RI Auto Body Repair Facilities Certification Program “Environmental and Occupational Health Compliance” RI Department of Environmental Management Office of Technical & Customer Assistance

Certification/Environmental Results Program Best applied in sectors where uniform enforcement is difficult to achieve: Best applied in sectors where uniform enforcement is difficult to achieve: - Auto body industry - Auto salvage yard facilities - Exterior lead paint removal contractors - Underground storage tanks

Auto Body Industry Fewer than 350 shops in Rhode Island (2006); 1,600 tons VOCs Fewer than 350 shops in Rhode Island (2006); 1,600 tons VOCs Mostly small business: Mostly small business: Average of 5 employees; 60% of shops employ ≤ 4 people Average of 5 employees; 60% of shops employ ≤ 4 people Average of 5 vehicles per week Average of 5 vehicles per week Under-regulated Under-regulated * National Estimates u ~60,000 facilities nationwide u $26 billion industry u >450,000 people u 286,000 tons of VOC’s

RI Auto Body Repair Facilities Certification Program Participation in program is voluntary Participation in program is voluntary First round of certification checklists submitted First round of certification checklists submitted in 2003, second round submitted in 2006 in 2003, second round submitted in 2006 Shops self-certify to RIDEM/OTCA that they are Shops self-certify to RIDEM/OTCA that they are complying with environmental and occupational complying with environmental and occupational health protection requirements health protection requirements All auto body facilities operating in the State of All auto body facilities operating in the State of Rhode Island must comply with the standards, Rhode Island must comply with the standards, whether or not they self-certify whether or not they self-certify

RI Auto Body Repair Facilities Certification Program Incentives to participate: - Reduced inspection priority for participants - Reduced inspection priority for participants - Opportunity to come into compliance without - Opportunity to come into compliance without fear of enforcement action and gravity based penalties fear of enforcement action and gravity based penalties - RIDEM/URI/RIDOH technical & compliance - RIDEM/URI/RIDOH technical & compliance assistance assistance - Random regulatory inspections for - Random regulatory inspections for non-participants non-participants

RI Auto Body Repair Facilities Certification Program Three Major Components: 1. Compliance Certification - clear standards, accountability, self-evaluation - clear standards, accountability, self-evaluation 2. Performance Measurement 2. Performance Measurement - statistically-based, inspections & enforcement - statistically-based, inspections & enforcement 3. Technical/Compliance Assistance

RI Auto Body Repair Facilities Certification Program 1. Compliance Certification: 1. Compliance Certification: Components: Components:  Certification Workbook  Self-Certification Checklist

Auto Body Certification Workbook Explains regulations (in plain language) Explains regulations (in plain language) Designed to be used in conjunction with the accompanying self-certification checklist, and to be used as a reference in the facility Designed to be used in conjunction with the accompanying self-certification checklist, and to be used as a reference in the facility

Auto Body Certification Workbook Major Contents: Air Issues Water Pollution Control Hazardous Waste Pollution Prevention Worker Health and Safety Sample 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 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

Certification Checklist Checklist confirms compliance status Checklist confirms compliance status Self survey - used to determine where to make improvements Self survey - used to determine where to make improvements Required to submit checklist and RTCs to RIDEM/OTCA Required to submit checklist and RTCs to RIDEM/OTCA Failure to submit by a designated date may result in inspection Failure to submit by a designated date may result in inspection

Auto Body Industry - Certification Example of checklist questions:

Statistics used to measure change Statistics used to measure change Baseline - 40 out of 400 shops randomly selected and visited; average compliance rates determined Baseline - 40 out of 400 shops randomly selected and visited; average compliance rates determined After self-certification completed, another 40 shops randomly selected and audited or inspected for compliance status After self-certification completed, another 40 shops randomly selected and audited or inspected for compliance status “Before” and “After” comparisons made to determine program effectiveness “Before” and “After” comparisons made to determine program effectiveness 2. Performance Measurement

3. Technical Assistance Participating shops may need assistance to comply with regulations (on-site, telephone, ) URI and RIDEM/OTCA provide free consultation to help correct problems, such as: URI and RIDEM/OTCA provide free consultation to help correct problems, such as: –Facility modification for wash water –Drum labeling and management Companies still need to spend time and money, but costs can be minimized with technical assistance Companies still need to spend time and money, but costs can be minimized with technical assistance

Example of a “Return-to- Compliance Plan” (RTC) Submitted (Authorized Agents)

Example of a “Return-to- Compliance Plan” (RTC) Submitted (Employee Medical Exams)

2003 Results 367 RI DBR auto body shop licensees 367 RI DBR auto body shop licensees 171 completed checklists returned 171 completed checklists returned 15 businesses filed “Facility Non- Applicability Statement” 15 businesses filed “Facility Non- Applicability Statement” 51% response rate 51% response rate 282 Return-to-Compliance Plans w/ checklists filed with RIDEM/OTCA 282 Return-to-Compliance Plans w/ checklists filed with RIDEM/OTCA

RI Auto Body Repair Facilities Certification Program

2006 Results 336 RI DBR auto body shop licensees 336 RI DBR auto body shop licensees 140 completed checklists returned 140 completed checklists returned 5 businesses filed “Facility Non- Applicability Statement” 5 businesses filed “Facility Non- Applicability Statement” 43% response rate 43% response rate 94 Return-to-Compliance Plans w/ checklists filed with RIDEM/OTCA 94 Return-to-Compliance Plans w/ checklists filed with RIDEM/OTCA

RI Auto Body Repair Facilities Certification Program Underground Storage Tanks Underground Storage Tanks Auto Salvage Yard Facilities Auto Salvage Yard Facilities Exterior Lead Paint Removal Contractors Exterior Lead Paint Removal Contractors Hospitality Green Certification Hospitality Green Certification Other industry sectors being pursued:

Contact Information RI Department of Environmental Management RI Department of Environmental Management Office of Technical & Customer Assistance 235 Promenade Street Providence, RI Tom ArmstrongTelephone: (401) , Ext Tom ArmstrongTelephone: (401) , Ext Fax:(401) RIDEM Auto Body Web Address: