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23 practices affected by P2 include disposal of waste oil and Facilities filters, antifreeze, parts-cleaning fluid, batteries, refrigerants, paint thinners, and flammables. Exhaust emissions are ADA requirements for facilities set specific standards not part of P2; they were covered under the CAA described to accommodate persons with disabilities. These require- above. ments are regulated by local building codes and federal law. All public facilities must comply with the ADA, Suggestion: Develop practices to comply with P2 require- which includes requirements for wheelchair ramps, restroom ments by including procedures for reviewing MSDSs and identifying affected products deemed unacceptable for use in facilities, fire alarms, elevators, parking, and other facility your shop. Become familiar with local requirements, which areas. differ by jurisdiction. Some areas, for example, ban chlori- nated solvents, while others simply restrict quantities. Agen- Suggestion: When developing facility PMI practices, be sure cies should also consider the use of organic alternatives to to include inspection and repair of ADA equipment as part of hazardous products. Local health agencies are the best place your facility maintenance program. For example, fire alarm to begin obtaining information on acceptable products and systems and emergency evacuation plans need to be period- chemicals. ically tested. All tests and drills must be supervised by a designated safety person and documented. Certifications and Licenses OCCUPATIONAL SAFETY AND HEALTH Air Conditioning Repairs ADMINISTRATION (OSHA) The EPA requires that all technicians working on AC Overview systems be certified and use personal protection equipment The Occupational Safety and Health Administration (PPE). (OSHA) is the national mechanism to ensure safe and health- ful workplace conditions, created by the Occupational Safety and Health Act of 1970. Individual states may choose to Brake Repairs adopt different standards for workers in their jurisdiction. Air brake system repairs are regulated under CFR 49 Parts These standards will meet the approval of OSHA as long as 393/396 and FMVSS, which require technician certification they are as stringent as the federal requirements. OSHA to repair and maintain these brake systems. Use of PPE is regulations cover a broad range of hazards and include recommended. procedures for chemicals, containers, and container labels; equipment; industrial accidents/injuries; and training. OSHA Suggestion: For AC and air brake practices, include infor- also covers personal protective equipment (PPE), such as mation alerting workers that certification is required. Also respirators, hearing protection, gloves, and safety goggles for provide instructions for PPE use. employees working in areas with specific hazards; use of shop equipment; work done in confined spaces; and operat- AMERICANS WITH DISABILITIES ACT (ADA) ing forklifts. Agencies need to understand that there are no "OSHA- Buses exempt" states. So-called "OSHA states" have an OSHA- approved plan, while "non-OSHA states" have industrial Regulations promulgated under the Americans with safety rules and regulations that, while not formally approved Disabilities Act (ADA) affect buses by way of construction, by OSHA, nevertheless pertain to maintenance operations. equipment, and operational requirements. ADA mandates States with OSHA-approved plans receive federal funding that all newly constructed transit buses have wheelchair for up to 50 percent of the cost of enforcing their employee access in the form of a lift or ramp. The ADA sets minimum safety program. Additional information on OSHA is avail- width and height requirements for the door at the wheelchair able through the contact information shown at the end of this entry and specifies how wheelchairs must be secured on the section. bus. The ADA also establishes requirements for either the States and territories with OSHA-approved plans include driver to announce bus stops or the bus to be equipped with Alaska, Arizona, California, Connecticut, Hawaii, Indi- an automated bus stop annunciation system. Labels and signs ana, Iowa, Kentucky, Maryland, Michigan, Minnesota, that notify passengers to render their seats to persons with Nevada, New Jersey, New Mexico, New York, North disabilities are also part of the ADA. Carolina, Oregon, Puerto Rico, South Carolina, Tennessee, Utah, Vermont, Virgin Islands, Virginia, Washington, and Suggestion: Develop PMI practices that include procedures to verify that all ADA-mandated systems are functioning Wyoming. In these states, the employee safety plan meets or properly and include a means for the driver to notify mainte- exceeds all OSHA requirements and standards and must nance of any malfunctioning equipment. continue to do so to continue to receive funding. State or