package in the mail from DER you must complete it

and return it to DEP within the period of time specified. |

Spray Enclosure (Spray Booth or Spray Room) and Stack Height Requirements I

The state law provides several specific DEP guidelines3 for design and performance of spray
enclosures, in order to prevent or minimize air quality impacts from spray painting (Note: there
also are additional state, OSHA, and NFPA requirements for spray enclosures, as listed in Section
3 of the Workbook, items 17 and 18). These requirements include the following:

O Exhaust filters must consist of two or more layers of dry fiber mat, with a total thickness of

at least 2 inches. The filters must reduce exhaust spray paint emission by at least 97% fe

by weight. I

2 310 CMR 7.03(13)

3 310 CMR 7.03(13)

O The maximum air velocity at the face of the exhaust filter must not be greater than 200
linear feet per minute.

O Stack construction and performance requirements -

exhaust flow must be vertical and unrestricted by rain protection devices; \

stack must vent emissions at no less than 40 linear feet per second; and
stack height must be 10 feet above roof level or 35 feet above ground level.
O There may be NO visible emissions from the stack.

WORKBOOK

Coating and Equipment Requirements -- VOCs

You must make sure that you purchase and use compliant coatings (see the definition in the table
below). Massachusetts vendors are required to sell only VOC-compliant coatings.

Coating materials include surface preparation solutions, paints, and special finishes. The
Massachusetts air requirements4 list limits for the pounds of VOC per gallon (lbs VOC/gal.) that are
allowed for a variety of these solutions and materials. The following limits apply:

Type of Surface Preparation

Solution or

Coating Material

VOC Limit (as applied)

Surface preparation solution

1.67 lbs VOC/gal.

Pretreatment wash primer

6.5 lbs VOC/gal.

Primer/primer surfacer

4.8 lbs VOC/gal.

Primer sealer

4.6 lbs VOC/gal.

Topcoat (single stage or basecoat/clearcoat)

5.0 lbs VOC/gal.

Three- or four-stage topcoat

5.2 lbs VOC/gal.

Specialty coating

7.0 lbs VOC/gal.

"As applied" refers to the coating that is actually sprayed onto the vehicle. In other words, all the
components (such as paint, hardener, reducer, etc.) that make up a coating must be mixed so that
the total VOC content of the coating as applied is below the VOC limits (second column above).
"Compliant coatings" meet the requirements listed above when properly mixed and applied. Your
coating manufacturer should provide mixing and application instructions for each material.

State law5 requires that you use HVLP (high volume, low pressure) or LVLP (low volume, low
pressure) spray guns and train your operators to use this equipment safely and properly. Because
this equipment increases your painting transfer efficiency (see the definition in the Glossary Tool,
Section 5 of the Toolbox) when operated properly, HVLP or LVLP spray guns reduce the amount of
paint used. As a result, your total VOC emissions also are reduced. Complying with this equipment
requirement should save you money in the long term on raw materials and waste disposal costs.
You also must clean these guns in an approved gun washer to reduce your solvent use and
VOC emissions. These washers (1) recirculate solvent for reuse and (2) collect spent solvent;
they also use less solvent and less labor time to wash spray guns than older gun washing
methods.

Motor Vehicle Air Conditioning Requirements - CFCs

If you service or repair motor vehicle air conditioning (MVAC) systems or even if your workers
perform work under the hood of a vehicle for other than painting purposes, you must comply with
a variety of Clean Air Act requirements (Sections 608-612 cited previously).

4 310 CM R 7.18(28)

5 CMR 7.18(28)

Collision Repair Auto Shop Welp

Why do we need the MVAC requirements? These requirements are designed to
restrict the use and release ot ozone-depleting substances that harm the
environment. Regulated refrigerants include chlorofluorocarbon (CFC)-12 (also
known by the trade name Freon™), which was commonly used as a motor vehicle
air conditioning refrigerant. This compound is no longer produced but is still
commonly found in the MVACs of older vehicles.

The primary goal of these regulations is to prevent the release of CFC-1 2 and similar kj

compounds into the atmosphere during MVAC servicing. It is illegal to knowingly \\
release CFCs to the environment because they may contribute to long-term global k\
warming. Important requirements for MVAC servicing are summarized below.

Certification - For your purposes, any shop personnel that have the potential to service
(repair, alter, evacuate) the MVAC must possess MVAC servicing certification. This
certification is designed to make sure that operators are trained to properly manage CFC
refrigerants. A list of approved certification organizations can be obtained by calling the
EPA Stratospheric Ozone Hotline at (800) 296-1996.

Equipment - All equipment that (1) recovers or (2) recovers-and-recycles refrigerant from
MVACs must be approved by EPA or by an EPA-approved equipment testing organization. A
list of EPA-approved equipment can be obtained by calling the Ozone Hotline.

Z> Documentation - Shops that do MVAC work must certify to EPA that they use approved
CFC-12 reclamation equipment. When collected, refrigerant should be sent to a
reclamation facility and the name and address of that facility must be kept on file. You do
not need a special form to record this information; just keep it available. I

O Sale and Use - Regulated MVAC refrigerants must be managed in a manner to prevent
the sale of these refrigerants to unregistered parties. In order to ensure the safe handling
of these materials, only certified technicians can buy restricted refrigerants. If you buy |

these refrigerants, you must make sure that you comply with applicable sale restrictions. \

In addition, under Section 612 of the Clean Air Act, certain CFCs are not approved for use
in cars (for example, cars must have proper retrofits of their equipment before CFC-134a
can be used for their cooling systems). Check with a knowledgeable supplier or with EPA
for more information. To help you, EPA has developed a Fact Sheet called "Choosing and
Using Alternative Refrigerants". It is available on the EPA Ozone web page. I

For more information on how to comply with these requirements, call the EPA Stratospheric Ozone
Hotline at (800) 296-1996 or visit EPA's Ozone web page at http://www.epa.gov/ozone. The hotline
and web page provide a list of Technician Certification Programs, fact sheets regarding MVAC
Requirements, and specific Dos and Don'ts related to working with MVACs. You also can call EPA
in Region 1 for more information at (617) 565-3420 or (800) 821-1237.

WORKBOOK

B. Water Requirements6

2SSS

Industrial wastewater generated by your shop consists of vehicle wash water, shop
floor wash water, laundry water, and equipment wash down water. Industrial
wastewater that is managed improperly may threaten our drinking water supplies
and cause damage to the environment. Surface water bodies include lakes, rivers,
streams, and the ocean; they are used for recreation, fishing, natural habitats, and
drinking water supplies. Groundwater consists of layers of water that exist below the surface of the
ground. If wastewater is disposed onto or into the ground, pollutants in that wastewater (such as
solvents or oils) may seep into and contaminate groundwater. In Massachusetts, groundwater is a
valuable private and public drinking water supply source and must be protected. Floor drains in
your shop that discharge your industrial wastewater to a septic system, a cistern, or directly into, or
onto, the ground are NOT legal. If you currently discharge in this manner, you must seal the floor
drain and collect and contain your wastewater in a container or tank for proper management. Call
OTA for more information at (617) 727-3260.

Wastewater Discharges to a Sewer Line

If the floor drain or sinks in your shop go directly to a city sewage treatment plant (also called a
publicly owned treatment works or POTW), there are limits on the types of materials allowed in your
industrial wastewater discharge. You are not allowed to discharge:

3 Materials such as solvents, gasoline, large solids (such as large pebbles or gravel),
hazardous wastes, or excessive amounts of soap (or other organic chemicals). These
materials can cause a fire hazard or interfere with POTW treatment operations.

C Strongly corrosive wastes (See the Vehicle Washing activity, in Section 1 of the Toolbox, for
tips on how to manage battery acids) or strongly alkaline wastes. The pH limits
established by DEP are 5.5 or below for acids and 9.5 or greater for bases (standard
units). This means that if the pH of your waste is between 5.5 and 9.5, you can discharge
it to the sewer. If you are not sure about the pH level, you can easily measure pH using
simple tests or equipment.

