Caliber's Best-in-Class Hazardous Waste Management

Introduction to Hazardous Waste in Collision Repair

Collision repair is an inherently ecologically-sound industry. Repairing a part, rather than replacing one, is environmentally friendly on both ends of the chain: A damaged part is kept out of the waste stream, and the emissions generated by making a new part are avoided. However, the industry’s operations generate hazardous waste that – if improperly handled - may pose significant environmental and health risks.

Understanding Compliance and Penalties for Non-Compliance

Caliber recently shared a white paper to provide the industry with an essential guide for compliance regarding hazardous waste management. The paper provides a detailed overview of federal regulatory minimum standards, state-specific regulations, and provides information about regulatory agencies and initiatives. The most critical initiative being the Environmental Protection Agency’s (EPA) Resource Conservation and Recovery Act (RCRA), which creates the framework for the proper management (generation, transportation, treatment, storage, and disposal) of hazardous and non-hazardous waste. RCRA also regulates recordkeeping and assigns penalties for non-compliance.

Caliber Exceeds Minimums, Defining Best-in-Class

To ensure compliance, Caliber has created a nationwide standard operating procedure (SOP) which meets or exceeds all federal, state, and local hazardous waste regulations; it specifically addresses the unique regulatory requirements in the state of California.

But Caliber is committed to doing the right thing. Wherever possible, we align with the EPA’s best-practice recommendations, even if they are above-and-beyond the minimums for compliance.

Caliber’s goal is to not just dispose of hazardous materials, but to remove them from the waste stream entirely, when possible. To achieve this, we look to alternative, better-for-the-environment materials, or we partner with industry leaders to recycle both hazardous and non-hazardous waste.

Examples of Caliber’s best-in-class approach to hazardous and non-hazardous waste management:

• Caliber’s SOP specifies removal of solvent-based and water-based gun cleaners to align with center volume—a better system than adhering to local or state scheduling alone.
• All Caliber Collision centers spray water-based basecoat.
• Caliber prioritizes usage of other low-volatile organic compounds (VOC) and/or waterborne paint products.
• All Caliber centers use self-enclosed, recirculating, paint gun cleaning equipment.
• Technicians who are ASE Refrigerant Recovery and Recycling certified, exceeding industry standards and regulatory requirements.
• Significant investment in upgrading our centers to dustless ventilation systems, removing hazardous dust waste and helping to protect clean air.
• Cleaning solvent is recycled, and the recycled solvent is re-purchased, creating a closed-loop system.
• Used oil, oil filters, oily water, and antifreeze collected in our centers is recycled through our partnership with industry-leader Safety-Kleen.
• Caliber centers prioritize repairing parts, when compliant with OEM procedures, instead of replacing them. All Caliber Collision centers have plastic welders, to enable a greater number of parts repaired. This not only keeps waste out of landfills, it also helps reduce parts costs for our carrier partners.
• Repair procedures include the use of recycled automotive parts, when compliant with OEM procedures.
• Partnerships to ensure recycling of solid waste, including refurbishment or recycling of automotive lights.

These recycling programs exceed the minimum requirements set by the RCRA, which generally only prohibits the improper disposal (dumping) of hazardous waste. Where possible, Caliber has chosen to follow the EPA’s recommendation of recycling as the superior solution.

Recycling: Better than Disposal

Caliber prioritizes recycling both hazardous and non-hazardous waste where possible, ideally in a closed-loop system. One example of this is waste oil. By partnering with Safety-Kleen, we can ensure that our waste oil is recycled for consumer or industrial use, even when limitations of volume prevent Caliber from participating as a buyer of recycled products.

How closed-loop recycling of Caliber’s hazardous waste works:  

• Motor Oil: Filtered and re-refined into either new motor oil or lubricating oil; the process is subject to the same rigorous testing as products made from virgin oil, and the resulting product performs at least as well as virgin oil products. The solid metals filtered from the oil are also refined and sold as scrap metal.  Less energy is required to produce a gallon of re-refined base stock than a base stock from crude oil, helping to protect our environment in multiple ways.

This is the EPA’s recommended best-practice for waste oil.  

