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Safety 101
ARA C.A.R. certification offers you an advantage to laying the foundation of a powerful safety program.
Safety compliance is an important part of running a safe automotive shop. A safety program is a necessary part of doing business in a safe and compliant manner. Setting up a safety program is not as difficult as it may seem once you break down the necessary components in to smaller steps, using the ARA Certified Automotive Recycler (C.A.R.) program as a model.
  
The C.A.R. program’s basic safety standards offer auto recycling facilities guidance to compliance. This practical guide may be useful in designing a compliance program. The safety program standards discussed in this article provide general guidance and do not guarantee compliance with federal law.

To review C.A.R. program standards, visit the ARA Web site at www.a-r-a.org/content.asp?contentid=480.

Safety Program Safety Standard 8

A safety program where a specific individual is in charge of holding regularly scheduled safety meetings and safety inspections. 

WHAT TO DO:

1. Prepare/maintain a written hazard communication plan
2. Designate a Safety Supervisor
3. Compile/maintain the MSDS sheets for all chemical products stored on-site. (Download the basic auto recyclers MSDS at www.sueschauls.com/msds.html.) 
4. Conduct monthly/regularly scheduled safety meetings corresponding to the C.A.R. standards and other important topics. Log training events and maintain records on-site.
5. Conduct and log regular/annual safety inspections. Maintain records on-site.

Become Familiar with the Rule

The Hazard Communication Standard (HCS) is based on a simple concept – that employees have both a need and a right to know the hazards and identities of the chemicals they are exposed to when working. They also need to know what protective measures are available to prevent adverse effects from occurring. The HCS (29 CFR 1910.1200) is designed to provide employees with the information they need. Under the provisions of the Hazard Communication Standard, employers are responsible for informing employees of the hazards and the identities of workplace chemicals to which they are exposed.

Identify Responsible Staff

Simply stated this is the Safety Supervisor. Hazard communication is an ongoing program in the facility. In order to have a successful program, it is necessary to assign responsibility for both the initial and ongoing activities that have to be undertaken to comply with the rule. For any safety and health program, success depends on commitment and possibly a change in behavior, if employers understand the program, and are committed to its success, and if employees are motivated by the people presenting the information to them.

Identify Hazardous Workplace Chemicals

The Standard requires a list of hazardous chemicals in the workplace as part of the written hazard communication program. The list will serve as an inventory of everything for which a MSDS must be maintained.

The best way to prepare a comprehensive list is to survey the workplace. Purchasing records may also help. Employers should establish purchasing procedures that result in MSDSs being received before a material is used in the workplace.

Check your files against the inventory you have just compiled to ensure that an MSDS exists for each potentially hazardous chemical. If any are missing, contact your supplier and request one.

Preparing and Implementing a Hazard Communication Program

All workplaces where employees are exposed to hazardous chemicals must have a written plan which describes how the standard will be implemented in that facility. The plan does not have to be lengthy or complicated. It is intended to be a blueprint for implementation of your program – an assurance that all aspects of the requirements are addressed. (Download a sample plan at www.sueschauls.com/Haz_Comm__Sample_Plan.doc.)

Add the facility specific information and the name of the Safety Supervisor to the template plan provided. Add any additional site specific information to the plan and keep a copy of this written plan in the MSDS binder or readily available in case of an OSHA inspection.

Personal Protective Equipment Safety Standard 1

Photo submission required for this standard.

Utilization of Basic Personal Protective Equipment Including Gloves, Hard Hats, Safety Shoes, Safety Clothing, Safety Shields, and Goggles, When Required

Personal protective equipment (PPE) can help complement other measures taken by employers and employees to minimize hazards and unsafe conditions. Recent OSHA revisions require the employer to complete a written hazard evaluation of the workplace to determine employee hazards and the PPE necessary to protect them.

Personal Protective Equipment (PPE) is specialized clothing or equipment worn by employees for protection against health and safety hazards. Personal protective equipment is designed to protect many parts of the body, including; eyes, head, face, hands, feet, and ears.

WHAT TO DO:

1. Determine appropriate PPE for the facility and complete written hazard evaluation.
2. Train each employee required to use PPE.
3. Make PPE available to employees or require that employees provide their own PPE.
 
Eye Wash Station Safety Standard 2
Photo submission required for this standard.

OSHA Approved 15-Minute Eye Wash Station(s) Readily Accessible Near Corrosive Materials (i.e. battery storage, processing and recharge areas).

Workers’ eyes may be damaged very quickly by exposure to contaminants in battery storage or vehicle processing areas. The first fifteen seconds after an eye injury is critical. The American National Standards Institute (ANSI) suggests that eye wash stations be located within 100 feet, or a 10 second walk, of critical work areas.

WHAT TO DO:

1. Install/maintain an OSHA approved 15-minute eye wash station(s) where corrosive materials are used.
2. Provide annual training to employees on the location and use of an eyewash station.
3. Complete an Emergency Eye Wash Protection Plan and retain a copy in safety records.

Fire Extinguishers Safety Standard 3
Photo submission required for this standard.

