To:             Environmental Health and Safety CoordinatorFrom:        Sam Celly, BChE MChE JD CSPDate:         October 30, 2025Ref:           Electronic Verification Questionnaire (eVQ) CALIFORNIA BUSINESS ONLYWhat is eVQ?State of California EPA requires each Hazmat generator (producer of waste) to complete the Electronic Verification Questionnaire (eVQ) annually starting January 30, 2026. There are no fees involved to submit the eVQ, however, starting in 2026 the State will issue “late reporting penalties” for submissions made after March 31, 2026. For more information, visit https://dtsc.ca.gov/evq-penalties/If you have stopped operations involving hazardous waste, you can deactivate your EPA ID by filing DTSC Form 1358. Deactivation of the unused number can occur during the eVQ filing process as well.  Clients of Celly Services: Please complete the form below and email to accounts@cellyservices.com prior to January 31, 2026.Username: __________________________Password: ___________________________o  If Celly Services has completed eVQ for the dealer prior, please disregard question 1 & 2.Total Number of Employees1: ________________________________California Department of Tax & Fee Administration (CDTFA) Hazardous Waste Generation and Handling (G&H) Fee account number2: ________________________________Amount of Universal Waste generated (in tons): ________________________________1The total number of individuals employed by your entire company or organization throughout California during the 2025 calendar year. Include all employees who worked 500 hours or more, including those who worked at locations that did not generate hazardous waste.2 Sample Haz Waste Gen acct# 123-456789 – It will be a 9-digit number.3 Universal waste includes: Light bulbs, batteries (alkaline, lithium), non-empty aerosol canisters, CRT glass, mercury waste, and electronic devices: Computers, monitors, printers, cell phones, and any electronic equipment with a circuit board. For more detail visit universal-waste-fact-sheet.NotificationIf you have not received any notification, chances are it is going into a manager’s email box that is not being attended to or the manager is no longer at the company.  So, if you have no notification and your eVQ has not been completed, log into your eVQ (reset password if needed) and set up new user name and password; an override of the old one will be required.What happens if you do not file eVQ?The dealership’s EPA ID number will be made INACTIVE and penalties will follow. EPA sends an email that for failure to complete the eVQ, the number is getting inactivated.  Unfortunately, the dealership staff receiving the email fails to respond to the email or the email goes to an email account that is not being attended.  The hazardous waste hauler will stop picking up the hazardous waste as the EPA number has become inactive. Your hazardous waste oil tanks, drums and buckets will start to overflow! Only after completion of a new EPA ID application for reactivation of the EPA ID number and upon the completion of the eVQ, will the EPA ID number get reactivated. This whole process can take three weeks and can be demanding. Good news is that SB 158 eliminated the Manifest Fee & the EPA verification fee (the fees associated with eVQ). Other Useful Links·     Verification Questionnaire Step by Step Guide·     Check My ID Number Status

To:          Environmental Health and Safety CoordinatorFrom:     Sam Celly, BChE MChE JD CSPDate:      December 16, 2025Ref:        CALIFORNIA ONLY: Training Documentation Requirements Effective January 1, 2026 OverviewWhen an employee leaves a place of employment, the traning records are left behind.  Request by an ex-employee for traning records may go unanswered. CA state arrives to the rescue!  Beginning January 1, 2026, California is implementing requirements related to employee access to training records. They affect how dealerships record, maintain, and provide access to training programs. Regulatory agencies are also increasing expectations for annual safety training, particularly for operations involving hazardous materials, spill prevention, and environmental compliance. Proactive alignment now will reduce audit risk and improve readiness going into 2026.What Are the Changes in 2026Employers who maintain training or education records must ensure these records include:Employee nameTraining providerDate and duration of trainingCore competencies or subjects covered (e.g., Heat Illness Prevention, Hazmat, Emergency Response, etc.)Certification or qualification issued, if applicable.Celly Services has created an effortless pathway to obtain employee training records.Login to CSI E-Learn portalClick TRAINING RECORDS tab on the left menu.Type employee email or name on the top and Search.Click “Print Certificate” to obtain training certificate. Under the new law, employees have the right to request and receive copies of their training records.Recommended Actions for DealershipsTo prepare, before January 1, 2026, all dealerships should:Enroll employees onto Celly Services’ E-Learn portal for training modules and recordkeeping.Use this excel spreadsheet to enroll employees onto E-Learn.Once completed, email spreadsheet to elearn@cellyservices.comReview current training files for required documentation elements.Standardized training record templates across all departments.Sign-in-sheets on E-Learn will be updated to reflect the 2026 changes.Retain records in an accessible format (digital format recommended via uploading on E-Learn portal).Provide employees with access upon request within required time limits.Update written training policies to reflect these changes.Why This MattersIncreased regulatory scrutiny and audit frequency.Reduced liability exposure during incidentsStrengthened compliance posture for 2026 and beyond.Consistency across dealership locations and departmentsThank you for your attention to this important update.DISCLAIMER: The contents of this newsletter are merely for informational purposes only and are not to be considered as legal advice.   Employers must consult their lawyer for legal matters and EPA/OSHA consultants for matters related to Environmental, Health & Safety. The article was authored by Sam Celly of Celly Services, Inc. who has been helping automobile dealers comply with EPA and OSHA regulations since 1987.  Sam received his BE (1984) and MS (1986) in Chemical Engineering, followed by a J.D. from Southwestern University School of Law (1997).  Our newsletters can be accessed at www.epaoshablog.com.  Your comments/questions are always welcome.  Please send them to sam@cellyservices.com.

To:       Environmental Health and Safety Coordinator

From:  Sam Celly, BChE, MChE, JD, CSP

Ref:     Labor Law Posters

Date:   November 25, 2025

Background
Employers are required to maintain designated employee areas, such as breakrooms, that promote awareness of labor laws, safety responsibilities, and workplace rights. In addition to providing a clean and sanitary space, the breakroom often serves as a central posting location for mandated notices and company safety materials.

POSTER FOR ALL STATES

State and Federal Labor Law Posters.

• Source for: AZ, CA, CO, FL, GA, IL, NJ, NV, NY, OR, TX, UT, WA, & Federal labor law posters.
  CalChamber Store Labor Law Posters (Preorders for 2026 posters are available and will begin shipping out on December 22, 2025)

Heat Illness Prevention Posters: Recommended to educate employees on heat Illness. OSHA Heat Illness Prevention Poster

QR Code
OSHA’s recommended practices for safety and health programs include elements to encourage worker engagement and safety suggestions. Use the QR Code to print and place the safety suggestion poster on the Notice Board.  Available to Celly Services clients on the client login page.

