Archive for May, 2011

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

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, 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.

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.


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:

Who Are You Really Hiring?

Tuesday, May 17th, 2011

If you aren’t doing background checks and drug screens before you hire then you really don’t know who you are hiring.  KPA has found that over 30% of applicants we process through our HR system do not provide complete or accurate information on their application. To make a good hiring decision and to protect yourself in the event of a negligent hiring lawsuit a background check and drug test are a must. I’ll never forget having to testify against a client when I worked for one of the largest background companies in the US. The plaintiff’s attorney asked me if the client could have seen a history of substance abuse and traffic accidents if they had just been willing to spend $60 for a background check. I had to answer yes, the client had access and in fact had ordered background checks and drug tests in the past. Unfortunately a supervisor at the client company shortcut the process and put a person to work without the required background check. The new employee then promptly got drunk on the job and ran a company truck into the back of a car. The HR manager was not aware that the process had not been followed until after the accident had happened.  The settlement reached with the injured parties was over a million dollars.  Lessons learned?

1) Standardize the process for obtaining and reviewing background checks and drug tests.  If possible use software that will automate and force compliance to company policy for not just background checking but for the complete hiring process.

2) Don’t be penny wise and pound foolish.  A background check and drug testing will cost in the range of $60 to $75 dollars if you use a third party. A very small investment to make sure you know exactly who you are hiring.

3) Use a third party provider (they have  expertise, and access to data you won’t have ) but select with care.  Understand how they obtain their data. Make sure they provide compliance assistance as there are a  number of regulations at the state and federal level that govern the use of drug testing and background checks in hiring.

4) Never establish a policy that states “we don’t hire anyone with a criminal record”.  In many states this would be considered discrimination.  Each background check must be reviewed against the actual job and factors such as time since the criminal act, age at the time of the act, efforts at rehibiliationa and the serious of the crime must be considered.  Employers can determine that it is not in their best interest to hire a person with a criminal record but must show that the decision was made fairly and without discrimination.  Providing a ranking using specific criteria is where  third party provider can really add value.
For more information on background checking go to  or

Join the conversation: Do you always obtain a background check and drug test on a new hire?

Expensing prescription safety glasses: how high is the bar on safety at your dealership?

Thursday, May 12th, 2011

“If I have to choose, I’d rather see.” An auto technician explains why he wears prescription glasses instead of safety glasses while working on cars. “And the OTG glasses/ glasses combo doesn’t fit right. It’s too heavy and gets in my way.”  Considering that 126 million Americans wear eyeglasses, this is a common workplace dilemma that service managers deal with every day.

Recently, I was on a site inspection for a client in California. The service center was spotless; the only noticeable safety concern was that one of the six technicians was wearing prescription glasses instead of safety glasses. Honestly, at this point, I was impressed. Then, during the safety meeting, management raised the bar even further. The GM gave the go-ahead to have a pair of prescription safety glasses expensed to the company for the technician. “It is a lot cheaper to buy the glasses than to deal with an employee injury,” the GM explained.

It’s true. With an understanding that safety is a long-term investment, this is a very good decision on many levels. It will improve the employee’s value contribution and loyalty. It sends a clear message that safety is important, and systemic decisions like this one have already paid off for the company- they are growing while their competition is struggling.

With an eye on corporate responsibility, many companies promise that they take care of employees. Not surprisingly, there are different points of view on what that promise looks like. For this client, it looks like a genuine concern for employee well-being. What does the promise look like at your company?

Finalized Form I-9 Rules Effective May 16, 2011

Wednesday, May 11th, 2011

Effective May 16, 2011, employers must follow the newly finalized Form I-9 rule  (the rule was orginally published back in 2009). Here’s what that really means…

Don’t forget that  the final rules prohibits employers from accepting expired documents; revises the list of acceptable documents by removing outdated documents and making technical amendments; and adds documentation applicable to certain citizens of the Federated States of Micronesia and the Republic of the Marshall Islands.
The list of acceptable documents that employees may present to verify their identity and employment authorization is divided into “List A” documents, which show identity and employment authorization; “List B” documents, which show identity only; and “List C” documents, which show employment authorization only. Employers may continue to use the current version of the Form I-9 (Rev. 08/07/2009) or the previous version (Rev. 02/02/2009).  The U.S . Citizen and Immigration Service ( USCIS)  Handbook for Employers, Instructions for Completing the Form I-9 (M-274), was updated on Jan. 5, 2011.

Add Assessment Testing For Better Hiring Results

Tuesday, May 10th, 2011

As employers start hiring again two question we are frequently being asked from our HotlinkHR clients is “how can I make sure I hire person who really fits in here, we can’t afford a bad hire?” and “we’ve got the basic hiring process down but want to take it up a notch, what more can we do?”.   The answer to both questions is to add assessment testing to your hiring process.  Using assessment testing will help you understanding a person’s temperament and communication style which in turn will allow you to obtain better information during interviews, assess “culture fit” and provide insights into how the candidate will work with the  current  team.   Here’s a quick overview of the benefits of adding assessment test to your hiring process.

OSHA Cites Parker Hannifin $487,700. Fits Trend of Repeat Violations Across Multiple Locations

Wednesday, May 4th, 2011

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

Who Needs DOT HazMat Training? It’s More Employees Than You’d Think!

Wednesday, May 4th, 2011

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

Join the conversation:   How are you providing required training in your dealership.