1802 Safety And Health
This quick reference guide to Vermont Occupational Safety fast money loan and Health (VOSHA) requirements for automotive repair businesses has been compiled by the Pollution Prevention Division in consultation with Fred Satink of the Vermont Occupational Helath Program. John Roorda of the Vermont Occupational Safety Program, and Lisa Young of the Vermont Automotive Dealers Association. It is based, in part, upon OSHA publication #2209, “OSHA Handbook for Small Business.”
For full and complete detail on requirements, we recommend that you consult the VOSHA Voluntary Compliance Program in developing and implementing your company’s occupational safety and health programs.
You may contact the VOSHA voluntary compliance “Work Safe” at either (802) 828-2765 (safety) or (802) 865-7730 (health).
THE FOUR POINT WORKPLACE PROGRAM
A commitment to health and safety in the workplace is the only means of preventing accidents and injuries before they happen. Accidents and injuries not only inflict turmoil and pain into the lives of your employees, but may hinder the operations of your business. Losing a key employee to an injury, or a portion of your shop to a fire are a small businesses worst nightmares.
A commitment to safety and health in the workplace has been proven to be profitable by many businesses, small and large. An effective health and safety program means fewer worker compensation claims, a more productive and healthy workforce, and in some cases reduced prices for insurance coverage. VOSHA also allows a 25% fine reduction for facilities with “effective” health and safety programs.
VOSHA advocates a four point approach to developing a health and safety program for your business. Each point of a well organized program is equally important if effectiveness is desired. The goal of the four point approach is to develop a priority driven “action plan” your company can follow towards a safer workplace.
POINT 1: Management Commitment and Employee Involvement
A strong safety and health program begins with firm commitment of the owner and management of your company. At all times, the owner and management must express concern and demonstrate commitment for occupational safety and health. If the owner and management are not dedicated to a successful safety and health program and prevention and control of occupational hazards, it is likely that employees will not be interested either. Remember, success starts at the top.
POINT 2: Worksite Analysis
Once commitment is assured from above, it is a good idea to review the entire business in an attempt to identify and list all potential occupational exposures. Make a quick review and identify those that seem imminent threats. Spend some time looking over this guide, then review the facility again. It might even be a good idea to bring in a consultant or Vermont’s voluntary compliance program “Work Safe” at this time. Employees should be encouraged to report potentially hazardous situations without fear of reprisal. Finally, a review of “near misses” and investigation of accidents that do occur will help identify situations, machinery or operations that need to be modified or corrected.
POINT 3: Hazard Prevention and Control
At this point in the development of your “action plan”, you need to spent some time organizing occupational exposures, required paperwork, recordkeeping, signage, and training into a priority driven system. Rank your list of “to do’s” according to the imminent threat they pose employees if not immediately undertaken, the capital costs required to alleviate the threat, and your need for more information if a prevention and control measure has yet to be determined. Run this list by upper management and the owner before continuing. Be sure they understand what they are getting into, the costs of required changes, and potential impacts on employee productivity. Assure their commitment to the necessary changes and implement your “action plan”. It should be someone’s responsibility to periodically “inspect” the workplace for hazards, personal protective equipment use and adherence to company and state policies and regulations.
POINT 4: Training for Management and Employees
The most successful programs are engrossed with involvement at all levels of management and occupation. Start by getting help from other people employed in all aspects of the company’s operation. Develop a safety and health committee and orient them to safety and health issues, your priority scheme, and the major tenets of the company’s “action plan”. Work with these people to increase overall concern for occupational safety and health issues, smooth the implementation of change, further your efforts to identify hazards, and prevent and control exposures. Develop a newsletter committee, or utilize an existing newsletter for the general promotion of occupational safety and health, as well as to provide written training on exposures or required prevention and control procedures with broad bearing. Organize exposed employees on a set and frequent schedule to discuss common exposures, prevention and control measures, and emergency response procedures. Meet individually with employees exposed to isolated hazards.
