Archive for August, 2011

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.

What’s the Plan?

Friday, August 26th, 2011

This year has been marked by earthquakes, fires, tornadoes, floods, and now hurricanes. As a result, contingency plans are saving workers’ lives at businesses across the country. Contingency plans only work when they are in place and fully understood by staff before something happens.

Review your dealership’s plans, and check that they cover these subjects, along with some important details each plan should include.

Plans Should Cover

  • Release or threatened release of hazardous materials
  • Severe weather
  • Natural disasters
  • Fire

All Contingency Plans Should Include

  • Emergency notification procedures for oversight agencies and local emergency personnel
  • Evacuation procedures and maps
  • Computerized facility maps as required by oversight agencies. Includes locations of fire extinguishers, first aid kits, MSDS, eyewash, electrical shut-off, tank storage locations, evacuation assembly points, et cetera
  • Safety training for release or threatened release of a hazardous material

Worth a Read

Friday, August 19th, 2011

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

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.


 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.
 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.

Start Writing Effective Job Descriptions

Wednesday, August 3rd, 2011

Compliance Tip of the MonthA well written job description is a key component in all phases of the employment lifecycle.  Having a job description for each position and providing the job description to applicants and employees will assist you in:
1.    Recruitment, Interviewing and Hiring
2.    Orientation and Training
3.    Performance Management
4.    Disciplinary Action Support
5.    Legal Compliance and Lawsuit Defense

This template is designed specifically for human resources professionals at dealerships to help you write effective job descriptions. It is a free download, and we recommend using it as often as needed. It is available here:

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.”