Posts Tagged ‘hazard communication’

How OSHA’s Final Rule on Hazard Communication Changes Your Safety Program

Thursday, March 29th, 2012

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.


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 FAQOSHA 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.


OSHA’s Hazard Communication Requirements Explained

Wednesday, August 31st, 2011

There are five parts to an effective Hazard Communication program at your dealership. Your central record keeping should include a written program that demonstrates a commitment to chemical safety by management, Material Safety Data Sheets (MSDS) for every chemical on premise, a chemical inventory listing including quantities on premise, and documentation of all employee training activities around chemical safety. Additionally, make sure that all primary and secondary containers are properly labeled.

Keep up with these five things, and you’re in compliance with OSHA’s Hazard communication standard. Here are some more references about Hazard Communications on the web, and in video.

Hazard Communication at top of OSHA Top 10, 2010

How KPA helps dealerships create safety programs that comply with OSHA

Take two minutes and watch this video by Safety Engineer, Glorianna Cooley. She explains the core concepts around OSHA’s Hazard Communication Requirements and what they mean for dealerships and service centers.

I2P2 Top Priority on OSHA’s Fall Regulatory Agenda

Tuesday, December 21st, 2010

OSHA bannerAmong the other regulatory updates in OSHA’s semi-annual agenda that was released on December 20th in the Federal Register, the Injury and Illness Prevention Program (I2P2) was said to be at the top of OSHA Administrator Dr. David Michael’s priority list. We have been hearing a lot about I2P2 lately, but if you are unfamiliar with the program, it would require employers to find and fix hazards, and plan, implement, evaluate, and improve workplace processes and activities in the interest of protecting workers’ safety and health.

“OSHA believes that an injury and illness prevention program is a universal intervention that can be used in a wide spectrum of workplaces to dramatically reduce the number and severity of workplace injuries,” the agenda states. “Such programs have been shown to be effective in many workplaces in the United States and internationally.”

Other updates on regulatory actions including modernizing recording and reporting requirements, infectious diseases, OSHA’s Hazard Communication Standard (HCS), proposed combustible dust rule, proposal for an MSD Column on the OSHA 300 log, and the proposed Walking Working Surfaces and Personal Fall Protection Systems (Slips, Trips, and Fall Prevention) rule. Find out more information at

Read more about how a KPA safety program help you meet compliance with the I2P2 standard.

OSHA’s Top 10 Most Cited Violations for 2010

Wednesday, November 17th, 2010

OSHAOSHA’s Top 10 Most Cited Violations for the 2010 fiscal year was revealed at The National Safety Council (NSC) Congress and Expo in San Diego in EHS Today. Keeping with the trends of previous years, this new top 10 was only slightly different from last year’s top 10. Thomas Galassi, the director of OSHA’s directorate of enforcement programs, listed the 2010 top 10 at the NSC conference and said that OSHA generally sees “a degree of consistency in these violations” and that the “violations relate to falls, contact with equipment and exposure to harmful substances.”

For the second year in a row, we have compiled a list of the top ten violations by Auto Dealers for you.

  1. Hazard Communication
  2. Electrical safety requirements
  3. Abrasive wheel machinery
  4. Respiratory Protection
  5. General Duty Clause
  6. Personal Protective Equipment
  7. Walking/Working Surfaces (including stairs and ladders)
  8. Machinery and Machine Guarding
  9. Powered Industrial Trucks
  10. Medical Services and First Aid

Once again, our list was similar to our Top 10 list from last year. Hazard Communication was at the top of the list for a second year in a row and stands out as the most common violation cited by OSHA. Perhaps getting the word out about these haz-com requirements should be at the top of more public relations and association’s top 10 “to-do” lists. “These are very important,” Galassi said. “[They are] lessons learned in the workplace … lessons to take home.”

For more information about the Hazard Communication Standard, visit the OSHA’s Inspection Procedures for Hazard Communication Standards or learn more about OSHA safety, material safety data sheets (MSDS), and employee training.

Hazmat Training – Lives depend on it

Friday, November 12th, 2010

Tech training in service areaYou know how the old adage goes: “Train as if your life depends on it, because it does.” This is especially true when it comes to hazardous materials training – many lives depend on the proper training of Hazmat Employees.

As we have mentioned before, if you have hazardous chemicals in your facility (and remember that acetone and gasoline are hazardous chemicals), you must comply with DOT hazmat rules (Title 49 CFR 172, Subpart H) and OSHA’s Hazard Communication (“Right to Know”) Standard. If you don’t regularly ship hazmat or you are not a manufacturer of hazardous materials, don’t think that your dealership is immune to the regulations. Whether you or ship hazardous materials once per year or every day; around the block or across the country; in a small package or in a tank: You must protect your employees and the public from any potentially adverse effects of the chemicals being handled.

The idea is pretty straightforward: Workers have a right to know about the substances and chemicals with which they come in to contact, and any risks they may be exposed to, as well as the proper protective equipment to use. Under the Hazard Communication Standard, shippers are also required to maintain a database of Material Data Safety Sheets (MSDS) and a facility-specific chemical inventory of the chemical products stored and used throughout their facility.

Every employee who affects the safety of hazardous materials transportation is a Hazmat Employee and must be trained. This definition also applies to the owner or the operator of the vehicle transporting the hazardous materials in commerce or any employee who, during his or her course of employment:

  • Handles, loads, or unloads hazardous materials
  • Manufactures, marks, classifies, labels, packages, or otherwise represents containers, drums, or packagings which are classified for use in the transportation of hazardous materials
  • Prepares hazardous materials for transportation
  • Is responsible for storage and disposal of hazardous materials
  • Is responsible for safety of transporting hazardous materials
  • Operates or owns a vehicle to transport hazardous materials

Take this simple quiz to see if your dealership could pass an OSHA/DOT audit:

  1. Do you have records confirming at least one employee has DOT Hazmat Certification?
  2. Is this training being updated every three years?
  3. Did this training include the newly required “Security Awareness” training?
  4. Are you following the proper procedures for hazardous shipments using the proper labels, classifications, identification numbers, and packing groups according to the DOT’s hazardous materials table?
  5. Do you provide the required 24-hour emergency contact phone number on your shipping papers?

