| Introduction
Record keeping takes time
and trouble, but does not directly bring any profit
into the kitty. It is all too easy to spend our
time and effort on pleasing the customer, only
to find at a later date that the paperwork has
not been kept up to date. The end result, trying
to backtrack, often takes longer than keeping
records maintained in the first place.
The records are often the first
thing that an enforcement officer or insurance
assessor wants to review. If these are not as
they should be, then all sorts of awkward questions
or problems can result.
So what information should be kept? An outline
of the main records to ensure compliance with
environmental and health and safety legislation
is given below. There will be other records that
are needed to run your business (eg accounts,
employee files etc) but these are outside the
scope of this article.
General Safety
Health and safety legislation (eg
Control of Substances Hazardous to Health Regulations
1999) specifies that records of risk assessments
must be kept. These must be regularly monitored,
reviewed, and updated where necessary.
Records of responsibilities and
procedures for implementing the safety policy
are another set of details that must be maintained,
kept updated, and communicated to staff. A formalised
record is a legal requirement when there are five
or more people employed within a company.
Environmental Protection
Under Part 1 of the Environmental
Protection Act 1990, the Local Authority is responsible
for enforcing certain activities that fall within
the scope of this legislation. These are known
as prescribed processes. One such process is the
respraying of road vehicles. The current guidance
on this states that any vehicle respraying establishment
that uses or is likely to use one tonne or more
of organic solvents in any 12 month period is
required to apply for an Authorisation from their
Local Authority. A record of the Authorisation
application should be kept, as the Application
process can take several months and has been known
to get lost in the system.
In order to comply with conditions
which are laid down within any Authorisation issued,
there are certain record keeping requirements
which must be adhered to. Each Authorisation will
be slightly different in its requirements, but
will generally include things like:
records of visual olfactory tests,
daily or weekly (look and smell test)
any equipment malfunction that may cause an adverse
environmental emission
records of booth maintenance (eg filter changes).
Whilst garages emitting less than one tonne do
not currently have the legal obligation for record
keeping placed upon them, it is good practice
to maintain records of emissions. As environmental
concerns continue to increase, it is likely that
the one tonne threshold will be reduced.
The Department of Environment, Transport
and the Regions (DETR) has issued a guidance note
to help people understand what is required of
them to meet the legislation (available from The
Stationery Office - "Secretary of State’s
Guidance - Respraying of Road Vehicles PG6/34(97)).
VOC Records (Volatile Organic
Compounds)
Under clause 35 of PG6/34(97) it
is necessary to maintain records of these, regardless
of whether the garage is authorised to operate
a prescribed process. This is because an environmental
health officer (EHO) may visit to determine whether
your operation exceeds the one tonne limit.
If you have an Authorisation, then
you will be required to keep comprehensive VOC
purchase records and to send details to the Local
Authority of total use over a six month or annual
period. It is therefore important that VOC reports
are obtained regularly from everyone who supplies
products containing VOC (eg paints, thinners,
hardeners, cleaning substances, fillers).
Any Authorised operator is likely
to be required to maintain an updated list of
all solvent products that are used or stored on
the site, and the solvent content that is within
each product. (These will be expressed as grammes
per litre). This is to determine whether compliant
coatings are being used. Calculation of usage
is comprised as follows: Total organic solvent
purchases less the organic solvent waste that
is to be recycled.
Records of booth EPA compliance
certification
To meet clause 19 of PG6/34(97),
records should be maintained from the booth manufacturer
(or anyone who has upgraded or maintained the
booth) to demonstrate that it will meet an emission
control limit of 10mg/m3 of particulate matter
(ie dust). If you do not have this, then the Local
Authority is within its rights to insist upon
annual monitoring and to require you to produce
evidence of the results. You may therefore need
a specialist contractor, which will incur additional
expense.
Maintenance Records
Clause 45 states that all equipment
used to ensure effective control of emissions
to the air needs a preventive maintenance programme.
This is to eliminate or significantly reduce the
likelihood of accidental emission. Useful tips
about what is required in a preventive maintenance
programme can be found in "Environmental
Technology Best Practice Programme - Good Practice
Guides GG13", available free by calling tel:
0800 585794.
Records of any servicing or maintenance
should be kept, regardless of whether the work
has been carried out in-house or by contractors.
These should include:
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booths |
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mixing room extraction |
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dust extraction
equipment |
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gun cleaning machines |
In addition, a log should be maintained
of any booth filter changes that are made in the
interim period between servicing.
Other maintenance records should
include weekly checks of:-
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abatement equipment |
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booth interlocks |
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fans |
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pressure alarms |
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gun cleaning machine extraction |
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dust extraction |
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local exhaust ventilation |
Training Records
Clause 47 requires that staff at
all levels are given formal training and instruction
in their duties regarding control of the processes
that they operation and emissions to air. Training
records should be kept to demonstrate compliance
with this clause.
Records of any instructions, information
and training given to staff, contractors or temporary
workers must be compiled to meet health and safety
legislation. An example is training in the use
of respiratory equipment worn in the spray booth.
Training records should include:
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date and place
of training |
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subjects covered |
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details any practical
sessions or demonstrations |
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details and results
of any tests, questionnaires or other method
of checking that training has been understood. |
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Waste Records |
It is a legal requirement that
all waste is removed by licenced bodies. It is
therefore important to check that any waste remover
is authorised to remove the waste they are collecting,
and it is worth keeping a copy of their licence.
Transfer notes are required for
each consignment of waste. The transfer note for
controlled waste (general office waste) is often
issued by the waste remover on an annual basis
in the form of a ‘season ticket’.
However, special waste consignment notes are required
issued each time hazardous waste is removed (eg
solvents, tyres and oils).
Records of controlled waste only
need to be retained for two years. However, special
waste records must be held for at least three
years.
Petroleum Licence
If you store more than 15 litres
of petroleum-based spirit on site (excluding fuel
in vehicle tanks) then you are required to apply
for a Petroleum Licence. A record of the application
is needed, together with the arrangements you
have in place to demonstrate that the licence
requirements are being met.
Explosives Licence
Again, if you remove, fit or store
airbags on site then you are likely to need an
explosives licence. Records of the application,
together with arrangements you have in place to
ensure compliance, are needed.
PHSC, April 2001
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