Right-to-Know Laws at Your Dealership

Right-to-Know Laws at Your Dealership

Nick Bujeaud

District Manager

Past, Present, and Future

Moderator

Becky RossMarketing Manager

(303) 228-8753

bross@kpaonline.com

PRESENTED BY

Nick Bujeaud

District Manager

(303) 228-8750 x4005

nbujeaud@kpaonline.com

If you have questions during the presentation, please submit them using the “Questions” feature

QUESTIONSQuestions

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!

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Contact Information

23– KPA CONFIDENTIAL –

The recorded webinar and presentation slides will be emailed to you today including your local representative’s contact information.

www.kpaonline.com

bross@kpaonline.com

866-356-1735