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 walkthrough. 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. Lance, Soll & Lunghard, LLP | CPAs & Advisors | lslcpas.com | (714) 672-0022 Brea Sacramento “We have a fantastic relationship with the LSL team. They keep our interests top of mind and maintain a positive reputation in the industry.” Santa Ana -Craig Whetter, President, David Wilson Automotive Group (relationship since 1983) Donald Slater, CPA Automotive Services Partner donald.slater@lslcpas.com Mike Mangold, CPA Automotive Services Partner mike.mangold@lslcpas.com David Myers, CPA Automotive Tax Partner dave.myers@lslcpas.com
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