connecticut special: what will they fine me for?
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Connecticut Special: What Will they Fine me for?TRANSCRIPT
CONNECTICUT SPECIAL: WHAT WILL THEY FINE ME FOR?
www.kpaonline.com
(866) 356-1735
Questions
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CONNECTICUT SPECIAL: WHAT WILL THEY FINE ME FOR?
www.kpaonline.com
(866) 356-1735
KPA – Company Profile
Nationwide compliance auto industry expert on Safety, Environmental, HR, and Internet Marketing
Colorado Headquarters
27 Years Experience
5200 + Clients– Dealerships, Service,
Repair, Collision Centers
20 Offices Serving 46 States
Compliance products and services– OSHA– DOT– EPA– Workers’ Comp– Background checking– Onboarding– Harassment – Red Flags– Onsite inspections– Online and onsite training
and tracking– And many more…
In the press: “Red Tape Rising”
• Jan 22nd 2011 Article from The Economist – “Red Tape Rising”
• 167% Increase in Workplace Safety Violations
• Millions dumped into OSHA/EPA – “Foot Soldiers”
In the press: “OSHA is on the Prowl”
• Auditors “out and about” looking for violators
• Fines can range from 20K-90K
• 3 Calls: Good, Bad, and Ugly
• This is a cost “NOT covered by insurance”
• Is safety the real goal???
Real Word Examples
Proactive, yet still reactive – New Whistle Blower initiative – August 1st, 2011
Repeat Offender Classification (Groups Beware!) – examples of non fines at one location turning into 4x’s the fine at others – Sears / 53K NCD in March
*2004-2008 – 75 Inspections in the Northeast
*2009 – March, 2013 – 283 Inspections in the Northeast
GENERAL DUTY CLAUSE
Federal OSHA 5(a)1
What’s New in 2013?
- GHS – Globally Harmonized System (MSDS)
- Hospitals showing up as “first reporter”
- Increase in “Repeat Offender” designation…groups beware
- Significantly increased initial fines
HAZARD COMMUNICATION
Written Program
Chemical Inventory
MSDS (GHS by Dec 1st, 2013)
Container Labeling
Employee Training
EMERGENCY RESPONSE
Fire and Explosion
Facility Evacuation
Spill Response
Chemical Overexposure
Natural Disasters
EXAMPLE EMERGENCY EVACUATION MAP
PERSONAL PROTECTIVE EQUIPMENT
• Hazard Assessment• Employee Training
RESPIRATORY PROTECTION
Written Program
Medical Evaluations
Fit Testing
Training
High Liability
STORAGE TANK MANAGEMENT
Compliance Review• Underground Storage Tanks (USTs)• Aboveground Storage Tanks (ASTs)• SPCC Compliance
18
Permitting / Registration• Tier II Reporting - State• City Reporting• County Reporting
NEW SPCC REGULATIONS
Allows self certification using a template
Less than 10,000 gallons storage
No oil discharges over 1,000 gallons
No containers greater than 5,000 gallon storage
DEADLINE FOR COMPLIANCE WAS:
Nov 10th, 2011
DOT, FAA, TSA oh my!
Regulatory Procedures
1. Go to Airports
2. Pull HazMat Shipping Papers
3. Visit facility and audit signer of air bill
4. Call 24 hour emergency # while on site
5. Audit facility programs and procedures
Inspectors have a weekly quota for audits
Connecticut Specific Regulations
Quarterly Safety Committee Meetings:- CT dealers are required to conduct Quarterly Safety
Committee Meetings- Dealers are being audited
Repeat Offenders Violations
- This is a federal standard, however, the CT DOL is perhaps the most stringent in enforcing this across the Northeast (40K tack on to fine in April – ‘13)
TRUE COST OF AN ACCIDENT
Hidden Costs
• Damaged to lot, autos or equipment
• Unhappy customers• Clean-up time• Schedule delays• Training new
employees• Overhead costs• Damage to
reputation in community
• Lost time by other employees
Direct Costs• Insurance
costs
• Claim costs
• Lost time
• Medical bills
• Legal fees
SAFETY PAYS
Sales required to Pay for an Accident…
Accident Cost
Dealership Profit Margin
1% 2% 3% 4% 5%
$1,000 $100,000 $50,000 $33,333 $25,000 $20,000
$5,000 $500,000 $250,000 $166,667 $125,000 $100,000
$10,000 $1,000,000 $500,000 $333,333 $250,000 $200,000
$25,000 $2,500,000 $1,250,000 $833,333 $625,000 $500,000
$100,000 $10,000,000 $5,000,000 $3,333,333 $2,500,000 $2,000,000
HOW WILL YOU FARE?
Required Documentation:• Haz Comm (training)• Emergency Resp – (training)• PPE (training)• RPP (for paint work) / (training)
Physical Shop Compliance:• Stored Properly/Labeled Properly• Safety Hazards• Lifts Inspected• Monthly self inspections conducted?
FACILITY COMPLIANCE & SAFETY EVALUATION
Evaluation By KPA• Written Programs
• Training Records
• Compliance Issues
• Shop Issues
Webinar or Onsite
Formal Report• Summarizing Areas of Opportunity
KPA’S COMPLIANCE SYSTEMS
Contact Us
Rob Stansbury
484-326-9765 cell
Brian L. Torrez
303-228-2387 office
.