New EPA Standards for Air Pollutants
The new Environmental Protection Agency (EPA) compliance deadline for the National Emission Standards for Hazardous Air Pollutants (NESHAP) was in January. Do you think the rule is worthwhile or does it just place more of a burden on the repair industry?
The new standards are worthwhile, and yet, they do place a sizeable burden on shops. The reality is that many repair facilities were already accomplishing many of these requirements by using best practices. Many repairers I talked to this past year commented that they felt they were already close to compliance, with the exception of refinishing training and organizing their documentation.
There’s one note of caution to the collision repair industry: the NESHAP rule—otherwise known as 6H—can either protect a repairer, or expose him to legal liability. This has happened to our industry before. For example, in April 1998 the Occupational Safety and Health Administration (OSHA) Accepted Fit Test protocols went into effect.
Under these guidelines, anyone in the shop who was required to wear a respirator needed an annual fit test and a medical evaluation. The program was to be documented in similar fashion to the NESHAP documentation requirements. The OSHA protocols established a benchmark of the employee’s health at one particular point in time.
Imagine the importance that documentation could provide if a shop was ever legally challenged by an employee later on in their life. It could become your best protection if you have it all in order.
The new NESHAP rule could have similar protective benefits for shops that comply correctly. And shops that don’t comply could be exposed to more legal liability than they may be aware of.
Ray Fisher is the president of ASA-Michigan. This article represents his opinion and does not reflect the views of ASA-Michigan.