ask the expert: all your environment and safety questions answered
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Ask the Expert: All your Environment and Safety Questions AnsweredTRANSCRIPT
Ask the Expert: All your Environment and Safety Questions Answered
Eric Schmitz
April 11, 2023
Presenter
3
Eric SchmitzVP Product and Business
Development
California Registered Environmental Assessor
15 years of dealer experience
303-228-8766
If you have questions during the presentation, please submit them using the “Questions” feature
QUESTIONSQuestions
Recent Dealer Citations
• Fluorescent Light Tube Disposal - household hazardous waste
• Airbag Detonation – considered treatment of hazardous waste
• DOT Shipment of fuel pump by air
Resources
OSHA 300 Log:
http://www.osha.gov/recordkeeping/ppt1/RK1exempttable.html
Training Resources:
http://www.kpaonline.com/news-and-events/newsletter/compliance-newsletter-june-2011/training-requirements.html
Supplemental Restraint System Recycling
The Problem:Clients deploying airbags & seatbelt pre-tensioners…
• Unsafe - Enormous potential energy stored and generated upon detonation.
• Illegal - EPA views detonation as treatment of hazardous waste• Environmental Negative - The detonated materials end up in
a landfill.
Supplemental Restraint System Recycling
The Options:• Shipment back to the manufacturer• Sell or donate them• Detonation and disposal as normal refuse - KPA
recommends dealers DO NOT detonate any airbags, or seatbelt pre-tensioners.
• Shipment and disposal as hazardous waste• Shipment as recycled materials…
----AND----
Don’t forget the DOT shipping Rules
OSHA Initiatives – I2P2
Outline
• White Paper Highlights• Secretary Hilda Solis• Recent OSHA Online Chat• 2012 DOL Budget Discussion • Summary
I2P2 White Paper Highlights (January 2012)
• Currently 15 states have regulations requiring an IIPP:
Arkansas, California, Hawaii, Louisiana, Michigan, Minnesota, Mississippi, Montana, North Carolina, New Hampshire, Nevada, New York, Oregon, Utah, and Washington.
• 19 states either have insurance premium incentives or have suggestive language to employers to adopt an IIPP.
I2P2 White Paper Highlights
2009 fatality rates in California, Hawaii and Washington were as much as 31 percent
below the national average.
I2P2 White Paper Highlights
Internal OSHA Small Business Study
By adopting an IIPP companies experienced:
• A reduction in the number of injuries and illnesses. • Improved compliance with regulatory requirements. • Improved business and cost savings. • Improved efficiency and productivity in operations and
material use. • An improved workplace environment with greater
collective responsibility for workplace health and safety. • Improved reputation and image in the community.
I2P2 White Paper Highlights
2009 OSHA examination of joint labor-management safety committees.
Committees participated in:• hazard identification • workplace inspection• safety management
IIPP
Lower experience mod
Increase in
all areas of
compliance
This is further evidence that programs with strong management commitment and active worker participation are effective in reducing injury risk, while "paper" programs are, not surprisingly, ineffective.
Plan Prevent Protect Regulatory Strategy
Secretary Hilda Solis
This agenda continues to build upon the Secretary Hilda Solis’ regulatory strategy of plan, prevent, protect; and solidifies the Agency’s commitment to strengthening the worker’s voice in the workplace. OSHA’s proposed regulatory initiative, the
Injury and Illness Prevention Program proposal, will help employers to set up a process to “find and fix” workplace hazards. This approach has been embraced by thousands of employers across the country, and is very similar to standards currently in place in California and several other states.
- Dr. David Michaels, Assistant Secretary of Labor for OSHA on January 5th, 2012
Recent Online Regulatory Chat with OSHA
Productivity and worker safety are not competing priorities. OSHA is developing regulatory solutions that create safer jobs and support business growth. Last year, OSHA added an Injury and Illness Prevention Program standard to the regulatory agenda. This proposed rule will require employers to develop a program that will help them address their health and safety hazards in a systematic proactive way. To gather information for this rule, OSHA has reached out to the business community, worker representatives and State Plan OSHA’s that have similar requirements. OSHA will base its proposal on the real world experience of employers and the substantial evidence on reductions in injuries and illnesses from employers who have implemented similar programs.
Jordan Barab, Deputy Assistant Secretary of
Labor for OSHA
Source: http://www.dol.gov/regulations/chat-osha-201012.htm
2012 DOL BudgetQ&A Session with Secretary Solis
1:36 Comment From Stephen Lee: The President's budget request calls for a 37 percent increase in funding for OSHA's standards group. Can you specify what OSHA will do with the extra $7 million?
1:36 David Michaels, OSHA: The request for OSHA includes increases of $6.4 million to improve regulatory standards that protect workers; including combustible dust, infectious disease, walking and working surfaces, hazard communication and silica. Included in the request is $2.4 million in the safety and health standards budget activity to continue to develop the Injury and Illness Prevention Program rule.
Source: http://www.dol.gov/budget/chat-budget-20110214-static.htm
2012 DOL BudgetQ&A Session with Secretary Solis
1:48 David Michaels, OSHA: Since the majority of companies, especially small businesses, do not currently have programs, OSHA will use some of this proposed funding to conduct extensive site surveys and economic and feasibility analyses to ensure that a rule is developed that employers of all sizes can easily comply with. In addition, we plan to begin to develop compliance assistance materials to help small and large employers develop prevention programs.
Source: http://www.dol.gov/budget/chat-budget-20110214-static.htm
1:50 David Michaels, OSHA: The free, on-site consultation program is OSHA’s most important small business program. OSHA is requesting an increase of $1 million to provide a necessary inflationary adjustment for the program and an additional 500 visits will be conducted.
1:51 Comment From Mike: Can we expect DOL to hire additional OSHA compliance officers (inspectors) under this budget?
1:51 David Michaels, OSHA: The FY2012 budget request includes funding for an additional 25 compliance officers.
2012 DOL BudgetQ&A Session with Secretary Solis
2012 DOL BudgetQ&A Session with Secretary Solis
1:59 David Michaels, OSHA: Our number one regulatory priority remains injury and illness prevention programs.
2:20 David Michaels, OSHA: In FY2012, OSHA will provide an increase of $1.5 million to provide a necessary inflationary adjustment for state programs to help cover, among other costs for increasingly budget-strapped states, State Plan staff annual pay raises. After conducting a review of all state plans last year, OSHA is in the process of increasing oversight over state plan operations to ensure that they are at least as effective as the Federal program.
Summary
• Creation of a federal IIPP regulation within 29 CFR 1910 is likely.
• Regulation will likely include:• Minimum employee threshold• Management Commitment• Joint Labor-Management Requirement• Find & Fix approach to hazards• Written Program
• Jim Thornton of Northrup-Grumman Summary• Dealerships and groups with the EHS Pro
product are ahead of the game.
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