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Self-Audit Checklist

for owners and managers enrolled in the
ColorAll® Compliance Services Program

This checklist has been designed to assist you in complying with environmental and safety regulations. We recommend you review this list on a regular basis and any time you make a change to your process or materials. By taking a proactive approach to determining regulatory compliance, you may avoid unplanned expenditures in the future and continue to meet your responsibility of maintaining a healthy work environment.

By regularly evaluating your process and activities, you can better understand how your business impacts the environment and your employees. It can help you identify areas of potential concern and regulations that may need additional investigation. This checklist is not required by most governing agencies, but is intended to be used as a survey to assess the status of your compliance with regulations that affect your business.

This checklist addresses the general regulatory categories of air, water, land, waste, and hazardous materials, as they relate to surface coating operations and the ColorAll® process.

In addition to legal compliance, another benefit to conducting a self-evaluation is the ability to identify areas of waste and to avoid unnecessary expenses. Many companies can save money by finding ways to avoid costs associated with the storage, treatment, or disposal of non-hazardous and hazardous wastes. By evaluating each operation in the company, opportunities for waste minimization can be realized.

Remember: the benefits of compliance can include a safe and healthy workplace, increased efficiency, wiser use of resources, improved productivity and employee morale, and an enhanced public image.

If you have any questions about this checklist or how to conduct a self-audit, contact Bruce Nash at 954 461 3102

Review each question carefully and check the appropriate box. Any “no” or “cannot determine” answers are indicators that a potential problem exists and should be investigated further. Take notes on the questions that received a “no” or a “cannot determine” response and use this self-audit information to create a working list of environmental compliance issues that may require further investigation.

AIR

Air emissions are the release of any dusts, fumes, gasses, mists, odors, smoke or vapors, or any combination of them, to the outside atmosphere.

If your company has air emissions, have you investigated whether it complies with state or regional requirements for these air emissions?

If your company activities result in air emissions, have these been identified, measured, and documented?

Has the company obtained any air permits required by the state, county, or regional air control board?

Are all of the company’s state or local permits up-to-date?

Does the company periodically monitor whether it remains in compliance with the conditions of the permit?

If the company has made any changes to its materials or processes, has it determined whether or not these changes affect its regulatory compliance?

Does the company use low-VOC (5%) or VOC-compliant materials?

Does the company use high transfer efficiency spray applications or HVLP spray guns?

If the company has ever received complaints regarding odors, noise, or nuisance, has the company eliminated or implemented controls of these emissions, and have the complaints ceased?

Is the company using an emissions control device or structure, if it is required?

Are all odors, visible and invisible emissions, and particulates that are emitted during company activities controlled in compliance with existing regulations and laws?

If a compliance plan is required by your environmental department, has the company submitted it?

If motor vehicles are used in the day-to-day operation of the company, is maintenance conducted on a regular basis to meet inspection standards?

Are employees made aware of the risks of air emissions and given access to material information and MSDS?

Are employees who work around air emissions given sufficient respiratory protection?

If employees use respirators during their work, have they been fit tested and given a medical evaluation?

Has the company created a Respiratory Protection written program?

WATER

Wastewater discharge is the release of sewage, industrial wastewater, stormwater or other pollutants to surface or groundwater.

Has the company investigated whether it complies with local, state and federal regulations for all wastewater discharges?

If the company's activities result in wastewater discharges, have these been identified, measured and documented?

If the company discharges wastewater into a municipal treatment system, is it in compliance with all municipal and federal pre-treatment requirements?

If water is currently used as a cleaning or cooling agent, is the water disposed of properly, in accordance with state regulations?

Are all of the company's state SPDES permits to discharge wastewater up-to-date?

If the company has an industrial activity which is exposed to storm water, does the company have a permit to discharge this storm water?

LAND USE

Has the company investigated whether it complies with all local, state and federal regulations on land use?

SOLID WASTE

Solid waste is any material that is discarded as spent or useless by its owner.

Is the company recycling the materials that are required to be recycled in the community?

If the company contracts with a waste transporter to transport regulated solid or hazardous waste, is the transporter legally permitted?

HAZMAT

Hazardous materials are materials or chemicals that are reactive, corrosive, ignitable or toxic.

Reactive means the material undergoes violent chemical reaction with water. Reactive materials include those that can generate toxic gases or fumes.

Corrosive means the material dissolves metals and other materials, or burns the skin. Corrosive materials include rust or paint removers, acid or alkaline cleaning fluids, and battery acid or material having a pH of 2.0 or lower, or 12.5 or higher is corrosive.

Ignitable means the material catches fire easily. Ignitable materials include many organic solvents, some paint wastes and strong oxidizing agents. A liquid is ignitable if it has a flash point of less than 60 degrees Centigrade (140 degrees Fahrenheit).

Toxic means that the materials, chemicals or fumes maybe noxious, poisonous, venomous, virulent or pestilent. Toxic substances also may have high concentrations of heavy metals such as mercury, cadmium, lead or certain pesticides that could contaminate surface or groundwater.

