A Smooth CAR Ride
THE ROAD TO COMPLIANCE THROUGH THE CAR CHECKLIST
By the CAR Committee
Editor’s Note: This is an overview of the “CAR (Certified Automotive Recycler) Program Guide for All Recyclers,” an extensive checklist that certifies participating automotive recycling facilities meet specified general business, environmental, safety, and licensing standards. The complete CAR standards and program application, along with the full Program Guide, can be downloaded at a-r-a.org/best-practices/programs/car-gold-seal/.
CAR members distinguish themselves as professional recyclers who are committed to meeting the highest compliance standards set by the industry. CAR application procedures include a scoring system designed to more clearly explain the details of the certification process. The scoring system allows users to work toward certification in small steps, and the process can be started and stopped with ease.
An ARA member interested in CAR certification can easily complete the application (found on ARA’s website), then move on to the points protocol or scoring of the shop processes. The licensing requirements are already met by most, if not all, ARA members.
This program overview will determine just how certification-ready your facility measures up. You’ll be surprised how far along you already are in the process to become certified.
The “CAR Program Guide for All Recyclers” contains valuable information and links to ARA University training. The CAR application will include submission of photo proof of some standards, as indicated on the application.
To begin, it is required that the applicant must:
• Be ARA members in good standing.
• Fill out one CAR application per business license.
• Complete the two-page CAR application, which details information about the business as related to facility demographics and operations, and
provides proof of required licenses/permits.
Certified Auto Recyclers comply with all laws and business requirements. For CAR Certification, professional automotive recyclers are required to:
◊ Be a professionally LICENSED RECYCLER in compliance with the state rules that authorize the business to operate (if applicable), other city, county or municipal permits may also apply.
◊ To obtain a Federal Employer Identification Number or FEIN.
◊ To obtain a state sales tax permit.
◊ To obtain a National Motor Vehicle Title Information System (NMVTIS) reporting number and report to the system at least monthly.
Furthermore, other criteria in business practices are:
◊ General Business Standards: Snap seven specific photos required to meet the standards (should only take a few minutes).
◊ Department of Labor: Required Department of Labor Employee information signage is posted.
◊ Customer Parking: Adequate, Well-Graded or Paved, Well-Drained Customer Parking Facility is Separate from the Vehicle Holding Area.
◊ Sales and Reception Area: Clean and Organized Retail Sales Counter and Reception Area.
◊ Signage: Signs in Good Taste and of Positive Tone.
◊ Buildings and Property: Building and Property is Well-Maintained to Reflect a Clean, Orderly, and Safe Operation.
◊ Salvage Vehicle Storage: Safe and Organized areas.
◊ Licensed Delivery and Recovery Vehicles: Delivery and Support Vehicles are Well-Maintained to Ensure Employee and Community Safety.
Now, let’s take a look at some of the other requirements to be considered a Certified Auto Recycler.
CAR Environmental Standards
The CAR Environmental Standards cover a wide array of rules and best management practices. Some general topics such as spill cleanup, fluid management, parts cleaning and stormwater permitting can be addressed in separate pieces so as not to get overwhelmed when new to the program.
Part quality is important to professional auto recyclers because it is what sets ARA members apart from the “junkyards.” To attain the quality and cleanliness desired, parts washing processes of all kinds can be found at automotive recycling facilities.
Solvent parts cleaning is less prevalent in used auto parts shops these days. In most salvage yards, only a small volume or no hazardous waste (spent) solvent is generated.
Shops that do generate spent solvent must manage it as a hazardous waste with off-site disposal through an authorized hazardous waste management company. The storage containers must stayed sealed and be labeled as HAZARDOUS WASTE and, generally speaking, the waste should be sent off-site at least every six months.
To meet the CAR Standard for spent solvent:
◊ Submit a photo of the properly labeled storage drum and verify that hazardous waste shipping manifests are kept on-site in backwards chronological order for the last three (3) years.
◊ Solvent Cleaners: Spent Solvents are Managed as Hazardous Waste and Manifested with a Hazardous Waste Management Company.
Water washing parts is on the increase in used parts preparation. Many salvage yards are washing parts with a power washer, a spray cabinet or a sink basin water-based parts washer. These operations all generate wastewater that must meet local regulations as well as CAR standards.
In nutshell, wash water cannot be discharged on the ground or to a septic system. Salvage yards not on city sewer will need alternative disposal methods. The CAR Standards simply require that wash water or wastewater be disposed in a compliant manner:
◊ Waste Water from Aqueous Parts Washers: Wash Water From Water-based Parts Washers is Either Recycled or Collected For Disposal in an Approved Manner.
◊ Pressure Washer: Overspray of Oily Water Contained and Recycled or Transported for Disposal.
◊ Other Non-Solvent Cleaners: Wash Fluids are Contained and Recycled or Transported for Disposal.
Spill cleanup is so important in the cleanliness of an auto salvage facility that the CAR Standard(s) for spill cleanup are peppered throughout the environmental and safety sections of the point scoring system. The reason for this heavy weighting on spill cleanup is that a clean facility will have fewer environmental and safety concerns than a dirty shop.
Spill kits supplied with the appropriate spill clean material and adequate in volume to manage potential spills are required in the fluid evacuation area, fluid storage areas, crusher area and parts storage areas.
