Approved Assessor Inspections Identify Common Areas of Non-Compliance

BODYSHOP

Approved Assessor Inspections Identify Common Areas of Non-Compliance

March 31, 2014

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The approved assessors who carry out the inspections of bodyshops for compliance with the paint regulations have reported back to the EPA on the initial findings of their first 3 months of inspections. This has provided useful information on common issues which arise during the assessment. The information below includes details of a number of areas which vehicle refinishers may wish to consider addressing to improve their chances of having a compliant assessment report.

Spray gun transfer efficiency
Refinishers should retain the relevant technical documentation for new spray guns and obtain a hard copy of the technical specification for existing equipment in order to demonstrate the transfer efficiency of the gun.

Training records
In some cases no records are available to demonstrate staff are adequately trained. When training is provided to staff (e.g. by a contractor or by a paint company), a brief training sheet indicating who was present at the training, who provided the training, the date provided and the content of the training should be completed. The trainer and trainees should sign the record.

Certificate of compliance on display/available.
Refinishers should ensure their current certificate is on display and plan their next inspection in good time so that a the certificate is still valid during the approved assessor inspection.

Waste records
A copy of the waste collectors permit/licence for the company collecting waste should be available for review on site. Wastes must not be collected by un-regulated operators. Waste contractors can provide a copy of their permit/licence. Records of all solvent-containing waste collections from the site should be maintained. All solvent waste must be stored in closed containers.

Paints products list
A list of products purchased/used, broken down into the relevant product categories should be maintained. This should be updated as necessary. Paint suppliers should be able to help with this task.

Use of non-compliant products
Only compliant products should be used. This is a major non-compliance and may lead to prosecution. All relevant products must be properly labelled and technical data sheets for the products should also be available to verify their solvent content.

In relation to the issue of maintaining a current certificate of compliance, there is no problem with having an assessment carried out a couple of months in advance of the current certificate expiry date, and in fact the EPA would recommend this. Once the approved assessor has identified any non-compliances they will give the repairer a defined period of time (up to a month) to fix the non-compliance and send them evidence that they have rectified the issue. If a repairer fails to respond to the assessor then they will issue a non-compliant report. It is therefore strongly advised that repairers respond promptly on any noted non-compliances to ensure they are closed out and a satisfactory assessment report can be completed. This avoids the time and expense of arranging a repeat assessment.

Many of these issues detailed above can be overcome very simply by maintaining a compliance file with the relevant documents included, with updates being added as necessary. The best practice guidance document for vehicle refinishers (see www.decopaints.ie) contains a useful pre-assessment checklist to help bodyshops ensure that their inspection goes as smoothly as possible. The level of compliance demonstrated by the operator will influence the length of certification which is received from the local authority so it is in the interests of the refinisher to ensure a high level of compliance.

Finally, bodyshops are urged to make sure that they submit the completed application form, approved assessors report and appropriate fee to their local authority in order to obtain their certificate of compliance. There is no benefit to be gained in waiting to submit an application as certificates will be back-dated to the date of expiry of the previous certificate.

The EPA says that hopefully by taking account of the above, repairers will be in a stronger position in order to gain the maximum 3-year certification period.