Appendix C

Proposed Survey Instrument for On-Site Inspections

Date of Visit: ________________________________

Agency/Regional Office: ____________________ 

Assistance Provider:__________________________________________

Tel.______________________

Facility
Name:___________________________________________________________________
________

Facility
Address:________________________________________________________________
_________

Name and Title of Facility Contact Person:
________________________________________________________________________
____________

Telephone number of Facility Contact Person:

________________________________________________________________________
____________

Introduction

Hi, my name is [interviewer name].  I am here on behalf of the U.S.
Environmental Protection Agency. We are conducting a survey related to
environmental practices at autobody shops.  The survey will help EPA
improve the assistance it provides to shops in complying with
environmental regulations.   Are you the person I should speak to about
environmental issues in your shop?  

(If no, ask to speak with appropriate person and repeat above
introduction  The ideal respondent (in survey research this is called
the “most knowledgeable person” -- MKP) is the person from the shop
who keeps up with environmental requirements, is familiar with shop set
up and operations, and perhaps receives information through training or
attending workshops or manages the operations of the shop.)  

Great.  It will take us about 1 hr to walk through the shop and complete
the survey, and your responses will remain anonymous.  Is there an
office, or a place where we can sit to go over some of the basic
questions first?

Based on our observations and experience testing the survey out in
shops, it works best to go through all interview questions up front in a
quiet office area and then ask to be shown through the shop for
observations 

SECTION A: INTRODUCTION

A1.	Which of the following categories best describes your role at this
shop? (read categories):  

	

	___	Owner 	

	___	Manager

	___	Technician who applies spray coatings       

	___	Another role (specify)__________________________________________

A2.	Do the operations at your shop include the application of surface
coatings to vehicles or parts?

	

___	Yes

	___	No ( End survey

A3.	Is this shop part of a corporate chain?

	___	Yes (specify which
one)_____________________________________________

	___	No

SECTION B: TRAINING

	

B1.	a. Have your employees taken a training program that covers proper
hazardous waste management procedures?  

___	Yes	

___	No( Skip to B 2	 

___	Don't know ( Skip to B 2

b.  Is the documentation related to the hazardous waste management
training program present and available for review?   

___	Yes

___	No 

___	Don't know

	CA provider may examine documentation to determine whether or not shop
has program.  The CA provider will not evaluate the quality of the
training program.  

	___	Shop has training program	

___	Shop does not have training program

___	Not sure

B2.	a. Have ALL spray technicians been trained regarding spray
equipment?   

	

___	Yes (all)

___	Yes (some)

	___	No ( Skip to C 1

	___	Not sure ( Skip to C 1

b. Has the training addressed and/or included the following regarding
spray equipment? (read responses; check all that apply)

___	Selection

___	Set-up

___	Use 

___	Maintenance

___	Hands on with equipment

___	Classroom

	c. Are the training records present and available for review? 

CA provider may examine documentation (certificates, dates, places) to
determine whether or not the spray technicians have been properly
trained (meaning they have been trained in all 6 areas listed in
question B2(b) above).  

	___	All technicians have been properly trained. 

___	Some (but not all) technicians have been properly trained 

___	None of the technicians has been properly trained

___	Records not available 

 

SECTION C: AIR POLLUTANTS

When we walk through the shop, it would be helpful if you could show me
your spray guns.  

C1.  	a.  Does your shop have a spray booth?

	___	Yes

	___	No ( Skip to C2 

b. Are ALL spray coatings applied in the spray booth?  

	___	Yes

	___	No 

___ 	Don’t know 

c. When did your shop first begin using this spray booth to apply
coatings? (read responses)

___ 	Less than 2 years

___	2-5 years ago

___	More than 5 years ago

___	Don’t know

C2.	a.  Is the spray booth ventilated with an exhaust fan?

___	Yes, spray booth is ventilated

___	No, spray booth is NOT ventilated ( Skip to C3

___	Don’t know ( Skip to C3

b. 	Do you know the capture efficiency rating of your booth exhaust
system? 