Listed below are standards typically found to apply to automotive repair industries. Standards are organized in this guide under broad headings and are not necessarily a reflection of the organizational pattern setforth in the original federal code of standards. Keep in mind that certain standards (lock-out/tag-out, electrical, hazard communication, personal protective equipment, etc.) may be applicable to multiple areas and operations of your shop, and should probably be referenced under multiple headings below. However, duplication of listings has been eliminated in this guide wherever possible, and by no means is this meant to suggest that these standards do not apply.
Safety and Health Program Management and Coordination
- RECOMMENDATION: Designate one: person to be responsible for health and safety programs.
- RECOMMENDATION: Maintain procedures for handling employee complaints.
- RECOMMENDATION: Establish awareness procedures for continuous safety and health education.
- OSHA workplace poster.
- Emergency telephone numbers.
- Toxic substance or harmful physical agents (e.g. lead, noise, asbestos standard posting.)
- Exiting/Means of egress.
- No eating, drinking, or smoking signs where appropriate.
- OSHA log 200 during the month of February each year.
Medical Services and First Aid
- RECOMMENDATION: Pre-employment physical examinations for all employees.
- A hospital, clinic, etc. must be within four minutes of the facility or an employee must be trained in First Aid. NOTE: If First Aid-trained employees are required, then Blood Born Pathogen standard applies (see relevant section below).
- Arrangements for medical consultation, especially if respirators are required for any area or operation at the facility.
- Availability of First Aid kits that have been approved by a local physician. First Aid kits should be inspected and restocked on a regular basis.
- Track employee illness and injury on either OSHA form 101 or maintain OSHA log 200.
- Maintain employee medical and employee exposure records for bloodborne pathogens, carbon monoxide, solvents, welding fumes, asbestos, lead, benzene, ethylene glycol, noise, corrosives, and other toxics.
- Secure arrangements for long-term maintenance of records. For example, an MSDS or other record of chemicals used must be maintained for 30 years.
- Maintain permits for lifts, compressors, gas tanks, fire extinguishers, etc.
- Equipment grounding, equipment safety device and fire extinguisher inspection logs.
- Hazard communication
- Plan must list and describe all hazards; hazard characteristics or constituents; availability of Material Safety Data Sheets (MSDS’s); define routes of entry/exposure for each hazard; discuss signs of exposure; list procedures for preventing and controlling exposures; describe use of protective equipment: use/availability of engineering controls; and procedures for responding to each exposure.
- Provide training for employees potentially exposed to hazards. Training program must also be written, describe the hazard communication standard, and communicate all aspects of the written plan.
- Maintain a compilation of MSDS sheets.
- Assure that all containers are labeled with the chemicals trade name, it’s hazard (flammable, irritant, etc.), and target organ effects.
- Emergency medical procedures
- Define whether first aid will be provided on-site. First Aid must be provided if medical facilities are not within 4 minutes of the facility.
- If First Aid is to be provided on-site, responsible personnel must be designated and adequately trained (see also section describing Blood Born Pathogen standard).
- Provide written procedures and employee training that describe how to differentiate between incidents requiring only First Aid and those requiring emergency medical attention: define appropriate name, telephone number and directions to the closest medical response facilities, or those medical facilities with which care has been pre-arranged: and define parties to be informed in both First Aid and Emergency medical situations.
- Bloodborne pathogens
- Availability of personal protective equipment (gloves in first aid kit, etc.) and training for all employees is required whether policy is to provide on-site medical attention or not. Plan is required if employees will provide first aid.
- Plan should identify those individuals potentially exposed, list available preventive controls (gloves, masks, shower, etc.), define procedures for First Aid response, define a schedule for reviewing control effectiveness, provide procedures for dealing with contaminated equipment, waste and/or potential exposure, establish a means of tracking and recording incidents, and document employee awareness
- training.Blood testing should be available to potential source and exposed employees, and each exposed employee must be given appropriate counseling concerning precautions to take during the period after the exposure incident.