POSTERS FOR CALIFORNIA

State and Federal Labor Law Posters.

• Source for CA & Federal labor law posters.
  CalChamber Store Labor Law Posters (Preorders for 2026 posters are available and will begin shipping out on December 22, 2025)

Heat Illness Prevention Posters: Recommended to educate employees on heat Illness. OSHA Heat Illness Prevention Poster

California Mercantile Wage and Hour Poster can be downloaded from the state website Wage and Hour Poster English & Wage and Hour Poster Spanish

California Prop 65 signs

California Prop 65 signs summary

Injury and Illness Prevention Program (IIPP) Policy Statement: Cal/OSHA under the IIPP program that employees be notified of the location of the IIPP.

Note
The following fillable sections on labor law posters MUST befilled out completely.

• Emergency contacts (hospital, physician, police, fire dept, and ambulance)
• Medical Provider Network (California only)
• See the poster from your state for other mandatory information

CALIFORNIA The Workplace Know Your Rights Act (Posters Required)

SB294 was signed into California law by Governor Newson on October 12, 2025. The Workplace Know Your Rights Act takes effect on January 1, 2026 and requires California employers to provide a stand-alone notice informing all employees of various workplace rights, including those related to workers’ compensation, immigration practices, notices of inspection, organizing, and constitutional rights during law enforcement actions in the workplace (Fourth Amendment to the United States Constitution to be free from unreasonable searches and seizures and rights under the Fifth Amendment to the United States Constitution to due process and against self-incrimination).

• The California Labor Commissioner will publish a stand-alone notice template by January 1, 2026 for employers to use in, and will update the notice must annually.By July 1, California Labor Commissioner will publish a video that informs employees of their rights (in English and Spanish), and a separate video informing employers of their responsibilities. Employers should prepare to comply with the new requirements and monitor the California Labor Commissioner’s Office website for the notice and videos from the Labor Commissioner.
• By March 30, 2026, employers must allow current employees, and new employees upon hire, to designate an emergency contact in case of arrest or detention at work. HR manager must update employee records.
• Employers who violate the Act face civil penalties of $500 per employee, per violation. Specifically for violations of the emergency contact requirements, employers face civil penalties of $500 per employee for each day the violation occurs, up to a maximum of $10,000 per employee.

Legalese
California SB 294 has a list of legal rights for employees and obligations for the employer.  Employers are well served to consult their labor lawyer to stay compliant.  The labor law poster list provided is for guidance purposes and the employer should contact their labor counsel for a complete list of notifications.

DISCLAIMER: The contents of this newsletter are for informational purposes only and are not to be considered legal advice. Employers must consult their lawyer for legal matters and EPA/OSHA consultants for matters related to Environmental, Health & Safety. The article was authored by Sam Celly of Celly Services, Inc. who has been helping automobile dealers in Arizona, California, Hawaii, Idaho, Nevada, New Mexico, New York, Texas, and Virginia comply with EPA and OSHA regulations for over 35 years. Sam is a Certified Safety Professional (No. 16515) certified by the National Board of Certified Safety Professionals. Sam received his BE (1984) and MS (1986) in Chemical Engineering, followed by a J.D. from Southwestern University School of Law (1997). Sam is a member of the American Chemical Society (No. 31176063), American Industrial Hygiene Association (No. 124715), and National Association of Dealer Counsel (NADC). Sam also serves on the Board of Orange County American Industrial Hygiene Association and on CA Industrial Hygiene Council (CIHC). Our newsletters can be accessed at www.epaoshablog.com. We welcome your comments/questions. Please send them to sam@cellyservices.com.

To: Environmental Health and Safety Coordinator

From: Sam Celly, BChE MChE JD CSP

Date: November 24, 2025

Ref: SB 1215 requires California retailers to register with CDTFA and collect a new recycling fee on products containing non-removable (embedded) batteries starting January 1, 2026.

Introduction & Purpose
Effective January 1, 2026, retailers doing business in California—including automotive dealerships—must comply with the newly established Covered Battery-Embedded Products (“CBE”) Waste Recycling Fee, administered under Senate Bill (SB) 1215. Retailers must register with the California Department of Tax and Fee Administration (CDTFA) and collect the CBEP fee at the point of sale or lease of applicable products. 

The program is jointly overseen by CDTFA, CalRecycle, and the Department of Toxic Substances Control (DTSC). It is intended to support statewide recycling of electronic products containing non-removable batteries. The new law expands the existing Electronic Waste Recycling Act of 2003 to include these “covered battery-embedded products.”

What Is a Covered Battery-Embedded Product?
Covered battery-embedded product means “a product containing a battery or battery pack that is not designed to be removed from the product by the consumer.”(California Public Resources Code 42464(d)(1), as amended by SB 1215, 2022.)

Examples of CBE at dealerships

• Consumer electronics
• EV-related accessories
• Diagnostic or programming devices
• Electronic tools or service accessories
• TPMS-Tire Pressure Monitoring Systems
• Smartphones, tablets, and similar sealed battery devices

Note:  Key fobs are not considered CBE because it contains a battery that is designed to be easily removed by the user with common household tools.

TPMS Sensors – Possible Inclusion
Many Tire Pressure Monitoring System (TPMS) sensors contain sealed lithium batteries that are not easily user replaceable. This design places TPMS within the scope of a CBE. As of the date of this memo, no TPMS manufacturer has released official SB 1215 guidance. Dealerships should prepare for potential inclusion and monitor manufacturer updates closely.

Exclusions
The following are not classified as CBE.

• Certain medical devices
• Covered electronic devices (already subject to California’s e-Waste fee)
• Certain energy storage systems
• Certain electronic nicotine delivery systems

The following transactions are not subject to the CBE waste recycling fee.

• A sale for resale
• A sale to Native Americans on Indian country
• Sale of CBE products the retailer ships directly to a location outside California when the transaction is not subject to California sales or use tax. The fee will apply if the buyer takes possession of the CBE products in California

CBE Fee Rates
CalRecycle has now finalized the 2026 fee structure.  This will be revised annually in October and will take effect January 1 of the following year.

• 1.5% of the retail sales price
• Capped at $15 per product
• Effective January 1, 2026
• Dealership POS systems will need to incorporate the percentage-based calculation and the per-item cap. They may retain three percent of the CBE waste recycling fee collected as reimbursement for all fee collection costs.

