Did you take the October Newsletter matching game challenge? Think fast! This is a quick refresher for DOT signs that you might see around the service bay. Match symbols to win. See how fast you can go! Play solo or with a group. Follow this link to test your skills:
http://www.kpaonline.com/news-and-events/newsletter/october-2011/dot-hazard-signs-memory-game.html
You’ve asked for it and now it’s here: The Safe Driving online training course. If you or your employees test drive vehicles that have been in for service, shuttle customers to or from your location, take customers on test drives as part of the sales process, or transport vehicles or parts from one location to another, this course will help increase the number of safety precautions you take every time you get behind the wheel.
Take the course for a spin today! Go to mykpaonline.com > Dashboard > My Online Training > and then scroll down until you see Safe Driving. When you’re finished, let us know what you think by taking the survey at the end of the course.
Also, keep an eye out for a new course on respiratory protection set to launch this fall. Have a course you’d like to see KPA develop? Let us know!
Recently, we received this note from one of our clients. I’d like to thank them for the kind words, and share it with our online community because it has some helpful information about Hazmat shipping by air.
“Just a note to let you know, we had a visit from an FAA hazardous materials agent today. We shipped a used fuel pump back to Honda on the 11th per their request. We shipped it air per the Airbill info that Honda supplied. He said that they check all air shipments of Hazmat materials and needed copies of my training certification and asked a few questions, he had copies of the Airbill. Said he checks Fedex daily for all Hazmat airbills. He also said we should call the emergency response number that we are listing to make sure that it is valid and current, and that we are covered under their contract. I let him know that we use KPA for our training; he said they are the best. I asked and he said everything was okay, left a Hazmat transportation safety infopack. Also said they are focused on air shipments and not ground shipping, and was surprised that Honda did not ship the part by ground. He pretty much told me that I should refuse to ship by air.”
Training Requirements for Dealership Employees
The quick guide to training: who needs it, in which areas and departments, for which enforcement agencies, and how often each training requirement must be renewed. Check the list at http://kpa.co/iSyVAA
Under the DOT regulations (Title 49 Part 172.702) any employee defined as a hazmat employee is required to be trained. So you ask what is a hazmat employee? The definition is found in (Title 49 Part 171.8) and includes employees that:
• Load, unload, or handle hazardous materials
• Prepare, package, label or mark hazardous materials
• Operate a vehicle used to transport hazardous materials
Now of course not all employees at your facility need to be DOT trained, but depending on who is responsible for different operations you may have to train more employees than you would like. So for an automotive service facility employees that need to be trained include:
• Parts management – they oversee the transportation of hazmat
• Parts shipping & receiving – they load & unload hazmat & might even prepare shipping papers
Additional employees that may need to be trained include:
• Parts drivers – they may transport hazmat
• Service employees – they may prepare & package hazmat (take for example a battery being returned to the manufacturer. The service employee prepares the battery for shipment and may even place it in the shipping container
• Service management – they may oversee hazmat employee operations and may sign for hazmat shipments with the disposal of their facilities wastes.
Learn more about KPA’s hazmat training at http://www.kpaonline.com/ehs/dot.html
Join the conversation: How are you providing required training in your dealership.
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.
“Oh no! We have a serious problem. The plant office manager ran into my office with a frantic look of panic on her face. The company safety inspectors are here and they want to see an MSDS on the Wite-Out. What will we do?”
Although this article written by Greg Klima titled “MSDS Gone Wild!” never explains if you really do need an material data safety sheet (MSDS) on Wite-Out, it’s a side of hazard communication that you don’t see too often, and it’s an interesting insight into an alarming scenario.
The story plays out like this: you are scrambling through your binders or your MSDS database of chemicals (just like about a thousand other safety professionals do every year when safety professionals show up). You are panicking because you have been taught to believe that you need an MSDS on every chemical in your facility, including Sally’s mayonnaise packets, Timmy’s aspirin, and Billy’s cosmetic dental floss, and the author’s advice while this hectic scenario plays out is to:
Relax!
It’s true that the purpose of the hazard communication standard is meant to set rules to inform employees of risks which they are exposed to when working with potentially hazardous chemicals, but while the intentions of this basic rule of haz-com makes us keep our binders and databases updated in the event of an emergency or a facility audit, we have perhaps become almost too good at this practice. We now may have MSDS on items we don’t necessarily need to have them for – the truth is we do not need to have an MSDS on every single chemical in our facility. Once we determine which items not to worry about keeping on file, the easier it may be to maintain records. It’s that simple.
When Do I Not Need an MSDS?
