Prevention Plans

Managing for Winter Weather at Your Dealership

Monday, October 29th, 2012

As eastern states brace for the worst of Hurricane Sandy, here are several tips to help your dealership to safely handle cold and snow in the storm’s aftermath. Take actions to protect employees from injuries and illnesses, minimize damage and recover quicker following a winter storm situation. Here’s a quick video to help you get ready.

Also, here are some helpful apps for your smartphone to help you prepare, remain connected, and stay safe during weather emergencies:


Android and iPhone

This is a great app to keep your important files safe, even if your computer is inaccessible.  If you have copies of your most important files stored in a Dropbox account, you can access them from anywhere. Essentially, Dropbox uses cloud storage. Install the program on your PC or Mac, upload files to your folder, and they are instantly available on all your other computers. And with the app, everything can be found on your mobile devices as well. Don’t have network access? Don’t worry. If you starred your important files, you can still get them on your phone.


5-0 Radio Police Scanner Lite

During a disaster, everyone hears rumors. What’s really going on? The answer might be on police band radio, which you can pick up using this free app on your phone. This isn’t talk radio; it’s an unfiltered feed from police scanners, firefighters and other emergency public-safety officers. While it shouldn’t be your only news source, it’s worth listening in.

Android users, try the free Scanner Radio app.


MotionX GPS Drive
99 cents

If you have an iPhone, MotionX GPS Drive is the cheapest and most popular way to guide you out of town on an unfamiliar route. The software even will work without a cellular signal, if you plan ahead and download and cache maps. It provides live traffic, turn-by-turn navigation, up-to-date maps and search, Facebook Places and Wikipedia integration.

For help with your local traffic and commutes, Android and iPhone users might consider theWaze app, too. This app provides free navigation and connects you to your local driving community.

American Red Cross: Shelter View

When an emergency is at hand, the American Red Cross steps in to provide shelter. That’s great as long as you know where the shelter is. American Red Cross: Shelter View shows you where to go.

Currently, this app is not available for Android, but you can still go online to search for a Red Cross shelter.

Hurricane Tracker

When a hurricane is approaching, you don’t want a storm-tracker map from three hours ago; you want the latest official maps, data and projections. This hurricane-tracking app is for serious weather junkies and people who want to be better-informed as they make decisions.

For Android, try the free Hurricane Software app.



Did we miss anything? Share your best winter safety tips with other dealerships by commenting on this post.

How to Prevent Most Injuries at Your Dealership

Wednesday, May 9th, 2012

Radiation burns from Acetylene torches, lacerations from the parts grinder,  a blast of compressed air on the eye -these are just a few reasons why the right PPE and simple safety procedures are so important at dealerships. The Occupational Safety and Health Administration reports that 3.3 million Americans suffer from serious occupational injuries every year, but at least 60 percent of these injuries can be avoided by adopting a “safety culture” that emphasizes planning and doing in the safest way possible.

Make sure that your program is based on simple, sound, and proven ideas that are in compliance with existing laws and regulations.  Ultimately, it’s good for the entire company, and results in decreased incidence of workplace injuries and illnesses, reduced costs (including significant reductions in workers’ compensation premiums) and enhances overall business operations.

OSHA Reminds Employers to Post Injury/Illness Summaries

Tuesday, April 17th, 2012

Employers who are required to keep the OSHA Form 300 Injury and Illness log must post OSHA’s Form 300A from Feb. 1 to April 30, 2012 in a common area wherever notices to workers are usually posted. The summary must list the total numbers of job-related injuries and illnesses that occurred in 2011. All establishment summaries must be certified by a company executive.

Copies of the OSHA Forms 300, 300A and 301 are available for download on the OSHA Recordkeeping Web page. See OSHA’s Recordkeeping Handbook for more information on posting requirements for OSHA’s Form 300A.

What We Can All Learn from a Hammer

Friday, January 27th, 2012

A colleague told me about an incident at one of her dealerships, where a technician hit his own knee with a hammer and filed a workman’s comp claim. In the story, the man was in a hurry to fix a rusty part on an older vehicle.  He propped the piece of metal against his leg for support, swung a hammer at the part- missed the part but did some serious damage to his kneecap.


What is your first reaction?


My first thought was that this guy must not be too bright. My reaction is a surface reaction. It lets me hear the story without really having to think about what is going on. I judged that this is one incident, with one individual who brought this on by his own thoughtless actions. This kind of thinking is a very neat way of hearing the story without having to think about it or change the way I do business.


But of course, intelligence is not the real problem in the story. The real problem is that we’ve all done something thoughtless like this when we’re in a hurry.


The root cause of this incident is not the hammer or the technician. They are only part of a larger system that is built around a set of priorities.


Looking at this accident though the eyes of an investigator, there are a number of things to consider if we want to actually prevent accidents like this from happening:


  1. The technician was so focused on meeting a deadline that he took an obvious risk. What could be done in the work environment to balance doing a job quickly with doing a job safely?
  2. Who is responsible for worker safety?Leaving worker safety up to the individual worker gets mixed results. Many workers believe whole heartedly that the customer comes first. They do whatever they can to meet difficult deadlines, often taking unnecessary risks (or compromising the quality of services rendered). Workers need to know that safety is actually the top priority- and it needs to be communicated clearly through actions and policies.
  3. Consider the process. Where is the proper tool for the job located relative to the work station? Is there a way to make it less time consuming for the worker to do his job safely?


