CalABC Hot Topic Monthly Alert!

Provided Courtesy of Celly Services & Board Member, Sam Celly.


What is the purpose of the California Annual EPA ID Number Verification Questionnaire?

Anyone who generates, transports, offers for transport, treats, stores, or disposes of hazardous waste must have a hazardous waste identification (ID) number, which is used to identify the hazardous waste handler and track the hazardous waste from the point of origin to its final disposal ("cradle to grave").


The purpose of this verification is to ensure that the information on record for the EPA ID Number is correct and current.


The annual Verification Questionnaire and fees assessment for hazardous waste ID numbers and hazardous waste manifests is required by California Health & Safety Code section 25205.15 and 25205.16. Any generator, transporter, or facility operator who fails to provide information required by the department to verify the accuracy of hazardous waste activity data shall be subject to suspension of any and all identification numbers assigned and to any other enforcement action (Health & Safety Code section 25205.16(c)).

What to do?


Hazardous waste generators register on the state web site. All one has to do is log-in and complete the questionnaire to determine if any fees are due. Fees must be paid promptly with the system generated invoice. Fees can range from $150-600 per EPA ID number, depending upon the number of employees at the dealership and the hazardous waste manifests completed for the year.

Options available now:


What happens if you do not file EVQ: 


The Automotive Repair Shop’s EPA ID number will be made inactive. There is no real warning to the Automotive Repair Shop. The hauler stops picking up the hazardous waste as the EPA number has become inactive. Your hazardous waste oil tanks, drums and buckets can continue to overflow! Only after completion of a new EPA ID application, completion of the EVQ and upon the payment of fees, the EPA ID number gets reactivated. This whole process can take over 2 weeks and can be demanding. 


In summary, consider this matter as critical and get it done ASAP. 


Celly Services is a great member

and are always here to help.  

You can reach Sam at 562-704-4000 or

Other Useful Links:



Repair Orders: Get it Right by Writing it Right

"Estimate Tips"


Hello Industry Members:


With this month’s installment of our series on “Get it Right by Writing It Right” we are focusing on Estimate Tips for Estimate Amounts, Signatures, Designation of Authority, Parts and Sublet. During this series of articles, we are looking at the Bureau of Automotive Repair (BAR) Regulations and how they relate to successfully transacting with your customers.


No Charge Tickets. When writing an estimate for what are known as No Charge tickets, an estimate amount is required. Examples of No Charge tickets can be Multi-Point Inspection, warranty repairs, and for customer concerns about a prior repair, etc. Often there are three different types of estimate formats found for No Charge tickets. The first being no estimate amount at all. By law you are to provide an estimate amount for your customer understanding of the estimated cost. The second being a zero with a slash thru it. The third is “N/C” (No Charge) being used instead of an estimate amount. As referenced in a prior installment, BAR doesn’t accept abbreviations.  I do know that some BAR Representative will accept N/C. Even so, if your customer’s first language is English, the meaning of N/C is normally understood.  If your customer’s first language is not English, their understanding of N/C could be something different.  A universal language is dollar amount of “$0.00”.  My recommendation for customer clarity is to not use the estimate formats described above, but always use a dollar amount whether it is a No Charge ticket or not.  


How to avoid the customer’s five o’clock tax surprise. BAR law does not require you to provide an estimate amount that includes tax. To avoid customer complaints of their final invoiced amount (due to tax) being more than your estimated amount, my recommendation is to include tax into your estimated amount or add to your estimated amount the statement of “Plus Tax”.  These two options and how they are used can depend on your preference or what your Repair Order System accepts for an estimate amount.  These options are easier to use than having to explain BAR laws to your customer and hope it satisfies them.


Contract Signature. When obtaining a customer’s signature on an estimate, you must first realize they are also signing a contract.  The contract is not just for the required estimated amount and repair authorization but also for contractual disclosures. Contractual disclosures are normally found on the front and back of your estimate and invoice.  Examples of these contract disclosures would be a warranty statement and statements such as “Customer states no articles of personal property have been left in the vehicle and this facility is not responsible for inspection thereof”. Always have your customer sign the estimate/contract (when present) for your facility’s contractual protection and BAR requirements.


Customer authorization signature lines and multiple-page estimates. With Repair Order Systems that have two signature lines, one for repair authorization and one for the estimated amount, always have your customer sign both lines. The most common occurrence is to find a customer signature for the estimate amount only and no signature for repair authorization. Which means you cannot do the repairs.  When providing multiple page estimates my recommendation is to have all pages signed by the customer.  Again, this depends on the Repair Order System you are using. When the signature lines are on the first page and the number of pages is referenced, “1 of 2”, etc., then use the first page signature lines as designed. When your Repair Order System has no additional page references and signature lines are on all pages with the last page showing the estimated amount, then have your customer sign the last page of the contract or all pages. The most common issue is to find the customer signature only on the first page.  With the BAR, I dealt with consumer complaints saying they never saw the last page and the estimated amount. In this case, how do you prove that the customer saw the last page and estimated amount? When in doubt, always have the customer sign all pages of a multiple-page estimate. Remember when using electronic signatures, your repair orders must show a legible electronic signature and be maintain for at least three years.


