FAQs: Essential EHS Compliance Questions Answered

Paperwork

What written plans am I required to maintain for my business?

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This will vary based on the type of business that you are in and where you are located in the United States. The most commonly required plans are as follows: Hazard Analysis, Hazard Communication, Respirator Program, Emergency Action Program, Injury & Illness Prevention Program, OSHA Recordkeeping, Lockout Tagout, Forklift Program, and Hazard Material Business Plan

What do I need to document for a training class to be compliant?

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Documentation must include an agenda of what was reviewed, a signed attendance sheet from employees, and a date the training occurred.

How long do I need to keep medical evaluations and fit testing records?

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There isn’t a requirement for these records beyond current employees, however we believe it to be good practice to keep these records indefinitely.

I have an AC Machine for refrigerant recovery and recharges. What do I need to do?

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You must register the machine with the EPA and have any employee that uses it certified. We can help, click here for more information.

How long do I need to keep MSDS records?

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30 years

How long do I need to keep waste manifests?

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3 Years

How long is a forklift certification good for?

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3 Years

How often do I need to complete a booth filter test?

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A booth filter test is not a requirement if the business would prefer to dispose of the filter media as Hazardous Waste. However, this tends to be more expensive. A new test will only need to be completed if the chemicals being used change.

Regulatory Requirements

How often do I need to make a Job Hazard Assessment?

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OSHA requires this to be completed every year.

How long do I need to keep my OSHA 300 Logs?

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5 years

When do I need to post my OSHA 300A Summaries?

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February 1st through April 30th of every year in a common area for all employees such as a break room.

What permits, licenses, and reports am I required to maintain?

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This will vary based on the type of business that you are in and where you are located in the United States.

Posters &Logs

Am I required to post the Federal and State labor posters (i.e. minimum wage and discrimination)?

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This will vary based on the type of business that you are in and where you are located in the United States.

Am I required to get a new labor poster every year?

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This will depend on regulations that may change every year. Some “poster companies” will tell you they made changes to the form and you need a new one, but if the content from a regulation and law standpoint did not change, you are in compliance even though it may have been purchased a few years ago.

When do I need to post a No Smoking sign?

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These need to be posted in all immediate areas of flammable chemicals.

When do I need to post a No Exit sign?

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If there are any doors in your facility that do not lead to an exit that could be mistaken for an exit, you will need a No Exit sign. If the door is marked as a bathroom (for example), you do not need a No Exit.

How often do I need to complete an inspection of the eye wash?

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For plumbed units, weekly. For manufactured units, you will use the recommendation from the manufacturer (most suggest weekly).

How often do I need to check my hazardous waste stations?

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Weekly

How often do I need to check my fire extinguishers?

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Monthly

How often do I need to document my respirator and booth filter change-outs?

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As they occur with indications of which respirators and/or filters were changed out (i.e. Exhaust vs. Floor)

How often do I need to inspect Lineman’s Gloves?

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Every 6 months

How often do I need to inspect the Forklift?

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Daily

Body Shop

What are the requirements for an eye wash station?

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Click here for complete requirements

What are the requirements for secondary containers (i.e. spray bottles, squeeze bottles)?

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Any secondary container must be clearly labeled with the name of the chemical, name of the manufacturer, and any hazard warnings or HMIS information. This includes spray bottles of water.

What is the minimum amount of first aid that I’m required to keep on hand?

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This will depend on the type of business that you are in and the various operations that are being performed. We can help with a job hazard assessment to give you the minimum requirements per ANSI standards. Contact us for more information.

What do I need to check for when I’m inspecting my extinguishers?

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An extinguisher must be mounted, accessible with 36″ clearance, be tagged for service within the last 12 months, pin in place, must have a sign indicating its location, and must be in the green on the gauge.

What are my requirements for emergency exits?

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An emergency exit must be unlocked during business hours, free of obstructions in the immediate area, and have an illuminated EXIT sign above it.

What are my requirements for electrical panels?

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An electrical panel must have 36″ of clearance in the immediate area, be unlocked, doors closed, no open spaces for breakers, and all breakers must be clearly labeled.

What are my requirements for compressed gas cylinders?

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All gas cylinders must be stored upright, secured to prevent tipping, capped, and oxygen and acetylene separated by 20 feet. This applies even for empty gas cylinders, however it does not apply if the cylinders are currently “in use” by being on a welder or cart.