Registration Timeline
CDTFA opens online registration for the CBEP Waste Recycling Fee account today, November 19, 2025.
Dealerships without CDTFA credentials (username, password, or seller’s permit) must create them using the “Sign Up Now” feature in the CDTFA Online Services Portal.

Filing Requirements & Due Dates
Returns and payments are due the last day of the month following each calendar quarter. For example, the first required reporting period is for the first quarter, January 1 through March 31. The return and fee payment are due on or before April 30th. The return is due on either a quarterly or yearly filing basis, and filing frequency is assigned when you register. You are required to file a return even if you did not have any reportable activity or do not owe an amount during the reporting period.

Dealership Responsibilities

• Fee collection at POS (including leases)
• Filing CBE returns, at assigned frequency
• Timely remittance of fees to CDTFA
• Retain 3% of fees as reimbursement for all fee collection costs
• Inventory review and system updates

Non-compliance may result in CDTFA penalties, interest, and enforcement action.

For More Information
CDTFA – CBE Waste Recycling Fee Guide
Provides instructions for registration, filing, and fee remittance.

CDTFA Customer Service Center
1-800-400-7115 (TTY: 711)
Monday–Friday, 7:30 a.m.–5:00 p.m. Pacific
Select: Special Taxes and Fees

CSI Client Testimonials
https://cellyservices.com/testimonials/

DISCLAIMER: The contents of this newsletter are merely for informational purposes only and are not to be considered as legal advice.  Employers must consult their lawyer for legal matters and EPA/OSHA consultants for matters related to Environmental, Health & Safety. The article was authored by Sam Celly of Celly Services, Inc. who has been helping automobile dealers comply with EPA and OSHA regulations since 1987.  Sam received his BE (1984) and MS (1986) in Chemical Engineering, followed by a J.D. from Southwestern University School of Law (1997).  Our newsletters can be accessed at www.epaoshablog.com.  Your comments/questions are always welcome.  Please send them to sam@cellyservices.com.

TO:               Environmental Health and Safety (EHS) CoordinatorFROM:         Sam Celly, BChE MChE, JD CSPSUBJECT:    Accident Investigation: Who? What? Where? When? How?DATE:          October 17, 2025 Accident investigation should be the cornerstone of any safety program.  Many safety programs concentrate on safety inspections and training but miss out on accident investigation.  They do so at their own peril.  Investigating accidents is not only a good idea, but also a requirement.  Here, we provide some guidance and tools to complete an accident investigation. OSHA strongly encourages employers to investigate all incidents in which a worker was hurt, as well as close calls (sometimes called “near misses”), in which a worker might have been hurt if circumstances had been slightly different.  National Safety Council defines accident as an undesired event that causes injury or property damage.  An incident, on the other hand, is an unplanned, undesired event that adversely affects the completion of the task.  Near misses are events with no injury or loss, but with a slight shift in time or location, an injury would have easily happened. To many, “accident” suggests an event that was random, and could not have been prevented. Since nearly all worksite fatalities, injuries, and illnesses are preventable, OSHA suggests using the term “incident” investigation.  OSHA needs to be notified regarding serious accidents within a specific timeframe.  The timeframe varies between CA state and federal regulations.  For fatalities and serious injuries such as amputations, the dealership should seek legal counsel right away. Accident InvestigationAccident investigations should be conducted by trained individuals with the primary focus of understanding why the accident or near miss occurred and what actions can be taken to preclude recurrence. In smaller organizations, the responsibility may lie directly with the supervisor responsible for the affected area or employee. Questions to ask in an accident investigation include: 1.     What happened?Describe what took place to prompt the investigation: an injury to an employee, an incident that caused a delay in production, damaged material or any other conditions recognized as having potential for losses or delays. 2.     Why did the incident happen?Obtain all the facts surrounding the occurrence: what caused the situation to occur; who was involved; was/were the employee(s) qualified to perform the functions involved in the accident or near miss; were they properly trained; were proper operating procedures established for the task involved; were procedures followed, and if not, why not; where else does this or a similar situation exist, and how can it be corrected? 3.     What should be done?The person conducting the investigation must determine which aspects of the operation or processes require additional attention. It is important to note that the purpose here is not to establish blame, but to determine what type of constructive action can eliminate the cause(s) of the accident or near miss. 4.     What action has been taken?Action already taken to reduce or eliminate the exposures being investigated should be noted, along with those remaining to be addressed. Any interim or temporary precautions should also be noted. Pending corrective action and reason for delaying its implementation should be identified.Corrective action should be identified in terms of how it will prevent a recurrence of the accident or near miss and how it will improve the overall operation. This will assist in selling solutions to management. The solution should be a means of achieving accident control and total operation control.The safety committee should review investigations of all accidents and near miss incidents to assist in recommending appropriate corrective actions to prevent a similar recurrence.  Thorough investigation of all accidents and near misses will help you identify causes and needed corrections, and can help you determine why accidents occur, where they happen, and any accident trends. Such information is critical to preventing and controlling hazards and potential accidents. Accident Investigation Form (Form Attached)Fraud Prevention Tool: Keep in mind that properly completed investigations can later serve as tools in fraud prevention as well.  At the time of the accident, it is not apparent which case will be considered fraud, and which one will end up in litigation.  Statements noted at the scene of the accident carry sufficient evidentiary weight in legal situations.  Forms that are normally and customarily completed by corporations are admissible evidence and statements given immediately after an accident or incident are admissible as well.  Questions to ask in an accident investigation include:Age: Noting the age, at times, help us determine if the injury occurred to an aged person involved strenuous work activity.  You may have to provide training, engineering controls to prevent the injury from reoccurrence.  At times, you may need to reassign the person to another job function temporarily.  Do not discriminate on the basis of the injured employees’ age.Accident Time/Date v. Reported Time/Date: Normally, accidents are visible to other employees in the work area.  However, many times the employee reports an accident much later than its occurrence.  It could be genuine, i.e., the back sprain really started hurting the next day.  Or it may be that a personal injury at home or during recreational activities is being attributed to workplace injury.  Record the facts now; it may help your case later.  You may also document the date/time the employee sought medical assistance on the form.Equipment Being Operated: Was the employee trained in its use?  Is the equipment new?  Was the equipment damaged or in need of repair? Is the equipment being used for the task it has been provided for?Part of Body Injured: Document on the part of the body injured and the extent of injury and loss of motion etc.  Sometimes the employee reports injury to one part of the body.  However, the employee may later (and when lawyers arrive) decide to list a whole lot of other body parts with injuries.  Your document cannot refute all other injuries alleged by the employee, but it definitely gives guidance to your counsel as to what the employee reported at the time of the injury.Description of Accident: Be careful in stating your case.  Just state the facts.  Remember this document may go in the hands of people litigating the case against you.  If the injury involves a serious accident, such as amputation or fatality, ask your lawyer to help you with the forms.  OSHA will use this document to weave penalties that can reach into the thousands, so a word of caution here.Primary Causes: The trio that is the root cause of most accidents is improper tools, improper procedures, or the employee was in a hurry.  Whatever the cause, write it down. It is your possible solution to prevent the injury from reoccurring.Corrective Measures: Generally, the corrective action may be obvious and the action you intend to take is clear.  If not, you may discuss options and actions with others and complete another form for documenting steps taken to prevent such accidents.  It may involve safety training, providing personal protective equipment or its use thereof, purchasing new equipment, or good old-fashioned counseling of the employee.  Equipment LOTO must be noted if the equipment was defective or damaged.Witnesses: Document witness statements.  The sooner, the better.  Memory begins to fade with the passage of time.  Some people avoid this, stating that the nature and severity of accident does not require one.  We believe good practice is good practice for a reason.  Document all who saw and what they saw in each accident you document.  If the accident involves a serious injury or a fatality, ask your lawyer to take witness statements.Witness statement taken immediately following an accident are clearly admissible.  Statements taken months after the accident and after litigation ensues may not be admissible.Third Party Causation: Interact with third party to eliminate such accidents in future.  Inform your insurance company to follow up with subrogation. Safety Counseling Form (Form Attached)Once you have found the root cause of the accident, it is important to counsel the employee.  If the accident involves carelessness as a cause, state that the employee may face disciplinary actions consistent with the employer’s policy on such matters up to and including suspension or termination.  Lack of action on part of management may implicate the manager for not taking preventive action that could have prevented future accidents.  California statutes carry jail term for managers of sites where employees were killed or seriously injured. Employee Statement of Injury (Form Attached)Employees shall use this form to report all work-related injuries, illnesses, or “near miss” events (which could have caused an injury or illness) – no matter how minor. This helps us identify and correct hazards before they cause serious injuries. This form shall be completed by employees as soon as possible and given to a supervisor for further action. Declination of Immediate Medical Care (Form Attached)The nature of certain injuries may be such that the employee declines treatment from a clinic even though the employer provided the option.  In certain instances, you may not give the employee the option to decline treatment.  Use your judgement.  The law says that you must provide employee treatment when you have knowledge of workplace injury!  Forms for documenting the employee declining medical treatment are attached and may be used as necessary. DISCLAIMER: The contents of this newsletter are merely for informational purposes only and are not to be considered as legal advice.   Employers must consult their lawyer for legal matters and EPA/OSHA consultants for matters related to Environmental, Health & Safety. The article was authored by Sam Celly of Celly Services, Inc. who has been helping automobile dealers comply with EPA and OSHA regulations since 1987.  Sam received his BE (1984) and MS (1986) in Chemical Engineering, followed by a J.D. from Southwestern University School of Law (1997).  Our newsletters can be accessed at www.epaoshablog.com.  Your comments/questions are always welcome.  Please send them to sam@cellyservices.com.