If the on-site storage of gasoline, diesel and/or oil exceeds 1320 gallons (in containers larger than 55 gallons) then an SPCC or Spill Prevention Control and Countermeasure plan is required to be implemented at the facility. A facility with an used oil-fired furnace may fall in to this category. Facilities that do not have used oil furnaces should reduce tankage and increase frequency of pick up by their used oil marketer to stay under the threshold.
Specific standards are:
◊ Spill Clean Up Kit: Adequately sized Spill kit(s) are available in close proximity to the storage and/or removal areas of the fluids listed in the environmental standards section of this application.
◊ All Appropriate Spill Supplies are Available in the following process areas: Fluid Removal & Dismantling Area(s), Sellable Core Storage Area(s) Recyclable Cores (e.g. Engines and Transmissions), Salvage Vehicle Storage Area(s) and Crusher Area.
◊ SPCC If > 1320 gallons of Petroleum Product Storage: More than 1,320 gallon of On-Site Storage for Oil & Fuel AND SPCC Implemented.
◊ Crusher Area: Fluids From Crushing are Contained and Collected For Disposal.
◊ No Spills or Leaks on Ground.
Fluid management is a core component of the CAR Standards. It is the essence of professional auto recycling that the salvage yard is maintained free of contamination. That process starts with fluid evacuation prior to long term storage or crushing of vehicles.
Fluid storage in compatible containers (that are properly labeled) is essential. “Right-sizing” the amount of storage is also important. If an inspector finds a high volume shop with only one 55-gallon drums marked USED OIL then an expectation that less than 25 cars are processed per week and records showing weekly pickup should be readily available.
CAR Standards require both adequate storage and recordkeeping.
If the on-site storage capacity (that means full or empty tanks, totes or drums) of petroleum products such as gasoline, diesel and/or oil exceeds 1320 gallons (in containers 55 gallons or larger) then an SPCC or Spill Prevention Control and Countermeasure plan is required to be implemented at the facility.
Increased regulatory focus on SPCC is raising the bar on secondary containment requirements. Fluid storage should be inside a building or outside with secondary containment. Be mindful that fuels must be stored outside and that the local fire marshal will have an opinion on how far from the building and/or perimeter of the property the gasoline/diesel tanks can be situated.
Specific standards are to ensure that fluids are properly removed as part of the dismantling procedure or prior to crushing the vehicles, including used oil, transmission, brake and power steering fluids, with proper recordkeeping. It also requires proper storage and records for antifreeze, fuel, fluid storage and crusher area.
Recovery of Other Toxins
Fluid evacuation gets a lot of attention but recovery and recycling of other regulated material is equally important. The most important reason to remove the “toxins” from the salvage vehicles is to return the metal to a commodity-like state so that it too can be recycled under the scrap metal exemption. These other wastes are exempt from hazardous waste regulation if recycled.
Recover and recycle mercury switches, batteries, refrigerants, and tires from vehicles during the fluid evacuation or dismantling process. Recordkeeping is especially important on these waste because the generator must prove that the batteries, mercury switches or refrigerants were recycled to be exempt. Tires for the most part are a local regulation.
The Clean Water Act prohibits the discharge of pollutants to the waters of the United States from any point source, unless the discharge is in compliance with a National Pollutant Discharge Elimination System (NPDES) permit. NPDES or stormwater program established a framework for regulating storm water discharge based on industrial activity.
Those industries identified by standard industrial classification (SIC) code include salvage activity. Automotive salvage activity typically uses SIC code 5015 for wholesale used automotive parts. Automotive salvage yards have particular concerns for adding pollutant to storm water runoff due to the sheer number of vehicles present in a yard at any given time.
Storm Water Pollution Prevention Plan (SWPPP). Effective pollution prevention of storm water pollutants is accomplished by choosing applicable Best Management Practices (BMPs) as identified in the SWPPP developed as part of the storm water permit requirements.
The SWPPP must be signed and made available to regulatory inspectors upon request.
Monitoring and Reporting Requirements. In most states, the facility is required to sample runoff for the presence of contamination in storm water discharge. Facilities must retain a copy of the storm water pollution prevention plan, records of all monitoring information, copies of all reports required by the permit, and records of all data used to complete the application for the permit.
Hazard Communication Program
The updated Hazard Communication Standard changed the Safety Data Sheets from the old Material Safety Data Sheet to the new standardized format SDS. Other updates to rule came with the change too. Mainly, that everyone should have a written Hazard Communication Plan and some employee training is required.
The Haz Comm Rule and the CAR Standard require that a Safety Supervisor be named. The employees must be trained on the products as well as the new format of the SDS. The information is widely available at www.osha.gov/dsg/hazcom/index.html
Employees assigned to specialty jobs such as operating a forklift, preparing hazardous material for shipping and operating a cutting torch require special skills and training to perform the task. ARA University has training modules available to keep members’ employee certified.
Shop Safety Supplies
Safety compliance requires the purchase and stocking of basic equipment like personal protective equipment, fire extinguishers, eyewash, spill kit(s) and first aid kit. The CAR Standard simply states that facilities must be compliant with the rules applicable to them based on the OSHA criteria.
Good Sense Standards
In general, CAR standards for certification make good common sense for professional automotive recyclers. Most of the ARA membership practices these standards in their businesses. To determine if you meet all the requirements and to apply for certification, download the full “CAR Program Guide for All Recyclers” from the ARA website.
Raising the level of your business standards brings assurance to your customers that you are dedicated to best business practices, inspires your team to excellence and provides overall industry credibility that is much needed to achieve the goals of ARA such as acquiring part numbers and fending off limiting regulations.