M is for Missing - Are You in Compliance with OSHA’s New Requirement?
By Anthony Analetto
In a world where it’s possible for a doctor to accidentally leave a watch inside a patient, it’s hard to argue against the possibility that a detailer can leave a bottle of some fruity scented chemical in the back seat of a car within reach of a child, or that an employee can accidentally spill tire cleaner on his or her leg. Quickly knowing what to do in an emergency has been the purpose of Material Safety Data Sheets (MSDS) for years, but the system has changed. OSHA’S Hazard Communication Standard (HCS) changed in 2012. MSDS was changed to SDS and there are several requirements all car wash operators must have addressed by June 1, 2016 to be fully compliant.
The change of MSDS to SDS is about more than dropping the letter M. It’s an initiative to improve the safety of material handling and make it easier to react quickly and correctly when an accident occurs. Every wash should have risk-prevention and counter-measure plans in place, and what better opportunity to review your program than while updating documentation to be in compliance with the new requirements — let’s take a look.
Make it Easy to Find SDS Information in an Emergency
The change from MSDS to SDS is simply a new standard that makes it clearer and easier for you, your employees, and first responders such as firefighters and medical emergency personnel to understand hazardous material on your property, how to handle it, how to react if you accidentally come into contact with it, and what to do in an emergency. Manufacturers should have already completed the transition of all documentation to the SDS standard this year and distributors had until December 1, 2015, to do so. Chances are you’ve received SDSs already and may not have realized you had to replace the old MSDSs with the updated documents.
Getting the SDS for each chemical and putting it in a binder, however, isn’t enough. Each employee must know what it is, where to find it, and how to read it. Signed training records should be available upon inspection. SDS formatting and appearance are different and training should be part of your new-hire procedure as well as an ongoing program to reinforce its importance. If you don’t already have an SDS center hanging on your wall, buy one immediately, and don’t overlook the labeling of secondary containers such as plastic spray bottles. Having perfect SDS documentation at your site would be useless for the parent of the child in the back seat of the car I mentioned above. What could they tell paramedics or a doctor if the bottle had no label? Sometimes chemical suppliers can provide you with labels to apply on secondary containers, but often it’s safer to buy supplies in the size you use already labeled. However you go about doing it, don’t take the risk of not maintaining strict labeling procedures for all secondary containers. Make sure every container that has a chemical has a label.
Provide Personal Protection Equipment (PPE)
It’s common sense to use proper PPE. OSHA standards require that all “affected” employees and contractors utilize proper PPE. What specific devices you need vary depending on the chemicals and services offered. The first step is always to do a hazard assessment of the entire workplace. There is a lot of literature available to assist you in performing your workplace assessment, but a good place to start is at www.osha.gov. The workplace assessment should be updated annually. This complete walk-through of your operation will identify every occurrence where an employee can come in contact with a hazardous condition.
Things that you should look for are low clearances, location of flammable substances, hazardous chemicals, excessive noise, and moving machinery. Once each hazard is identified, you must document it along with a specific PPE that must be used to eliminate the hazard. The most common PPEs found at a car wash include eye protection, splash guards, face shields, nitril gloves, ear plugs, rubber soled shoes, warning signs, burn sleeves, barrier cream, and aprons. It is critical to be very specific in your documentation. Never indicate something generic such as facial protection, be very specific with the actual PPE that must be used.
Review Your Emergency Response Plan
OSHA guidelines also direct employers to implement an emergency action plan. The importance of doing this cannot be over emphasized. Benefits include reduced workman’s comp rates, improved employee morale, and decreased employee downtime from injury. Creating your plan will take some time and consideration. It will include emergency contact lists and procedures, as well as plans for evacuation, fire prevention, readiness and focus, hazardous material release response, medical emergency, severe weather, and overall site organization. Each car wash represents different considerations, but an excellent place to get started is with the free resources found on the OSHA website.
Enforce Lock-Out/Tag-Out Procedures
If you don’t already have a lock-out/tag-out kit at your wash, buy one; it will be the best hundred dollars you can spend. Select a kit with the proper quantity and type of locks and tags for the equipment at your wash. In addition to all wash components, you will also want to make sure you have supplies for air compressors, conveyors, pumps, air lines, and hydraulic lines. Make sure you communicate a policy for immediate replacement of any item in the kit that becomes unusable.
Basically lock out/tag out dictates that any person servicing machinery or equipment must physically disable the item before working on it. Whenever possible, a lock must be used to keep the item from being reenergized. If it is not possible to lock out an item, then it must be tagged out. Only the person who has locked or tagged out the item is permitted to reenergize it, unless that person has left the property and passed authority to another, according to the plan you have put in place. Under no circumstance can an item ever be reenergized before the lock out/tag out is removed.
The concept is simple, and the required supplies affordable. It protects the person working on the machine or component from serious injury or death. It prevents machines or components from becoming active while someone is working on them. Examples of risks could include electricity, gravity, and hydraulics. Like PPE, the difficulty lies in ensuring that procedures are adhered to always, without exception. It demands a formal, well documented training policy. Affected employees must understand both the use of locks and tags, and the need to use them no matter how quick they think the service will be. Training is not a one-shot deal. At minimum, all affected employees should be re-trained on an annual basis. In addition, training must be administered whenever an employee is reclassified or placed into a position requiring the use of electrically energized machinery or equipment. Employees should formally sign documentation thatthey have received training.
View it as an Opportunity
I’ve been told that when the Coast Guard stops a boat, they’ll ask the owner to get the documentation. While they’re gone they’ll ask the youngest crew member if they know where the life jackets are, and if they don’t know, the owner is fined. OSHA is similar and you must be prepared. Complying with the new SDS format is a requirement, but when you combine it with an audit of your entire prevention and counter-measure plan and train your employees on them before an accident happens, it becomes an opportunity. Taking a few minutes to stock your safety supplies, refine your documentation, and review your training procedures will pay off every time.
Good luck, and good washing!
Washing cars for over 30 years, Anthony Analetto serves as president of SONNY’S The CarWash Factory, creator of the Original Xtreme-Xpress Mini-Tunnel, and the largest manufacturer of conveyorized car wash equipment, parts, and supplies in the world. He can be reached at Aanaletto@SonnysDirect.com or at (800) 327-8723 ext. 104.