To:       ClientsFrom:  Sam CellySub:     Workers Compensation, Experience-Modifier, and How Litigation is Adding to Our ClaimsDate:   September 18, 2025 Introduction. Dealerships Workers Compensation (WC) insurance costs have increased effective September 1, 2025 with the California Department of Insurance approving a rate increase of about 9%. Background.  Workers Compensation (WC) insurance is mandatory in the United States and many other countries. It ensures employees receive medical treatment and disability benefits for workplace injuries, while protecting employers by providing immunity from employee lawsuits for alleged negligence. WC premiums are paid entirely by employers and represent a significant, manageable business expense. Steady over nearly a decade, rate increases are attributed to rising medical and claims costs, more cumulative trauma claims, and increased claim adjustment expenses.                                                                                                                                                                                                            Cost Containment. WC premiums are calculated using a base rate that reflects job duties, payroll size, and the number of employees. This base rate is then adjusted by an experience modifier (X-Mod) tied directly to the frequency and severity of workplace injuries. Losses are calculated from claims paid by the insurance company, so every claim impacts your premium for multiple years. Preventing injuries is the most effective cost-control strategy. Being Proactive. Reducing both injuries and claims, starts with a proactive approach to safety and claims management. Employers should:Form and maintain an active Safety CommitteeDesignate an approved medical clinicEncourage open communicationDocument thoroughly Accident Investigation, Employee Statement of Injury, Employee Counseling, Declination of treatment by employeeVerify coverage for contractors working on your premises and others Post-Claim. Promptly report all claims to the carrier even declinations with signed forms. In California, the 90-day rule for workers’ compensation claims means that if the insurance carrier fails to accept or deny a claim within 90 days of it being submitted to the employer, the claim is presumed accepted.Ensure supervisors investigate each claim and notify your carrier if legitimacy is in question. If a third party is at fault, pursue subrogation. Offer modified duty, when possible, to reduce costs, and work closely with your claims adjuster by providing requested information quickly for efficient claim handling. Managing Your Claims. Stay actively engaged in the claims process ask for updates frequently. Open claims with high reserves are a major reason X-Mods increase. Remember that legal expenses do not affect your X-Mod, but illegitimate claims should always be challenged. Sometimes settling quickly is more cost-effective than allowing claims to linger. For litigated cases, voluntary resignations may be part of the settlement strategy. Ultimately, the best claim is one that is prevented, and the next best is one that is promptly closed. Calculating Costs.  In California, payroll data and incurred losses over a four-year period are used to calculate an employer s workers compensation premium. For example, the 2025 X-Mod basis for policy renewal on January 1, 2025 are WC claims from 2021, 2022, and 2023.  While 2024, most recent year s claims are excluded from the X-Mod calculation, it remains critical for underwriting. Even with a favorable or credit X-Mod, a dealership with multiple recent claims may be viewed by carriers as having a weak safety culture, leading to fewer quotes and/or higher premiums. Checklist before submitting your data.Are payroll data correct?Are X-Mods calculated correctly?  Per insurance brokers 75% of all X-Mods are incorrect.Are subrograted & joint claims included or missing? Cost Savings. Two employers with identical payrolls (Table A) show how injury rates drive costs. Employer II had four more injuries than Employer I, resulting in $282,500 in losses versus $45,004. This difference raised Employer II s annual premium by $174,540 in 2015. Because claims affect premiums for three years, preventing injuries saves money while also improving morale, productivity, and competitiveness.Table A:  Payroll Data (both Employer I & II)EmployeeAnnual PayrollNo. of EmployeesPayroll Year 1Payroll Year 2Payroll Year 3Clerical/Office Staff (code 8810)$ 50,000.0020$ 1,000,000.00$ 1,000,000.00$ 1,000,000.00Sales Staff(Code 8748)$ 80,000.0020$ 1,600,000.00$ 1,600,000.00$1,600,000.00Technicians(Code 8391)$ 80,000.0023$ 1,840,000.00$ 1,840,000.00$1,840,000.00Service Writers, Parts Counter, Parts and Service Managers(Code 8391B)$ 85,700.007$ 600,000.00$ 600,000.00$600,000.000Total 70$ 5,040,000.00$ 5,040,000.00$5,040,000.00Table B:  Injury Data & Losses Paid per Injury  Employer IEmployer IIYearClaim #Type of InjuryIncurred LossesType of InjuryIncurred LossesYear 11Cut Finger$ 1Back Injury$   50,000.00Year 12Cut Finger$ 1Back Injury$     7,500.00Year 13Broken Finger$ 10,000.00Broken Finger$   10,000.00Year 14Cut Finger$ 1Elbow Sprain$     5,000.00Year 15Head Injury$ 5,000.00Head Injury$     5,000.00Year 26Arm Rash$ 1Fatality*$ 175,000.00Year 37Back Injury/Cumulative Trauma$ 25,000.00Back Injury/Cumulative Trauma$   25,000.00Year 38Arm Rash$   5,000.00Arm Rash$     5,000.00Total  $ 45,004.00 $ 282,500.00*Death benefits are statutorily limited in certain states.  For California, death benefits are capped at $320,000. Only $175,000 is used in this sample calculation.                                                                         Table C:  Estimated Premium Costs Premium Based on Employee Count & PayrollExperience ModificationTotal 2025 Premiums(before credits) Employer I$ 264,500.000.85$ 224,825.00Employer II$ 264,500.001.51$ 399,395.00DISCLAIMER: Employers must consult with their WC Insurance brokers for a better understanding of their WC premiums and safety consultants for matters related to safety.  The contents of this newsletter are for informational purposes only and not to be considered as legal advice.   The premium numbers are for discussion purposes and actual numbers for X-Mod and premium calculations may vary on a case-by-case basis. The article was authored by Sam Celly of Celly Services, Inc. who has been helping automobile dealers comply with EPA & OSHA regulations since 1987.  Sam received his BE (1984) and MS (1986) in Chemical Engineering followed by a J.D. from Southwestern University School of Law (1997).  Our newsletters can be accessed at www.epaoshablog.com.  Your comments/questions are always welcome.  Please send them to sam@cellyservices.com.

