Safety is More Than Wearing Safety Glasses, May 2014

Download Available: Safety Is More Than Wearing Safety Glasses

Many dealers think that having a safety inspection and correction of hazards constitute an effective safety program, or better still, compliance with OSHA regulations is an effective means to gauge safety.  Nothing could be farther from the truth.  Over my 25 years of experience with dealers in the safety arena, I have found these six to be the most effective means to reduce injuries at the workplace and effectively reduce premiums.

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News and Views, May 2014

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CA OSH APPEALS BOARD DECISION: EYE-WASH STATIONS IN PARTS DEPT.

Background:  Existing law requires an employer to provide eye wash stations that comply with ANSI standards.  Eye wash stations must be within 10 seconds walking distance and not over 100 feet from the potential point of hazard.  Most dealers have provided an eye wash in the service department within those stipulations.

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Compliance with 2014 OSHA Heat Illness Prevention, April 2014

Download Available: COMPLIANCE WITH 2014 OSHA HEAT ILLNESS PREVENTION 

Background:  Cal/OSHA released the 2014 Heat Illness Prevention Campaign on March 25, 2014. Workers who are exposed to extreme heat or who work in hot environments are at a risk of heat stress that 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 other physical injuries in workers as it may result in sweaty palms, fogged-up safety glasses, and dizziness.

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Are Your Gas Cans Safe?, February 2014

Download Available: IS MY GAS CAN SAFE

The maintenance and operation of gasoline tanks, both aboveground and underground, has become expensive, highly regulated, and burdensome.  Automobile dealers have resorted to gas dolly equipment where a small amount of gasoline can be added to each new automobile delivered to the dealership.  We note that automobiles delivered to dealerships from manufacturers have very small amounts of gasoline; this being a result of U.S. Department of Transportation (DOT) regulations, which dictate that minimal amounts of gasoline be retained in gas tanks of vehicles in transport.  We write this memo to discuss DOT, OSHA, and CARB regulations applicable to gasoline being transported from a public gasoline station to dealerships for a later fill in automobiles on the lot.

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California ARB Regulations Impacting Aboveground Gasoline Tanks & SCAQMD, January 2014

Download Available: CARB & SCAQMD Regulations Impacting Gas Tanks

CALIFORNIA ARB REGULATIONS IMPACTING ABOVEGROUND GASOLINE TANKS

California Air Resources Board (CARB), a division of Cal-EPA, is the regulatory body that controls emissions of pollutants into the atmosphere in the state of California.  Deadlines for compliance are as follows:  http://www.arb.ca.gov/vapor/cp-206.pdf.

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Top 10 Citations from Federal OSHA in 2013, January 2014

Download Available: Top 10 Hits

The Federal Occupational Health & Safety Administration (OSHA) is responsible for enacting and enforcing safety laws in the US.  In certain states such as California, Cal-OSHA, a state agency, enforces laws that are as stringent as Federal OSHA laws.  The top 10 citations issued to the general industry by Federal-OSHA in 2013 are discussed below.  Top 10 citations for the auto industry may be different than those listed below.

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Safety on Test Drives, January 2013

Download Available: Safety On A Test Drive

Accident 1:  A fatal accident occurred on a test drive when a prospective customer crashed into a car taking a left turn in front of the dealership vehicle.  The customer test-driving the vehicle was found to be driving at an unsafe speed.  During the trial proceedings, the customer stated that the salesperson’s aggressive driving during the first part of the test drive induced the customer to speed, as a result of which the accident occurred.  The salesperson had stated that they should drive fast and “see what this car can do.”  The jury found negligence on part of the dealership and awarded more than $12 million in damages to the family of the deceased.

Solution:  Utilize the Safe Demo Drive Training Memo from CSI to train the sales staff to never drive in an unsafe manner and to obey all traffic laws, especially speed limits, when out on a test drive.

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OSHA Inspection Cheat Sheet, August 2013

Download Available: OSHA Inspection Cheatsheet

Hazard Communication Program (HCP) of OSHA is one of the most frequently cited code violations against automotive dealers.  This program, also known as Right-To-Know in California, requires employers to provide information to employees on hazardous chemicals at the workplace. See http://www.dir.ca.gov/title8/5194.html and 29CFR1910.1200.  We stumbled upon a checklist that OSHA provides to their inspectors to audit the HCP at your workplace.  So now that we know what they are checking for, it is time to get ready for an inspection!  Questions from the checklist are in italics below.  To facilitate a quick compliance audit, we have added a possible short answer after each question.

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GHs, No Big Deal

Download Available: GHS – No Big Deal

A STRAIGHT TALK ON GHS

We wrote to you about Globally Harmonized System (GHS) in the July 2013 Newsletter and the July 2013 monthly training memo on GHS & SDS.  Clients have received last minute newsletters and seminars drumming up business for GHS and some are uncertain as to whether they have complied with their obligations in a timely manner.  We write this memo to reassure clients that they have met the training deadline, presuming the July training was done in a timely manner.  Needless to say, each CSI client will receive training on GHS as part of an ongoing annual Hazard Communication Program (HCP).  Here are answers to some common questions.

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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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