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Bus and Motor Coach Library

A “Quick Reference” Checklist to EPA and Other Federal Regulations

Author – Carmen Daecher (2002)

If your organization contracts out its service, repair, and maintenance to an outside service garage, it is of course their responsibility to ensure that their facility conforms to all governing regulations. However you are still responsible for the safe and environmentally sound operation of your vehicles, and therefore, you are still required to develop the necessary written procedures and policies, and reporting requirements under the regulations that pertain to operating bus vehicles. 

If you operate your own garage and service facility, the procedures and policies become rather comprehensive, and you probably may require a third-party consultant to efficiently develop or review an effective oversight program, and to manage an on-going self-audit program. 
Should you wish to develop your own procedures and policies then it should be acknowledged that this would require a substantial investment in time and effort.    Firstly, one must become familiar at least on a general level with all aspects of EPA and OSHA regulations.  One should then carry out a detailed accounting of what aspects of one's business might relate to those regulations. 

Once establishing which aspects of your business are subject to EPA and OSHA regulations it is important to set up a framework on which to develop a comprehensive and satisfactory (to authorities) set of procedures and policies that will assure that your operation will adequately comply to EPA and other regulations. 
From this point it becomes more of a "fill in the blanks" game, in which you imbed all details of your procedures and policies.  Once this is complete, the next step is to "test" your procedures and policies.  You do this by considering every possibility and every event that could go wrong, and read through your procedures to ensure that these are adequately addressed as follows:
a)  that every likely event or situation is covered
b)  that the in-place procedure effectively meets proper requirements and solutions according to regulations
c)  that it is readable and easily understood by all staff members
d)  that you conduct an effective well-documented and certified staff training and awareness program
e)  that you develop a comprehensive self-audit system that provides a documented review on a regular basis       

            Unfortunately developing a set of policies and procedures to deal effectively with all relevant regulations that include DOT, EPA, and OSHA, is quite involved.  Regulations require not only written procedures and policies, but staff training, proper record keeping, designated coordinators, and in some cases a reporting mechanism.
Although larger bus operations are relatively well acquainted with DOT, EPA and OSHA regulations, many smaller to mid-sized bus fleet operators are not quite so informed about these regulations.  Most may have heard of the term  "EPA-something" as being some obscure federal administration or jurisdiction, but few really understand the depth and breadth of these regulations, nor do they realize that the EPA - the Environmental Protection Agency - has taken a keen interest in how you as a bus operator conduct your business affairs.

Following, Mr. Daecher provides a checklist and audit information of basic requirements under EPA & OSHA regulations. Your organization's environmental and safety program must comply with the following:

 - Management and proper disposal of wastes such as antifreeze, used oil filters, used oil, absorbents, solvents, paint wastes and filters, scrap tires, batteries, lavatory waste and all other wastes generated.

 -  Management and proper disposal of wastewaters such as service bay drain wastewaters, tank bottom waters, vehicle wash waters and stormwater.

 - Management of fuel storage and liquid storage systems such as underground and aboveground storage tanks and containers used to store used oil or hazardous wastes.

 -  Compliance with clean air requirements for air conditioning servicing, automotive refinishing operations, Stage I and II vapor recovery at gasoline dispensing facilities, use of proper fuels and applicable alternative fuel requirements.

 - Community Right-to-Know reporting of hazardous materials stored on site.

 -  Requirements for recycling of solid wastes and waste minimization.