To:          Environmental Health and Safety Coordinator From:     Sam Celly, BChE MChE JD CSP Ref:        Iceberg Effect: The Hidden Costs of Accidents Date:      June 4, 2025 Workplace accidents can be expensive for any corporation. Management often can brush away accidents and injuries by stating that it is just part of doing business. Some may look at accidents in terms of the dollar costs of treating injured employees, replacing injured employees, replacing broken machinery, etc. Accident-related expenses often go much deeper than what meets the eye. Hence the iceberg effect. The visible tip of an iceberg represents only a tiny fraction of its true impact, just like the immediate costs of an accident. Managers understand the acute impact of workplace injuries—medical bills, damaged equipment, and downtime—but the hidden costs lurking beneath the surface are even more devastating.   Accidents come with substantial costs that often go unnoticed until they start piling up. Here are some common ones. Loss in Productivity. When an accident happens, work slows down or stops entirely, resulting in delays and inefficiencies. For example, your only transmission mechanic breaks an arm and is gone temporarily for 6 weeks on disability. You must find a substitute. For calculation purposes, the tech was paid $40/hr. Your labor rate is $240/hour. The $200 differential at 40hrs/week is $8000 weekly. For six weeks of down time, you lost $48,000. Lost time is serious money! Employee Replacement Costs. If the employee is permanently disabled, you need to hire another mechanic. Lube techs may come easy; a master mechanic is likely more difficult to lure to your store. According to the 2023 NADA Dealership Workforce Study, average cost to recruit and onboard a hire is $5,000. Time to fill is another factor, impacting overall costs. According to DHI Group’s Hiring Indicators 2017 Report, retail industry had a time to fill average of 25 days. That’s 25 days of customers waiting for a specialist to repair their vehicle. Training Costs. Companies spend significant time and money training new hires to company standards and their way of conducting business. According to the NADA Study, the average training cost for dealership employees is $1200. These can spin upward to $10,000 per employee depending on their skill level and job according to CBTNews! Legal Fees & Fines. Companies may face lawsuits, regulatory fines, or settlements, which can be financially draining. OSHA fines and penalties are $16,500 per violation and $165,000 for willful violation. With nearly 40 years’ experience in workplace safety, I am confident that OSHA will find a code violation for serious accident, roping you into a regulatory morass of appeals, hearings and penalties. Trial lawyers are lurking in the waters too.  If they smell employer culpability that caused serious accident or harm, they will bypass the Workers Comp Judge under some novel theory and head to Superior Court. Equipment & Property Damage. Repairs and replacements for damaged tools, machinery, or infrastructure can be costly. Downtime for equipment can create backlog and loss of productivity. If a customer’s vehicle is damaged during the incident, associated cost may follow, such as providing a loaner until repairs are made. Increased Insurance Premiums. Insurance costs often rise after an accident, adding immediate and long-term financial strain to the dealer. Emotional & Psychological Impact. Accidents can lower morale, increase stress, and lead to long-term emotional effects on employees. Reputation Damage. A serious accident can hurt a company’s public image, making it harder to attract employees and even customers. Customers may demand buyback if a vehicle is damaged during an accident at the dealership. This is an excellent framework for understanding why proactive workplace safety measures are a financial necessity and not merely compliance. Preventative measures like rigorous safety training, regular equipment maintenance, and fostering a safety-conscious workplace culture can significantly reduce these risks. Companies that invest in safety upfront often find that their return on investment (ROI) outweighs the costs of handling accidents after they occur. DISCLAIMER: The contents of this newsletter are merely for informational purposes only and are not to be considered as legal advice.   Employers must consult their lawyer for legal matters and EPA/OSHA consultants for matters related to Environmental, Health & Safety. The article was authored by Sam Celly of Celly Services, Inc. who has been helping automobile dealers comply with EPA and OSHA regulations since 1987.  Sam received his BE (1984) and MS (1986) in Chemical Engineering, followed by a J.D. from Southwestern University School of Law (1997).  Our newsletters can be accessed at www.epaoshablog.com.  Your comments/questions are always welcome.  Please send them to sam@cellyservices.com.

