• Ensure all hazardous material containers (oil quarts, coolant containers, etc.) are completely empty (drip-dry) prior to disposing in the trash. Aerosol cans, i.e., must also be completely empty. • Ensure all waste caddies are labeled for their content and disposition/disposal, i.e., “Waste Oil — Empty Daily” or “Waste Coolant — Empty Daily.” • Ensure all waste containers 55 gallons or greater have secondary containment. Also, ensure containment is kept clean. Waste Tank Structural Assessment (Title 22): Waste tanks need a structural assessment conducted by a registered Professional Engineer (PE) every five years. Facilities generating less than 1000 kg/month of waste are exempt from this requirement. Keep the tank report accessible. Spill Prevention Control & Containment Plan: Facilities with petroleum products storage exceeding 1,320 gallons must have a current Spill Prevention Control & Countermeasure Plan (SPCC). Conduct DAILY inspections of the aboveground storage tanks. Maintain log(s) for a minimum of three years for recordkeeping. The plan must be renewed every five years. Waste Disposal Paperwork (and Manifest): Maintain all waste manifests for hazardous waste pick-up docs on site for three years. When a hazardous waste manifest is generated, copy the manifest and mail the copy to DTSC Generator Manifests, Department of Toxic Substances Control, P.O. Box 400, Sacramento, CA 95812. Once a signed copy is received from the TSDF, match the signed copy to the original manifest copy. The six-page manifest is expressly required for waste streams such as contaminated gasoline and waste brake fluid. Used oil and used coolant are exempt from the six-page manifest process. To read the Hazardous Waste Manifest Information, scan the QR code. https://dtsc.ca.gov/hazardous-waste-manifest-information Universal Waste Considerations Common Universal Waste: Includes any electronic device that is hazardous waste, such as computers, televisions, VCRs, stereos, copiers and fax machines. Other wastes such as household-type batteries, electric lamps, non-empty aerosol cans, cathode ray tubes and mercury switches are considered universal waste. Federal Exemptions: In 2011, the U.S. EPA created an exemption for businesses that generate a combination of hazardous waste (Resource Conservation and Recovery Act [RCRA] wastes) and universal waste in an amount of less than 100 kg/month. California has enacted regulations that require all facilities, without any exemptions, to recycle all universal waste. Key Personnel Service Manager: The Service Manager and other managers must be on top of environmental issues that arise in CUPA inspections. It is critical to establish processes as follows: • What are the duties of the management staff regarding hazardous waste compliance? • Who completed training on hazmat (including an annual refresher) and emergency response, and where are the documents maintained? Where is it kept for easy access? • Facility Inspection: The Service Manager or another department manager must accompany the inspector on the annual walk-through. Notice of Violations (NOV), if any are issued, must be corrected in the established time frame. Who is responsible for completing the tasks noted on violations? The penalties occur when the NOV goes unanswered. Some dealerships change managers often, and new managers fail to address the pending violations in a timely manner. Establish a process that requires the General Manager to be copied on any violations that are handed to the dealership. The General Manager should monitor and ensure the correction of violations. CSI must be copied on the violation as well. DISCLAIMER: The contents of this newsletter are for informational purposes only and are not to be considered legal advice. Employers must consult their lawyer for legal matters and EPA/OSHA consultants for matters related to Environmental, Health & Safety. The article was authored by Sam Celly of Celly Services, Inc. who has been helping automobile dealers in Arizona, California, Hawaii, Idaho, Nevada, New Mexico, New York, Texas and Virginia comply with EPA and OSHA regulations for over 35 years. Sam is a Certified Safety Professional (No. 16515) certified by the National Board of Certified Safety Professionals. Sam received his BE (1984) and MS (1986) in Chemical Engineering, followed by a J.D. from Southwestern University School of Law (1997). Sam is a member of the American Chemical Society (No. 31176063), American Industrial Hygiene Association (No. 124715), and National Association of Dealer Counsel (NADC). Sam also serves on the Board of Orange County American Industrial Hygiene Association and on CA Industrial Hygiene Council (CIHC). Our newsletters can be accessed at www.epaoshablog.com. We welcome your comments/questions. Please send them to sam@cellyservices.com. 13
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