rhode island’s erp experience: automotive refinishing sector
DESCRIPTION
2007 National Environmental Partnership Summit. Rhode Island’s ERP Experience: Automotive Refinishing Sector. Richard T. Enander, Ph.D. Bureau of Environmental Protection/OTCA RI Department of Environmental Management. What We Liked About the MAERP. - PowerPoint PPT PresentationTRANSCRIPT
Rhode Island’s ERP Experience:Rhode Island’s ERP Experience: Automotive Refinishing SectorAutomotive Refinishing Sector
Richard T. Enander, Ph.D. Richard T. Enander, Ph.D. Bureau of Environmental Protection/OTCABureau of Environmental Protection/OTCA
RI Department of Environmental ManagementRI Department of Environmental Management
2007 National Environmental Partnership Summit
What We Liked About the MAERPWhat We Liked About the MAERP RI 1RI 1stst state to adopt MADEP model + health state to adopt MADEP model + health Statistically Based Performance Measurement Statistically Based Performance Measurement Self-evaluation and accountability through Self-evaluation and accountability through
comprehensive certificationcomprehensive certification Accommodates multimedia pollution and worker healthAccommodates multimedia pollution and worker health Capable of reaching larger segment of the regulated Capable of reaching larger segment of the regulated
community than traditional enforcement programscommunity than traditional enforcement programs SupplementsSupplements traditional inspection programs and traditional inspection programs and does does notnot replace existing regulatory structures replace existing regulatory structures
Environmental Results ProgramEnvironmental Results Program RI experience--best applied where uniform RI experience--best applied where uniform
enforcement is difficult to achieve:enforcement is difficult to achieve: • Auto body industryAuto body industry
Est. 4 RIDEM Divisions (Air, Water, Waste, OC&I) and Est. 4 RIDEM Divisions (Air, Water, Waste, OC&I) and OSHA inspected OSHA inspected <5%<5% of all licensed shops (n=367)of all licensed shops (n=367) in in any given yrany given yr
Probability of multimedia inspection = Probability of multimedia inspection = 00
• Auto salvage yards, exterior lead paint removal contractors, Auto salvage yards, exterior lead paint removal contractors, underground storage tanks, hospitality industry (future)underground storage tanks, hospitality industry (future)
Why the Auto Body Sector?Why the Auto Body Sector? Environment-Health ConcernsEnvironment-Health Concerns:: EnvironmentalEnvironmental
Avg. size shop 5 people; <5 cars per weekAvg. size shop 5 people; <5 cars per week Chemicals used/released diverse & variable:Chemicals used/released diverse & variable:
- VOCs (1,600 tons), MeCl strippers (1/5 shops)- VOCs (1,600 tons), MeCl strippers (1/5 shops) Hazardous Waste ~ 3-55 gal drums per shop per yr.Hazardous Waste ~ 3-55 gal drums per shop per yr. RIDEM received neighbor complaintsRIDEM received neighbor complaints Fugitive sanding dust emissions (toxic metals)Fugitive sanding dust emissions (toxic metals)
-15 cars/wk > 100 lbs./yr-15 cars/wk > 100 lbs./yr Take-home toxicsTake-home toxics
Environment-Health ConcernsEnvironment-Health Concerns: : RI Auto Body IndustryRI Auto Body IndustryWorker HealthWorker Health
Documented workplace exp: isocyanates, paint solvents,Documented workplace exp: isocyanates, paint solvents,MeCl strippersMeCl strippers
Lead exposureLead exposure Work clothesWork clothes Lead Screening: RI Department of Health
Blood Pb Data (ug/dl)Office/Painter 3-6Bodymen 28, 38
17 Avg.Nat’l Avg. <3
Work shirt Work shirt (ug/8in(ug/8in22) ) (fd=4/5)(fd=4/5) MinMin Med Med MaxMax
PbPb 2266 4545
Hand wipesHand wipes (total ug)(total ug)(fd=6/6)(fd=6/6) Min Min MedMed MaxMax
PbPb 33 104104 211211
Results Published in Peer-Reviewed Literature:Results Published in Peer-Reviewed Literature:
American Journal of Industrial Medicine 44:312-320 (2003) American Industrial Hygiene Association Journal 63:741.749 (2002) American Industrial Hygiene Association Journal 59:478-489 (1998)
Abstracts available at RIDEM website: http://www.dem.ri.gov/programs/benviron/assist/pdf/peer.pdf
RI Autobody ERPRI Autobody ERP
Voluntary program Voluntary program Shops Shops self-certifyself-certify to RIDEM that they to RIDEM that they
were complying with environmental were complying with environmental and occupational health protection and occupational health protection requirementsrequirements
IncentivesIncentives Incentives to participateIncentives to participate
- Reduced inspection priority - Reduced inspection priority
- Opportunity to come into compliance - Opportunity to come into compliance without fear of enforcement action without fear of enforcement action
- RIDEM/DOH technical & compliance - RIDEM/DOH technical & compliance assistanceassistance