Fire Safety

What do I need to check for when I’m inspecting my extinguishers?

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What are my requirements for emergency exits?

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An emergency exit must be unlocked during business hours, free of obstructions in the immediate area, and have an illuminated EXIT sign above it.

What are my requirements for electrical panels?

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An electrical panel must have 36″ of clearance in the immediate area, be unlocked, doors closed, no open spaces for breakers, and all breakers must be clearly labeled.

What are my requirements for compressed gas cylinders?

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Paint Equipment

What are my requirements for a mix room?

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A mix room must have 4″ spill containment, be an enclosed room, have explosion proof wiring for electrical equipment, have a sprinkler or fire suppression system, have adequate ventilation, have a light and fan on a switch, and the door must remain closed at all times except when entering or leaving the room.

What are my requirements for a 6H compliant prep station?

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A prep station must have a roof, 3 side walls or curtains, curtains that extend from the roof to the floor, and the air is drawn into the area (curtains will pull slightly inward).

What are my requirements for a paint booth?

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This will vary depending on your location. It is best that you review this with a local paint booth vendor or contractor.

What are the requirements for secondary containers (i.e. spray bottles, squeeze bottles)?

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Any secondary container must be clearly labeled with the name of the chemical, name of the manufacturer, and any hazard warnings or HMIS information. This includes spray bottles of water.

Can I spray thinner or gun cleaner to clean a spray gun?

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You will not be in compliance with 6H-NESHAP in this instance.

What are my requirements for a gun washer?

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The gun washer must remain closed at all times unless in active use and be exhausted outside.

Car Wash

What are the requirements for secondary containers (i.e. spray bottles, squeeze bottles)?

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Any secondary container must be clearly labeled with the name of the chemical, name of the manufacturer, and any hazard warnings or HMIS information. This includes spray bottles of water.

What are my requirements for GFI outlets?

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The rule of thumb is that if there is a regular presence of water (i.e. car washing) than any outlet that may be used by the employees in the area must ground fault protected. This would include an outlet that may be somewhere else, but accessed by an extension cord.

What are my drainage requirements?

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This will vary by the types of chemicals that are being used and where you are located in the United States.

Waste

What are the common hazardous wastes that are likely in my body shop?

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Liquid paint waste, solid paint waste, thinner waste, used oil, used antifreeze, shop rags, shop dust, and paint booth filters are the most common.

What are my requirements for spill containment?

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If you are storing a chemical that requires spill containment, the best rule of thumb is that the containment must be equal to or greater in capacity than the largest container that you have stored on the containment (i.e. a 55 gallon drum needs at least 55 gallon containment).

What are my requirements for paint booth filters?

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If you have not had them tested and certified as non-hazardous, then they must be disposed of as hazardous waste with a licensed transporter and disposal facility. We can help you get them tested. Once they are certified non-hazardous, you can discard them in your general waste streams. Click Here to learn more.

What do I do with fluorescent bulbs?

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These can’t go into the trash. They must be disposed of as Universal Waste. We recommend taking them to a local hardware store for disposal (i.e. Lowe’s).

Can I throw away hardened paint into the dumpster?

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No. All paint products must go into a liquid paint waste drum before the PPS liner or cans are thrown into the general waste streams. If you have hardened paint from recycling your thinner, then the solid waste must be disposed of as hazardous waste.

Personal Protective Equipment

What types of safety equipment must be worn for a detailer?

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Most likely safety glasses and chemical resistant gloves depending on job responsibilities.

What types of safety equipment must be worn for a buffer?

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Most likely safety glasses, chemical resistant gloves, and a respirator depending on job responsibilities.

What types of safety equipment must be worn for a welder?

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Most likely a UV mask, leather gloves, and a respirator depending on job responsibilities.

What types of safety equipment must be worn for a body tech?

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Most likely safety glasses, chemical resistant gloves, cut resistant gloves, ear plugs, steel toed boots, and a respirator depending on the job responsibilities.

What types of safety equipment must be worn for a painter?

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Most likely a shoot suit, chemical resistant gloves, safety glasses, and a respirator depending on the job responsibilities. A painter must also wear a fresh air intake system or PAPR system that would take the place of a respirator.

NESHAP 6H

What happens if I have started a new shop in the last two years and I have not submitted the Initial Notification or Compliance Certification?

