In this month’s column, two very important topics are covered. The first part is about “safety,” which refers to shop policies, preventive measures, and established practices designed to reduce the potential for injury to detailing technicians and damage to customer vehicles. The second part explores “compliance,” which refers to the shop owner’s efforts to ensure the operation remains in compliance with all applicable local, state, and federal regulations.
Safety First
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 comprehensive safety policies are in place, clearly communicated to employees, and that employees have the resources necessary to implement them.
The company’s safety policies should be in writing and included in the employee manual. It’s best to have this manual on your own computer in a format that allows you to modify it easily, so it can be updated as situations arise that require new policies.
It is not enough to hand an employee a stack of printed pages to read. Most states require employers to hold mandatory regular safety meetings, sometimes as often as weekly. Consider this an opportunity to explain and clarify the company’s safety policies through discussion and demonstration of approved safety techniques.
This meeting also gives employees the opportunity to share their observations about safety issues and to seek clarification on policy specifics that might be confusing. Each safety meeting should be documented with the date, who attended, and what was discussed.
Safety starts with personal protection. Each employee should be equipped with items such as OSHA-approved safety glasses and hearing protection, chemical-resistant gloves, an apron, and any other apparel that helps prevent injury. The “policy” part comes into play when management makes it clear that the use of these items is mandatory. Management’s responsibility is to consistently enforce that policy and ensure personal protective equipment is available.
Of course, even the best safety program cannot completely prevent accidents. Thus, the need for emergency equipment such as fire extinguishers, eyewash stations, and first-aid kits (with instructions). The extinguisher can also help protect customer vehicles from damage 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 if an employee accidentally squirts a chemical into their 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.
A critical component of shop safety involves vehicle movement through the shop. Appropriate policy will include identifying the personnel authorized to move customer vehicles, as well as a list of precautions to be taken before repositioning 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’s door open or with any equipment on the car.
When educating employees about these rules, remind them that their purpose is to ensure the safety of fellow employees and reduce the risk of damaging customer cars.
An injured employee can be expensive to the business from two perspectives. The first is that the company may be responsible for the injured employee’s medical care. The second is the “cost” of that employee’s lost productivity during recovery. So, it can be argued that a serious approach to employee safety is an investment against potential loss.
Chemical Safety And Management
Detail shops are not immune to local, state, and federal regulations governing chemical management, even though our operations may handle relatively small quantities 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 the SDS for that chemical available. 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 employees.
Additionally, every bottle or container containing a chemical must be properly labeled. So, when you pour your favorite all-purpose cleaner into a trigger sprayer, for example, you must label that bottle (even if with a marker) with the chemical name, the 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.
Part of management’s job is to educate all employees on the proper use of each chemical in the shop, including proper dilution ratios, first aid, and spill cleanup procedures. For example, at a safety meeting, the manager might actually read the entire label for each chemical, including the dilution instructions, which should be clearly emphasized as “required” rather than “suggested.”
Dilution of concentrated chemicals is of particular concern. 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 damage the vehicle and, more importantly, cause injury to the employee from incidental contact or inhalation of the overly concentrated chemical. One solution for dilution issues is to have a dilution station where dilutable chemicals are automatically diluted, or diluted in large batches, by a dedicated manager or a single “chemical monitor,” who is the only person allowed to dilute. With this system in place, the technicians who want to refill their chemical bottles deal only with pre-diluted chemicals and never touch the concentrate.
Another responsibility of the shop owner is to have a hazardous materials management plan in place. This includes proper storage of flammable chemicals in a specially designed and marked metal cabinet, as well as having a spill kit available in the event that a large quantity of chemical accidentally spills on the ground.
It is not enough to have these plans in place, however. Once again, it is critical that all employees be educated on the chemical management plans and on what to do in the event of chemical accidents.
Regulatory Compliance
Every business owner, regardless of the type of business, is responsible for complying with all local, state, and federal regulations. At first, this can seem like a daunting task. However, it can be accomplished with some persistent effort and patience.
The “for-sure” compliance issues for most operations include:
• 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 obtained 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. Workers’ compensation insurance can be purchased from your business insurance agent (who may also cover your garage keeper’s and business liability insurance). We spoke about chemical management above.
There are potentially numerous municipal (city-level) and county regulations to adhere to. Visit their offices or search online to find information on 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 than spend a lot of time and effort trying to locate and fine “offenders.”
An important compliance consideration is adherence to the Clean Water Act of 1973, which requires that water entering natural watercourses and bodies such as streams, rivers, lakes, and the ocean 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 enforcement of this regulation is left to local municipalities, so your city or county may or may not enforce it strictly. As a professional operator and good steward of our environment, the best approach is to collect wastewater and dispose of it properly.
Summary
Paying attention to safety and compliance issues does not immediately lead to greater profits. But taking the time to address these issues up front can help prevent costly consequences in the future.
Prentice St. Clair, CD-SV/RIT, has been serving the automotive reconditioning industry since 1999 with impassioned consulting and training and the goal of increasing the profitability of the automotive detailing and reconditioning industry. He is proud to have been inducted into the International Detailing Association’s Hall of Fame. Prentice welcomes inquiries that lead to the opportunity to help readers achieve excellent results. He can be reached via call or text at (619) 701-1100 or e-mail at prentice@detailingprogress.com.