- Employee awareness training should include: a description of the OSHA standard for Bloodborne Pathogens, symptamology of bloodborn diseases, modes of transmission of bloodborne pathogens, the exposure control plan including control methods and post-evaluation and follow-up, and signs and labels used at the facility.
- Fire prevention and egress
- Document and provide employee training on the availability and use of fire extinguishers, alarm systems, automatic fire suppression system, and describe safety procedures, responsibilities, and means of egress during fire emergencies. Fire extinguishers should be inspected monthly.
- Exposures to toxic or physical agents (e.g. lead, asbestos, noise,etc.)
- Document for each toxic or physical agent: the hazardous effect, routes of exposure/entry, signs of over-exposure, use/maintenance/inspection procedures of protective personal equipment or mechanical and engineered controls, and procedures for dealing with over-exposure.
- Respiratory Protection Program (where respirators are used or required)
- Provide respirators in areas where engineering controls do not protect the health of employees, maintain a respiratory protection program, and require employees use respirators where appropriate. A respiratory protection program must include training for respirator users on selection, use, maintenance and limitations of respirators. The program must be regularly evaluated to determine its effectiveness.
- All respirators must be inspected, repaired and cleaned at least monthly, or after each use.
- Consult a local physician to determine which employees are physically able to use the equipment.
- The respiratory protection standard is highly specific. Consult the VOSHA (Health) “Work Safe” program for further detail.
- Fire Protection
- Assure that the local fire department is aware of fire hazards at your facility.
- Maintain certification of fire alarm system and that sprinkler systems are frequently inspected and tested by a responsible party or professional.
- Availability of appropriate fire extinguishers that are regularly serviced, recharged and tagged.
- Periodic (annually recommended) employee training in proper use of fire extinguishers and fire protection procedures.
- Protective Equipment
- Require eye protection where appropriate (check MSDS for detail).
- Require face shield protection for operations involving welding,cutting, grinding or use of abrasive wheels, hand-tools, etc.
- Require approved protective clothing (aprons, etc.), gloves, and shields where an employee may be exposed to cuts, bums, skin irritants, caustics or skin absorbed toxins. Make available and require the use of approved respirators in cases of emergency or regular use (check MSDS for detail).
- Maintain protective equipment in sanitary condition, sanitize at regular intervals, and especially if used by multiple employees.
- Make dual eye flush, and in some cases even body showers, available in areas where injurious or corrosive compounds are used (check MSDS for detail). Designate eating and drinking areas separate from areas of potential exposure. Provide noise protection or engineering controls where 85 db/8hr. twa is surpassed.
- Provide approved protective equipment and require its use for cleaning spills and leaks of toxic and hazardous chemicals, materials, and liquids: Be careful not to violate other standards during these operations.
- General Work Environment
- All work areas must be clean, orderly, and well illuminated. Even elevated surfaces must be cleaned of dust (combustibles) periodically and provided with standard guard rail and four-inch toe board where appropriate. Stacked, piled, or racked materials must be stored in a manner as to eliminate falling, rolling, etc. Provide at least two means of egress from any elevated work area. Spills and leaks must be contained and cleaned immediately.
- All walking surfaces must be clean and slip-resistant. Aisle space must be provided and kept clear, especially around machinery. Mark all directional changes in aisleways and be sure sufficient head room is available. Provide guard rails on walkways elevated more than thirty inches that can handle up to 200 pounds and allow 1.5 inches between rail and mounting. Stairs should be at least 22 inches wide, made from sound material, especially landings. Mark landings that exit into traffic.
- Toilets and washing facilities must be provided and cleaned regularly.
- All pits and floor openings must be covered or otherwise guarded: this includes grates over floor drains.
- All combustible or flammable materials, liquids, debris, etc. must be contained in approved metal containers and covered.
- All gas or oil fueled devices must be equipped with flame failure controls.
- Mark all doors by purpose: “EXIT”, “STORE ROOM”, “NOT AN EXIT”, etc.
