By Janet L. Keyes, MS, CIH and Carol A. Keyes, CSP

October is Fire Safety Month. Why dedicate a whole month to fire safety? Because fires kill and fires cost. NFPA reported that fire departments responded to a fire somewhere in the US every 23 seconds in 2023. The Insurance Information Institute estimated property damage from non-residential fires to be over $3 billion. Over 3500 people lost their lives, over 13,000 were injured in fires that year. Structures (homes, businesses) accounted for more than a third of the fires. Vehicles accounted for 15%. And structural and vehicle fires were responsible for 89% of the deaths and 85% of the injuries.

Are you at risk? And if you are, are there ways you can lower your risk?

Do a risk assessment first. What could cause a fire in your shop? Fires need heat, oxygen, and fuel (and the chemical reaction to initiate the fire). You have those in your shop. Oxygen is in the air we breathe. Have an oxyacetylene torch? Then you have cylinders of nearly pure oxygen in your shop.

The fuel for a fire could be anything that burns, from the carpet in a car to a rag used to wipe up oil. But you have some products that burn a lot easier than rags. Gasoline, brake cleaner, and paint solvents ignite easily. Aerosol cans usually are kept under pressure with a mixture of propane and isobutane, gases as flammable as natural gas. Partswasher fluid can burn. Oil takes a lot more heat to ignite than thinner or gasoline, but it is certainly combustible.

Heat could be flame or a spark. Ask anyone who uses an oxyacetylene torch or welds if they’ve ever started a fire. We guarantee at least one employee will admit to having done so. Space heaters are known fire starters. “Electrical malfunctions” were responsible for 6% of Minnesota fires in 2023, according to the Minnesota Fire Marshal’s office. Is your wiring in good shape? Do people use electricity correctly?

Now that you’ve identified what could cause a fire, how can you control those? These are some of the critical steps:

• Check equipment before using to make sure it is in good condition. Repair or replace damaged cords. Don’t overload outlets or extension cords.
• Flammable liquids such as gasoline, lacquer thinner, and even windshield washer fluid can generate a static charge when they are poured. To dissipate the static, use metal containers and bond and ground them. Connect the metal container to a building ground, then make sure that the receiving container is physically connected (preferably by a wire) to the original container.
• Watch out for welding and torch use. Remember sparks can travel far. If you cannot remove flammable or combustible material from the area, cover them with fire resistant welding blankets. Never weld or cut near a paint booth or prep station.
• Limit the amount of flammable materials sprayed outside of approved paint booths. One can of brake cleaner or an ounce or two of primer isn’t a huge hazard. Consistently spraying those in areas not designed for spraying flammable materials puts you at risk of fire.

We would bet you have some emergency preparations in place, even if you haven’t done anything to prepare for a fire. So you’re not completely unprepared.  You can thank the thousands of people who died in fires in years past for those preparations. Their deaths led to fire code, OSHA, and building code requirements to make your shop safer.

You probably have exit signs to guide people towards a safe place outside. You are likely to have fire extinguishers to stop the very small fire before it grows. You might have a fire sprinkler system, which will keep a fire in check if it does begin to spread. Your paint booth is probably designed to be explosion-proof, so no spark from an exhaust could ignite the flammable vapors. You probably purchased some sorbent such as floor dry, to clean up small spills.  Those are a good start, as long as you maintain them.

Train your employees to prevent fires. But prepare them so they know what to do in case of fire. Do they know how to use fire extinguishers? Hands-on training, using a burn pan, is the best way to learn, as that gives people the feel for how extinguishers work. Check with your local fire department, as they may offer that training. Employees who learn how to use an extinguisher and have the opportunity to practice are more likely to know how to react when there is a fire, whether at work or at home. Make sure they also know when not to use an extinguisher. You don’t want them injured trying to fight a fire that has started to spread.

How would your shop warn everyone if they need to get out because of a fire? If your shop is small, yelling might be the easiest way. Don’t forget to alert office staff, too. If you have an intercom system, does everyone know how to use it? If your shop is connected to other businesses, decide how you will notify them. And assign someone to guide any customers who are in your building.

Have you thought about where employees should go if they need to flee because of a fire? You need to account for everyone, so you don’t want them running home. Don’t risk a firefighter’s life to hunt for someone comfortably lounging at home.  Pick a meeting spot, near the building but away from the route that fire trucks will take.  Post it and tell employees about it, so they remember to go there.

Have you ever done a fire drill? That’s a good way to be prepared – and to find the holes in your preparation. They don’t take very long – it should take only a few minutes to get everyone out and accounted for. When people have to physically carry out an action, such as evacuating, they’re more likely to remember how to do that when the disaster strikes.

Invite your fire department in for a visit. That gives them the opportunity to get to know your facility. And they may see hazards you missed.

This article originally appeared in AASP-MN News (October 2025).  It is intended to provide general information (no advice) about current safety topics.  If you have questions about emergency and disaster planning, handling workplace injuries, workplace safety rules, or other safety issues, contact CHESS at 651-481-9787 or carkey@chess-safety.com. 

by Janet L. Keyes

 Some people read the Sunday Times. Some read blogs. I read OSHA serious accident reports. They’re useful – but scary – guides to what can go wrong.

OSHA requires prompt reporting of any injuries that caused amputation of any body part, loss of an eye, or overnight hospitalization. Those reports might trigger an inspection; at the least, they’re likely to trigger an inquiry from OSHA to find out what happened. And the reports get added to OSHA’s database (if you want to look them up, go to www.osha.gov/severe-injury-reports).

What did I find when I looked for the serious injuries reported for body and mechanical shops? The most common serious injuries for both types of shops were fractures, followed by amputations.  Vehicles accounted for the most mechanical shop injuries, followed by tires and floors. For body shops, it was the floor (slips and falls), followed by vehicle and mobile equipment parts, metal chips, jacks, and fuel. But that’s all abstract. What were some of the more notable incidents?

Belts and tires – especially tires – seem to cause a lot of finger amputations. An employee mounting a tire caught a finger between the rim and caliper. One person’s thumb was caught in the tire machine as it lowered to break the bead from the rim. Another lost a fingertip when he tried to determine if the tire was coming off the rim while it was spinning. A mechanic was hunting down a wheel bearing noise by spinning the tire and listening with a stethoscope. As he did so, his right hand slipped into the rim, catching his fingertip. The lesson: getting fingers between tires and rim is a good way to lose a fingertip.

Getting fingers around moving belts will do that, too. An Illinois technician lost three fingers when his hand was on the motor belt as a coworker started the vehicle. Another had cuts and bruises, bad enough to require hospitalization and surgery, when his hand was caught in the moving serpentine belt for a car’s air conditioning unit. Belts on machines are usually diligently guarded, with the machine turned off and locked out if the guard has to be removed. That may not always be feasible during car repair. But mechanics need to remember that those moving belts can remove fingers.

We harp on the need to wear safety glasses in nearly every walkthrough we do. There’s a reason for that. When an employee removed a panel from a vehicle using a clip removal tool, the tool bounced off the vehicle door and punctured the employee’s eye. An employee pulled a metal object out of a tire; it flew out and struck him in the eye. He was hospitalized because of that. Another employee used a box cutter to remove some plastic wrap. The blade snapped, flying into his eye and cutting it.

I don’t consider box cutters to be all that dangerous. But this injury was severe enough to require reporting to OSHA.

Anyone who attends the training I do has heard me holler, repeatedly, about labeling containers and about not using food containers for chemicals. This case illustrates why: An employee used Gatorade bottles to store floor cleaning products. The employee mistakenly drank the floor cleaner, became very ill, and was hospitalized. I can hear you saying, “I would never be that stupid.” But we see food containers reused for chemicals much too often. And we’ve heard from people who have made that type of mistake. Usually, it’s been taking a swig of paint thinner. That’s not good for you, but it isn’t likely to cause the type of chemical burns floor cleaners can cause. The take-home rules: never ever use food containers for anything you won’t drink. And always label containers.

Another take-home rule: do not siphon by mouth. An employee was doing that to remove water from a tank. He ingested chemicals in the siphon hose, making him sick enough to require hospitalization.

Air blow guns should never be pointed at anyone, including yourself. Why? A Caliber Collision employee found out the hard way. When he used compressed air to blow off a car, he blew the air across his hand, causing an embolism. I knew that was theoretically possible, but had never before seen a documented case of it.

Air is one thing that can be injected under the skin. Grease is another. An employee was using a pressurized pneumatic grease gun when a leak in the line injected the grease into his middle finger. Injection injuries like that don’t seem like much at first. But if all of that foreign material isn’t removed, the body tissues will die. The recommended treatment: extensive surgery.

Both body and mechanical shops work a lot with flammable liquids – gasoline, thinner, brake cleaner. Because we use those so much, we often forget about the fire danger. An employee installing a fuel pump on a car was sprayed with fuel as he tried to bleed the air out of the fuel lines. As he jumped to get away from the spraying fuel, the wrench he was using touched the positive terminal on the battery and sparked. That ignited the fuel, burning the mechanic’s hand. In a different shop, an employee used thinner to clean car parts, getting the solvent on his gloves. He went outside for a smoke. As he lit up, the thinner on his gloves ignited.

The body shop employee’s burns were completely preventable. Use less flammable solvents for cleaning – they may not evaporate as quickly, but they’re a lot safer. Don’t wear gloves that can absorb cleaning solvents. And don’t smoke. The fuel pump incident may have been harder to prevent. Maybe the technician just needed to be more careful around gasoline, which is much more flammable than thinner.

The full list of serious incidents is over 250 entries long (and doesn’t include states like Minnesota, that have their own OSHA programs). I’ll leave you with one more category: injuries caused by moving cars. An employee drove a pickup onto an alignment rack, got out and started to set wheel chocks when the truck began rolling backwards. When he tried to jump into the truck to stop it, he fell. The truck ran over him, fracturing both legs. Another mechanic was repairing brakes underneath a vehicle when it moved, rolling over his right side. The result: a fractured femur and ankle and a dislocated hip. And in a case that sounded too familiar, because we nearly had it happen at one of our shops: an employee was guiding a co-worker as he drove a car onto a four post lift. The co-worker accidentally hit the gas pedal instead of the brake. The car jumped forward, pinning the employee against a tool box. The employee suffered a spinal fracture, cracked ribs, a lacerated spleen and a hematoma.

When that type of incident happened at our shop, the shop instituted some basic precautions. Don’t stand directly between the vehicle and a fixed object; stand to the side. Make sure technicians know how to operate the vehicle. This car had a manual transmission, which the technician had never driven.

We learn from things that went wrong. It’s much less painful to learn from others’ mistakes. What have you learned from these? Can you share that knowledge with your employees? Are there changes you can make in your shop, to protect employees from serious harm?

This article originally appeared in AASP-MN News (September 2025).  It is intended to provide general information (no advice) about current safety topics.  To discuss your specific concerns and how CHESS may help, please contact CHESS at 651-481-9787 or chess@chess-safety.com.

By Janet L. Keyes, CIH

If you walk through your shop, how many times do you need to step over a hose, a cord, a car part? How often do you need to step around a hole? Walk carefully because of an oil spill or water?

If you navigate those successfully, you probably don’t think much about the hazards. But slips, trips, and falls account for quite a few workplace strain/sprain injuries, some broken bones, lots of bruises – and even fatalities. And they can often be prevented by taking relatively simple measures.

What’s the difference between a slip, a trip, and a fall? A slip is a loss of balance caused by too little friction between your feet and the surface you walk on. It’s friction that keeps your feet from sliding around. Put on a pair of ice skates and glide on the ice – it’s the low coefficient of friction that lets you smoothly cross the ice. Switch to broomball shoes with a thick and knobby rubber layer on the bottom, and you’ll stick to the ice instead. Those have a high coefficient of friction.

You trip when your foot hits an object while momentum is carrying your body forward, causing a loss of balance. The object could be uneven pavement, a hole, a hose left across the floor, a change in the floor level.

When we think of falls, we usually think of falling off of something, such as a roof or a ladder. But falls can occur on the same level. Any time you move too far off of your center of gravity, you’ll fall. If you stick your arms out to break your fall, you might well break your arms. Land on your head on a concrete floor, and you could have a permanent brain injury.

How do you prevent these accidents?

Keep your workplace cleaned up. This can be a challenge, given the abundance of air hoses, extension cords, and car parts in every shop. But we’ve been in shops that are rigorous about putting stuff away – and that means people work more efficiently. They don’t have to step over things. They don’t have to hunt for the extension cord or the tool buried under a bumper. And they’re less likely to trip and fall.