3 Large volumes of heated water without approval from your local POTW. It is unlikely that
your shop will need to dispose of a large quantity of heated water at one time.

In addition, you should check with your local POTW to determine discharge limits for petroleum-
based oil and grease discharges. In many cases, you will be required to have an oil-water separator
(sometimes called a gas trap or grease trap) on your drain to remove oily waste from wastewater
before it enters the sewer.

An oil-water separator removes solids and oil from your wastewater and collects them for proper
disposal. The rest of the wastewater is discharged to the sewer. It is important to maintain an oil-
water separator so that it functions properly. It should be checked weekly to see if the sludge in the
bottom or the floating oily waste needs to be removed and disposed. These wastes need to be

e314 CMR 2.00-12.00

(Zollision Repair Auto Shop Welp

managed either as a hazardous waste or as an oily waste, depending on the content. Section
2.1.2.C discusses waste management.

Vehicle Washing Concerns

Vehicle wash water is the primary industrial wastewater concern associated with auto body shops. J
This auto body shop wastewater can contain several pollutants, including:

3 soaps or detergents \

Z> road oils and greases

Z> paint dust or solvent residues from sanding and grinding operations

Z> de-icing salts

3 metal chips, flakes, and dust

Z> fluids that leak from a vehicle

Currently, your shop does not need a sewer connection permit from DER However, it is likely that
your shop will be covered by a new DEP regulation regarding sewer connections that is expected
to be issued in early 1999. For more information, you can contact DEP at (617) 292-5638. If your
shop already has a sewer-use permit from your local POTA/V, you must comply with the requirements
in that permit.

(1) Outdoor Vehicle Washing

Because it is a business activity, washing vehicles outdoors on your shop's driveway or parking lot
is subject to different requirements than would apply to a resident washing his or her personal
vehicle outside.

Wastewater from vehicle washing that is allowed to run off your lot will either (1) go into storm
drains, (2) seep into the surrounding soil, or (3) flow into nearby creeks and gullies. Regardless of
where it goes, your wastewater will go into the environment untreated and therefore poses a potential
hazard to local surface water and groundwater quality.

Important: You should make sure to manage your wastewater properly. If water withdrawn from a nearby
well or body of water contains pollutants that could be from your shop, you may be held liable for the
cleanup of that water. You could also be forced to pay fines for violation of laws designed to protect water
quality. Therefore, it is in your best interest to manage your wastewater properly.

The BEST way to reduce the potential for law suits and penalties is to collect all of your wastewater
and have it picked up for proper treatment and disposal. You can collect the wastewater by
washing vehicles (1) within a bermed area (using either a permanent or temporary watertight
berm), (2) on a tarp or specially designed vehicle wash pad area, or (3) using other mechanisms

lil

To help you be aware of what potential liabilities exist, you should contact your local conservation
commission or regional DEP office to find out if your shop is in a sensitive area. They should be able
to tell you if there are wells or designated drinking water sources nearby, if you are situated over an
important underground source of water, or if you are in a designated area for environmental concern.

WORKBOOK

which prevent the wastewater from running off into storm drains, into surface water, or onto the
soil. The collected wastewater should be transferred into a container. You can drain, pump, or
wet-vac the wastewater to transfer it into the container.

The next best way to avoid pollution liability is contaminant separation of your wastewater. This
alternative is less protective than having your wastewater picked up but is MORE protective than
direct discharge of the wastewater. Section 3 of the Toolbox (Resources, Forms, and Other Tools)
provides a diagram of a container system that can be used for wastewater management before
discharge. Once your wastewater is collected, let it stand for several hours (usually overnight) so
that solids settle to the bottom and any oily materials float to the top. Then use sorbents (such as
pads or socks) to remove the floating oil and dispose of the sludge from the bottom as either an
industrial or hazardous waste. The remaining wastewater can be poured out (preferably into your
indoor drain, assuming that you have an oil-water separator and are connected to a POTW).
Discharging the water through a filter or fine mesh screen to catch any particulates that did not
settle out of the water will give you added assurance that you are not harming the environment.

Finally, a very basic approach that offers less protection than the above methods, but is still better
than direct discharge is to place oil-sorbents (like socks or berms that are designed for oil
absorption) or even rags in the path of wastewater runoff. This approach can help remove some
of the contaminants from this wastewater, depending on what you use and how you use it. Dispose
of the contaminated sorbents properly.

Cleaner and Safer Operations: No matter what separation method you apply, you also should
implement the best management practice tips for Vehicle Washing provided in Section 1 of the Toolbox.
These tips will help you meet water requirements, reduce your potential liability, and reduce your impact
on water quality. In addition, use the Section 3 Self-Assessment Checklist in the Workbook, comply with
the best management practices and requirements listed, and document your efforts. All of these steps are
good ways to demonstrate that you are making a "good faith effort" to meet the requirements and reduce
your impact on water quality.

(2) Indoor Vehicle Washing

Even if you wash vehicles indoors, most of the water compliance and Cleaner and Safer Operations
tips will apply to your washing operations. Many of the limitations on industrial wastewater
discussed earlier may apply to indoor vehicle wastewater. That is why it is important to know
what wastes may be washed into your floor drain during vehicle washing, either from the vehicle
or from the shop floor.

Remember: You can call OTA at (61 7) 727-3260 for free help in setting up a wastewater
management program for your shop.

2-10

Collision Repair Auto Shop Welp

C. Hazardous Waste Requirements7

The improper management of hazardous waste can greatly damage human health and
the environment. EPA and DEP enforce hazardous waste requirements for shops that
generate, transport, treat, store, or dispose of hazardous waste. Common auto body
wastes that are considered hazardous include: waste paints, waste solvents, saturated
clean-up materials, and some solvent-containing fillers.

All hazardous waste requirements are designed to protect the environment. This section describes
some important and basic requirements for operating your shop in compliance with DEP hazardous
waste regulations.

If you have questions concerning hazardous waste, call the DEP Hazardous Waste Management
Hotline at (61 7) 292-5898.

1 Hazardous Waste and Waste Oil Generator Status
First, you should determine your hazardous waste and waste oil generator status. Use
the table below to determine if you are a Very Small Quantity Generator (VSQG), a Small
Quantity Generator (SQG), or a Large Quantity Generator (LQG). It is possible that your status
could be different for each waste category (hazardous waste or waste oil) - this is called having a
"dual status."

Hazardous Waste and Waste Oil Generator Status Evaluation

If you generate hazardous waste at the following rate...

Your generator status is...

0 to 26 gallons of hazardous waste per month

VSQG

27 to 270 gallons of hazardous waste per month

SQG

More than 270 gallons of hazardous waste per month

LQG

If you generate waste oil at the following rate...

Your generator status is...

0 to 26 gallons of waste oil per month

VSQG

27 to 270 gallons of waste oil per month

SQG

More than 270 gallons of waste oil per month

LQG

Note: Your generator status is based on the largest generator category that you meet in any one month during
the last 1 2 months of waste generation (not an average of the last 1 2 months of waste generation data) .

Your generator status is important because it impacts which of the following requirements
apply to you.

310 CMR 30.00

2-11

WORKBOOK

2 Hazardous Waste ID Number and DEP One-time Notification
If you are a SQG or LQG of hazardous waste, you must obtain a Hazardous Waste ID
number from EPA and notify DEP that you are generating waste. Your Hazardous Waste ID
number is specific to your facility and is used to track the waste after it leaves your shop. If you are
a VSQG you must register with DEP and you will self-assign your hazardous waste ID number by
using your telephone number, including area code with the prefix MV. Instructions for obtaining the
forms that are required to apply for a Hazardous Waste ID number and submit a one-time notification
to DEP are included in Section 3 of the Toolbox.