Read more of our EHS DOT blogs.

If you are unable to answer “yes” to every question, contact us to learn more about our new standalone DOT and MSDS service.

Beyond “Right To Know” for MSDS information

Friday, November 5th, 2010

Your employees have the “right to know” about hazardous chemicals in the workplace under OSHA’s Hazard Communication Standard (HCS) which states “employers with hazardous chemicals in the workplace must have label and material safety data sheets (MSDS) for their exposed workers and train them appropriately.” The HCS allows for MSDS to be kept hard copy format or online – but in the event of an emergency, do you really want your employees scrambling for a binder full of MSDSs and then frantically looking for the right sheet among many? Online systems provide search tools, index, and immediate access making critical information not just available but “easy to find.” Online systems with a backup CD-Rom option give you “peace of mind” if your internet connection goes down during an emergency. When seconds count in the event of an emergency that involves hazardous chemicals “easy to find” and “peace of mind” is just as important as the right to know.

OSHA Severe Violator Enforcement Program Now in Effect!

Thursday, June 24th, 2010

“The New OSHA” as described by many department heads is showing its colors and making good on its promises.  The recently enacted Severe Violator Enforcement Program (SVEP) is  now in effect and being enforced.  What exactly does this mean to you?

In the words of David Michaels, OSHA administrator, “SVEP will help OSHA concentrate its efforts on those repeatedly recalcitrant employers who fail to meet their obligations under the Occupational Safety and Health Act. It will include a more intense examination of an employer’s practices for systemic problems that would trigger additional mandatory inspections.”

In reality it means more inspections, bigger fines and larger inspection scope.  Basically if you’re not making real efforts to keep your employees safe, it’ll cost you.  Under this program OSHA has promised to visit more employers with higher incidence rates, automatically include employers for follow up inspections, visit other locations run under the same corporate umbrella and raise fines for the first time since the 1990s.  The fine increase is significant from a max penalty for a  willful violation from $70,000 to $250,000.

We’ll see how all of this pans out for our clients, although with what we’ve personally seen in the past few months in much of the country, this program certainly seems to be on track.  Have any of you seen an increase in regulatory pressure?

Missing face plates on electrical outlets: $52,500 fine

Thursday, May 13th, 2010

Okay. It’s not exactly that. OSHA proposed the $52,500 penalties for four violations: a repeat violation is for failing to provide functioning safety latches on the hydraulic automobile lifts, a serious citation is for missing face plates on electrical outlets, and two other-than-serious violations are for recordkeeping deficiencies and hazard communication deficiencies. The company has 15 business days from receipt of the citations to comply, request an informal conference with OSHA’s area director, or contest the findings before the independent Occupational Safety and Health Review Commission.

Two learning lessons from this press release:

(1) OSHA is STILL providing you the opportunity to reduce the fine by complying or contesting. HOWEVER, the damage is to your reputation is already done when a press release like this goes out from OSHA

(2) These violations are just a few in pretty much an end-less, and growing, list of potential violations. You can use EHS checklists but that gets you only so far.These checklists typically don’t cover the  General Duty Clause very well, and makes it virtually impossible to rely on checklists alone. For reference, the general duty clause states that “Each employer shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees”

My advice: stop playing whac-a-mole with regulations, do a risk assessment, and engage in a formal safety program.

OSHA fine amounts increasing?

Wednesday, April 28th, 2010

Just read an article in Tire Review that OSHA fined a Toledo dealer $177,800 as the result of an October 2009 accident in which four employees were injured. OSHA cited the dealer for three violations of worker safety regulations after investigating the accident. The employees suffered injuries when an agricultural tire being worked on exploded. No question that the accident was very serious as an OSHA spokesman said that the dealer did not provide a safety cage or barrier to protect employees working on large commercial tires, failed to ensure employees worked outside the trajectory path, and that the tire’s maximum inflation pressure was exceeded when the employees attempted to seat the tire’s beads. In addition, citations were issued because employees failed to wear safety glasses and not having a required valve pressure gauge.

My point here is only that I’m under the impression that the fines imposed by OSHA are increasing? Do you have similar experiences? What do you think? Please respond below with your comments.

OSHA’s Top Most Cited Violations

Thursday, November 12th, 2009

EHS Today published an article on October 29 about the Top 10 Most Cited Violations for 2009. According to Richard Fairfax, director of OSHA’s directorate of enforcement programs, 81 percent of the violations OSHA recorded throughout the year were either serious or willful violations. The number of top 10 violations has increased almost 30 percent over the same time period in 2008.

We though you may find it interesting to see the top 10 for Auto Dealers:

  1. Hazard Communication
  2. Electrical safety requirements
  3. General Duty Clause
  4. Personal Protective Equipment
  5. Spray finishing using flammable and combustible materials
  6. Abrasive wheel machinery
  7. Respiratory Protection
  8. Portable fire extinguishers
  9. Exit routes, emergency action plans and fire prevention plans
  10. Machinery and Machine Guarding

Consistent with inspections by KPA’s engineers and registrations in dashboards, OSHA found that by far the most common violations by Auto Dealers are related to hazard communication. Details of OSHA requirements are outlined in OSHA’s Inspection Procedures for Hazard Communication Standards. Violations include deficiencies in chemical inventories, written hazard communication program, material data sheets (MSDS), and employee training.