___	% Capture efficiency (list numerical value)

	___	Don’t know 

c.	Is the documentation related to the capture efficiency of your booth
exhaust system present and available for review?  

If respondent is unsure, note that this information would typically be
found on the filter package or provided by the distributor.  CA provider
may review documentation to determine the capture efficiency: 

	___	% Capture efficiency (list numerical value)

	___	Cannot find it

	 

d. 	When was this booth exhaust system first used at your shop? (read
responses)

___ 	Less than 2 years ago

___	2-5 years ago

___	More than 5 years ago

___	Don’t know

	When we walk through the shop, it would be helpful if you could show me
your spray booth and exhaust system.

C3.  	a. Do you have a separate paint mixing room?  

___	Yes 

	___	No ( Skip to C4

b. When did your shop first begin using this mixing room? (read
responses)

___ 	Less than 2 years

___	2-5 years ago

___	More than 5 years ago

___	Don’t know

C4.	a. Do you have a prep station where coatings are applied on vehicle
components?  

___	Yes 

	___	No ( Skip to C5

b.  When did your shop first begin using this prep station?  (read
responses)

___ 	Less than 2 years

___	2-5 years ago

___	More than 5 years ago

___	Don’t know

When we walk through the shop, it would be helpful if you could show me
the mixing room and/or the prep station. 

C5.	a. 	How do technicians at your shop typically clean the spray guns? 


	___	Use a fully enclosed spray gun washer

	___	Use a fully enclosed spray gun washer and occasionally disassemble
and clean by 

		hands

	___	Flush with solvent (but don’t spray)

	___	Spray coatings and/or solvent through the gun

	___	Clean disassembled gun by hand or through mechanical methods

	___	Other (specify)
____________________________________________________

b.  	When was this spray gun cleaning approach first used at your shop?

___ 	Less than 2 years ago

___	2-5 years ago

___	More than 5 years ago

___	Don’t know

When we walk through the shop, it would be helpful if you could show me
the gun cleaning area and operations.

C6.	Do you use waterborne paints?  

___ 	Yes

___ 	No( Skip C8

___	Don’t know( Skip C8

C7. 	Do you use waterborne paints for your: (read responses)

___ 	Basecoat

___	Primer

___	Other (specify)	____________________________________________________

C8. 	On average, about how many gallons of each of the following
coatings are applied in your shop each week?   

	Basecoat:	_______ gallons	_______ don’t know	

	Primer:	_______ gallons	_______ don’t know

	Topcoat:	_______ gallons	_______ don’t know 

	Total Estimate: ________gallons	_______don’t know

C9.	Who is your primary supplier of paint coating products?  

	Supplier:
________________________________________________________________

Would you please provide contact information for that supplier?  We are
asking because we would like to partner with the suppliers to provide
compliance assistance in the future.

Contact Information:
_______________________________________________________

C10.	Does your shop have Material Safety Data Sheets (MSDS) and coating
formulation data supplied by the manufacturer for the solvents and
coatings that you use?  Is this documentation present and available for
review? 

CA provider observes documentation and records whether or not it is
sufficient.  If no physical documentation is available, CA provider will
confirm if shop uses a color matching computer technology on-site that
has formulation data in it, and if so, ask to see data.

___	Yes, documentation available for all solvents and coatings

___	Documentation available for some solvents and coatings, but not all

___	Documentation not available for any solvents or coatings

___	Don’t know

C11.	Do the coatings used by your shop contain any of the following
hazardous air pollutants: chromium, lead, cadmium, nickel, or manganese
(includes compounds of these metals)? 

	___	Yes

	___	No 

	___	Don’t know 

C12.	a. Do you use chemical products for paint stripping tasks?

	___	Yes

___	No ( Skip C13

___ 	Don’t Know

b. What chemical products do you use for paint stripping?

