PLYMOUTH, MI - ASA of Michigan is challenging the Coordinating Committee For Automotive Repair’s (CCAR®) S/P2 certification program, claiming it’s not the only source for environmental training and that it fails to meet compliance requirements within the state.
“The Automotive Service Association of Michigan (ASAM) does not support S/P2 training as the only acceptable source for environmental awareness, nor does the S/P2 program meet all the requirements for environmental compliance in the State of Michigan,” says ASA Michigan Vice President Ray Fisher in a prepared statement. “Furthermore, I am surprised that any insurance carrier would demand these requirements within an agreement or remove a facility for not taking the training. The language of most service agreements already protects them by requiring that the repair facility ‘abide by all local, state and federal laws.’”
According to Fisher, ASA-Michigan recently toured the State with Michigan Department of Environmental Quality (DEQ) staff and rolled out a new environmental compliance training and awareness program. A copy of the program can be downloaded online at www.asamichigan.com. “This program is complete, endorsed and enforced by the Michigan D.E.Q., and is already paid for through our tax dollars. Why not use it?” he says.
Robert Stewart, president of CCAR, defended his program. Stewart claims the entire Michigan Auto Body Environmental Compliance Workbook and Checklist is clearly referenced and integrated within the S/P2 Collision course for Michigan-based users.
CCAR provides S/P2 (Safety & Pollution Prevention) to more than 1,750 automotive career-training programs in all 50 states at no cost to the schools. In the last school year, over 144,000 students had access to the collision or mechanical versions. In Michigan, over 7,800 mechanical and collision students were trained by S/P2 free of charge in the past year, he says.
The DEQ training program to which Fisher refers began two years ago when ASA of Michigan (then Automotive Service Councils of Michigan) and Michigan DEQ began working together to develop a “user friendly” version of the compliance requirements that collision repair facilities must follow. A similar program for the mechanical/transmission repair facilities is being developed.
“ASAM sat down with the DEQ to review environmental guidelines and rules for automotive repair shops. It was requested that materials be developed that were easier for repair facilities to follow and understand. We started working from there and created a simple but complete compliance assessment and guideline,” reports Ron Meyer, president of ASA Michigan. “The support and networking received from the automotive repair industry, DEQ, paint vendors, waste management haulers and private consultants was tremendous and allowed this program to be completed and made available to all Michigan shop owners earlier this year!”
ASA Michigan authorities claim CCAR issues an S/P2 disclaimer that it does not guarantee compliance within a state and refers you to the state website for further information. The link on CCAR’s web page is the “State Contact List” in Michigan http://www.ccar-greenlink.org/contacts/index.html. The link continues until you are at the State of Michigan DEQ website, which is free to everyone.
CCAR’s Stewart claims the content of CCAR’s S/P2 (Safety & Pollution Prevention) training extends beyond that of the Michigan DEQ material to cover both Occupational Safety and Health Administration (OSHA) and U.S. Environmental Protection Agency (EPA) regulatory requirements.
“Guidebooks and checklists are good tools; however, experience has shown us that no regulatory document or program can guarantee compliance,” says Stewart. “In addition, Environmental Results Programs (ERPs) are primarily used only by the owners or managers of repair facilities and can be a valid part of the overall environmental compliance process.”
In cooperation with the EPA, CCAR has operated CCAR-GreenLink®, the Environmental Compliance Assistance Center for Auto Repair, since 1995. “This free service has provided and refined the EPA’s ‘Consolidated Screening Checklist for Automotive Repair Facilities Guidebook,’ which is available for download,” claims Stewart. “We have assisted other states in the development and dissemination of similar ERPs, such as the one Michigan DEQ has recently established.”
He added that in developing the S/P2 training, CCAR has sought to bring vital environmental information, together with applicable safety training derived from federal and state guidelines, to all levels of the automotive repair community – with a focus that includes owners/managers and front-line technicians:
- S/P2 was specifically designed to educate and test comprehension on EPA and OSHA issues in an easy to use format.
- S/P2’s training, testing and validation approach has been adopted by all major original equipment manufacturers (OEMs), as well as thousands of facilities (consolidators, associations, insurers, chains, franchises, associations, federal and state governments, and individual repair shops), and feedback shows it works well.
- S/P2 serves a national audience, which requires ongoing work to be knowledgeable and current with requirements in all 50 states. As regulatory information changes, it is verified and uploaded to all of CCAR’s products.
- S/P2 lends itself to individual facilities as well as multi-unit organizations.
“We are steadily working toward our goal of training every worker and student involved in automotive repair, maintenance and insurance claims handling on S/P2 issues, which in turn will reduce injury, illness and environmental impact,” says Stewart. “The ability to verify a level of safety and environmental compliance awareness in a consistent manner is becoming important to business entities that view social responsibility as part of a sincere mission statement. S/P2 delivers the relevant information in a convenient and user-friendly manner, tests for comprehension, tracks usage, and documents completion. It provides accountability to entities as small as a single shop to the largest OEMs.”
Fisher maintains that the State of Michigan reviewed S/P2 earlier this year and found that it fails to comply with Michigan’s rules. “It is like the customer who buys full coverage on their automobile only to find out at the time of a claim that ‘full coverage’ did not include car rental. Then it is too late,” he says. “The same would hold true for repair facilities in Michigan that feel they are compliant because they have a S/P2 certificate of completion, but are cited for a Michigan non-compliance issue.”
