The General Duty Clause explained for dealerships and service centers by an OSHA enforcement expert. This video covers how dealerships get cited for General Duty Clause violations, and how to identify and address issues before they become citations. General Duty Clause is one of the top OSHA violations for 2011.
Our engineers have found some rather unusual instances of general duty clause issues at dealerships. How does you facility identify and address general duty clause issues?
What is OSHA citing dealerships for most frequently these days? We compared our notes from KPA inspections at dealerships and service centers across the country with the most recent numbers released by OSHA for the transportation industry. We used this information to put together the Top 10 most cited violations by dealers to help your dealership get prepared for 2012.
Get the facts by signing up for tomorrow’s webinar presented by Eric Schmitz, Vice President of Products and Business Development at KPA.
Yesterday’s post discussed training violations OSHA issued to a parts and used car dealership in Illinois. Physical hazards were also a large part of the 14 safety and 6 health violations facing the company.
Here is the list of physical hazard citations from Bill Smith Auto Parts, Inc, along with recommendations for improvement.*
| Violation image | Violation descriptions and recommendations for improvement |
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Missing machine guarding
This usually happens on parts grinders. Check the machine for side guards, correct adjustments on the tool rests and tongue guards, and proper anchoring. If in doubt, this 2 min. video gives a good overview of grinder safety. |
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Improperly maintained industrial trucks
Check that forklifts and other lift trucks are maintained in working order according to the manufacturer’s recommendations through. You should include documentation of maintenance.
This could also be a housekeeping issue. Outdated and unused equipment should be removed from the premises. |
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Improperly stored hazardous materials
If they are flammable, containers need to be grounded, or outfitted with a bonding wire. All containers need to be approved for their contents, and they need to have lids. Document inspections storage areas, and everything should be labeled. |
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Lack of guarding on open-sided floors
All elevated work surfaces, including but not limited to alignment or lube racks, in ground lube pits and storage platforms should have proper fall protection measures. |
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Failing to properly store compressed gas cylinders
Compressed gas cylinders should be securely fastened to rigid structures so they won’t fall or be knocked over. |
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Lack of guarding on pulleys and other equipment lower than 7 feet from the floor: struck-by hazards
Replace guards/restraints on pulleys to ensure safe operation. |
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Damaged electrical cords in use
A very common problem that poses a serious shock hazard. The damaged cord should be replaced. Never splice an electrical cord as a repair method, and make sure the cord is the right length to avoid using extension cords as permanent wiring. This handy Extension Cord Checklist is available for more information about shock hazards. |
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Unlabeled hazardous material containers
Apply a “Hazardous Waste” label to the container and fill out the required information. Typically, this violation is cited with language like “potentially hazardous waste” because in general, the inspector does not actually test contents of each and every barrel. That is why all containers need to be labeled, including “non-hazardous waste.” |
| Use your imagination. | Unsanitary conditions in restroom
You might not be familiar with OSHA code 29 CFR 1910.141, but it requires that all restroom facilities, particularly those accessible to employees, remain clean and sanitary at all times. |
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Failing to post visible “no smoking” signs in areas where flammable materials were present
All areas where smoking is prohibited in the facility must be labeled “no smoking or open flame.” Including flammable or combustible storage areas. For more information, read this post, “Danger in Detail.” |
“Employers are responsible for knowing what hazards exist in their facilities and for following OSHA standards to ensure the safety and health of their workers,” explains Tom Bielema, director for OSHA’s Peoria office. While Bill Smith Auto Parts is working with OSHA to use the inspection report as an opportunity for improvement, all of these violations are avoidable, and precautionary measures should be part of your facility’s daily routine.
This is an opportunity for you to look over your facility, check your paperwork, and share this list with your employees as an educational opportunity, because the best environmental health and safety strategies are supported at every level of the company.
Many, if not all, violations and workplace accidents are preventable with KPA’s services. KPA’s Environmental, Health, and Safety (EHS) service is designed for dealerships to effectively manage and document safety and environmental compliance. EHS services include regular on-site facility visits conducted by a professional with environmental safety compliance experience including OSHA and EPA, an electronic MSDS database, online training courses, required signage and labels, and 24 hour hotlines. All of this information is available at your fingertips through myKPAonline.com, which features a dashboard indicating your facility’s overall level of environmental health and safety.
In the event of an emergency – including inspection visits by federal or state inspectors – your KPA engineer is only a phone call away.
*images are from KPA’s database, and do not represent the exact conditions at Smith Auto Parts.
Sometimes, good businesses make bad decisions. Small businesses are especially vulnerable to bad decisions in using substandard safety processes and systems. During a recent OSHA visit, an auto parts store in Urbana, Illinois learned the value of investing in safe operating conditions the hard way. Bill Smith Auto Parts, Inc. was fined $49,000 for a combination of 14 safety and 6 health violations.
On the list of violations are the usual suspects from OSHA’s top 10, and are things to watch for at any automotive parts or resale facility. Here is the list of citations from Bill Smith Auto Parts, Inc, along with recommendations for improvement.*
For this blog, the violations are discussed in two editions: training and physical hazards in the work environment.
