Rhode Island’s ERP Experience: Automotive Refinishing Sector Richard T. Enander, Ph.D. Bureau of Environmental Protection/OTCA RI Department of Environmental Management 2007 National Environmental Partnership Summit

What We Liked About the MAERP  RI 1 st state to adopt MADEP model + health  Statistically Based Performance Measurement  Self-evaluation and accountability through comprehensive certification  Accommodates multimedia pollution and worker health  Capable of reaching larger segment of the regulated community than traditional enforcement programs  Supplements traditional inspection programs and does not replace existing regulatory structures does not replace existing regulatory structures

Environmental Results Program RI experience--best applied where uniform enforcement is difficult to achieve: RI experience--best applied where uniform enforcement is difficult to achieve: Auto body industryAuto body industry  Est. 4 RIDEM Divisions (Air, Water, Waste, OC&I) and OSHA inspected <5% of all licensed shops (n=367) in any given yr  Probability of multimedia inspection = 0 Auto salvage yards, exterior lead paint removal contractors, underground storage tanks, hospitality industry (future)Auto salvage yards, exterior lead paint removal contractors, underground storage tanks, hospitality industry (future)

Why the Auto Body Sector? Environment-Health Concerns : Environmental uAvg. size shop 5 people; <5 cars per week uChemicals used/released diverse & variable: - VOCs (1,600 tons), MeCl strippers (1/5 shops) uHazardous Waste ~ 3-55 gal drums per shop per yr. uRIDEM received neighbor complaints uFugitive sanding dust emissions (toxic metals) -15 cars/wk > 100 lbs./yr -15 cars/wk > 100 lbs./yr uTake-home toxics

Environment-Health Concerns : RI Auto Body Industry Worker Health u Documented workplace exp: isocyanates, paint solvents, MeCl strippers u Lead exposure u Work clothes Lead Screening: RI Department of Health Blood Pb Data (ug/dl) Office/Painter 3-6 Bodymen 28, Avg. Nat’l Avg. <3

Work shirt (ug/8in 2 ) Work shirt (ug/8in 2 ) (fd=4/5)Min MedMax Pb2645 Hand wipes (total ug) Hand wipes (total ug) (fd=6/6)Min MedMax Pb

Results Published in Peer-Reviewed Literature: Results Published in Peer-Reviewed Literature: American Journal of Industrial Medicine 44: (2003) American Industrial Hygiene Association Journal 63: (2002) American Industrial Hygiene Association Journal 59: (1998) u u Abstracts available at RIDEM website:

RI Autobody ERP  Voluntary program  Shops self-certify to RIDEM that they were complying with environmental and occupational health protection requirements

Incentives  Incentives to participate - Reduced inspection priority - Reduced inspection priority - Opportunity to come into compliance without fear of enforcement action - Opportunity to come into compliance without fear of enforcement action - RIDEM/DOH technical & compliance assistance - Random regulatory inspections for non-participants non-participants

Environmental Results Program ERP Implementation Steps: 1. Establish Industry Baseline Performance 2. Launch Environmental Results Program 2. Launch Environmental Results Program 3. Receive/Tabulate Checklist & RTC Data (A/B 6 mos. after launch) 4. Conduct Post-ERP Inspections and Statistical Analysis of Field Data

Environmental Results Program ERP Implementation Steps: 1. Establish Industry Baseline Performance - conduct random facility inspections - # statistically pre-determined: n 1 = 40; n 2 =42

 Idea is to use statistics used to measure change  “Before” and “After” comparisons made to determine program effectiveness Performance Measurement

Environmental Results Program ERP Implementation Steps: 2. Launch Environmental Results Program - mail certification workbook and checklists - conduct workshops - conduct workshops

Autobody Certification Workbook  Explains regulations (in plain English)  Designed to be used in conjunction with the accompanying self-certification checklist and to be used as a reference in the facility

Autobody Certification Workbook   Air Issues   Wastewater Issues   Hazardous Waste   Pollution Prevention   Worker Health and Safety   Example Plans

Certification Checklist  The checklist contains a series of compliance questions, which generally require “yes” or “no” answers about whether or not the facility is following applicable environmental and occupational health and safety requirements

Environmental Results Program ERP Implementation Steps: 3. Receive Self-cert. Checklist & RTC Data DBR licensed shops -171 voluntary certifications/15 NA statements -49% participation rate -271 Return-to-Compliance Plans w/ checklists filed

Examples of Return to Compliance Plan Submittals (Authorized Agents)

Return to Compliance Plans (UIC)

Saw cuts for floor trench system RTC (wash water runoff prevention )

Return to Compliance Plans (Employee Medical Exams)

…body shop work bench area before ERP (large, high volume facility)

…same shop before ERP and dustless vacuum system

New booths and cleaner shop after ERP

Environmental Results Program ERP Implementation Steps: 4. Conduct Post-ERP Inspections and Statistical Analysis of Field Data - random facility post-ERP inspections - # statistically pre-determined: n 1 = 40; n 2 =42 - # statistically pre-determined: n 1 = 40; n 2 =42

Contact Information Richard Enander, Office of Technical & Customer Assistance RI Department of Environmental Management Tel. 401/ ext RIDEM Auto Body Web Address: index.htm