Who is your customer? Per BAR, the person who brings the vehicle in for repairs is your customer. This does not mean it has to be the registered owner as a lot of the industry wants to believe. There are exceptions to this rule which is called Unusual Circumstances. This could be a tow-in, dropped off after hours or someone else bringing the vehicle in for your customer. We will focus on Unusual Circumstances and Additional Authorization with next month’s installment. The person who brings the vehicle in for repairs is the name that should appear on your repair order. When the name on the repair order is the husband and the wife is the person who signs and brings in the vehicle, who is your customer? The wife or the husband?  In this case the best thing to do would be to update your customer information to include both names which avoids the questions of who your customer is. When a customer informs you that they want their brother to authorize any additional repairs, BAR definition of this is “Designation of Person to Authorize Additional Diagnosis, Repair, or Parts”.  Another term used is Designation of Authority and this requires additional information to be provided and signed by your customer. BAR requires this to be done by using a separate form or being built into your work order/estimate format. The following are the requirements:


This exact statement of “I hereby designate the individual named below to authorize any additional work not specified or party not included in the original estimate for Parts and Labor”.


The name of the designee _____________________________. (Important to note the person is over 18 and isn’t a minor, as the customer can challenge you the “minor” wasn’t authorized to make the decision on the vehicle.)


The contact information for the designee which can be the phone number, text number, fax number, email address or other electronic means _____________________________.

Customer’s signature ______________________.

Date of signing ___________________________.

The work order number ____________________.


When using a form for the Designation of Authority, you must provide a copy of the form with the work order/estimate as soon as the customer signs it. If your Designation of Authority is built into your work order/estimate format, you will not need to include the work order/estimate number and you will still need to provide a copy to the customer as soon as signed.


Parts. Newest laws state “Each part in the estimate shall be new unless specifically identified as used, rebuilt or reconditioned”. Tips for dealing with the latter three categories. No abbreviations or jargon are allowed unless you have a legend on your work order/estimate that describes the abbreviations or jargon and how they fit into these three categories. Without a legend the use of abbreviations and jargon terms of Reblt, Recon etc. is not allowed and when used makes the estimate nonspecific.  That means the facility is not allowed to collect any money or even perform the repair or service.  When using a “parts kit” such as a brake spring kit or other “kits” be sure to last the name of the “parts kit” and the part number on your invoice. This avoids having to line list all the parts contained in the “kit”.


Sublet. For sublet repairs, a facility must receive consent from the customer to have someone other than your facility performs repairs while the customer’s vehicle is in your possession for repairs.  A windshield replacement is a good example of this. Your facility’s estimate must notify the customer of the sublet repairs.  Examples can be, Replace Windshield Sublet Repair or Sublet Windshield Replacement.  If the customer is to ask, you must disclose the name and location of the sublet repair facility. This can be done orally and is not required to be in writing. 


As we have said in past articles we published, in many cases customers complain either because their vehicle wasn’t serviced or repaired to their satisfaction, or they didn’t understand what happened or it didn’t fix the problem.  These estimate tips and prior articles we publish are an attempt to help explain how to stay out of trouble with both the BAR and your customer. 

This article’s tips  are for estimates amounts, signatures, designation of authority, parts and sublet have also been designed to show how to cover your facility’s assets when dealing with these aspects of estimates.



Stay tuned for our next installment of Unusual Circumstances and Additional Authorization!




Jerry Froehlich

JBS  “Advisement for Automotive Repair and BAR Issues”


Phone 909-649-5599

Lunch and Learn October 16th 2019 at 12:30am

at the UTI Sacramento Campus.

Come to our lunch and learn and hear attorney Rachelle Taylor Golden discussing the latest lawsuit trend with Private Attorneys General Act - PAGA claims. Get yourself up to speed in a hurry and protect you and your organization.

Rachelle Taylor Golden


Hatmaker Law Group

7522 N. Colonial Avenue Ste. 105

Fresno, CA 93711

P: 559-374-0077 / F: 559-374-0078



Universal Technical Institute

4100 Duckhorn Dr.

Sacramento, CA 95834

P: 916-263-9100


If you would like to attend be sure to contact our Executive Director Johan Gallo by calling him at 949-433-4513 or email

Upcoming Events

Oct 16th






Oct 17th

CalABC Board Meetings: General Session 2:00 pm - 4:45 pm. Closed Session 5:00 pm - 5:30 pm. Location at UTI Sacramento Campus.


2019 BAR Advisory Meetings: 9:30 am - 1:00 pm / Special Afternoon Sessions TBA 2:00 pm - 4:00 pm. Location at the Department of Consumer Affairs HQ! Hearing Room 102 1625 North Market Blvd. Sacramenton, CA 95834

CalABC Membership Information - Join Today!


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Executive Director, CalABC

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Monday, August 12, 2019

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