AUTO BODY CERTIFICATION PROGRAM
Conclusions drawn from the analysis of the data indicated potential health and environmental problems from the metal bearing sanding dust. The risk from cumulative exposure to take home toxics, such as lead, was a major concern to the authors. Odors from painting and cleaning systems have caused problems to neighboring businesses that are in close proximity to the shops. Fugitive dust can escape on dry summer days and lead to additional exposure concerns in urban and crowded areas.
The Rhode Island Department of Environmental Managements Pollution Prevention Program began to address these problems in November of 1998 with the distribution of a letter to all autobody shop owners in the state. The letter urged caution in the management of the sanding dust and recommended methods to reduce worker exposure as well as cumulative exposure. Five health protection guidelines were provided to reduce workplace/home exposures:
Pollution prevention measures, such as eliminating solvents to clean skin surfaces and eliminating methylene chloride-based paint strippers, were strongly encouraged. Regulatory compliance assistance was offered and five fact sheets were included for posting in areas frequently accessed by the shop employees. Each single page fact sheet addressed the following subjects: Pollution Prevention, Safety Concerns, Hazardous Waste Management, Air Pollution Control, and Water Pollution Control. The fact sheets were presented in clear plastic envelopes on a key ring for ease of posting and handling.
- Use high-velocity, low-volume ventilated sanders with adequate filter efficiencies.
- Use laundry facilities, if available. If laundry facilities are not available, bring a change of clothes to work. Leave work clothes and shoes at work. If possible, shower at work.
- Wear appropriate personal protective equipment.
- Wash hands before eating.
- Do not leave food or drink in the work area as dust can travel and contaminate these items.
The Pollution Prevention Program continued working collaboratively in this sector with the Rhode Island Department of Health, the U. S. Occupational Safety and Health Administration and the Davies Career and Technical High School. This partnership led to the signing of a Memorandum of Understanding in September of 1999. The MOU memorialized this unique joint venture and paved the way for the development of a new approach to assisting and regulating this high-risk industry.
The authors, through their association with the interstate group NEWMOA (note 1), became familiar with the Environmental Results Program (ERP) used in Massachusetts to regulate certain business sectors. Major elements of the ERP include:
The Massachusetts Department of Environmental Protection, administrators and regulators of the program, has reported a number of significant results from the program. The number of facilities regulated increased dramatically over the traditional permitting program. Environmental Business Practice Indicators were developed to measure industry performance. Statistically significant improvements to regulatory compliance were readily documented. Department resources were more efficiently utilized. The program was recognized as a better way to do business by the US Environmental Protection Agency, and has been expanded into a number of other sectors. (note 2)
- Certification replaces case by case permits.
- Clear standards and compliance assistance.
- Corporate accountability and self-evaluation.
- Inspections and enforcement.
The autobody industry in Rhode Island consists of mainly small and medium sized shops that are operated with minimal resources. The industry is subject to regulation by a number of state and federal agencies concerned with air and water pollution, hazardous waste generation, and worker health and safety. The self-certification method was recognized as an excellent template for addressing the full range of requirements that these shops are responsible for.
At a meeting with the autobody shop owners held in November of 1999 at the Davies Vocational High School, the Department introduced the concept of a certification program. The vision for this program includes development of a checklist with the following elements:
Completion of the checklist will be followed by the compilation of an instruction manual that will provide guidance to the shop owners completing the certificate checklist.
- Requirements for compliance with Air Pollution Control Regulations and Hazardous Waste generation rules regulated by the DEM.
- Worker Health and Safety requirements regulated by OSHA.
- Water Pollution discharge requirements regulated by local sewer authorities.
- Pollution Prevention recommendations developed by the DEM.
- An employee training program developed by a team with representation form the Davies Vocational High School, the University of Rhode Island Center for Pollution Prevention and the DEM's Office of Customer and Technical Assistance.
The Department established a stakeholder process consisting of a workgroup with members from the DEM, DOH, the Narragansett Bay Commission, which is Rhode Islands largest sewer authority, Davies, OSHA, and an Advisory Team consisting of autobody shop owners representing small, medium, and large shops in Rhode Island.
The workgroup and Advisory Team held their first meeting on March 7, 2000. Representatives from the Massachusetts DEP gave a presentation on the development and implementation of the ERP. The presentation resulted in a foundation for the future development of the Rhode Island Program.
Note 1- NEWMOA is the North East Waste Management Officials Association, a non-profit interstate association, consisting of the States of Connecticut, Maine, Massachusetts, New Hampshire, New York, Rhode Island, and Vermont
Note 2- The Massachusetts Department of Environmental Protection utilizes the ERP in the Photoprocessing, Dry Cleaning and Printing Industries