Labeling Requirements

Every hazardous waste drum which you accumulate must be labeled with the following

information:

• the words "HAZARDOUS WASTE,"

• the name of the waste, for example, "waste paint solvent",

• the type of hazard (e.g., ignitable, corrosive, reactive, toxic, or waste code for listed

wastes), and

• if you are a SQG or LQG, the date on which accumulation began.

A sample hazardous waste label is provided in Section 3 of the Toolbox.

Hazardous Waste Storage/Accumulation

Your shop should have a designated area where containers of waste are man-
aged until they are picked up for recycling or disposal. You must do the following in
your storage/accumulation area:

• clearly mark the area's edges (for example, yellow painted lines could be used);

• post a sign that says "HAZARDOUS WASTE" in letters that are 1-inch high or larger;

• check hazardous waste containers weekly for rust, cracks, or other damage that may lead
to a leak;

• surround outside hazardous waste storage/accumulation areas with a berm that can hold
up to (1) 10% of the maximum volume of all the containers in the area or (2) 110% of the
largest single container in the area, whichever is greater;

• cover outside storage/accumulation areas;

• store hazardous waste containers on a surface that is free of cracks and is resistant to
leaks or spills (unlike tar pavement which is porous and can allow liquids to seep into
underlying soils); and

• store containers in accordance with the volume and time limits that apply to you (see the
table on page 2-13).

2-12

Collision Repair Auto Shop Welp

Based on your hazardous waste generator status (from Item 1 above) you can store/
accumulate wastes in the following quantities and for the following time periods:

If your hazardous
waste generator
status is...

You can store/accumulate full
containers of waste up to

You can store/accumulate
containers for the following
period of time

VSQG

no more than 1 ,320 pounds
(about three, 55-gallon drums)

no specified limit

SQG

no more than 4,400 lbs (about 1 0 drums)

no more than 1 80 days

LQG

no volume limit

no more than 90 days

A satellite accumulation area is where partially full containers are used to collect wastes. When
containers are full, they must be dated and moved to an accumulation and storage area. Note: all
satellite accumulation areas must be at or near the point of waste generation and must be under
the control of the shop person doing the activity that is generating the waste (for example, the
spray painting worker in the spray enclosure area). You may accumulate up to 55 gallons of
hazardous waste in a satellite accumulation area, as long as each container is labeled and moved
to a central storage/accumulation area or shipped off-site within three days of being filled.

5 Transporting Waste
SQGs and LQGs are required to have hazardous waste transported by licensed
hazardous waste transporters. VSQGs can (1) self-transport waste to another generator
(if that shop is willing to that accept waste) or a receiving facility or (2) use licensed hazardous
waste transporters.

Contact the DEP Hazardous Waste Hotline at (61 7) 292-5898 to get a free list of licensed
hazardous waste transporters, the services that these transporters are licensed to provide, and
the types of generators that they service.

6 Record Keeping and Reporting
Before hazardous waste can be accepted by a licensed transporter, generators (like your
shop) must have a hazardous waste manifest completed and signed. The manifest is a
form that is used to track the amount of hazardous waste generated and the management of the
hazardous waste after it leaves your shop. Each manifest has several copies. Follow the directions
on the manifest regarding which copy you should keep and which copies go to the transporter, the
receiving facility, or other parties. For each shipment, a copy of the manifest from the receiving
facility documenting that your waste reached it final destination should be sent back to you within
30 days.

If after 30 days you have not received your copy of the manifest signed by the receiving facility,
you must contact the transporter or the owner/operator of the facility receiving the waste to find out
the status of the shipment. If you do not receive a copy of the manifest documenting your waste's

2-13

WOMKOUK

final destination within 15 days of contacting the facility (45 days after you shipped it), you should
file an Exception Report with DER LQGs also must submit a Biennial (every other year) Hazardous
Waste Report to the DER SQGs and VSQGs do not have to submit this report.

Finally, all waste generators are required to keep their copies of each manifest, Exception Reports,
and any results of sampling and analysis of hazardous waste for three years. VSQGs who self-
transport their waste do not have to complete manifests; however, they must obtain and keep
receipts from the facility that accepts their waste. LQGs also must keep a copy of their Biennial
Hazardous Waste Reports for three years after they are submitted.

Remember: Maintaining your manifest records or waste receipts protects you because it assures that your
hazardous wastes have been properly managed.

7 Accidental Spill or Release
When containing a spill in your shop, be sure to use the proper health and safety personal
protective equipment (as indicated by the Material Safety Data Sheet for each material),
and contain the spill as quickly as possible.

In some cases, you may not be able to contain all of the material, and some may become a
"release to the environment." If a "reportable quantity" of this material (see table below) is released,
you MUST report this event to the DEP within 24 hours — after making a complete attempt to
contain and clean up the spill. To report a spill, use a Spill Report form similar to the one included
in Section 3 of the Toolbox (Resources, Forms, and Other Tools).

You also should call the state spill report hotline at (617) 556-1 133 for the Boston area or (888)
304-1 1 33 for other parts of the state. If you do not report the spill to the proper authorities, you
may be subject to enforcement for noncompliance.

A "release to the environment" is when a regulated material escapes outside your shop, such as
through a window or door (if it is airborne), or leaks out of your shop through a crack in the floor or
an open door. These releases can harm air quality, or the nearby groundwater, surface water, or
soil quality, or present a risk to human health.

A "reportable quantity" is the amount of a regulated material that DEP considers to be significant. The table
below provides the reportable quantity of regulated materials commonly found in auto body shops.

Regulated Material Reportable Quantity

paint greater than 1 gallon

paint thinner greater than 1 gallon

oil greater than 1 0 gallons

power steering fluid or automatic transmission fluid greater than 1 0 gallons

2-14

Gollision Repair Kuto Shop Welp

8 Imminent Danger
An activity or condition that poses an immediate danger to human health or the
environment is defined by EPA as an imminent threat and by DEP as an imminent hazard.
For example, disposing of used paint thinner by pouring it onto the ground outside a shop is
considered to pose an immediate danger. If you suspect that you have observed an imminent
threat or hazard, call the DEP spill report line at (888) 304-1 133 and report the situation. You are
required by law to report such threats immediately.

Contingency and Emergency Planning \

SQGs are required to have an emergency plan (LQGs must have both an emergency plan

and a written contingency plan). The emergency plan must include or describe the following: fe

Z> a designated emergency coordinator, t

O an alarm or communication system to alert people inside the shop,

O a telephone or other communication system to contact emergency response teams, \

O portable fire extinguishers and automatic sprinklers or foam-producing equipment,

3 clearly marked lit exits that can be used to escape in an emergency,

3 a plan for instructing employees on emergency procedures,

O emergency phone numbers and an evacuation plan that is also clearly marked and posted,

Z> procedures to notify emergency response agencies of chemical and waste activities, and

O spill control materials and procedures.

O Petroleum-based parts cleaners such as mineral spirits or stoddard solvents
O Excess or off-specification kerosene or gasoline

Section 2 of the Toolbox, Health Protection and Fire Prevention Requirements, includes more
information on contingency and emergency plan requirements.

What Wastes Are Considered Hazardous?

There are two ways that a waste can be considered hazardous: (1) it can be a listed waste, or (2)
it can be hazardous based on its characteristics (either ignitable, corrosive, reactive, or toxic). You
can get a list of the "listed wastes" from DEP or OTA. The text below lists examples of auto body
wastes that can be characteristic and defines each characteristic in more detail.

Waste Characteristics and Definitions with Example Auto Body Wastes ij|

Ignitable - liquid wastes with a flash point of less than 140° Fahrenheit L

O Paint-related materials such as solvents, thinners, preparation solutions and coatings
(if MSDS indicates flash point is less than 140° Fahrenheit)

2-15

WORKBOOK

Corrosive - Waste having a pH of 2.0 or less (strong acids) or 12.5 or more (strong bases)
O Caustic degreasers for parts cleaning
O Rust removal solutions
Z> Lead-acid batteries
O Cleaning solutions that are alkaline or acidic

Reactive - unstable or explosive waste; waste which reacts violently when mixed with water;
wastes (such as sulfide or cyanide-bearing wastes) that release toxic vapors when exposed to
corrosive conditions

O Aerosol spray cans with contents that are under pressure

Toxic - waste which under acidic conditions leaches toxic metals, above certain limits. An EPA-
specified test, the Toxicity Characteristic Leaching Procedure (TCLP), can be used to determine if a
waste exceeds these limits. Or, you can use your knowledge of these wastes and disposal
requirements to evaluate whether the waste is toxic.