List Products:
________________________________________________________________

c. Have you checked these products for the presence of Methylene
Chloride?

___	Yes

___ 	No

___	Don’t know

[e.g. StripRDry, Booth Floor Stripper both made by CMA Philadelphia,
both contain MeCl]

	When we walk through the shop, it would be helpful if you could show me
the products.  

C13.	 May I please see records related to your shop’s methylene
chloride usage? 

	CA provider examines documentation and records annual usage:

______ 	Gallons per year (as supported by documentation)  

______	Don’t know; no documentation

C14.	Does your shop have a minimization plan for use of MeCl?  Could I
take a look at it?

CA provider examines documentation and determines whether or not a plan
exists:

___	Yes, shop has minimization plan

___	No, shop does not have minimization plan

C15.	Have you heard of EPA regulations related to spray painting
operations or paint stripping? 

	

___	Yes   

	___	No ( Skip to D1

C16.	When did you first hear of these regulations?

	_____________ Year 

_____________ Month 

	_____________ Don’t know

C17.	How did you first hear about the regulations, from a... (Read list
of sources)

Sources:

Circle all that apply	For each circled source, ask:  Who provided this
information?

Then check off provider from list below for that source. 

Do not read the list of providers.

	EPA	State	Supplier/vendor	Other auto body shops	Trade Ass’n	Local
Gov’t	OSHA	Don’t Know

Shop Visit









DVD









CD









Post Card









Fact Sheet









Website









Workshop









Another source











If another source, specify:
________________________________________________________

SECTION D: RCRA GENERATOR AND WASTE DETERMINATION 

D1.	About how much hazardous waste does your shop generate each month?
(read options)

	___	0 - 26 gal/mo (VSQG or equivalent)  

	___	27-270 gal/mo (SQG)  

	___	>270 gal/mo (LQG)  

	___	Don't know or your waste hauler handles that for you

	When we walk through the shop, it would be helpful if you could show me
the hazardous waste storage area. 

  

D2. 	Is the documentation related to shipping these wastes off site
present and available for review?  

CA provider should review documentation if the answer to D1 above is
“don’t know.” 

	___ 	Yes

___ 	No 

___ 	Don’t know	

When we walk through the shop, it would be helpful if you could show me
where used rags and towels are stored. 

D3.	Do you treat the following as hazardous wastes:  (read list of waste
streams)

Waste streams:

	For each waste stream, check off relevant response:

	Yes	No	Don’t Know	Not Applicable (i.e., this waste stream isn’t
generated at all)

Solvents





Paints





Sand blast debris





Use rags





Spray booth filters





Antifreeze





Waste oil





Another hazardous waste stream







If other, specify: ____________________________________________________

Note: Spent/used booth filters are typically being treated as solid
waste.  Advise shops that the only definitive way to know if those are
non-hazardous is by testing (TCLP) to determine whether they are
characteristic of hazardous waste.

SECTION E: EMERGENCY PROCEDURES (EPCRA)

E1.	Have you implemented emergency procedures in your shop?

	___	Yes

	___	No		

___	Don't Know

E2.	Is the documentation related to your emergency procedures present
and available for review?

CA provider reviews documentation and determines whether or not
emergency procedures are in place:

___ 	Shop has emergency procedures in place 

___	Shop does not have emergency procedures in place

	___	Don’t know 

Note to CA provider: Emergency procedures can include: The shop posting
the current name and telephone number of the emergency coordinator;
posting the location of fire extinguishers and spill control material,
and if present, fire alarm; posting the telephone number of the fire
department, unless the shop has a direct alarm.

SECTION F: COMPLIANCE ASSURANCE

F1. 	How do you obtain information on how to comply with federal and
state environmental regulations? (do not read responses; check all that
apply)

	___	Coating manufacturers or suppliers

	___	Corporate environmental division

___	Educational institutions (vocational technical school, community
college, specialized training center, etc.)

___	Environmental consultant

___	Other auto body shops 

___	Local government (town, city, or county)

___	OSHA 

___	State environmental agencies 

___	Suppliers

___	Trade association 

___	U.S. EPA

	___	Other (Specify)________________________________________________

	___	Don’t know

F2.  	Has your shop been inspected or visited by a government
environmental or health and safety official within the last six months?

