Author Archive

Eric Schmitz

Posts by Eric Schmitz:

Protect Yourself and Your Employees with Respiratory Protection

Monday, June 23rd, 2014

records

OSHA has instilled a variety of requirements for shops that have employees who wear respirators. This applies to any facility that conducts any spray coating operations including painting, priming, or rustproofing. (more…)

Is Your Dealership Exempt from Keeping an OSHA 300 Log?

Monday, June 16th, 2014

records

Many businesses, including dealerships, are currently exempt from keeping an OSHA 300 Log, depending on which SIC code their accounting department uses. All business activities that generate revenue are assigned a SIC code, based on the activity that generates the most revenue. Applicable dealership Exempt OSHA 300 Log SIC codes include New and Used Car Dealers (SIC Code 5511), Used Car Dealers (SIC Code 5521), and Motorcycle Dealers (SIC Code 5571). (more…)

December Tip of the Month: Don’t Let Them Rig Your Lifts

Monday, December 3rd, 2012

Overriding lift safety controls can be crushing. Never allow technicians to disable lift safety controls by using bungees or other devices to block them open. An OSHA local emphasis program for automotive lifts explains why:

Automotive service and repair work in the automotive industry exposes employees to crushing hazards with the use of automotive lifts. These hazards can be effectively controlled through proper maintenance of the automotive lifts and effective training for the employees on inspection and use of the automotive lifts. According to the Consumer Product Safety Commission, a total of 15,000 people were treated in hospitals for automotive lift, jack, or jack stand injuries during 2003.

While focusing on lift safety, watch for these five common hazards:

  • Unapproved hoist accessories
  • Missing or damaged contact pads
  • Vertical catch on above-ground hoists
  • Lack of training documentation
  • Lost owner’s manuals

Read the full article, Automatic Lift Review: Five Common Hazards that Bring Big OSHA Fines in KPA’s newsletter.

Complaint Results in $58,000.00 Fines for Pennsylvania Company

Monday, November 5th, 2012

Vortex Recycling’s is a small business, with 20 employees at a Pennsylvania facility. Recently, OSHA inspected the plant in response to a complaint. During the visit, the compliance officer found 27 violations, including one repeat violation for failure to remove a defective or unsafe powered industrial truck. The citation carries a $5600.00 fine, and stems from similar violation in 2008.

The company was cited for 25 serious violations, including:
•    Fall hazards
•    Electrical hazards
•    Struck-by hazards
•    Using equipment that is improperly installed, identified or located
•    Improperly maintaining emergency eyewash stations, and shower facilities
•    Improper portable fire extinguishers
•    Unguarded machinery
•    A lack of proper housekeeping procedures for areas around plant equipment
•    Failing to develop programs for energy control, hearing conservation, permit-required confined spaces and hazard communication.

A serious violation occurs when there is substantial probability that death or serious physical harm could result from a hazard about which the employer knows or should have known.

Employers are responsible for ensuring safe workplaces. If you think that some of these citations could be found at your dealership, you should discuss your concerns with your KPA safety engineer and address the situation immediately.

Electronic Hazardous Waste Manifests

Wednesday, October 17th, 2012

The days of 6 paper copies of a Hazardous Waste Manifest may finally be drawing to a close.  Earlier this month President Obama signed Senate Bill S.710; The Hazardous Waste Electronic Manifest Establishment Act.  This regulation amends the Solid Waste Disposal Act requiring the federal government to implement an optional electronic submission system within 3 years.  This optional system must be made available to any person currently required to submit paper manifests.

There is little in the regulation that defines the specifics of how this might be accomplished just a lot of information on how fees would be collected to pay for the system, and how they must promulgate additional regulations to carry out the implementation within the next year.  Overall the new system must be established “Not later than 3 years after the date of enactment”.   I guess that means that we could see the system sooner than the 3 year timetable.

From KPA’s perspective this regulation is long overdue.  As we continue to shift all of our programs online this is the first step towards eliminating all of those paper shipping receipts our client’s receive.  Ultimately, without making any specific promises, this regulation could pave the way for KPA to implement an online “Yellow Box”.

 

A Few Things You Should Know About OSHA’s Pending I2P2 Requirements

Friday, January 20th, 2012

This month OSHA published a whitepaper on Injury and Illness Prevention Programs (I2P2).  Leading up to this publication, there has been a lot of regulatory activity around I2P2. Shortly after proposing a federal standard for I2P2 in 2010, OSHA held a series of stakeholder meetings on the subject.  In this newly released whitepaper, OSHA makes clear that they see overwhelming value in moving forward.  The paper discusses the needs and benefits associated with a well-run program while downplaying the cost to business.

Questions raised by the whitepaper

What will the final regulation look like?  Who will it apply to?  And when will we see the first draft?  There are some preliminary indications in the white paper as to which industries the new regulation will affect, but the timeline for the new guideline is still up in the air. Additionally, there is a precedent for political pressures to get involved with crafting guidelines. In this case, it means that the federal standard will be based on a combination of state programs, the ANSI Z10 standard, and the OHSAS 18001 standard.  References in the whitepaper indicate that the regulation will require employers to abide by plans with some form of “management leadership, worker participation, hazard identification and assessment, hazard prevention and control, education and training, and program evaluation and improvement.”  The tone of the whitepaper indicates that OSHA sees benefits for all sizes of businesses but may lean towards reduced regulation for business under a certain threshold of employees (less than 10 or 15).

