By: Anthony Analetto
Originally Published in AutoLaundry Magazine
Last month I talked about avoiding physical accidents at your wash. This month, I’m going to step up to the pulpit and preach about material and equipment handling procedures. Most operators I know fall into one of three categories. The smallest group implements clear procedures and documentation for every person on their site. Then you have the largest group, those that are forever planning to create the procedures, training, and documentation, though few seem to get it done. The third group consists of operators who develop excellent programs for their staff but seem to feel that they and their trusted managers are exempt from such time consuming inconveniences. Sadly, I have the destroyed eyeglasses, clothing, and numerous stories of nearly tragic accidents that force me to admit being a member of that third group for most of my career. The fact is that most of us have an opportunity to improve upon our commitment to safety for our staff, customers, the environment, and ourselves. With that said, let’s move on to the basics of developing a risk prevention and counter measure plan.
Material Safety Data Sheets (MSDS)
Even with the best of intentions, mistakes happen. In a world where it’s possible for a doctor to accidentally leave a watch inside a patient – it’s hard to argue against the possibility that a detailer can leave a bottle of some cleaner, with a sweet fruity scent, in the back seat of a car within reach of a child. This scenario is only one of a thousand possibilities that demand instant knowledge of the danger, handling, and treatment for every chemical at a car wash. Quickly knowing what to do in an emergency is the purpose of Material Safety Data Sheets (MSDS). Whether it’s your customer, your son, daughter, or customer who walks by a hose that bursts, you can’t afford to ask the question – what should we do – without knowing where to find an answer in a matter of seconds.
It all starts with having the MSDS for every chemical on your property. According to federal law, manufacturers and importers of chemical products must produce an MSDS for each hazardous chemical they produce or import. This law also requires U.S. employers to have a MSDS in the workplace for each chemical that they use. An MSDS explains the hazards associated with the product, as well as what precautions to take to avoid those hazards. It also includes first aid and emergency contact information in the event of an accident.
Getting the MSDS for each chemical and putting it in a binder isn’t enough. Each employee must know what it is, where to find it, and how to read it. MSDS training should be part of your new hire procedure as well as an ongoing program to reinforce its importance. If you don’t already have an MSDS center hanging on your wall, turn to page 2748 in the new Grainger catalog, number 397. There you will find wall mounted kits, training booklets, and everything else you will need to comply with OSHA requirements.
Don’t overlook secondary containers. Having perfect MSDS documentation at your site would be useless for the parent of the child in the back seat of the car I mentioned above. What could they tell paramedics or a doctor if the bottle had no label? Often, chemical suppliers can provide you with labels to apply on secondary containers that include all emergency information. Some actually sell pre-labeled bottles for supplies commonly transferred. However you go about doing it, don’t take the risk of not maintaining strict labeling procedures for all secondary containers.
Personal Protection Equipment (PPE)
It’s not only common sense to use proper PPE, OSHA standards require that all “affected” employees and contractors utilize proper PPE. What specific devices you need varies depending on the chemicals and services offered. The first step is always to do an assessment of the entire workplace. There is a lot of literature available to assist you in performing your workplace assessment, but a good place to start is at www.osha.gov. The workplace assessment should be updated annually. This complete walk through of your operation will identify every occurrence where an employee can come in contact with a hazardous condition. Things that you should look for are low clearances, location of flammable substances, hazardous chemicals, excessive noise, and moving machinery. Once each hazard is identified, you must document it along with a specific PPE that must be used to eliminate the hazard. The most common PPEs found at a car wash include eye goggles, drum dollys, back braces, face shields, nitrile gloves, ear plugs, rubber soled shoes, warning signs, burn sleeves, barrier cream, and aprons. It is critical to be very specific in your documentation. Never indicate something generic such as facial protection, be very specific with the actual PPE that must be used.
Documenting all hazards is relatively easy. Providing an effective PPE for each situation is usually affordable. The real battle is making sure PPE is properly used and maintained. Often it will require extensive training and retraining. You will need to hold safety meetings. Posters, handouts, and signage should be incorporated to constantly remind all affected employees of company procedures. Implementing an effective program involves more effort than bolting a first aid kit to the wall, but is vital to providing a safe environment for your employees to work in.
Emergency Response Plan
OSHA guidelines also direct employers to implement an emergency action plan. The importance of doing this cannot be over emphasized. Benefits include reduced workman’s comp rates, improved employee moral, and decreased employee down time from injury. Creating your plan will take some time and consideration. It will include emergency contact lists and procedures, as well as plans for evacuation, fire prevention, readiness and focus, hazardous material release response, medical emergency, and overall site organization. Each car wash represents different considerations, but an excellent place to get started is with the free resources found on the OSHA website.
Lock Out / Tag Out
If you don’t already have a lock out / tag out kit at your wash, buy one, it will be the best hundred dollars you can spend. If you’re not sure what one looks like, I’ll again use Grainger as a non-industry specific supplier. Turn to page 2720 in their new catalog, number 397. You will find numerous options and most kits include a training guide. Select a kit with the proper quantity and type of locks and tags for the equipment at your wash. In addition to all wash components, you will also want to make sure you have supplies for air compressors, conveyors, pumps, air lines, and hydraulic lines. Make sure you communicate a policy for immediate replacement of any item in the kit that becomes unusable.
Basically lock out / tag out dictates that any person servicing machinery or equipment must physically disable the item before working on it. Whenever possible a lock must be used to keep the item from being re energized. If it is not possible to lock out an item, then it must be tagged out. Only the person who has locked or tagged out the item is permitted to re energize it, unless that person has left the property and passed authority to another according to the plan you have put in place. Under no circumstance can an item ever be re energized before the lock out / tag out is removed.
The concept is simple, and the required supplies affordable. Like PPE, the difficulty lies in ensuring that procedures are adhered to always, without exception. It demands a formal, well documented training policy. Affected employees must understand both the use of locks and tags, and the need to use them no matter how quick they think the service will be. Training is not a one shot deal. At minimum all affected employees should be re-trained on an annual basis. In addition, training must be administered whenever an employee is reclassified or placed into a position requiring the use of electrically energized machinery or equipment.
Summary
An ounce of prevention saves a pound of pain. It’s a lot of work to write manuals, create forms, and deliver training programs. Don’t lose site of the fact that the rewards for implementing a thorough risk prevention and counter measure plan go beyond reducing financial liabilities to your business. It’s the right thing to do for your customers, employees, the environment, and you. I hope everyone joins me this year in not only requiring our staff to follow procedures, but to take the few extra seconds ourselves to put on gloves, aprons, and face shields, even when no one is looking. I’m sure I’m not the only one who has probably pushed luck farther than it should be and decided that a few extra seconds has got to be less painful than an injury.
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