What is the best way to avoid fines from an inspection? Be Prepared! Professional athletes practice to ensure on game-day they will be prepared. Having a surprise, simulated inspection by an Environment & Safety professional will give your dealership employees the practice they need to be prepared when an inspector comes to your facility.
Learn more here: http://www.kpaonline.com/thefifthvisit
Under the OSHA Injury and Illness Recordkeeping and Reporting Requirements, most employers are required to record work-related injuries and illnesses using the OSHA 300 Logs. However, many businesses, including car dealerships, are currently exempt from most of the requirements, dependent on store’s primary Standard Industrial Classification (SIC) code.
The growing number of electric vehicles (EVs) increases the risk of electric shop in maintenance facilities. Be sure to provide your staff with the appropriate rubber insulating gloves.
The high-voltage systems on electric vehicles present a serious shock risk. In addition to training your staff in safety procedures, make sure they have the appropriate Personal Protective Equipment (PPE), including rubber insulating gloves. (See OSHA standard CFR 1910.137.)
What are they and how are they rated?
Rubber insulating gloves are designed to protect employees from electric current and are rated by the amount of voltage they are effective to protect employees:
Class Maximum AC/DC Voltage
00 500
0 1,000
1 7,500
2 17,000
3 26,500
4 36,000
Which gloves are right for my service center?
Most manufacturers recommend rubber insulating gloves rated, at minimum, Class 0, but be sure to check your OEM’s guidance. Also, fit each employee with the right size of gloves.
What sort of maintenance is required?
OSHA requires very specific measures for proper glove care and maintenance. I can’t cover all the details in this post, but here are a few tips:
Be sure to use the manufacturer’s guidance on proper safety processes. And as always, if you’re a KPA client, consult with your safety engineer about the training, safety processes and PPE needed for these vehicles. Or feel free to contact us regarding our environment and safety compliance services at (866) 356-1735.
According to OSHA, unsafe grinders are one of their most cited offenses. There are several common safety issues with grinders. This month, we’d like to focus your attention on the tongue guard – a small protective shield located at the top of the grinding wheel.
Each tongue guard should be positioned 1/4 inch from the wheel and the adjustment should be checked frequently. During safety inspections, we frequently find that tongue guards are missing or not adjusted properly. (See photo at right.)
The purpose of the tongue guard is to make sure that, if an object gets sucked up into the grinder, it doesn’t come back out at the top and hurt the operator. Serious injuries can occur if the guard is absent, or poorly installed.
Bench grinder with missing tongue guard.
KPA Resources – How to make sure your grinders are safe:
*This poster is typical of materials provided to KPA clients. If you’re not a client, you can request more info here.
Auto dealers find the disposal of undeployed airbags to be a significant challenge, because they can be considered “reactive hazardous waste” if they are not recycled. For many years, dealers have opted to deploy the airbags and then send them to disposal sites like traditional landfills or incinerators. However, the Federal Environmental Protection Agency (EPA) recently cited a dealer for doing so.
So what’s the best approach for disposing of undeployed airbags? Till now, dealers’ options have included:
Since the EPA recently cited a dealer for “treatment of hazardous waste without a permit” for deploying airbags, disposal of such items has become more problematic. Every dealer needs to weigh a variety of pros and cons, such as long-term liabilities and shipping costs.
Bottom line: If you’re not sure about the best approach for disposing undeployed airbags in your state, or if you’re using option 3 above, it’s time to reconsider your approach.
KPA Environment & Safety clients can contact their engineer for more information. Or, you can review the airbag page on our website.
It’s no secret that OSHA has aggressively pursued enforcement under President Obama’s Administration. With the closure of fiscal year 2011, OSHA published its semi-annual regulatory agenda, which shows the following trends regarding OSHA’s enforcement initiatives:
When it comes to enforcement, employers can expect to see a continued increase in OSHA activity for 2012. Despite the 100% increase in fine cost per violation, OSHA director Dr. David Michaels recently stated that the higher penalties are still too low when compared to other regulatory agencies.
KPA’s records show that the agency is following through on its intentions. We have seen a sharp increase in frequency of OSHA visits to clients in February, especially in New England states.
Changing Priorities at OSHA
In a January 12, 2012 interview with Bloomberg, OSHA director Dr. David Michaels said that the agency plans to issue rules in 2012 updating regulations concerning hazard communication, confined spaces, and recordkeeping (OSHA 300 Logs). For example the recordkeeping change may include a requirement for auto dealers to maintain OSHA 300 logs as well as vastly increase accident reporting requirements. While it is doubtful that all of these rules would pass into law, this activity indicates a shift in focus from previous hot issues. The agency is also setting sites on modifying Permissible Exposure Limits (PELs) and on Jan. 6, 2012, OSHA sent a letter to the Small Business Administration (SBA), informing the SBA of its intention to convene a Small Business Advocacy Review panel for its I2P2 rule. Panels are convened for all rules expected to have a significant impact on a substantial number of U.S. small businesses and are typically viewed as one of the first steps in the process of implementing a large rulemaking.