Guidelines for an I2P2 Program

Based on the whitepaper and influencers in the legislative process, programs are likely to be evaluated on the following criteria:

  1. Does management participate and encourage involvement in the safety systems and processes in your workplace?  This involvement is the key to letting your employees know that you care and that safety is an important part of everyone’s job.  There’s no better way to build a strong safety culture than to lead by example.
  2. Do your workers participate in the safety program?  This includes participation in safety committee meetings, gathering and acting on employee suggestions, or as part of your hazard identification process.  Remember that employees are more likely to know about the hazards they face than management.
  3. Do you have a system in place to identify hazards in your workplace?  Once identified, is there a process in place to ensure timely correction?  Identifying and correcting hazards not only eliminates risk of injury, but sends an important message to your employees that you value their safety.
  4. Do you proactively evaluate your employees work practices and new processes to prevent and control new hazards?  This is where it’s good to look at industry experts and pool resources among many similar businesses to identify trends and new hazards before they occur.
  5. Do you conduct regular health and safety training for your employees?  Training can be specific to a particular task or general in nature – either way taking time out for safety training sends the message that your business values safety over speediness.
  6. Finally do you measure the effectiveness of your program and seek ways to improve it?  Can you measure your facility against your peers or departments against each other?  A good software tool will make these metrics easier to manage and simple accident investigations and evaluations will give you insight into where to improve the process.

The Point

If you’re a KPA Environment & Safety Pro client, then you already have the foundations to comply with the pending I2P2 requirements. Our programs include safety committees, incident tracking, and written programs based on industry best practices. Currently, these programs meet proposed I2P2 regulation requirements.  If things change in the legislative process, KPA will modify our programs to ensure compliance with any new regulations.

 

Additional information on OSHA’s I2P2 initiative and a copy of the whitepaper are available at:  http://www.osha.gov/dsg/topics/safetyhealth/

 

What do you think? Have you been watching these developments as OSHA crafts new regulations? Are you ready if it goes into place in 2012?

The Secret to Getting Ahead of Corporate Responsibility

Friday, October 28th, 2011

Corporate Responsibility used to refer to a few fortune 500 companies, and their efforts to not seem well, “corporatey.” The idea was that companies should care about the environment and their employees as much as their profits (the buzzword for this was triple bottom line). During the recession as profits grew slim, the concept evolved. It is still evolving, but in ways that make it easier for family-owned businesses like dealerships to shine.

The voluntary Global Reporting Initiative is picking-up steam, and most OEMs are already making tracks toward public performance reporting on a number of indicators. It is a matter of time before their affiliated dealerships and repair centers are also affected. This article from EHStoday discusses the direction things are headed in more detail, but here are a few areas of interest that will position your dealership favorably as public reporting gains momentum.

  1. Make sure your facility is up to code.
    Document facility audits, inspections, along with injury and illness rates. Chances are, facility inspections will become more standardized across regions, but the good news is that if you’re already documenting and keeping up with compliance in your area, then your dealership is ready to ride this wave.
  2. Make sure your employment practices are up to code
    For GRI, there are a number of standards around rates of new employee hires and employee turnover by age group, gender and region, return-to-work and retention rates after parental leave by gender, and the ratio of basic salary and remuneration of women and men by employee category and by significant locations of operations. Basically, this means that your HR team needs to document that employment practices are by the books, and keep accurate records, especially around these employment activities.
  3. Keep sponsoring the little league team.
    Small businesses have an advantage in GRI reporting because they rely on a local clientele. Already, most dealerships have learned to reach out and support a number of local community efforts, and they enjoy a return on investment from good publicity, name recognition, and influence that come from these activities.

While businesses in general are moving toward more transparency, it is important to remember that these efforts are not expected to come at the expense of autonomy or profits. A lot is going on right now around implementing public reporting in a way that actually makes businesses more competitive, and ultimately will cut-down on the number of reports and regulatory agencies that companies will have to report to. In the short-term, you’ll be managing a better run business. In the long-term, you’ll be preparing your business for days when public reporting is a by-word for “good-business.”

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 http://www.kpaonline.com/ehs/dot.html

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

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?

OSHA considering I2P2 – Injury and Illness prevention Program

Friday, June 4th, 2010

OSHA is conducting stakeholder meetings to draft a proposed rule around a federal Injury and Illness prevention Program.  Based on recent comments by OSHA chief Dr. David Michaels the department is looking to encourage businesses to proactively identify and correct hazards.  OSHA will be conducting a series of stake holder meetings in June to solicit input on a draft rule.  They have published some information at http://www.dol.gov/federalregister/HtmlDisplay.aspx?DocId=23834&AgencyId=17.

This is not the first time that OSHA has gone down this path, the most recent attempt to create a Federal Injury and Illness Prevention Standard was tabled in August of 2002.  However with the current administration it appears more likely that the standard will move forward this time.

How it will affect KPA clients remains to be seen, but with KPA’s current program modeled after the California IIPP rules; it is likely that a current KPA client will exceed compliance with few program adjustments. California has required business with more than 10 employees to have an Injury and Illness Prevention Program since 1991.