New regulations require California Haz Waste generators to report critical waste related information to regulatory agencies including first responders.  The requirements are: Add Quick Reference Guide to annual CERS: CSI will complete on your behalf.Label hazards on hazardous waste containers: Your haz waste hauler will provide them.Provide 3 emergency response contacts: Complete attached doc. Email to us ASAP.

Introduction

The California Department of Toxic Substance Control (DTSC) has adopted the federal Generator Improvements Rule (GIR) to provide additional environmental protections and to gain swift access to critical facility information. Generally, the GIR applies to all businesses who generate hazardous waste, regardless of the waste quantity generated. GIR requires the submission of a Quick Reference Guide (QRG) that contains three emergency contacts, waste generated onsite, and facility maps with special requirements (Large Quantity Generators only).  See definitions on page 2.

California Environmental Reporting System (CERS) requires all businesses that handle hazardous materials in quantities equal to or greater than 55 gallons of liquids, 500 pounds of solids, or 200 cubic feet of gas at standard temperature and pressure or quantities of extremely hazardous substances above the threshold planning quantity to:

• Inventory their hazardous materials,
• Develop a site map,
• Develop an emergency plan,
• Implement a training program for employees, and
• Submit a CERS report annually.

The CERS annual report includes: Business owner/operator details, hazardous materials and waste inventory matrix, facility identification and operations overview, emergency communication phone number, notifications emergency containment, cleanup procedures, facility evaluation, and arrangement of emergency services, emergency equipment, earthquake vulnerability, employee training details and list of other attachments.  The attachments this year include the GIR.

GIR Hazardous Waste Labeling and Marking Requirement

Key GIR requirements for labeling and recordkeeping of hazardous waste tanks/containers are:

1. Generators must mark or label their tanks with an indication of the hazards of the contents.  Labels from DOT OR OSHA Haz-Com OR NFPA are acceptable.

Your waste hauler may provide warning labels for waste tanks.

Example of NFPA labels: Used Oil Placard:   Used Coolant Placard:

Some sources to buy NFPA labels: NFPA Used Oil Label Blank NFPA Diamond Label

• Generators must use inventory logs, monitoring equipment, or other records to demonstrate that hazardous waste has been emptied within the applicable time period of first entering the tank/container. Your waste haulers will provide labels highlighting dates of accumulation. Dealers must ensure hazardous waste is not stored past the applicable time period. Contact waste hauler if labels are missing or past the storage time limit.
• Generators must keep inventory logs or records on site and readily available for inspection. Pick-up receipts/manifests related to environmental matters must be kept in Black Box provided by Celly Services for ready access when the facility is inspected.

WHAT WE NEED FROM YOU RIGHT AWAY Names of three emergency coordinators and a 7-day/24-hour emergency telephone number. Please use the attached form to provide names and numbers for your dealership. Note on how to select emergency contacts for your facility. The contacts should: Have knowledge of the location and type of haz wastes and haz materials.Have managerial level decision making capability.Live relatively close by in order to respond to an after-hour emergency quickly.

Large Quantity Generator (LQG): “Generators of 1,000 kg or more of hazardous waste per calendar month (excluding universal wastes).” About a total of 300 gallons/month of used oil, used coolant etc. will place you above the 1,000 kg threshold. Small Quantity Generators generate less than 1,000 kg of hazardous waste/mo.

Ref: Frequently Asked Questions for the Adoption of Generator Improvements Rule (GIR) in California | Department of Toxic Substances Control

CERS Portal

DISCLAIMER: The contents of this newsletter are for informational purposes only and are not to be considered as legal advice. Employers must consult their lawyer for legal matters and EPA/OSHA consultants for matters related to Environmental, Health & Safety. The article was authored by Sam Celly of Celly Services, Inc. who has been helping automobile dealers in Arizona, California, Hawaii, Idaho, Nevada, New Mexico, New York, Texas, and Virginia comply with EPA and OSHA regulations for over 35 years. Sam is a Certified Safety Professional (No. 16515) certified by the National Board of Certified Safety Professionals. Sam received his BE (1984) and MS (1986) in Chemical Engineering, followed by a J.D. from Southwestern University School of Law (1997). Sam is a member of the American Chemical Society (No. 31176063), American Industrial Hygiene Association (No. 124715), and National Association of Dealer Counsel (NADC). Sam also serves on the Board of Orange County American Industrial Hygiene Association and on CA Industrial Hygiene Council (CIHC). Our newsletters can be accessed at www.epaoshablog.com. Your comments/questions are always welcome. Please send them to sam@cellyservices.com.

COMPLETE THE FORM BELOW AND EMAIL TO SUPPORT@CELLYSERVICES.COM Facility Name ______________________________________________________________________________   Street Address _____________________________________________________________________________   City, State, Zip _____________________________________________________________________________   NOTE 1: How to select emergency contacts for your facility.  The contacts should: Have knowledge of the location and type of haz waste and haz material.Have managerial level decision making capabilityLive relatively close by to respond to an after-hour emergency quickly NOTE 2: Following guidance in Note 1 above, preferably select your Service Manager, Parts Manager, and General Manager.  For bigger stores or multiple dealerships select your Director of Fixed Operations. Facility Emergency Contacts: Primary Emergency Coordinator: Name: _____________________________________________________ Title: _____________________________________________________ 24/7 Emergency Phone Number: _____________________________________________________ Email: _____________________________________________________ Secondary Emergency Coordinator and phone number: Name: _____________________________________________________ Title: _____________________________________________________ 24/7 Emergency Phone Number: _____________________________________________________ Email: _____________________________________________________ Tertiary Emergency Coordinator and phone number: Name: _____________________________________________________ Title: _____________________________________________________ 24/7 Emergency Phone Number: _____________________________________________________ Email: _____________________________________________________ Important: Facility contacts must be updated within 30 days when there is a change. Email your Celly Services representative with the updated Facility Contact list.

