By Matthew Genna, Partner Engineering and Science, Inc.
In December, the US Department of Labor issued a release detailing a fatal flash fire at an auto dealership in Alabama. “Inspectors determined that the employees were using a flammable brake wash to scrub the service pit floor when the fire occurred,” the release said. “As a result, three employees were fatally injured and a fourth was critically burned. A fifth employee was treated for smoke inhalation and released.”
A flash fire is a sudden, intense fire caused by ignition of a mixture of air and a dispersed flammable substance such as a solid, flammable or combustible liquid, or a flammable gas.
The OSHA Area Director reporting on the event blamed the dealership’s “failure to effectively implement a hazard communication program.” The dealership was fined over $150,000 for serious safety violations and given 15 business days to comply or contest the findings before an OSHA review commission. In addition, a wrongful death lawsuit on behalf of the children of one of the victims was filed against the dealership.
It’s easy to dismiss OSHA compliance as a hassle—particularly in the case of administrative controls like a Hazard Communications Program—until an event like this reminds us why we establish safety protocols in the first place.
This tragic story serves as a wake-up call to automotive businesses across the country: Do you have a Hazard Communication Program in place? Is it current and effectively implemented? Do your employees know which chemicals they are working with and how to protect themselves?
What is a Hazard Communication Program?
OSHA’s Hazard Communication Standard (OSHA 29 CRF 1910.1200) requires that the identities and hazards of all chemicals within the workplace must be available and understandable to workers. This includes all chemicals produced in or imported to the United States.
In other words, do your employees know which chemicals in the workplace are hazardous? Are all the chemicals in your facility properly labelled with the type of hazard—i.e. fire, corrosive, inhalation—clearly identified? Do the employees understand the risk and proper handling procedures for these chemicals? Do they know where to find the Safety Data Sheets for all the chemicals that they work with? Have the employees been trained regarding the Hazard Communication Standard?
A written Hazard Communication Program will answer these questions and more. It will meet the OSHA standard with a comprehensive plan to classify hazardous chemicals and take appropriate measures to educate and protect employees, and may include:
- Preparing a written document outlining the Hazardous Communication Plan;
- Maintaining an inventory of the hazardous chemicals present in the workplace;
- Ensuring all the hazardous chemicals are properly labeled;
- Preparation and distribution of Safety Data Sheets (SDS);
- Providing employees with a Hazard Communication training program regarding chemical hazards and protective measures; and
- Providing Right to Know Survey filing services.
Why should you implement a Hazard Communication Program?
Beyond the obligation to protect your employees’ health and safety, as well as the legal requirement to achieve compliance, you can consider a Hazard Communication Program an investment in the value of your dealership. Here are three ways that safety programs like a Hazard Communication Program impact your bottom line.
- Risk Mitigation: OSHA compliance is a liability issue. Failure to comply can cost big bucks in fees. If a dealership has an established safety program, including employee education and training, then it is less likely to incur fees, but also less likely to incur more serious liability, such as the deaths in Alabama dealership fire.
- Brand identity: A serious safety incident or a reputation for being unsafe hurts your brand and could impact sales. As a driver of demand, brand identity is a component of blue-sky multiples. Therefore, establishing a culture of safety in your dealership could boost the blue-sky valuation of your business.
- Profitability: Safe workplaces and safety training improve the quality of life of a dealership’s employees and technicians. When your dealership is known as a safe place to work, you can attract and retain better employees, making operations more productive and minimizing the expense of employee turnover. Also, safety incidents can be expensive: worker’s compensation claims, lawsuits, damage or loss of property, and interrupted operations will take a toll on your balance sheet.
Partner Engineering and Science, Inc., is a market-leading provider of environmental, engineering and energy consulting and design services, supporting real estate owners, lenders and operators throughout the life cycle of their assets.
Matthew Genna, a project manager for Partner Engineering and Science, Inc., specializes in health and safety consulting. He conducts regulatory compliance audits and workplace accident investigations; develops safety programs; and facilitates education and training to clients in the automotive, industrial and manufacturing sectors. He can be reached at 732-380-1700 x1271 or firstname.lastname@example.org