Audit Compliance Education (ACE) Program Automotive Environmental Compliance VACC OHSE Unit 1
WorkSafe Victoria Introduction • Program Background and Results • Automotive Industry • Environmental Risks of the Industry • Environmental Solutions • Questions VACC IR, OHS & Training – HR Forum 2
WorkSafe Victoria Program background and Results • In 2012, the EPA Annual Plan highlighted body repairers and part recycler activities as an environmental risk in certain locations around Melbourne. • EPA conducted research and consulted with industry stakeholders on the issue. • The VACC were approached by EPA Victoria to conduct a funded pilot program to assist Small and Medium Enterprises (SME) in Body Repair and Parts Recycling. • The program was titled Audit Compliance Education (ACE Program), which outlines the phases of the SME assistance program. – Phase 1- Conduct 100 audits across Body Repairers and Part Recycler SMEs. – Phase 2- Education via seminars and guidance for the industry. • Part of the education was to produce an Automotive Industry Environmental Guide and fact sheets to assist SMEs. VACC IR, OHS & Training – HR Forum 3
WorkSafe Victoria Program background and Results Data from the environmental audits was collated and analysed to determine industry environmental issues. From the audit data the top issues were: Body Repair • Inadequate spill response • Vehicle Washing to stormwater • Bunding of chemicals was inadequate • Management of Prescribed Waste Parts Recycler • Inadequate spill response • Bunding of chemicals • Site contamination 4
WorkSafe Victoria Program background and Results From the audits, VACC also analysed the common compliance barriers. The barriers identified were: Cost Implications Lack Compliance Infrastructure Knowledge on Barriers Limitations Compliance Lack of Service Providers VACC IR, OHS & Training – HR Forum 5
WorkSafe Victoria Environmental Laws Act • EPA Act • State Environmental Protection Policies SEPPs, Regs, • Regulations WMPs, NCOs • Waste Management Policies • Notifiable Chemical Orders Guidance • Practice Guidance * Note. Some of these documents are referred to in SEPPs, WMPs and Regulations. VACC IR, OHS & Training – HR Forum 6
WorkSafe Victoria Environmental Laws Below is a list of the main environmental issues covered by the Act: • Pollution of Air, land and Water • Waste • Litter • Noise • Motor Vehicles • Hazardous Chemicals For further information on the above refer to the EPA website for fact sheets and guidance. VACC IR, OHS & Training – HR Forum 7
WorkSafe Victoria Environmental Laws Waste Management Hierarchy Preferable EPA Guiding Principle for waste management and Recycling. The Act states that all waste should be managed in accordance with the hierarchy. Least Preferable VACC IR, OHS & Training – HR Forum 8
WorkSafe Victoria Environmental Risks of the Industry 9
WorkSafe Victoria Water Pollution Chemicals and processes near drains – Waste oil and chemicals stored near drains and/or near workshop entries that lead to drains – Wet rubbing runoff to stormwater drains Leaking chemical containers and bins – Waste bins onsite leak and go to stormwater drains – Empty chemical containers leak (residue) or have rain wash off go to stormwater – Old vehicle batteries are uncovered and leak Workshop cleaning – Workshop floor cleaning with mop/bucket is emptied to stormwater or hose down to stormwater Lack of spill response VACC IR, OHS & Training – HR Forum 10
WorkSafe Victoria Water Pollution Car washing • Washing to stormwater • Sites not having triple interceptors/oil water separators • Car washing areas (that have triple interceptors/oil water separators) aren’t adequately bunded and it runs off to stormwater VACC IR, OHS & Training – HR Forum 11
WorkSafe Victoria Air Pollution • Uncontrolled spray painting outside of spray booths (more to do with preparation and priming). • Paint fume issues due to inadequate spray booths and stack heights (this includes odour issues). • Air conditioning gas recovery and handling. VACC IR, OHS & Training – HR Forum 12
WorkSafe Victoria Land Pollution • Chemical spills and Storing Chemicals on unsealed ground: – Parts containing oils are stored on dirt/gravel areas of yards – Vehicle leaks- Stored onsite or work conducted outside – Waste oil drums or tanks on dirt, i.e. oil leaches into the soil – Other waste liquids or sludges in drums and tanks on dirt VACC IR, OHS & Training – HR Forum 13