While OSHA’s overall budget remains about the same as last year, there are some significant shifting of funds within the agency. The FY 2013 proposed budget includes a 23.5% increase, including 37 new employees, for the agency’s 21 whistleblower protection programs. In other words, the current administration is encouraging workers to come forward with whistleblower complaints and the agency is targeting employers who retaliate against workers who file OSHA complaints. This reinforces the value of effective Safety Committees which promote communication of safety issues between employees and management.
Lower Priorities
In 2013, OSHA will no longer offer its Corporate and Merit Voluntary Protection Program (VPP) to new sites. The VPP star program will also decrease in services.
While OSHA continues to work on potential rulemaking on the musculoskeletal disorder recordkeeping (MDS), the proposed rule has been reclassified as a long-term action with no timetable for completing the rulemaking process. This means that the proposed separate 300 logs for musculoskeletal disorders may not be a requirement for a while, although back cases will continue to be recorded as either injuries or illnesses depending on the condition resulted from an event or exposure.
Summary
To sum it up, funds for whistleblower programs are going up, enforcement funding will stay the same, but there is a projected increase in inspection frequency. Some compliance assistance funding will be cut.
Dealerships and service centers should continue to review their ongoing assessments of workplace hazards and ensure that their employees are adequately trained on the numerous regulatory requirements enforced by OSHA. Compliance is still the best defense.
As the dust settles around OSHA’s final rule on Hazard Communication, it is easy to see how this is going to affect safety programs at small businesses in the automotive industry. This final rule will become effective, in part, on June 26, 2012, with a built-in transition period and a fully effective date of June 1, 2016.
The standard changes OSHA’s current hazard communication requirements to conform to the Globally Harmonized System of Classification and Labeling of Chemicals (GHS) and international trade laws. There are three parts of OSHA’s Hazard Communication Requirement that will be affected: system-labels, SDSs, and employee training.
System-labels
Part of the new requirement mandates that labels will contain a signal word, pictogram, hazard statement and precautionary statement for each hazard class and category. Labels will also have to disclose voluntary threshold limit values (TLVs) established by the American Conference of Governmental Industrial Hygienists (ACGIH). They will also disclose carcinogen status from nationally and internationally recognized lists of carcinogens.
Material Safety Data Sheets (MSDS) becomes Safety Data Sheets (SDS)
Under the new rule, hazards will be communicated through a set of 16 hazard categories, including a new category of hazards – “Hazards Not Otherwise Classified” and labels will also include combustible dust in the definition of “hazardous chemical.”
Employee Training
Employee training will have to be updated so that employees are knowledgeable about the new system labeling requirements and new hazard classifications. The training requirement will go into effect December of 2013.
The final standard can be found on OSHA’s website. Compliance guidance on the new standard, including Highlights and FAQ, OSHA Fact Sheet and OSHA Quick Cards, can be found on the agency’s website as well.
What’s your take on the changes to the hazard communication standard? Is your safety program ready for this new rule? Leave a comment and share your thoughts with the KPA blog community.
Un-deployed airbags and seatbelt pre-tensioners can be recycled through KPA’s new recovery program. We help small businesses with transportation logistics, and ensure DOT compliant transportation of these devices on their journey to the recycling facility where 95% of materials are recovered. Find out more at http://www.kpaonline.com/what-we-do/ehs/airbagrecycling.html
OSHA just announced that updated charts and manuals for servicing multi-piece and single-piece rim wheels are available, and that updated manuals will soon be distributed to the regulated community.
In updating this information, OSHA decided not to print large posters with the updated information, but to provide an 8.5 inch by 11 inch printed manuals containing this information that employers could use in the shop as an alternative to displaying the large posters. The manual would be more portable and accessible than a large poster, which employers typically mounted on a wall.
To reduce the distribution burden, OSHA will print and mail the manuals, but not the posters. The posters, as well as the manuals, will be available in electronic files (PDF) on the OSHA Web site at http://www.osha.gov/publications (and type “tire chart” in the search field).
OSHA also is revising the content of its two existing charts. The “Multi-piece Rim Matching Chart” will provide an updated list of multi-piece rim wheel components, both current and obsolete, while the “Demounting and Mounting Procedures for Truck/Bus Tires” chart will consist of two separate charts entitled “Demounting and Mounting Procedures for Tubeless Truck and Bus Tires” and “Demounting and Mounting Procedures for Tube-Type Truck and Bus Tires.”
Consistent with these revisions, OSHA is amending the definitions of “charts” in paragraph (b) of the standard to refer to the new Department of Labor charts (i.e., manuals or posters), or to any other information or poster that provides at least the same instructions, safety precautions, and other information contained in OSHA’s charts, and that is applicable to the types of rim wheels the employer is servicing.
The deadline for completing a Spill Prevention , Control, and Countermeasure (SPCC) plan for your facility has been extended six times since 2002, but the latest deadline on November 10, 2011 has passed without an extension. The New SPCC regulations are now law.
The SPCC requirements are intended to help prevent discharge of oil into navigable waters or adjoining shorelines. If your facility has the potential storage capacity of 1320 gallons or more of petroleum products, you must act, potentially even if you already have a SPCC plan in place.
To find out more about EPA’s SPCC requirements you can either visit the EPA’s Emergency Management information pages, or contact KPA. We can prepare, amend, and help you implement a SPCC plan that keeps your business in compliance with these requirements.