Some workers seem born to be messy. But they can learn. Give them designated spots for common items. Remind them to straighten up. It might take daily reminders for weeks, as bad habits seem much easier to learn than good ones. If you persist, you may find their productivity increases as they get used to being neat.

Install overhead cord reels. Put in more outlets, to minimize extension cord use. Encourage the use of battery-powered tools to eliminate many of those cords and hoses.

Eliminate slippery surfaces whenever you can. That means clearing ice and snow in your parking lot. It also means cleaning up oil or other spills right away. Better yet, prevent the spills. Should you put drip pans underneath chemical dispensers? Do leaky valves need repair? Do you need bigger funnels?

It isn’t just liquids that can make floors slippery. Powders such as those from sanding can be even greater slip hazards than liquids. Investing in a vacuum system to control dust could make it much easier to keep your floors (and the rest of your shop) clean.

Check the condition of your floors. Do you have spalled concrete? Cracks in the floor? Broken floor grates? Drop-offs? OSHA considers any opening in a floor that’s at least 2” wide to be a tripping hazard.  Cover those, permanently if possible. The cost of keeping your floors in good condition will be quickly offset by the money you don’t need to spend because of an injury.

Look at how you’re maintaining your floors. Are they being cleaned correctly? Soapy residue could make your floors more slippery. Ineffective cleaners won’t remove oil spills. Infrequent cleaning can make it harder to clean effectively.

Does your floor have changes in levels, such as raised areas, perhaps where an addition was put on? Those can be tripping hazards. Ideally, smooth out the floor. If you can’t do that, make the change easy to see. Paint it or tape it with a bright contrasting color. Ensure the area has enough lighting to make it easy for people to see the change.

We’re sure you’re not keen on being shoe police. Take a look, though, at what footwear employees wear. That applies to technicians and office personnel. While sandals, high heels, or slippery soles might be perfectly okay for someone who sits at a desk all day, that footwear is not appropriate for anyone who walks into the shop areas, even if it is just to deliver a message. 

People are designed to be upright. When they suddenly and unexpectedly go down, the consequences can be severe. You can take steps to prevent slips, trips, and falls: tidy your shop; eliminate the tripping hazards; control slippery surfaces. It takes an ongoing effort, an effort that will pay off with reduced injuries and with more efficient workers.

This article originally appeared in AASP-MN News (July 2025).  It is intended to provide general information (no advice) about current safety topics.  To discuss your specific concerns and how CHESS may help, please contact CHESS at 651-481-9787 or chess@chess-safety.com.

By Janet Keyes, CIH

Who has heard of the dangers of electric vehicle fires? Yep – I see a lot of raised hands.

Who has thought about the dangers of gasoline vehicle fires?

Anyone ever have a car start on fire?

There’s an inherent fire danger with vehicles. Most have plastic containers full of gasoline, a liquid more flammable than paint thinner. The body might be steel, but the car has plenty of plastic. And while the plastic may not ignite easily, it certainly can burn. Many vehicles have aluminum or magnesium components. Aluminum and magnesium burn.

So why are we now so concerned about fires with electric vehicles? We’ve had years to figure out how to put out car fires. The standard fire extinguisher in your shop, an A/B/C or a B/C extinguisher, does an effective job with gasoline. Lithium-ion batteries, used for EVs, for many battery-powered tools, and for the cell phone in your pocket, are a new and different kind of fire hazard. And while they are usually less likely to ignite than the container of gasoline, they can be much harder to put out.

Lithium-ion batteries (Li-ion) have become widely used because they pack a lot of power in a small space. But some characteristics make them a special hazard in a fire.

Hybrid vehicles might have Li-ion batteries or nickel-metal hydride (NiMH) batteries. Because the latter aren’t nearly as powerful as Li-ion, they are no longer used in all-electric vehicles.

Batteries work by creating electrical current when ions move through an electrolyte, from an anode to a cathode. In a lead-acid battery, the electrolyte is a sulfuric acid/water solution. A NiMH battery uses an alkaline material such as potassium hydroxide for its electrolyte. Those won’t ignite.  In a lithium-ion battery, the electrolyte is a flammable solvent.

What’s required for a fire? Fuel, a source of electrons, heat, and a chemical reaction. The Li-ion battery supplies the fuel and the source of electrons. Heat could be from a spark, from overcharging, from a short circuit caused by damage, or from a fire external to the battery.

If one battery cell generates more heat than it can dissipate, it can cause adjacent cells to fail and overheat. The overheated cell can lead to the barrier separating the anode and cathode to melt or distort, causing an internal short circuit. The cathode begins breaking down, releasing more heat and oxygen. And then cell temperatures keep rising – and you have thermal runaway. Eventually, all of the cells in the battery can heat up and ignite.

Lithium-ion battery fires are difficult to detect, difficult to control, and difficult to extinguish. You can’t use fire suppressants to remove oxygen, because the runaway reaction is generating its own oxygen. Cooling with water or foam works if it can get to the fire. But in newer vehicles, the batteries are in waterproof and fire-resistant protective cases, so firefighters can’t get extinguishing agents on the fire itself. Often, allowing the fire to burn itself out is the best option. Fire departments may be able to cover the vehicle with a special fire blanket, to protect the surrounding area and to contain the toxic and flammable gases given off in the fire.. Until the battery is completely discharged or destroyed, there’s still a chance of cells reigniting.

If you have a damaged EV:

• Assume the high voltage battery is energized and could shock you
• Treat the vehicle as a fire hazard. Store it outside when you can, fifty feet away from any structure or other vehicle.
• If you see any sparks, flame, or smoke, if there’s any leaking fluid from the battery compartment, if it seems hot, or if you hear noises (gurgling, popping, bubbling, hissing) from the high voltage battery, call 911 right away.
  • If the vehicle’s on a lift, lower it before you evacuate. That makes it easier for the firefighters to deal with it.
• Don’t bother trying to use an extinguisher on a Li-ion car battery fire. You won’t succeed.

Keep in mind that Li-ion batteries in tools and phones can also undergo thermal runaway. The danger isn’t as great because of their small size. But make sure your technicians handle those with care. Don’t abuse or try to modify the batteries. Use only batteries and chargers okayed by the manufacturer. And if a battery is leaking, heating up, or making noise, get it outside, away from anything that can ignite. If one of these small batteries does ignite, call 911. If it’s safe for you to do so, you can try using an ABC or BC extinguisher on the small battery.

This article originally appeared in AASP-MN News (June 2025).  It is intended to provide general information (no advice) about current safety topics.  To discuss your specific concerns and how CHESS may help, please contact CHESS at 651-481-9787 or chess@chess-safety.com.

By Janet L. Keyes, CIH

Anyone have a grinder? A compressor? A shop press? Electrical panels? A mezzanine?

One thing all of those have in common: they require guarding. People stick fingers where they don’t belong – sometimes because they don’t see a hazard; sometimes without thinking. Parts break and fly out. Work creates flying chips and sparks. Wrapping employees in personal protective equipment won’t keep their hands out of a grinder. Telling people to “be more careful” won’t stop a bearing from flying out if it fractures when pressed. Guards aren’t substitutes for personal protective equipment or careful operations, but they provide safeguards.

The guards on your grinder protect the user from where the machine acts on the work piece: they are point of operation guards. The standard grinding wheel has three guards:

• A guard around the wheel itself. This needs to cover 75% of the wheel. It keeps the user from coming into contact with the rapidly turning abrasive surface. Of more importance, it will help contain any shrapnel if the wheel explodes. That can happen if the grinder operates at a higher speed than the wheel is rated for, if the wheel is mounted incorrectly, if it wears too unevenly, or if it was damaged before it was installed (for instance, from dropping it).
• The work rest. The work rest supports the workpiece so the user can maintain steady contact with the wheel. But it also reduces the risk of something such as a glove or a loose sleeve from being dragged into the wheel. It needs to be kept as close as possible to the wheel (no more than 1/8” away).
• The tongue guard, at the top of the wheel opening, and adjusted to be within ¼” of the wheel. The tongue guard can prevent pieces of a shattered wheel from flying out and striking the user. It also helps contain sparks. We often see these missing or incorrectly adjusted because many people don’t know their purpose.

Grinders and other equipment may also need guards over their on/off switches (“motor start buttons,” to quote OSHA regs), so they can’t start accidentally.  The grey grinder pictured here has that guard over its toggle switch.

Guards on hydraulic shop presses are also point of operation guards. When those presses exert tons of pressure, the piece being pressed can shatter explosively, sending fragments out with force.

The guards for these act as curtains or barriers to blunt the force. These presses usually don’t come with guards, in part because the manufacturers don’t know what you’re pressing.

Some companies use ballistic blankets as guards, wrapping the blanket around the piece. Others fabricate their own guards (if you do that, use something that won’t shatter, such as polycarbonate or expanded metal). And some companies will sell you guards for these. Expanded metal mesh curtains are a popular option.

Your compressors don’t have point of operation guards, but they do need guards over the power transmission apparatus. That’s OSHA’s way of saying that belts and pulleys need to be guarded. We rarely see problems with these unless the compressor is old. But we have seen severe injuries when the guards are removed before the belt comes to a complete stop.

These aren’t the only things that need to be guarded. All of your shop’s electrical wiring should be guarded, by wire insulation or by covers on electrical components. Fan blades must be guarded, either by covers with openings too small to fit a finger or by distance. That mezzanine mentioned in the opening paragraph? Guard that with railings: a top rail at about 42”, able to withstand 200 pounds of force against it; a midrail, and a nominal 4” high toeboard. The toeboard keeps someone from sliding through the opening and, more likely to happen, keeps anyone on the mezzanine from inadvertently kicking a tool off the edge (and onto a coworker below).

Keep guards in place. Adjust them correctly. Remove them only if the hazard is removed – the grinder unplugged, the compressor turned off and locked out so it can’t be restarted. If the guards are in the way, investigate – as they’re probably the wrong type of guard for the job.

This article originally appeared in AASP-MN News (January 2025).  It is intended to provide general information (no advice) about current safety topics.  To discuss your specific concerns and how CHESS may help, please contact CHESS at 651-481-9787 or chess@chess-safety.com.

By Janet L. Keyes, CIH

If you were asked how to control the hazards from using spray paint, what would you answer?

Often, the first answer given is “wear a respirator.” That’s a reasonable response, but it isn’t the best response. Why not? If you’re going to use a respirator effectively, it has to be the right one for the job. It has to fit you well. It needs to be maintained. It only protects the person wearing it, not the other people in the area. It doesn’t eliminate the fire hazard from the spray paint. It doesn’t protect your skin or, usually, your eyes.

You can add gloves to protect your hands and safety glasses to protect your eyes. But the gloves need to be effective against the chemical. A lot of gloves can’t hold up to the solvents in thinner; they’ll disintegrate. Gloves reduce dexterity. Safety glasses don’t seal, so chemicals can get past them. You could use chemical safety goggles, but those can be uncomfortable. And neither gloves nor goggles protect people near you.

We consider personal protective equipment such as respirators and gloves to be the last line of defense, not the first. In the safety and health field, we cite the hierarchy of controls:

• Can you eliminate the hazard? If not,
• Can you substitute something that’s less hazardous? If not,
• Can you use engineering controls? If not,
• Can you use administrative controls, changing work practices? If not, then
• Fall back on personal protective equipment.

Let’s look at two real-life examples:

A shop employee received a cut on his hand when he was emptying trash. He reached into a dumpster to push the trash down and a razor blade cut his hand badly enough to require stitches. How would you have prevented recurrences?

You could have the employee wear heavy or cut resistant gloves. That’s not a bad idea if anyone must reach into trash containers. But you’ll need to make sure anyone who might reach into the trash has those gloves available. We can think of several other options.

Use administrative controls: Instruct employees that razor blades cannot go into the trash. Along with that, provide convenient containers for the blades. We’ve seen sharps containers used for that purpose. If you do that, cover up or remove the biohazard warning on those. Better yet, just use empty paint cans with lids. Cut a slot in the lid and label the can “used blades.” Provide enough of those that no one has to search for one.

Consider engineering controls. Is there another tool such as a putty knife that would do the same job? One that wouldn’t be disposable? Or one with a retractable blade?

