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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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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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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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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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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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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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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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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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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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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