O Paints that contain metals of at least the following levels using the TCLP test: arsenic [5
milligrams/Liter (mg^L)], barium (100 mg/L), cadmium (1 mg/L), lead (5 mg^L), mercury (0.2
mg'L), selenium (1 mg/L), and silver (5 mg/L) - your paint supplier should be able to tell you
the metals content of your paint

O Related paint wastes such as paint booth filters which may contain metals

You need to evaluate your wastes in terms of how they were generated and how they are managed
(current physical characteristics and, in some cases, their treatment or disposal) to determine
whether they are hazardous. For example:

O Paint that is wet or mixed with a thinner or other solvent is considered hazardous.
However, dry paint in the bottom of an empty can may be disposed of as a solid waste.

O Rags which are saturated with waste oil are considered hazardous. If they are not
saturated (that is, not one drop of fluid can be squeezed from each rag), they are
considered to be a nonhazardous solid waste, in accordance with DEP's One-drop policy.
If you are sending rags to a laundry, be sure that the laundry is capable of treating the oil
and other materials that are on the used rags.

2.1.3 Health Protection and Fire Prevention Requirements

The U.S. Occupational Safety and Health Administration (OSHA) is the part of the U.S. Department
of Labor that governs regulations related to the health and safety of you, your employees, and your
work areas.

The Massachusetts Division of Occupational Safety - OSHA Consultation Program can provide
technical assistance and consultation services for OSHA requirements. The program can be
contacted at (61 7) 969-71 77.

2-16

Collision Repair Auto Shop Welp

OSHA requires that you:

3 prevent injuries and illnesses through the use of engineering controls (see definition in
Section 5 of the Toolbox, Glossary Tool), whenever possible;

3 when personal protection equipment (PPE) is required, make sure your workers wear the
correct PPE to protect them from physical injuries, illnesses, and hearing loss;

3 train employees on hazards and safe work practices to prevent injury;

3 properly ventilate spray painting areas and flammable storage areas;

3 use or store flammable chemicals properly;

3 have fire prevention plans and equipment;

3 guard machinery against hazards; and

3 keep records of employee injuries and accidents.

Some of these requirements overlap with hazardous waste contingency or emergency plan
requirements. Therefore, you should make sure that your plans are consistent. If you do this, you
will find that you can use some of your contingency or emergency plan components to address
your OSHA planning requirements. Section 2 of the Toolbox, Health Protection and Fire Prevention
Requirements, includes more information on these requirements.

2.2 POLLUTION PREVENTION OVERVIEW

The first step on the road to environmental compliance is to look for opportunities to use fewer
hazardous materials and to generate less waste — in other words, avoid pollution at its source.
Why manage wastes when you can eliminate them?

Pollution prevention techniques can help you reduce your compliance burdens, make your
workplace cleaner and safer, increase your competitiveness, and save you money. Pollution l|
prevention techniques include:

3 replacing toxic or hazardous materials with nonhazardous alternatives, Jj

3 replacing or modifying a process in order to use less of a hazardous material or generate
less waste,

3 improving regular housekeeping techniques to keep the work area clean and safe, and

3 reusing or recycling hazardous materials so that less of the hazardous raw materials J

are used.

The CRASH Course manual includes many pollution prevention ideas that you can implement in \

your shop. See the Section 1 of the Toolbox for pollution prevention tips that address each step of

the auto collision repair process. J

ill

2-17

WORKBOOK

Important: The first step to effective pollution prevention is to track your shop's use of materials
(particularly, hazardous materials) and your waste generation. Once you have gathered this information,
look for ways to avoid the use of harmful materials and to minimize waste. Keep regular records of your
inventory and waste pickup. Use this information to measure your progress (look for fewer purchases of
materials, fewer pickups of hazardous waste and other waste, and document your increased use of
nonhazardous alternatives) .Some shops track raw material use per month or per number of repair jobs to
track production efficiency.

The following examples of pollution prevention will give you an idea of how pollution prevention can
be implemented in your shop and what benefits it can provide.

Example #1:

Shop A avoids using phosphate-based soaps except for cleaning whitewall tires and other special
needs. The phosphate-based soap is clearly labeled "for whitewalls and special use only" and is
kept in a closed locker. Meanwhile, the owner has asked his jobber to investigate and recommend
any non-phosphate cleaners that might effectively replace the phosphate-based cleaner.

By minimizing the use of phosphate-based soaps, Shop A reduces its potential liability for local
surface water and groundwater quality problems caused by phosphate contamination, or for any
problems at the local POTW associated with phosphates.

Example #2:

Shop B recently switched to HVLP spray guns for spray painting and all employees attended
a one-day training on the use of HVLP guns. Note: HVLP or LVLP guns are required in
Massachusetts.

HVLP spray guns can increase your painting transfer efficiency significantly. However, proper
training is just as important, since the new guns require a different technique to obtain quality
coatings with minimal paint waste. The end benefits for Shop B are: (1 ) reduced VOC emissions
(through greater transfer efficiency and reduced paint use), (2) improved working conditions
(greater transfer efficiency produces less overspray), and (3) reduced operating costs (less
paint needed).

Example #3:

Shop C brings in a lot of vehicles that have been heavily damaged (for example, with ruptured oil
lines, gas lines, and antifreeze tanks). The shop also does a fair volume of cutting and grinding
during the course of repairing vehicles, which generates a lot of metal dust and fragments. It can
also produce sparks that can ignite flammable vapors.

As each vehicle is brought in, employees carefully go over the entire car to look for existing and
potential leaks. They keep drip pans nearby, and slide them under the vehicle to catch any leaking
fluids. If possible, they keep the dripping fluids separated (by using one pan for oil, one pan for
antifreeze, etc.). Any puddles of fluid on the floor are contained or cleaned up with absorbent
pads or socks. After each activity, employees quickly sweep up any excess dusts off the floor.

2-18

Collision Repair Auto Shop Welp

Each of these steps prevent harmful materials from collecting on the shop floor. This keeps the
shop clean, relatively dust-free, and helps prevent metals or toxics from being washed down the
shop's drains. It also reduces the chance that sparks will ignite flammable vapors associated with
leaked fluids and prevents dust from getting into the paint, which can ruin a paint job. By keeping
fluid wastes separated, Shop C can recycle waste oil and antifreeze, rather than having to dispose
of them along with any battery acids or other hazardous materials. \

Example #4:

Shop D generated a lot of spent solvent from washing small parts and tools and other solvent
cleaning. The shop has installed an enclosed gun washer (these or other approved gun washers
are required by Massachusetts DEP). This allows employees to reuse these solvents to clean their
HVLP spray guns. In addition to allowing Shop D to recycle solvent (and reduce the need to
purchase new solvent), the enclosed gun washer provides effective cleaning of HVLP guns without
evaporation of VOCs in the solvent and saves nearly 15 minutes of labor time in cleaning the guns
with each use with each use.

This all saves the shop money, of course, as well as helping the shop to minimize its total VOC
emissions.

Pollution Prevention Summary

As you can see from the examples above, the clear benefits of pollution prevention include:

3 reduced liability

O reduced operating costs

O greater efficiency |

O less waste

O a cleaner and safer shop I

Pollution prevention also helps minimize the uncertainty that is associated with the use of hazardous i
materials and management of hazardous waste — you may find that pollution prevention simply h
makes your shop an easier, less worrisome facility to operate. \

Pollution prevention steps take some extra effort and you may find that some of the tips in this
manual do not work for your shop. However, it is important to review your operations and determine
where pollution prevention is possible in order to move your shop toward compliance and improve
the environmental, health, and safety performance of your shop.

