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

Project Man 



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University of Massachusetts 
Depository C,py 

Executive Office of 
Environmental Affairs 

♦ Office of Technical Assistance 
for Toxics Use Reduction 



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


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 





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
























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 


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 



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. 


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 


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 


2.1.3 Health Protection and Fire Prevention Requirements 2-16 

2.2 Pollution Prevention Overview 2-17 


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. 


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 


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 


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 


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 



Massachusetts Crash* Course 

Project Manual 

"(Collision Repair Auto Shop Help) 






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. 


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. 






Collision Repair Auto Shop Welp 


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. 


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. 



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. 



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 


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. 





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 Requirements 1 


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 
law 2 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 guidelines 3 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. 



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 requirements 4 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 law 5 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 

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. 


B. Water Requirements 6 


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 

e 314 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 





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. 



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. 


Collision Repair Auto Shop Welp 

C. Hazardous Waste Requirements 7 

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... 

to 26 gallons of hazardous waste per month 


27 to 270 gallons of hazardous waste per month 


More than 270 gallons of hazardous waste per month 


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

Your generator status is... 

to 26 gallons of waste oil per month 


27 to 270 gallons of waste oil per month 


More than 270 gallons of waste oil per month 


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 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 


• 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). 


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 


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

no specified limit 


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

no more than 1 80 days 


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 



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 gallons 

power steering fluid or automatic transmission fluid greater than 1 gallons 


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) 





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. 


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. 


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 






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 

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. 


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 




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. 





Willi kit II Ilk 



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. 


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 

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 



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. 



Occupancy Permit 



Cutting Torch Permit 


Oxygen and Acetylene Storage Permit 


Flammable Storage Permit 



Paint Storage Permit 


Towing License 


Indoor Vehicle Storage Permit (Garage 




Use of Premises Permit (Outdoor Vehicle Storage) 


Business Registration with your City or 




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? □ □ 









(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 

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. 


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 

□ □ 

□ □ 





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. 


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 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 

□ □ 

□ □ 


Yes No 

□ □ 






Yes No 

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

□ Very Small Quantity Generator (VSQG): generate 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 



Sand blast debris 


Spray booth filters 


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. 














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, 


(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 

(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: 

□ □ 



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. 


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


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 

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 

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 

□ □ 

□ □ 

□ □ 

□ □ 

□ □ 

□ □ 

□ □ 

□ □ 

□ □ 

□ □ 

□ □ 





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. 


□ □ 




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.