The basics of workplace safety
There are many good reasons to cultivate a culture of safety in a tire dealership. It will help keep employees injury-free and able to perform their duties. It will help keep the shop in compliance with the United States Department of Labor’s (DOL) Occupational Safety and Health Administration (OSHA) regulations. It is also important for liability and insurance purposes.
The most important reason might be: “The tire dealer or shop manager should want to protect his people, and that should be the main reason to care about workplace safety, because it’s the right thing to do,” says Kevin Rohlwing, Tire Industry Association (TIA) senior vice president of training.
Under the Occupational Safety and Health Act of 1970, employers are responsible for providing safe and healthful workplaces for their employees. OSHA says its role is to assure these conditions are met by setting and enforcing standards, and providing training, education and assistance.
TIA also provides training and education specific to tire dealerships, and dealers need to know what areas to focus on to keep employees safe and the business profitable.
“Safety has to be a culture at a tire dealership,” says Rohlwing. “That’s probably the biggest struggle a dealer is going to have is to get a culture of safety from top to bottom. It starts with the owner and with the manager.”
After employee safety, the next highest priority for a tire dealer should be OSHA compliance. In some states OSHA regulations are enforced at the federal level, and in some there are local OSHA regulations.
“There are about 20 states that have local OSHA, such as Maryland, which has Maryland Occupational Safety and Health, or MOSH,” says Rohlwing. “There usually is never that big of a difference between federal and state; it’s more about who enforces it. Is it being enforced at the national level or on the local level?”
Rohlwing says a tire dealer can find out if the dealership meets OSHA standards by requesting a safety audit.
“If a dealer wants that, OSHA will send somebody to do a safety audit and tell them what they have to do to be in compliance. It’s probably against the nature of most tire dealers to call OSHA on themselves, and say, ‘Hey, come in and look at my operation,’ but if you really want to make sure that you’re compliant with every single regulation, that’s probably the best way to do it.”
Rohlwing says that much of what OSHA regulates could be considered “the basics.” There are four main areas for tire dealers to focus on, and they are not only the basics of workplace safety, but of OSHA compliance:
- employees have to wear personal protective equipment (PPE) and machine guards have to be in place;
- lifts must be inspected and used correctly;
- chemicals have to be stored properly with safety data sheets (SDS) on file; and
- trip and fall hazards must be identified and aisles must be cleared.
Personal protective equipment
Rohlwing says in order to identify what PPE is needed, a tire dealer must perform a hazard assessment of his shop.
“You walk through a shop and identify every potential hazard to technicians,” says Rohlwing. “Based on the hazard analysis, that’s how you get to the safety side of it. OK, we’ve identified all of these hazards, now what are we going to do to protect the technicians?”
Hazard assessments are required at all auto repair facilities. Assessments evaluate any hazards that may exist in a shop, what the employees do on a regular basis, what they’re exposed to, and what personal protective equipment they are required to wear.
Examples of PPE are:
- eyes — safety glasses, goggles;
- faces — face shields;
- heads — hard hats;
- feet — safety shoes;
- hands and arms — gloves;
- bodies — vests;
- hearing — ear plugs, earmuffs.
Tire dealers can write their own hazard assessment, or some companies, such as KPA LLC, provide hazard assessments services. KPA is a compliance expert on safety, environmental and human resources issues.
How does a tire dealer perform a hazard assessment?
“A good first step is to use the KPA risk assessment tool (www.kpaonline.com/environmentandsafety101) or download a checklist from OSHA or your state’s DOL or OSHA website,” says Eric Schmitz, vice president of product and business development at KPA.
“A hazard assessment is just one component of an effective loss control program. A hazard assessment requires observing the work environment and recording everything from behaviors to materials that could cause an accident. The assessment has to be evaluated, and a framework is built around those findings. Together, the two parts form a plan of effective and sufficient preventive measures. A successful risk management program engages employees.”
To create a PPE hazard assessment, document each employee’s tasks, what hazards they are exposed to, and then, finally, how the hazards are eliminated. Engineering controls such as guards and shields on the equipment should be used to eliminate hazards whenever possible. PPE should always be the last line of defense. Keep your PPE hazard assessment filed on-site to provide to OSHA during inspections.
After performing a hazard assessment and identifying danger areas, then PPE items are brought into place. In auto repair facilities, PPE starts with eye protection. In a typical tire service facility, the eyes are constantly bombarded with dust and other airborne particles, especially when repairing tires with rotary tools and attachments.
Something as simple as a valve core has the potential to be hazardous to the eye. Technicians must always wear approved protective eye wear with side shields to protect the eyes from all types of hazards. However, when using a rotary wire brush to clean rim flanges, a full face shield is recommended.
