Walden Associates

Walden Associates In business for over 17 years

Allied Member of the GNYADA for over 10 years

Walden has history of aiding member dealerships in meeting their

Environmental Health & Safety (EHS) needs

•

Environmental Health and Safety Management

for New York Automobile Dealerships

EHS Inspection: Potential Violations

Walden Associates

EHS Inspection Potential Violations

1. Petroleum Bulk Storage (PBS)

and Chemical Bulk Storage

(CBS)

2. HAZCOM

3. Record keeping

4. Electrical

5. Personal Protective

Equipment (PPE)

6. Fire Extinguishers

7. Respiratory Protection

8. Abrasive Wheel Machinery

9. Welding

10. Power Industrial Trucks

11. Car Wash Station

12. Exit Signs

Walden Associates

Potential EHS Violation #1 - PBS and CBS (NYCRR Part 612, 613 & 614)

• Lack of posted registration permit.

• AST not UL listing. • Lack of components such as leak detection, vents, etc.

Potential EHS Violation #2 – HAZCOM (OSHA Part 1910.1200)

• Lack of written HAZCOM Plan.

• Lack of employee training records. • Unlabeled containers in the shop.

EHS Inspection Potential Violations

Walden Associates

Potential EHS Violation #3 – Recordkeeping (OSHA Part 1904 )

OSHA Inspector asks: show me your records and notes

• Lack of records of serious occupational injuries, using OSHA 300 Log. • Lack of OSHA required plans such as Emergency Action Plan, etc.

Potential EHS Violation #4 – Electrical (OSHA Part 1910)

• Cut and taped extension cords.

• Overloaded extension cords.

EHS Inspection Potential Violations

Walden Associates

Potential EHS Violation #5 – PPE (OSHA Part 1910 Subpart I)

• Employer not providing adequate

personal protective equipment (PPE) such as proper gloves, goggles, etc.

Potential EHS Violation #6 – Fire Extinguishers (OSHA Part 1910.157)

• Lack of fire extinguishers inspection tags

• Fire extinguishers not spaced uniformly, readily accessible and not identified correctly.

EHS Inspection Potential Violations

Walden Associates

Potential EHS Violation #7 – Respiratory Protection (OSHA Part 1910.134)

• Lack of written respiratory protection plan,

medical evaluation of employees, respirators fit testing, training, etc.

Potential EHS Violation #8 – Abrasive Wheel Machinery (OSHA Part 1910.215)

• Incorrect distance between abrasive wheel and safety guard.

EHS Inspection Potential Violations

Walden Associates

Potential EHS Violation #9 – Welding (OSHA Part 1910.252)

Potential EHS Violation #10 – Power Industrial Trucks (OSHA Part 1910.178)

• Welding gas cylinders not chained or strapped when not in use.

• Fork lift operated by employees without valid certificate to operate.

EHS Inspection Potential Violations

Walden Associates

• Illegal discharge to on-site drywell, potential contamination with heavy

metals.

Potential EHS Violation #11 – Car Wash Station (6 NYCRR Part 750 – SPDES Permit)

Potential EHS Violation #12 – Exit Signs (OSHA Part 1910.37)

• Lack, broken or not sufficient quantity of exit signs.

EHS Inspection Potential Violations

Walden Associates

What to do to avoid OSHA and environmental penalties: 1. Register your tanks with NYSDEC or other governing agency.

2. Conduct annual HAZCOM training.

3. Prepare OSHA/ Environmental required plans such as HAZCOM Plan, Emergency

Action Plan (EAP), etc.

4. Provide your employees with necessary PPE.

5. Assure that your employees have necessary certification (i.e. to operate power

industrial trucks).

6. Engage a professional to conduct EHS inspection – there might be many more

potential violations in your shop!

EHS Inspection Conclusions

Walden Associates

Walden Associates Environmental Health & Safety (EHS)

Consulting Services

Health and Safety related:

• Conduct HAZCOM Training

• Written HAZCOM Plans

• Respiratory Protection Plans

• Respirator Fit Test & Training

• Emergency Response Plans

• Indoor Air Monitoring

• Forklift Safety Training

• Hearing Conservation Plans

• OSHA Consulting Auditing and Advice

Environmental related:

• AST Design Permitting and As-Built Registration

• NYC DEP Community Right-to-Know Filings, Right-to-Know

Training

• Environmental Investigations & Site Closures

• Dealership Pre-purchase / Sale (Phase I & II Environmental

Site Assessments)

• UST Upgrades / Design Permitting

• Environmental Compliance Consulting