The approved assessors who carry out the inspections of bodyshops for compliance with the paints regulations have reported back to the Environmental Protection Agency (EPA) on the initial findings of their first three months of inspections, and this has provided useful information on common issues which arise during the assessment.
The table below includes details of a few areas which vehicle refinishers may wish to consider addressing to improve their chances of having a compliant assessment report.
|Spray gun transfer efficiency
||You should retain the relevant technical documentation for new spray guns and obtain a hard copy of the technical specification for existing equipment in order to demonstrate the transfer efficiency of the gun.
||In some cases no records are available to demonstrate staff are adequately trained. When training is provided to your staff (e.g. by a contractor or by a paint company), complete a brief training sheet indicating who was present at the training, who provided the training, the date provided and the content of the training. Get the trainer and trainees to sign the record.
|Certificate of compliance on display/available.
||Ensure your current certificate is on display. Plan your next inspection in good time so that your new certificate is still valid during the approved assessor inspection.
||A copy of the waste collectors permit/licence for the company collecting your waste should be available for review on your site. Wastes must not be collected by un-regulated operators. Your waste contractor can provide you with a copy of their permit/licence. You should also keep a record of all solvent-containing waste collections from your site. All solvent waste must be stored in closed containers.
|Paints products list
||A list of products purchased/used, broken down into the relevant product categories should be maintained. This should be updated as necessary. Your paint supplier should be able to help you with this task.
|Use of non-compliant products
||Only compliant products should be used. This is a major non-compliance and may lead to prosecution. All relevant products must be properly labelled and technical data sheets for the products should also be available to verify their solvent content.