right-to-know laws at your dealership
DESCRIPTION
Right-to-Know Laws at Your DealershipTRANSCRIPT
Right-to-Know Laws at Your
Dealership
Nick Bujeaud
District Manager
Past, Present, and Future
Today’s Agenda
• Where did these laws come from and why it’s
important to comply
• What you need to have in place at your dealership
• Globally Harmonized System (GHS)
• Nick’s “Do it Now” Top 5
Why is Right-to-Know Important?
• Employee safety and morale
• Community responsibility
• Cost savings
• Litigation
• Compliance
The History: Workplace Right-to-Know:
OSHA’s Hazard Communication Standard
• 1970 – OSHA established
to standardize safety for
US workers
• 1983 – OSHA’s Hazard
Communication Standard
to protect employees
potentially exposed to
hazardous chemicals
29 CFR 1910.1200
HazComm Needs: Written Program
• List of hazardous
chemicals
• Hazards of non-routine
tasks
• Multi-employer workplace
• Labels and other forms of
warning
• Safety data sheets
• Employee information
and training
HazComm Needs: Chemical Inventory
Chemical Name Location Part Number
Brake Kleen Parts and Service BG-310
Automatic Transmission Fluid Oil Storage Room, Service ATF-111
5W30 Motor Oil Oil Storage Room, Service MOP12345
Windshield Washer Fluid Parts and Service 43-899
Wire Wheel Acid Cleaner Recon Department FT-16
Carburetor Cleaner Parts and Service CARB6789
Upholstery Cleaner Recon Department 161718
Parts Cleaning Solvent Service SK-10
HazComm Needs: MSDS
HazComm Needs: Container Labeling
HazComm Needs: Employee Training
• Facility operations where
chemicals are present
• Location of written program
and MSDS
• Methods used to detect
presence or release
• Physical health hazards
• Measures employees can
take to protect themselves
• Details of the written program
WHEN REQUIRED?
• At time of initial assignment
• When new chemical hazard is introduced
The History: Community Right-to-Know
• Dec. 2, 1984 – The
Bhopal Disaster at Union
Carbide India Limited
• 1985 – CA Democrat
Henry Waxman called for
the U.S. Inquiry into the
Bhopal Disaster
• 1986 – U.S. Congress
passed the Emergency
Planning and Community
Right-to-Know Act
Estimates of up to 16,000 deaths and 550,000 injuries and gas related deaths as a result of releasing 40 tons of Methyl Isocyanate (MIC) into the air
EPCRA Reporting Requirements (Sections 311-312)
• Increase community awareness and facilitate emergency planning
• For anyone required by HazComm standard to prepare a MSDS
Thresholds:
• 10,000 pounds for hazardous chemicals
• Threshold planning quantity of extremely hazardous substances
Report to:
SERC, LEPC, and local fire department
NOTE:
Local municipalities reserve the right to make these reporting requirements more stringent
EPCRA Reporting Requirements (Sections 311-312)
CONVERSIONS
Motor Oil 10,000 lbs. 1,388 gallons
Gasoline 10,000 lbs. 1,587 gallons
Antifreeze 10,000 lbs. 1,075 gallons
• United Nations
• Provide consistency of
chemical safety
document
• More efficient access
• Easier to understand
• U.S. – HazComm
2012, “Right-to-
Understand”
The Future: Globally Harmonized System (GHS)
December 2013:
• Training to include new 16 part “Safety Data
Sheets” and labeling requirements
• Written hazard communication program update
The Future: Globally Harmonized System (GHS)
June 2015:
• All safety data
sheets must be in
the uniform 16
section format
The Future: Globally Harmonized System (GHS)
December
2016:
The Future: Globally Harmonized System (GHS)
Nick’s Do it Now Top 5!
1. Chemical inventory and inventory your chemicals
(slides 6 and 12)
2. Create a written hazard communication plan (slide 5)
3. Walk your facility. Are all containers clearly
labeled?
4. Multi-employer workplace: have a conversation
about right-to-know with contractors
5. New hire safety training program (slide 9)
Thanks for your attention today!