Training
In order to remain compliant with OSHA regulations and reduce losses at the facility, all regulatory programs should be in place and
implemented including:
• Hazard Communication & Emergency Response Program
• PPE Program & Hazard Assessment
• Ergonomics Prevention (if applicable)
• Powered Industrial Trucks (if applicable)
• Respiratory Protection Program (if applicable)
• Heat Illness Prevention Program (if applicable)
Read the conclusion to this post at:
http://blog.kpaonline.com/2011/05/osha-fines-auto-dealer-49000-1/
The U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA) issued 33 citations to the Parker Hannifin Corp. plant in Batesville, Mississippi. Half are repeat citations (which come with much higher price tags) that are based on similar situations found during previous inspections conducted at other company locations. Ohio-based Parker Hannifin has 170 facilities throughout the U.S. and manufactures machinery for hydraulics, air conditioning, refrigeration and aerospace systems.
The list of violations are the usual suspects from OSHA’s top 10, and are things to watch for at any automotive repair or manufacturing facility (this is a good time to look over your facility and check your paperwork):
• Air pressure is not to exceed more than 30 pounds per square inch for cleaning equipment
• Failure to document periodic inspections of the lockout/tagout process in place to prevent accidental energy start-up
• Failure to train workers on lockout/tagout procedures
• Failure to unblock exit doors and routes
• Failure to provide machine guarding
• Failure to correct electrical deficiencies
• Failure to attach hazardous warning labels to tanks containing hazardous substances
• Defective safety latch on a hoist and damaged hooks on an overhead crane
• Unapproved electrical equipment used in a hazardous location
• Failure to post signage indicating the direction of travel to the nearest exit;
• Failure to provide a danger permit-required confined space sign
• Failure to mark a web sling with the rated load capacity
• Failure to require workers to wear goggles or suitable eye protection while welding
• Failure to provide personal protective equipment
There’s a reason that Parts Grinders are one of the top OSHA violations. Just last week I visited a dealer who has been a KPA client for more than 14 years and an excellent record when it comes to environmental and safety. Yet, during our quarterly inspection we found that their parts grinder was not mounted properly: see picture. This violates Federal Regulation 29 CFR 1910.212(b) “Anchoring fixed machinery. Machines designed for a fixed location shall be securely anchored to prevent walking or moving.”
Fixed Ops managers should be on high OHSA alert for these situations.
About a month ago we wrote a blog about how your parts grinder can pass an OSHA inspection. The event that triggered this blog was that OSHA issued five citations totaling $75,000 to Pep Boys for a “repeat violation” and at the center of the fines was a parts grinder. Parts grinders, or abrasive wheel machinery, were the third most cited auto dealership violations in 2010. Parts grinders are citable violations because by nature, they involve contact between employees and equipment.
Are your parts grinders safe?
On a busy day, the floor can be covered in soaps, “engine juices,” oils, chemicals, and solvents. Flammable liquids in 55 gallon drums line the wall, with a high risk of explosion from any ignition source.
This is where the safety culture at your dealership gets the road test. In the detail department, where staff is usually subcontracted, and not normally a part of the safety committee. How do you measure the risk of workplace hazards and compliance liabilities in this work area?
Here’s the short-list of what to consider in your wash bay risk assessment:
Subcontractors and Liability
Even if the work is subcontracted, the dealership could be liable for accidents or injuries. OSHA fines and financial liability both play a part. You should make sure that your subcontractor has adequate insurance. Get a certificate of insurance from your subcontractor, check that the coverage is adequate and keep it on file at your dealership. As the primary employer at the dealership, OSHA may also find you responsible for your subcontractor’s omissions. Check up on all of your subcontractors to make sure they’re not cutting corners.
Recently, OSHA cited Pep Boys for serious and repeat safety violations. The chain faces a total of $75,000 in fines. The unusual part of the report is the way that OSHA counted the violations.
What happened is that in 2009, a citation was issued to a facility in one location for OSHA violations. In 2011, a different Pep Boys facility was found to have similar hazards as the first facility. This second location was issued fines for serious and repeat violations because OSHA counted the violations as though all Pep Boys facilities are a single unit.
The implication is that OSHA expects company-wide communication from all businesses with more than one rooftop. This is why the Instant Compliance Visibility feature of MyKPAOnline delivers a quick snapshot of compliance for all levels of the organization down to the individual manager.
OSHA recently issued five citations totaling $75,000 to the Pep Boys auto service company after a facility inspection in Hamden, CT for a “repeat violation.” The previous citation was at a different franchise location. At the center of the fines is a parts grinder.
Parts grinders, or abrasive wheel machinery, were the third most cited auto dealership violations in 2010. Parts grinders are citable violations because by nature, they involve contact between employees and equipment. Robert Kowalski, OSHA’s area director in Bridgeport, warns the chain that, “It would be to the benefit of its workers’ safety company-wide for this employer to determine if similar hazards exist at other stores and to eliminate them if they do.”
Watch this two minute video. It explains what OSHA looks for in parts grinders during an inspection, how to comply with OSHA standards, and also has safety tips for parts grinder operators.
Airbags contain hazardous materials. Requirements for commercial shipping of these materials vary depending on if your parts department will ship the airbags by ground or air.
Ground Shipments
Air Shipments
KPA recommends that all clients should review DOT certified employee status:
Clients with additional questions on DOT hazmat certification, FAA investigations, and IATA certification are encouraged to contact their KPA engineer.