	____	Yes

	____	No ( Skip to F 4

	____	Don’t know ( Skip to F 4

F3.	What type of government official inspected or visited your shop?
(check all that apply)

	___	EPA 

	___	State

	___	Local government (environmental, health or fire department)

	___	OSHA

	___	Other (specify) ___________________________________________________

	___	Don’t know/Cannot recall

F4.	a. Have you made any changes in the last year in your shop
operations (e.g., the type of equipment you use, techniques you use, or
training you provide)?  

	____	Yes

	____	No ( Skip to F 5

____	Don’t know ( Skip to F 5

b. What changed?

Comment:________________________________________________________________
______

________________________________________________________________________
______

c. Why did this change happen?  

Comment:________________________________________________________________
______

________________________________________________________________________
______

F5.  	Is there any other information about your shop's operations that
you'd like to share before we walk through the shop together?  Is there
anything that you would like EPA to know or to do related to assistance
or inspections or other activities that impact your operations?

Comment:________________________________________________________________
______

________________________________________________________________________
______

SECTION G: Walk Through (The order of these questions may have to be
rearranged based on the set up of the shop.)

G1.  May I see the spray guns you use? (Check all that apply)

____	HVLP (High Volume Low Pressure)

	____	Electrostatic

	____	Airless spray gun

	____	Air assisted airless

	____	Other (specify) ___________________________________________

	____	Don’t know

Note for CA provider:  If flow is 15-26 cubic feet per minute and PSI at
orifice is less than 10 lb per square inch, then likely to be an HVLP
spray gun.  Other equivalent high transfer efficiency technology
examples include: electrostatic application, airless spray gun, and
air-assisted airless guns.

G2.	Verify the Manufacturer of the Spray guns:

	_____________________________________________  Manufacturer  

	

	______________________________________________Manufacturer	

	______________________________________________ Manufacturer  	

	___ Don’t know

G3.	May I see the gun cleaning area, operations?  

	CA provider observes cleaning procedures and categorizes cleaning
technique:

	___	Use a fully enclosed spray gun washer

	___	Use a fully enclosed spray gun washer and occasionally disassemble
and clean by 

		hands

___	Flush with solvent (but don’t spray)

	___	Spray coatings and/or solvent through the gun

	___	Clean disassembled gun by hand or through mechanical methods

	___	Other (specify)
____________________________________________________

G4.	May I see your spray booth? 

___If no spray booth present, check here and skip to G7.

CA provider performs visual inspection to confirm that spray booths,
where coatings are applied to full vehicles, are fully enclosed and
ventilated.  Check all that apply:

	___	Spray booth is fully enclosed with a full roof, four complete walls
or side curtains

	___	Spray booth is not fully enclosed

	___	Spray booth is ventilated with an exhaust fan

	___	Spray booth is not ventilated with an exhaust fan

___	There is evidence that at least some spray coating occurs outside of
a spray booth

	

G5.	May I see the particle filter on the spray booth exhaust? 

CA provider performs visual inspection of pipe and filter and determines
whether or not there is a particle filter on the exhaust:  

___	Yes, the station has a particle filter

___	No, the station does not have a particle filter

___	Not sure

Note to CA provider: you may see a wall fan and small box with filter.

G6.	Is the particulate filter in good condition?  Look for rips or gaps
in the particulate filters; check to see if the filters appear to be
clogged with paint residue or dust. 

	CA provider records condition of particulate filters:

	___	Good condition

	___	Fair condition

	___ 	Poor condition

	___	Don’t know

 If the filters are not in good condition, CA Provider should ask the
shop to revisit manufacturer’s recommendation.

