florida auto dealers are being targeted by state and county regulators
DESCRIPTION
Florida Auto Dealers are being targeted by State and County RegulatorsTRANSCRIPT
FLORIDA AUTO DEALERS ARE BEING TARGETED BY STATE AND COUNTY
REGULATORS
www.kpaonline.com
(866) 356-1735
Questions
• If you have questions during the presentation, please submit them using the “Questions” feature
• Questions will be answered at the end of the webinar
Introduction from Ted Smith – FADA President
Presented by
Cameron CurtisSenior Account [email protected]
(303) 228-2389
Hannah CrawfordTeam Leader SE
[email protected](303) 228-2389
KPA – Company Profile
Nationwide compliance auto industry expert on Safety, Environmental, HR, and Internet Marketing
Colorado Headquarters
26 Years Experience
451 Clients in FL
4500 + Nationwide Clients– Dealerships, Service,
Repair, Collision Centers
Compliance products and services– OSHA– DOT– EPA– Workers’ Comp– Background checking– Onboarding– Harassment – Red Flags– Onsite inspections– Online and onsite training
and tracking– And many more…
In the press: “Red Tape Rising”
• Jan 22nd 2011 Article from The Economist – “Red Tape Rising”
• 167% Increase in Workplace Safety Violations
• 16% Increase in regulatory workforce
• Millions dumped into OSHA/EPA – “Foot Soldiers”
• Fines can range from 3.5K-90K
“New Sheriff in Town”
- Quote from Labor Secretary, Hilda Solis:
“OSHA received over 100 inspectors in our 2010 budget, as well as an additional 25 requested in 2011. We are also moving 35 inspectors from compliance assistance activities to enforcement….There’s a new Sheriff in town.”
- President Obama’s 2010-2011 Budget:• $69 million increase for worker protection
programs• Hire 180 new inspectors and investigators
Inspections on the Rise
Florida Inspections Over the Last 5 Years
2008 2009 2010 2011 2012
FDEP 33 63 111 129 114
OSHA 5 3 20 23 13
• 400% Increase in Inspections from 2008 to 2011
Who is Inspecting your Dealership?
1. FDEP Divisions• Storm Water• Storage Tanks• Air Quality• Hazardous Waste
2. OSHA
3. DOT/FAA/TSA
The Inspector Comes Knocking…
FDEP DISTRICT MAP
• EPA Delegation
FDEP: Storm Water Division - What are they looking for?
• Car wash runoff• Oil/water separator connections
and maintenance• Septic tanks• Storm drains
FDEP: Storage Tanks Division - What are they looking for? (con’t..)
• Registered storage tanks• >550 aboveground• >110 underground
• Overfill prevention• Tank condition• Paperwork
• Insurance• Release Detection Response Level
FDEP: Air Quality Division - What are they looking for? (con’t..)
• 6H
FDEP: Hazardous Waste Division - What are they looking for? (con’t..)
• Housekeeping• Container management• Employee training• Waste disposal and tracking
Common Waste Streams
Used Oil/Filters/Coolant/Gasoline:1. Used ATF, oil/synthetics
2. Used oil/fuel filters
3. Used antifreeze
4. Contaminated gasoline
Not hazardous waste if recycled.
Common Waste Streams
Parts Washers:
1. Drum filled
2. Recycling
3. Hot/aqueous parts washers
4. Brake Washers
5. Continued Use Programs
6. Smart/SafeWashers
MAY BE HAZARDOUS WASTE!
Common Waste Streams
Paint/Thinner Waste:1. Waterborne
2. Solvent-containing
3. Recyclers – “hockey pucks”
MAY BE HAZARDOUS WASTE!
Common Waste Streams
Paint Booth Filters:
May be hazardous waste, especially if using paint containing heavy metals.
Common Waste Streams
Universal Waste:1. Batteries
2. Fluorescent lamps
3. E-waste
Not hazardous waste if recycled.
Common Waste Streams
Tires:Many states have specific tire storage
regulations – how many, where they are stored, how they are stored
Common Waste Streams
Shop Towels, Paper Towels:
1. Can be laundered at a facility connected to a POTW
2. If not laundered, must be collected as a hazardous waste if contaminated with a toxic, F002, or F005 chemical
Common Waste Streams
Wheel Weights:Lead-containing wheel weights are hazardous
and must be recycled or disposed of as hazardous waste.
Not hazardous waste if recycled.
Common Waste Streams
Oil/Water Separators:Sludge must be tested or presumed hazardous.
MAY BE HAZARDOUS WASTE!
Common Waste Streams
Brake Dust:Some states consider dust
from the lathe to be potentially hazardous, depending on the content of your rotors. At a minimum, dust should be collected neatly in a bin.
Common Waste Streams
Aerosol Cans:
1. May be thrown in trash if completely empty of product AND propellant
2. May be punctured with an approved device only – waste must be captured
MAY BE HAZARDOUS WASTE!
SUMMARY – OSHA TOP 10
FEDERAL ONLY
OSHA – WHAT ARE THEY LOOKING FOR (CON’T..)
HAZARD COMMUNICATION
-Written Program
-Chemical Inventory
-Material Safety Data Sheets
-Container Labeling
-Employee Training
EMERGENCY RESPONSE
-Fire and Explosion
-Facility Evacuation
-Spill Response
-Chemical Overexposure
-Natural Disasters
EXAMPLE EMERGENCY EVACUATION MAP
PERSONAL PROTECTIVE EQUIPMENT
• Hazard Assessment
• Employee Training
RESPIRATORY PROTECTION
-Written Program
-Medical Evaluations
-Fit Testing
-Training
-High Liability
HOW WILL YOU FARE?
Required Documentation:• Haz Comm (training)• Emergency Resp – (training)• PPE (training)• RPP (for paint work) / (training)
Physical Shop Compliance:• Stored Properly/Labeled Properly• Safety Hazards• Lifts Inspected• Monthly self inspections conducted?
DOT, FAA, TSA – What are they looking for (con’t..)
DOT Hazmat Certification
DOT Hazmat Certification Compliance
Penalty Policy: “When the violation is a continuing one, each day of the violation constitutes a separate offense” DO NOT SHIP HAZMATS VIA AIR
DOT Hazmat Certification
• Online training.• Certification required every 3-years.• New employees within 45-days of
employment.• 24-hour phone number on shipping papers.• Post certifications.
How to handle an Inspection
1. Don’t Panic – Welcome
2. Escort to Management
3. Clear your Schedule
4. www.mykpaonline (Call your Engineer)
5. Document
6. Answer Questions
7. Paper Review
8. Get an Out-Brief
FACILITY COMPLIANCE & SAFETY EVALUATION
Evaluation By KPA• Written Programs
• Training Records
• Compliance Issues
• Shop Issues
Webinar or Onsite
Formal Report• Summarizing Areas of Opportunity
KPA’S COMPLIANCE SYSTEMS
QUESTIONS?
FREE CONSULTING TIME!!!