Other types of PPE that passenger and light truck tire technicians may require are heavy-duty work gloves for handling tires with exposed steel, hearing protection when using pneumatic tools, and leather work boots or shoes with non-slip soles.
According to the OSHA regulation 29 CFR 1910.132, every employee must wear personal protective equipment and know the answers to the following questions:
- When is PPE necessary?
- What PPE is necessary?
- How should the PPE be properly donned, doffed, adjusted and worn?
- What are the limitations of PPE?
- What must be done for the proper care, maintenance, useful life and disposal of the PPE?
The employer’s responsibility is to provide PPE to employees (at no cost to them), train employees on their use, and to enforce their use. It is recommended that a business develop a PPE policy that is acknowledged by employees with documentation. This allows management to enforce the use of PPE based on established policy. OSHA may conclude that employers are in violation of the enforcement standard if they have no history of disciplinary action. PPE training should occur before the employees use PPE. Training is typically performed in the new hire process at a minimum.
Employers should review their PPE program frequently and make changes as necessary. The addition of new hazards at the facility or new chemicals may necessitate new types of PPE. Managers are encouraged to review all new SDS sheets to ensure that proper PPE is available to all employees who require it.
Lifts: inspections, proper use
“The main thing right now from a safety perspective that OSHA seems to be focusing on are lifts,” says Rohlwing. “Dealers have to make sure that all lifts are functional and that all the safety stops are operational and everything is properly labeled.”
The most common safety issues uncovered during a lift inspection center around maintenance issues, product misuse and poor or non-existent operator training. A few examples might include: slack, rusty, dry or damaged link chains or wire ropes; worn rotating parts; worn sliding parts; worn vehicle contact points; missing over-travel stops; lift controls and safety devices that have been over-ridden, removed or damaged; obliteration of labels; use of incorrect components or parts; unintended use; deformed structural components; failure to employ proper care in operation or maintenance; or missing instructional materials.
“The American National Standard governing lift operation, inspection and maintenance ANSI/ALI ALOIM (current edition), requires that all vehicle lifts be inspected at least annually by a qualified lift inspector,” says R.W. “Bob” O’Gorman, president of the Automotive Lift Institute (ALI).
“As OSHA and other health and safety officers have stepped up their enforcement of lift safety and inspection standards, we’ve seen the demand for qualified lift inspectors increase dramatically.”
O’Gorman says that in response to this growing demand, the ALI invested several years and more than $700,000 to develop the ALI Lift Inspector Certification Program, which was introduced in 2012.
“It’s a natural extension of the other important lift safety programs ALI manages in support of our mission to promote the safe design, construction, installation, service, inspection and use of vehicle lifts.”
ALI says the Lift Inspector Certification Program is the first in North America to independently test and certify vehicle lift inspectors while also evaluating their employer’s record keeping and quality control measures. ALI’s online directory of certified inspectors allows shop owners, supervisors and technicians to find local ALI-certified lift inspectors.
But it’s not only certified ALI Lift Inspectors who can inspect lifts. “The ANSI/ALI ALOIM (current edition) calls on lift operators to perform daily inspections of their lifts prior to use,” says O’Gorman. “It also requires periodic inspection in accordance with the lift manufacturer recommendations. These inspections must be performed by a ‘qualified lift inspector.’ The standard includes qualifications, training and documentation requirements for qualified lift inspectors.”
O’Gorman says the ALI Lift Inspector Certification Program takes the onus off of the customer to determine if someone presenting himself or herself as a “qualified” lift inspector actually meets all of these requirements.
So what conditions have to be met for a lift to be considered safe? “A lift itself can only be ‘certified’ at the time it is designed, tested and manufactured,” says O’Gorman. “For vehicle lifts, there is a separate American National Standard, ANSI/ALI ALCTV (current edition) that covers safety requirements for construction, testing and validation. To be ALI certified, a lift must have been tested and proven to meet all the requirements of this standard by an OSHA-accredited and ALI-authorized Nationally Recognized Testing Laboratory (NRTL).”
A lift that passes an annual inspection and is appropriately labeled by an ALI-certified inspector is considered safe for continued use until an abnormal event requiring re-inspection occurs, or findings from a daily or regularly scheduled check causes the need for re-inspection.
Responsible lift manufacturers will provide recommendations identifying inspection points and frequency beyond those required by the national safety standard defining a minimum annual inspection.
