Safety: Industry Updates

A Note About Hazmat and FAA

Tuesday, August 2nd, 2011

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.”

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.

 

You Can’t Teach a Young Dog With Old Tricks

Friday, July 15th, 2011

Here’s what you already know: technology is intrinsic for most Gen Y workers. Furthermore, for most of them, a day isn’t complete without texting, facebook, twitter, foursquare, or other information stream of choice.

According to a new poll from Public Policy Polling, this daily technology immersion changes the way a young person learns. You can reach them more effectively through a training program that speaks to their basic learning needs.

Trainer’s Takeaways:

  • Get mobile, and think outside the classroom. Young workers value location freedom. They prefer learning through hand-held mobile devices or laptops.
  • Keep training sessions short, or give frequent breaks. For all age groups, the first 15 minutes and last 5 are the most retained. If you can’t shorten the session, arrange it so that important information is covered during these learning windows.
  • Interaction is king. The more interactive the training is, the more engaged the young students will be. Remember Gardner’s Theory of Multiple Intelligences? It holds true for this generation, and using multiple channels to reach your audience  training exercises.

These findings don’t mean that young workers don’t want to learn. The findings only indicate that a little accommodation  strengthens your training program by reaching students through their preferred learning style.

The Disclaimer:
By nature, polls can only measure general trends. There are exceptions to every generalization, and some of them may be working at your dealership.

The Training Challenge:
The bottom line is that your safety programs are not effective if your students are tuning out during an important presentation. Small accommodations go a long way, especially if you’re noticing behavioral trends in your employees that mirror findings from this poll.

The complete poll, titled “Corporate Voices National Worker Surve” is available here:

http://corporatevoices.org/system/files/WPO+Survey+Analysis.pdf

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

When to Align Company Safety Policy and Company Culture

Friday, June 24th, 2011

In business, culture predicts outcome. For example, Adoflson & Peterson Construction, won the EHS 2010 America’s Safest Company Award. The company went on to  attain 4.4 million consecutive hours worked without a lost time accident. Another safe company finalist, Armstrong World Industries, Inc is ranked as a top 5 building products company, with the highest free cash flow per share rating. There are many more examples like these that demonstrate the positive relationship between strong safety cultures and successful business outcomes.

Best Practices
Company safety is a direct reflection of the decisions leaders make, the things they say, the systems they implement and oversee, and the value they place on safety with respect to other objectives. It is a combination of company policy- the official rules, and company culture- what employees actually do and say.

There should always be alignment between safety policies and company culture. If company culture doesn’t support all safety policies, then there is a problem.

Addressing the problem looks at the policy first. Ask two questions:

  • Is it in compliance with the latest regulatory updates?
  • Is it specific, measurable, attainable, relevant and timely (SMART)?

If the answer to either is no, then the policy needs to change.

If the problem is not the policy, then the culture needs to change. Safety isn’t something that can be delegated; it has to be part of workplace vales for everyone, from the CEO to each worker. If your company culture is not in alignment with company policy, it is time to change the culture.

How to Change Company Culture

Now is a perfect time for your company to adopt a safety culture. The process is different, depending on if your company is in a stage of growth or a stage of turbulence. If you have been with your company for more than a few years, you know about this. The chart below is from the classic resource, Evolution and Revolution as Organizations Grow. It is a model of how organizations develop. Basically, it shows that long stages of growth, or evolution, are interrupted by periods of turbulence, or revolution as a company adjusts to market pressures and the company’s growing size.

Approach for Stages of Evolution

During stages of evolution, business goes smoothly and market environments are healthy; profits come relatively easy. Generally, adopting a safety culture would look like a policy shift. To employees, the decision would look like a proactive investment in their well-being.  Characteristics of a change during evolution:

  • Usually starts with senior management
  • Employees see it as a policy shift
  • Focuses on goals like trust, innovation, or fairness

Approach for Stages of Revolution

Stages of revolution could also be called crisis situations. They can be a reaction to tougher markets- like a recession, or from internal pressures- like an unexpected spike in employee turnover. During a crisis, company policies and practices come under review, and companies that are unable to abandon past practices and adopt organizational changes are likely to either fold or level off in growth. The critical task for management is to find a new set of organizational practices that will become the basis for the next stage of growth.

Characteristics of a change during evolution:

  • Usually involves more levels of management
  • Employees see it as a break from current policy
  • Focuses on goals like team-building, management credibility, or precautionary steps

Adopting best safety practices at any time takes planning and tenacity. But it is worth it. Keep in mind the famous line from Tom Northup, a thought leader and author in organizational management, “All organizations are perfectly designed to get the results they are now getting. If we want different results, we must change the way we do things.”

 

Want LOHAS Customers? Put Safety First.

Wednesday, June 15th, 2011

LOHAS is that upscale  market segment with high price elasticity, tremendous brand loyalty, and a deep desire to buy green goods from sustainable companies. Getting a piece of the green market just got “safer” with the June 13, 2011 launch of the Center for Safety and Health Sustainability in Chicago.

“Whatever claim an organization wants to make about being sustainable, they can’t do it unless they’re safe,” says Thomas F. Cecich, VP of Professional Affairs for the center.

The Center is a global collaborative effort from the American Industrial Hygiene Association (AIHA), the American Society of Safety Engineers (ASSE), and the U.K.-based Institution of Occupational Safety and Health (IOSH).

The Center is charged with steering how environmental health and safety professionals and systems fit in the framework of organizations’ long-term sustainability.

As an organizational stakeholder of the Global Reporting Initiative (GRI), the center has the resources and focus to establish standards across industries and public policies on a global level. Already, it is making headway in this area, and the center is looking for occupational safety and health professionals to participate in the development of GRI’s G4 Guidelines, to be published in 2013.

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.

 

Sneak Peak: Interactive Compliance Game

Friday, June 3rd, 2011

Watch for the KPA June Newsletter in your inbox on Monday. We’ve got the most pressing topics including state regulations about airbag deployments, electrical vehicle service safety, an HR quiz about sexual harassment, a comprehensive training checklist, and partnership announcements…and more.

Just for fun, here is a sneak-peak of a new article, which is actually a quick, interactive game: Spot the Violations.

 

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

Evict Your Tire Mosquitoes

Monday, May 23rd, 2011

Looking through the rain across the back lot, a pile of waste tires catches my eye. As I get closer to the pile, a buzzy little mosquito lands softly on my arm. I brush her away only to be attacked moments later by a hungry mob of blood suckers.

State Health Departments and the Environmental Protection Agency are also looking for places like this tire pile. News sources across the Midwest and Southeast report that the departments are on a mission against disease-carrying mosquitoes. As part of this effort, they are targeting mosquito breeding grounds, including dealerships and similar businesses with tire storage areas. Given the population explosion of mosquitoes this year, here are some guidelines to effectively address mosquito pools inside the tires.

Sheltered Storage: Drain tires of water and store them under a roof or well maintained waterproof enclosure to prevent water accumulation.

Exposed Storage of Waste Tires: Cut, slice, poke holes, or otherwise do what it takes to guarantee efficient drainage routes in each tire to prevent water accumulation inside the tires.

Pesticide Alternatives: If you can’t store the tires in a way to prevent water accumulation, then treat the tires with an appropriate pesticide according to manufacturer’s directions. Repeat as necessary.

Reminder: tires must be stored individually or stacked so each tire is accessible for spraying.

Maintain a written record of tire treatments that includes:

  • Name of the business
  • Date of spraying
  • Type of spray used
  • Person doing the spraying