The other example: a shop applies undercoatings. The product they used contained acetone, hexane, and asphalt. Acetone and hexane catch fire very easily. Hexane has been shown to cause nerve damage. The work was usually done in a repair bay, with the vehicle on a lift. The product directions call for it to be sprayed on. When we looked at what controls were needed, we advised that it needed the same controls as required for painting vehicles:

• This was spray application of a very flammable liquid. So it needed to be done in a spray booth or a spray area, an area with explosion-proof wiring, adequate mechanical ventilation, and fire suppression.
• The person applying the undercoating probably would need to wear a respirator. But we would need to monitor the air during application to confirm that, and to determine how long a respirator would last. If a respirator is required, then the employee needs medical approval, annual training and annual fit testing. The respirator would need to be maintained correctly.
• Chemical resistant gloves would be needed. There are few gloves that hold up to acetone. Thin nitrile gloves, costing 30 cents a pair, won’t work. $35 a pair thick butyl gloves will.
• Any waste from this or from cleanup will be hazardous waste.

A quick Internet search showed at least one alternative product, a water-based undercoating. It isn’t flammable, so applying it in a repair bay is acceptable. We don’t think any respirator will be needed. We still recommend gloves, but the thirty cents a pair nitrile gloves will work. And use of this product won’t generate hazardous waste. Even if the water-based undercoating costs more to purchase, it will cost less to use.

In this case, we can use one of the best types of controls, substitution.

When you’re faced with trying to decide how to protect your workers or yourself, don’t immediately go for personal protective equipment. Instead, consider the hierarchy of controls. Can you eliminate the hazard? Substitute something less hazardous? Use engineering controls? Change work procedures? We don’t think you can eliminate PPE. But if we can reduce our reliance on things people have to wear, employees will be safer and your costs, often, will be less.

This article originally appeared in AASP-MN News (December 2024).  It is intended to provide general information (no advice) about current safety topics. To discuss your specific concerns and how CHESS may help, please contact CHESS at 651-481-9787 or chess@chess-safety.com.

By Janet L. Keyes, CIH and Carol Keyes, CSP

You meet with your staff. Maybe it’s daily, to discuss production schedules. Maybe it’s weekly, to check in and see how things are going. Maybe safety concerns are brought up – is that hoist not working right? Is that outlet dead? These are usually informal meetings, with no record of who attended and not much done to track what was discussed.

Those shop meetings are useful, but safety is likely taking a back seat. There’s a way to bring it forward – establish a safety committee.

Do you need to have a safety committee? Probably. If you have more than 25 employees, you do. If you’re required to have an AWAIR program (a basic safety program, outlining responsibilities), you do. Whether you need an AWAIR program is based on your industry’s injury rate. That list is updated every five years. And that list currently includes any automotive repair shops (mechanical, collision, glass replacement, oil change, car washes…).

So if you work on cars, regardless of how small you are, you need a safety committee. (An aside: if you have ten or fewer employees, OSHA’s not likely to do a planned safety inspection, the most common type. While a small shop must have a safety committee, it probably would not face an OSHA penalty for lack of a committee).

Who needs to be on the committee? It has to be at least half employees, and the employees should select who’s on the committee. If you have a union, the union chooses members.

What should a safety committee do?

Minnesota rules spell out some requirements. If you have a bad injury record, at least 1.4 times your industry average, the safety committee has to do a walkaround of your shop at least once each quarter, looking for any hazards. You need to keep a record of those hazards and what the committee recommended to correct the hazard. The committee needs to have a way to solicit safety suggestions and hazard reports. It is supposed to review any work-related injuries or illnesses and come up with recommendations to prevent recurrences. You need to keep a record of those recommendations for at least two years.

Just one more bureaucratic layer, right? Change your thinking – a safety committee doesn’t have to be too onerous, and it can make your shop safer. You’re allowed a lot of flexibility in how you structure and run the committee. Other than the quarterly meeting requirement for high-injury shops, the rules don’t say how often you need to meet. The rules don’t dictate how big the committee has to be or exactly what the committee has to do. The most important point: employees need to know they have an avenue to raise safety concerns.

If you have a shop with a dozen employees, how could you structure the safety committee? You might consider having a committee of the whole – have all employees be part of the committee.

Or encourage a few employees to volunteer to participate. While safety committee members are supposed to be chosen by their peers, our experience has been that people don’t tend to step forward without encouragement. By the way, you need to pay employees for their work on the safety committee.

At least once or (better yet) twice a year, gather everyone together. Make it clear the purpose is to discuss any safety concerns and the past year’s or past six months’ safety performance. What injuries occurred? Does anyone have ideas to prevent them? Were there any safety incidents – where equipment was damaged or where somebody said, “whew, that was a close one?”

You could make this part of your shop meeting, but make sure the safety part is documented.

You can meet more often than once or twice a year – you decide. For larger shops, meeting quarterly may make more sense. Bring in lunch for the committee members, as everyone participates better with food. 

Keep a record of who was there and what was discussed. It can be handwritten, but make sure it includes the date and any follow-up actions required. Post that record on the employee bulletin board.

Once a year, have your safety committee develop some goals – not “have no accidents” but things people can do, such as check the vehicle hoists, get all containers labeled, or ask your local fire department if they will train your employees on fire extinguisher use.

Enlist safety committee members to check the things that require routine inspections. Fire extinguishers need to be looked at each month, to make sure they are where they’re supposed to be and are still charged. Plumbed eyewashes need to be flushed each week so they don’t develop crud in the lines. Gravity fed eyewashes need to be checked to ensure the solution hasn’t expired or been used. Exit lights don’t do any good if the batteries are dead and they don’t light up. Assign the tasks of checking these to safety committee members.

We send our clients monthly building inspection forms. Develop your own. Then delegate completing it to safety committee members. Rotate the task, so different people start learning to look for safety hazards – and so it isn’t much of a burden for any one person.

When OSHA does an inspection, the inspector will ask if you have a safety committee. The inspector will also ask that question of employees. If the answer is no, you’ll not only be cited for lack of a committee, but you’ll pay more for any other violations found. OSHA discounts penalties based on company size, history, and good faith. If you don’t have a safety committee, you won’t get the full good faith discount. That could be the difference between getting a $250 citation and a $1000 citation. Not a huge amount itself, but these can add up.

Put together a safety committee. Meet routinely – every January, if you decide on once-a-year meetings. Take the opportunity to review last year’s safety performance – what injuries occurred? What accidents happened? Ask if there are any safety concerns. Document.

That’s not so difficult, now, is it?

This article originally appeared in AASP News (October 2024)  It is intended to provide general information (no advice) about current safety topics. To discuss your specific concerns and how CHESS may help, please contact CHESS at 651-481-9787 or chess@chess-safety.com.

Carol Keyes, CSP, CCM, CRC

Do you feel prepared if Minnesota OSHA shows up at your door? Does your staff know what to do? A word of advice: Hiding is not an option.

Minnesota OSHA has recently inspected several automotive repair and tire shops, either because of complaints or as part of programmed inspections. A typical inspection has resulted in about $1500 in penalties, but we know of one as high as $8000. And, if you fail to abate the citations and file your paperwork on time, that $8000 can easily balloon to over $40,000!

Here are some (relatively) easy pointers:

Be prepared before OSHA arrives.

• Keep records of all safety training. Know where your safety records are located.
• Make sure employees have – and use – the proper personal protective equipment. The primary items will be safety glasses, face shields (for transferring chemicals and grinding), and hearing protection.
• Have written safety programs and know where to find them. Do the same with preventive maintenance records (hoist inspections, eyewash maintenance…).
• Keep your OSHA 300 logs of injuries up to date.
• Keep records of safety committee meetings. Any opportunity you give employees to provide feedback on safety and that you document could be considered a safety committee meeting.
• Make sure your front office folks know what to do when OSHA shows up. And that they know to notify the shop owner or manager immediately.

When OSHA arrives:

• Ask for their business card and why they are at your shop (was it a complaint, or your site just came up for inspection).
• Offer them a cup of coffee. Ask what records they will want to see and start gathering those. If you have a break room or office where you can meet with them, set them up in there.
• Be polite. You can refuse to let them in, but they will just come back with a warrant. We don’t recommend that.
• The inspector will hold an opening conference to review the purpose of the visit.
• Provide the documents they request, if you have them. Most inspectors will also give you 24 hours to email the records to them.

The walk around

• Never allow the inspector to go into your shop unaccompanied. If you aren’t available, have a manager go with them. Make sure whoever goes along knows what to do.
• The inspector will walk through your shop. Go with that person. Take notes. Take pictures – anything the inspector photographs, you also need to photograph. You won’t be able to see the inspector’s records, so you want to make sure your records are thorough.
• If the inspector points out a concern, such as a damaged extension cord, fix it immediately if you can. Cut the cord and put it in the trash.
• The inspector will interview employees. That is a private conversation, so stand aside during this.

OSHA has had a lot of staff turnover, with experienced inspectors retiring. That means the inspector you get may have never been in your type of shop. You don’t have to volunteer information, but do explain your processes and operation.

After the inspection

• Don’t wait for the inspection report to start correcting issues that the inspector pointed out. If they mentioned the need for correct labeling on containers, get your containers labeled. If they said you need forklift training and evaluations, get that scheduled. Once the report arrives you may have very little time before the abatement date, the date by which violations must be corrected.
• Read the whole packet. It’s long, even if you get just one citation. Look for these parts:
  • Citation and Notification of Penalties. This spells out what problem was found, what standard was violated, how much you’ll be penalized, and the date by which you must correct the problem.
  • You need to pay this promptly, unless you are contesting the citations.
  • Mandatory Progress Report. You have to send this in. This tells OSHA that you are correcting the problems. It is mandatory.
  • Petition for Modification of Abatement Date: if you can’t get the fixes made by the abatement date, OSHA will issue an extension only if you request it. Use this form to request more time. Extensions are usually only for 30 days, but you can submit additional requests if needed, as long as you can show progress toward completing the abatement.
  • Notice of Contest: if you are going to contest the citation, the abatement date, or the penalties, you will need to complete this form and have it notarized.
  • Expedited Informal Settlement Agreement (EISA): if you only have one or two serious citations, MNOSHA may offer a discount if you do not contest the citations. It is almost always worth taking if offered.
• Pay attention to dates! You only have 20 calendar days from the date on the citation packet to contest.
• Pay attention to instructions! If you contest and forget to have the form notarized, OSHA will reject it. They are not at all forgiving on these procedures or deadlines.

Should you contest citations? Yes.

OSHA doesn’t get upset if you contest citations. You won’t end up on a hit list.

You can contest the citation, the amount, the abatement dates, the type of violation, or the entire citation. Even if you agree you were in violation, we always recommend contesting at least the amount. You can usually get at least a 30%, up to a max of 40%, reduction in penalties if you contest. But you still need to correct any hazards that were found.

If you are offered an Expedited Informal Settlement Agreement, it usually is worth accepting that and not contesting the citations (unless you think they were wrong).

Penalties

While OSHA penalties seem to be a mystery, they follow a very specific formula. The maximum penalty per violation (other than fatalities) is currently $15,625. The actual penalty is discounted from that based on probability (how many people are exposed to the hazard, how close and how often employees are exposed) and severity (how bad could an injury from that hazard be).

You can get up to 95% credit off the penalty: up to 30% for good faith (you have a safety program, you do annual training, you have safety committee minutes), 55% for size of company, and 10% for not having been cited for the same violation within the last three years.

The best prevention against OSHA violations is having a strong safety program. Don’t think you’re doing okay just because you’ve had few injuries. That might be due to luck. As any gambler will tell you, luck isn’t very reliable.

This article originally appeared in AASP News (September 2024)  It is intended to provide general information (no advice) about current safety topics. To discuss your specific concerns and how CHESS may help, please contact CHESS at 651-481-9787 or chess@chess-safety.com. 

By Janet L. Keyes, CIH

Which of these are in your shop: brake cleaner, gasoline, windshield washer fluid, motor oil, partswasher solvent?

Which of these can catch fire?

Which are classified as flammable liquids, with flash points under 200°F?

The answer to the first question: all, if you’re a mechanical shop. If you don’t do any mechanical work, you probably don’t have a partswasher or brake cleaner. But everyone has gasoline, washer fluid and motor oil.

The answer to the second: all of them can ignite. It takes the most energy to burn motor oil – that’s the least flammable of the bunch, followed by partswasher solvent.

The answer to the third: Most readers will readily answer brake cleaner and gasoline. The one that people often don’t guess is windshield washer fluid. But in northern climates like Minnesota, it contains enough methanol to make it very flammable.

