|The Department of Environmental Management (DEM) launched an Auto Body Environmental/Occupational Health Compliance Self-Certification Program in December 2002 as a voluntary initiative. The program takes a multi-media approach, a simpler and more useful way to regulate the auto body repair sector in a less threatening manner, through a single source. This program is similar to the successful Environmental Results program run by the Massachusetts DEP, which has produced significantly higher compliance rates and improved environmental business practices. The auto body repair industry is a previously under-regulated small business industry sector in Rhode Island.
Program participants are the Rhode Island Departments of Environmental Management, Health, and Business Regulation, U. S. Department of Labor, Occupational Safety & Health Administration (OSHA), and William M. Davies Jr. Career & Technical High School. The program leverages scarce resources, reaches a substantially higher percentage of the regulated sector than routine enforcement inspections, and requires relatively less effort to comply by the regulated community than traditional permitting and enforcement programs.
With startup funding from EPA Region 1-New England in 1994, the results of field research addressing environmental releases, take-home toxics, and work place exposures (to lead and to other toxicants) were incorporated into a broad based self-certification program. The program covers training requirements, hazardous waste management, air quality standards, occupational health and safety, and pollution prevention techniques. Training for the most advanced, cost-saving technology available to the auto body industry is offered. Other services include blood lead testing, sampling of environmental surfaces for lead, and worker education.
The program has already shown environmentally measurable results. Certification workbooks and self-certification checklists were sent to the 373 auto body shops licensed by the Rhode Island Department of Business Regulation (DBR) in December 2002, with a June 30, 2003, deadline to respond. Completed checklists were returned by 170 businesses, and 14 businesses in the auto repair industry filed Non-Applicability Statements (a 50.1 percent response rate to the mailing).
Some examples of compliance improvements being taken by these shops include facility modifications to improve vehicle wash water management; purchase and use of solvent recyclers; contingency procedures and emergency plan development; purchase and use of technologies that prevent the release of and reduce worker exposures to metal bearing sanding dust; sending staff to physician's offices for physical exams as part of upgraded respiratory protection programs; environmental and health and safety training for workers; and eliminating the use of the EPA- and OSHA-regulated carcinogen methylene chloride as a paint stripper.
DEM has also developed a pollution prevention curriculum for auto body technicians and students that will be incorporated into course work at the William M. Davies Career and Technical High School. Highlights of the curriculum were demonstrated in a PowerPoint® presentation during a news conference at Crown Collision Center, Inc. in Pawtucket, a participating auto body shop.
The program proceeds in the following areas: field audits and enforcement inspections of randomly selected facilities; follow-up with shops that submitted RTC Plan forms for compliance status on items identified on forms; work with the DEM Management Information Systems Unit to develop a comprehensive database of information from participating shops that allows for data management and analysis; QA/QC each checklist returned and make follow-up calls or communicate with shops as needed; summarize data from submitted checklists by shop; prepare a summary report of data; and share results of data with DEM regulatory offices, state partners, and stakeholders.
In order to conduct post program implementation field audits, entries were assigned identifier numbers in alphabetical order by shop. Seventy identifier numbers were chosen by electronically generated random selection. Of those shops selected, 34 shops submitted completed checklists, 34 did not submit checklists (1 awaiting submission), and 2 submitted Non-Applicability Statements.
Field audits of selected shops that submitted checklists are conducted by DEM Office of Technical and Customer Assistance staff, and enforcement inspections of those not submitting checklists are conducted by DEM Office of Compliance and Inspection staff.
In 2005, RI DEM's Pollution Prevention Program Manager analyzed data from the first round of auto body repair facility certifications received in 2004. The results showed statistically significant improvement in hazardous waste management, air pollution control, pollution prevention measures, wastewater discharge, and worker health and safety. The range of improvement for statistically significant Environmentally Beneficial Performance Indicators (EBPI) was 23 percent to 47 percent, with an average improvement rate of 37 percent overall. Of the 171 shops that certified, 69 submitted a total of 234 Return-to-Compliance plans.
Rhode Island DEM has updated its Certification Workbook and Certification Checklist Package for the next round of voluntary regulatory compliance certifications by auto body repair facilities. Certification packages were mailed in March and returned June 30, 2006. The facilities certify compliance with hazardous waste, air pollution, and water pollution environmental regulations, and Occupational Safety and Health Administration (OSHA) regulations. The Certification Workbook presents regulatory compliance guidance as well as helpful pollution prevention information. Participants are offered free pollution prevention technical and compliance assistance, and are placed on a Certified Facility List on the RI DEM website and receive a Certificate of Participation.
RI DEM completed its second round of self-certification under its Auto Body Repair Facilities Certification Program in 2006.
Since the first certification took place in 2003, the number of auto body repair facilities licensed by the Rhode Island Department of Business Regulation, with the license required by law to operate, declined 8.5 percent from 367 to 336 facilities. To date, 43 percent of these facilities responded, with other facilities requesting short term extensions to complete certification.