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Conduct self-audits to stay ahead of OSHA

November 18, 2010

Dealers should perform quarterly audits—on their own or with a consultant—for compliance with federal, state and local regulations on environmental, health and safety compliance.


The top environmental infractions over the last five years, in terms of the cost to dealers, have been: 

  • Failure to register motor vehicle air conditioning recycling equipment, used to recycle refrigerant, with the Environmental Protection Agency. Registration requires a specific form and location. As few as 5 percent of dealers are estimated to be registered.
  • Failure to have all technicians certified to work on air conditioning systems and certified in refrigerant reclamation, in accordance with Section 609 of the Clean Air Act. All records must be kept on site. An estimated 15 percent of dealers are compliant. 

Another matter is Department of Transportation hazardous materials training for parts personnel. Inspectors for the Federal Aviation Administration reportedly have visited dealers and asked for the names of employees who shipped DOT hazardous materials without certification.


Certification is critical because parts such as air bags, considered a HAZMAT, are shipped between dealers all over the country.