Many Occupational Safety and Health Administration (OSHA) health & safety standards require employers to provide their employees with protective equipment, including personal protective equipment (PPE), when such equipment is necessary to protect employees from job-related injuries, illnesses, and fatalities. These requirements address PPE of many kinds: hard hats, gloves, goggles, safety shoes, safety glasses, goggles, face shields, chemical protective equipment, and so forth. They state that the employer is to provide such PPE. However, these provisions do not specify that the employer is to provide such PPE at no cost to the employee. Continue reading
Preventing Oil Spills, December 2007
Every so often, a dealership has a spill of oil/ATF from their bulk storage tanks on the floor of the shop area during after-hours or on a weekend. The leak source can be attributed to equipment failure as follows:
Southern California Fires, October 2006
The fires raging through seven counties in Southern California have burnt through thousands of acres and have resulted in widespread loss to property. The intense smoke and ash generated by the fires have resulted in health & safety issues that must be addressed by the employers. A brief summary of the concerns and the employer response is as follows:
Refrigerant Recycling Requirements For Motor Vehicles Under Clean Air Act (CAA), October 2006
Background: Since July 1992, regulations promulgated under the CAA require that motor vehicle air conditioning refrigerant be recycled. Last week, auto dealers in San Francisco area were penalized for violations arising under this act. We must note that these CAA regulations are federal regulations and are applicable to all auto dealers in the US and not to San Francisco dealers alone. To achieve compliance under this regulation, dealers must act as follows:
- Clean Air Act Section 609 Technician Certification Program: All employees working on A/C systems must be trained and tested by a program approved by EPA on how to properly recover and recycle refrigerant (such as Freon 12, HFC-134(a) or any other approved by EPA approved refrigerant).
- Clean Air Act Section 609 Approved Equipment: Must utilize EPA approved recycling equipment and mail a completed USEPA Refrigerant or Recycling Device Acquisition Certification Form to EPA.
Hazardous Waste Manifest Changes, August 2006
Background: Present US law requires that most hazardous waste be transported from hazardous waste generators (dealerships) to permitted recycling, treatment, storage, or disposal facilities (TSDF) by registered hazardous waste transporters, and that each shipment be accompanied by a hazardous waste manifest. The manifest is the document that provides information for “cradle-to-grave” tracking of the hazardous waste.
The good new is that the dealers in California and other states do not have to manifest used oil, used coolant, used oil filters or any of the Universal Wastes. The only waste that is regularly manifested to disposal from dealerships’ is their clarifier sludge. As of July 2000, manifests were no longer required in California for parts cleaning solvent (both water based and petroleum based) even though certain haulers continue to manifest the parts washer waste.
Every state had a different manifest and believe me; they were as different as they could be. California had a six-page manifest with blue, white and yellow colors. Texas, Arizona and Alabama each had them in different colors and formats. In summary, keeping track of manifests was a state-to-state mission and confusing at best. Now the Feds have marched in with a new manifest applicable to one and all in every state.
The Heat is On, May 2006
Background: As summer approaches, and the mercury rises, the probability of an employee illness due to heat stroke/stress rises as well. We write this memo to make you aware of these issues so you can minimize or rather eliminate loss time and other losses due to heat illnesses.
Gasoline Tank Dispenser Hoses – New Requirements in California, February 2006
California regulations require that all underground Gasoline Dispenser Facilities (GDF) be equipped with Phase II vapor recovery systems that have been certified as compatible for fueling vehicles (think hoses) equipped with Onboard Refueling Vapor Recovery (ORVR) systems. So how do you know your GDF needs upgrades? Just give your designated operator or gasoline tank contractor a call and hopefully he/she will have an answer. The deadline for compliance is March 1, 2006.
Fluorescent Lamps & Used Batteries Recycling, January 2006
On February 8, 2006, regulations that require recycling of mercury containing fluorescent lamps, batteries, (non-automotive type) and other mercury containing materials will be prohibited from disposal as ordinary trash and required to be recycled. Some of the Universal Wastes that require recycling is as follows:
- Fluorescent Lamps
- Mercury Containing Switches, Novelties & other products
- Batteries (non-automotive kind)
- Non-Empty Aerosols
- Cathode Ray Tube
Used Oil Recycling Program, November 2005
This is probably the best-kept secret: dealers can get money from the State! First, look at your new oil (or ATF, gear oil) bill. You will see a $0.16 fee for every gallon of oil purchased. You can get this fee back. All you have you do is become a Used Oil Recycling Center. Believe me, there are hundreds of them in L.A. County, so jump on the smart money bandwagon. Dealers, depending upon their oil use, have been getting up to four to five thousand dollars annually. Also, as a business helping to keep the environment clean adds a big plus to your image in the community.
Jail Time? May 2004
There are a few acts of omission or commission by the management that can get them to jail, i.e., the act is considered criminal in nature. Consider the case where a hoist in the shop is “jumping” (mal-functioning). The technician walks into the office of the Service Manager and informs that the hoist is not working and needs immediate repair. The Service Manager is busy in his every day chores and burdened with mounting expenses for the month, delays the repair of the hoist to the next month. Two weeks later, a car falls off the mal-functioning hoist and the operator employee is killed.
Celly Services Inc. 