government and the shop environment · emphasis programs and initiatives ... programs osha provides...
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Government and the Shop Environment
Presented by:Governmental Committee
Darrell Amberson, Chair, Lamettry’s Collision
Bob Redding, Vice Chair, Automotive Service Association
Janet Chaney, Vice Chair, Cave Creek Business Development
Brandon Thomas, GMG EnviroSafe, Inc
Jeanne Silver, CARSTAR Mundelein
John Eck, General Motors
Russell Thrall, Collision Week
Stephan Regan, Regan Strategies
Steve Daniel, Lamettry’s Collision
Chad Sulkala, Allstate
Governmental Committee Members
• March 2018- the U.S. Senate passed S. 2155, the “Economic Growth, Regulatory Relief and Consumer Protection Act”• The House passed Dodd-Frank reform legislation repealed the Federal Insurance Office (FIO).
The Senate bill does not address the FIO. The Senate and House must work out their differences in conference or the House could accept the Senate language.
• October 2017- the U.S. Senate Committee on Commerce, Science, and Transportation approved S. 1885, the American Vision for Safer Transportation Through Advancement of Revolutionary Technologies (AV START) Act• Despite bipartisan support, several Senators have objected to the bill, citing insufficient
consumer protections.
• The Senate bill contains language addressing data access and cybersecurity. The House previously passed their version, H.R. 3388, the SELF DRIVE Act.
Legislative Update, Federal
• Indiana SB 164- Contained language that would allow a work-around for insurers by recommending adherence to “industry standards” as an alternative to the vehicle manufacturer’s repair procedures. The bill stalled in conference in early March.
• Rhode Island SB 2679- Prohibits insurance companies from mandating the use of aftermarket parts without consent of vehicle owner for a collision-damaged part of a vehicle less than 48 months beyond manufacture date. The bill also contains language regarding OEM repair procedures.
Legislative Update, States
Moderator:
Brandon Thomas
CEO, GMG EnviroSafe
John Olaechea, CSP
Compliance Assistance Specialist
OSHA – Region VIII
Christine Hoefler
Small Business Assistance Program Coordinator
Colorado Department of Public Health & Environment
Panelists:
Questions?
John OlaecheaO c c upat i ona l S afety and Hea l th A dm i n i st rat i on
OSHA Update for Automotive Services
John Olaechea, CSPCompliance Assistance Specialist
OSHA Region VIII1244 Speer Blvd
Suite 551Denver, CO 80204
Update Topics
Emphasis Programs and Initiatives
Automotive Services Emphasis Program and Associated Hazards
Compliance Assistance
Questions
Englewood AO
303-843-4500
Denver AO - 303-844-5285
Private-Sector and Federal Employers in Colorado, North Dakota, South Dakota and Montana.
Within Wyoming and Utah, Private and Public Sectors are covered by State Plan OSHA and Federal Employers are covered by Federal OSHA.
www.osha.govWe Can Help
www.osha.gov
OSHA Region VIII Jurisdiction
State Plan vs Federal
Safety and Health enforcement for most private sector employers in the 50 States and US jurisdictions is covered by:
OSHA (federal)
OSHA-approved State Plan
Colorado is Federal OSHA
State Plan
Must set standards “at least as effective” as OSHA
Many adopt the federal standard
Some create their own similar standards
Some adopt federal standards and go above and beyond developing extra standards
Emphasis programs may be different from federal programs
OSHA provides up to 50% of the funding and monitors the state program through audits
State Plan vs Federal
* Indicates State Plan in operation
National and Regional Emphasis Programs
How Does OSHA come to inspect a facility?
Programmed Inspections
National, Regional or Local Emphasis Programs
Unprogrammed Inspections
Complaints (from employees or their reps)
Referrals (from other sources)
Reports of fatalities or accidents
Have you had an OSHA inspection?
1 2
56%
44%
Yes
No
FY 17 NEP’s
Amputations in Manufacturing Lead Exposures (GI and Construction) Silica Exposures (GI and Construction) Hexavalent Chromium Exposures Process Safety Management Combustible Dust Trenching and Excavation Primary Metals Industries (Foundries) Shipbreaking
https://www.osha.gov/dep/neps/nep-programs.html
FY 17 Regional and Local EPs
Regional Emphasis Programs Fall Hazards in Construction Roadway Work Zone Activities Silica in Cut Stone and Slab Handling Oil and Gas Industry Grain Handling Facilities Workplace Violence in Residential Intellectual and Developmental
Disability Facilities
Local Emphasis Programs Hazards in Automotive Services (Billings/Bismarck/Englewood) Asbestos Abatement (Englewood) Scrap & Recycling (Englewood) Wood Manufacturing and Processing (Billings) Aircraft Support and Maintenance Facilities (Englewood)
https://www.osha.gov/dep/leps/leps.html
NAICS Codes covered by the Hazards in Automotive Services EP
What is the most frequently cited OSHA standard in the auto/body industry?
1 2 3 4 5
24%
0% 0%
10%
66%
Hazard Communication
Fork Lifts
Respiratory Protection
Fire Extinguishers
Paint Match Guarantee
Frequently Cited OSHA Standards
https://www.osha.gov/pls/imis/citedstandard.html
Top Automotive Violations
Hazards in Automotive Services Emphasis Program
Automotive Lifts
Annual inspections
Employee Training
Labels maintained
Proper operation required
Have you had your lifts inspected in the last year by a qualified inspector?
