Top 10 OSHA Citations of 2016, October 2016

Every October, the Department of Labor’s Occupational Safety and Health Administration releases a preliminary list of the 10 most frequently cited safety and health violations for the fiscal year, compiled from nearly 32,000 inspections of workplaces by federal OSHA staff.  One remarkable thing about the list is that it rarely changes. Year after year, thousands of the same on-the-job hazards are cited, any one of which could result in a fatality or severe injury.

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Injury Log Requirements & Accident Reporting to Fed-OSHA, September 2016

LOG 300, 300A & 301 REQUIRED FOR AUTO DEALERS

Background: Cal/OSHA now requires auto dealers and other employers to keep a record of occupational injuries and illnesses using OSHA Log 300. We note that Fed-OSHA had issued these requirements to auto dealers in 2015.

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Heat Illness Prevention Program Training, May 2016

BackgroundCal/OSHA heat illness prevention regulation (T8CCR3395) became effective on May 1, 2015.  This standard applies to outdoor areas of employment.  When porters are parking cars and salespersons are showing automobiles on display to customers or taking them on test drives, they are considered to be working outdoors.  Fed-OSHA also requires that employees be trained in heat illness prevention under a general injury prevention standard.  Cal/OSHA enforcement details are at http://www.dir.ca.gov/dosh/heatillnessqa.html.

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California Exemption to Log 300 & First Aid Kit, January 2016

CALIFORNIA LAW ON LOG 300

As of the start of 2016, the California Occupation Health & Safety Standards Board has not approved of the changes to the recordkeeping guidelines. This process can take up to six months, essentially pushing the compliance date to January 1, 2017.

In summary, auto dealers in California are currently exempt from Log 300 requirements.  See https://www.dir.ca.gov/dosh/DoshReg/FinalEmpRec.html.  Cal/OSHA has inspected dealers for regulatory violations and has not requested to see the Log 300 as they are exempt per state regulations.

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Changes to CA Environmental Regulations & OSHA Penalties, December 2015

CAL-EPA REGULATIONS EFFECTIVE 1/1/16

90-Day Storage Limit:  Automobile dealerships generating more than 1,000 kg of hazardous waste per month must  dispose of hazardous waste within 90 days (otherwise the facility must obtain a storage permit, an arduous process).  Almost all dealerships generate more than 1,000 kg (about 300 gallons) of used oil and used coolant per month and hence, must limit storage to 90 days.  In the past, local enforcement agencies excluded used oil from these calculations so all dealers fell below the 1,000 kg/mo. level.  The new law, SB 612, clarifies the fact that all hazardous waste generated at the facility are counted towards the 1,000 kg/mo. calculation.  For facilities generating less than 1,000 kg/mo. of hazardous waste (Federal Term: Small Quantity Generator), the maximum accumulation time is 180 days or 270 days if the waste must be transported more than 200 miles for treatment and disposal.

In summary, each hazardous waste storage container must have a proper date of accumulation marked on each container along with EPA required waste labeling and secondary containment requirements.  The waste must be disposed of within 90 days of the start date.  Almost all facilities have used oil pickup on a 30-day or more frequent cycle.  However, other smaller waste streams, such as used coolant or contaminated fuel, are not on the radar screen.  Dealers must ensure that these wastes are now on a 90-day pickup cycle through a licensed and registered hazardous waste hauler.  Contact your hauler to set up a required pickup schedule immediately.

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Foot Protection Requirements, October 2015

BACKGROUND: Safety inspections of the shop, parts, and car wash area have revealed that many employees are not wearing appropriate footwear that will protect them from foot injuries caused by crushing or falling objects, such as a rotor or a battery.  Penetrating actions may happen from a sharp object left on the shop floor. Also, footwear in the shop area must be slip resistant when employees are working on slippery surfaces, since slip hazards are common due to accidental spills of lubricants in the shop.  The porters in car wash are also subject to slip and fall hazards created by water and/or soap on the floor, and as such, their shoes must provide traction.

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Accident Investigation: The Who, What, When, Where, Why, and How, May 2015

Accident investigation should be the cornerstone of any safety program.  Many safety programs concentrate on safety inspections and training, but omit accident investigation.  Investigating accidents is not only a good idea, but also a requirement.  Below, we provide some guidance and tools to complete an accident investigation.

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