G7.	May I see your mixing room?

___If no mixing room present, check here and skip to G8.

CA provider performs visual inspection to confirm that mixing room is
enclosed and ventilated.  Check all that apply:

___	Mixing room is enclosed with a full roof and at least three complete
walls or side curtains

___ 	Mixing room is not enclosed as described above

___	Can’t tell if mixing room is enclosed 

	___	Mixing room is ventilated with an exhaust fan

	___	Mixing room is not ventilated with an exhaust fan

 	___ 	Can’t tell if mixing room is ventilated 

G8.	May I see your prep station?

___If no prep station present, check here and skip to G9.

CA provider performs visual inspection to confirm that prep station is
enclosed and ventilated.  Check all that apply:

___	Prep station is enclosed with a full roof and at least three
complete walls or side curtains

___ 	Prep station is not enclosed

___	Can’t tell if prep station is enclosed 

	___	Prep station is ventilated with an exhaust fan

 	___ 	Prep station is not ventilated

___	Can’t tell if prep station is ventilated 

G9.	May I see the products you use for paint stripping? 

	Examine products for ingredients with methylene chloride. 

 

	___	Yes, products with methylene chloride are used

	___	No, products with methylene chloride are not used	

___	Don't know/can’t tell

G10.	May I see your hazardous waste storage area?  

CA Provider: Are all hazardous waste containers properly labeled with
the words “hazardous waste” and clearly marked with the date on
which accumulation began?

___	Yes

___	No

___	Don’t know

Note: CA provider will use best professional judgment to determine what
is “clear” and “legible” and whether the shop made a “genuine
and complete effort” to meet this requirement.

G11.	CA Provider: What is the earliest date that accumulation began in
any of the drums? 

__________________  	Month/year of earliest beginning accumulation date 

__________________	Not sure / Drums poorly labeled

Note to CA provider: No storage limits for VSQGs; SQGs has a <4400lbs &
180 day limit, body shops are not expected to be LQGs.  

G12.	CA Provider: Are all hazardous waste containers closed unless waste
is being added or removed?  

___	Yes

___	No

___	Don’t know

Note: “closed” means that if the containers were tipped, nothing
would spill. “Funnels” are acceptable if they are closed.

G13.	CA Provider: Approximately how much hazardous waste is currently on
site ( excluding waste in satellite accumulation areas)?

	_________________	Gallons of hazardous waste (approximate)

	_________________	Not sure / Drums poorly labeled

G14.	Can you please show me where you store used absorbent paint
applicators such as shop rags and towels?

CA provider: are the containers closed when not in use?

____	Yes, containers are closed

____	No, containers are not closed

____     Don’t use rags, towels

____	Don’t know

G15.	Is there any indication of spills in or near the shop?   CA
provider will check for stains on the ground and in and around manholes,
leaking tanks and containers and/or pooled liquids.

___	Yes

___	No

___	Comment
_____________________________________________________________

G16.	Does the shop appear to be operating in such a way as to violate
the CAA 112(r)(1) general duty clause – namely:  “The owners and
operators of stationary sources producing, processing, handling or
storing [a chemical in 40 CFR Part 68 or any other extremely hazardous
substance] have a general duty [in the same manner and to the same
extent as he general duty clause in the Occupational Safety and Health
Act (OSHA)], to identify hazards which may result from... releases using
appropriate hazard assessment techniques, to design and maintain a safe
shop taking such steps as are necessary to prevent releases, and to
minimize the consequences of accidental releases which do occur.”

___	Yes, shop appears to violate clause

___	No, shop does not appear to violate clause

___	Undetermined

Thank you for your time.  

	Provide site visit debrief and compliance assistance



Appendix C, Page   PAGE  1 

Appendix C, Page   PAGE  1 

KEY:

Boldface Font – Spoken question

Normal Font – Site visit record/contacts and response options

Italics – Instruction for compliance assistance provider (not spoken)