2-19

Willi kit II Ilk

2-20

SELF-ASSESSMENT CHECKLIST

You should use this checklist to learn about the federal, state, and local regulations and
requirements that apply to auto body shops. This checklist is not a comprehensive list of all
requirements, but is based on the basic requirements discussed in Section 2 of this Workbook.

Basic requirements that all auto body shops are required to meet are indicated in bold and
with a •. Pay particular attention to these questions. For each of these questions, you are
in compliance if you answer "Yes" to all parts of a numbered question that have a •. A
"No" answer indicates that you are NOT in compliance.

Other questions address additional steps that you can take to make your shop cleaner and
safer or they may ask you to document operations in your shop. For these questions, what
your answer indicates will be clear or will be explained in the text that follows each particular
question. Additional information for some items is provided in italics afterthe item oryou maybe
directed to other sections of the manual.

Use this checklist to evaluate, improve, and document your compliance. Doing so will help you
demonstrate your good faith effort to comply and improve the environmental, health, and
safety standards of your shop. Here is how to use the checklist:

IRead and understand each item on the checklist. Some items are easy to understand.
Explanations for other items are provided in italics or you may be directed to
other sections of the manual for more information. You also may want to contact the
resources listed in Section 3 of the Toolbox. To comply with an item, you need to understand it
first. Not understanding a requirement is not considered a good reason for noncompliance.

2 Copy and use the checklist. Make blank copies of this checklist before you use it.
Then complete a new checklist roughly each quarter (four times per year). For many
items, a yes or no answer is required. For other items, you may need to collect
documents, complete fill-in-the blank tables, or contact your supplier for help in obtaining
information, before you are able to answer the item yes or no. In some cases, you may be
told to skip an item because it does not apply to you. These are the only items that you
should skip.

3
4

Complete the checklist. Proceed through each item on the checklist until you have
answered and/or completed all of the items. You are now ready to evaluate your
compliance.

Evaluate your compliance. For questions printed in bold and with a •, you are in

compliance if you answer "Yes" to all parts of that question that have a •. You must be
able to document your compliance (for example, if you indicate that you have an occupancy

Collision Repair Auto Shop Welp

WORKBOOK

permit, you must have that occupancy permit at your shop in case an inspector asks for it). Other
questions address additional steps that you can take to make your shop cleaner and safer, or they
may ask for documentation about other operations in your shop. For these questions, what your
answer indicates will be clear or will be explained in the text that follows each particular question.

5 Address noncompliance items. You must work to address any noncompliance items
that you identify. To do this, address the bold (•) items first. By the time you are
finished, you should be able to address all of these checklist items by answering yes and you
should have documentation demonstrating your compliance (unless an item is not applicable to
you). You also should demonstrate your efforts for the non-bold (non-check) items by implementing
the recommendations for best management practices and documenting these efforts.

6 Maintain and go beyond compliance. Now that you are in compliance, you must main-
tain compliance. Complete a checklist each quarter and keep the completed checklist with
your other EHS documents (training records, manifests, and other materials). You also can use
the pollution prevention tips included in this manual to evaluate and implement waste reduction and
money-saving ideas that will move you beyond compliance.

Here's a list of the Permits, Licenses, and Registrations that are commonly required for auto body
shops in Massachusetts. The requirements for your shop depend on the activities that you perform.
A check mark (•) indicates an item that is always required. Items that do not have a • are required
under certain circumstances. For these other items, use the Self-Assessment Checklist to determine
which apply to you.

PERMITS, LICENSES, AND REGISTRATIONS (Always Required = «0

Occupancy Permit

•

Cutting Torch Permit

Oxygen and Acetylene Storage Permit

Flammable Storage Permit

•

Paint Storage Permit

Towing License

Indoor Vehicle Storage Permit (Garage

Permit)

•

Use of Premises Permit (Outdoor Vehicle Storage)

Business Registration with your City or

Town

•

Auto Body Shop License (RS Number)

•

- Surety Bond for $10,000 •

■ Worker's Compensation Policy •

- Appraiser's License •

■ Federal and State Tax Requirements •

Collision Repair Auto Shop Welp

3 Hazardous Waste Registration

- Generator Identification Number and DEP Notification

•

O Fire Prevention Permits

- Ventilation Permit

•

- Spray Enclosure Permit

•

(1 )• Does your shop have an Occupancy Permit from your local Code Enforcement Yes No
Agency? □ □

Your Occupancy Permit must be posted in an easy-to-see location in the shop.

(2) Are cutting torches, acetylene cylinders, or oxygen cylinders stored in your

shop? If No, go to item 3. □ □

•If Yes, does your shop have valid permits from the Fire Department to store
cutting torches, acetylene cylinders, and oxygen cylinders? □ □

$)• Does your shop have a valid Flammable Storage Permit from the Fire Department
so that you may legally store paints, oxygen, acetylene, and other flammable
materials on site? □ □

(4)^ Do you have a valid Paint Storage Permit from the Fire Department? □ □

(5) Does your shop provide a police-ordered towing service? If No, go to item 6. □ □

•If Yes, do you have a valid Towing License from the Massachusetts Division of
Transportation? □ □

(6) Are vehicles stored indoors at your shop? If No, go to item 7. □ □

"Indoor storage" includes having the cars inside to be worked on.

•If Yes, do you have a valid Indoor Vehicle Storage Permit (sometimes called a
Garage Permit) from the Fire Department? □ □

(7) Are vehicles stored outdoors at your shop for more than 30 days? If No, go □ □
to item 8.

•If Yes, do you have a valid Use of Premises Permit from your local Code
Enforcement Agency? □ □

(8)^ Is your shop registered as an auto body repair business with the local City or

Town hall? □ □

S
!!

WORKBOOK

(9)^ Has your shop registered with the State Division of Standards and obtained
an auto body shop license? If Yes, go to item 10.

If No, be sure that you can answer Yes to the following questions before you
contact the Division of Standards to get this required license:

Do you have an Auto Repair Surety Bond for at least $1 0,000?

If your shop employs more than one person or you are incorporated, do you
have a Worker's Compensation Policy?

Does at least one employee in your shop have a Commonwealth Appraiser's
License?

Does your shop have a Federal Tax Identification (ID) number?

Has your shop registered with the Massachusetts Department of Revenue and
obtained a sales tax registration number? □ □

Once you have obtained your auto body shop license (RS Number), it must be
posted in an easy-to-see location in your shop. This license is required to operate
your shop legally.

3.2 AIR REQUIREMENTS

Yes No

□

Yes No

(1 0) Does your shop use less than 670 gallons per month (emit less than 2.5 tons

per month) of VOC-containing materials? If Yes, go to item 11. □ □

If Yes, you may claim an exemption from DEP air permitting requirements if you
can document your material use for the last 12 months and comply with spray
enclosure and coating material requirements (items 12 through 17).

•If No (that is, if you use more than 670 gallons per month of VOC-containing
materials or can not comply with items 1 2 through 1 7) , do you have a DEP Air
Permit and comply with all of its requirements? □ □

If No, contact your nearest DEP regional service center for more information about
the permitting process. See Section 3 of the Toolbox for contact information.

(1 1 ) Has your shop received a DEP Air Emission Statement Package in the mail? □ □
If No, goto item 12.

•If Yes, have you completed and returned the package to DEP by the date
specified? □ □

(12)^ Do you use high efficiency paint spray guns? □ □

High Volume Low Pressure (HVLP) and Low Volume Low Pressure (LVLP) spray
guns fit this criteria and are required by state law.

Collision Repair Auto Shop Welp

If Yes, provide the model name and number:

// No, you are not complying with state law. See the Vendor List in Section 3. 5. 2 of the
Toolbox for information on where to purchase high efficiency paint spray guns. Read
more about high efficiency spray guns in Section 2. 1.2. A in the Workbook.