1 2
62%
38%
Yes
No
Automotive Lifts
Minimum of annual inspection per ANSI/ALI ALOIM:2008
Section 5.5 requires frequency recommended by mfg but at least annual
Section 5.6: Inspection Points
Mfg checklist if available
Appropriate checklist from appendix
5.6 lists inspection points to be covered
Automotive Lifts
Qualified Inspector (Section 5.2)
9 qualification categories listed
Training described
Inspection must be documented and maintained
Observations and findings
Subsequent repairs and replacements
Automotive Lifts
Operator Qualifications (Section 4.1)
Written/oral communications
Mathematical/mechanical/electrical principals
Demonstrated physical ability
Operator Training (Section 4.2)
Manufacturer instructions
ALI publications: Lifting it Right, Safety Tips and Quick Ref Guide for Vehicle Lifting Points and Frame Engaging Lifts
Document using form in appendix
Common Health Hazards in the Automotive Services Industry
Chemical Usage/Hazard Communication
Isocyanates
Respiratory Protection
Hydrogen Fluoride/Hydrofluoric Acid
Personal Protective Equipment (PPE)
Methylene Chloride
Noise
Paint/Solvent Storage (Ventilation)
Paint Booths
Silica and Asbestos
Hazard Communication 1910.1200
Provide Information to employees about the hazards of the chemicals in the workplace
Labelling
Safety Data Sheets
Training
Written Program
2012 Update to the GHS
Hazard Communication Resourceswww.osha.gov
Methylene Chloride (1910.1052)
Often used as a stripper
Carcinogen
Expanded Health Standard Requiring:
Exposure Assessment
Respiratory Protection
Eyewash
Regulated Area
Medical Surveillance
Respiratory Protection (1910.134)
Written Program
Medical Evaluations
Fit Tests
Training
Proper Storage (not in the paint room)
Change schedule (based on what?)
Personal Protective Equipment (1910.132)
Complete a hazard assessment (JHA)
Eye protection
Skin protection (suits for painters)
Gloves (compatible with the chemical)
Paint/Solvent Storage Rooms 1910.106
Construction
Fire resistive
Liquid tight, sills
Electrical (Subpart S)
Ventilation
Tied to lights
6 air changes per hour
Mechanical vs gravity
Electrical Hazards
Electrical Hazards
Electrical Hazards in Wet Conditions
Use grounded or double insulated tools
Cords free of damage
Frequent inspection of equipment
Compressed Air
Combustible Dust
Metal dusts such as aluminum can cause fire/deflagration/explosion
Hazards created when:
Dust is combustible
Dust is dispersed in air and concentration is above MEC (min explosible conc)
Ignition source exists
Confinement
Combustible Dust
National Emphasis Program
Citable under: 1910.176 (housekeeping)
1910.94 (ventilation)
General Duty Clause (Section 5a1)
General Duty Clause: NFPA 654 (prevention of fire)
NFPA 484 (combustible metals)
Operator’s manual
Industry practices
Other consensus standards
Combustible Dust
Report a fatality or severe injury
All employers are required to notify OSHA when an employee is killed on the job or suffers a work-related hospitalization, amputation, or loss of an eye.
A fatality must be reported within 8 hours.
An in-patient hospitalization, amputation, or eye loss must be reported within 24 hours.
During business hours, call the nearest OSHA office
Or call the OSHA 24-hour hotline 1-800-321-6742 (OSHA)
Online at www.osha.gov
Be prepared to supply: Name of the establishment, location and time of the incident, names of employees affected, brief description of incident, and a contact person and phone number
How can employers report to OSHA?
Timeline
Final Rule Federal Register Notice – May 12, 2016
Employee Rights effective date – August 10, 2016
Electronic Reporting effective Date – January 1, 2017
Phase-in data submission due dates
Submission
year
Establishments with 250 or
more employees in industries
covered by the recordkeeping
rule
Establishments with
20-249 employees In
select industries
Submission
deadline
2017
CY 2016 300A Form CY 2016 300A Form July 1, 2017
Dec 31,
2017
2018CY 2017 300A, 300, 301 Forms CY 2017 300A Form July 1, 2018
2019 and
beyond
300A, 300, 301 Forms 300A Form March 2
Outreach Materials
Improve Tracking Webpage at http://www.osha.gov/recordkeeping/finalrule/index.html
Link to Rule
FAQs
Fact sheet
Press release
List of covered industries
Compliance Assistance
OSHA Consultation
Free
Confidential
On-site audits
Training
Sampling/Monitoring
Program Review
http://csu-
cvmbs.colostate.edu/academics/er
hs/osha/Pages/default.aspx
OSHA Compliance Assistance
Regional Compliance Assistance Newsletter
Send request to [email protected] subscribe
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Q & A
Questions?
Disclaimer
This information has been developed by an OSHA Compliance Assistance Specialist and is intended to assist employers, workers, and others as they strive to improve workplace health and safety. While we attempt to thoroughly address specific topics, it is not possible to include discussion of everything necessary to ensure a healthy and safe working environment in a presentation of this nature. Thus, this information must be understood as a tool for addressing workplace hazards, rather than an exhaustive statement of an employer’s legal obligations, which are defined by statute, regulations, and standards. Likewise, to the extent that this information references practices or procedures that may enhance health or safety, but which are not required by a statute, regulation, or standard, it cannot, and does not, create additional legal obligations. Finally, over time, OSHA may modify rules and interpretations in light of new technology, information, or circumstances; to keep apprised of such developments, or to review information on a wide range of occupational safety and health topics, you can visit OSHA’s website at www.osha.gov.
Working Together, We Can Help
www.osha.gov
800-321-OSHA (6742)