Features

Ducks in a Row - Safety and Compliance

By Prentice St. Clair

08/22/19

In this month’s column, I’d like to circle back to a topic that I’ve covered a couple of times many years ago — with some updates. The first part is about “safety,” which refers to things like shop policies, preventative measures, and established practices that are designed to reduce the potential for injury to detailing technicians and damage to customer vehicles. The second part is about “compliance,” which refers to the detail shop owner’s efforts to ensure that the operation stays within all applicable local, state, and federal regulations.

SAFETY FIRST

To start, let’s get one thing straight right up front. Shop safety is ultimately the responsibility of the owner or manager. The person in charge of the operation must ensure that there are comprehensive safety policies in place, that those policies are clearly communicated to the employees, and that the employees have the resources necessary to fulfill those policies.

The company safety policies should be in written form and part of an employee manual. It’s best to have this manual on your own computer in a format that allows you to modify it with commonly available word-processing software so that the manual can be easily changed as new situations arise that require new policies.

Yet it is not enough to hand an employee a stack of printed pages to read. Most states require that the employer hold mandatory regular safety meetings, sometimes as often as weekly. Consider this an opportunity to explain and clarify company safety policy with discussion and actual demonstration of approved safety techniques. This meeting will also give the employees the opportunity to share their own observations about safety issues, as well as to seek clarification on those policy specifics that might be confusing. Each safety meeting should be documented as to when it occurred, who attended, and what was discussed.

Personal Protection

Safety starts with personal protection. Each employee should be equipped with such items as OSHA-approved safety glasses and hearing protection, chemical-resistant gloves, an apron, as well as any other apparel that can help prevent injury. The “policy” part comes in when management makes it clear when the use of these items is mandatory. The management responsibility comes in the form of consistent enforcement of that policy in addition to making sure the personal protection equipment is available for use.

Of course, the best safety program cannot completely prevent accidents. Thus, the need for emergency equipment like fire extinguishers, eye-wash stations, and first-aid kits (with instructions). The extinguisher can also help protect against damage to the customer’s vehicle in the event of a small fire.

The eye-wash station is critical in the chemical-rich environment of a detail shop. A quick rinse-out of the eyes can help prevent permanent loss of sight in the event that an employee accidentally squirts chemical into the eyes. And the first aid kit should have provisions for simple cuts and abrasions, as well as provisions for more serious accidents.

Safety policy also includes how things are done in the shop. Chemical management is a big one and we will discuss that in a separate section. Other shop safety policy items might include keeping the floor free of towels, bottles, and unnecessary cords or hoses, as well as cleaning up spills to avoid slip-and-falls. Also important is how technicians use and store equipment, for example, having heavy equipment on lower shelves and properly capping all bottles.

Vehicle Movement

A critical component of shop safety involves vehicle movement through the shop. Appropriate policy will include identifying the personnel that have permission to move customer vehicles as well as a list of precautions that must be taken before re-positioning a customer vehicle. Establish very clear rules about vehicle movement, including:
• Have a second person keep watch as the vehicle is moved.
• Walk completely around the vehicle before moving it to check for items that might be run over.
• Tap the horn and check all mirrors before moving the vehicle.
• Do not move the vehicle with the driver door open or with any equipment on the car.

When educating the employees about these rules, remind them that these procedural rules are there for the safety of fellow employees as well as reducing the potential for damaging customer cars.

An injured employee can be expensive to the business from two perspectives. The first is the fact that the company may well be responsible for the medical care of the injured employee. The second is the “cost” of losing the productivity of that particular employee during recovery. So, it can be argued that a serious approach to employee safety is an investment against potential loss.

CHEMICAL SAFETY AND MANAGEMENT

The first thing to realize about chemical management in a detail shop is that we are not immune from the local, state, and federal regulations dealing with chemical management, even though our operation might have a relatively small quantity of chemicals compared to some other businesses. We still must have a Safety Data Sheet (SDS) for every chemical in the shop, and that SDS must be readily available for employees to examine.

