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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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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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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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 →

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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