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1 RI Auto Body Repair Facilities Certification Program Environmental and Occupational Health Compliance RI Department of Environmental Management Office of Technical & Customer Assistance
2 Certification/Environmental Results Program Best applied in sectors where uniform enforcement is difficult to achieve: - Auto body industry - Auto salvage yard facilities - Exterior lead paint removal contractors - Underground storage tanks
3 Auto Body Industry Fewer than 350 shops in Rhode Island (2006); 1,600 tons VOCs Mostly small business: Average of 5 employees; 60% of shops employ 4 people Average of 5 vehicles per week Under-regulatedregulated *N National le Estimates te ~60,000 facilities nationwide $26 billion industry >450,000 people 286,000 tons of VOC s
4 RI Auto Body Repair Facilities Certification Program Participation in program is voluntary First round of certification checklists submitted in 2003, second round submitted in 2006 Shops self-certify to RIDEM/OTCA that they are complying with environmental and occupational health protection requirements All auto body facilities operating in the State of Rhode Island must comply with the standards, whether or not they self-certify
5 RI Auto Body Repair Facilities Certification Program Incentives to participate: - Reduced inspection priority for participants - Opportunity to come into compliance without fear of enforcement action and gravity based penalties - RIDEM/URI/RIDOH technical & compliance assistance - Random regulatory inspections for non-participants
6 RI Auto Body Repair Facilities Certification Program Three Major Components: 1. Compliance Certification - clear standards, accountability, self-evaluation evaluation 2. Performance Measurement - statistically-based, inspections & enforcement 3. Technical/Compliance Assistance
7 RI Auto Body Repair Facilities Certification Program 1. Compliance Certification: Components: Certification Workbook Self-Certification Checklist
8 Auto Body Certification Workbook Explains regulations (in plain language) Designed to be used in conjunction with the accompanying self-certification checklist, and to be used as a reference in the facility
9 Auto Body Certification Workbook Major Contents: Air Issues Water Pollution Control Hazardous Waste Pollution Prevention Worker Health and Safety Sample Plans
10 Certification Checklist The checklist contains a series of compliance questions, which generally require yes or no answers about whether or not the facility is following applicable environmental and occupational health and safety requirements
11 Checklist confirms compliance status Self survey - used to determine where to make improvements Required to submit checklist and RTCs to RIDEM/OTCA Failure to submit by a designated date may result in inspection Certification Checklist
12 Auto Body Industry - Certification Example of checklist questions:
13 2. Performance Measurement Statistics used to measure change Baseline - 40 out of 400 shops randomly selected and visited; average compliance rates determined After self-certification completed, another 40 shops randomly selected and audited or inspected for compliance status Before and After comparisons made to determine program effectiveness
14 3. Technical Assistance Participating shops may need assistance to comply with regulations (on-site, telephone, ) URI and RIDEM/OTCA provide free consultation to help correct problems, such as: Facility modification for wash water Drum labeling and management Companies still need to spend time and money, but costs can be minimized with technical assistance
15 Example of a Return-to to- Compliance Plan (RTC) Submitted (Authorized Agents)
16 Example of a Return-to- Compliance Plan (RTC) Submitted (Employee Medical Exams)
17 2003 Results 367 RI DBR auto body shop licensees 171 completed checklists returned 15 businesses filed Facility Non- Applicability Statement 51% response rate 282 Return-to-Compliance Plans w/ checklists filed with RIDEM/OTCA
18 RI Auto Body Repair Facilities Certification Program Table IV. Summary of baseline and post-erp implementation filed audit data. EBPI Baseline Post-ERP* % Compliance % Compliance %Improvement 1 Manifest tracking Accumulation label 25 55** 30** 3 Secure area Authorized agents 28 63** 35** 5 Methylene chloride usage Enclosed gun cleaners ** 17** 7 Unpermitted floor drains 24 67** 43** 8 Wash water runoff Discharge signage Safety/health poster Haz Com program PPE program Respiratory protection program Lockout/tagout program % Compliance = proportion of shops in compliance at baseline or post-erp implementation p p p p p p p * OTCA + OC&I post-erp participant and non-participant data for statistically significant EBPIs combined. ** Statistically significant OTCA ERP participant data only (i.e., combined data did not achieve statistical significance).
19 2006 Results 336 RI DBR auto body shop licensees 140 completed checklists returned 5 businesses filed Facility Non- Applicability Statement 43% response rate 94 Return-to-Compliance Plans w/ checklists filed with RIDEM/OTCA
20 RI Auto Body Repair Facilities Certification Program Other industry sectors being pursued: Underground Storage Tanks Auto Salvage Yard Facilities Exterior Lead Paint Removal Contractors Hospitality Green Certification
21 Contact Information RI Department e t of Environmental Management age e Office of Technical & Customer Assistance 235 Promenade Street Providence, RI Tom Armstrong Telephone: (401) , Ext thomas.armstrong@dem.ri.gov Fax: (401) RIDEM Auto Body Web Address:
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