OSHA’s Housekeeping Regulation Explained (Housekeeping Part 2)

Thursday, December 6th, 2012

At a glance the OSHA regulatory standard 29 CFR 1910.22 states that all places of employment, passageways, storerooms, and service room shall be kept clean and sanitary.  So this regulation will cover every square inch of your facility.   Everything from your service department to your janitor closets and bathrooms.  It also mentions that to help facilitate cleaning all protruding nails, splinters, holes, and loose boards need to be fixed beforehand.

Moving past the definition, the OSHA regulation specifically identifies toilet facilities, waste disposal, wet processes, water supply, change rooms, vermin control, and food supply. OSHA can use the Housekeeping regulation as a catch all for any unsanitary condition. It also applies to items that you can’t see like odors.

How Much Can it Cost if OSHA Inspectors Finds Housekeeping Issues?

  • $1800 depending on situation (general duty clause)
  • $2700 general housekeeping initial penalty

Top General Housekeeping Issues:

  • Waste disposal
  • Clean and Dry Floors
  • Vermin control
  • Water supply (potable and non-potable water)
  • Toilet facilities
  • Food handling, storage, preparation and consumption

Waste Disposal

This includes detached buildings, forgotten corners of storage areas, detail areas, and body shops.

Ask the right questions: Is the trash getting taken out daily? Are there enough trash cans? Are the trash cans conveniently located so that disposing of an item doesn’t require slowing down work?

What is an acceptable trash can? Carefully inspect any container that you would consider using for a waste receptacle. Consider the following:

  • Waste receptacles cannot leak
  • It should have a tight fitting cover unless it can be maintained in a sanitary condition without a cover
  • Trash should be removed as often as possible to maintain a sanitary condition

Vermin Control, Toilet Facilities

It is hard to attract and keep top performing employees with dirty toilets and vermin in working environments. Working conditions like these tend to trigger OSHA calls, and customers  tend to spread the word about dirty bathrooms more often than they would talk about clean showrooms. If these are issues at your facility, they need to be addressed and you should consider hiring a subcontractor to fix the problem immediately and follow up on a regular schedule.

Clean and Dry Floors
Even the floor in the detail area needs be maintained. A “Wet Process” involves a location where liquid is used as part of the working process, and workers should be provided mats and the area should have proper drainage.

What about weather conditions?

According to an OSHA interpretation of the standard, rain and snow are not considered part of a wet process, and general housekeeping rules apply to weather related slip hazards. As long as a hazard exists, employees and customers should be protected from the hazard, even if it is a slip hazard from rain or snow.

Water Supply
Potable Water

  • Drinking water must be provided (at all times, especially in hot and dry weather conditions)
  • Water fountains must be clean and sanitary
    • If providing water bottles instead of drinking fountains is more feasible, it is technically acceptable.
    • Potable water in bathrooms must be provided for hand washing

Non-potable water

  • Non-potable water must be clearly labeled

Food and Beverages

  • No employee is allowed to consume or store food or beverages in any area exposed to a toxic material- this means the service area, paint room, and detail areas of the dealership.
  • No eating or storage of food in the bathroom
  • Any trash can used for disposal of food must be emptied daily.


Whose responsibility is it?

  • Ultimately, it is the employer’s responsibility to provide a clean and safe work environment.


Housekeeping: What It Means, and Why It Matters (Housekeeping Part 1)

2012-10-11 10.03 Yuck! Housekeeping Regulations for Dealers that You Just Have to Know [Webinar]

Spring Cleaning for Three Trouble Areas in the Service Bay

OSHA Fines Auto Parts and Used Car Dealer $49,000 for Safety and Health Violations: Conclusion

OSHA Top 10 Citations for Dealerships and Service Centers in 2012

Tuesday, November 27th, 2012

Managers need fast, straightforward answers to their compliance concerns. To meet this need, KPA researched the Top 10 OSHA Citations for Dealerships and Service Centers by combining OSHA’s annual Most Frequently Cited Regulations for Dealerships, and OSHA’s annual Most Frequently Cited Regulations for Repair Shops. We pin-pointed specific machinery and processes at facilities that were frequently cited, and developed the Top 10 OSHA Citations for Dealerships and Service Centers.
The List
1. Hazard Communication
2. Respiratory Protection
3. Unguarded Machinery (Parts Grinder)
4. Electrical Safety Requirements
5. Powered Industrial Trucks
6. Exit Routes and Emergency Action Plans
7. Portable Fire Extinguishers
8. Spray Finishing Using Flammable Liquids (especially at collision centers)
9. General Duty Clause
10. Improperly Maintained Emergency Eyewash Stations

Learn More
KPA will host a free educational webinar on November 29th about OSHA’s Top 10 Most Cited Violations by Dealers. Register now at to attend or to receive a link to the recorded webinar.

