do you have everything you need on file?
DESCRIPTION
Do you have everything you need on file?TRANSCRIPT
Required OSHA / EPA Paperwork
Glorianna L. Cooley, REM, CSP
EHS Engineer
April 25, 2013
Do you have everything
you need on file?
Presenter
Glorianna L. Cooley, REM, CSP
• EHS Engineer
• 8+ years in the EHS field
• (614) 432-5044
Regulatory Agencies Requiring Paperwork
Agenda
• Regulatory Site Visit Overview
• OSHA Paperwork
• EPA Paperwork
• DOT Paperwork
– PHMSA Paperwork
• Local City/State Paperwork
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
OSHA Paperwork
• Emergency Response
– Required Written Program
– Annual Required Training
– Evacuation Maps
Do you have what you
need on file? Yes No
OSHA Paperwork
• Hazard Communication
– Required Written Program
– Annual Required Training
– Material Safety Data Sheets (MSDS)
Do you have what you
need on file? Yes No
OSHA Paperwork
• Forklift Safety
– Required Written Program
– 3 Year Required Training
– Equipment Inspections
– Manufacturer Written Approval for Attachments
Do you have what you
need on file? Yes No
OSHA Paperwork
• 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
Do you have what you
need on file? Yes No
OSHA Paperwork
• Required Paperwork
– Bloodborne Pathogens Program
– OSHA 300 Log • http://www.osha.gov/recordkeeping/new-osha300form1-1-04.pdf
– PPE Hazard Assessments
Do you have what you
need on file? Yes No
OSHA Paperwork
• Required Monthly Inspections – Fire Extinguishers
– First Aid Kits
– Eye Wash Stations
– Exit Signs
– Oil Water Separators
• Required Annual Inspections – Fire Suppression Systems
– Automotive Lifts
– Overhead Cranes
– Forklifts Do you have what you
need on file? Yes No
OSHA Paperwork
• Additional Required Training
– Automotive Lift Safety
– Personal Protective Equipment
Do you have what you
need on file? Yes No
EPA Paperwork
• 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
Do you have what you
need on file? Yes No
EPA Paperwork
• 6H Area Source Rule
– Notification of Compliance to the EPA
– 6H Painter Training
– 98% Efficiency Filter Documentation
Do you have what you
need on file? Yes No
EPA Paperwork
• Waste Disposal – Tires
– Batteries
– Used Oil
– Used Oil Filters
– Antifreeze
– Waste Paint
– Paint Booth Filters
– Waste Solvents
– Oil Water Separator Clean Out
– Lead Weights
– Brake Dust
– Aerosol Cans
– Light Bulbs
– Parts Washer Skimmer Do you have what you
need on file? Yes No
EPA Paperwork
• TCLP Test Results
– Oil Water Separator
– Water Based Paint
– Paint Booth Filters
Do you have what you
need on file? Yes No
EPA Paperwork
• SPCC Plan
– Required if more than 1320 gallons
– Requires secondary containment
– Requires SPCC training
– Requires tank testing
Do you have what you
need on file? Yes No
EPA Paperwork
• UST Compliance
– Class A, B, C Operator Training
– Required Maintenance
– Required Testing
Do you have what you
need on file? Yes No
EPA Paperwork
• EPA ID #
• Hazardous Waste Generator Status
– CESQG
– SQG
– LQG
Do you have what you
need on file? Yes No
EPA Paperwork
• Tier II Reporting
– 10,000 lbs of any chemical
– 500 lbs of any extremely hazardous chemical
– Must by filed by March 1st every year to 3 places:
• SERC
• LEPC
• Local Fire Dept
Do you have what you
need on file? Yes No
DOT Paperwork
• Hazmat Shipping
– 3-Year DOT Training
– 24-Hr Emergency Response Phone #
• PHMSA
– 1000 lbs of hazmat in transit requires a Placard
– Must register with PHMSA
– Must carry DOT Emergency Response Guidebook or
MSDS with shipment
Do you have what you
need on file? Yes No
Local City/State Paperwork
• Air Permits
– Body Shops
– Gas Dispensing Facilities
Do you have what you
need on file? Yes No
Facility Inspections
• Now that the inspector has reviewed your
paperwork – let’s take a look in your shop!