We classify flammable liquids based on their flash point, the temperature at which they give off enough vapors to ignite. If you bring gasoline down to a temperature below -45°F (that’s 45 degrees below 0°F), it won’t ignite. (Maybe you’ve heard of someone plunging a lit match into gasoline, to show that it won’t burn. It doesn’t – because it’s the vapors that burn, not the liquid. You need the oxygen in the air, mixed with the vapors, for ignition to occur.) According to OSHA, if it has a flash point below 73°F, it’s a Category 1 or 2 flammable liquid. Below 140°F, it’s a category 3 flammable. The Fire Code classification is slightly different: if the flash point is below 73°F, it’s a hazard class I-A or I-B flammable liquid. If below 100°F, it’s I-C, and below 140°, hazard class II.

Gasoline and brake cleaner are OSHA hazard category 2 flammable liquids and Fire Code I-B. Partswasher has a flash point just above 140°F. Motor oil’s is usually over 400°F. Ready to use all season washer fluid: usually between 80°F and 110 °F. If it’s concentrated, meant to be diluted for use, the flash point will be 54°F, making it a hazard category 2 or I-B flammable liquid.

Why does the classification make a difference? The more flammable the liquid is, the more fire precautions you need to take.

You need to limit how much you have on hand. OSHA and the Fire Code limit you to 120 gallons of 1B or 1C flammables per fire control area – that’s an area separated by fire-rated construction from the rest of the building. If the area is sprinklered, the Minnesota Fire Code lets you double the amount. If you use flammable cabinets for storage, the Fire Code allows double the amount. Most collision repair shops have mixing rooms, designed as inside storage rooms for flammable liquids. If that room is sprinklered, with exhaust ventilation designed to capture vapors from a spill, a sill to contain any spill, and fire-rated construction, you can legally exceed those limits. But if you have multiple drums or totes of washer fluid and brake cleaner sitting out on your shop floor, you’re probably over the limit.

Use the right containers. The original manufacturers’ containers are supposed to meet certain specifications. Don’t transfer flammable liquids to your empty plastic jugs. Containers for gasoline need to be self-closing, have flame arrestors, and be vented – and you need to be able to ground or bond them.

Ground and bond your containers. When you pour a flammable liquid, the action of pouring creates static electricity. Combine static electricity with flammable vapors and you have the ingredients for a fire. Know the warnings about not filling gas cans in the back of your pickup truck? That’s prohibited because of static electricity. Whether you’re emptying a car’s gas tank prior to repairs or dispensing brake cleaner or thinner, you need to control that static.

Grounding is done by connecting a grounding wire to a building ground. That can be a grounding rod sunk into the ground, metal water pipes, or metal building components that are grounded. Bonding is connecting a metal wire between the original container and receiving container. Bonding equalizes the static charge between the two containers. Grounding gives the static charge somewhere safe to go.

Plastic containers cannot be grounded, but a dangerous static charge can still build up when you pour from or into them. Metal containers are a better choice.

A lot of suppliers provide washer fluid in plastic drums or totes (IBCs). That doesn’t release you from the need to bond and ground, but it does make doing so a lot harder. You can put the drum on a steel plate that’s grounded. For dispensing, you can use a stainless steel pump that extends to the bottom of the container.

For effective bonding and grounding, you need to ensure that you have a solid connection between the container and the grounding or bonding wire. If the drum is painted, make sure you scrape off the paint or use a clip that can penetrate through the paint.

We have seen an increase in citations from OSHA for flammable material storage and lack of grounding and/or bonding.

We learn from others’ tragedies. Even a small container of a flammable liquid can start a fire. A repair shop in California learned this the hard way, when one of their mechanics poured gasoline from a bucket into a newly installed fuel tank. Gasoline spilled onto an incandescent work light. The resulting fire killed the mechanic. Treat flammable liquids with care.

This article first appeared in  AASP-MN News July 2024.  It is intended to provide general information (no advice) about current safety topics.  To discuss your specific concerns and how CHESS may help, please contact CHESS at 651-481-9787 or chess@chess-safety.com.

By Carol Keyes, CSP & Janet L. Keyes, CIH

You wouldn’t give back to a customer a just-painted car that had fish eyes. Nor would you return a vehicle that was not properly aligned. The quality of the work you do is important: it keeps customers returning and it protects you from a lawsuit if a vehicle is an accident, with claims of causation due to poor repair work. The safety of customers is important to your business.

So is the safety of your employees. An employee who is out of work due to an injury is costly, with workers’ comp being only part of the cost. Your production capability is lower. Other employees need to make up the work, making them more prone to injury if they are working too much overtime, if they are fatigued or if they are stressed.

The employee home with an injury is losing income. They are in pain, maybe having to go to therapy several times a week. They cannot do what they used to do, which puts stress on the family.

So, how do you help prevent injuries? We may not be able to prevent all of them, but we can reduce them and control what does happen. How do you enforce quality? You let employees know that it is important to your business. You show them what you expect. You coach them. Same with safety. Call out unsafe behaviors. And call out safe actions, too, so employees know you value that.

Set the example when you walk through your shop. Wear safety glasses. If it’s loud, put on ear muffs. If something’s out of place, blocking a fire extinguisher, an electrical panel, or an exit, move it. If you see an unlabeled container, label it.

Make sure employees have the personal protective equipment they need, and that it fits. You’re legally obligated to provide them with the safety glasses, hearing protection, and respirators needed for the job. This is not a place to skimp – if safety glasses get scratched up, employees won’t wear them. If the only type of hearing protection you provide are earplugs that employees find uncomfortable (or that don’t fit their ear canals), they won’t wear them.

Encourage employees to let you know when they need a different tool, or a scaffold, or if a piece of equipment needs repair. And, act on that information. Responding to employee concerns and suggestions in a positive way is the best way to reinforce that their safety matters to you.

Provide safety training. Once a year for Right to Know/Hazard Communication is a great start, but add a quick safety reminder at shop meetings. Ask for feedback or concerns. Keeping safety in front of employees reinforces the importance of safety.

Work with employees to address the hazards of the job. Your insurance company loss control rep, your safety consultant, the fire marshal, or OSHA might walk through your shop, but they’re seeing just a snapshot of what goes on. They’ll notice problems like a blocked exit, but unless the timing’s right, they won’t see the technician who starts a fire when he uses a torch because he left a rag in the way, or the detailer who sprays wheel acid without any eye or skin protection.

Have you ever heard of job hazard analyses? They’re also called job safety analyses. Fancy names for a simple process of walking through a job, step by step, to identify its hazards and come up with controls. Sort of like blueprinting a car. Ask your employees what tasks they think are the most hazardous. Then evaluate the top tasks. Work with them to list the steps – and the control measures they should be taking to prevent harm. A simple example: using a floor jack. What could go wrong with placing it? With jacking up the vehicle? With lowering it?

We’re not suggesting you do the job hazard analysis for every job. Instead, consider it as one tool to get you and your employees thinking about a safe workplace. Your employees are your best resource for identifying and controlling the hazards in the workplace. They may not know the hazards of a particular chemical, but they know what they use and how they use it.

When we talk with shop owners, we often hear them lament about the difficulty in finding skilled technicians. That makes keeping good people critical to your success. What if those good employees can’t work because they’ve been injured? If you make the investment in their safety and health now, it will pay off.

This article originally appeared in AASP-MN News (April 2024)).  It is intended to provide general information (no advice) about current safety topics. To discuss your specific concerns and how CHESS may help, please contact CHESS at 651-481-9787 or chess@chess-safety.com.

By Janet L. Keyes, CIH

Have you ever been in a Dollar Tree or Family Dollar store? Good for bargains, but they haven’t been good places to be if a fire breaks out. Good luck on getting to a fire extinguisher. Hope you can get to the exit door – and maybe it will be unlocked so you can get outside.

In 1911, 146 garment workers died in the Triangle Shirtwaist fire in Manhattan, many jumping out of windows to their deaths on the sidewalk below. The workers couldn’t escape. Exits were blocked. Exit doors were locked. They had fire extinguishers of sorts – buckets of water – but there were too few.  In the aftermath, rules were written to keep exits clear and to have fire extinguishers at hand.  But some companies have ignored the lessons of Triangle Shirtwaist.

Dollar Tree and Family Dollar ignored the lessons. We don’t think their deliberate ignorance has killed anyone yet. But it has cost the company over $13 million since 2017. Last August, they agreed to a settlement agreement with OSHA, paying $1.35 million immediately and agreeing to pay much more if problems such as blocked exits or extinguishers recur. The company also agreed to develop an enhanced safety program, adding safety staff, changing how they manage inventory, and putting in engineering controls such as extended shelving. OSHA came down hard on these discount stores, not because anyone was injured or killed, but because history has shown, time and again, that people will be killed if they cannot escape.

What did the stores do wrong?

Materials were stored haphazardly, in unstable stacks higher than eight feet tall.

Products were stored in front of fire extinguishers and electrical panels. If you can’t get to the extinguisher within seconds, the fire will spread. If you can’t shut off electrical power quickly, someone could be electrocuted.

Back room exit routes and exit doors were blocked. Merchandise would be delivered and left where it was dropped, because the stores lacked the personnel or space to get the material out of the way.

Exits were locked, unable to be opened from the inside “without keys, tools, or special knowledge.” The path to and away from the exits was less than 28” wide (that goes along with the blocked exit routes).

You wouldn’t violate any of these requirements, would you?  

Parts delivery people prioritize getting deliveries done. They aren’t going to check if they are blocking an exit or fire extinguisher. You need to have a place for those parts or need to make sure they are put away promptly.

Body shops often need to store old car parts until repair is complete. You need to find space to store those securely.  And that space cannot be in front of your electrical panels, fire extinguishers, or exits. We usually haven’t seen this as a problem if you use parts carts and have a designated place to put them. But especially in small shops, we have seen parts carts left higgledy-piggledy, blocking exit routes and emergency equipment access.

Many facilities carefully stripe the floor below electrical panels and fire extinguishers. They may even put down yellow stripes to delineate exit paths. OSHA’s settlement agreement with Dollar Tree requires their stores to do that. But paint can wear off. And even if it doesn’t wear off, it can be ignored. It seems some folks think that the yellow stripes mean “store here!”  We think marking the areas that need to be kept clear is wise, but only if employees know the purpose of the markings and the markings aren’t ignored.

The Dollar Tree settlement doesn’t cover Minnesota stores. But Minnesota hasn’t left Dollar Tree off the hook. The most recent posted citation, the result of a complaint last April, incurred a penalty of $28,000. The standards the store violated aren’t complicated. The main one, considered a willful violation (they knew it was wrong and did it anyway) was this:

“Exit routes must be free and unobstructed. No materials or equipment may be placed, either permanently or temporarily, within the exit route. The exit access must not go through a room that can be locked, such as a bathroom, to reach an exit or exit discharge, nor may it lead into a dead-end corridor. Stairs or a ramp must be provided where the exit route is not substantially level.”

Dollar Tree penalties were so high because they kept having the same violations, albeit in different stores. OSHA quite reasonably thinks that management should correct problems brought to their attention. Once one Dollar Tree store was cited for blocked exits, Dollar Tree should have corrected the problem in all Dollar Tree stores. Because they didn’t, the citations became willful or repeat citations. That increased penalties ten-fold. Keep that in mind if you have multiple shops – a problem cited at one may only cost you $1000. But if the same problem is found at your other shops, it may cost you $10,000.

Don’t be like Dollar Tree – or like the Triangle Shirtwaist Company over a hundred years ago. Make sure employees can get out safely and quickly when the unexpected happens.

This article originally appeared in AASP-MN News (January 2024).  It is intended to provide general information (no advice) about current safety topics.  To discuss your specific concerns and how CHESS may help, please contact CHESS at 651-481-9787 or chess@chess-safety.com.

By Janet L. Keyes, CIH

Does your face get cold in winter? There’s an easy fix – grow a beard. But that doesn’t work for some men, most women – or many painters. Every employee required to wear a tight-fitting respirator must not have facial hair where the respirator seals to the face. End of story. 

My employee says he can’t smell anything when he’s wearing the respirator, even with his beard. It fits okay then – right? 

No.

Relying on one’s sense of smell isn’t reliable. Have you ever walked into a mixing room and been taken aback by the strong solvent smell? How do your painters tolerate that? Olfactory fatigue. If you remain in an area with a strong smell, your nose gets tired and stops responding. Painters are around organic solvents all day, whether painting, mixing, or degreasing. You cannot rely on them to be able to detect a respirator leak by smell.

