the good, the bad, and the ugly: osha stories from the field
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www.kpaonline.com
(866) 356-1735
The Good, the Bad, and the Ugly: OSHA Stories From the Field
Thank you for joining the webinar. We will begin at 10am Mountain Time.
www.kpaonline.com
(866) 356-1735
The Good, the Bad, and the Ugly: OSHA Stories From the Field
Thank you for joining the webinar. We will begin at 10am Mountain Time.
PresenterPresenter
Janet WimmerEHS Engineer
(901) 277-0301 jwimmer@kpaonline.com
QuestionsQuestions
• If you have questions during the presentation, please submit them using the “Questions” feature
• Questions will be answered at the end of the webinar
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Handling an OSHA inspection in the proper
manner can save you a lot of money.
While you are listening to me, think about
your dealership and how you would develop
an OSHA Inspector Response Plan
– KPA CONFIDENTIAL –
Why this is Important ?Why this is Important ?
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• Setting the tone While Buying Time
• Acting on the First Impressions List
• The Walk Around
• The Follow-up
• Obvious Paperwork and Operations Items
– KPA CONFIDENTIAL –
What I am CoveringWhat I am Covering
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• Be Prepared
• Assume the Best of Intentions
• Don’t Get Shook UP
• Double Check Your Attitude
• Note the Inspectors Attitude
– KPA CONFIDENTIAL –
Establishing AttitudeEstablishing Attitude
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• Put on Your Happy Face
• Invite the Inspector to Your Office
• Ask if he/she would like a cup of Coffee
• Keep Your Happy Face on
– KPA CONFIDENTIAL –
GreetingGreeting
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• Ask to See the Inspector’s Credentials
• Ask the Purpose of the Visit
• There are Three Primary Purposes
– An Employee Complaint
– A “Targeted” Inspection
– A Complete OSHA Inspection
– KPA CONFIDENTIAL –
QuestionsQuestions
10– KPA CONFIDENTIAL –
Stay On TargetStay On Target
• An Employee Complaint Take the Inspector to the complaint area
• A “Targeted” Inspection Give Information on the Target return to the office
• A Complete OSHA Inspection The Inspector does a complete inspection
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• You want to see what the inspector sees
• Take notes on everything said
• If the Inspector is not talking, ask questions
– What is he/she looking at?
– Is there a violation?
– Is it serious?
• Your notes will determine how you respond
– KPA CONFIDENTIAL –
Stay With the InspectorStay With the Inspector
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• Your Plan is set in Motion
– The OSHA Inspector Alarm goes out
– Your designate goes through the shop
– Inspects for potential obvious problem
– KPA CONFIDENTIAL –
In The Meantime…First ImpressionsIn The Meantime…First Impressions
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Slip hazards: Spills on the floorTrip hazards: Hoses and cordsTool Condition: GrinderPPE: safety glasses, safety goggles, gloves Housekeeping: Trash, debris, rags on the floorSanitary Conditions: Food in the workplaceFire Safety: Blocked fire extinguishersEvacuation: Blocked or locked exit doors
– KPA CONFIDENTIAL –
Potential Short ListPotential Short List
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• Ask for an “Exit” meeting in your office
• Ask if there will be a fine. If the answer is “Yes”, ask if you are illegible for a small business reduction.
• After the Inspector Leaves
– Review your notes and add comments
– Call your consultant and go over the information
– Develop an action plan
– KPA CONFIDENTIAL –
After the Walk-AroundAfter the Walk-Around
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• Fix anything that can be easily fixed
– Make notes about your actions
– Take pictures
– Maintain a file
• Schedule any repair needed by an outside vendor
– KPA CONFIDENTIAL –
The Action PlanThe Action Plan
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• Review it carefully, especially the time deadlines
• Send the citation to your consultant and schedule a conversation
• Take pictures of all actions such as posting the violation notice
• If fines are levied, request an informal meeting within the designated time frame
– KPA CONFIDENTIAL –
Receiving the CitationReceiving the Citation
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• If no fine is levied, complete your response as soon as possible—definitely before the deadline.
• If possible, complete the response prior to the informal meeting
• Make sure you have documented every action
• Take your consultant to the meeting
• Good attitude and good faith effort are very helpful in reducing fines
– KPA CONFIDENTIAL –
The ResponseThe Response
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OSHA items are in two categories:
• PAPERWORK
• OPERATIONS
We will discuss the most common items that need to be addressed on a regular basis.
– KPA CONFIDENTIAL –
Key Items on OSHA ListsKey Items on OSHA Lists
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The OSHA 300 FormMost inspectors consider the OSHA 300 Form an indication of your knowledge of OSHA regulations. Key points:• Dealerships use the Standard Industrial Classification (SIC) Code of the area of the business that brings in the most money.• This is normally sales. • The SIC code for sales is 5511• This number is exempt from keeping an OSHA 300 form• If you do not know what I am talking about,
YOU NEED A CONSULTANT
– KPA CONFIDENTIAL –
PAPERWORKPAPERWORK
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The Hazard Communication Requirements
• A Written Program
• A Chemical Product List
• Material Safety Data Sheets for the Products on the List
• All containers labeled with the contents and the hazard
• Employee Training
• Contractor Notification of Hazards in the Workplace
– KPA CONFIDENTIAL –
PAPERWORK-HAZARD COMMUNICATIONPAPERWORK-HAZARD COMMUNICATION
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Emergency Action / Fire Prevention Plan
• A Written Program
• Emergency Equipment / Emergency Evacuation Map
• Emergency Phone Numbers Posted
• Evacuation Drill
“RALLY POINT”• Do You and All Your Employees Know Where to Meet if an
Evacuation is required
– KPA CONFIDENTIAL –
PAPERWORK-EMERGENCY ACTION PLANPAPERWORK-EMERGENCY ACTION PLAN
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Hazard Assessment of the WorkplaceThis is an analysis of the workplace to determine what Hazardous Activities are conducted, what hazard is created, and what you must do to protect your employees.
