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What you need to know about OSHA, EPA, and DOT Compliance
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Equipment Dealers:
What you need to know about
OSHA, EPA, and DOT Compliance
February 5, 2013
Speakers
Zach Pucillo, CSP
EHS Engineer
8+ years in the EHS field
(317) 201-2335
Glorianna Cooley, REM, CSP
EHS Engineer
6+ years in the EHS field
(614) 432-5044
Joseph (Joe) R. Dykes
Director, Member Services
NAEDA
Joseph R. Dykes is Director of Member Services for the North American Equipment Dealers Association (NAEDA). Previously he also was Executive Vice President of the NAEDA-affiliated Mississippi Valley Equipment Association (MVEA), a position he held since 1990. The board of directors of MVEA voted to dissolve its association in March 2011. Dykes joined the NAEDA staff in May 2008 serving as the Director of Outdoor Power Equipment Programs in addition to being the Executive Vice President of MVEA. As director of Member Services, Dykes is responsible for all liaison activities for NAEDA program partners and researching, developing and implementing new partner programs. He is also responsible for all promotional activities and for working with the various program partners, dealers and supporting affiliate associations to ensure effective, ongoing program success. Prior to joining MVEA, Dykes was employed with the American Soybean Association, headquartered in St. Louis, Mo. He graduated from Illinois State University in 1980 with a bachelor’s degree in agribusiness. Dykes and his wife, Mickey, have three children, Matthew, Brian and Katie. Dykes can be reached at 636/349-6205 or [email protected].
The North American Equipment Dealers Association is based in Fenton, Mo. It provides educational, financial, and legal assistance, as well as legislative services to approximately 5,000 dealers in the United States and Canada.
Agenda
Common Violations at Equipment Dealers
OSHA Regulations
EPA Regulations
DOT Regulations
Regulatory Site Visit Overview
Common Violations at Equipment Dealers
Safety Regulations
Emergency Response– Required Written Program– Annual Required Training– Evacuation Maps
Safety Regulations
Hazard Communication(#1 Cited OSHA Violation)– Required Written Program– Annual Required Training (NEW GHS by 12-1-13)– Safety Data Sheets (SDS)– Chemical Inventory– Container Labeling
Safety Regulations
Powered Industrial Truck Safety– Required Written Program– 3 Year Required Training (Onsite)– Equipment Inspections– Manufacturer Written Approval for Attachments
Safety Regulations
Fall Protection– Fall Protection Equipment Selection– Equipment Inspections– Employee Training
Safety Regulations
Respiratory Protection– Required Written Program– Annual Required Fit Testing & Training– Medical Evaluations– Voluntary Use App D Forms
• http://www.osha.gov/SLTC/etools/respiratory/voluntaryuses.html
Safety Regulations
Confined Space Requirements– Confined Space
• Limited or restricted means for entry or exit and not designed for continuous occupancy
– Permit Required Confined Space• Hazardous atmosphere• Engulfment hazard• Trapped or asphyxiated• Or any other serious hazard
Safety Regulations
Required Paperwork– Bloodborne Pathogens Program
• http://www.kpaonline.com/assets/media/bbp/bbp-assessment.html
– OSHA 300 Log• OSHA 300A Summary Posted Feb 1-Apr 30• http://www.osha.gov/recordkeeping/new-osha300form1-1-04.pdf
– PPE Hazard Assessments– Required Monthly & Annual Inspections
Safety Regulations
• Key Lockout Program– Written Program– Equipment Selection– Training Documented
Environmental Regulations
Refrigerant Recovery & Recycling– Register all AC Machines with the EPA
• http://www.epa.gov/ozone/title6/609/mvac_cert_form.pdf
– All Technician AC Cards on file
Environmental Regulations
6H Area Source Rule
– Notification of Compliance to the EPA– 6H Painter Training– 98% Efficiency Filter Documentation– HVLP Spray Equipment
Environmental Regulations
Waste Disposal – Tires– Batteries– Used Oil– Used Oil Filters– Antifreeze– Waste Paint– Paint Booth Filters– Waste Solvents– Oil Water Separator Clean Out– Aerosol Cans– Light Bulbs
Environmental Regulations
Hazardous Waste Determinations– TCLP Test Results
• Oil Water Separator• Water Based Paint• Paint Booth Filters
– Generator Knowledge• Ignitable• Corrosive• Reactive• Toxic• Listed
Environmental Regulations
Hazardous Waste– EPA ID #– Container Compliance– Manifests– Hazardous Waste Generator Status
• CESQG (<220lbs month)• SGQ (220-2200lbs month)• LGQ (>2200lbs month)
Environmental Regulations
SPCC Plan
– Required if more than 1,320 gallons– Written plan– Secondary containment– SPCC training– Tank testing
Environmental Regulations
UST Compliance– Class A, B, C Operator Training– Required Maintenance & Testing– Financial Responsibility– UST Permit
Environmental Regulations
Tier II Reporting
– 10,000 lbs of any chemical– 500 lbs of any extremely hazardous chemical– 1600 gal gas, 1400 gal diesel, 100 used batteries, 1075 gal antifreeze, 1550 gal new
oil, 1550 used oil if burn in furnace (any given time – not related to tank capacity)
– Must by filed by March 1st every year to 3 places:• SERC• LEPC• Local Fire Dept
Department of Transportation
Hazmat Shipping
– 3-Year DOT Training– 24-Hr Emergency Response Phone #– Drug & Alcohol Driver Supervisor Training
PHMSA– 1000 lbs of hazmat in transit requires a Placard– Must register with PHMSA– Must carry DOT Emergency Response Guidebook or
MSDS with shipment
Regulatory Site Visit Overview
Introduce inspectors to applicable managers
Find out the purpose of the inspection
Have safety/environmental records ready
Escort them through the appropriate area
Have a closing conference
Questions? Contact us at………
www.kpaonline.com
Zach Pucillo, CSP
EHS Engineer
(317) 201-2335
Glorianna Cooley, REM, CSP
EHS Engineer
(614) 432-5044
