By the ARA Certification Committee
These requirements reflect OSHA’s belief that training is an essential part of every employer’s safety and health program for protecting workers from injuries and illnesses.
Simple safety steps can be implemented to significantly increase OSHA compliance at any auto recycling facility. The Certified Auto Recycler (CAR) standards can provide members with the tools to audit and improve their yard safety compliance. A safety culture is easier to create than anticipated with simple safety steps.
Start with the basics. Start with the rule that is the basis of OSHA regulations.
Does the facility have a written Hazard Communication Standard (HCS) plan in which all employees have been trained on HCS & GHS Standards?
The 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.
But first the facility must prepare and maintain a written Hazard Communication Plan. A sample plan is available for download at https://aracertification.com/guidance. The written plan should narrate the procedures for keeping updated information about the chemical in the workplace and making that information available to the employees.
The plan requires that an individual is designated as the safety supervisor.
The CAR standard asks for the name and email address of the facility’s safety supervisor.
Conduct an inventory of chemicals in the workplace. Maintain this list along with the corresponding Safety Data Sheets (SDS). 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. The SDS book should be available to employees in the area where the chemicals are used and/or stored.
The CAR standards ask: Are workplace chemicals listed in an inventory and the corresponding Safety Data Sheets (SDS) information complete, up-to-date and easily accessible? Document verification is required in the CAR program. Material Safety Data Sheets (MSDS) pre-date SDS and should be replaced with updated versions every five years.
In 2012, in addition to changing the format of MSDS to SDS the Hazard Communication rule added labeling requirements that also lined up with other United Nations’ members to standardize workplace chemical awareness. That is the reason the secondary labels required in the workplace are called the Globally Harmonized System (GHS) of chemical identification labels.
OSHA Has Labeling Requirements Under the Globally Harmonized System
The HCS has labeling requirements that display the GHS identification of chemicals, signal words, pictograms and precautionary statements. The type of label required in the workplace is called a secondary label (not for transport). Containers of all sizes must be labeled. One label can meet environmental and NFPA requirements too.
The CAR standards ask: Are the GHS of chemical identification labels adhered to tanks, totes, drums and fluid containers of all sizes?
Training on the Hazard Communication Standard is required to make employee aware that the rule is there to protect them. The training should include a review of the written HCS plan, how to read the SDS and where to find them in their workplace and what the labels with the pictograms are indicating as a warning.
These requirements reflect OSHA’s belief that training is an essential part of every employer’s safety and health program for protecting workers from injuries and illnesses. Many researchers conclude that those who are new on the job have a higher rate of accidents and injuries than more experienced workers.
Other safety training topics are required by OSHA, many on an annual basis. The CAR program safety standards covers these topic areas and asks: Does the facility have a safety program with regularly scheduled safety meetings and inspections that are logged? OSHA concluded that effective management of worker safety and health protection is a decisive factor in reducing the extent and the severity of work-related injuries and illnesses. Effective management addresses all work-related hazards, whether or not they are regulated by government standards.