OSHA’s respirator standard states that “employers shall not permit respirators with tight fitting facepieces to be worn by employees who have facial hair that comes between the sealing surface of the facepiece and the face or that interferes with valve function; or any condition that interferes with the face-to-facepiece seal or valve function.” That explicitly prohibits beards. Goatees are okay – if they are trimmed back so they fit inside the respirator. Mustaches are fine, as long as they aren’t elaborate walrus mustaches that stick out of the respirator. Sideburns – no problem if they don’t extend too far.

My employee was able to pass a fit test with his beard. It must be okay. 

No, it isn’t okay.

Fit-testing is done to determine if a respirator is the right size and shape to protect the employee. OSHA requires that initially, annually, and if there is a change that affects respirator fit. That change could be changing the brand or size of the respirator. It would also include a change in the employee’s face, such as a broken nose or significant weight loss.

No one respirator fits everybody. Nose sizes differ. Some chins are pointed; some are round. Some people have broad faces; some narrow. Manufacturers make different sizes and styles to accommodate as many faces as possible. If you only give your employees one choice of respirator, it might fit everyone – or it may not. Fit testing is the way to determine if employees are able to obtain a fit good enough to provide the level of protection needed.

Although OSHA’s respirator standard lays out exactly how fit testing is to be done, it is not a completely objective science. The most common type of fit testing, qualitative fit testing, relies on an employee’s ability to taste or smell the challenge agent. It often isn’t done correctly – too few exercises are used, it’s done too quickly, or the tester doesn’t verify that the respirator user can sense the challenge agent. Even when done correctly, it is subjective. Someone with a beard could pass, simply by stating that the test agent wasn’t detected.

Another type of fit testing, quantitative fit testing, is much more objective. This measures the amount of leakage into the facepiece by measuring the pressure differential or by measuring microscopic particles in the air. But even this method has variables that can change whether someone passes or fails. If we test someone with a beard, that person could pass. But we’d be in violation of OSHA’s standard – and risking that person’s health – if we say the beard is okay.

I’ll have my employee shave when he’s being fit-tested. That’s adequate, isn’t it?

No. Absolutely no.

Your painters’ respirators are meant to keep them from breathing contaminants when they’re working. If the respirator doesn’t seal well, it won’t keep out contaminants. And facial hair breaks that seal. Vapors and small particles easily get past those hairs. NIOSH reports that facial hair under the respirator’s seal will cause 20 to 1000 times more leakage than a clean-shaven face.

Fit testing shows that the respirator can fit well enough. But if you change how the respirator fits by adding a beard, the fit test results no longer apply.

Why can body techs have beards?

NIOSH studies have shown that dust levels from body work are typically below occupational exposure limits. That means respirator use is not mandatory. We encourage respirator use in dusty conditions (although we really prefer to have the dust controlled by other means, such as vacuum sanders). But that use is voluntary, so fit isn’t critical.

If your body techs are using cartridge-type respirators, they need the same medical approvals required of your painters. They need sufficient training to ensure using the respirator will not cause any harm. They need to keep the respirators clean and in good condition, same as your painters.

If their work is very dusty, dusty enough that respirator use becomes mandatory, then the beards have to go.

I’ll lose my painter if I tell him he has to shave.

Then provide a respirator that can be worn with a beard, an air-supplied respirator or a loose-fitting powered air purifying respirator. Many painters like these a lot, once they get used to them. They are cooler in summer and provide a higher level of protection. But they can’t be slipped on and off as easily as half-mask respirators. They are more expensive than half mask respirators. If you use air supplied respirators, you need to make sure the air is filtered to provide breathing quality air and is tested for carbon monoxide (and you have to keep the airlines to the respirator separate from those for the paint gun).

Are respirators really needed?

Maybe not, particularly if you spray waterborne paints (and primers and clears – assuming they’re available to you). The only way to know is to monitor the air. To do that, the painter would wear a monitor that collects the chemicals of concern onto appropriate media, such as activated charcoal. A qualified laboratory would then extract the chemicals and measure how much was collected. Divide that by the time exposed to get the air concentration. 

We’ve found, though, that the mist from painting can be high enough to require respirator use, even if the vapor levels aren’t high enough.

The take-home message: Bearded painters cannot wear tight-fitting respirators (not safely, at least). They need to stay clean-shaven – or switch to loose-fitting respirators (airline or powered air purifying respirators). You need to do initial and annual fit testing for tight-fitting respirators, so you know the respirators can protect them. But the respirator has to be worn as it was fitted, with no facial hair breaking the seal.

The take-home message: Bearded painters cannot wear tight-fitting respirators (not safely, at least). They need to stay clean-shaven – or switch to loose-fitting respirators (airline or powered air purifying respirators). You need to do initial and annual fit testing for tight-fitting respirators, so you know the respirators can protect them. But the respirator has to be worn as it was fitted, with no facial hair breaking the seal.

This article first appeared in AASP News December 2022.

By Janet L. Keyes, CIH

Sore back. Aching shoulders. Painful wrists. That’s the problem with getting older, isn’t it? It’s more likely to be the problem if you repeatedly ask more from your body than it can handle. Most of you have suffered through pains from overexertion. Rest, take ibuprofen for a day or two, and you’re ready to go again.

But what if you can’t rest? What if you need to keep lifting that awkward part to keep doing your job? Hammering a part? Holding a paint sprayer? Kneeling on a concrete floor? That little nagging ache that you can ignore one time becomes a big ache, difficult to ignore. The ibuprofen yields to stronger painkillers. The docs recommend surgery. You can’t do your job anymore. And those stronger painkillers have led to addiction. Depression sets in. And thoughts of suicide arise.

Far-fetched? No. Opioids, used for pain relief, can cause addiction. Those addicted are at higher risk for suicide. The construction industry has recently recognized this problem (see  https://blogs.cdc.gov/niosh-science-blog/2021/09/14/opioids-in-construction/). The automotive repair industry doesn’t have the same high risk of suicide – but that doesn’t mean we should ignore the problem.

In fact, it makes good business sense to try to make work easier on your workers’ bodies. If work takes less effort, people can do more in the same amount of time. Efficiency and good ergonomics go hand-in-hand. Reduce the risk of musculoskeletal disorders, and you save twice: you don’t pay for those expensive back or shoulder injuries, and employees can get more done.

How can you do that?

Look at your job flow. Where are parts kept? Do employees need to go onto a mezzanine to fetch a part? That takes time – but also means carrying parts up and down stairs, a task that could easily lead to strains.

Look at work height. Do you provide vehicle lifts in good condition? Or do employees need to jack up vehicles and rely on jack stands and creepers? Do employees need to stand on rickety stepstools and stretch to reach taller vehicles? Or do you provide sturdy and stable platforms?  Can they be adjusted to accommodate the different heights of your employees and the different heights of vehicles? One of the goals with good ergonomic design is to have neutral postures, where employees don’t have to bend or twist or stretch to do their jobs.

Look at what other industries and other companies have done to reduce wear and tear. An auto body technician recently showed us his Racatac kneeling sitting creeper, developed, he said, for the flooring industry. It let him kneel comfortably while sanding the side of a car. He could have knelt on the floor, but that starts hurting pretty quickly and can lead to chronic knee problems. He could have used knee pads, but they’re not always comfortable, and don’t provide the mobility of the creeper.

But your technicians provide their own tools! True – but you’re the one who pays the workers’ comp premiums and who has to scramble for workers if one is out because of low back pain. So it is likely to your benefit to subsidize equipment or tools that make work physically easier.

Watch your workers, and talk to them. Look at their body positions when they work. Do your painter’s arms get tired from holding the spray gun? What tasks make their backs or shoulders ache? Do they have ideas to make work easier?

We know what factors prevent musculoskeletal disorders such as sprains, strains, back injuries, and shoulder pain.

• Design the job so employees don’t need to lift too much. It isn’t just the weight of objects that determines how much they can safely lift. It’s also the shape and where it’s being lifted to and from. Lifting a 50-pound box with handholds off the back of a delivery truck is easier than lifting a bulky car part with nothing to grab onto from the floor.
• Take advantage of people’s power zone, that area between knees and chest, extending out the length of the forearm. That’s where work should be done, because that’s where people have the most strength and flexibility. That’s also where heavy objects should be stored.
• Encourage neutrality. A neutral posture – head up, looking forward; arms down at sides – puts the least amount of stress on the body. If tools force wrists to bend, the user is more likely to develop wrist problems. If employees need to work overhead, shoulder and neck problems become likely.
• Make the work easier. If it takes less force, produces less vibration, and minimizes repetitive motions, employees will work more comfortably. If they’re more comfortable, they can do more. They’re happier. Productivity goes up, and you’re happier.

Many of the workplace safety measures we want to see don’t provide an immediate payback. You won’t see the hearing damage caused by noise until years later. You don’t see the fires that didn’t occur.  Ergonomic improvements are different – even if you can’t see the back aches you prevented, you can see the improvements in productivity. Good ergonomics = work smarter, not harder.

For questions on ergonomics or other safety related questions, contact Carol Keyes at CHESS, Inc.

This article first appeared in AASP News (October 2023). 

By Janet L. Keyes, CIH

Ever look at a safety data sheet? Ever wonder why you’re required to have them available to employees? Have any employees ever asked to see one?

Safety data sheets exist for one important reason: to convey more information about a product than you can glean from the label or from Right to Know/hazard communication training. And that additional information is crucial. Training can cover general hazards, but it has a hard time delving into detail on any one product. Labels are too space-limited; their purpose is to give you a quick idea of the major hazards and precautions (if you can read the small type!). If you really want to know what makes a product hazardous, what its hazards are, and how you can deal with those hazards, the safety data sheet is the best place to start.

How can you use them? Let’s look at one, for Finishmaster’s Smart Lacquer Thinner. Many of you have used this product. It’s a typical lacquer thinner. And this SDS is pretty well-written, so it’s a good example. Not all safety data sheets are this good. The manufacturers are responsible for providing them – and some manufacturers don’t have the resources or knowledge to provide an accurate SDS. And some of the companies that write SDSs make them way too technical for their primary audience – those who use the product – to understand.

SECTION 1.  All SDSs will start out with contact information – who’s responsible for the product and who you can call if you have health or safety problems with it. Finishmaster uses a service called Infotrac to answer your emergency questions. Other manufacturers may use Chemtrec, part of the American Chemistry Council. And others may handle emergencies in-house.

SECTION 2. The next section looks a lot like the product label, complete with the pictograms that provide a general warning about product hazards. But the SDS will also have the hazard classification. If I’m writing an SDS, one of my first steps will be to classify its hazards according to specific criteria. Does it catch on fire easily? If so, it’s classified as a flammable liquid. Can it cause permanent eye damage? The hazard classification system is a global system, based on objective criteria. The aim: ensure products with the same hazards get the same warnings.

The lacquer thinner is classified as “category 2: acute oral toxicity.” That means the lethal dose for lab animals is between 5 milligrams and 50 milligrams per kilogram of body weight – if converted to human scale, about a tenth of an ounce could kill an adult. A category 1 chemical would be at least ten times more toxic, and a chemical classified as acutely toxic category 4 at least ten times less toxic. Because of that category 2 acute toxicity classification, lacquer thinner gets the skull and crossbones pictogram, along with the warning, Danger. Toxic if swallowed.

SECTION 3. What ingredients are responsible for that toxic warning? Section 3 lists the potential culprits. I can’t tell which one is acutely toxic, but I could dig into more. And the toxicology section towards the end of the SDS might tell me.

SECTION 4. The First Aid Measures section gives pretty straightforward recommendations for exposure. It tells me if throwing up after swallowing the chemical is recommended (it isn’t. Who would swallow lacquer thinner, you ask? I know a body tech who did, because it had been put into a soda pop container). I’d still want to call the poison center for advice.

Of more value: this section tells me what the most important immediate symptoms will be. As too many body shop workers know, it will severely irritate eyes. But do users know that repeated overexposure can cause permanent brain and nervous system damage?

SECTION 5. As we’ll see when we get to the physical characteristics section and as you already know, thinner catches fire easily. But have you thought about what to do if it ignites? Pouring water on the fire will spread it, because it’s lighter than water. If you read the firefighting section when you get the product, instead of waiting until it ignites, you can make sure you have the right type of extinguisher. Combine that with the section on handling and storage, and you’ll know what measures to take to avoid a fire.

SECTION 6. The section on accidental release measures is about as straightforward as the first aid section – confine it, clean it up, dispose of properly. But would you think to ventilate the area? To make sure people stop grinding or doing other spark-creating activities?

SECTION 7, which advises on how to handle this safely, should be required reading before you even order the product. Were you aware that you can get flash fires with thinner? Have you thought about how to store it safely?

SECTION 8. How will you make sure employees aren’t overexposed? The next section covers that. It’s better to use engineering controls, such as good ventilation, and good work practices than to depend on the use of personal protective equipment. But sometimes all are needed. For instance, if you can’t choose a safer solvent for wiping down parts, skin contact will occur. What type of gloves will work? Finishmaster recommends neoprene gloves. Nitrile gloves, the type we see most often, will degrade quickly when in contact with toluene, which makes up 19% of this thinner.

SECTION 9, physical and chemical properties, is my favorite section, because this tells me how the chemical will behave. If it has a vapor pressure above, say, 1 mmHg, it will evaporate readily enough that breathing it could lead to overexposure. That’s not a hard and fast number. Mercury has a vapor pressure of only 0.0012 mmHg – but it is a potent neurotoxicant. In a poorly ventilated area or if you’re frequently exposed, it could poison you.

The flash point tells me how readily the chemical will ignite – the lower the flash point, the greater the fire hazard. The flash point for gasoline is about -45°F, much lower than the 24°F for thinner. But both of those are low enough to be major fire hazards.

If a pH is listed, I can tell how corrosive the chemical is. The pH scale goes from 0, for very strong acids, to 14, for very strong alkalis. Neutral is 7. The pH of wheel acid and battery acid is below 1. The pH of floor cleaners is usually around 13. Mix those, and they’ll react violently. Get either in your eye, and you could have permanent eye damage.

SECTION 10. I don’t need to remember my chemistry to know what I can’t mix with this product – I can just read Section 10, Stability and Reactivity. Incompatibility isn’t something I need to worry about with thinner. This section tells me it is stable, with no particular conditions or other materials to avoid.

SECTION 11. If I want to find out more about its health hazards, Section 11, Toxicological Information, is the place to go. What are its chronic effects, those from repeated overexposure? Can it cause cancer?  That’s most often determined by the evaluations of one of two agencies, IARC under the World Health Organization and NTP, under the Department of Health and Human Services in the US. They will classify chemicals as known carcinogens, suspect carcinogens, not classifiable, or probably not carcinogenic.

SECTION 13. If we’re trying to figure out how to dispose of waste thinner, we might consult section 13, Disposal Considerations. Sometimes, this will clearly state that the material is not hazardous waste. But even if it states that, keep in mind that you need to check local regulations, and that how you use the product can make it hazardous waste.

SECTIONS 12, 14, 15. There is a section on ecological information – would it kill fish or beneficial insects? How it needs to be classified for shipping is Section 14. Regulatory information, such as whether it is a hazardous air pollutant, is found in Section 15. And then any other information the company thinks is needed for the user will be in the last section.

Safety data sheets aren’t exactly light reading. But they provide a wealth of information about the product. Too much for you? Stick with the sections on handling and storage, on exposure controls, and first aid measures. Read those, and you’ll have a good grasp of how to handle the material safely.

This article originally appeared in AASP-MN News (September 2023).  It is intended to provide general information (no advice) about current safety topics. For questions on Safety Data Sheets please contact CHESS at 651-481-9787 or chess@chess-safety.com.

By Janet L. Keyes, CIH

What kills in automotive shops?

Being crushed by vehicles. Taking cars for test drives. As we were perusing OSHA inspections for car dealers, we were struck by the number of fatality reports. That led to a search for OSHA-reported vehicle fatalities, such as these:

• A year ago, an employee started up a pickup truck to move it out of the repair shop. It immediately shot forward, crushing another employee against another vehicle. The truck had been left in gear because the parking brake wasn’t working.
• In July 2021, an employee put an RV on jacks to fix a flat tire. The RV shifted and fell, crushing the mechanic.
• Again in 2021, two different shops used forklifts to raise and move cars. When a car at each of those shops fell off the forklift, it crushed an employee to death.
• August, 2021. This time, the car wasn’t on a forklift. It was on an ordinary hydraulic lift when, for unexplained reasons, it rocked and then fell, killing the employee.

Don’t stand between vehicles and fixed objects. Inspect your lifts and jacks. Never rely on hydraulics – use jack stands; make sure the safety latches for vehicle lifts work. Don’t take shortcuts when working under vehicles.

Go Ahead and Contest

We recently saved a company $18,367. How? We recommended that they contest some OSHA violations. The company didn’t question the citations. They hadn’t been doing Right to Know/Hazard Communication training. They weren’t using respirators correctly. Employees were overexposed to a substance. Equipment wasn’t guarded. They hired us to help correct those problems. But we still recommended contesting because if you contest the citation, there’s a good chance you’ll pay less. If you don’t contest the citation, you’ll pay the full amount.

OSHA isn’t in the money-making business. Penalties assessed against employers go to Minnesota’s general fund, not MN/OSHA. MN/OSHA prefers to get corrections in place and come to a settlement agreement than to try to get every last penny out of an employer. OSHA doesn’t get mad or offended if you contest citations. Instead, our clients have usually been offered a 40% penalty reduction, once OSHA sees the companies are trying to correct the problems.

The company that saved $18K in OSHA penalties ended up paying a lot of money anyway. They had to pay us to get them on the right track with training and control measures. They paid for ventilation system upgrades and machine guarding fixes. It would have been cheaper to have fixed the problems before OSHA came in.

If you want to pay even more, don’t contest the citation and don’t correct the problem. In 2018, a car dealer in Duluth was cited for respirator program problems and lack of carbon monoxide monitoring. They paid the full amount of $2400. This past February, OSHA cited them for the same problems. This time, the dealer paid the full penalty of $4500. If it happens again, their penalties would jump substantially. For Minnesota to be able to continue to run its own OSHA program, it must raise its penalties to be in line with federal OSHA. Federal OSHA charges a minimum of $11,162 for repeated violations. $22,324 may not buy a new car, but it still is a good chunk of change.

Body Techs and Respirators

Painters need to wear respirators because of the isocyanates and solvents in the products they spray. Do body techs need respirators?  

We don’t think they usually do, but they may want to. Dust levels may be uncomfortable, but are not likely to be close to legal or recommended exposure limits. Styrene, the solvent in body filler, is also likely to be well below limits. Respirators may be needed for priming or spraying poly, but those tasks need to be done in a spray booth or prep station to control the fire hazards.

If body techs are using N95 filtering facepieces, all you need to do to comply with OSHA’s respirator requirements is to hand out Appendix D to OSHA’s respirator standard. That cautions that users should read and follow manufacturer’s instructions, use NIOSH-approved respirators, wear the respirators only for protection against relatively low levels of particulates, and keep track of their respirator.

But when we walk through body shops, we often see elastomeric (rubber-type) respirators, such as the bodyman’s mask. You can’t get by with just handing out Appendix D if employees use that type of respirator, even if use isn’t mandatory. You need to do three things to ensure use of the respirator won’t harm the employee:

• Get medical clearance. Anyone who is required to wear any type of respirator, including N95 filtering facepieces, must have medical approval to wear the respirator. But that’s also required for voluntary users of elastomeric respirators. Your occupational health clinic can handle this for you. There are also online options.
• Have standard procedures addressing how to take care of the respirator, so it doesn’t harm the user.
• Train users on those standard procedures, so they know how to take care of their respirators. They need to keep their respirators clean and in good condition. We shouldn’t see dirty masks with worn-out straps left on top of body techs’ tool chests.

As long as respirator use is not required, body techs don’t need annual fit testing and training and they can be as hairy as they want. If they need to wear a respirator, though, they must be clean-shaven where the respirator seals to their face. If they aren’t, the respirator won’t give them enough protection.

This article originally appeared in AASP-MN News (June 2023).  It is intended to provide general information (no advice) about current safety topics. To discuss your specific concerns and how CHESS may help, please contact CHESS at 651-481-9787 or chess@chess-safety.com.

By Carol A. Keyes, CSP and Janet L. Keyes, CIH

Has any employee ever gotten a scratch? Something in an eye? Stubbed a toe? Received a paper cut? Would you report that to your insurance company? I doubt it, but if it happened at work, you should.

Imagine the worst: the scratch and paper cut become infected with flesh-eating bacteria; the stubbed toe is broken and just won’t heal. Gunk in eye leads to a weekend emergency room visit. These no-big-deal injuries are now days of lost work time, dollars of medical expenses. And because your workers’ comp carrier never heard of these injuries until they blew up, the insurer questions if they really are work-related – and if they are, why you didn’t report them right away. That could saddle the employee with a big medical bill, a lot of ill will, and maybe even a visit to an attorney. The insurance company could end up paying a fine for late reporting, a cost that will certainly be passed on to you.

Most of the time, that scratch or stubbed toe or paper cut or eye heals quickly. Most of the time, those minor injuries stay minor. If you report them to workers’ comp, your insurer will open a file and then close it, with no costs incurred and no penalty given to you.

So why should you go through the effort of reporting these minor injuries? We gave you one reason – in case they turn into something major. If the employee ends up in the emergency room over the weekend, both you and the employee are covered.

Keeping track of those minor injuries helps you identify patterns. If you have one employee with something in the eye, you might attribute it to clumsiness or working under a very rusty car. But what if five employees report something in their eye? It might be time to look at what’s causing that. Maybe you need to rethink your policies on safety glasses in the body shop.

You might be tempted to just pay out of pocket for that weekend ER visit. But that isn’t allowed under the workers’ comp law. You could end up paying more in premiums, paying penalties, and even have your insurance cancelled. And if something goes wrong – the stubbed toe becomes infected and requires hospitalization – you could be on the hook for high medical costs, too. Protect yourself and your employees by submitting injuries to your workers’ comp carrier.

What do you do with all these minor injury reports? Track them and review them. Look for trends. You can track them on an OSHA 300 log or another spreadsheet. Record the facts: who was involved, what happened (stubbed toe on vehicle hoist), when, what task was being done, what was the injury. It is easy to forget what happened five months ago, but now you can look at your spreadsheet for any common issues or concerns.

Now that you’ve identified a problem trend, how can you correct it?

Talk with your employees in your next safety committee meeting. What safety committee? you ask – the one that you now must have. A new law in Minnesota requires it for every company that falls under the AWAIR (A Workplace Accident and Injury Reduction program) standard. Formerly, all companies with 25 or more employees needed a safety committee. There are some exemptions for lower-hazard companies with fewer than ten employees. All automotive repair facilities (collision and mechanical repair) are required to have AWAIR programs – so start forming your safety committee.

So how do you start a safety committee? What should it do?

Do you meet with your employees for production or other staff meetings?  Once a month or every other month, add time to discuss safety issues. Have a set agenda, ask for input, and take notes. Voilá – you have a safety committee. If you’re a large shop, it may make sense to have a handful of employees (some from each area) make up your safety committee. But small shops can have committees of the whole.

This could be your agenda:

• Any recent injury or near-miss. How can you prevent recurrences (safety glasses, replacing damaged ladders, wearing gloves…)?
• Issues seen when you walked through your facility—blocked fire extinguishers, expired or used eye wash station, electrical panels blocked
• Discuss a recent safety article from AASP-MN News, such as safe storage of tires or welding hazards
• Safety concerns from employees

Take notes of what was discussed, who attended, and any decisions made. Post them on your employee bulletin board.

Linking the AWAIR standard to safety committees is new. As we write this, MNOSHA has not yet updated its website with information about it. But that shouldn’t stop you. A safety committee is easy enough to implement, and it can lead to a safer workplace – and a safer workplace is a more productive workplace. Safety pays.

This article originally appeared in AASP-MN News (July 2023).  It is intended to provide general information (no advice) about current safety topics. To discuss your specific concerns and how CHESS may help, please contact CHESS at 651-481-9787 or chess@chess-safety.com .

By Janet L. Keyes, CIH

How did you interpret that sentence? Was it a question about whether your residence is clean? Or was it a question about whether you’ve gone through and gotten rid of all the miscellaneous no-longer-needed stuff that accumulates? We don’t really care about the answer to the first question. If the answer to the second is never, or not recently, it’s time to talk about housekeeping.

You’ve seen pictures of garbage houses or hoarder houses. Your shop isn’t anything like those. But unless you’re particularly diligent, stuff piles up. You try out a new product and no one likes it, so the barely-used container stays on a back shelf. You purchase a specialty piece of equipment but use it only once. It takes up residence in a back corner. If you have unlimited space, you may never need that back corner. But most shops do not have unlimited space. And too often, that stuff isn’t in the back corner but is left where it was last used, in the middle of the shop.

