April Tip of the Month: Spring Cleaning for Three Trouble Areas in the Service Bay

Sunday, April 1st, 2012

Compliance Tip of the MonthKeeping a facility clean and organized ensures better compliance with environment and safety regulations. It is also connected to improved productivity and employee morale. Take a moment to see if these three common trouble spots are being addressed at your facility. They can actually indicate the overall performance of your safety program, and are usually targeted during regulatory inspections.

1.    Food and Beverage in the Service Bay    

The service bay is filled with oils, sprays, lubricants, and other hazardous chemicals. For this reason, the service bay (and body shop, detail area, etc.) is classified as a hazardous chemicals area, where it is illegal to prepare or consume food.

All food (including bagels and snacks) should be restricted to the break room. Food storage and preparation equipment also needs to be restricted to the break room.

The law permits some beverages in hazardous work areas, but with restrictions. All drink containers must be covered, and containers should clearly indicate contents.

2.     Eyewash Stations

All stations need to have documentation of monthly inspections and maintenance, as prescribed by the manufacturer’s specifications. Stations needs to be kept clean, in proper operating condition, and accompanied by a correctly mounted sign. All stations must be easily accessible for emergency situations.

3.    Clear the Clutter

Get rid of small groups of empty compressed gas cylinders, used batteries, full roll-arounds, and similar items that tend to collect in the corners of work stations and in quieter places in the service bay. All of these can bring fines if they are not properly stored or disposed of.

These areas won’t clean themselves. Enlist the help of employees or supervisors who work in the service area to monitor and address housekeeping issues for that area. Because they are the most familiar with the area and its problems, these individuals often are the best resource for suggesting the tools or equipment to eliminate or resolve housekeeping issues.

Is your Safety Incentive Program Illegal?

Friday, March 30th, 2012


In a recent memo sent to OSHA regional administrators and whistleblower program managers, Deputy Assistant Secretary Richard Fairfax gives a general warning to businesses against tying management or supervisory bonuses to lower reported injury rates. The memo also clarifies four areas where businesses often have policies and practices that discourage reporting and could constitute unlawful discrimination against employees for reporting injuries.

Make sure that your company policy does not include any of these practices or policies.


1. Policies that take disciplinary action against employees who are injured on the job, regardless of circumstance.

2. Policies or practices that discipline employees who report an injury or illness, and the stated reason is that the employee has violated an employer rule about the time or manner for reporting injuries and illnesses. This section also applies where the employer’s reporting requirements are unreasonable, unduly burdensome, or enforced with unjustifiably harsh sanctions.

3. Policies that discipline an employee for reporting an injury, on the grounds that the injury resulted from the employee violating a company safety rule. An indication that a policy is unlawful is if the employer does not monitor for compliance with the work rule in the absence of an injury.

4. Programs that unintentionally or intentionally provide employees an incentive to not report injuries. For example, an employer might enter all employees who have not been injured in the previous year in a drawing to win a prize, or a team of employees might be awarded a bonus if no one from the team is injured over some period of time.

The full memo is posted by OSHA at this link.

Employer Safety Incentive and Disincentive Policies and Practices Memorandum

Getting Ready for a Safety Audit

Tuesday, March 6th, 2012

This article from EHSToday has some suggestions for service managers who like to be prepared before a third party safety audit. Although it is written for manufacturers, the short list of suggestions would be very practical for dealerships and service centers.

The Auditors Are Coming! The Auditors Are Coming!.

Prepare Your Business for Winter Storms

Sunday, October 2nd, 2011

Compliance Tip of the MonthYou don’t need a weather man to know this winter will come with more extreme storms. Before they hit, prepare your business to handle extreme cold and snow. Take action this fall to protect employees from injuries and illnesses, minimize damage and recover quicker following a winter storm situation. Here’s a quick checklist to help you get ready.

  1. Get familiar with NOAA National Weather Service and weather warning systems at
  2. Replenish emergency stockpiles and supplies in a safe location onsite
  3. Prepare for power outages: test the back-up emergency power generator, and back-up heating source
  4. Check condition of sandbags, shovels, road salt or ice melt
  5. Have a business emergency/continuity plan
  6. Maintain an inventory of all equipment and assets for your business in the event of structural damage


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.

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.


Compliance Tip of the Month

Friday, July 1st, 2011

Training Requirements for Dealership EmployeesTraining Requirements for Dealership Employees
The quick guide to training: who needs it, in which areas and departments, for which enforcement agencies, and how often each training requirement must be renewed. Check the list at

A Lot of Safety on Your Lot

Sunday, May 1st, 2011

Compliance Tip of the MonthInventory lots, parking lots, and holding lots make up the backbone of your business, and need to be kept safe. Here are a few basic safety checks keep your lots up to code, and keep them safe for employees and customers. First, make sure the speed limit is posted, blind spots are eliminated, and that employees are given specific test drive routes if they leave the premises with customers as part of their job. If golf carts are part of your business, safe operating rules need to be posted in the cab of each cart.

All employees need to practice safe driving. This includes using seatbelts, and eliminating the use of cell phones while behind the wheel. All paperwork needs to be current, including safe driver training records, and DMV records.

More details are available in the May 2011 newsletter article, “Lot Safety Checklist” at

What Goes In Your Dealership’s First Aid Kit

Friday, April 15th, 2011

At a moment’s notice, your first aid kit needs to be ready for safe, effective responses to emergency situations. OSHA requires that first aid supplies are available for all employees. The short list of OSHA’s required contents is here:

A few things to keep in mind:

  • It can be a liability to have too many items in your first aid kit, since you’re dispensing medicine that someone could be allergic to. It is better to have several basic first aid kits located around the facility than one large kit.
  • The kit needs to be clearly marked.
  • Make sure all employees understand that the kit is for emergencies only- not for daily use.
  • Make sure enough staff members are trained in first aid to cover an emergency situation on any shift (keep copies of certificates on file) or professional emergency responders can reach your facility within 3-4 minutes.
  • If you decide to train emergency responders at your facility and make them responsible for care, you’ll need a Bloodborne pathogen program.
  • Make sure the first aid kit is restocked after each use.


Watch this video and take a quick tour of your First Aid Kit.

Your Parts Grinder Can Pass an OSHA Inspection. Here’s How.

Monday, March 7th, 2011

OSHA recently issued five citations totaling $75,000 to the Pep Boys auto service company after a facility inspection in Hamden, CT for a “repeat violation.” The previous citation was at a different franchise location. At the center of the fines is a parts grinder.

Parts grinders, or abrasive wheel machinery, were the third most cited auto dealership violations in 2010. Parts grinders are citable violations because by nature, they involve contact between employees and equipment. Robert Kowalski, OSHA’s area director in Bridgeport, warns the chain that, “It would be to the benefit of its workers’ safety company-wide for this employer to determine if similar hazards exist at other stores and to eliminate them if they do.”

Watch this two minute video. It explains what OSHA looks for in parts grinders during an inspection, how to comply with OSHA standards, and also has safety tips for parts grinder operators.