AERA Safety Standards & Environmental Compliance 5 — Questions and Answers
Question 1: A shop uses a solvent recycling unit to reclaim chlorinated degreaser on-site. Under RCRA, the reclaimed solvent is generally:
- Still classified as hazardous waste and requires a manifest for movement
- Excluded from hazardous waste rules if legitimately reclaimed for reuse (Correct answer)
- Subject to universal waste rules only
- Automatically classified as a new product requiring EPA registration
Correct answer: Excluded from hazardous waste rules if legitimately reclaimed for reuse
Solvents reclaimed on-site and reused in the same process are excluded from RCRA hazardous waste regulations under the reclamation exclusion when legitimately recycled.
Question 2: Which engineering control is most effective at reducing a machine operator's exposure to airborne metal particles generated during cylinder boring?
- Administrative rotation of workers to limit exposure time
- Requiring workers to hold their breath during cutting passes
- Local exhaust ventilation (LEV) capturing dust at the source (Correct answer)
- Dilution ventilation using ceiling fans
Correct answer: Local exhaust ventilation (LEV) capturing dust at the source
Local exhaust ventilation captures contaminants at their source before they disperse into the work environment, making it the most effective engineering control.
Question 3: When is an engine rebuilding shop REQUIRED to submit a Tier II chemical inventory report under EPCRA Section 312?
- When any amount of a hazardous chemical is on-site
- When hazardous chemicals are stored at or above OSHA threshold quantities (Correct answer)
- Only if a chemical spill has occurred in the prior year
- When the shop employs more than 10 workers
Correct answer: When hazardous chemicals are stored at or above OSHA threshold quantities
EPCRA Section 312 Tier II reporting is required when covered hazardous chemicals are present on-site at or above the 10,000-pound (or lower EHS) reporting threshold at any point during the year.
Question 4: What is the primary purpose of a Job Hazard Analysis (JHA) conducted before an engine rebuild procedure?
- To estimate labor costs for the repair
- To systematically identify hazards and determine controls for each job step (Correct answer)
- To document customer approval for the repair
- To schedule parts ordering and delivery timelines
Correct answer: To systematically identify hazards and determine controls for each job step
A JHA breaks a job into steps, identifies hazards at each step, and specifies controls, making it a core proactive safety planning tool.
Question 5: Shops that perform chrome plating on engine components are regulated under the Clean Air Act NESHAP for chromium emissions. The primary health hazard driving this regulation is:
- Hexavalent chromium (Cr VI) being a known human carcinogen (Correct answer)
- Trivalent chromium causing acute respiratory irritation only
- Chrome fumes causing noise-induced hearing loss
- Chrome mist causing chemical burns to flooring
Correct answer: Hexavalent chromium (Cr VI) being a known human carcinogen
Hexavalent chromium (Cr VI) generated during hard chrome plating is classified as a known human carcinogen by IARC and EPA, driving strict NESHAP emission controls.
Question 6: An OSHA inspection finds that a shop's grinding wheel guard was removed to allow grinding of an oversized part. This violation would most likely be classified as:
- De minimis — no penalty issued
- Other-than-serious — minimal fine
- Serious — substantial probability of death or serious harm (Correct answer)
- Imminent danger — immediate shutdown order
Correct answer: Serious — substantial probability of death or serious harm
Removing a required machine guard creates substantial probability of serious injury from wheel contact or wheel burst, qualifying as a Serious violation under OSHA classification.
Question 7: Under EPA's Clean Water Act, a shop that discharges process wastewater (such as parts-washing water) to a local publicly owned treatment works (POTW) must comply with:
- No regulations — POTWs accept all industrial wastewater
- Local pretreatment standards and categorical standards if applicable (Correct answer)
- Only federal NPDES permit requirements directly
- Annual toxicity testing and report to EPA directly
Correct answer: Local pretreatment standards and categorical standards if applicable
Industrial users discharging to a POTW must comply with local pretreatment standards and any applicable categorical pretreatment standards to protect the treatment plant and receiving waters.
AERA Safety Standards & Environmental Compliance 5
A shop uses a solvent recycling unit to reclaim chlorinated degreaser on-site.
Under RCRA, the reclaimed solvent is generally: