KPA Blog

OSHA

« Older Entries
Newer Entries »

OSHA’s Hazard Communication Requirements Explained

Wednesday, August 31st, 2011

There are five parts to an effective Hazard Communication program at your dealership. Your central record keeping should include a written program that demonstrates a commitment to chemical safety by management, Material Safety Data Sheets (MSDS) for every chemical on premise, a chemical inventory listing including quantities on premise, and documentation of all employee training activities around chemical safety. Additionally, make sure that all primary and secondary containers are properly labeled.

Keep up with these five things, and you’re in compliance with OSHA’s Hazard communication standard. Here are some more references about Hazard Communications on the web, and in video.

Hazard Communication at top of OSHA Top 10, 2010

How KPA helps dealerships create safety programs that comply with OSHA

Take two minutes and watch this video by Safety Engineer, Glorianna Cooley. She explains the core concepts around OSHA’s Hazard Communication Requirements and what they mean for dealerships and service centers.

Tags: , , , ,
Posted in OSHA, Prevention Plans | Leave a Comment »

Worth a Read

Friday, August 19th, 2011

Tags: , ,
Posted in Environment: Industry Updates, OSHA, Safety Culture | Leave a Comment »

OSHA General Duty Clause Explained

Friday, August 12th, 2011


OSHA enforces thousands of health and safety standards and rules. In addition to all these standards, there is one regulation that covers all hazardous conditions. This is the General Duty Clause (GDC), or section 5(a)(1) of the Occupational Safety and  Health Act. It states:

“Each employer shall furnish his (sic) employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious harm to his employees.”

The General Duty Clause is actually meant to clear things up a bit. It means that if there are actual injuries occurring, or a situation that could lead to an injury; if there are actual illnesses or health effects among workers or a situation that could lead to disease or illness; or if there is a situation that just doesn’t sit right- it worries us even if we are not “experts”- then this situation probably violates the General Duty Clause.

Read the full article in our August Newsletter

   Watch a 2 minute video about the General Duty Clause

Tags: , ,
Posted in Environment: Industry Updates, OSHA, Safety: Industry Updates | Leave a Comment »

Managing Compliance: Checklist for Flammable Liquids

Friday, August 5th, 2011

It seems to me that just about every liquid in an engine is flammable- from the obvious like gasoline and oil all the way down to windshield wiper fluid.  Add acetone, paints, paint solvents, degreasers, and detergents to the mix, and anyone can see the extent we need flammable liquids to service vehicles. Every automotive dealership, service station, and collision center has to keep a number of these on hand, and technicians need to handle them daily.

However, these chemicals are inherently dangerous, and that makes them heavily regulated. Here is the short list of “common sense and legally required safeguards for workers” that Brenda Gordon, OSHA’s area director for Boston and Southeastern Massachusetts referred to as part of Monroe Muffler’s recent $184,000.00 citation. This list focuses on areas where flammable liquids are in use- not where they are stored. It is not exhaustive, and you should discuss state and local regulations with your KPA safety engineer.

 

 Facility
 No smoking in the building. Check to make sure no smoking signs are properly mounted in and around the service bay and any areas- including outdoor areas- with flammable liquids
 All metal flammable storage containers need to be grounded with alligator clips and ground wires. Fixed storage drums need to be affixed to a grounded pipe. Gas caddies need bonding wire, complete with metal clips. Always use a pump for transfers.
 All lids need to be closed when not in use- including funnel lids and paint containers.
Remove all ignition sources located near flammable or combustible chemicals.
 Flammable liquids should never be transferred to non-approved containers (don’t use plastic cans, don’t let your technicians use empty beverage containers to mix solvents).
 Make sure your shop has enough fire extinguishers, that they are properly mounted, accessible, with signage, and that they passed the latest monthly inspection. Make sure there is at least one near the flammable liquids area.
 Maintain fire prevention equipment and plans. Keep emergency numbers posted by all phones.
Personal Protective Equipment
Any fuel-piping systems need to be equipped with flashback arrestors to prevent backflow of Oxygen or flashback into the fuel-gas.
Make sure hoses are in good condition
Make sure all shut-off valves are closed when not in use.
Training
 General shop and tool safety for all employees, as needed. Keep all certificates on file.
 Personal Protective Equipment Safety annually. Keep all certificates on file.
 Tool specific safety training, as needed. Keep all certificates on file.

Tags: , , , , , ,
Posted in Checklists, OSHA | Leave a Comment »

Monthly Facility Inspection List

Friday, July 29th, 2011

As the last business day in July, today is a great day to take care of your monthly facility inspections.

There are a few items in your dealership that need to be inspected and updated every month. There should be tags on these items for signatures and dates. These are safety inspection items, and federal law requires that they are monitored and maintained by the dealership on a monthly schedule. Here’s the short list:

Monthly Facility Inspection Checklist
Emergency lighting (short test)- make sure all exit signs (aka luminaries) are present and clean. Activate the system long enough to test each exit sign. Document defects and corrective actions. Check each exit sign for functional back-up system. If necessary, replace back-up power sources (battery packs).
Above Ground Storage Tank- Make sure monthly inspections are conducted as required by SPCC regulations.
First Aid Kits- Check the contents and make sure supplies are accounted for, and at the correct level. Make sure first aid kits are properly mounted and accessible. Sign and date inspection card.
Elevators with a phone or fire department call button- The requirement does not specify who is to perform the operation- maintainence company, elevator inspector, equipment owner or lessee- only that it is performed and that a written record of findings is kept on premises. Periodically, circuts and relays should be checked.
Eyewash stations- Check signage, make sure area is clear and the station is accessible at all times. It should be clean and ready for an emergency. Check portable stations for fluid expiration dates. Sign and date the inspection card.
Fire extinguishers- needle should be in the green, inspect for signs of damage or use. Make sure extinguisher signs are present and extinguisher is properly mounted.
Lifts- perform leak test: check for functionality, oil level and leaks in rolling bridge, wheel free, valves and hoses. Check moving parts for excess play, wear lubrication, and grease. Test switches and terminals to make sure the electrical components are in good shape. Check for overall condition including rust, damage wear, and alignment. Make sure decking and covers are secure, check anchor bolts, and all safety features for functionality.

Depending on your size, kinds of services that you offer, and your location, there may be other monthly inspection items that are part of your dealership’s safety responsibilities. You should talk to your KPA safety engineer to find out about other monthly inspection requirements specific to your state or local area.

It is also a good idea to keep an eye on other time-sensitive inspection items that need annual or periodic inspection and documentation (fire alarm systems, oil/water separators, new product tanks, lift inspections, permit renewals, waste storage areas…); they may need attention soon.

 

Tags: , , , ,
Posted in Checklists, Environment: Industry Updates, OSHA, Safety: Industry Updates | Leave a Comment »

OSHA Proposes Changes to Recordkeeping Requirements for Dealerships

Thursday, June 30th, 2011

OSHA is currently requesting comments for a proposed regulation change to their recordkeeping requirements.  Currently, new and used car dealerships classified under Standard Industrial Classification (SIC) code 5511 are considered a “low risk industry” and are partially exempt from OSHA’s recordkeeping requirements.  In this proposed regulation, in an effort to embrace a new industrial classification system introduced in 1997, OSHA is reclassifying new and used car dealerships as North American Industry Classification System (NAICS) Code 4411 – Automobile Dealers.  This new classification and the associated injury and illness statistics place dealerships outside the “low risk industry” profile, disqualifying them from the partial exemption.  If this rule is accepted as is, dealers will be required to maintain additional accident information and post summaries of this data at the dealership every year.

Additional changes in this proposed regulation will require businesses to report work-related amputations to OSHA and all work-related fatalities and in-patient hospitalizations.  Currently reporting is only required for work-related fatalities and in-patient hospitalizations of three or more employees.

If you’d like to voice your opinion to OSHA on this proposed regulation  they would love your feedback on the following:

1. Should any additional industries be exempt from any of the recordkeeping requirements in Part 1904?

2. Should OSHA base partial exemptions on more detailed or more aggregated industry classifications, such as two-digit, three-digit, or six-digit NAICS codes?

3. Which industry sectors, if any, should be ineligible for partial exemption?

4. Instead of using an average DART rate of 75 percent of the most recent national DART rate, is there a better way to determine which industries should be included in Appendix A?

5. Should OSHA consider numbers of workers injured or made ill in each industry in addition to industry injury/illness rates in determining eligibility for partial exemption?

6. Are there any other data that should be applied as additional or alternative criteria for purposes of determining eligibility for partial exemption?

7. Should OSHA regularly update the list of lower-hazard exempted industries? If so, how frequently should the list be updated?

8. Are there any specific types of training, education, and compliance assistance OSHA could provide that would be particularly helpful in facilitating compliance with the recordkeeping requirements?

Comments may be submitted online at Regulations.gov

Tags: , ,
Posted in DOL, Employee Relations, OSHA, Safety: Industry Updates | Leave a Comment »

Quick Take: Required PPE for Dealership Employees

Friday, June 10th, 2011

Employers are required to provide personal protective equipment at no cost to the employee [OSHA's Final Rule].

Substandard personal protective equipment (PPE) is the sixth most cited auto dealership violation for 2010. OSHA requires the use of PPE to reduce employee exposures to hazards in the workplace, and when used correctly, PPE saves lives and money.

For the most part, state regulatory standards are in line with federal OSHA standards for PPE, but it is a good idea to talk to the KPA engineer in your area to make sure that your facility is in compliance with state and local policies.

