Fixed Ops Journal - December 2021 - F16

FIXED OPS JOURNAL
5
O
Interview by Dan Shine
minutes with ...
 Stephany Birkholz, environmental, health and safety team supervisor, KPA
ne thing many dealership fi xed ops
departments are not ready for is a
planned or surprise visit from local,
state or federal environmental inspectors.
Stephany Birkholz, 34, an environment,
health and safety team supervisor at consulting
and training fi rm KPA, discusses how
service departments can maintain a safe and
productive workplace. Here are edited excerpts.
Q: What important items should be covered
during environmental training?
A: Proper hazardous waste disposal is one of
the most important things that fi xed ops departments
need to know when it comes to
EPA compliance. Federal law requires that
hazardous waste is properly identifi ed and
disposed of - and all of this needs to be communicated
to employees.
What are some common EPA violations that
service departments commit?
One of the most common EPA violations in a
service department is incomplete or missing
hazardous waste determination on oil-water
separator liquid.
A byproduct of this process is sludge, and
service departments are required to properly
dispose of it per their local authorities' requirements.
Fines are issued when the service
department can't provide documentation
showing the waste has been properly categorized
using a Toxicity Characteristic Leaching
Procedure.
Parts washers are often cited, too. Service
departments can get fi ned when they introduce
an aerosol or an external product that's
not part of the parts washer system. Th is can
change the fl ashpoint or add toxicity to the
process.
You never want to introduce any external
chemicals to a parts washer process because
it can create a snowball eff ect along the waste
disposal chain, sometimes called the cradleto-grave
process. Improper labeling is another.
Everything needs to be labeled - like used
oil, used oil fi lters, used antifreeze, etc., so
things don't end up in the trash that shouldn't
be there (like an aerosol can). I also frequently
see improper or incomplete paperwork. Facilities
can have trouble managing the multiple
PAGE 16 DECEMBER 2021
"
" One of the most common
EPA violations in a service
department is incomplete
or missing hazardous
waste determination on
oil-water separator liquid. "
layers of regulation at the local, state and federal
level. Facilities are required to retain disposal
receipts or manifests of all wastes for
three years.
What are some EPA compliance areas that
collision centers forget about?
Collision centers struggle with properly categorizing
hazardous waste, also known as
hazardous waste determination. We start to
see large fi nes when a facility doesn't properly
determine its hazardous waste or allows it to
evaporate by leaving containers open. A common
example of this is a paint shop leaving
the funnel to the waste drum open or when
solvent-based paint is left out to harden. If a
facility doesn't notify the EPA they are operating
as a small quantity generator, this is another
area where fi nes will be steep. Lastly, try
to stay away from chlorinated solvents. Th e
days of using the chlorinated dip basket gun
cleaners are no more. In fact, you probably aren't
able to purchase chlorinated solvents
anymore from paint suppliers. It's a liability
and regulatory burden for them, too.
When an EPA compliance offi cer visits a service
department, what are some tips for
managers on how to handle the visit?
Th ere are fi ve things that managers need to
know to best handle a visit:
1. Be kind and helpful to the inspector. Visits
are typically unannounced, but you should do
everything you can to make their job as easy
as possible, and they'll likely do the same.
2. Ask [for] and verify the inspector's credentials
and request an opening conference. Th e
conference should explain the nature, purpose
and scope of the inspection or visit. Before
the visit begins, you should also ask
which records need to be reviewed so someone
can work on gathering those during the
walkthrough.
3. Escort the inspector at all times. You are expected
as a hazardous waste generator to have
one person who can stop what they're doing
at all times and assist the inspector during
their walkthrough. Do not ever allow them to
wander off by themselves. And anytime they
take a photo, you should do the same.
4. Fix small issues on the spot. If something
isn't labeled properly, doing so on the spot
can show that you're willing to take action
quickly and take the inspection seriously.
5. Ask for a closing conference. Th is should
address any next steps, time frames or deadlines
and identify anything the inspector
wants you to follow up about.
At KPA, we equip our clients with a " Yellow
Box, " which includes all of the waste disposal
documentation that an EPA compliance offi -
cer needs to conduct an inspection. I recommend
that all service departments have some
version of this to ensure a smooth inspection
process.
If you work with an environment, health
and safety consultant, they can help ensure
you're ready for any planned or surprise EPA
inspection. 
"
Fixed Ops Journal - December 2021

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