Readily Available, Appropriately Typed, and Fully Charged Fire Extinguishers

Fires may be caused by welding or torching, fuel or fume explosions, electrical problems, or ignition of combustibles. Take preventive measures, learn how to recognize and respond to different types of fires, and properly handle and store chemicals and flammable liquids.

WHAT TO DO:

1. Mount portable fire extinguishers in designated areas so that they are readily and easily identified and accessible.
2. Select appropriate type of extinguisher for potential class of fire.
3. Maintain fire extinguishers in a fully charged and operable condition.
4. Document inspections and annual maintenance on a tag affixed to each extinguisher.
5. Arrange for hydrostatic testing by trained persons at specified intervals by state.
6. Train employees on fire prevention and emergency response.

OSHA rule 29 CFR 1910.157 states that an employer shall provide approved portable fire extinguishers and shall mount, locate and identify them so that they are readily accessible to employees without subjecting the employees to possible injury.

Fire extinguishers must be maintained in a fully charged and operable condition and kept in their designated places at all times except during use. Fire extinguishers for employee use should be selected and distributed based on the classes of anticipated workplace fires and on the size and degree of hazard which would affect their use. A multi-purpose ABC rated fire extinguisher is appropriate for an auto salvage operation.
 
Inspection Requirements

• Inspect monthly – Portable fire extinguishers shall be visually inspected monthly.
• Conduct annual maintenance – Fire extinguishers are subjected to an annual maintenance check. Record the annual maintenance date and retain this record for one year after the last entry. Hire a professional.

Many of the multi-purpose inexpensive fire extinguishers are on the manufacturer’s recall list. It only makes sense to use a professional fire extinguisher service to protect your employees and your business. Provide adequate protection such as back up fire extinguishers when portable fire extinguishers are removed from service for maintenance and recharging.

Torch Protocol Safety Standard 4
Photocopy submission required for this standard.

Company will administer and sign the C.A.R. Torch-use Education & Orientation Protocol prior to an employee’s use of a cutting torch.

WHAT TO DO:

1. Retain a signed and dated copy of this and any other training programs in the
employee files prior to use of a gas cutting torch.
2. Conduct and log cutting torch safety awareness for all employees at least once annually.
Download the Employee training material at www.a-r-a.org/files/torch_protocol_2009.pdf
 
First Aid Kit Safety Standard 5

Photo submission required for this standard.

A properly stocked first aid kit that is in close proximity to the dismantling areas, and is adequately sized for the number of employees in that area.
 
A first aid kit allows trained workers to respond to a minor injury or illness, and to provide temporary relief of a more serious injury until professional medical assistance is obtained.

WHAT TO DO:

1. Keep one or more first aid kits clean, dry, and readily available to workers.
2. Notify the workers of the locations of the first aid kits.
3. Keep the first aid kits well-stocked to treat common industrial injuries (bumps and abrasions, cuts, burns, strains and sprains, and eye injuries).

Every salvage yard should maintain a first aid kit on-site at the facility in the event of a medical emergency. A well stocked first aid kit can complement other safety equipment such as the eye wash station and personal protective equipment. Together these supplies can protect employees.

OSHA First Aid Kits and supplies are required to be readily available per 29CFR1910.151.b (Medical Services and First Aid). OSHA does not have a minimum requirement, but references ANSI Z308.1-2003 Minimum Requirements for Workplace First Aid Kits. 

Spill Kit Safety Standard 6
Photo submission required for this standard.

Adequately sized spill kit(s) are available in close proximity to the storage and/or removal areas of the fluids listed in the environmental standards section of this application.

Every salvage yard should maintain a spill cleanup kit on-site at the facility in the event of an emergency spill. Spills have a few issues with which to be concerned.
First is the protection of employees (and customers) if the spill contains hazardous material. To accomplish this task the appropriate type of spill cleanup kit must be selected from the myriad of choices available.

The second issue is to make sure that employees are trained on the use and locations of all spill cleanup kits. Simple to do as long as you do it, it’s called TRAINING.

Finally, if the quantity of material spilled is sizeable or made of acutely hazardous chemicals the spill must be reported to the regulatory agency. In some instances, an emergency response team will be discharged. These types of spills are infrequent at a well-equipped salvage yard.

WHAT TO DO:

1. Maintain a spill kit(s) that contains appropriate absorbents and/or containment devices to handle the type and amount of fluids that could be released.
2. Place the labeled spill kit(s) where fluids are used or stored.
3. Provide and document training to appropriate workers on how to properly manage fluids, prevent spills and leaks, respond and clean up a spill, and dispose of the used absorbents.

Self Serve Safety Posters  Safety Standard 7
Photo submission required for this standard.

Self Service facilities have posted safety reminders for customers.

The Occupational Safety and Health Administration (OSHA) and state labor departments require safety posters to be displayed in businesses that are subject to OSHA reviews. Safety posters remind employees of precautions they need to take to remain safe in the workplace. In self-serve facilities safety posters can also remind technicians that are customers to conduct themselves in a safe manner too.

Sue Schauls is an independent environmental consultant with automotive expertise. She is the Iowa Automotive Recyclers Executive Director & I-CARE Program Manager and the CCAR-Greenlink Technical Advisor. Schauls, found at www.SueSchauls.com, participates in the ARA CAR, Technical Advisory and Affiliate Chapters committees.

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