OFFICIAL PUBLICATION OF THE NEW CAR DEALERS OF SAN DIEGO

Pub. 12 2023-2024 Issue 1

EPA, OSHA and Worker’s Comp Compliance Seminar Recap

In late September, the NCDA hosted a Celly Services seminar to provide dealer members with valuable training about EPA, OSHA and Worker’s Comp Compliance requirements. Attended by general managers, fixed ops managers and service directors, topics covered in this informative and interactive seminar included:

  • In-person Training vs. Hands-on Training: This included forklift training (theoretical and practical), lockout/tagout and respiratory protection.
  • SB 158 and Hazardous Waste: Covered Hazardous Waste Cost Recovery per SB 158 (CA Generation and Handling Fee).
  • Cost Recovery for Hazardous Waste Expenses: The BAR says you can’t make a profit, we discussed how a hazardous waste fee should be calculated and placed on your RO and invoice.
  • Cal OSHA Injury Log: Discussions on understanding recordable vs. reportable incidents, the three forms you need to complete, and when and how long to maintain records.
  • OSHA Inspection: Covered what triggers an OSHA inspection and how to minimize the scope of an OSHA inspection, as well as citations and the appeals process.
  • Worker’s Comp Rate: Including how it is calculated and why high ex-mod can hurt you. And fighting the three F’s — frivolous, fraudulent and fictitious claims.
  • Foot Protection Requirements: Reviewed protections required from electrical hazards, falling objects, crushing or penetrating actions and abnormally wet conditions (ASTM F 2412-05 and F 2413-05). Shoe policy and enforcement, and who pays?
  • Eye Injury Prevention Requirements: Discussed when eye protection is required, what types are there, if eyeglasses count and what employees who wear glasses can do.
  • Certified Unified Program Agency (CUPA): Covered the most common violations related to annual CUPA inspections.
  • First Aid Kits: This included discussions on the ANSI updated list of minimum requirements for Class A and Class B kits, new items required, how many are necessary and how to store them.
  • Refrigerant Recycling: Discussed which employees need section 609 certification, records keeping, as well as EPA auditing and penalties.
  • Electronic Verification Questionnaire: Reviewed the importance of annual submittal to prevent deactivation of EPA ID numbers.
  • Injury and Illness Prevention Program (IIPP): Reviewed the eight elements of the written IIPP, which is required for any company that has 10 or more employees
  • Hazard Communication Program (HCP): Reviewed the five basic elements of the HCP, which is required for employers whose employees work with hazardous chemicals.
  • Heat Illness Prevention Program (HIPP): Reviewed the HIPP that is required for employers whose employees work in a hot environment.
  • Personal Protective Equipment (PPE): Reviewed the PPE, when it’s required, who should wear it, who should pay for it and how it should be stored.
  • Emergency Response Plan: Reviewed emergency response plans that are required for any company that has 10 or more employees.