Audit, Compliance and Risk Blog

Common Violations at Dealerships, Service and Repair Facilities

Posted by STP Editorial Team on Mon, Dec 09, 2013 on a limited survey of the Certified Unified Program Agencies (CUPAs) of the California Environmental Protection Agency (Cal/EPA), the Department of Toxic Substances Control (DTSC) found the following top eight violations:

  • Improper, incomplete, worn or missing labels

  • Improper container management including not closed, in poor condition or not secure

  • Missing manifests, consolidated manifest receipts, bill of lading, recycling and disposal receipts for oil filters, brake metal shavings, used oil, used solvent, and used antifreeze

  • Lack of weekly container and daily tank inspections including logs

  • Conducting and documenting training

  • Housekeeping problems including keeping secondary containment clean and dry at all times, cleaning up spills and failing to minimize a release

  • No accumulation start dates

  • Incomplete Contingency or Business Plans.

Portable Fire Extinguisher Maintenance and Standards Updates

Effective October 1, 2013, the State Fire Marshal is amending the regulations for portable fire extinguishers, specifically regarding maintenance for electronic monitoring, extinguisher cabinets, and water mist type extinguishers. These changes also clarify fire extinguisher licensee requirements, update language to be consistent with national standards, and update versions of several standards for testing of portable fire extinguishers that are incorporated by reference. (California Notice Register 2013 No. 30-Z, page 1124; July 26, 2013.)

Installation of Sprinkler Systems for Fire Control

Effective October 1, 2013, Cal/OSHA is updating the sprinkler installation standards in various sections in Title 8, which refer to an outdated version of NFPA 13 (Standard for the Installation of Sprinkler Systems). This action removes references to NFPA 13 and amends the rules to use the word “approved” for all references to sprinklers or other fire protection systems and equipment. Where appropriate, a note referring to the California Fire Code (CFC) for more information has been added. The word “approved” is defined as referring “to products, materials, devices, systems, or installations that have been approved, listed, labeled, or certified as conforming to applicable governmental or other nationally recognized standards, or applicable scientific principles.” Using this definition of “approved” allows for compliance using a variety of methods, including NFPA 13 and the CFC. Rules impacted by this action include fire control requirements for flammable and combustible liquid storage, processing plants, and tanks inside buildings; and standards for automatic sprinkler systems installed in any work place. (California Notice Register 2013 No. 31-Z, page 1144; August 2, 2013.)

STP has recently published an update to Vehicle Maintenance Facilities in California: A Federal and State Compliance Guide and also publishes the following related guides:

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Tags: Corporate Governance, Health & Safety, Environmental risks, Environmental, EPA