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The Rule requires that shops opened after September 17, 2007 to be in full compliance with the rule as of January 9, 2008. These shops are considered “new sources” and if they are not in compliance with the rule they can face penalties. Pursue Compliance Certification and submit as soon as possible.

What if I haven’t submitted the Initial Notification that was due in January 2010?

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You are in violation of the Rule. Submit the Initial Notification as soon as possible.

Can the EPA shut my shop down if I am not in compliance when they come in or is there a window of opportunity to fix the problem after I get caught?

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While EPA may not specifically “shut down” a shop, they can impose fines that may be difficult for a small business to cover.

Can a painter be fined for working in a shop that is not in compliance or just the shop owner?

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The ultimate responsibility for compliance with the rule is on the owner of the shop, not the individual painters.

What are key requirements for an approved spray booth? Prep station?

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Spray booths for spray painting vehicles must be fully enclosed and be ventilated at negative pressure or up to 0.05 inches water gauge positive pressure. Booths must have seals on all doors and other openings and an automatic pressure balancing system.

Prep stations for spray painting parts off of vehicles must have a full roof, at least three complete walls or side curtains (up to the roof). They must be ventilated so air is drawn into the prep station.

Do I have to do all painting and priming in the booth if I don’t have a prep station or prep area set-up the right way?

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All spray priming and painting must be done in an appropriate booth or prep station.Parts can be primed and painted in an approved prep station. Vehicles or parts on a vehicle must be sprayed in an approved booth.

When re-doing a prep station that is currently not to code (lights, electrical, and motor) does it have to be brought up to code, or do you just have to do just what the EPA wants, and not worry about anything else? For example, if it is a room with three walls and a pull down door, does it still need a top?

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The federal rule is silent on code issues as those can vary at the local level. However, compliance with the federal rule is NOT an excuse to disregard local code or safety requirements which still apply as do all applicable OSHA requirements.

A room with three walls and a pull down door may be considered a booth, but it must also meet the filter requirements and must function as a booth (with no storage of extra parts, old materials, etc.) The room’s ceiling may then function as the roof of the booth.

If all I do is sand in the prep station, do I still have to install a roof and sides?

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No, the rule only applies to “spray application” of products, so sanding is not a covered activity under this rule.

Can I paint a fender on a vehicle in my spray booth? How about parts?

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Parts attached to the vehicle can only be sprayed in your spray booth. Any part not attached to the vehicle may be sprayed in either an approved prep station or the spray booth.

What are key requirements for an approved spray booth? Prep station?

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What are the painter training and certification requirements?

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The EPA’s NESHAP 6H regulation has specific painter training requirements that must include:

Spray gun selection, set-up, and operation
Techniques to improve transfer efficiency and minimize overspray
Routine spray booth and filter maintenance
Filter selection and installation
Proper spray gun cleaning
NESHAP compliance requirements

Required hands-on training must include the following:

Successful completion of content training
HVLP or equivalent gun usage
Proper mixing of materials
Spray gun set-up, usage, and cleaning consistent with training and regulation
Spraying only in booth and / or approved prep station
Proper spray techniques
Booth maintenance procedures implemented and documented

Owner / Operator Certification:

We recommend that this hands-on training be done as part of the painter training certification in the shop. This certification must be signed only by the owner / operator of the business, not a paint company, jobber, equipment supplier, EnviroSafe or other vendor. Details on certification are found in EnviroSafe’s NESHAP Manager’s Handbook.Please note that the NESHAP painter training requirements are distinct from the 60-Minute Annual Compliance SP2 Training requirements. Painter training must be refreshed and certified by the owner/operator every 5 years.

What happens if I don’t have the paper work that shows how I have certified my people and I just fill in and sign the log?

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The owner or operator of the shop is the responsible party under the requirements of the federal rule, and paperwork and recordkeeping are part of the rule requirements. It is important to maintain all records in a location that is easily accessible if an inspector comes to your shop. If you do not have the necessary recordkeeping and documentation you can be found to be in violation of the rule and can face penalties.

Frequently Asked EHS Compliance Questions

Paperwork

Regulatory Requirements

Posters &Logs

Body Shop

Fire Safety

Paint Equipment

Car Wash

Waste

Personal Protective Equipment

NESHAP 6H

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