- Do not use portable ladders as permanent fixtures. All metal ladders should be labeled, “CAUTION! Do Not Use Around Electrical Equipment”
- Hand Tools and Equipment
- Use only hand tools that are UL approved and in good condition. Handle and store tools as to maintain proper working condition.
- Protective equipment such as safety glasses, fare shields, etc. must be worn if tool may produce flying materials or be subject to breakage.
- Inform employees of the hazards of faulty or improper use of tools.
- Abrasive Wheel Equipment – Grinders
- All abrasive wheels or grinders must be permanently mounted, grounded with metallic conduit wiring, have adequate adjusted work rests and tongue, individual on and off switches, have ample side guards, and splash guards, as well as dust collection, if necessary.Use of protective goggles or face shield is required.
- Machine Guarding
- Training in the safe operation of each machine is required (see manufacturer manual).
- All machinery must be inspected regularly for safe operation.
- Operator must be able to reach all controls from point of operation and be protected from hazards in that position.
- Machines should not be able to start-up automatically in power-outage situations and low-level current surges should not be able to start-up machine.
- IT’S A GOOD IDEA TO CONSULT THE “WORK SAFE” PROGRAM FOR COMPLIANCE SUGGESTIONS ON EACH INDIVIDUAL MACHINE!
- Lock-out/Tag-out Procedures
- All equipment capable of storing energy must be locked-out and tagged as such for installation, service, repairs, adjustments, etc. Where power supply disconnection is not allowed, control circuit must be locked-out and tagged. A safety check of locked-out equipment must be undertaken prior to service, repair, etc. and may only be conducted by the party designated and trained in lock-out/tag-out procedures
- Define which equipment in your shop store energy (e.g. mechanical, hydraulic, air, etc.) and differentiate as to whether they are energized by a single or multiple energy source(s). Electrical equipment not storing other energy, and that are of the cord and plug variety, may simply be unplugged with the plug remaining in view of whomever is providing service. Other equipment must have written lock-out/tag-out procedures.
- Employees undertaking lock-out/tag-out procedures must be trained in lock-out/tag-out procedures and be identifiable by lock, key or tag tracking mechanisms while undertaking a procedure.
- Welding, Cutting and Brazing
- Many standards affect welding, cutting and brazing operations, you should be particularly concerned with:
- All equipment should be of an appropriate type. All cylinders should be handled in a manner as to prevent release of compressed gas, damage to the cylinder, or exposure to external heat sources.
- Signs should be posted reading: “DANGER! NO SMOKING, MATCHES, OR OPEN LIGHTS”.
- Remove regulators and secure valve caps to cylinders before moving cylinders.
- Unless on a cart for use, separate stored acetylene and oxygen with a fire rated wall or adequate distance.
- While welding, cutting or brazing take care that all combustibles are either removed, guarded, or wet-down.
- Only authorized and trained personnel should operate welding, cutting and brazing equipment, and they should have a copy of operating instructions for reference.
- Measure prevalence of welding fumes to determine if health standards are surpassed and if mechanical ventilation is required.
- All operators are required to wear eye protection helmets, hand shields, goggles, and protective clothing.
- Welding shields should be used at all times to protect other employees.
- Many standards affect welding, cutting and brazing operations, you should be particularly concerned with:
- Compressors and Compressed Air
- All compressors should be maintained and operated according to manufacturer recommendations. All should be equipped with pressure relief valves, pressure gauges, air intake filters, and guarding that completely encloses the belt drive system.
- Before repair of compressor, system must be locked-out and bled.
- Post signs that warn of the automatic start-up feature of compressors.
- inspect safety devices on compressors frequently.
- Do not use to clean-off clothes or body.
- Employees must wear protective chip guarding and other protective equipment while using compressed air to clean.
- Compressed air abrasive blast cleaning equipment must be equipped with a manual operating valve. Clip-on chuck and an in-line regulator must be used when inflating tires.
