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Article: Environmental Record Keeping for Vehicle FinishersRecord 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. Records to ensure compliance with environmental and health and safety legislationGeneral Safety Health and safety legislation (e.g. 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:
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. Relevant Work Activities Managers should investigate the risks where workers use vibrating tools for prolonged periods. Any vibrating tool or process which causes tingling or numbness after 5-10 minutes of continuous use is considered as suspect, and should be used with extreme care. 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:
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:
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:
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 If you would like to find out more about how PHSC can help, contact us now on 01622 717700!
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