Download Available: How To Handle An OSHA Inspection

Under the Occupational Safety and Health Act of 1970 (the Act), the Occupational Safety and Health Administration (OSHA) is authorized to conduct workplace inspections and investigations to determine whether employers are complying with standards issued by the agency. OSHA also enforces Section 5(a)(1) of the Act, known as the “General Duty Clause,” which requires that every working man and woman must be provided with a safe and healthful workplace. OSHA does not have staff to go and inspect all employers so an inspection is usually a result of a complaint from an agency (fire department, hospital, paramedics), disgruntled employee, or a third party having knowledge of a violation.

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Download Available: Eye Wash & Deluge Shower Requirements

Current OSHA regulations require that an emergency eyewash stations be provided whenever employees may come into contact with chemicals that can cause corrosion, severe irritation, or permanent tissue damage.  Conditions such as battery charging in shop, usage of corrosive chemicals or irritants in detail or shop require the installation of an eye wash station and a deluge shower depending upon the chemicals used in the shop area.

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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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Download Available: NEWS AND VIEWS

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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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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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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