• Oil filters: Crushed into small pieces, heated to remove remaining oil (which is collected and added to the recycling stream listed above), metal parts are melted down and sold as scrap metal. 

• Oily water: Skimmed (oil skimmed off is processed as above), treated to be chemically and biologically safe, then discharged.   

• Solvent: Filtered and distilled to perform like new. Caliber re-purchases the cleansed solvents for use in our centers.    

Environmental Sustainability is Essential to the Long-Term Stability of the Insurance Industry

Sustainability Matters to Consumers

There have now been numerous studies showing that the American consumer cares about the sustainability of products they buy, even when there is a noticeable cost increase. Consumer preference for sustainable products is consistent, ranging from small, day-to-day purchases, such as food and household items (as shown in a recent study from McKinsey & Company) all the way to large-ticket items. Sustainability is driving sales growth of EVs and hybrids, with 72% of potential electric vehicle buyers citing the environment as a key factor in their decision making, according to Pew Research.   

Sustainability Value-Chains Can be a Differentiator for Insurers

Given the competitive automotive liability environment, it may be difficult for carriers to offer price incentives to attract or retain customers. In this environment, sustainable business practices can be a differentiator among insurance providers. Vehicle owners seek transparency and accountability and prioritize organizations that commit to energy efficiency and help reduce emissions.

Offering transparent value chains can be a further differentiator. This includes partnering with repairers like Caliber, who commit to energy-saving measures, best-in-class hazardous waste management, and prioritizing sustainability in repair processes.

Impact of Environmentally-Accelerated Weather Events on Carriers

The insurance industry is heavily impacted by the long-term pressures created through unsustainable practices. Insurers are among the first to feel the negative ramifications of climate-related weather events and the potential economic instability created through poor governance by businesses.

Internal & External Compliance Monitoring

Caliber has several partnerships and internal processes to ensure we remain compliant with federal and state hazardous waste regulations.

Internal procedures to ensure continuous compliance:

• Mandatory new-hire and annual environmental health and safety (EH&S) training for all teammates.
• Daily safety inspections by our General Managers.
• Weekly hazardous waste inspections by our General Managers.
• Regular reports provided to senior leadership.
• Dedicated environmental specialists in-house; including our Senior Director of Environmental Compliance, previously a Certified Unified Program Agencies (CUPA) inspector before joining Caliber .

External partnerships to ensure continuous compliance:

• A national agreement with Safety-Kleen, the largest environmental services company in North America, to dispose of our liquid, sludge and much of our hazardous waste.
• Safety-Kleen also specializes in closed-loop recycling, turning oily waste into new motor oil or lubricating oil, and recycling anti-freeze and solvents.
• Since 2012, Caliber has partnered with GMG EnviroSafe to support our EH&S compliance program.
  • Their Compliance Coordinators conduct unannounced quarterly assessments at every center to ensure compliance with all of Caliber’s regulatory obligations. 
  • They also support our training programs, assist with specific EH&S projects, and provide technical assistance on myriad safety and health issues.

Caliber’s Ongoing Responsibilities & Commitments

Pass-Through Costs Only

In accordance with applicable law, Caliber’s invoices to our carrier partners will contain pass-through hazardous waste costs; Caliber will in no way profit from the proper handling and disposal of hazardous waste.

Continued Compliance

Caliber will continue to review and revise its policies and procedures, as necessary, to remain compliant with all regulatory obligations and fulfill our commitment to doing the right thing. These enhancements may be reflected in quarterly rate changes.

Creating Value-Chains Through Reporting

Caliber is leading the collision repair industry when it comes to comprehensive reporting of our holistic environmental, social, and governance (ESG) efforts. We know that our partners benefit from value-chain tracking.

Our annual sustainability report includes Caliber’s performance aligned to the Sustainability Accounting Standards Board (SASB) Index. We evaluate and select the metrics we believe are most relevant to our business model and will continue to review. The specific metrics we have selected include:

• Employee health and safety
• Labor practices
• Employee engagement, diversity, and inclusion
• Business ethics
• Data security
• Corporate risk, including BCP and disaster
• GHG emissions
• Waste and hazardous materials management
• Product quality and safety