(1 3)^ Do you train operators in the proper use of the paint spray guns?

If No, contact the manufacturer for information on proper spray gun operation.
When used properly high efficiency spray guns can significantly increase transfer
efficiency so that more paint gets on the part and less is lost to the air. This
saves you money and is required by state law.

(1 4)^ Are spray guns cleaned in a gun washer that (1 ) recirculates solvent for reuse
and (2) collects spent solvent?

If Yes, list the model name and number:

Yes No

□ □

(15)^Do you keep monthly purchase records of coating and surface preparation
products for the last 1 2 months?

You must keep these records for at least the last 12 months. Your paint supplier may
be able to provide you with monthly or yearly summaries of your purchases. This also
will help you document compliance with item 10.

(16)^ Does your shop use only coatings and surface preparation products that
comply with mandated VOC concentration limits?

Coatings and surface preparation products must meet VOC concentration limits.
Lacquer-based coatings (with very few exceptions) do not comply with
Massachusetts regulations. For more information on VOC limits for particular
coatings, see the table on page 2-6 of this Workbook. Remember that the limits
apply to the coatings "as applied", so it is important that they be mixed and
applied as instructed by the manufacturer. This also will help you document
compliance with item 10.

(1 7)^ Do you comply with DEP spray enclosure requirements?

The spray enclosure requirements are:

♦ Exhaust filters must consist of two or more layers of dry fiber mat, with a total
thickness of at least 2 inches. The filters must reduce exhaust spray paint
emissions by at least 97% by weight;

♦ The maximum air velocity at the face of the exhaust filter must not be
greater than 200 linear feet per minute;

♦ Stack construction and performance requirements; (1) exhaust flow must
be vertical and unrestricted by rain protection devices; (2) stack must vent

□ □

WORKBOOK

Yes No

emissions at no less than 40 linear feet per second; and (3) stack height
must be 10 feet above roof level or 35 feet above ground level; and

♦ There may be NO visible emissions from the stack.

(18)^ Do you comply with paint spray exhaust system requirements (items 67-79
of this checklist)?

(1 9) Do you service (repair, alter, evacuate) motor vehicle air conditioning units at
your shop? If No, go to item 20.

•If Yes, are you complying with the requirements described on pages 2-6
and 2-7 of the Workbook?

Basically, motor vehicle air conditioning system service is regulated to control
the release of refrigerants that can harm the ozone layer. You must (1) have
certified equipment and technicians (2) comply with documentation requirements
and (3) follow sale and purchase restrictions to be in compliance with this item.

Much of the wastewater generated by auto body repair shops comes from vehicle
washing. The following questions address steps that you should take to avoid
water pollution problems. section 2 of the workbook (pages 2-8 through 2-
1 0) and Section 1 of the Toolbox (Auto Body Repair Step-By-Step) provide
more information on best management practices for vehicle washing.

(20) Before washing a vehicle, do you sweep the area where you will be washing
the vehicle?

(21 ) Do you check vehicles for fluid leaks before washing them?

(22) Do you contain and collect leaked fluids from underneath a vehicle before
you wash it?

(23) Before washing a vehicle, do you remove as much leaked fluid as possible
from the vehicle using solvent wipes?

(24) Do you use phosphate-free, biodegradable soaps and detergents for
washing vehicles, as much as possible?

(25) Do you use phosphate-based soaps for whitewalls and special uses only?

It is recommended that you spray whitewall tires with phosphate-based soap and
rub with non-rusting abrasive pads, such as nylon. Wash down wheels and tires
after pre-wiping with the phosphate-based cleaner.

(26) Do you minimize the amount of water you use to the greatest extent possible?

Some shops find that high-pressure washing equipment improves cleaning results
while reducing water use.

□ □

Yes No

□

□ □

Collision Repair Auto Shop Welp

(27) Do you wash vehicles outdoors? If No, go to item 28.

If Yes, you should be able to answer yes to the following questions to show
you are making a good faith effort to protect the environment:

Do you use berms to collect wastewater, and run the wastewater through an
oil-water separator to remove oil and grit before discharging it?

Do you wash vehicles away from ground that is not covered by concrete or
other impermeable surfaces?

Do you wash vehicles away from storm drains and manage your wastewater
as described on pages 2-8 through 2-10?

(28) Do you educate your employees on the importance of avoiding surface water
and groundwater pollution?

(29)^Are you sure that you DO NOT discharge any wastewater to (1) a septic
system or (2) groundwater or surface water without a permit?

You should check with your local POTW to determine if it requires the use of
an oil-water separator on your drain to remove oily waste from wastewater
before it enters the sewer.

(30) Does your shop have an oil-water separator?

Oil-water separators (sometimes called oil or grease traps) separate oil and grit
from water. Make sure that you maintain your oil-water separator by removing
floating oil and collected sludge and managing them properly.

3.4 HAZARDOUS WASTE REQUIREMENTS

Hazardous wastes include materials such as used paints, spent solvents, and
solvent- or paint-soaked rags. see the hazardous waste text in section 2 of
the Workbook (pages 2-1 1 through 2-1 6) for more information on determining
if your wastes are considered hazardous.

Generator Status
(31 )• Do you know your hazardous waste generator status? Mark the correct box.

□ Very Small Quantity Generator (VSQG): generate 0 to 26 gallons/month.

□ Small Quantity Generator (SQG): generate 27 to 270 gallons/month.

□ Large Quantity Generator (LQG): generate more than 270 gallons/month.

Yes No

□ □

Hazardous
Waste

Yes No

□ □

WORKBOOK

Yes No

(32)^ Do you know your waste oil generator status? Mark the correct box. □ □

□ Very Small Quantity Generator (VSQG): generate 0 to 26 gallons/month.

□ Small Quantity Generator (SQG): generate 27 to 270 gallons/month.

□ Large Quantity Generator (SQG): generate more than 270 gallons/month.

Your generator status determines how some of the following items impact you. If
you are a VSQG go to item 33 and then 34. If you are a SQG or LQG, go to item
33 and then 35.

(33) Provide waste type information for the following table:

Waste Type Quantity Generated On-site Quantity Disposal

Per Month Accumulated* Method

Solvents

Paints

Sand blast debris

Rags

Spray booth filters

Antifreeze

Waste Oil

* You should indicate the time period over which this quantity was accumulated to help
you keep track of the storage quantities and times you are allowed.

(34)^For VSQGs, does your shop make sure that it meets the maximum allowed

storage/accumulation quantity of three drums at one time? Go to item 36. □ □

There is no storage/accumulation time limit for VSQGs.

(35)^For SQGs, does your shop make sure that it meets the maximum storage/
accumulation quantity limit of ten drums [less than 4,400 pounds (lbs)] and
time limit of 180 days? □ □

Auto body shops generally are not expected to be LQGs. However, if you are a
LQG, make sure that you meet the time period limit of 90 days for storage (there
is no storage/accumulation quantity limit for LQGs).

Collision Repair Auto Shop Welp

Waste Generator Identification and Notification

(36V Does your shop have a permanent twelve-digit EPA generator identification
(ID) number for the generation of hazardous waste?

If yes, provide this number:

If No, and you are a SQG or LQG that disposes of hazardous waste, you must
obtain an ID number before using a hazardous waste transporter. If No, and you
are a VSQG, you do not have to apply for an ID number; however, you must
notify DEP (see item 37) and self-assign a generator ID number (use the prefix
MV and your 10-digit business phone number as your self-assigned VSQG ID
number). For SQGs and LQGs, follow the directions for obtaining a generator
ID number that are included in Section 3 of the Toolbox, or call the DEP
hazardous waste hotline at (617) 292-5898 for help.

(37V Has your shop ever notified DEP of hazardous waste activity?

If No, follow the directions in Section 3 of the Toolbox for notifying DEP or call
the DEP hazardous waste hotline at (617) 292-5898 for help.

(38V Are you able to document that all wastes that are managed as non-hazardous
are properly classified?