BACKGROUND: Safety inspections of the shop and parts department have revealed that many employees are not wearing appropriate footwear that can adequately protect them from foot injuries caused by crushing or falling objects, such as a rotor or a battery.  Sharp objects left on the shop floor can also penetrate the shoe and injure the foot. Footwear in the shop area must be slip resistant to protect employees should they encounter slippery surfaces (slip hazards are common due to accidental spills of lubricants in the shop).  The porters are subject to abnormally wet locations (car wash) and as such, their shoes must provide traction.  Recently, an automobile dealer was cited for failure to provide safety shoes.  A penalty of $5850 was assessed by Cal/OSHA for this serious violation.  California Court of Appeals has also upheld a citation against employers not providing proper safety footwear. See Home Depot U.S.A., Inc. v. Cal. Occupational Safety & Health Appeals Bd., E070417 (Cal. Ct. App. Oct. 17, 2019)

 

WHAT DO THE CALIFORNIA REGULATIONS SAY:

The Cal/OSHA regulation (T8CCR3385) is stated as follows:

1. Appropriate foot protection shall be required for employees who are exposed to foot injuries from electrical hazards, hot, corrosive, poisonous substances, falling objects, crushing, or penetrating actions, which may cause injuries or who are required to work in abnormally wet locations.
2. Footwear which is defective or inappropriate to the extent that its ordinary use creates the possibility of foot injuries shall not be worn.
3. (1) Protective footwear for employees purchased after January 26, 2007 shall meet the requirements and specifications in American Society for Testing and Materials (ASTM) F 2412-05, Standard Test Methods for Foot Protection and ASTM F 2413-05, Standard Specification for Performance Requirements for Foot Protection which are hereby incorporated by reference.  The ASTM standard as quoted in the OSHA standard has been updated.  See note below.

 

Note 1: ASTM F2412-18a and ASTM F2413-18 are the most current standards in the industry. ASTM F2413-18 contains basic requirements to evaluate footwear, which include: Impact resistance (I), Compression resistance (C), Metatarsal protection (MT), and Conductive properties (CD) to limit static electricity buildup. In addition to these requirements, this standard requires labeling on the safety footwear to identify specific protections.

Note 2:  Cal/OSHA regulations, as mentioned above, state that footwear that creates the possibility of foot injuries shall not be worn and hence, any shoes that may cause injuries from ordinary use in the shop area should not be used.

WHAT DO THE FEDERAL REGULATIONS SAY: 

Federal Regulation as stated in CFR 1910.136(a) is as follows:  The employer shall ensure that each affected employee uses protective footwear when working in areas where there is a danger of foot injuries due to falling or rolling objects, or objects piercing the sole, or when the use of protective footwear will protect the affected employee from an electrical hazard, such as a static-discharge or electric-shock hazard, that remains after the employer takes other necessary protective measures.

Note 3:  The criteria for protective footwear is listed in 1910.136(b)(1)(i) where the footwear must meet the ASTM F-2412-2005, “Standard Test Methods for Foot Protection,” and ASTM F-2413-2005, “Standard Specification for Performance Requirements for Protective Footwear,” which are incorporated by reference in § 1910.6.  As noted above the ASTM regulations have been updated in 2018 and should be used for selection of footwear.

 

BEST PROTECTION:  Shoes for staff must meet ASTM standard as listed in Note(s) above.  The shoe must have metatarsal protection with a skid resistance sole. Metatarsal protectors consist of a guard that fits over the instep protecting the top of the foot from heavy items and are normally manufactured from aluminum, steel, or lightweight composites.  The car wash staff and any staff that encounter slippery surfaces must also wear shoes with soles that provide slip resistance and good traction.

HAZARD ASSESSMENT: OSHA regulations require that the employer conduct a workplace hazard assessment and provide PPE for protection from physical and health hazards present at the workplace.  If the hazard assessment of parts and service employees indicates the possibility of a foot hazard injury from falling objects, PPE should be provided.  See Title 8 California Code of Regulations Section 3380.  Fed-OSHA requirements on Hazard Assessment and Personal Protective Equipment selection are listed under CFR 1910.132 (a-d).

 

WHO PAYS-CA: The California Labor Code requires employers to “furnish and use safety devices and safeguards…” (Labor Code § 6401). The term “safety device” includes “any practicable method of mitigating or preventing” danger. Protective footwear is covered as a safety device. The Labor Code also requires employers to “provide and use safety devices and safeguards reasonably adequate to render the employment and place of employment safe.” (Labor Code § 6403).  Legal opinion on this matter has been made clear by the California Supreme Court. The Court has ruled that the words “provide” and “furnish” mean that the employer both supplies and pays for the personal protective gear.  (See Bendix Forest Products Corp. v. Division of Occupational Safety & Health (1979) 25 Cal. 3rd 465, 471-473).

 

WHO PAYS-Federal:  The shoes with metatarsal protection and slip resistant shoes are considered specialty footwear and require the employer to pay for the protective footwear.  OSHA has exempted employers from payment when the safety shoes are non-specialty type.

 

PROTECTIVE SHOE POLICY & ENFORCEMENT: The employer must provide shoes to each employee subject to foot injury hazards. Since shoes must be fitted for size and comfort, it is practical to seek help from a professional shoe supply company. Replacement upon wear and tear of the PPE is also the responsibility of the employer, along with instructions on proper usage, care, cleanliness, and maintenance. A written protective footwear policy should be adopted and distributed to all employees, and employee acknowledgment should be retained in files. Enforcement of policy, along with disciplinary action against employees violating the policy must also be put into effect.

 

SUMMARY: Proper footwear for certain employees is not an option but is a requirement under the law. Employees with their feet protected are less likely to be injured from falling objects. Shoes with good traction help mitigate slip and fall hazards. Fewer injuries translate to fewer workers’ compensation claims and a reduction in related premiums. Improved productivity, better employee morale, and increased shop efficiency are also a given. 

DISCLAIMER:  The contents of this newsletter are merely for informational purposes only and are not to be considered as legal advice.   Employers must consult their lawyer for legal matters and EPA/OSHA consultants for matters related to Environmental, Health & Safety. The article was authored by Sam Celly of Celly Services, Inc. who has been helping automobile dealers comply with EPA and OSHA regulations since 1987.  Sam received his BE (1984) and MS (1986) in Chemical Engineering, followed by a J.D. from Southwestern University School of Law (1997).  Our newsletters can be accessed at www.epaoshablog.com.  Your comments/questions are always welcome.  Please send them to sam@cellyservices.com.

