Have you signed up for the free 6H Emission Standards webinar on January 20, 2011? Peter Zaidel, product manager at KPA, will review the EPA-6H (40 Code of Federal Regulations 63, Subpart HHHHHH) requirements so you can be sure you’re fully compliant. Click here for the registration form. You cannot make it on January 20? I’d highly recommend you still sign up as you will receive an email after the webinar with a link to the recording.
Environment: Industry Updates
Free webinar on EPA’s 6H emission standard
Monday, January 10th, 2011OMB Watch reports drastic increase in OSHA citations for 2010
Tuesday, December 28th, 2010
A new study by OMB Watch finds that the Obama administration has noticeably increased enforcement of workplace safety laws, and supporting data also showed that the administration was making consumer health and environmental regulations enforcement tougher.
In 2009, the Occupational Safety and Health Administration (OSHA) issued more than 68,000 citations – more than twice the amount of citations issued the previous year by the Bush administration. In 2010, the drastic trend upwards continued with citations skyrocketing at almost 114,000 by the middle of July. You do the math and you can see how many citations might be issued in 2011 – maybe triple that amount and add a few more.
OMB Watch reported seeing similar trends at other agencies but none were quite as steep in comparison to the previous administration. The Environmental Protection Agency (EPA) increased the average amount for a fine against the Clean Water Act by nearly one-third during the Obama administration’s first 18 months; however, the penalties for serious violations were issued at a slightly slower rate compared to that of the preceding administration.
Please read more about OSHA safety compliance and how KPA can help you find a solution to support your dealership’s safety culture.
Beyond Improving Profits – Safety Culture Is a Key Benefit for Employees
Monday, December 13th, 2010
Creating a positive safety culture is one of the most important things you can do for your employees. The benefits of a strong safety culture go beyond reduction in insurance premiums, limiting exposure to fines and lawsuits and reducing time lost to an accident. A safe and healthy workplace shows that you care about the well being of your employees. Employees are happiest and most productive in a workplace where they have a high degree of trust in management. A positive safety culture is an important factor in confirming management’s commitment to employees.
Notice I said creating a positive safety culture is important for employee well being not just creating safety programs. Safety programs provide the structure required to manage safety in your organization and are a key component in developing a rewarding safety culture, but a good safety culture also emphasizes a shared vision between management and employees, strong employee involvement, and behavioral based safety training.
There are several key elements to creating a positive safety culture:
- Management, at all levels, must be involved and participate in the safety program to show they genuinely care about the well being and safety of every employee.
- Management and employees must participate together in collaborative problem solving to identify safe and unsafe behavior.
- All employees should receive high quality safety training (consider hiring an expert third party) and follow training with ongoing coaching and on the job training from all levels in the organization.
- Operational processes and policies must be established that ensure that safety is always at the forefront of any action or activity.
- All employees must be empowered to report and when necessary act on unsafe behavior, and identified issues must be quickly addressed by management.
To learn more about creating and maintaining a strong safety culture check out these free resources: http://www.kpaonline.com/ehs/osha.html or http://www.osha.gov/SLTC/etools/safetyhealth/index.html
Join the conversation: What do you believe to be the most important element in creating a positive safety culture?
EPA intends to employ vigorous and targeted civil and criminal enforcement
Wednesday, November 24th, 2010In order to provide effective and consistent enforcement of federal laws nationwide, the Environmental Protection Agency (EPA) is stepping up its civil and criminal enforcement by targeting the most serious hazards that relate to air, water, and chemicals. The EPA summarized the measures it will take on how it plans to use “vigorous and targeted” civil and criminal enforcement in the 2011-2015 EPA Strategic Plan. The plan outlines strategic measures for the criminal enforcement program by taking “aggressive action against pollution problems that make a difference in communities.”
For the first time, the EPA has included the measures it plans to take to enforce these hazards in order to protect human health and the environment, as well as protecting the low-income, minority, and tribal communities which may be disproportionally impacted by these hazards. The EPA states that in order to achieve these goals, they need both new strategies and compliance to the rules that they already have. This concentrated effort is meant to achieve “increased transparency” so that more of your business’s information will be accessible to the public and the best way to comply would be to become more involved in your facility’s operations.
Some of the specified enforcement maintenance that the EPA will take by 2015 includes:
- Here are some of the enforcement actions EPA plans to take by 2015:
- Conduct 105,000 federal inspections and evaluations (FY 2005-2009 baseline: 21,000 annually)
- Initiate 19,500 civil judicial and administrative enforcement cases and bring 19,000 to a conclusion (FY 2005-2009 baseline: 3,900 )
- Review overall compliance status of 100 percent of open consent decrees (FY 2009: 100 percent)
- Increase the percentage of criminal cases with charges filed to 45 percent (FY 2009 baseline: 36 percent)
- Maintain an 85 percent conviction rate for criminal defendants
For more information, check out the 2011-2015 EPA Strategic Plan.
MSDS Gone Wild!
Friday, November 19th, 2010
“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.
