The EPA is developing fact sheets to be distributed to collision repair facilities and to communities surrounding these facilities, with an eye toward protecting the environment and workers. ASA asked its Collision Operations Committee to review the EPA draft. ASA followed with comments to the EPA. It is important that the voices of collision repairers become louder as these standards are developed.

The U.S. Environmental Protection Agency (EPA) is developing "Tools for Communities," a collection of fact sheets to be distributed to collision repair facilities and communities surrounding these facilities. The Automotive Service Association (ASA) had an opportunity to review the draft proposal and submit comments to the EPA. It is ASA's understanding that the final information sheets will be available prior to the end of 2004.

The EPA's Office of Air Quality Planning and Standards developed the following concept:

"As community groups, local agencies and others begin to assess and understand the nature of the risk posed by air toxic emission sources, we believe they will seek information on what measures they can take to encourage those sources to make changes in their operations. Often, the only tool available to those seeking change will be to encourage voluntary pollution prevention and risk reduction measures. There is already a wealth of information on these types of measures, but it is often directed to the source itself, and the measures usually address solid waste and water pollution impacts in addition to air pollution reduction measures. The purpose of these information sheets is for community groups to use as they work with sources of local emissions and to focus on the air pollution benefits of various voluntary reduction measures. These sheets are intended as a screening tool for communities to determine if there are measures they might want to pursue, and to give them information on how to learn more."

The EPA is working with 14 general sectors of the business community to assemble fact sheets for community organizations. The collision industry is one of those 14 sectors. The EPA views all 14 as being potential stationary sources for air toxins.

There are several general concerns about the "Tools for Communities" proposal. One could argue that more information for communities near collision repair facilities will only enhance the relationship between the local community and the collision repair facility. Another view is that this information, as it is distributed, will initiate community concerns that are exaggerated or are not reality.

ASA asked its Collision Operations Committee to review the EPA draft. ASA followed with comments to the EPA.

The industry must first get used to the idea that these fact sheets will be distributed by the EPA. Then, it must also understand that the fact sheets most likely will mirror past EPA inferences as to what equipment and training are necessary for a collision repair facility to operate in a manner protective of the environment and workers.

Specifically, Collision Operations Committee members noted that equipment criteria fell short of what most collision repair facilities active in the industry are now using. This is a concern that has been voiced by ASA for a number of years. This debate moved to a public forum in the 1990s as Pennsylvania worked to implement training and equipment standards for collision repair facilities. These standards were woefully short of what collision repairers had asked the state to consider.

Unfortunately, these same equipment and training standards have served as a model for other states as they cautiously consider establishing equipment and training criteria. The Washington, D.C.-based Ozone Transport Commission, guiding state air quality programs from Virginia to Vermont, adopted these same Pennsylvania standards.

With the recent conclusion of the EPA's regulatory process for those manufacturers of vehicles and other equipment that require the use of refinishing products, the EPA will now move to establishing a baseline for the use of paint products in collision repair facilities. ASA is working with the EPA as it develops this additional regulation. Some of the EPA's professional staff members have been visiting collision repair facilities to see firsthand the use of refinishing products, equipment and to discuss training for collision personnel.

Once the final "Tools for Communities" notebook is completed, ASA will make it available on the ASA Web site for repair facilities to review.

Whether it is information sheets, paint product controls or other collision-related initiatives by the EPA or the U.S. Department of Labor, there is a general reluctance to require the types of equipment and training standards that those active in the collision industry are imposing on themselves. Are these standards too burdensome on some repair shops? Is it fair for some shops to spend the time and resources for training and equipment while others ignore what may be an industry standard - adhering only to what local, state and federal laws require?

As some states consider licensing programs for repairers, these issues are part of the debate. One cannot ignore in a licensing program the necessity for equipment and training standards. In collision shop surveys conducted by ASA, shop owners were adamant in calling for strict standards for licensing programs to avoid "just another tax" by state governments.

Whether it's EPA voluntary or mandatory collision standards, U.S. Department of Labor initiatives or state licensing proposals, it is important that the voices of collision repairers become louder as these standards are developed. Policies that fall short of where the collision industry desires to be will only frustrate those industry participants that have accepted more advanced environmental and worker safety standards.

Bob Redding is the Automotive Service Association's Washington, D.C., representative. He is a member of several federal and state advisory committees involved in the automotive industry. For more information about the legislative activities of ASA, visit www.TakingTheHill.com.

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