Each department at a dealership has to fill out a written PPE hazard assessment.  This assessment includes:

  • descriptions of the department’s  hazards that employees are exposed to on a daily basis
  • PPE provided by the dealership to protect the employee from that hazard.

A typical example of a hazard in located in the parts department would be a key cutting machine.  The hazard is the exposure of the eyes to metal shavings. The dealership would mark that safety glasses are provided to employees when using the key cutting machine.  These assessments must be renewed on an annual basis.

Here is the basic list of personal protective equipment at dealerships (assuming a service bay at the facility):

  • Respiratory: Proper respiratory equipment to protect against particulates and fumes depending on the job function. Make sure to that any employee needing a respirator completes a medical evaluation and a fit test before donning a respirator.
  • Noise exposure: ear plugs, ear protectors, or ear muffs depending on the noise level and length of exposure.
  • Eye and Face Protection: safety goggles, wrap around frames, visors, face shields, masks depending on risk exposures. [related article] Eye and face protection needs to be marked with a manufacturer’s brand (this helps the OSHA inspector determine that the PPE meets with ANSI standards).
  • Proper footwear: work boots, not tennis shoes in the service bay.  Work boots are currently under a cost exemption.  They are the only pieces of PPE that the employer is not required to provide at no cost to the employee.
  • Hand protection: Electric Shock Insulated gloves if working with electrical components [EV service technicians], protection against skin absorption of harmful substances, severe cuts or lacerations, abrasions, punctures, chemical burns, and thermal burns depending on risk exposure.
  • Training: [list of all required training for dealerships, including PPE requirements and frequency]

Watch this two minute video. It explains what kinds of personal protective equipment are needed at the dealership, how to comply with OSHA standards, and a real example of PPE that saved a technician’s head.

 

Tags: , , ,
Posted in OSHA, Safety: Industry Updates | Leave a Comment »

How to Implement a Successful I2P2 Program

Tuesday, May 24th, 2011

Like most Auto Dealers, you probably want to know how OSHA’s I2P2 (Injury and Illness Protection Program) will impact your business. Last week, EHSToday published an article “AIHce 2011: The Ins and Outs of I2P2 and Worker Involvement” about a roundtable discussion with William Perry, CIH, deputy director of OSHA’s Directorate of Standards and Guidance, and Bill Kojola, who works in the safety and health department at AFL-CIO.

My take-aways from this article came from the comments from Kojola. He said that for an injury and illness prevention program to be successful, it must accomplish the following goals:

  • It must encourage reporting – not just injuries, but ideas to control hazards.
  • It must shift from lagging to leading indicators.
  • It must get at root causes.
  • It must make use of documentation.
  • It must remove barriers to worker participation.

It’s no coincidence that our online safety system myKPAonline can be the make-it-or-break-it answer to implementing such a program. myKPAonline was partially driven by California’s IIPP program which can be considered as a precursor to I2P2. The picture shows a screenshot of myKPAonline for a dealership and provides reporting, documentation, root causes, and actionable information to implement a safety program.

Implementing I2P2 with myKPAonline

Implementing I2P2 with myKPAonline

Tags:
Posted in Employee Relations, OSHA, Prevention Plans, Safety: Industry Updates | Leave a Comment »

OSHA Fines Auto Parts and Used Car Dealer $49,000 for Safety and Health Violations: Conclusion

Wednesday, May 18th, 2011

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
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.
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.
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.
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.
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.
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.
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.
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.
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.

Tags: , , , ,
Posted in Citations, OSHA | Leave a Comment »

OSHA Fines Auto Parts and Used Car Dealer $49,000 for Safety and Health Violations

Tuesday, May 17th, 2011

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)

 

Violation image Violation description
No Documentation of Respirator Safety Program 

In order to comply with OSHA regulations for Respiratory Protection, every facility that requires employees to wear respirators should have at a minimum annual training and fit testing records, medical records, and respirator maintenance records for the past five years.
No Documentation of Hazardous Communications Program 

In order to comply with OSHA’s Hazard Communication requirements, every facility that stores or uses chemicals on site should at least have a written program, MSDS data sheets, labeling on all containers, annual and new hire training. This program needs to be accessible (most facilities post a MSDS access poster) and updated annually.

 

… and Lack of Hazardous Materials Training

Training should be completed for all employees involved in the transportation of hazardous materials every 3 years.

No Access to Material Data Safety Sheets 

MSDS sheets need to be available within 5 minutes and contain records for all chemical compounds on site.

Read the conclusion to this post at:

http://blog.kpaonline.com/2011/05/osha-fines-auto-dealer-49000-1/

Tags: , , ,
Posted in Citations, OSHA | Leave a Comment »

« Older Entries
Newer Entries »