1. 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 with meeting their
Environmental Health & Safety (EHS) needs.
Environmental Health and Safety Management
for New York Automobile Dealerships
HAZCOM

2. Walden Associates
Top Ten OSHA Violations
1. HAZCOM (Part 1910.1200)
2. Respiratory protection (Part 1910.134)
3. Abrasive wheel machinery (Part 1910.215)
4. Wiring methods and equipment for general use (Part 1910.305)
5. General requirements (Part 1910)
6. Powered industrial trucks (fork lifts) (Part 1910.178)
7. Portable fire extinguishers (Part 1910.157)
8. Maintenance, safeguard, and operational features for exit routes (Part 1910.37)
9. Hearing conservation (Part 1910.95)
10. Personal Protective Equipment (PPE) (Part 1910 Subpart I)

3. Walden Associates
HAZCOM
29 CFR 1910.1200
Hazard Communication Standard
Ensure that information regarding all hazards
is transmitted to managers/employees in a consistent manner.
(This includes showroom employees!)
A HAZCOM Plan includes:
• Written HAZCOM Plan
• Chemical Labeling
• Inventory of Chemicals
• SDS Sheets Available
• TrainingBottom Line:
Develop and Implement a HAZCOM program with
training, and keep records on file.

4. Walden Associates
Employees must receive training when:
• Hired on the job
• Job requires working with chemicals
• New hazard is introduced into the work area
• Annually (HAZCOM awareness training)
HAZCOM
29 CFR 1910.1200

5. Walden Associates
 Obtain copy of HAZCOM standard (Provided in Handbook)
 Read and understand the requirements
 Assign responsibility for tasks
 Prepare inventory of hazardous chemicals
 Ensure containers of hazardous chemicals are labeled
 Obtain SDS for each hazardous chemical stored on-site
 Prepare written program
 Make SDSs available to workers
 Conduct awareness training of workers
 Establish procedures to maintain current program
 Establish procedures to evaluate effectiveness
HAZCOM
29 CFR 1910.1200
Checklist for Compliance

6. Walden Associates
On May 26, 2012 OSHA introduced changes to HAZCOM rule to coordinate it with
Globalized Harmonized System (GHS):
 Labels – must include a signal word, pictogram, hazard statement and precautionary statement for each
hazard and category.
 Safety Data Sheets (SDS) – the new format requires 16 specific sections.
 Information and Training - employees must be trained on new labels and SDS by December 1, 2013.
 Hazard Classification – chemical manufacturers and importers are required to determine the hazards of
the chemicals they produce or import.
HAZCOM
29 CFR 1910.1200
Flame Health Hazard Gas Cylinder

7. Walden Associates
WHAT IS HAZARDOUS WASTE?
• Ignitability (flash point < 140 F)
• Toxicity (fails TCLP test)
• Corrosivity (pH less than 2 and more than 12.5)
• Reactivity (unstable, violent reactions with water, typically not stored in repair shops)
Does YOUR Facility Generate more than
220 lbs. of Hazardous Waste per month?
Hazardous Wastes

8. Walden Associates
HAZARDOUS WASTE IN THE DEALERSHIPS:
• Tires
• Used/Waste Oil
• Used Antifreeze
• Batteries
• Air Bags
• Rags
• Mercury Switches
• Used/Spent Solvents
• Used Oil Filters
• Absorbents
Hazardous Wastes

9. Walden Associates
Conditionally Exempt Small Quantity Generators
(CESQG)
Small Quantity Generators (SQG) Large Quantity Generators (LQG)
Conditionally Exempt Small Quantity Generators
(CESQG) meet any of the following conditions:
•Generate no more than 220 pounds per month of
the listed and/or characteristic hazardous waste
•Generate no more than 2.2 pounds per month of
acute hazardous waste
•Store no more than 2,200 pounds of listed and/or
characteristics hazardous waste
•Store no more than 2.2 pounds of acutely hazardous
waste
SQG do not meet CESQG conditions but meet all of the
following conditions:
Generate between than 220 pounds and 2,200 pounds per
month of the listed and/or characteristic hazardous waste
Generate no more than 2.2 pounds per month of acute
hazardous waste
Store no more than 13,200 pounds of listed and/or
characteristics hazardous waste
Store no more than 2.2pounds of acutely hazardous waste
LQG meet any of the following conditions:
 Generate more than 2,200 pounds per
month of the listed and/or
characteristic hazardous waste
 Generate more than 2.2 pounds per
month of acute hazardous waste
 Store more than 2.2 pounds of acutely
hazardous waste
Hazardous Wastes

10. 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