Who cares if you’re tidy and uncluttered? Your local Fire Inspector cares. The Fire Code says that “storage of materials in buildings shall be orderly.” OSHA cares. “All places of employment shall be kept clean to the extent that the nature of the work allows.” And “all places of employment…are [to be] kept in a clean, orderly, and sanitary condition. Why do they care? Because messy shops increase the fire hazard. Messy shops increase the hazards from slips and falls. Messy shops are more dangerous.

Can employees get out quickly in an emergency? Can they get to fire extinguishers or eyewashes? People tend to forget about things they don’t use often – such as emergency equipment. One cramped shop had a large tool chest, a stepstool, a box, a creeper, and a pail all stored in front of an emergency exit at the back of the shop. If a fire broke out in the front, employees would have no way of escaping quickly. Ever hear of disastrous fires where many people died because they couldn’t reach an exit in time? In Boston in 1942, nearly 500 people died in the Cocoanut Grove Nightclub fire – many couldn’t get out because some exit doors were locked. 

Good housekeeping is more than just keeping emergency equipment clear. The risk of a fire increases with clutter. You already have a lot of flammable and combustible material in your shop. You get parts and supplies in cardboard boxes. Your employees use rags to wipe up oil spills or wipe down cars. Does anyone grind or weld? Those sparks can travel thirty feet. A spark landing in a pile of rags could smolder for hours. So tidy up, to reduce the fire risk.

As you walk through your shop, what do you have to step over? See that cord across the aisle? What about the air hose? Those are tripping hazards. And if you stumble over the extension cord, you might pull it out of the wall, damaging the plug or pulling off its grounding pin. We doubt that you can eliminate those cords and hoses entirely. But is there a better way to handle them? Cord reels and drop outlets might keep them out of the way. Requiring employees to put them away, unplugging extension cords at the end of each day, will also help keep them tidy.

Don’t tolerate liquid spills. Cars have lots of liquids in them – gasoline, oil, coolant, washer fluid. Two of those are very flammable. The other two can burn. All are environmental pollutants. If you have employees who can’t pour into drums, get bigger funnels. Never let drums be filled to the very top, so they don’t overflow. And you need to leave room for expansion (that’s why your 55-gallon drum of thinner only holds 53 gallons). 

Designate a spot for things to live. Mark where your welders will be kept. Store ladders in the same spot each day. If you’re tight on space, having designated locations for everything (even for trash containers!) makes it easier to find everything. Figure out what is used often; if equipment is rarely used, store it out of the way. If you have a designated location for it, it can be found when it is needed.

Put things away. When you’re done with the spot welder, put it back in its place. Use a broom? Hang it back up. This is easier once things have a place to go.

Don’t hoard. Go through the shop at least once a year. Ask if anyone’s used this equipment or that product. If the answer is no, get rid of it (following environmental regulations, of course). We all have those round-to-it projects – that cord you plan to fix, the equipment you want to weld back together. But if you haven’t been able to get to it in the past year, what makes you think you’ll get to it in the coming year?

If you’ve taken any management courses or read management books, you probably have heard of the 5S Methodology: Sort, Set in order, Shine, Standardize, and Sustain. It really is just good housekeeping. Get rid of what you don’t need. Have a place for things. Keep your shop tidy. Repeat. It’s an ongoing effort. Management gurus tout it because it improves productivity. It makes it easier for your employees to do their jobs. But it also makes your workplace safer. 

This article originally appeared in AASP-MN News (April 2023).  It is intended to provide general information (no advice) about current safety topics. To discuss your specific concerns and how CHESS may help, please contact CHESS at 651-481-9787 or chess@chess-safety.com.

By Janet L. Keyes, CIH

Ask your body techs and mechanics this question, “Have you ever started a fire when welding?”

We predict that more than half of them will say yes. And we can predict their answers when you ask them what started on fire. Rags. Parts of cars, such as foam insulation and carpeting. Their clothing. Themselves.

Another question to ask your technicians: “Have you ever had welder’s flash?” Don’t be surprised if nearly all of them say yes. Ask them how it happened. Sometimes, it’s because someone else was welding near them. Sometimes, it’s from the radiation reflecting off a nearby wall. Sometimes, the battery on their autodarkening welding helmet gave out. And sometimes, inexcusably, they decided to weld without eye protection.

What is welder’s flash? It’s photokeratitis – a burn on the lens of the eye caused by the intense ultraviolet radiation from welding (too much sun, particularly when reflected off snow or water, can cause it, too. In that case, it’s called snow blindness). It usually isn’t felt immediately. Instead, symptoms often show up at night, hours after the exposure occurred. Welders report it feeling like ground glass or burning sand in their eyes.

Fires cost you money. Employees who need to take time off work because their eyes hurt aren’t productive. Don’t underestimate the hazards of welding.

Welding hazards aren’t limited to fires and welders’ flash. Electrical shock can occur, especially if cables and connectors are damaged. The ultraviolet radiation can cause skin burns, just like a sunburn. The heat can cause thermal burns. Breathing in the fumes can damage lungs and increase the risk of lung cancer. If the metal is galvanized (zinc-coated), getting a big noseful of the fume can lead to metal fume fever. Several hours after breathing in the zinc fumes, the welder will start feeling like he’s come down with the flu – achy, feverish, chilled. That usually requires a day or two off work to recover.

It’s all very well and good to say how hazardous welding can be. What can you do about that? Stop welding? That isn’t realistic. Instead, think about ways to reduce the risk.

Don’t let welding burn down your shop. The Minnesota Fire Code requires that welding either be done in areas authorized for that purpose or that a hot work permit be filled out each time anyone welds (and the permit just means you take the steps to make an area safe for welding). What makes an area safe for welding? Flying sparks or slags won’t hit anything that burns easily. Floors are kept clean. Walls and partitions won’t burn. There’s no welding or torch use on containers that held flammable liquids or gases unless those have been thoroughly cleaned or purged. You have a fire extinguisher at hand, with people trained on how to use it.

The body shop or mechanics’ shop can be a designated area for welding. But you need to keep things that easily ignite out of the area. Keep aerosol cans and body filler on tool chests, not on the floor. Limit how much of those are out in the shop. Make sure rags are picked up and put into closed metal containers. Check that the extinguisher is close to hand.

If you’re welding on a car, try to fire-proof it. Can you remove any interior components, such as foam-padded seats? If you can’t remove them, use welding blankets or welding and spark deflection paper to cover it up. That adds to the cost and time, but you’ll make it up by not having to replace the vehicle.

Of course, don’t allow any welding in painting and priming areas.

Make sure welders dress appropriately for the job. As the employer, you are responsible for providing the required personal protective equipment. Even for quick welding jobs, that means welding helmets and leather gloves. Leather jackets keep sparks from burning clothes and skin. Is a respirator needed?

Those in the area need to be protected from the flash. The best option is to set up welding screens. The screens block the ultraviolet radiation and sparks. If that isn’t feasible, at least require everyone in the shop to wear polycarbonate safety glasses; teach them to look away from welding; and train welders to alert others in the area when they’re about to weld. If they’re helping someone who’s welding, they need the same level of protection, including a welding helmet, as the welder.

Don’t allow technicians to burn off coatings. Grinding them off is much safer. Only bare metal should be welded. Solvent residues and coatings can create toxic fumes.

How can we ensure welders don’t breathe too much of the fume? Welding helmets block some. Having good general ventilation in the shop provides some protection. But if anyone does a lot of welding, wearing a respirator with N95 or P100 filters is a good idea. And you must include that person in your respiratory protection program – getting medical approval for respirator use, training them on correct care and use each year, and fit testing.

Welding is hazardous. We can’t eliminate the hazards, but we can mitigate them. If your technicians need to weld, remind them of what they need to do to weld safely. Better to take five minutes now, instead of rebuilding the burned-down shop later.

This article originally appeared in  AASP-MN News (January 2023).  It is intended to provide general information (no advice) about current safety topics. To discuss your specific concerns and how CHESS may help, please contact CHESS at 651-481-9787 or chess@chess-safety.com.

By Janet L. Keyes, CIH 

What’s the quickest way to remove dust from a surface? Blow it. Use your compressed air gun, cranked to maximum pressure, to get that surface clean. But that dust doesn’t disappear. It just moves from one surface to another. Some dust will settle quickly. Smaller dust particles can linger in the air for hours. You’ll breathe those in, as will everyone near you. A good idea? Not for your lungs and eyes.

Do you remember the anthrax attacks in 2001? Letters containing anthrax spores were sent through the US Postal Service to reporters and elected officials. As the letters went through postal facilities, they were sorted by high-speed machines and by hand. Each day, maintenance employees used compressed air to blow the accumulated paper dust off of the machines. When they did so, they spread the spores throughout the building. Four workers breathed in the spores and became infected with anthrax. Two died. Two mail processing facilities were closed down and decontaminated, at a cost of nearly $200 million. The post office doesn’t clean machines with compressed air anymore.

You’re not likely to have weaponized anthrax spores in your dust. But what will be in it? That depends on what it’s from. In the days when asbestos-containing brakes were common, the dust would contain asbestos fibers, good at causing respiratory cancer and good at remaining suspended in air for a long time. Is the dust from cleaning out mouse droppings? Breathing that dust puts you at risk of disease, asthma, and allergic reactions.

What if it’s just body filler and paint? Most of that dust does not have any specific toxic effect, but too much dust of any sort can be damaging to breathe.

There are alternatives to using compressed air for cleaning. Dust capture tools, attached to grinders and sanders, remove the dust when it is created. They keep your shop from getting a fine dust layer over everything. They can speed up the work, too, because employees don’t need to stop what they’re doing to blow off the dust. You don’t need to stop all work periodically to clean the shop. You won’t have to replace air filters as often. Capturing the dust at the source also reduces the fire risk from combustible dust, such as that from body filler.

You can use water to control dust. When asbestos brakes were common, that was a recommended way to control brake dust. Mechanics were to spray water with a detergent added to it to wet all brake and clutch parts and then wipe down the parts with a rag, to be disposed of as asbestos waste. People who work with stone routinely do it wet, too. The water they use effectively controls silica dust, as long as the dust isn’t allowed to dry out. Is that feasible for your work? Probably not.

If you can’t capture the dust when it is created, you can vacuum it up. But you’d want to use a vacuum with an efficient filter, so fine dust doesn’t come in one end and go out the other. Vacuuming cleans the shop floor, but takes a lot of time and effort – and it’s hard to vacuum irregular surfaces such as the clutter on top of tool boxes.

What if those methods won’t work? If you absolutely must blow it, do it right.

Require that everyone use OSHA-compliant air guns. These are designed so that blocking the tip doesn’t make the air hose pop off and whip around. They may have a port in the side of the nozzle, to divert the air flow (don’t let anyone cover that port with tape. Doing so is actually self-defeating, because that port creates a Venturi effect, actually increasing the tip pressure during normal use). Other compliant guns may have star-shaped tips or solid tips, with the air coming out from behind the tip. Those designs make it very hard to block the tip.

Require employees to wear safety glasses and hearing protection if they must use compressed air. The flying particles will get in eyes. The air itself is usually loud enough that it can damage hearing in minutes. There are air blow guns designed to be quiet (Silvent and Exair are two manufacturers of quieter compliant air guns), but they are more expensive. We rarely see those in the shops we visit.

Strongly discourage employees from using compressed air on themselves. That’s how people blow air into skin breaks, leading to infections. And never let anyone turn a blow gun on someone else.

Automotive work can be dusty. But there are better options than putting that dust back in the air.

OSHA safety grants have funded dust capture systems. For information about those, about dust control and evaluation or for other safety issues contact CHESS at 651-481-9787; toll free at 877-481-9787, or carkey@chess-safety.com.   

This article originally appeared  in AASP-MN News (December 2022).  It is intended to provide general information (no advice) about current safety topics.  To discuss your specific concerns and how CHESS may help, please contact CHESS at 651-481-9787 or chess@chess-safety.com.

By Janet L. Keyes, CIH and Carol A. Keyes, CSP

Has anyone slipped out in your parking lot? Was it from last winter’s ice? Or did someone trip over a curb? Anyone trip on an air hose? Fallen down in your shop? Did it happen to an employee? A customer? What did that cost you?

Slips, trips, and falls are common – and expensive. According to Liberty Mutual, falls on the same level cost US businesses over ten billion dollars a year. Slips and trips,without falling, add another $2.5 billion.

What kinds of injuries are we talking about? If you’re lucky, just bruises and scrapes. But too often, it will be strains and sprains, broken bones, and even brain injuries. No wonder your insurance carrier sends out advisories about slip/trip/fall hazards each year.

