Chemicals — Safety and Right-to-Know Programs
Tailoring a safety and right-to-know program for your detail operation is a good way to comply with federal and state regulations. It’s also common sense. As the detail industry continues to grow and mature, it is gaining more and more exposure — not only to potential customers, but also to government agencies and officials.
The effect of this exposure is quite simple: You will be required to meet all of the federal OSHA rules and regulations (as well as state regulations) regarding chemicals, their content, hazards, and safety precautions. These rules may generate a great deal of concern, and your immediate reaction may be negative. However, your reaction may be inappropriate.
Think about it. Doesn’t it make sense that you and your employees know what kind of chemicals you
are using? How they can harm you? What they contain? What to do if they get on your skin, in your eyes, or are ingested?
This is what this is all about: protecting you and your employees.
As an operator, I too became concerned when I received a letter from the International Carwash Association indicating the severe repercussions that could occur if my business did not comply with the rules. In order to find out what the rules were, we contacted the State of Oregon Accident Prevention Division. Pleased that we were concerned about this, they sent out to our two stores an inspector whose only purpose was to review our operation and tailor a safety and right-to-know program for us. This organization is not an enforcement group. They will not report us to any other agency as long as we agree to put into effect within 45 days the program they outlined for us. The following is the program prepared by the State of Oregon Accident Prevention Division for our stores. As you read it, you will see there is nothing extraordinary in the requirements, only common sense.
WRITTEN HAZARD COMMUNICATION PROGRAM
In order to comply with Oregon Occupational Health and Safety Code (OAR CHAPTER 437) Division 155, Hazard Communication, the following written Hazard Communication Program has been established for Detail Plus Car Appearance Centers.
All company divisions and sections are included in this program. The written program will be available in each store for review by any interested employee.
The company will meet the requirements of this rule as follows:
1. Container Labeling
The store manager will verify that all containers received for use will:
- Be clearly labeled as to the contents
- Note the appropriate hazard warning
- List the manufacturer’s name and address
It is the policy of this company that no container will be released for use until the above data is verified.
The store manager will ensure that all secondary containers are labeled either with an extra copy of the original manufacturer’s label or with the “central stores” generic labels, which have identification and hazard warning blocks. For help with labeling, see our safety/health officer.
2. Material Safety Data Sheets (MSDS)
Copies of MSDS for all hazardous chemicals to which employees of this company may be exposed will be kept at the office of each store.
MSDS will be available to all employees in their work area for review during each work shift. If MSDS are not available or new chemicals in use do not have MSDS, immediately contact Keith Duplessie at corporate headquarters.
3. Employee Information and Training
Prior to starting work, each new employee will attend a health and safety orientation and will receive information and training on the following:
- An overview of the requirements contained in Division 115, Hazard Communication Rules.
- Chemicals present in their workplace operations.
- Location and availability of our written hazard program. Physical and health effects of the hazardous chemicals.
- Methods and observation techniques used to determine the presence or release of hazardous chemicals in the work area.
- How to reduce or prevent exposure to these hazardous chemicals through use of control/work practices and personal protective equipment.
- Steps the company has taken to reduce or prevent exposure to these chemicals.
- Safety emergency procedures to follow if the employee is exposed to these chemicals.
- How to read labels and review MSDS to obtain appropriate hazard information.
After attending the training class, each employee will sign a form to verify that they attended the training, received our written material, and understood this company’s policies on hazard communication.
Prior to a new hazardous chemical being introduced into any section of this company, each employee of that section will be given information as outlined above.
The store manager is responsible for ensuring that MSDS on the new chemical(s) are available.
4. Hazardous Chemicals List
The following is a list of all known hazardous and non-hazardous chemicals used by company employees. More information on each chemical noted is available by reviewing MSDS located in the office at each store.
- Solvent
- Miracle Overspray Remover
- Paint Cleaner
- Paint Sealant
- Cream Wax
- Compound
- Swirl/Away Polish
- Upholstery Shampoo
- Window Cleaner
- Fabric Protectant
- One Step Cleaner/Glaze
- Wheel Cleaner
- Gel Degreaser
- Fragrance
- Mink Oil
- Vinyl Dressing
- All Purpose Cleaner
5. Hazardous Non-Routine Tasks
Periodically, employees must perform hazardous non-routine tasks. Before starting work on such projects, each affected employee will be given information by the section supervisor about hazardous chemicals to which they may be exposed during such activity.
The information will include:
- Specific chemical hazards.
- Protective/safety measures employees can take.
- Measures the company has taken to reduce the hazards, including ventilation, respirators, presence of another employee, and emergency procedures.
6. Chemicals in Pipes
Work activities are often performed by employees in areas where chemicals are transferred through pipes.
Prior to starting work in these areas, employees will contact the store manager for information regarding:
- The chemicals in the pipes.
- Potential hazards.
- Safety precautions to be taken.
7. Informing Contractors
It is the responsibility of the store manager to provide contractors (with employees) the following information:
- Hazardous chemicals to which they may be exposed while on the job site, and the procedure for obtaining MSDS.
- Precautions employees may take to lessen the possibility of exposure, by using appropriate protective measures, and an explanation of the labeling system used.
Also, it is the responsibility of the store manager to identify and obtain MSDS for the chemicals the contractor is bringing into the workplace.
CONTACT YOUR STATE AGENCY
If you do not have such a complete program in effect, I can only advise you that you are subjecting yourself and your employees to great physical harm, not to mention potentially heavy financial penalties.
It is critical that you contact the appropriate agency in your state to have them assist you in developing this program. If you do not and the hammer falls, you only have yourself to blame.
FOR YOUR OWN PROTECTION
The International Carwash Association continually stresses the importance of compliance with federal, state, and local occupational safety and health regulations and has gathered a great deal of information about the subject.
Car wash operators should be aware, the association warns, that willful disregard of OSHA regulations can end up with operators paying heavy fines or even going to jail. Keep in mind that many states have requirements that are stricter than the federal law. For our own protection, it’s terribly important to comply with whichever is stricter.
How can you find out what regulations apply to your area? Call the ICA at (312) 321-5199. They have a complete list of all OSHA offices, state by state, including regional offices, and they will be happy to give you the appropriate telephone numbers and addresses.
Keith Duplessie is the technical services manager for Portland, OR-based Detail Plus Car Appearance Systems. You can reach Keith at keith@detailplus.com.
