GNYADA November 2015 Newsletter

WindshieldWasher Fluid: The Storage Rules

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There are many questions on onsite storage of windshield washer fluid at a dealership. Answers depend on what region of metro NY you’re in.

Based on OSHA regulations, all facilities must: Clearly label containers of wind- shield washer fluid Always keep the necessary docu- mentation, such as Safety Data Sheets (SDSs), available to employees and inspectors Train all employees on the hazards of the product Windshield washer fluid is typically a mixture of water and methanol — the latter, in high concentrations, can be toxic, flammable and otherwise harmful to those who come into con- tact with it. The concentration of methanol in windshield washer fluid n n n low NYSDEC and NCDH require- ments: If a facility has less than five drums totaling less than 250 gallons of storage, the fluid drum does not need to be registered, but should be stored properly, as described earlier. If a facility stores more than 185 gal- lons of fluid with more than a 1% concentration of methanol, then the facility would have to follow stricter Chemical Bulk Storage regulations and register all containers with NCDH . LOCATION GUIDES BY COUNTY

varies from manufacturer to manu- facturer, but average concentration is between 20-40%. All counties can potentially regulate windshield washer fluid differently. If your dealership is located in Rockland, Dutchess, Putnam or Orange counties — or if you store the fluid in containers larger than 55- gallon drums — you should contact your local regulatory agency or Walden Associates (516.624.7200) to assure that you are storing chemicals properly.

UNIVERSAL RULES

All facilities should: Store containers on spill pallets, or in a bermed or diked area, to col- lect accidental spills Avoid stacking drums or contain- ers more than two-high Protect drums / containers from vehicular traffic Store fluid in well ventilated areas Avoid mixing windshield washer fluid with any other chemicals n n n n n New York City Dealerships or service centers within New York City’s five boroughs must follow NYSDEC and NYCDEP reg- ulations regarding windshield washer fluid. If your facility stores more than ten lbs. of methanol, you must report the windshield washer fluid to the city, under the Community Right-to- Know Program. (If your fluid has a 35% methanol concentration, four gallons of windshield washer fluid makes up 10 lbs. of methanol.)

Below are the storage rules for NYC, Nassau, Suffolk and Westchester.

SCDHS regulations governing stor- age requirements are similar to NCDH requirements. Only if a facili- ty has more than five drums or more than 250 gallons, must they register all drums. If they store large amounts in tanks, they must properly register the tank as well.

Westchester County In Westchester, NYSDEC and

WCDH regulations simply state that all containers must be stored proper- ly, but do not have to be registered.

Nassau County Nassau County dealerships must fol-

Suffolk County In Suffolk County, NYSDEC and

Renew Your Membership Today! GNYADA is on top of the issues that affect dealerships and impact your bottom line. Your membership allows the Association to have an important strategic presence in Albany and D.C. Every day, we assist dealers through a maze of regulations, steering you away from the pitfalls generated by so many requirements. It is important that we have the most current contact information for your key staff members, so we can keep them informed about important issues. Please download and complete the dealer contact form at www.gnyada.com/dealers/member/ overview , and email it to Jennifer at Jennifer@gnyada.com or fax her at 718.508.4772.

Greater New York Automobile Dealers Association • www.gnyada.com

The Newsletter • November 2015

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