If No, you should be able to document how these wastes were determined to be
non-hazardous. For example, you can show that a waste is non-hazardous by
using the information provided in its respective material safety data sheet (MSDS)
or by documenting that no hazardous materials were involved with the generation
of the waste. If you are not sure about a waste classification, call the DEP
hazardous waste hotline at (617) 292-5898 for help.

Yes No

□ □

Hazardous Waste Storage/Accumulation (S/A)

(39V Does your shop have a designated hazardous waste S/A area?

(40V Are non-hazardous waste materials stored separately from hazardous waste?

(41 )• Is your hazardous waste S/A area clearly labeled with a sign with letters that
are at least one inch high that says "Hazardous Waste"?

(42V Are the boundaries of the S/A area distinguishable from other areas and
clearly marked with, for instance, a yellow line or chain?

(43V Is the floor of the hazardous waste S/A area impervious to leaks, without any
cracks, openings, or drains?

(44V If the S/A area is outdoors, is there adequate secondary containment (for
liquid materials)? If not applicable, check here and go to item 46.

□

WORKBOOK

Yes No

Adequate secondary containment for an outdoor liquid hazardous waste S/A
area means having a berm or diked area which will hold leaks or spills that are
10 percent of the total allowed volume of the S/A area (based on your generator
status) or 1 10 percent of the volume of the largest container, whichever is greater.

(45)^ Is your outside hazardous waste S/A area secured against trespassers? □ □

Container Management

(46)^ Are containers of hazardous and non-hazardous waste properly labeled? □ □

"Proper" labeling includes the words "Hazardous Waste" or "Non-Hazardous
Waste" and the name of the waste. Also, list the waste characteristic or code
(such as ignitable, toxic, D002, etc.); and your name, address, and hazardous
waste ID number. The date storage began also is required for SQGs and LQGs.
A sample hazardous waste label is provided in Section 3 of the Toolbox.

(47)^ Are containers of hazardous waste properly closed? □ □

"Properly closed" means that containers are closed tightly so that hazardous
waste does not evaporate or spill.

(48)^ Are containers of hazardous waste in good condition? □ □

"Good condition" means that the containers are not dented, rusted, cracked,
or opened.

Documentation, Transport and Off-site Management

The U.S. Department of Transportation regulates the transport of hazardous materials,

INCLUDING HAZARDOUS WASTE. EPA AND DEP REGULATE THE MANAGEMENT AND DISPOSAL OF
HAZARDOUS WASTE TO PROTECT THE ENVIRONMENT AND HUMAN HEALTH. REQUIREMENTS THAT
IMPACT YOU ARE SUMMARIZED BELOW. A HAZARDOUS WASTE MANIFEST IS THE DOCUMENT WHICH
LOGS THE JOURNEY OF A HAZARDOUS WASTE FROM "CRADLE TO GRAVE". If HAZARDOUS WASTE
THAT LEAVES YOUR SHOP IS DISPOSED OF IMPROPERLY, YOU ARE RESPONSIBLE. THEREFORE, IT IS
IMPORTANT FOR YOU TO KNOW WHERE YOUR WASTE IS GOING AND TO MAKE SURE THAT IT IS HANDLED
SAFELY. IF YOU ARE A VSQG AND SELF-TRANSPORT WASTE, GO TO ITEM 49 BELOW. If YOU ARE A
VSQG AND DO NOT SELF-TRANSPORT WASTE, GO TO ITEM 52. SQGs AND LQGs CAN NOT SELF-
TRANSPORT WASTE AND SHOULD GO TO ITEM 52.

(49)^ If you are a VSQG and you self-transport hazardous waste, do you document

waste generation and management? □ □

VSQGs that self-transport waste do not have to complete hazardous waste
manifests. However, they are required to maintain a list of the waste type, waste
quantity, date of waste transport, and date of waste treatment or disposal.

Collision Repair Auto Shop Welp

(50)^ If you are a VSQG and you self-transport hazardous waste, indicate where
the waste is taken (all facilities used) :

Yes No

You need to document where your waste is taken to prove that you properly
manage the waste.

(51 )• If you are a VSQG and self-transport hazardous waste, do you get and keep

proofs of receipt from the facility that accepts your waste? Go to item 55. □ □

You need to get these receipts to prove that your waste is properly managed.

(52y For SQGs and LQGs (and VSQGs that do not self-transport their waste), do

you have hazardous waste manifests completely filled out and distributed? □ □

See Section 2.1.2.C of the Workbook for more information on how to complete
a manifest and distribute it properly

(53)^ Do you keep your hazardous waste manifests for at least three years? □ □

EPA requires that you keep manifests for three years, but it is a good idea to
keep them indefinitely. Also keep any waste sampling, Exception Report, or
Biennial Report data (for LQGs) for three years (see Section 2.1.2.C of the
Workbook).

(54)^ Do you use licensed hazardous waste transporters? □ □

If Yes, indicate the name(s) of these transporters:

You must use a licensed hazardous waste transporter if you are a SQG or LQG.
All generators must record where their waste is taken. Call the DEP hazardous
waste hotline at (61 7) 292-5898 for a list of licensed hazardous waste transporters
and the waste types that they are licensed to transport.

(55)^Are your hazardous waste containers properly labeled for transport

and disposal? □ □

Containers must be labeled with the words "Hazardous Waste"; the name of
the waste; the type of hazardous waste (such as reactive, corrosive, toxic,
etc.); and your name, address, and generator ID number.

Aboveground Storage Tank (AST) Requirements
(56) Does your shop have an AST?

If Yes, provide the following information:
AST capacity:

□ □

WORKBOOK

Date installed:

Type of waste stored:.

Yes No

• If Yes, does the AST and its containment meet the hazardous waste
storage/accumulation requirements of items 39-48?

Underground Storage Tank (UST) Requirements

(57) Does your shop have a UST? If No, go to item 58. □ □

• If Yes, was the UST installed after 1 989? If Yes, go to item 58. □ □

• If No, does the UST comply with the UST requirements described below? □ □

All USTs that were installed before January 1989 and that are not double-walled
must be upgraded with leak detection devices OR taken out of service by
December 22, 1998. To continue to use an older UST (one that was installed
before January 1989), the UST must have at least ONE of the following spill and
release prevention factors: (1) double walls with interstitial monitoring (see
Definition in Section 5 of the Toolbox), (2) an in-tank monitoring device installed
by a qualified professional (call the State Fire Marshal at the number listed below
for more information), or (3) monitoring equipment that can detect vapors within
the soil gas of the evacuation zone of the UST If you have a UST that was
installed before January of 1989, call the State Fire Marshal at (978) 567-3300
for information on testing your UST for leaks and retrofitting it to meet the new
standards by December 22, 1998.

3.5 HEALTH PROTECTION AND FIRE PREVENTION
REQUIREMENTS

This section of the checklist addresses federal, state and local SAFETY AND HEALTH Yes No

AND FIRE PREVENTION REQUIREMENTS (INCLUDING BUILDING AND ELECTRICAL CODE
REQUIREMENTS) THAT ARE DESIGNED TO ALLOW THE SAFE OPERATION OF SPRAY PAINTING
AREAS AND EQUIPMENT IN YOUR AUTO BODY SHOP (ALSO SEE THE TOOLBOX, SECTION 2).

Occupational Safety and Health Act (OSHA) Requirements

(58)i/ Does your shop have a written Hazard Communication Program that meets

basic OSHA requirements? □ □

See Section 2 of the Toolbox for Hazard Communication Program requirements.

(59)^ Are Material Safety Data Sheets (MSDS) for every hazardous chemical that

you use available to employees in the shop? □ □

See Section 2 of the Toolbox for more information on MSDSs.

Collision Repair Auto Shop Welp

(60)^ Does your shop have a Personal Protection Equipment (PPE) Program that
meets basic OSHA requirements?

See section 2 of the Toolbox for PPE Program requirements.