- Regularly drain from lowest point of pressure.
- Rated load for hook and bridle must be marked and always visible to operator.
- All hoists must be able to hold up to 125 % of it’s rated load.
- Do not use hoist chain/rope as a sling and don’t carry loads over people.
- RECOMMENDATION: Lifts should have the ANSI (American National Standard) label of compliance, manufacturer’s name, rated load capacity, model, serial number, and operating instructions clearly posted.
- Lifts must have a locking mechanism in place anytime someone is under the lift. Some lifts have this feature only when they are fully extended. Compliance for these lifts requires that all work is conducted with the lift in its fully extended position. Lifts lacking built-in step locking mechanisms, must be secured with an adjustable jack able to support three times the lifts rated capacity. Secure the lift, not the car.
- Spraying Operations
- Adequate ventilation must be provided, where enclosed, mechanical ventilation is required. Be sure exhaust is non-circulating.
- Do not spray within 20 feet of flames, sparks, operating electrical motors and other ignition sources.
- Illuminate spray areas with explosion-proof lighting. Portable lights are not allowed in body shop spray area.
- Post “NO SMOKING” signs.
- All combustible material must be removed from spray area frequently.
- Properly ground all electrical equipment used in spray areas.
- All operators must be trained in the proper use of respirators and should wear respirators and protective clothing whenever exposure standards could be surpassed. Use of respirators requires the development of a respiratory protection program.
- CONSULT THE VOSHA “WORK SAFE” PROGRAM ON A CASE-BY-CASE BASIS TO DETERMINE MOST EFFECTIVE MEANS OF COMPLIANCE.
- Environmental Controls
- All employees must be aware of environmental hazards, trained to identify signs of exposure and over-exposure, understand how to choose and use protective equipment, and what to do in emergency or first aid situations. All must be provided in written form as well.
- Employers should assess employee exposure to any environmental hazard, including: welding fumes, abrasive or other respirable dust, asbestos, carbon monoxide, paints, especially epoxies, other solvents, caustics and noise to determine appropriate training, proper protective equipment and necessary engineering controls to limit exposure.
- CONSULT THE VOLUNTARY VOSHA (HEALTH) “WORK SAFE” PROGRAM TO DETERMINE IF EXPOSURE STANDARDS ARE SURPASSED AND IF ENGINEERING CONTROLS ARE NECESSARY.
- Flammables and Combustible Materials
- Storage rooms, cabinets and containers must be designed according to rating of materials to be stored/used in the area. In most cases, gravitational or mechanical ventilation must be provided. In almost all situations, lighting must be of the explosion-proof type.
- All containers must be compatible with the material to be stored, fire resistant, approved as such, and grounded.
- All areas and storage tanks must be labeled with “NO SMOKING” signs.
- All storage tanks, containers, etc. must be equipped with venting.
- Appropriate fire extinguishers must be available wherever flammables/combustibles are stored. Sprinkler heads must be directed so that water will not be sprayed into operating electrical switch boards or equipment.
- IT IS HIGHLY RECOMMENDED THAT YOU CONSULT WITH THE OSHA “WORK SAFE” PROGRAM ON A CASE-BY-CASE BASIS!
- All electrical equipment, both portable and permanent must be grounded or have the means of being grounded.
- All cords must have a grounding conductor.
- No outlets, circuit breakers, switches, or extension cord connections are allowed within eighteen inches of the floor (class I, division H areas) unless area is otherwise classified.
- Employees should inspect all machinery, equipment and cords prior to energizing. All hazardous conditions are to be remanded immediately and prior to energizing.
- All electrical raceways and enclosures (switches, receptacles, junction boxes, etc. must be secured and provided tight-fitting covers or plates.
- All electrical contract work must be compliant with OSHA standards.
- Ground Fault Circuit Interrupters (GFCI) are required for new outlets, and sometimes on existing outlets.
Source: US EPA Office of Air and Radiation Stratospheric Protection Division
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Last Update – 21-Mar-97