- Random - Random regulatory inspectionsregulatory inspections for for non-participantsnon-participants
Environmental Results ProgramEnvironmental Results Program
ERP Implementation Steps:ERP Implementation Steps:1.1. Establish Industry Baseline PerformanceEstablish Industry Baseline Performance
2. Launch Environmental Results Program2. Launch Environmental Results Program3. Receive/Tabulate Checklist & RTC Data3. Receive/Tabulate Checklist & RTC Data
(A/B 6 mos. after launch)(A/B 6 mos. after launch)
4. Conduct Post-ERP Inspections and 4. Conduct Post-ERP Inspections and Statistical Analysis of Field DataStatistical Analysis of Field Data
Environmental Results ProgramEnvironmental Results Program
ERP Implementation Steps:ERP Implementation Steps:
1.1. Establish Industry Baseline PerformanceEstablish Industry Baseline Performance- conduct random facility inspections - conduct random facility inspections
- # statistically pre-determined: n- # statistically pre-determined: n11 = 40; n = 40; n22=42=42
Idea is to use statistics used to measure Idea is to use statistics used to measure changechange
““Before” and “After” comparisons made to Before” and “After” comparisons made to determine program effectivenessdetermine program effectiveness
Performance MeasurementPerformance Measurement
Environmental Results ProgramEnvironmental Results Program
ERP Implementation Steps:ERP Implementation Steps:
2. Launch Environmental Results Program2. Launch Environmental Results Program
- mail certification workbook and checklists- mail certification workbook and checklists
- conduct workshops- conduct workshops
Autobody Certification WorkbookAutobody Certification Workbook
Explains regulations Explains regulations (in plain English)(in plain English)
Designed to be used Designed to be used in conjunction with in conjunction with the accompanying the accompanying self-certification self-certification checklist and to be checklist and to be used as a reference used as a reference in the facilityin the facility
Autobody Certification WorkbookAutobody Certification Workbook
Air Issues Wastewater Issues Hazardous Waste Pollution Prevention Worker Health and
Safety Example Plans
Certification ChecklistCertification Checklist
The checklist The checklist contains a series of contains a series of compliance questions, compliance questions, which generally which generally require “yes” or “no” require “yes” or “no” answers about answers about whether or not the whether or not the facility is following facility is following applicable applicable environmental and environmental and occupational health occupational health and safety and safety requirementsrequirements
Environmental Results ProgramEnvironmental Results Program
ERP Implementation Steps:ERP Implementation Steps:
3. Receive Self-cert. Checklist & RTC Data3. Receive Self-cert. Checklist & RTC Data
- 367 DBR licensed shops- 367 DBR licensed shops
-171 voluntary certifications/15 NA statements-171 voluntary certifications/15 NA statements
-49% participation rate-49% participation rate
-271 Return-to-Compliance Plans w/ checklists filed-271 Return-to-Compliance Plans w/ checklists filed
Examples of Examples of Return to Return to
Compliance Compliance Plan Plan
Submittals Submittals (Authorized (Authorized
Agents)Agents)
Return to Return to Compliance Compliance Plans (UIC)Plans (UIC)
Saw cuts for floor Saw cuts for floor trench systemtrench system
RTC RTC (wash (wash water water runoff runoff prevention )prevention )
Return to Return to Compliance Compliance
Plans Plans (Employee (Employee
Medical Medical Exams)Exams)
……body shop body shop work bench work bench area before area before
ERPERP(large, high (large, high
volume volume facility)facility)
……same shop before ERP and same shop before ERP and dustless vacuum systemdustless vacuum system
New booths and cleaner shop after ERPNew booths and cleaner shop after ERP
Environmental Results ProgramEnvironmental Results Program
ERP Implementation Steps:ERP Implementation Steps:4. Conduct Post-ERP Inspections and Statistical 4. Conduct Post-ERP Inspections and Statistical
Analysis of Field DataAnalysis of Field Data
- random facility post-ERP inspections - random facility post-ERP inspections
- # statistically pre-determined: n- # statistically pre-determined: n11 = 40; = 40; nn22=42=42
Contact InformationContact InformationRichard Enander, [email protected] Enander, [email protected] of Technical & Customer AssistanceOffice of Technical & Customer AssistanceRI Department of Environmental ManagementRI Department of Environmental ManagementTel. 401/222-4700 ext. 4411Tel. 401/222-4700 ext. 4411
RIDEM Auto Body Web Address:RIDEM Auto Body Web Address: www.state.ri.us/DEM/programs/benviron/assist/ www.state.ri.us/DEM/programs/benviron/assist/ index.htmindex.htm