Whether you slip or trip, the result is the same – you fall, or you stumble but manage to stay upright. But the mechanism is different. With a slip, your feet slide. In a trip, your foot strikes something and stops but your body continues forward. Or you could step and fall – your leading foot lands on something lower or higher than expected, throwing you forward or to the side. You’ve probably experienced that when a step is slightly higher or lower than others.

Slips are caused by a lack of traction. In geek terms, the coefficient of friction between shoes and the walking surface is too low.  Think of the slipperiness of detail areas, where soaps and water are used. To eliminate the slip, increase the coefficient of friction. Clean up water or oil spills right away. For chronically wet areas, install mats or nonslip flooring. Reduce foot traffic in the wet or oily areas. Don’t let employees use wash bays as walk ways. Even if it’s the quickest route into the building, it’s a bad walking path.

Maintain your floors so they stay non-slippery. A highly polished floor may look great, but it won’t look so good when you’re helping a customer back to his feet. Keep the floors clean. Fine dust on your shop floor changes your non-slip shoes into smooth soles, increasing the likelihood of slipping. Follow the advice of the floor manufacturer for cleaning products and use those products according to label directions, so you don’t end up with slippery buildup on the floor.

Shoes make a big difference in preventing slips, but that’s harder for you to control. While you can dictate what footwear is allowed in the production areas, you can’t tell customers to wear sensible shoes. That makes paying attention to your floors and parking lots and walkways, in winter and in summer, even more important.

Trips happen when feet encounter obstacles. Prevent them by getting rid of the obstacles. Reward good housekeeping practices and don’t allow bad ones. Hang up air hoses and extension cords when they aren’t in use. Route those so they don’t run over walkways. Have designated spots for all equipment. Give employees time to clean up their areas, so “I was too busy to clean” never becomes a valid excuse.

If housekeeping is a constant struggle, talk with your employees to find out why it’s a problem. Rearranging the work area might make a huge difference. An example: if all of air hoses are on the west wall, employees on the east side will need to run the hoses across walking paths. Running an airline to the east wall will cost you, but it’s less than the cost of an injury that sends an employee to the emergency room. 

Start mapping where people report tripping. Is there a threshold or a change in flooring that causes trips? If so, eliminate it if you can. If you can’t eliminate it, mark it to provide a highly visible reminder. Do floor drains or grates stick up, creating a tripping hazard? Or are they broken, creating uneven surfaces? Repair them. Is an area poorly lit? Add lights.

Look at where parts are stored. If you require employees to carry bulky parts up and down stairs, you’re asking for an accident. Stairs are required to have handrails, because those have been shown to help control balance and prevent falls. If an employee is carrying a bumper down stairs, how can that person hold the handrail? If you’re so space-limited that you need to store things on a mezzanine, look at alternative ways to get it up and down.

Whenever anyone reports a slip, trip, or fall, investigate. Do that for the near misses, too. Where was it? What happened? What caused the problem? Don’t dismiss it as “well, it’s snowy out” or “he was rushing.”  We can’t prevent snow, but why did this snowfall cause someone to slip? We can discourage rushing – but why did rushing cause the employee to trip this time but not last time?

Slips, trips and falls cost you money. They can injure employees and customers. We won’t claim you can prevent them completely, but you can’t prevent them at all if you don’t try.

This article originally appeared in AASP-MN News (September 2022).  It is intended to provide general information (no advice) about current safety topics.  To discuss  your specific safety concerns and how CHESS may help, please contact CHESS at 651-481-9787 or chess@chess-safety.com.

If you want your blood pressure raised, get inspected. It doesn’t matter if it’s from your county hazardous waste inspector, your fire marshal, OSHA, or (worst of all) the sales tax people. You might try to do everything right, but – well, sometimes you get lax. Sometimes you don’t pay close attention to what goes on out back. Sometimes you just have too much else to deal with. Or you’re so busy dealing with shop issues that you forget about front office issues.

What typically happens in a safety or environmental inspection? The inspector shows up, presents credentials, asks to see records, and then walks through the facility. You should go with that person. If the inspector points out a problem, fix it right away if you can. If you can’t do an immediate fix, take notes so you can get it fixed as soon as possible. The inspector leaves.

And then you get a notice in the mail or by email, telling you that you have to fix things – and that you have deadlines to meet, and need to notify the agency when they are fixed. Don’t ignore that paperwork.

If that paperwork ends up in the “round tuit” file, it will cost you.

Even if you made all the corrections, if you didn’t officially notify the agency of that, it will cost you.

It will cost you money and it will cost you time.

A company with operations similar to yours had a hazardous waste inspection. The inspector found solvent-contaminated rags in the trash. A drum of waste thinner wasn’t labeled as hazardous waste and its funnel was left open. They didn’t do weekly hazardous waste inspections. Solvent from a partswasher wasn’t reported on their annual report. Used oil containers were missing used oil labels. And they had no proof that employees had ever been told how to handle waste.

The company received a notice of violation from the county. They were required to make immediate fixes, and to provide the county with documentation that they had made the corrections. They made most of the fixes, but not all. And we think they didn’t tell the county about their actions.

The result: they are now facing misdemeanor criminal charges and are paying a lawyer to deal with a county attorney. And they’ve hired us to help ensure it doesn’t happen again.

This isn’t the first time we’ve been brought in after someone forgot to deal with the paperwork. The previous time was for an OSHA inspection. The corrections were made, but OSHA cited them for failure to abate because they didn’t report the fixes. Failure to abate penalties can be up to $7000 per day. That adds up quickly.

The people who inspect you don’t do it because they want the money. OSHA penalties don’t fund OSHA. Hazardous waste inspectors don’t get bonus pay for making you hire a lawyer. If you are cited, it creates more work for them. And because the citation indicates something was wrong, either unsafe for workers or bad for the environment, they want the problem corrected.

You don’t know if or when you’ll be inspected. You could get an OSHA inspection because of an employee complaint. It could be because you had an injury bad enough to require overnight hospitalization or loss of a finger (you know you need to report those to OSHA, right?). Or it could be a programmed or targeted inspection, one done because you’re in an industry with an above-average injury rate or with exposure to some particular hazard (such as isocyanates in paint). Hazardous waste inspections are usually routine, based on how large a generator you are.

You can save yourself a lot of headaches by having your paperwork in order before the inspector shows up. There are some records inspectors will always ask for. For hazardous waste, be able to show what hazardous and regulated waste you shipped out and where it went. Be prepared to show the OSHA inspector your safety training records and injury logs. Keep your records organized and know where they are. You don’t need an elaborate recordkeeping system; it can be as simple as a file folder for all hazardous waste records for each year. But don’t lose that folder in the black hole of your desk. Put it into a drawer and label the drawer, so you can find it when you need it.

After an inspection, watch for the follow-up paperwork or email. As soon as you receive it, read it. Take notes about what corrections you need to make. Highlight the deadlines – and mark them on your calendar so you don’t forget them. If you can’t meet the deadlines or don’t understand what you need to do, call or email the inspector (they aren’t ogres out to get you. If they know you are trying to do the right thing, they’ll usually try to be helpful). AASP-MN members can also call CHESS for a free but limited consultation, to help you understand the citation and your options.

Submit your responses to the inspector on time. If you can’t correct the problem in time, ask for an extension. Inspectors have some flexibility with deadlines as long as you are clearly working towards a resolution. But they don’t have flexibility once the deadlines have passed. Procrastination will be at your expense.

This article originally appeared in AASP-MN News (October 2022).  It is intended to provide general information (no advice) about current safety topics.  To discuss your specific concerns and how CHESS may help, please contact CHESS at 651-481-9787 or chess@chess-safety.com.

By Janet L. Keyes, CIH and Carol A. Keyes, CSP

Buffalo, New York, is no more tropical than St. Paul, Minnesota. It isn’t a place where you think people will die from heat. But a 35-year old man died from heat exposure just two years ago. He had just started a job as a laborer, working for a subcontractor installing guardrails on a state bridge. Because he was new at the job, his foreman gave him an easy job – sorting bolts and nuts into five-gallon buckets, then delivering them to the folks installing the guardrails. But it was hot, with temperatures reaching 95°F, relative humidity of 31%, little wind, and sunny.  And he was a diligent worker, not taking breaks and not taking the time to get the water he left in his car, at the other side of the bridge.

Didn’t he know better? Why did he allow himself to get into such a bad state?

That’s the scary part of heat stress and heat stroke – people don’t realize how dangerous a situation it is. Victims don’t know that they might be close to death. This man worked quietly alone, with no one paying attention to him – until he collapsed.

OSHA fined the company a paltry sum, $7,557.  More critically, the company began taking heat seriously. They trained their employees. They developed an acclimatization program.

Your employees don’t work outside. But are they in cars that have been sitting outside? Cars act like greenhouses. According to the National Weather Service, the temperature inside a car can go up by 40°F in only 60 minutes, with most of that rise in the first 30 minutes. If it’s 90°F outside, it could be over 130° in the car! Employees may not be in the vehicle for long, but doing that repeatedly can take its toll.

Is your shop air-conditioned? The offices probably are. Ironic, as people sitting at desks or standing at counters are less at risk of heat stress than a painter wearing a spray suit or a mechanic struggling to loosen a recalcitrant nut. They may not have the sun beating down on them, but they can still be exposed to too much heat.

Outside of the torrid weather, three factors led to the Buffalo man’s death. He was new to the job. He didn’t drink enough water. And no one – not the employee, not his coworkers, not his supervisor – paid attention to the distress he was feeling.

The circumstances aren’t uncommon.

Most heat-related fatalities occur when temperatures get into the 90s. And most occur in new workers, regardless of age. It takes time, about two weeks of gradually increasing exposure, to acclimate to heat. That isn’t just getting used to heat. Once people become acclimated, their bodies become better at cooling. They sweat more and begin sweating sooner, but don’t lose as much salt when they sweat. A new employee who dives into the job isn’t acclimated – that person cannot safely keep up with those who have adjusted to heat.

People won’t lose acclimatization if they take a weekend off. But if they spend two weeks in northern Canada when it’s hot here, they will lose much of their heat tolerance. They will regain it quicker, though.

Acclimatization allows workers to do their job normally when the weather is hot. But we have the challenge of sporadic hot days, so people don’t have much chance to acclimate.

It is logical, but wrong, to rely on thirst to know if you need to drink water. People who are dehydrated will be thirsty. But people who are dehydrated are at greater risk of heat illness. Waiting until people are thirsty (and already dehydrated) is a bad practice, because thirst isn’t a good indicator of the body’s need for water. On those hot days, encourage workers to drink. And make it easy to do so, by having water or sports drinks readily available. Freezer pops, especially those that have electrolytes, can help as well.

Water is so boring to drink, though! It’s still consistently been found to be one of the best choices for hot weather. Flavored sports drinks contain electrolytes, which can stimulate thirst and help keep the sodium balance in your body, and carbohydrates, which help your body take up sodium. But they may also contain a lot of sugar. And you’ll find electrolytes and carbohydrates in food. The Korey Stringer Institute, which focuses on athletes’ exposure to heat, recommends using water for exercise sessions of less than an hour and sports drinks for prolonged exertion.

Be alert for the signs of heat illness. Heat rash isn’t particularly bad – it’s just an itchy skin rash where the sweat can’t evaporate. Heat cramps, usually caused by too little salt, can cause muscle spasms and pain. If a worker tries to power through a heat cramp, muscle damage can develop. Better to take a break, massage the muscle, and replace those electrolytes. Much more serious: heat exhaustion, characterized by heavy sweating, headaches, nausea, and dizziness. If any workers are experiencing that, get them to a cool area to rest and get them to drink water or, better yet, electrolyte replacement drinks. Monitor their condition, in case it turns into the most dangerous heat illness, heat stroke.

Heat stroke kills. Someone suffering from heat stroke is no longer able to cool down. Their body temperature is going up. They may be acting strangely. Their skin will be hot and flushed. This is a medical emergency – they need to be cooled immediately and you need to call 911. The scariest part about heat stroke is that people suffering from it may not realize they are in danger.

On those hot days, monitor your workers’ condition and encourage coworkers to keep an eye on each other. Allow more breaks. Set up cooling fans. Provide cool beverages and encourage employees to drink. And if anyone is showing signs of heat stress, take action right away, before it becomes serious. Time in an air-conditioned room, drinking water, and using cold compresses will usually be enough to resolve heat illness.

This article originally appeared in AASP-MN News (July 2022).  It is intended to provide general information (no advice) about current safety topics. To discuss your specific concerns and how CHESS may help, please contact CHESS at 651-481-9787 or chess@chess-safety.com.