employers with fewer than 11 employees can claim exemption. Facilities with any number of employees must follow other OSHA safety standards as required through Federal OSHA or an OSHA- approved state program.


OSHA says that employers have three options for reporting these severe inci- dents. You can call your nearest area OSHA office during normal business hours, call the 24-hour hotline at 1-800- 321-OSHA, or report online. For training information on OSHA’s 300 Log, go to www.arauniversity.org. Your ARA Safety Committee and the ARA University monitor and, when pos- sible, comment on these regulatory pro- grams to make you aware of changes and to represent your concerns/issues. If you would like to participate in the Committee or have questions about the OSHA 300 Log reporting requirements, please email ARA staff at betsy@a-r-a.org.


State Issues


RA reached out to OKLAHOMA Attorney General Scott Pruitt in November in response to a press release issued by Pruitt’s office that referred to “salvaged parts or other substandard materials” utilized in vehicle repairs. The press release issued by the Attorney General’s office stated that the office was “looking into reports that certain insurers are coercing Oklahomans into using auto body repair shops that may use salvaged parts or other substandard materials to make repairs, while claiming to use new parts or materials made by the automobile manufacturer.” ARA expressed concern with the press release because it leads the reader to believe that salvaged, used and/or recy- cled automotive parts are unsafe and inferior to new orig- inal equipment manufacturer (OEM) parts. This mischaracterization does a disservice to the many profes- sional automotive recyclers in Oklahoma and ARA empha- sized to Pruitt that Green Recycled Parts®


A are OEM parts,


designed by the OEM, and built to meet the OEM require- ments for fit, finish, durability, reliability and safety. ARA also referenced the West Virginia Supreme Court of Appeals’ recently ruled that their state’s Automotive Crash Parts Act does not apply to the use of salvage/recycled OEM parts and as such, affirmed the use of salvage/recy- cled OEM crash parts in vehicle repairs. The Court found that state statute did not prohibit body shops or insurers from utilizing salvage/recycled parts, that aftermarket crash parts and salvage/recycled OEM crash parts are “dia-


EPA Updates 2010 Guidance Memorandum on Stormwater Permit Requirements and Numeric Effluent Limits


he U.S. Environmental Protection Agency (EPA) has released the final version of its 2014 memo on stormwater permitting issues. It addresses key issues of interest to ARA members, including when to set numeric limits in stormwater permits. In November 2010, the original memo called for a radical change from past policies and recommended an increased use of numeric limits in stormwater permits, in stark contrast to previous guidance memos which histor- ically had promoted the use of a best management practice (BMP) approach. ARA joined other industries in express- ing strong concerns about requirements listed in the 2010 memo, and we are very pleased that the comments appear to have had a significant positive impact on


T


the new policy regarding the use of numeric limits in stormwater permits. The 2014 memo restores the 2002 BMP approach but also states that EPA “sup- ports an approach with greater emphasis on clear, specific, and measurable permit requirements, and, where feasible, numeric NPDES permit provisions.” The specific language on numeric lim- its in the new memo is much different than in 2010 as it keeps the door open for BMPs as long as they are effective in reducing the discharge of the pollutant of concern. EPA then provides several examples of these controls, which include numeric limits, narrative requirements, and BMPs. It appears that all of those options are, according to EPA, permissi- ble under the new memo. In early 2015, EPA will release a com- pendium of state industrial stormwater permit approaches and ARA will confirm that BMPs are included as appropriate. ■


metrically” different products and not interchangeable, and, moreover, applauded the insurers for using measures to reduce premium costs for their customers. In September, ARA pursued similar outreach to


LOUISIANA Attorney General Buddy Caldwell after he made disparaging remarks about recycled automotive parts. Coverage of that exchange was included in a Collision Repair magazine story entitled “Automotive Recyclers are Not Junkyards.” Attorney General Caldwell has filed suit against State Farm Insurance alleging the insurer has violated the state’s Unfair Trade Practices and Consumer Protection Law by steering consumers to direct repair providers that have signed agreements with the insurance company. In remarks about the lawsuit, Attorney General Buddy Caldwell stated that State Farm deceives customers by steering them to cheaper or used auto parts, or parts found to be knock-offs of questionable quality. ARA is working with automotive recyclers and its affiliated chapter organization in NEW JERSEY to address two pieces of legislation that could have a negative impact on ARA and ARANJ member businesses. A3579 and S2433 address motor vehicle data recording devices and propose penalties for any person who knowingly alters or deletes data on a recording device within two years after a crash that resulted in bodily injury or death. Given that professional automotive recyclers have no way of knowing whether a salvage vehicle purchased at auction was involved in such a crash event, ARA, ARANJ and other stakeholders are working with the bill sponsors to address this concern. ■


January-February 2015 | Automotive Recycling 67


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