As a member of the Greater New York Auto Dealers Association (GNYADA), Walden Environmental Engineering, PLLC (Walden) is aware of the issues that face car dealerships in their day to day operations. Representative examples the various environmental and health and safety consulting services Walden provides to dealerships are presented below.
- Walden was retained to perform a compliance inspection for a car dealership located in New York City whose facilities included three mechanic shops and vehicle drop off facility. The intent of the inspection was to identify any issues which might warrant a violation or fine from various regulatory agencies such as the New York City Department of Environmental Protection (NYCDEP), New York State Department of Environmental Conservation (NYSDEC), New York City Fire Department (FDNY) and OSHA. After identifying the various issues discovered during the inspection, Walden discussed remedies with the client, identifying which parties were best suited to resolve the issues.
- Walden was contacted by an existing client to discuss some issues which were discovered at its dealership facilities. The client, understanding that these issues could result in fines or violations from multiple agencies, requested that Walden conduct inspections to identify compliance issues and recommend cost-effective actions to address them.
During the site walk through Walden visited four (4) facilities; two mechanic shops, a car maintenance facility which included a car wash, and a vehicle drop off facility. At each facility, Walden noted non-compliance issues related to aboveground/underground (AST/UST) storage tanks, OSHA health and safety, Tier II filing (RTK) requirements and miscellaneous other items of concern.
The AST/UST issues included; a lack of proper documentation for the tanks (a registration was required due to the amount of petroleum product stored on site), required signage was not posted, and tanks were not equipped with emergency vents and other appurtenances required for compliance. Walden discussed these issues with the client and recommended various adjustments required to gain compliance. Once these items were addressed, Walden filed for a registration with the NYSDEC for the facility. As the facility was exempt, a registration fee of $0 was required.
OSHA issues were identified with regards to the operations in the mechanics garage. The exhaust system installed to ensure fumes are vented out of the building was not being utilized by the workers, causing toxic fumes to build up in the facility. Walden discussed this finding with the management and then performed HAZCOM and OSHA training for the mechanic shop workers. One of Walden’s safety professionals discussed various issues typically faced by mechanic shop workers and how the workers can avoid work place injuries.
The NYCDEP requires all facilities which store hazardous materials to file a Tier II filing annually, which involves an inspection of the facility’s chemical substances and reporting the department. Depending on the number of hazardous substances and extremely hazardous substances stored at a facility, different actions are required. Walden inspected the chemical substance inventory at one of the client’s facilities and determined that Tier II filings were required based on the multiple hazardous materials present. The facility had never completed a Tier II filing, so Walden prepared the submittal and determined that the facility was exempt from any fees.
Other issues observed during the inspection were not directly related to potential violations but were viewed as poor operational practices, such as deteriorating ceilings which posed a threat to workers and vehicles, exposed electrical panels, and obscured eye washes, among other items. Walden recommended best management practices to the client to improve safe operations.
During these inspections, Walden relied on years of experience and expertise in various regulations to identify non-compliance issues and confidently inform the client on the best approach to gain compliance and avoid violations and penalties