POST YOUR INJURY LOG (300A) ON EMPLOYEE NOTICE BOARD 2-1-21 TO 4-30-21 LOG 300, 300A & 301 REQUIRED FOR AUTO DEALERS

 

Background: Cal/OSHA and Fed-OSHA require auto dealers and other employers to keep a record of occupational injuries and illnesses using OSHA Log 300 and to post a summary on the employee notice board from February 1 to April 30, 2021.

 

Forms & Guidance to Fill: Fed-OSHA and Cal/OSHA forms are identical in nature.

 

California Forms: https://www.dir.ca.gov/dosh/DoshReg/ApndxA300Final.pdf (Fillable Form) Cal/OSHA exempts certain industries: https://www.dir.ca.gov/t8/14300_2.html

 

Federal-OSHA: https://www.osha.gov/recordkeeping/RKforms.html ·        OSHA Form 300 – Log of Work-Related Injuries & Illnesses ·        OSHA Form 300A – Summary of Work-Related Injuries & Illnesses ·        OSHA Form 301 – Injury & Illness Incident Report Fed-OSHA exempts certain industries: https://www.osha.gov/recordkeeping/ppt1/RK1exempttable.html

 

Posting Requirements: Form 300A (Summary of Work-Related Injuries & Illnesses) for 2020 must be posted on the employee notice board from February 1, 2021 to April 30, 2021. ONLY Form 300A needs to be posted. Disclosing injured employee name on the notice board is a big no-no.

 

Cal/OSHA Guide on Completing Forms: http://www.dir.ca.gov/dosh/dosh_publications/reckeepoverview.pdf   Fed-OSHA Guide on Completing Forms: https://www.osha.gov/recordkeeping/tutorial.html

 

Tutorial for Completing Forms: A tutorial is available to assist in completing the forms at https://www.osha.gov/recordkeeping/tutorial.html

 

Recordkeeping Questions & Answers: See https://www.osha.gov/recordkeeping

 

First-Aid Not Recordable on Log 300: First-aid is https://www.osha.gov/recordkeeping/firstaid_list.pdf​.   Serious Injury: Call your local OSHA office to report serious injury. Cal/OSHA’s phone number is on the employee labor law poster. Fed-OSHA reporting line is 1-800-321-6742 (OSHA). California and Federal definitions of serious injury differ. California Code on reporting serious injury is https://www.dir.ca.gov/title8/342.html.

 

Commentary: The forms are provided as a tool for the employer to document injuries, inform employees of accidents at the facility and allow OSHA inspectors to obtain a quick summary of accidents in the workplace.  Employers must use this log as a management tool to gauge the nature and frequency of injuries in order to determine corrective measures for accident elimination and counsel employees who show up on the accident log on a repeated basis. Certain highlights of the forms are as follows: ·     Requires records to include any work-related injury or illness resulting in one of the following: death, days away from work, restricted work or transfer to another job, medical treatment beyond first-aid, loss of consciousness, or diagnosis of a significant injury or illness by a physician or other licensed health care professional.  ·     Requires a significant degree of aggravation before a preexisting injury or illness becomes recordable. ·     Requires employers to record cases when injured or ill employees are restricted from their “normal duties,” which are defined as work activities employees regularly perform at least once per week. ·     You may stop counting days of restricted work activity or days away from work once the total of either or the combination of both reaches 180 days. ·     Focus on days away or days restricted or transferred. Rules rely on calendar days instead of workdays! ·     Requires employers to establish a procedure for employees to report injuries and illnesses and to tell their employees how to report. Employers are prohibited from discriminating against employees who report. Employee representatives will have access to those parts of OSHA Form 301 relevant to the employees they represent.

 

Cal/OSHA Reporting Guidelines: An employee trips in the service driveway of your dealership during normal course of business and seeks medical treatment. Employee comes back to work the next day but continues treatment of physiotherapy and medication. After 6 months, the MD states that only surgery can cure the knee problem and the employee proceeds with knee replacement surgery. The issue is whether this knee accident is now Cal/OSHA reportable as a serious injury accident. Yes, the accident must be reported to Cal/OSHA under the serious injury reporting statutes (Section 342). Employers are required to report incidents within 8 hours to Cal/OSHA as follows: ·     Any fatality. ·     Any inpatient hospitalization for work related injury or illness, for anything other than medical observation or diagnostic testing must be reported. ·     An amputation, the loss of an eye, or any serious degree of permanent disfigurement, but does not include any injury or illness or death caused by an accident on a public street or highway, unless the accident occurred in a construction zone.

 

Fed-OSHA Reporting Guidelines: Employers have to report the following events to Fed-OSHA: ·     All work-related fatalities ·     All work-related in-patient hospitalizations of one or more employees ·     All work-related amputations ·     All work-related losses of an eye Employers must report work-related fatalities within 8 hours of finding out about it. For any in-patient hospitalization, amputation, or eye loss employers must report the incident within 24 hours of learning about it. Only fatalities occurring within 30 days of the work-related incident must be reported to OSHA. Furthermore, for an inpatient hospitalization, amputation or loss of an eye, then incidents must be reported to OSHA only if they occur within 24 hours of the work-related incident.

 

Questions Asked During Reporting: 1.  Time and date of accident/event 2.  Employer’s name, address and telephone number 3.  Name and job title of the person reporting the accident 4.  Address of accident/event site 5.  Name of person to contact at accident/event site 6.  Name and address of injured employee(s) 7.  Nature of injuries 8.  Location where injured employee(s) was/were taken for medical treatment 9.  List and identity of other law enforcement agencies present at the accident/event site 10.  Description of accident/event and whether the accident scene or instrumentality has been altered.

 

Electronic Recordkeeping Submission: Establishments with 250 or more employees that are currently required to keep OSHA injury and illness records must electronically submit information from OSHA Forms 300 — Log of Work-Related Injuries and Illnesses, 300A — Summary of Work-Related Injuries and Illnesses, and 301 — Injury and Illness Incident Report. See https://www.osha.gov/Publications/OSHA3862.pdf.

 

 

 

DISCLAIMER: The contents of this newsletter are merely for informational purposes only and are not to be considered as professional advice. Information from www.osha.gov was used to prepare part of this newsletter. Employers must consult their lawyer for legal matters and safety consultants for matters related to safety. The article was authored by Sam Celly of Celly Services, Inc. who has been helping automobile dealers comply with EPA & OSHA regulations since 1987. Sam received his BE (1984) and MS (1986) in Chemical Engineering followed by a J.D. from Southwestern University School of Law (1997). Our newsletters can be accessed at www.epaoshablog.com. Your comments/questions are always welcome. Please send them to sam@cellyservices.com.