Lift inspectors certified by ALI will tag every lift that passes inspection with a serialized, color-coded inspection label that indicates the month and year the lift passed inspection. A unique four digit number is on every label to identify the person performing each lift inspection. In this way it is easy to see at a glance if lifts are current on their inspection requirements and ALI is able to trace each and every inspection to the inspector placing the label on the lift.
Safety data sheets
According to TIA, since tire service facilities often include other types of mechanical repair and maintenance, technicians can be exposed to different substances and chemicals on a regular basis.
In the event that accidental ingestion, exposure or inhalation should occur, technicians should consult the safety data sheet (SDS) for that particular substance and then contact emergency services if directed.
“Safety data sheets used to be called material safety data sheets or MSDS,” says Rohlwing. “That’s probably one of the easiest ways for a tire dealer to get tripped up in an OSHA investigation. Every single chemical in the shop has to be listed in that safety data sheet. Every chemical that they use and every fluid has to be stored properly and a safety data sheet has to be on file in the shop and accessible to the employees. That seems to be a real easy mark for the OSHA inspectors.”
SDSs come from the manufacturer and a typical tire shop is required to have them on file for everything from brake parts cleaner, oil, power steering fluid, transmission fluid, and everything else that contains any kind of chemical.
“It also has to be specific to the product,” says Rohlwing. “If you have four different brands of oil then you have to have a safety data sheet for each brand. If there’s a chemical in the shop, an OSHA inspector can say, ‘Where is the safety data sheet for this?’ and if you don’t have it, that’s a violation.”
Trip and fall hazards
Housekeeping also plays a critical role in workplace safety. Scrap tires should be removed from the service area as soon as possible so they don’t become trip hazards.
Spills and loose material on the floors should be cleaned up immediately to prevent a slip and fall accident.
“Hoses should be on reels and off the floor,” says Rohlwing. “If you’ve got an exit door, there has to be a clear aisle all the way to that door.”
Rohlwing says storage is a big issue at tire dealerships because space is a premium. Dealers use any available space for storage, but they must remember that they cannot block an exit, an entrance or an aisle way.
Attention to housekeeping is critical, says Rohlwing. “Are spills cleaned up properly? What is your policy for a spill? Do you have pads? Do you have clean-up kits? Do you have oil-dry? What do you do with the oil-dry after it’s used?”
To eliminate trip and fall hazards, all of these questions have to be answered and communicated to all employees.
Dealers and managers must determine the plan of action in the event of a chemical spill. Spills also must be cleaned up immediately.
“I see that quite a bit when I walk into shops,” Rohlwing says. “Something was spilled an hour or two ago, and it’s still on the floor. That can’t happen.”
Spreading safety from shop to street
Finally, technicians must realize that the hazards related to passenger and light truck tire service in the shop only represent part of the risks.
When a tire fails or a wheel is separated from the vehicle at highway speed, the loss of control can result in a severe accident. Therefore, technicians should always follow the guidelines that have been established to promote safety in the shop and on the highway. ■
OSHA checklist for establishing a PPE program
The Occupational Health and Safety Administration (OSHA) offers a personal protective equipment (PPE) checklist for business owners on its website, (www.osha.gov). When determining shop functions that may require PPE, tire dealers and managers must pay attention to activities that involve any hazards to the face, head, feet, hands, body and hearing.
- Identify steps taken to assess potential hazards in every employee’s work space and in workplace operation procedures.
- Identify appropriate PPE selection criteria.
- Identify how you will train employees on the use of PPE, including:
- What PPE is necessary.
- When PPE is necessary.
- How to properly inspect PPE for wear or damage.
- The limitations of the PPE.
- How to properly put on, adjust the fit and take off the PPE.
- How to properly care for and store PPE.
- Identify how you will assess employee understanding of PPE training.
- Identify how you will enforce proper PPE use.
- Identify how you will provide for any required medical examinations.
- Identify how and when to evaluate the PPE program.
Something as simple as a valve core has the potential to be hazardous to the eye. TIA trainers note technicians must always wear approved protective eyewear with side shields to protect the eyes from all types of hazards.
Stretching helps prevent back injuries
According to the Tire Industry Association, the nature of automotive tire service requires constant lifting and bending, so it’s no surprise that a recent survey of workers’ comp claims in the tire industry revealed that 44% of all injuries were back strains.
That is why it is important to always bend the knees and lift with the legs, especially when lifting tire and wheel assemblies off the ground. And when determining the working height of the vehicle for tire service, technicians should keep wheels around waist-level or lower.
A major component of every lifting safety program is proper stretching prior to each day’s work. Studies have shown that after instituting company-wide stretching exercises, the number and severity of employee injuries can be significantly reduced. Always consult a doctor before starting a stretching or exercise program.