By law, the supplier or manufacturer of every chemical must have available the SDS sheet for that chemical. Many suppliers have these documents available for download from their website. Gather these printouts and place them — in alphabetical order by brand name — in a binder labeled “SDS.” This binder should be easily available to the employees.

Additionally, every bottle or container that has a chemical in it must be properly labeled. So, when you pour off your favorite all-purpose cleaner into a trigger sprayer, for example, you must label that bottle (even if with a marker) with the name of the chemical, the chemical diamond hazard symbol, and first aid instructions. The easy way to deal with this is to work with a detail chemical supplier that has pre-labeled bottles available.

Dilution

Part of management’s job is to also educate all employees about the proper use of each of the chemicals in the shop, including proper dilution ratios, first aid, and spill clean-up directions. For example, the manager might actually read the entire label of each chemical, including the dilution instructions, which should be clearly emphasized as “required” and not just “suggested.”

Dilution of concentrated chemicals is of particular concern, as I have personally seen many instances of improperly diluted chemicals. Usually the problem is that the ready-to-use spray bottles contain an overly concentrated dilution of the chemical, typically because the technician who filled the bottle thinks that “more is better.”

Over-dilution of concentrates can lead to ineffective batches. Under-dilution can lead to damage on the vehicle and, more importantly, injury to the employee due to incidental contact or inhalation of the overly concentrated chemical.
One solution for dilution issues is to have a dilution station in which dilutable chemicals are automatically diluted or diluted in large batches by a dedicated manager. With this system in place, the technicians who want to refill their chemical bottles deal only with pre-diluted chemical and never touch the concentrate.

Another responsibility of the shop owner is to have a hazardous material management plan in place for the shop. This includes proper storage of flammable chemicals in a specially designed and marked flammable metal cabinet, as well as having a spill kit available in the event that a large quantity of chemical should accidentally spill on the ground.

It is not enough to have these plans in place, however. Once again, it is critical that all employees be educated in the chemical management plans as well as what to do in the event of accidents involving chemicals.

REGULATORY COMPLIANCE

Every business owner, regardless of the type of business, is responsible for remaining in compliance with all local, state, and federal regulations. At first, this can seem like a daunting task, sort-of a David and Goliath situation. However, it can be accomplished, with some persistent effort and patience.

The “for-sure” compliance issues for most operations are going to be:
• Possession of a local business license.
• Adherence to federal and state labor laws (if you have employees).
• Worker’s compensation insurance coverage (if you have employees).
• Correct management of chemicals.
• Adherence to the Clean Water Act.

The local business license can typically be taken care of through your city or county government. Adherence to labor laws is more complicated, but there’s plenty of information available online, or you can consult with an employment attorney. Worker’s compensation insurance can be purchased from your business insurance agent (who may also be covering your garage keeper’s and business liability insurance). We spoke about chemical management above.
Of course, I cannot tell you what other municipal (city-level) and county regulations there might be for your situation, but I suspect that if you visit their offices or search online, you can find some information about the regulations that might apply to your operation. Most government organizations are cooperative in providing information and answering questions. They would much rather collect a small annual licensing fee instead of spending a lot of time and effort trying to locate and fine “offenders.”

An important compliance consideration for our industry is adherence to the Clean Water Act of 1973, which specifies that water running into natural water courses and bodies like streams, rivers, lakes, and the ocean, must be free of contamination. This means no dirt, no debris, and no chemicals — not even “biodegradable” chemicals. In short, anything other than natural precipitation is forbidden from entering the storm drain system.

The actual enforcement of this regulation is left up to local municipalities, so your city or county may or may not enforce the regulation strictly. As a professional operator and good steward of our environment, the best approach is to collect washing wastewater and dispose of it properly.

SUMMARY

Paying attention to safety and compliance issues does not immediately lead to greater profits, no doubt. But spending the time to take care of these issues up front can help prevent expensive consequences in the future.

Prentice St. Clair is an International Detailing Association Recognized Trainer and Certified Detailer. As the president of Detail in Progress Inc., he has been providing training and consulting to car washes and detail shops since 1999. He is available at (619) 701-1100 or prentice@detailinprogress.com.



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