A little research combined with regulation-savvy planning adds up to a compliant collision repair shop.
Hazardous waste is generated in every collision repair shop, and each shop must handle the waste properly in order to comply with environmental regulations. Unfortunately, most shops generate hazardous waste in many different forms, and identifying the waste is almost as difficult as finding the time to collect and dispose of the waste in a safe, efficient manner.
If your shop generates even a small amount of hazardous waste over the course of a month, your business is considered a generator. And it is the owner's responsibility, as the waste generator, to handle these wastes according to federal, state and local regulations. Some repair shops tackle the compliance job alone, but complying with every requirement is a time-consuming task that requires a good understanding of government regulations. If a body shop does not have the resources to handle the job alone, the best solution may be to hire a professional waste management company.
Before deciding how to handle hazardous waste, the collision repair shop owner should know exactly what type of wastes are involved and accurately assess the needs of the shop. Determining what type of waste the shop generates is an important first step. Overlooking an obvious type of waste can result in penalties if the shop is examined by outside authorities. Even worse, some waste may actually pose a hazardous condition for employees. Absorbents, for example, are a handy,
economical way to control spills, but absorbents are also considered waste and should be treated accordingly. Unused rags and wipes pose no environmental risk, yet the moment a spill is wiped up with a rag, that rag becomes waste that is regulated by whatever guidelines apply to the spilled substance. Other types of wastes that a body shop may generate include antifreeze, buffing pads, cleaning thinners, paints, waxes and polishes, fluorescent lamps, paint removers, parts cleaner solvents, used oil and used oil filters.
Once different wastes have been identified, current waste management practices should be assessed. Collision repair shops must follow specific OSHA guidelines, such as MSDS and Employee Right-to-Know.Written emergency procedures and a plan to implement those procedures should be in place, and employees should receive compliance training.
Estimating the amount of waste a collision repair shop generates is also helpful when developing a waste management plan. The amount of waste generated depends on the variety of work a shop performs-for instance, specific quantities of paint may be used over a period of time or paint usage may vary as a shop's business cycle changes.
Another factor to consider is how much waste a body shop currently has on hand. Assessing the level of on-site waste will help establish an immediate need versus an anticipated need. If a shop employee tosses used rags and wipes in the trash, the shop will have "zero" rags and wipes on hand. If the rags and wipes have been collected in a drum at the shop then the immediate need is known, but the question of long-term usage must still be answered. In both cases, knowing the amount of waste on hand provides a starting point for measuring usage, which is the key to developing an effective waste management program.
Identifying the different types and amount of waste a shop has generated, and developing proper waste management practices, is just the beginning. All of the related compliance paperwork must still be filled out-and then there's the collection, removal and transport of the waste. Shops that are not equipped to properly handle all of these waste management tasks should turn to an outside source for assistance.
Using an Outside Source
Choosing the right waste management provider can make it easier for a collision repair shop to deal with compliance issues, and allow the shop's employees to concentrate on their work, thereby increasing efficiency and productivity. When evaluating waste management companies, be sure to check out each firm's credentials as well as the services offered. The company's service representatives should be trained and certified to safely pick up and remove hazardous waste and be able to recommend the best services to meet a shop's individual needs.
The company's waste management services should be backed up, in writing, with a comprehensive guarantee. If the provider doesn't offer this protection, a body shop can be found liable in the case of a spill or accident, even when the waste is no longer in the shop's possession.
The convenience of the provider's services should be investigated as well. Consider where the company is located and how often the service representative will be able to make pick-ups or answer specific questions about handling unusual wastes. Finding a waste management company that will tailor services to meet customer needs can make a difference, especially when problems arise.
Most importantly, inquire about the scope of products and services that the waste management company offers. Ask what types of waste the provider will pick up, how often and in what volume. Timely waste removal is just as critical for small body shops as it is for larger repair shops. Also, find out what happens after the hazardous waste has been collected and removed from the shop. The law requires proper treatment of waste: to avoid penalty, each type of waste must be disposed of or recycled according to specific regulations. In addition, ask if the waste management company's service includes assistance with compliance-related paperwork.
All of these factors should be given careful consideration when dealing with compliance issues, choosing an outside provider or developing an effective waste management program. Managing hazardous waste is obviously not a part-time activity; it is a full-time commitment that each collision repair shop must make to stay in business.
For more information on managing hazardous waste in collision repair shops contact Safety-Kleen Corp., One Brinckman Way, Elgin, IL 60123;or phone 800-342-6564.

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