(61 )• Does your shop have one or more eye wash stations that are properly
maintained?

Eye wash stations should be located within 100 feet of the potential hazard and
should be capable of flushing both eyes for 15 minutes or more.

(62)^ Does your shop use respirators for worker protection? If No, go to item 63.

Most auto body shops will need to use respirators. If you are not sure if
respirators are required for your shop, call the OSHA Consultation Program at
(617) 969-7177.

•If Yes, does your shop have a Respiratory Protection Program (including
medical screening and fit testing) that meets basic OSHA requirements?

If your shop uses respirators, you must implement this program. See Section 2
of the Toolbox for Respiratory Protection Program requirements.

(63)^ Does your shop require a Hearing Protection Program? If No, go to item 64.

If you are not sure if your shop must have this program, call the OSHA
Consultation Program at (617) 969-7177.

•If Yes, does your Hearing Protection Program meet basic OSHA
requirements?

See Section 2 of the Toolbox for Hearing Protection Program requirements.

(64)^ Have personnel that handle hazardous substances and waste, or flammable
or combustible materials, been trained (1) in emergency procedures and (2)
in the safe handling, storage, transfer, and use of the materials?

(65V Do you keep records of the dates and the training provided to personnel?

(66) Does your shop have 1 1 or more employees? If No, go to item 67.

•If Yes, do you keep records of occupational injuries or illnesses, as required
by OSHA? If No, you must maintain these records. Continue with this item.

•Do you have an OSHA 200 log of accidents and incidents posted during the
month of February?

If your shop has 1 1 or more employees, you need to keep records and maintain
this OSHA 200 log all year; you must post the log in your shop during the month
of February each year.

Yes No

□ □

3-13

WORKBOOK

Spray Painting Enclosure and Surrounding Area(s)

Yes No

(67V Does your shop use a spray enclosure to control spray paint in the air? □ □

If No, stop all spraying jobs and install a compliant spray enclosure immediately.
A spray enclosure is required by State Building Code Requirements [780 Code
of Massachusetts Regulations (CMR) 419.0]. See page 2-5 of the Workbook
and item 1 7 for spray enclosure requirements.

(68V Does your spray enclosure have a functioning mechanical exhaust system? □ □

(69V Does your shop have a Spray Enclosure Permit from your local Code

Enforcement Agency? □ □

(70V Is your spray enclosure constructed of fire resistant materials? □ □

Spray enclosure walls must have a minimum of a 1-hour fire resistance rating to
be considered fire resistant.

(71 )• Are fire extinguishers installed near the spray enclosure? □ □

Make sure that extinguishers are appropriate for spray painting-related fires,
and that shop employees are trained in using them.

{72)%/ Are Class II or noncombustible filters used in the spray enclosure system? □ □

{73)%/ Does your spray enclosure have sufficient ventilation to maintain an air transfer

rate of 1 00 linear feet per minute across the enclosure? □ □

NFPA Code 33 requires that spray enclosures be outfitted with exhaust systems
that provide uniform airflow across the width and height of the enclosure. There
are several ways to monitor the velocity of your exhaust system. You may install
and regularly check visible gauges; you may install audible alarms to alert you
when velocity is too low; or you may set up a regular inspection program to
check the condition of the filter surface to avoid use of a clogged filter.

(74V Is electrical equipment located in or near the spray enclosure designed to be

spark proof? □ □

If electrical ventilation equipment (such as a fan motor) is located in the spray
room or booth, it must be explosion-proof and approved for Class I, Division I
locations. Ventilation equipment that is interlocked with spray equipment and
located within 5 feet of the opening of the spray booth or room must be
approved for Class I, Division 2 locations. Ventilation equipment that is not
interlocked with spray equipment and located within 10 feet of the opening of
the spray booth or room must be approved for Class I, Division 2 locations. All
electrical equipment located 3 feet above the spray booth or room or within 3
feet of the opening of the spray booth or room must be approved for Class I,
Division 2 locations. All electrical equipment located within 20 feet of the
opening must be spark-proof.

Collision Repair Auto Shop Welp

(75)^Are "No Smoking" and other hazard warning signs posted in obvious
locations in spray enclosure and surrounding areas?

(76)^ Do you store only a one day supply of flammable or combustible liquids in
your spray painting enclosure and surrounding area?

No more than a clay's supply of flammable or combustible liquids may be
stored in the spray enclosure or surrounding area.

(77)i/ Are the spray painting enclosure and surrounding areas free of fire hazards
from hot surfaces?

No space heating appliances, portable heat panels, steam pipes, or hot
surfaces are allowed in spray painting areas.

□ □

Spray Enclosure Exhaust Stack

(78)^ Is the spray enclosure exhaust stack properly located? □ □

As required by NFPA Code 33, the open end of the stack must end at least 25
feet from any combustible walls or unprotected openings.

(79)^ Are you careful to avoid any complaints from neighbors about paint dust,

odors, or other air pollution coming from your shop? □ □

Flammable Storage

(80)^Are all solvents, coatings, and cleaning materials contained in tightly-
closed containers?

(81) Are you required to use a flammable storage cabinet or room (see below)
for the storage of your flammable liquids? If No, go to item 84.

A flammable storage room is required when certain amounts of flammable
liquids are stored within one "fire area. " A fire area is defined as any part of
the shop separated by a wall that has a one-hour fire resistance rating. It is
unlikely that many auto body shops store enough flammable materials to require
a flammable storage room. However, flammable storage cabinets are required
by OSHA if you store more than 25 gallons of highly flammable material. The
NFPA also recommends the use of a flammable storage cabinet for storing
flammable liquids (up to 60 gallons).

•If Yes, do you use a flammable storage cabinet or room to store your
flammable liquids? Continue with items 82 and 83 below.

□ □

WORKBOOK

Yes No

(82)^ Is the flammable storage room mechanically ventilated? □ □

•If Yes, is the flammable storage room ventilated at a minimum rate of 1

cubic foot per minute per square foot of room area? □ □

Note: Flammable storage cabinets are designed not to be ventilated, while
flammable storage rooms are required to be ventilated.

(83)^ Is your automatic fire system operating properly? □ □

You should test this system as required to make sure that it is operational.

Mixing Rooms

(84)i/When transferring flammable liquids from a drum to a small container for

shop use, do you ground and bond both containers to eliminate static sparks? □ □

Class I and II liquids that are in containers with a volume of 5 gallons or more,
may only be transferred (1) through an opening in the top of the container
using an "approved" pump or (2) through a self-closing valve or self-closing
faucet. Class I liquid transfer equipment also must be grounded and the
nozzle and container must be bonded to one another to prevent ignition due
to static discharge.

(85V Are mixing rooms or areas ventilated at a rate of 1 cubic foot per meter per

square foot floor area? □ □

Fire Prevention, Emergency, and Contingency Planning

(86V Does your shop have a sprinkler system? If No, you need to install one;

continue to item 87. □ □

•If Yes, are sprinkler heads kept unclogged so that they will work if a

fire occurs? □ □

(87V Do you provide emergency training to your employees? □ □

Emergency training is required by OSHA, Code of Federal Regulations (CFR)
1910.38 and 1910.157, and should include items such as fire extinguisher
training, emergency responsibilities, emergency numbers, and how to use MSDS
information. You must document this training. See Section 2 of the Toolbox for
more information.

(88V Are emergency telephone numbers listed by the telephone? □ □

(89V Does your shop have a working fire extinguisher? □ □

(90V Does your shop have a spill control plan? □ □

(91 )• Have you posted emergency information? □ □

You must post the locations of fire extinguishers, alarms, evacuation routes, and
post-exit meeting places.

Internet Archive Audio

Featured

Top

Images

Featured

Top

Software

Featured

Top

Books

Featured

Top

Video

Featured

Top

Mobile Apps

Browser Extensions

Archive-It Subscription

Save Page Now

Full text of "Massachusetts CRASH course project manual : (collision repair auto shop help) [workbook]"

See other formats