If you check OSHA’s 29 CFR 1910.1200, you’ll see that OSHA is very specific about exceptions to its application and scope. MSDS are only one form of hazard communication. Two additional ways to inform employees about potential risks include container labeling and employee training. Other details include what chemicals are exempt from this rule (29 CFR 1910.1200(b)) and which categories of hazardous chemicals do not apply (29 CFR 1910.1200(b)(6)). Knowing what to be worried about now might save you some fretting in the future.
At KPA, we can help you maintain and update your facility’s MSDS database and chemical inventory as well as provide training and expert advice to help you support a safe and healthy workplace. With seven EHS services, we can help you comply with DOT and MSDS and hazard communication requirements all the way up to a complete environmental, health, and safety program. Each KPA service consists of a combination of online software, on-site services, function-specific training, and expert consulting necessary for a complete compliance program. Contact us to learn what level of support is right for your business.
You know how the old adage goes: “Train as if your life depends on it, because it does.” This is especially true when it comes to hazardous materials training – many lives depend on the proper training of Hazmat Employees.
As we have mentioned before, if you have hazardous chemicals in your facility (and remember that acetone and gasoline are hazardous chemicals), you must comply with DOT hazmat rules (Title 49 CFR 172, Subpart H) and OSHA’s Hazard Communication (“Right to Know”) Standard. If you don’t regularly ship hazmat or you are not a manufacturer of hazardous materials, don’t think that your dealership is immune to the regulations. Whether you or ship hazardous materials once per year or every day; around the block or across the country; in a small package or in a tank: You must protect your employees and the public from any potentially adverse effects of the chemicals being handled.
The idea is pretty straightforward: Workers have a right to know about the substances and chemicals with which they come in to contact, and any risks they may be exposed to, as well as the proper protective equipment to use. Under the Hazard Communication Standard, shippers are also required to maintain a database of Material Data Safety Sheets (MSDS) and a facility-specific chemical inventory of the chemical products stored and used throughout their facility.
Every employee who affects the safety of hazardous materials transportation is a Hazmat Employee and must be trained. This definition also applies to the owner or the operator of the vehicle transporting the hazardous materials in commerce or any employee who, during his or her course of employment:
Take this simple quiz to see if your dealership could pass an OSHA/DOT audit:
Read more of our EHS DOT blogs.
If you are unable to answer “yes” to every question, contact us to learn more about our new standalone DOT and MSDS service.
Are you aware that each and every tire that is sold at your dealership must be accompanied by a completed registration for every customer?
You should be. Though registration of tires has been a federal mandate of The National Highway Traffic Safety Administration (NHTSA) since the 1970s, enforcement has significantly increased. Penalties for noncompliance can range from $1,000 per tire with a maximum fine of $880,000.
In order to comply, the tire dealer must provide consumers with:
The registration form must be pre-addressed, mailable, and must be offered free of charge. If you choose to register the tires electronically, you must choose a method that is acceptable to the tire manufacturer. A number of third-party tire registration vendors exist in the market to help with this requirement.
The objective of this regulation is consumer safety, which aims to remove potentially unsafe tires from the streets in the event of a safety-related tire recall. It is the buyer’s right is to be notified in case there is a problem with the tire that could lead to serious or life-threatening injury if left unaware, and it is your responsibility to ensure they have registered tires, or the information to do so themselves when they leave your facility. Tire registration at the time of purchase is the only realistic way for a manufacturer to notify the buyer of the tire recall.
For more information, check out the rule from the Department of Transportation (DOT) and the recent amendments regarding electronic registration.
We learned from our GM dealer clients that they received notifications to temporarily suspend all Hazardous Materials shipments from GM dealers on Thursday, September 2, 2010. The communication also outlined the steps that GM dealers have to take to lift the shipment suspension. In order to be allowed to ship hazmat again, all GM dealers will have to declare completed HAZMAT Certification Training for all hazmat employees by Friday, September 17, 2010.
The regulations that apply to GM’s DOT training requirements are 49 CFR §172.704 “Training requirements”, and 172.702(a) “Applicability and responsibility for training and testing”. The requirements include general awareness/familiarization training, function-specific training, safety training, emergency response, measures to protect employees from exposure to hazardous materials, procedures for handling hazardous materials, in-depth security training, as well as OSHA, EPA, and initial and recurrent training.
Other requirements are items such as recordkeeping of hazmat employees’ training, compliance, and certification that the hazmat employee has been trained and tested.
If you’re concerned whether or not your dealership is meeting these requirements, KPA can help – please call us at (866) 356-1735. Contact us for more information about DOT hazmat training.