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.

Dealer Fined for Fluorescent Tube Disposall – Are You Properly Managing Your Universal Wastes?

Tuesday, May 8th, 2012

The Situation
Recently, a dealership was heavily fined for improper disposal of fluorescent lamps. With the best of intentions, a porter came in on the weekend and took 150 of the dealership’s used fluorescent lamps to a public roundup at a community college. He was not aware that regulations in his area prohibited small and large quantity generators (a common classification for dealerships) from taking universal waste to public events, which are intended for households only. He was greeted by a representative from the county’s hazardous waste division and given a citation on the spot for illegal disposal of hazardous waste. He was then informed that the agency would come to the dealership to perform a full hazardous waste compliance inspection. Regardless of the dealership’s good intentions for disposal, ultimately they were heavily fined for violating regulations.

Lessons Learned

Universal wastes commonly found at dealerships include fluorescent and HID light bulbs, electronic devices, mercury containing equipment, non-empty aerosol cans, and small alkaline batteries. These items are regulated because they contain mercury, lead, cadmium, copper and other substances that are hazardous to human health and the environment.While most dealerships are recycling these wastes, they are unclear about the additional labeling, storage, disposal, and recordkeeping requirements that can expose the dealership to liability.

State and local laws vary between jurisdictions, but a general rule of thumb is to maintain accurate labeling practices in correct storage containers. Labels should include descriptions of the waste products as well as generation dates. Most state regulations don’t permit wastes to accumulate for more than a year, so don’t let stuff pile up in the back room. Remember that containers need to be compatible with their contents. Keep accurate records. Make sure that your subcontractors are accurate in their reporting, and that your records are also up to date.


Get more details about this topic in the May KPA Newsletter on Monday (click here to subscribe).


OSHA Cites Two Florida Companies for Gas Station Explosion

Wednesday, February 29th, 2012

On August 19, 2011, a massive fire broke out at a BP gas station on State Route 16 just outside of Saint Augustine, Florida. A half mile radius was evacuated around the station, the highway was closed, and over 4000 homes and businesses lost power as three fire and rescue units fought to contain the blaze. An employee was seriously injured in the incident.

Following a six month investigation, OSHA has cited Coomes Oil & Supply Inc., doing business as the 5th Wheel BP gas station in St. Augustine, and Florida Rock & Tank Lines Inc for serious and willful violations.

According to an OSHA news release, the incident happened when a Florida Rock & Tank Lines delivery driver was refilling an above-ground gasoline storage tank that had a broken gauge. The tank overflowed, and the combination of vapors and heat from the running delivery truck caused an explosion. OSHA’s inspection found that the gas station and Florida Rock & Tank Lines decided to refill the storage tank even though the liquid level gauging system was inoperable.

OSHA has proposed a $70,000 fine against Florida Rock & Tank Lines along with a citation for one willful violation. This violation is for “failing to provide the delivery driver to determine if the storage tank had enough capacity for additional gasoline.”

A $7,000 fine has been proposed for Coomes for a “serious violation” because there was substantial probability that death or serious physical harm could result from a hazard about which the employer knew or should have known.

A few things about this incident caught my attention. First, I think it is interesting that Florida Rock and Tank Lines was issued the maximum fine for the willful violation, and Cooms was issued the minimum fine carried by its violation.

The second part of the incident that caught my attention is that the gas station is one of the last in the country to use above ground fuel tanks. I wouldn’t be surprised if this incident triggers targeted inspections for above ground fuel tanks at automotive businesses. If you have above ground storage tanks at your facility, make sure that monthly inspections are conducted as required by SPCC regulations, and that all safety features are in good working condition.

General Duty Clause in Plain English

Monday, November 14th, 2011

The General Duty Clause explained for dealerships and service centers by an OSHA enforcement expert. This video covers how dealerships get cited for General Duty Clause violations, and how to identify and address issues before they become citations. General Duty Clause is one of the top OSHA violations for 2011.

Our engineers have found some rather unusual instances of general duty clause issues at dealerships. How does you facility identify and address general duty clause issues?

What is the OSHA Top Ten for Dealerships in FY 2011?

Wednesday, October 26th, 2011

What is OSHA citing dealerships for most frequently these days? We compared our notes from KPA inspections at dealerships and service centers across the country with the most recent numbers released by OSHA for the transportation industry. We used this information to put together the Top 10 most cited violations by dealers to help your dealership get prepared for 2012.

Get the facts by signing up for tomorrow’s webinar presented by Eric Schmitz, Vice President of Products and Business Development at KPA.

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:

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