• Key Points- If mechanical means cannot be provided to protect the employee, PPE must be provided at no cost to employee
- It is the employer’s responsibility that the employee wear PPE
- Either prescription safety glasses or safety glasses that fit over prescription glasses must be provided
– KPA CONFIDENTIAL –
PAPERWORK-HAZARD ASSESSMENTPAPERWORK-HAZARD ASSESSMENT
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Respiratory Protection RequirementsService Department employees that use proper procedures do not need respiratory protection. Collision Center employees do need respiratory protection
• A written program must be present if protection is required
• A written program must be present for voluntary use of a solvent vapor respirator • Voluntary use of a filtering face-piece requires compliance with appendix D• Persons who wear respiratory protection must have permission from a medical provider• Persons who wear respiratory protection must be fit-tested annually
– KPA CONFIDENTIAL –
PAPERWORK-RESPIRATORY PROTECTIONPAPERWORK-RESPIRATORY PROTECTION
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PAPERWORKOSHA may ask to see records such as paint booth sprinkler system maintenance, air compressor certifications, air quality analysis, and more…. I talked about the most obvious items.
OPERATIONSThere are 400 items on the KPA inspection list. I will now touch on the most obvious to an inspector. These items should be obvious to your managers for they involve the actual safety of your operations.
– KPA CONFIDENTIAL –
PAPERWORK TO OPERATIONSPAPERWORK TO OPERATIONS
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CONTAINERS: Including pails, secondary containers, used gallon containers, drums, and tanks.
•Must be closed if not in use
•Must be labeled with the name of the product
•Must be labeled with the primary hazard such as “FLAMMABLE”
– KPA CONFIDENTIAL –
OPERATIONSOPERATIONS
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GRINDERS: The easiest item to cite and the hardest to keep in compliance
• Eye shields present and clear
• Work rest within ¼ inch of wheel
• Secured to the table or floor
• Electrical cord and plug intact
• Tongue guard in place
– KPA CONFIDENTIAL –
OPERATIONSOPERATIONS
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ELECTRICAL BOX:
• Must be closed
• Three feet space in front must be clear (marking the space with a yellow line helps)
• The switches must be marked
– KPA CONFIDENTIAL –
OPERATIONSOPERATIONS
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FIRE EXTINGUISHERS: Must be inspected annually by an outside vendor. Must be inspected monthly by in-house personnel
• Is the fire extinguisher blocked
• Is the fire extinguisher in charge
• Is the fire extinguisher marked
• Is the fire extinguisher mounted
• Is the vendor tag in place
– KPA CONFIDENTIAL –
OPERATIONSOPERATIONS
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EXIT ACCESS: No matter how many bay doors you have, the exit door is the emergency exit.
• Must be unlocked when employees are present• Must not be blocked from the inside or the outside•The exit sign must be lit at all times
– KPA CONFIDENTIAL –
OPERATIONSOPERATIONS
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ELECTRICAL CORDS: Including extension cords, small equipment cords, fan cords, lift wiring, etc.
• Must not have a cut or loss of coating
• Must not show the inside wires on the cord
• Must have the ground in place
• Must not be repaired with electrical tape
•If the pretty wires can be seen at the plug, the plug must be re-fixed to the cord
– KPA CONFIDENTIAL –
OPERATIONSOPERATIONS
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EYE WASH: If materials are present that could be corrosive to the eye, an eye wash must be present.
• Material Safety Data Sheets: Flush with water for fifteen minutes
• A portable eye wash should only be used, if no water is available in the department
•The eye wash must be clean, have useable water flow, and be unblocked
– KPA CONFIDENTIAL –
OPERATIONSOPERATIONS
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SLIP, TRIP, AND FALL: The assumption that people are looking where they are going is wrong.
• Cords not on reels or wound up• Electrical cords stretched across air space• Debris including trash, parts, jugs, rags, or harnesses.• Standing water, spilled automotive fluids, oil residue• Broken grates or holes in the floor• Uneven, unmarked floor surfaces
– KPA CONFIDENTIAL –
OPERATIONSOPERATIONS
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Good Attitude
Realistic PlanQuick Action
Attention to the DetailCommon Sense
– KPA CONFIDENTIAL –
SUMMARYSUMMARY
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Free Consulting Time!Free Consulting Time!
– KPA CONFIDENTIAL –
QUESTIONS?
Contact UsContact Uswww.kpaonline.com
bross@kpaonline.com
866-356-1735
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A copy of the recorded webinar and presentation slides will be emailed to you today.
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