Automotive repair shops are required to comply with all local, state and Federal laws that apply to their businesses. However, two of the least well understood legal compliance areas involve OSHA workplace safety laws and EPA pollution prevention statutes. These are important requirements every repair facility must meet, and failure to do so can result in significant fines and expensive lawsuits.
The information on this page is presented by AAA to help repair shops assess their level of OSHA and EPA compliance. Also provided are links to several resources that shops can use in addressing any compliance shortfalls. This information has been assembled in cooperation with the Coordinating Committee for Automotive Repair (CCAR®), a AAA preferred partner that provides Safety and Pollution Prevention (S/P2) training to industry including AAA clubs and their affiliated auto repair businesses. Areas covered on this page include:
OSHA AND EPA REQUIREMENTS
OSHA regulations require every employee involved in automotive repair and maintenance to be trained on workplace safety and environmental issues before entering the workplace and again on at least an annual basis. EPA regulations require every repair business to closely monitor and control its generation and disposal of hazardous waste. The resources below provide basic outlines of the requirements, and can be used to help assess and achieve compliance with applicable OSHA and EPA regulations.
To ensure a more comprehensive understanding of the issues involved, any individual charged with managing OSHA and EPA compliance issues is very strongly encouraged to complete the relevant CCAR S/P2 training discussed later on this page before taking any remedial compliance actions.
OSHA WORKPLACE SAFETY RESOURCES
CCAR Safety Screening Checklist – This safety screening checklist was developed by CCAR with the assistance of industry professionals who have identified those areas where safety problems most often occur. It allows a repair facility owner, general manager, supervisor or technician to review the key safety practices and quickly determine any areas of concern.
AAA List of OSHA/EPA Required Documentation – During an OSHA shop visit, one of the first things an inspector will ask to see is the written and/or printed plans, records, files, forms, lists, posters and signage required for OSHA compliance. This list, developed by AAA staff and reviewed by CCAR, describes the most common workplace safety and pollution prevention program documentation requirements for auto repair facilities.
Federal OSHA Web site – The Federal OSHA Web site contains everything you would ever want to know about workplace safety
and more. The Compliance Assistance link on the home page is a good place to begin when seeking auto repair related information.
EPA POLLUTION PREVENTION RESOURCES
EPA Consolidated Screening Checklist for Automotive Repair Facilities Guidebook – This 100-page publication from the EPA is the bible for auto repair shop compliance with pollution prevention laws. It contains the EPA Consolidated Screening Checklist for Automotive Repair Facilities which can be used to assess a repair facilitys compliance with pollution prevention statutes. The Checklist covers the most common areas where pollution issues arise, but it can be challenging to use for anyone not familiar with the many government program acronyms employed.
AAA Consolidated Screening Checklist for Automotive Repair Facilities – This form is an enhanced version of the EPA Checklist that has been edited by AAA and reviewed by CCAR for greater clarity and ease of use. Even so, like the EPA original, it is best used in conjunction with the Guidebook which contains extensive explanations and clarifications of the requirements.
CCAR Pollution Prevention Screening Checklist – Like the EPA and AAA checklists, this form enables a shop owner to quickly assess their level of compliance with pollution prevention statutes. Again, it is best used in conjunction with the EPA Guidebook.
AAA List of OSHA/EPA Required Documentation– During an EPA shop visit, one of the first things an inspector will ask to see is the written and/or printed plans, records, files, forms, lists, posters and signage required for EPA compliance. This documentation list, developed by AAA and reviewed by CCAR, describes the most common workplace safety and pollution prevention program documentation requirements for auto repair facilities.
Federal EPA website – The Federal EPA Web site contains everything you would ever want to know about pollution prevention
and more. The Business and Non Profits link under Resources on the home page is a good place to begin when seeking repair related information.
ADDITIONAL OSHA/EPA COMPLIANCE RESOURCES
State/Local Environmental, Health and Safety Agencies – Maintained by CCAR, this page has links to governmental workplace safety and pollution prevention regulatory offices in every state.
Web Sites on Workplace Safety, Pollution Prevention and OSHA/EPA Compliance – Maintained by CCAR, this page has links to featured sites, compliance assistance centers, and Federal/state Web pages that contain information relevant to OSHA/EPA compliance.
COMPLIANCE DOCUMENTS
AAA Chemical Information Sheet – An important element of any OSHA Hazard Communication and Safety Plan is an inventory of all chemicals used in the business, along with copies of the Material Safety Data Sheets (MSDS) for each. This document provides a framework for building such a list.
OSHA 3165 Poster – By law, the OSHA 3165 plain language poster must be displayed in any business subject to OSHA workplace safety oversight.
OSHA Recordkeeping Forms – This document includes the three forms required by OSHA to track work-related illnesses and injuries, and related incident reports.
OSHA Respirator Evaluation Form – Where the use of respirators is required by OSHA regulations (typically in the collision repair segment of the auto repair industry) a current copy of this form must be on file for all affected employees.
CCAR TRAINING
CCAR Safety and Pollution Prevention (S/P2) Training – A direct link to the S/P2 training program page on the CCAR Web site. The S/P2 training program is available at a discounted price to AAA clubs and affiliated service providers.
CCAR Home Page – Home page of the CCAR Web site which offers access to extensive information on workplace safety and pollution prevention resources, including their S/P2 training program.
CCAR Page on AAA.biz – This AAA.biz page provides any repair facility access to information on CCAR and its products and services.
DISCLAIMER
AAA offers this page as a public service and believes the information it contains to be accurate as of the date posted. However, AAA does not guarantee the accuracy or completeness of the information, and will not be liable for any damage or loss suffered as a result of reliance on this information.
The information on this page covers common workplace safety and pollution prevention requirements for auto repair facilities. However, every shops situation is unique, and some shops may be required to meet additional requirements not specifically addressed here. Examples include laws pertaining to: underground and aboveground fuel and oil storage tanks, petroleum contact water, air emissions and permitting, construction-related environmental issues, wellhead protection, hazardous substance discharge reporting, and more. In addition, the information on this page is based on workplace safety and pollution prevention programs administered by the Federal government. State and local laws, regulations, and rulings may also apply in lieu of, or in addition to, the Federal requirements.
Consultation with appropriate industry and governmental workplace safety and pollution prevention authorities is strongly encouraged as part of any compliance planning process to ensure all legal requirements are satisfactorily addressed. In particular, the relevant state and local statutes should always be carefully reviewed and considered prior to taking any actions based on information from this page. |