Has the company investigated whether it complies with all local, state and federal regulations on hazardous material storage, handling and disposal activities?

If the company uses, manufactures or stores chemicals at its site, is it in compliance with the federal mandate (under the SARA Title III Community-Right-to-Know law) to file inventory forms and chemical release information with a local emergency planning committee?

Is local fire protection adequate and equipped to provide protection in the event of an accident or problem involving hazardous or toxic materials?

Has the company determined whether it has hazardous wastes on site?

Has the closest Fire Department been informed of the location and quantities of hazardous materials on site that have the potential to cause fire, explosions, releases of toxic gases or obnoxious odors?

If the company stores hazardous materials on site, are emergency telephone numbers posted along with information about the location of emergency equipment?

If the business generates more than 100 kilograms of hazardous waste in a month or stores more than 1000 kilograms of waste, or if the state has more stringent requirements, has the company obtained an EPA identification number?

Are the chemical names and inventory quantities of the raw materials stored and used on-site readily available along with Material Safety Data Sheets?

Is information about the storage methods on site for all federally regulated hazardous substances used as raw materials continuously updated and readily available?

Are hazardous materials ordered on an as needed basis to avoid stockpiling of hazardous materials?

Are all hazardous or toxic raw materials clearly labeled, easily identifiable and regularly inspected for container leaks, corrosion, rupture or other failures?

Are materials stored so that they do not react with one another or with containers?

Does the storage of hazardous raw materials comply with state and local fire codes?

Are all hazardous or toxic products clearly labeled and easily identifiable?

Does the company have a written emergency response plan?

Have all employees been trained in how to respond to an accidental hazardous materials incident?

Have all employees received hazard communication training?

Is this training continuous and ongoing?

Are materials protected from rain/snow in sealed containers or under tarp or roof? Please note dumpsters need to be closed and sealed to the extent that water will not enter or exit them.

Are paints and thinners stored in containers that are labeled with the contents of the container, are closed with lids tight when not in use, and contained in such a way that a spill would not reach a drain or otherwise leave the facility?

HAZWASTE

A waste is damaged, defective, or superfluous material produced as an unwanted by-product of a manufacturing process, chemical laboratory, or nuclear reactor. A material is not a waste until it is determined that it is no longer needed.

Does your facility generate hazardous wastes?

Does your facility generate more than 100 kg (220lbs.) of hazardous waste per month?

Does your facility have an EPA RCRA ID number?

Do you maintain copies of hazardous waste manifests on-site for 3 years?

Are there containers or tanks that hold hazardous waste?

1. Are the containers and/or tanks clearly marked with the words "Hazardous Waste," and are they marked with the accumulation start date?
2. Are all containers and/or tanks tightly closed and free from leakage?
3. Do satellite accumulation areas contain less than 55 gallons of accumulating wastes?
4. Are all full containers in satellite accumulation areas sealed and dated less than 3 days ago?

Are hazardous wastes stored in accordance with state and federal regulations?

Is care taken to segregate hazardous wastes from non-hazardous wastes?

Are all wastes properly dated and labeled?

Has proper transport, storage and disposal been arranged for any state and federally regulated hazardous wastes resulting from business operations?

If the company contracts with a waste transporter for the disposal of its hazardous wastes, does the transporter have a U.S. Environmental Protection Agency identification number and any applicable local transporter permits?

Does the company's waste transporter have certification to transport the specific types of wastes and quantities of waste produced by the firm?

If the company disposes of its hazardous wastes at a waste Treatment, Storage and Disposal Facility (TSD), does the TSD have U.S. Environmental Protection Agency and any applicable local identification numbers, and is the TSD authorized to accept the type of wastes the company produces?

If hazardous wastes are shipped to a TSD, does the business retain copies of shipping manifests for a minimum of three years?

Does the company have any reason to believe that hazardous waste is disposed of on site?

Has the company determined whether it has hazardous wastes on site?

If the business generates or stores hazardous waste, has it obtained an EPA identification number?

If the company generates or stores hazardous waste, does the company know its generator status?

Are you managing your hazardous waste containers in accordance with the storage container requirements?

Are you complying with the liquid and hazardous waste disposal requirements?

Do your hazardous waste containers appear to be poorly maintained or may otherwise release hazardous waste to the environment?

Do chemicals or wastes appear to have been discharged to the environment through improper handling, leaks, spills, dumping or other discharges?

Does your facility use solvents?

Are used solvents stored in containers that are compatible with the substance they are storing, have no signs of leaks or damage due to major dents or rust, and are closed (lids are on, caps are screwed on tight) except when actually adding or removing liquid?

Are containers labeled “used solvents” or do they show the chemical name of the solvent?

If your company uses rags, are the rags cleaned or disposed in a legal manner?

Are used rags stored in compliance with local and federal laws?

If your company uses absorbents for spills or leaks, have you determined whether used absorbents are considered hazardous before disposal?

Does your facility determine whether paints are considered hazardous before disposal?

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