Florida Auto Dealers are being targeted by State and County Regulators

FLORIDA AUTO DEALERS ARE BEING TARGETED BY STATE AND COUNTY

REGULATORS

www.kpaonline.com

(866) 356-1735

Questions

• If you have questions during the presentation, please submit them using the “Questions” feature

• Questions will be answered at the end of the webinar

Introduction from Ted Smith – FADA President

Presented by

Cameron CurtisSenior Account Executiveccurtis@kpaonline.com

(303) 228-2389

Hannah CrawfordTeam Leader SE

hcrawford@kpaonline.com(303) 228-2389

KPA – Company Profile

Nationwide compliance auto industry expert on Safety, Environmental, HR, and Internet Marketing

Colorado Headquarters

26 Years Experience

451 Clients in FL

4500 + Nationwide Clients– Dealerships, Service,

Repair, Collision Centers

Compliance products and services– OSHA– DOT– EPA– Workers’ Comp– Background checking– Onboarding– Harassment – Red Flags– Onsite inspections– Online and onsite training

and tracking– And many more…

In the press: “Red Tape Rising”

• Jan 22nd 2011 Article from The Economist – “Red Tape Rising”

• 167% Increase in Workplace Safety Violations

• 16% Increase in regulatory workforce

• Millions dumped into OSHA/EPA – “Foot Soldiers”

• Fines can range from 3.5K-90K

“New Sheriff in Town”

- Quote from Labor Secretary, Hilda Solis:

“OSHA received over 100 inspectors in our 2010 budget, as well as an additional 25 requested in 2011. We are also moving 35 inspectors from compliance assistance activities to enforcement….There’s a new Sheriff in town.”

- President Obama’s 2010-2011 Budget:• $69 million increase for worker protection

programs• Hire 180 new inspectors and investigators

Inspections on the Rise

Florida Inspections Over the Last 5 Years

2008 2009 2010 2011 2012

FDEP 33 63 111 129 114

OSHA 5 3 20 23 13

• 400% Increase in Inspections from 2008 to 2011

Who is Inspecting your Dealership?

1. FDEP Divisions• Storm Water• Storage Tanks• Air Quality• Hazardous Waste

2. OSHA

3. DOT/FAA/TSA

The Inspector Comes Knocking…

FDEP DISTRICT MAP

• EPA Delegation

FDEP: Storm Water Division - What are they looking for?

• Car wash runoff• Oil/water separator connections

and maintenance• Septic tanks• Storm drains

FDEP: Storage Tanks Division - What are they looking for? (con’t..)

• Registered storage tanks• >550 aboveground• >110 underground

• Overfill prevention• Tank condition• Paperwork

• Insurance• Release Detection Response Level

FDEP: Air Quality Division - What are they looking for? (con’t..)

• 6H

FDEP: Hazardous Waste Division - What are they looking for? (con’t..)

• Housekeeping• Container management• Employee training• Waste disposal and tracking

Common Waste Streams

Used Oil/Filters/Coolant/Gasoline:1. Used ATF, oil/synthetics

2. Used oil/fuel filters

3. Used antifreeze

4. Contaminated gasoline

Not hazardous waste if recycled.

Common Waste Streams

Parts Washers:

1. Drum filled

2. Recycling

3. Hot/aqueous parts washers

4. Brake Washers

5. Continued Use Programs

6. Smart/SafeWashers

MAY BE HAZARDOUS WASTE!

Common Waste Streams

Paint/Thinner Waste:1. Waterborne

2. Solvent-containing

3. Recyclers – “hockey pucks”

MAY BE HAZARDOUS WASTE!

Common Waste Streams

Paint Booth Filters:

May be hazardous waste, especially if using paint containing heavy metals.

Common Waste Streams

Universal Waste:1. Batteries

2. Fluorescent lamps

3. E-waste

Not hazardous waste if recycled.

Common Waste Streams

Tires:Many states have specific tire storage

regulations – how many, where they are stored, how they are stored

Common Waste Streams

Shop Towels, Paper Towels:

1. Can be laundered at a facility connected to a POTW

2. If not laundered, must be collected as a hazardous waste if contaminated with a toxic, F002, or F005 chemical

Common Waste Streams

Wheel Weights:Lead-containing wheel weights are hazardous

and must be recycled or disposed of as hazardous waste.

Not hazardous waste if recycled.

Common Waste Streams

Oil/Water Separators:Sludge must be tested or presumed hazardous.

MAY BE HAZARDOUS WASTE!

Common Waste Streams

Brake Dust:Some states consider dust

from the lathe to be potentially hazardous, depending on the content of your rotors. At a minimum, dust should be collected neatly in a bin.

Common Waste Streams

Aerosol Cans:

1. May be thrown in trash if completely empty of product AND propellant

2. May be punctured with an approved device only – waste must be captured

MAY BE HAZARDOUS WASTE!

SUMMARY – OSHA TOP 10

FEDERAL ONLY

OSHA – WHAT ARE THEY LOOKING FOR (CON’T..)

HAZARD COMMUNICATION

-Written Program

-Chemical Inventory

-Material Safety Data Sheets

-Container Labeling

-Employee Training

EMERGENCY RESPONSE

-Fire and Explosion

-Facility Evacuation

-Spill Response

-Chemical Overexposure

-Natural Disasters

EXAMPLE EMERGENCY EVACUATION MAP

PERSONAL PROTECTIVE EQUIPMENT

• Hazard Assessment

• Employee Training

RESPIRATORY PROTECTION

-Written Program

-Medical Evaluations

-Fit Testing

-Training

-High Liability

HOW WILL YOU FARE?

Required Documentation:• Haz Comm (training)• Emergency Resp – (training)• PPE (training)• RPP (for paint work) / (training)

Physical Shop Compliance:• Stored Properly/Labeled Properly• Safety Hazards• Lifts Inspected• Monthly self inspections conducted?

DOT, FAA, TSA – What are they looking for (con’t..)

DOT Hazmat Certification

DOT Hazmat Certification Compliance

Penalty Policy: “When the violation is a continuing one, each day of the violation constitutes a separate offense” DO NOT SHIP HAZMATS VIA AIR

DOT Hazmat Certification

• Online training.• Certification required every 3-years.• New employees within 45-days of

employment.• 24-hour phone number on shipping papers.• Post certifications.

How to handle an Inspection

1. Don’t Panic – Welcome

2. Escort to Management

3. Clear your Schedule

4. www.mykpaonline (Call your Engineer)

5. Document

6. Answer Questions

7. Paper Review

8. Get an Out-Brief

FACILITY COMPLIANCE & SAFETY EVALUATION

Evaluation By KPA• Written Programs

• Training Records

• Compliance Issues

• Shop Issues

Webinar or Onsite

Formal Report• Summarizing Areas of Opportunity

KPA’S COMPLIANCE SYSTEMS

QUESTIONS?

FREE CONSULTING TIME!!!

Contact Us

Cameron Curtis

ccurtis@kpaonline.com

303-228-2389

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