WorkSafe Victoria Land Pollution • Underground tanks – Underground oil or fuel tanks without leak detection mechanisms • Lack of spill response VACC IR, OHS & Training – HR Forum 14
WorkSafe Victoria Noise Pollution Noisy plant such as: – Loud extraction fans from body repairers – Air compressors – Pressure washer (used outdoors) – Pneumatic tools (e.g. impact wrench) Loud processes: – Body repair work – Cutting processes – Changing of tyres work 15
WorkSafe Victoria Wastes of the Industry Below are the main automotive industry wastes that are deemed as Prescribed Industrial Waste (PIW) and can be a risk: Waste Oil and Coolant • Potential to spill Spent Oil Filters • Incorrectly disposed and leaks Empty chemical drums and • Incorrectly disposed containers with residue (plastic or • Leaks can contaminate recycling processes steel) Used gun wash and paint sludge • Potential to spill 16
WorkSafe Victoria Wastes of the Industry Spray booth water (wet booths) • Incorrectly disposed • Incorrectly disposed Used solvents and solvent recovery sludge • Potential to spill • Incorrectly disposed Oil Water Separator /Triple Interceptor Sludge • Potential to spill or leak (depends on system type) • Incorrectly disposed Waste paint tins, cups and rags • Leaks can contaminate recycling processes Old LPG tanks • Fire and explosive risk Old batteries • Potential to leak • Incorrectly disposed Old tyres • Fire and biological risk in large quantities • Incorrectly disposed Used spill absorbent materials • Potential to leach 17
WorkSafe Victoria Environmental Solutions 18
WorkSafe Victoria Chemicals Management Bunding and Storage Locations A bund is a device intended to prevent the uncontrolled escape of hazardous liquid into stormwater, sewerage or soil. Bunding can be designed in a number of ways including: – A designated storage area located within a building to prevent any spillage from reaching stormwater or the sewer, – A sealed building to prevent the escape of spills, – A small area within a building designed to contain spills, – A large raised container that liquid containers/drums are placed into. VACC IR, OHS & Training – HR Forum 19
WorkSafe Victoria Chemicals Management VACC IR, OHS & Training – HR Forum 20
WorkSafe Victoria Chemicals Management VACC IR, OHS & Training – HR Forum 21
WorkSafe Victoria Chemicals Management 22
WorkSafe Victoria Chemicals Management 23
WorkSafe Victoria Chemicals Management 24
WorkSafe Victoria Chemicals Management Selection of chemicals – Look at chemicals that are safer for the environment and the human user. For example, changing from solvent based parts washers to solvent free (biological based system) – Prior to purchase, review the Material Safety Data Sheet and discuss with the supplier the disposal options of the used chemical and the packaging – Reduce the quantity of chemicals stored and used onsite VACC IR, OHS & Training – HR Forum 25
WorkSafe Victoria Chemicals Management Spills response – Spill kits should be present in workshops to address chemical spills from accidental release from vehicles, containers and work processes. – Use the correct spill absorbents for the potential chemical spills. Spill absorbents do vary. – Ensure all employees are adequately trained on spill response – Conduct inspections on the spill response equipment to ensure it is well stocked. – Avoid employees and customers from putting rubbish in wheelie bin style spill kits – Refer to MSDS to follow spill and disposal instructions. 26
WorkSafe Victoria Plant and Equipment Management Noise reduction measures – Substitute plant and equipment for quieter models – Relocate plant and equipment – Isolate/sound proof plant, equipment and processes – Service plant and equipment to reduce noise and improve efficiency – Review operational hours of work and/or processes VACC IR, OHS & Training – HR Forum 27
WorkSafe Victoria Plant and Equipment Management Spray Painting and Spray Booths What are you spray painting with? Enamel paints Iso-cyanate based paints Water based paints VACC IR, OHS & Training – HR Forum 28
WorkSafe Victoria Plant and Equipment Management Spray Booth Compliance- Must comply to AS4114 Maintenance is required on booths to ensure they are working efficiently Filter changes (roof and floor) are changed regularly. Water system booths are dosed and cleaned out regularly VACC IR, OHS & Training – HR Forum 29
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