            Here are 14 additional points that you need to consider in combination with the above elements to make sure that you have an effective program:

- A statement of environmental and safety responsibility endorsed by top management and communicated to all employees;

 -   An environmental and safety management program established throughout your organization;

 -  Environmental and safety responsibilities delegated to a person(s) within the organization;

 -   Appropriate resources and budget been authorized and established by the organization;

 -   Provisions for periodic facility audits and reviews to monitor compliance, measure performance and control costs;

 -   Periodic education, training and awareness at all levels of the organization;

 -   Program objectives that are clearly communicated and responsibilities delegated to appropriate individuals;

 -   Established methods to ensure timely reports and permit renewals to all government agencies;

 -   A procedure for the organization, maintenance and storage of all records;

 -   Procedures to prepare for an EPA, OSHA or DOT inspection;

 -   Procedures for responding to notices of violation and other orders government agencies;

 -   Procedures to evaluate and inspect firms providing waste transport, treatment, storage and disposal of regulated wastes;

 -   Procedures to limit environmental liabilities from the purchase, lease or transfer of real estate;

 -   Policies that are enforced and incentives (or penalties) to maximize employee compliance.

From an OSHA point of view, have you attended to the following:

 -   Do you have descriptions for physical activities and work performed for each job?  Have you performed a job hazard analysis to determine hazards associated with each job?  Have you developed plans for minimizing the hazards defined? 

 -   Do you have a written Hazard Communication Program?  Do you have a complete hazardous chemical inventory list?  Do you have current Material Safety Data Sheets?  Have all employees been trained?

 -   Do you have a Bloodborne Pathogen Control Program?  Have you determined the possible situations where employees may be exposed?  Have you provided appropriate personal protective equipment?  Do you have appropriate spill and clean up kits?  Have the appropriate employees been trained regarding bloodborne pathogens, exposures, protection against exposure, etc.?

 -  Do you have an Emergency Evacuation Plan for fires, natural disasters, and bomb threats?  Have appropriate employees been designated to carry out the plan if an emergency arises?  Have appropriate employees been trained in the use of portable fire extinguishers?  Have all employees been informed of evacuation plans and protocols? 

 -   Do you have Lock-out/Tag-out Procedures if needed?  Have all employees involved in the maintenance of equipment that requires such procedures, been properly trained?

 -   If you use a forklift, have all operators been trained?  Do you have documentation of training?

 -   Have you developed and require the use of appropriate procedures for small tools and equipment, including the use of all safeguards (especially for those bench grinders!)? 

 -   Do you have appropriate medical and hygiene provisions for situations that can occur at the workplace?  Do you have a properly stocked first aid kit?  Do you have an irrigable eyewash station?  If appropriate, do you have a full body shower station?

 -   Have you defined necessary personal protective equipment needed by all employees to safely perform their job?  Have you specified the use of this equipment while performing their jobs?  Have you provided such equipment which can remain at the facility for use by the employees?  Has training been provided for the proper use of all personal protective equipment?

The Audit

The Audit is a Primary Tool to Ensure Continuing Compliance with DOT, EPA & OSHA regulations. One of the most important elements of an environmental and workplace management program is the audit.  An audit is periodic monitoring and review of facilities and operations, recordkeeping, waste handling procedures, etc. A comprehensive self-audit should be conducted at least semi-annually or whenever there is a change in facility coordinators.  The value of an audit is only as good as the person conducting it and the checklist or procedure used.  A good audit will indicate areas that may not be in compliance or which may require further evaluation or corrective action.
If you have let your programs slip regarding environmental and employee health and safety, fix them.  And if you don't have such programs, build them.  Complying with necessary environmental and workplace laws not only gives you piece of mind, but creates the type of environment within which your employees and others can perform their work safely and in good health.

 

Mr. Carmen Daecher, noted industry safety and regulatory consultant, and principal of Daecher Consulting Group (www.safetyteam.com) has developed a comprehensive guide specific to the bus and motorcoach industry that covers all aspects of EPA and other pertinent federal regulations. He has condensed the appropriate regulations and required procedures into a handy "quick reference" checklist, that he has kindly made available the industry. With his permission we have decided to publish this informative checklist and accompanying chart in its entirety. Note that this is merely a checklist, and not a comprehensive company policy, that every company operating bus or coach vehicles is required in writing, and understood and acknowledged by its appropriate employees. If you wish further information or consulting advice you may wish to contact the Daecher Consulting Group, Inc. at (717) 975-9190, or access their website at: www.safetyteam.com .