As a safety advocate, I try to learn from every accident or near miss, and to extract useful guidance that workers and management can act on in the moment. The lessons from the this accident have little to do with the the hammer or the knee. Looking at the bigger picture, there is a lot that can be learned from any accident or near miss as long as we don’t start by assuming that what happened is some kind of anomaly.

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:


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?

Tips to Keep Your SPCC Plan Legal

Friday, December 16th, 2011

By now, most dealerships who qualify for SPCC plans have completed them, but how many of us are following up with the compliance of the SPCC regulations after the plan is in place?

Has your plan been signed by a dealership plan manager?  Are the secondary containment descriptions accurate and in place?  Is your dealership documenting monthly visual inspections?  Are your tanks due for their 5 year SPCC review?  Tank integrity testing was recently brought to my attention.  Your dealership is responsible for complete tank integrity testing for all tanks onsite.  This goes beyond the simple visual inspection.  Here is the reg:

Federal (this requirement is not in effect until October 31, 2007) Under §112.108(c)(6), for bulk storage containers the owner must “Test each aboveground container for integrity on a regular schedule, and whenever you make material repairs. The frequency of and type of testing must take into account container size and design (such as floating roof, skid mounted, elevated, or partially buried). You must combine visual inspection with another testing technique such as hydrostatic testing, radiographic testing, ultrasonic testing, acoustic emissions testing, or another system of non-destructive shell testing. You must …”

One of the testing methods described was a hydrostatic test such as the testing completed on fire extinguishers every 6 years.  This testing will require assistance from a tank testing company.

SPCC 101: What You Need to Know About SPCC Plans

Monday, October 17th, 2011

SPCC stands for Spill Prevention, Control, and Countermeasure. At this point, the SPCC is expected to become required for businesses on November 10, 2011. The SPCC rule is complicated, and has implications for many industries. This post focuses on what the rule means for dealerships and automotive service centers.

Who Needs an SPCC Plan?
The EPA requires that all facilities with total above-ground petroleum storage capacity of at least 1320 gallons stored in 55 gallon containers or greater need an SPCC plan. This is regardless of actual petroleum quantity stored on site.

What Goes in an SPCC Plan
Your plan is required to describe
•    oil handling operations
•    spill prevention practices, discharge or drainage controls
•    personnel, equipment and resources at the facility that are used to prevent oil spills from reaching navigable waters or adjoining shorelines
•    countermeasures to contain, cleanup, and mitigate the effects of an oil spill that would impact navigable waters or adjoining shorelines

How to Get an SPCC Plan
Businesses can either have a Professional  Engineer create and certify an SPCC plan for their facility, or they can self-certify (see details here). If a business chooses to self-certify, only an owner or operator of the facility can certify the plan.  If you certify the plan, ultimately you are responsible for all the information in it. That is one benefit of having a Professional Engineer look it over. When they stamp your plan, they are putting their credentials behind the plan.

How Do You Know if Your Safety Program Is Working?

Friday, October 7th, 2011

How do you measure success? You look for things that you can track and measure. These key indicators are pretty standard, and should be documented and communicated as part of your safety program:

•Workplace inspections (KPA audits and your account are excellent resources)
•Exposure assessments
•Injury, illness, and incident tracking
•Employee input
•OSHA assessment

A note about injury rates: They’re a little misleading because they are lagging indicators- they do a great job at showing performance under past circumstances and are not reliable for predicting future performance (but you still have to track injury rates for reporting to regulatory agencies- so don’t ignore them).


Get a clear picture of where your program is headed: Culture predicts outcomes.

•Track work practices and sustained behaviors that increase or reduce hazards
•The level that culture supports safety objectives and activities
For example, how fast are issues addressed in your myKPAonline account?
•Workers’ interest in safety activities and behaviors
•The value placed on workplace safety by senior leadership compared to other objectives

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


I2P2 Part 2: Getting Started and Seven Parts of the Plan

Friday, September 30th, 2011

In the first post, we discussed what an effective I2P2 plan (Illness and Injury Prevention Planning, or sometimes IIPP) does, and the business case for implementing the I2P2 plan. This post gets a little more into how to set up the planning process for success. Begin at the top of your organization, with a committee of strategic leadership members.

In this planning phase, you’ll need to:

•Document the implementation process from the beginning; I2P2 is a company policy and needs to be documented as such.
–Demonstrate commitment to protection and continual improvement of employee health and safety
–Demonstrate that employees will be encouraged to effectively participate
–It helps to use existing workplace health and safety requirements as a framework ( such as 300 logs).
–Make sure it is in compliance with applicable laws and regulations.

Seven Parts

There are seven parts to a successful implementation of an I2P2 plan. It works based on “Plan-Do-Check-act” planning proceedure.

Using these seven steps, your business systemically eliminates underlying root causes of deficiencies, and moves toward long-term solution rather than one-time fix.

Example: inspection finds unguarded machine. Machine gets fixed and also process in place to discover underlying reason why machine is broken. Process might lead to replacing guards with more effective design, or replace the machines themselves so hazard is eliminated.

This illustration shows how the seven parts work together.