right-to-know laws at your dealership
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Right-to-Know Laws at Your DealershipTRANSCRIPT
Right-to-Know Laws at Your Dealership
Nick Bujeaud
District Manager
Past, Present, and Future
If you have questions during the presentation, please submit them using the “Questions” feature
QUESTIONSQuestions
Today’s Agenda
Where did these laws come from and why it’s important to comply
What you need to have in place at your dealership
Globally Harmonized System (GHS)
Nick’s “Do it Now” Top 5
Why is Right-to-Know Important?
Employee safety and morale
Community responsibility
Cost savings
Litigation
Compliance
The History: Workplace Right-to-Know:OSHA’s Hazard Communication Standard
• 1970 – OSHA established to standardize safety for US workers
• 1983 – OSHA’s Hazard Communication Standard to protect employees potentially exposed to hazardous chemicals
29 CFR 1910.1200
HazComm Needs: Written Program
• List of hazardous chemicals
• Hazards of non-routine tasks
• Multi-employer workplace• Labels and other forms of
warning• Safety data sheets• Employee information
and training
HazComm Needs: Chemical Inventory
Chemical Name Location Part Number
Brake Kleen Parts and Service BG-310
Automatic Transmission Fluid Oil Storage Room, Service ATF-111
5W30 Motor Oil Oil Storage Room, Service MOP12345
Windshield Washer Fluid Parts and Service 43-899
Wire Wheel Acid Cleaner Recon Department FT-16
Carburetor Cleaner Parts and Service CARB6789
Upholstery Cleaner Recon Department 161718
Parts Cleaning Solvent Service SK-10
HazComm Needs: MSDS
HazComm Needs: Container Labeling
HazComm Needs: Employee Training
• Facility operations where chemicals are present
• Location of written program and MSDS
• Methods used to detect presence or release
• Physical health hazards
• Measures employees can take to protect themselves
• Details of the written program
WHEN REQUIRED?• At time of initial
assignment
• When new chemical hazard is introduced
The History: Community Right-to-Know
• Dec. 2, 1984 – The Bhopal Disaster at Union Carbide India Limited
• 1985 – CA Democrat Henry Waxman called for the U.S. Inquiry into the Bhopal Disaster
• 1986 – U.S. Congress passed the Emergency Planning and Community Right-to-Know Act
Estimates of up to 16,000 deaths and 550,000 injuries and gas related deaths as a result of releasing 40 tons of Methyl Isocyanate (MIC) into the air
EPCRA Reporting Requirements (Sections 311-312)
• Increase community awareness and facilitate emergency planning
• For anyone required by HazComm standard to prepare a MSDS
Thresholds:• 10,000 pounds for hazardous chemicals
• Threshold planning quantity of extremely hazardous substances
Report to:
SERC, LEPC, and local fire department
NOTE:
Local municipalities reserve the right to make these reporting requirements more stringent
EPCRA Reporting Requirements (Sections 311-312)
CONVERSIONS
Motor Oil 10,000 lbs. 1,388 gallons
Gasoline 10,000 lbs. 1,587 gallons Antifreeze 10,000 lbs. 1,075 gallons
• United Nations
• Provide consistency of chemical safety document
• More efficient access
• Easier to understand
• U.S. – HazComm 2012, “Right-to-Understand”
The Future: Globally Harmonized System (GHS)
December 2013:
Training to include new 16 part “Safety Data Sheets” and labeling requirements
Written hazard communication program update
The Future: Globally Harmonized System (GHS)
June 2015:
All safety data sheets must be in the uniform 16 section format
The Future: Globally Harmonized System (GHS)
December 2016:
The Future: Globally Harmonized System (GHS)
Nick’s Do it Now Top 5!
1. Chemical inventory and inventory your chemicals (slides 6 and 12)
2. Create a written hazard communication plan (slide 5)
3. Walk your facility. Are all containers clearly labeled?
4. Multi-employer workplace: have a conversation about right-to-know with contractors
5. New hire safety training program (slide 9)
Thanks for your attention today!
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