OSHA Safety Compliance for Self-Serve Facilities

Mar 1, 2024 | Safety

Following key safety protocols ensures self-service facilities are safe for all.

By Sue Schauls

The ARA Certified Auto Recyclers (CAR) program is asked about safety rules for self-serve facilities every year. The bottom line on OSHA safety compliance is that the same rules apply to self-serve and full-service facilities because the Occupational Safety and Health Administration (OSHA) governs any business with employees – any number of employees. The Illness & Injury Reporting is the only rule that does not apply to businesses with fewer than 10 employees. All other rules apply to all businesses with employees present in the workplace.

Let the CAR Program Guide You

Simple safety steps can be implemented to significantly increase OSHA compliance at any auto recycling facility.

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 Hazard Communication Standard (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. That is the main purpose of Safety Data Sheets (SDS).

The CAR program asks direct and concise questions to put recyclers on the path to OSHA compliance:

1. Are workplace chemicals listed in an inventory and the corresponding Safety Data Sheets (SDS) information complete, up-to-date and easily accessible?

2. Are Globally Harmonized System (GHS) of chemical identification labels adhered to tanks, totes, drums and fluid containers of all sizes?

3. Does the facility have a safety program with regularly scheduled safety meetings and inspections that are logged?

4. Is basic personal protective equipment (PPE) available and used when required? PPE can help complement other measures taken by employers and employees to minimize hazards and unsafe conditions. Recent OSHA revisions require the employer to complete a written hazard evaluation of the workplace to determine employee hazards and the PPE necessary to protect them. PPE is specialized clothing or equipment worn by employees for protection against health and safety hazards. Personal protective equipment is designed to protect many parts of the body, including; eyes, head, face, hands, feet, and ears.

5. Is OSHA approved 15-minute eye wash station readily accessible near all fluid evacuation areas and near corrosive materials? Workers’ eyes may be damaged very quickly by exposure to contaminants in battery storage or vehicle processing areas. The first fifteen seconds after an eye injury is critical. The American National Standards Institute (ANSI) suggests that eye wash stations be located within 100 feet, or a 10 second walk, of critical work areas.

6. Are fire extinguishers readily available, appropriately labeled and fully charged with appropriate inspection tag? Inspected by third-party annually and on-site visual inspection by facility with required inspection tag completed monthly. Fires may be caused by welding or torching, fuel or fume explosions, electrical problems, or ignition of combustibles. Take preventive measures, learn how to recognize and respond to different types of fires, and properly handle and store chemicals and flammable liquids. OSHA rule 29 CFR 1910.157 states that an employer shall provide approved portable fire extinguishers and shall mount, locate and identify them so that they are readily accessible to employees without subjecting the employees to possible injury. A multi-purpose ABC rated fire extinguisher is appropriate for an auto salvage operation.

7. Are first aid kits readily available to employees in close proximity to the dismantling areas, and adequately sized for the number of employees in that area? A first aid kit allows trained workers to respond to a minor injury or illness, and to provide temporary relief of a more serious injury until professional medical assistance is obtained. Every salvage yard should maintain a first aid kit on-site at the facility in the event of a medical emergency. A well-stocked first aid kit can complement other safety equipment such as the eye wash station and personal protective equipment. Together these supplies can protect employees.

8. Is a Lock Out – Tag Out (LOTO) program in place? Are LOTO supplies, such as hasp locks and tags, available? This program includes employee training to remove power source from equipment prior to repair or maintenance. LOTO is a safety procedure used in industry to ensure that dangerous machines are properly shut off and not started up again prior to the completion of maintenance or servicing work. Proper LOTO procedures protect workers from unexpected electrical surges, moving parts, and other crushing, slicing, puncturing threats. 

9. Are hoists inspected on a regular basis, such as monthly for frequent use hoists and upon use for infrequently used hoist? Inspections should be logged monthly. Annual inspection should have a tag affixed to the automotive lifts.

10. Is the ARA “Cutting Torch Use Education and Orientation Protocol” signed by all employees using a cutting torch or has cutting torch been removed from facility? The ARA CAR program suggests that the gas cutting torch is a tool that should have limited use and that any use should be monitored and restricted to employees that have been properly trained. All safety protocols must  be in place prior to the use of any gas cutting torch. Facility management and every employee that uses the gas cutting torch should review this document. Further training may be required or advisable based upon jurisdiction or property and casualty insurance carrier requirements or suggestions. A cutting torch is a tool that if not properly used, can lead to explosion, fire, flash burns, skin burns, eye injury and even loss of life. Some insurance companies have changed their insurance policies so that property damage and loss caused by the use of a cutting torch would lead to steeply increased deductibles in the event of a claim.

11. Are spill kits located throughout the facility? Spill kit score is earned in the Enviro section of the audit. Every salvage yard should maintain a spill cleanup kit on-site at the facility in the event of an emergency spill. Spill kits provide protection for employees (and customers) if the spill contains hazardous material. To accomplish this task the appropriate type of spill cleanup kit must be selected from the myriad of choices available. Another issue is to make sure that employees are trained on the use and locations of all spill cleanup kits. Simple to do if you do it, in your training. Finally, if the quantity of material spilled is sizable or made of acutely hazardous chemicals the spill must be reported to the regulatory agency. In some instances, an emergency response team will be discharged. These types of spills are infrequent at a well-equipped salvage yard.

12. Is the business compliant with the OSHA 300 Log injury and Illness Reporting Requirements?

13. Does the site have documentation of DOT Certification Training for HazMat shipping within the past three years for employees preparing the shipping of airbags/seatbelt pretensioners/hybrid batteries from the facility?

14. Does the site have documentation within the past three years of certification training provided to all forklift operators?

15. Are safety signs and reminders posted and visible for customers at self-service facilities and for employees at all facilities?

    The CAR program 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.

    Visit https://aracertification.com/guidance for a checklist and other guidance documents to assist in attaining or maintaining compliance. 

    Sue Schauls is an environmental and safety expert whose career started 28 years ago at the Iowa Waste Reduction Center at University of Northern Iowa. She is the Certification Consultant to the ARA and can be reached at sue@a-r-a.org. She is also the Executive Director of the Iowa Automotive Recyclers association and compliance consultant to the industry through the ARA’s Certified Auto Recyclers (CAR) program and the I-CARE program – Iowa Certified Automotive Recyclers Environmental Program.

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