OSHA’s Top 10 Most Cited Violations for 2010
Wednesday, November 17th, 2010
OSHA’s Top 10 Most Cited Violations for the 2010 fiscal year was revealed at The National Safety Council (NSC) Congress and Expo in San Diego in EHS Today. Keeping with the trends of previous years, this new top 10 was only slightly different from last year’s top 10. Thomas Galassi, the director of OSHA’s directorate of enforcement programs, listed the 2010 top 10 at the NSC conference and said that OSHA generally sees “a degree of consistency in these violations” and that the “violations relate to falls, contact with equipment and exposure to harmful substances.”
For the second year in a row, we have compiled a list of the top ten violations by Auto Dealers for you.
- Hazard Communication
- Electrical safety requirements
- Abrasive wheel machinery
- Respiratory Protection
- General Duty Clause
- Personal Protective Equipment
- Walking/Working Surfaces (including stairs and ladders)
- Machinery and Machine Guarding
- Powered Industrial Trucks
- Medical Services and First Aid
Once again, our list was similar to our Top 10 list from last year. Hazard Communication was at the top of the list for a second year in a row and stands out as the most common violation cited by OSHA. Perhaps getting the word out about these haz-com requirements should be at the top of more public relations and association’s top 10 “to-do” lists. “These are very important,” Galassi said. “[They are] lessons learned in the workplace … lessons to take home.”
For more information about the Hazard Communication Standard, visit the OSHA’s Inspection Procedures for Hazard Communication Standards or learn more about OSHA safety, material safety data sheets (MSDS), and employee training.
Hazmat Training – Lives depend on it
Friday, November 12th, 2010
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:
- Handles, loads, or unloads hazardous materials
- Manufactures, marks, classifies, labels, packages, or otherwise represents containers, drums, or packagings which are classified for use in the transportation of hazardous materials
- Prepares hazardous materials for transportation
- Is responsible for storage and disposal of hazardous materials
- Is responsible for safety of transporting hazardous materials
- Operates or owns a vehicle to transport hazardous materials
Take this simple quiz to see if your dealership could pass an OSHA/DOT audit:
- Do you have records confirming at least one employee has DOT Hazmat Certification?
- Is this training being updated every three years?
- Did this training include the newly required “Security Awareness” training?
- Are you following the proper procedures for hazardous shipments using the proper labels, classifications, identification numbers, and packing groups according to the DOT’s hazardous materials table?
- Do you provide the required 24-hour emergency contact phone number on your shipping papers?
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.
Beyond “Right To Know” for MSDS information
Friday, November 5th, 2010
Your employees have the “right to know” about hazardous chemicals in the workplace under OSHA’s Hazard Communication Standard (HCS) which states “employers with hazardous chemicals in the workplace must have label and material safety data sheets (MSDS) for their exposed workers and train them appropriately.” The HCS allows for MSDS to be kept hard copy format or online – but in the event of an emergency, do you really want your employees scrambling for a binder full of MSDSs and then frantically looking for the right sheet among many? Online systems provide search tools, index, and immediate access making critical information not just available but “easy to find.” Online systems with a backup CD-Rom option give you “peace of mind” if your internet connection goes down during an emergency. When seconds count in the event of an emergency that involves hazardous chemicals “easy to find” and “peace of mind” is just as important as the right to know.
Announcing the latest KPA services!
Tuesday, November 2nd, 2010Here at KPA, we have good news to announce about our latest and greatest software and services! We have taken our Environmental, Health, and Safety services product line and we have more than (drum roll please…) doubled what we offer!
We have expanded our three levels of service to seven levels to accommodate all of the many different types of auto dealers, auto service shops, heavy equipment dealers and manufacturers. We now have more options and competitive pricing for the smaller, independent dealers in the marketplace as well as the many other size dealerships, so that we are able to be of help to any size or shape business.
Our latest offer includes a standalone DOT and MSDS service, the next level is Elements service, our Fundamental and Fundamental Plus, Core and Core Plus, and Pro service. In addition to these, we are excited to have incorporated a self-inspection and survey tool that is available on our online software, MyKPAOnline, so you don’t have to use other generic surveys to audit your site. Our other latest special feature which adds to our “Plus” services is the addition of “online conference and audit reviews.” These online, webinar-style audit reviews are a convenient and practical way to have your safety issues reviewed with your KPA safety professional from the comfort of your desk.
Read the latest news release and go to our EHS Software and Services.
Keep the great ideas coming; we are listening!
Now is the time to prepare, evaluate, update and implement your SPCC Plan
Sunday, August 1st, 2010
This year brings the hottest climate to the current state of environmental issues, and with the current focus of disasters such as the BP oil spill, enforcement is increasing and the consequences of non-compliance are expensive and potentially devastating.
The SPCC Rule essentially requires specific facilities to prepare, amend, certify, and implement an SPCC plan, thereby ensuring containment and countermeasures that will prevent oil discharges. Some elements of an SPCC plan include ensuring staff has undergone SPCC specific training, preparation of monthly self-inspection procedures and documentation, and a Five-year Plan review.
For more information, please see http://www.epa.gov/emergencies/content/spcc/index.htm