Globally Harmonized System for Classification & Labeling of Chemicals, July 2013

Download Available: GHS 

Background: GHS or the Globally Harmonized System for classification and labeling of chemicals has been adopted by OSHA earlier this year.  While GHS may be the buzz word, we are still talking about the Hazard Communication Program (HCP) enacted by OSHA in 1986 that is currently in affect at 5 million employers across the United States.  HCP covers a written plan, MSDS, chemical labeling and training for employees that use these chemicals.  The implementation of GHS by OSHA is spread across the next few years as follows:

  • December 1, 2013: Train Employees on how to use the new Safety Data Sheet (SDS) and GHS Classification and Labeling
  • June 1, 2015: Compliance with the law regarding Labeling, Training, and the new Safety Data Sheets
  • December 1, 2015: Ship products with New Labels
  • June 1, 2016: Update the Hazard Communication Program and provide additional training for new hazards reported under the new SDS regime.

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Hazardous Waste Cost Recovery Charges on Repair Orders-Regulatory & Legislative Review, April 2013

Download Available: Hazardous Waste Disposal Charges Update 2013

We wrote to you in November 2012 regarding compliance with charging customers for hazardous waste disposal charges on the invoice.  A copy of the Dealer Alert from November 2012 (without the attachments) is enclosed with this letter.  Following the letter, we sought a regulatory and legislative review from experts in this area.

The experts have stated that the hazardous charges to customers must be direct costs related to hazardous waste disposal and these costs must be offset by any money the dealership receives from selling oil.  Depending upon the size of the dealership or dealership group, this amount can be anywhere from $0.75 to $1.00 per gallon of used oil.  For example, if the dealership receives $12,000 per year from the used oil hauler and the net expenses directly related to hazardous waste are $10,000, then the dealership should not charge customers for hazardous waste.  If the net expenses are more than the money received from selling used oil, then the dealership can recover the excess costs.

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Training on Heat Stress, April 2013

Download Available: Heat Stress Newsletter

Background:  Workers who are exposed to extreme heat or work in hot environments may be at risk of heat stress. Exposure to extreme heat can result in occupational illnesses and injuries. Heat stress can result in heat stroke, heat exhaustion, heat cramps, or heat rashes. Heat can also increase the risk of injuries in workers as it may result in sweaty palms, fogged-up safety glasses, and dizziness. Burns may also occur as a result of accidental contact with hot surfaces.

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Do’s and Don’ts of Safety Incentive Programs, March 2013

Download Available: Do’s and Dont’s of Safety Incentive Program

Safety Incentive Programs have been a positive influence on promoting safety and reducing accidents at the workplace.  Reduced injuries from successful incentive programs have saved thousands of dollars toward workers’ compensation insurance premiums and also minimized other losses.  Employee morale at safer places is also better resulting in greater productivity and profitability.  All in all, it is a win-win situation for both the employees and the employer.

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Double Down on Safety, August 2012

Download Available: Double Down on Safety-Workers Comp Rates Are Going Up email

Workers’ Compensation Insurance Rates Are Going Up:  The California Workers’ Compensation Insurance Rating Bureau (WCIRB) has submitted a mid-year 9.1% increase in the advisory rate to the Department of Insurance.  This follows a 37% increase Commissioner Jones approved on January 1, 2012, but the increase for some bureaucratic procedures were hidden from the public.  In a horrible economy where businesses are already in trouble, this could not have come at a worse time.  And this just off the press; the WCIRB is recommending a 10+ percent increase in the underlying pure premium rates for January 2013.  There are reasons that can explain this increase and dealers are encouraged to improve their mod-ratio, i.e., improve safety and reduce workplace injuries.

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There is Green in this Green Regulation, July 2012

Download Available: Solid Waste Recycling AB 341 Newsletter

The Law: As of July 1, 2012, businesses and other entities in California that generate 4 cubic yards (about one dumpster) or more of solid waste such as cardboard, metal, and plastic waste per week, are subject to mandatory recycling requirements. The intent of this law is to reduce greenhouse emissions by diverting commercial solid waste from landfills and expand opportunities for recycling.  Most automobile dealerships and body shops generate at least 4 cubic yards of waste per week, so compliance becomes mandatory.

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Universal Wastes, May 2012

Download Available: Universal Wastes

Reportedly, a porter at an automobile dealership tried to dispose 150 lamps at a household recycling center.  The recycling facility, meant for households wastes, declined the shipment and then cited the facility for improper disposal of fluorescent lamps (a Universal Waste).  In 2001, US EPA made changes to waste rules applying to spent mercury-containing light bulbs that would require recycling of these lamps and prohibit landfill disposal.  On the national level, exemption was created for businesses that generate a combination of hazardous wastes (RCRA wastes) and universal wastes in an amount of less than 100 kilograms a month.  California has enacted regulations that require all facilities, without any exemptions, to recycle Universal Wastes.  In Arizona, the state exempts dealers generating less than 100kg/month of RCRA and Universal Wastes under the federal regulations but the ADEQ strongly encourages the generators, to recycle the fluorescent lamps. Continue reading

Fines and Penalties on the Rise from Government Agencies, July 2011

Download Available: Fines from regulating agencies are on rise

Inspections and penalties from regulating agencies is nothing new.  However, these agencies that were once code enforcers, protecting the lives of employees or saving the environment look more like revenue generators for the government.  Other factors may be at work too.  The politicians are in cost cutting mode and in that bargain they may slash budget for agencies or eliminate them altogether.  With greater enforcement and fine collection, the agencies remain in forefront in minds of both the public and politicians alike.

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Grinder Safety, July 2011

Download Available: Grinder Safety

Background:  Shop or bench grinders are commonly used in automotive shop areas.  Violations with OSHA standards in operation of these grinders are very common.  Typically, these violations are rated serious and could easily be assessed as “willful & serious” i.e., the employer should have knowledge of this very common shop equipment.  Repeat violations can really mount up.  Fed-OSHA records from October 2006 thru September 2007 indicate that in the Manufacturing Industry grinders accounted for 974 citations with an average penalty of $354.  It was the 9th most cited violation.  Recently an auto service shop has been assessed a 75K penalty and this causes us to visit the safety issues related to abrasive wheel grinders.

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