Business Model Canvas (BMC)- A new venture concept
Recordkeeping 101: EPA and OSHA Required Paperwork
1. – KPA CONFIDENTIAL –
Recordkeeping 101: EPA and OSHA Required Paperwork
Thank you for joining the webinar.
We will begin at 10am Mountain Standard Time.
2. – KPA CONFIDENTIAL –
Recordkeeping 101: EPA and OSHA Required Paperwork
Thank you for joining the webinar.
We will begin at 10am Mountain Standard Time.
4. 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
5. KPA – Company Profile
• Nationwide
compliance expert on
Safety, Environmental,
HR
• Colorado
Headquarters
• 23 Years Experience
• 3000 + Clients
– Dealerships, Service,
Repair
• 20 Offices Serving 41
States
• 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…
6. So you think you’re covered?
– KPA CONFIDENTIAL –
7. This Week’s Headlines
“US Department of Labor's OSHA takes action to protect America„s
workers with severe violator program and increased penalties”
“US Department of Labor's OSHA proposes nearly $136,000 in penalties
against Sewon America Inc. for willful and serious safety violations”
FAA proposes $53,000 fine against Stewart & Stevenson, LLC for shipping a box
containing touch-up paint to FedEx Corp. for transportation by air...
“Nebraska firm pays $150,000 fine for waste problems”
“EPA fines Iowa battery maker over pollution”
11. EPA
– KPA CONFIDENTIAL –
Refrigerant Recovery and Recycling
609 AC Folder, to include:
- Technician Certifications
- Equipment Registrations
- Refrigerant Purchasing Records
12. EPA
– KPA CONFIDENTIAL –
Spill Prevention, Control,
and Countermeasures Plan
(SPCCP)
A facility starting
operation…
Must...
On or before
August 16, 2002
Continue to maintain its existing SPCC
Plan in accordance with the SPCC rule.
Amend and implement that Plan no
later than November 10, 2010
After August 16,
2002, through
November 10, 2010
Prepare and implement an SPCC Plan
no later than November 10, 2010
After November 10,
2010
Prepare and implement an SPCC Plan
before beginning operations
Fact Sheets
- New Plan when
elements of the
Plan change
- 5 year re-
certification
- Tank
Inspections, monthl
y
13. EPA
• UST
A. Corrosion Prevention
B. Leak Detection*
C. Financial Responsibility*
D. Closure Records
• Tier II: greater than 10,000 lbs. of
storage, annual submission, due by March 1
Gasoline: 1,600 gal.
Diesel Fuel: 1,399 gal.
Battery Acid: approx. 100 used batteries
Fuel Oil: 1,282 gal.
Antifreeze: 1,111 gal.
Motor Oil: 1,389 gal.
– KPA CONFIDENTIAL –
15. OSHA
• Hazard Communication Plan
Written Plan, current
Chemical Inventory, annual update + 30 year archive
MSDS, current, accessed in under 10 minutes
– KPA CONFIDENTIAL –
16. OSHA
• Emergency Response Plan
current, updated as changes occur
- Fire Response
- Spill Response
- Natural Disasters
– KPA CONFIDENTIAL –
17. OSHA
– KPA CONFIDENTIAL –
Hazard Assessment/ PPE Selection*
- current
- updated as new hazards are introduced to the work area
18. OSHA
• Respiratory Protection Program
Written Program, current
Respirator Change-Out log
Appendix D for Voluntary use, 1 time per employee, per respirator
Fit-Test Records, current and required annually
Medical Evaluations*, 30 years after employment
– KPA CONFIDENTIAL –
20. OSHA
• OSHA logs (SIC 5500 exempt)
301: Not Required
300: Current
300A: Post from February 1 through April 30 for
the previous year
• Inspections
Fire Extinguishers*: Annual/ Monthly
First Aid Kits*: Monthly
Eye Wash Stations*: Monthly
Facility Hazards*: Regularly
– KPA CONFIDENTIAL –
21. Training
• Emergency Response
- ALL employees
- Upon initial employment and annual refresher
- Archive current only
• Hazard Communication
- EEs exposed to hazardous chemicals
- Upon initial assignment and again when a new hazard in introduced
- Archive current only
• PPE
- EEs required to use PPE
- Upon initial assignment and when changes occur
- Archive current only
• Forklift
- Forklift Operators upon initial assignment, when an incident occurs, and 3 yr
refresher
- Archive current only
– KPA CONFIDENTIAL –
22. Training
– KPA CONFIDENTIAL –
• DOT Hazardous Materials
- Haz Mat employees
- Within 90 days of initial assignment if shipments are directly supervised by
someone trained, refreshed every 3 years
- Archive for 90 days after employment ends
• Respiratory Protection
- EEs required to use a respirator
- Upon initial assignment, when changes occur, and annual refresher
- Archive current only
• Respirator Fit-Testing
- EEs using a tight fitting respirator
- Upon initial assignment and refreshed annually
- Archive current only
23. Training
• Forklift
- Forklift Operators
- Upon initial assignment, whenever an incident occurs, and 3 year refresher
- Archive current only
• Hazardous Waste Management
- EEs of Small Quantity Generators (SQGs) of hazardous waste
handling, storing, or managing hazardous waste
- Upon initial assignment and annual refresher
- Archive current only
– KPA CONFIDENTIAL –
24. Best Management Practices
• Hiring process to include all EHS training in
new EE orientation
• Centralize and organize all documents in
Business Office or HR Department
- Organize waste streams by type, group by year
- Keep all training records behind an updated EE list with hire dates
- Break down other folders by category discussed here: 609 AC, SPCCP,
UST, written programs, etc.
• Retain a copy of anything mailed to a
regulatory agency and attach a certified mail
receipt
– KPA CONFIDENTIAL –
25. BMPs
• Clearly identify responsibility and empower
that employee
• Internal Audit Schedule
• Obtain Certificates of Insurance for all outside
contractors
• Seek counsel from EHS Professionals and
attorneys in your area!
– KPA CONFIDENTIAL –
26. Nick’s “Do it Now” Top 5
1. If you have over 1,320 gallons of petroleum, start
on that SPCCP!
2. Hazard Assessment and PPE Selection/Provision!
3. Employee Training!
4. Organize all these documents in 1 central
location! Empower someone at your facility to be
responsible for this stuff!
5. Obtain certificates of insurance for all outside
contractors!
– KPA CONFIDENTIAL –
28. Contact Information
– KPA CONFIDENTIAL –
The recorded webinar and presentation slides will be emailed to
you today including your local representative‟s contact information.
www.kpaonline.com
bross@kpaonline.com
866-288-8765
Notes de l'éditeur
The current maximum penalty for a serious violation, one capable of causing death or serious physical harm, is $7,000 and the maximum penalty for a willful violation is $70,000. These will change to $12,000 and $250,000, respectively.
The requirements of this rule cover 7 areas; Notification, Painter Training, Spray Gun Selection, Spray Gun Cleaning, Spray Booths, Re-Notification and finally Recordkeeping.
