Pub. 2 2013 Issue 1

Summer 2013 27 Stationary bulk containers at the dealership that are refilled by vendors on site will require new labeling. Some tanks/drums that will require new labeling are as follows: • Gasoline/Diesel tanks or dispensers • New Oil/ATF tanks • Paint Gun Cleaner Drums in Body Shop • Detail Chemical Drums Safety Data Sheet: The GHS program calls for all MSDS in effect now to be changed to the new SDS under a new format. The SDS will list hazards in addition to the ones on the MSDS in areas as follows: • Environmental Hazards (EPA guided) • Ecological Information • Disposal Consideration (EPA guided) • Transport Information (DOT guided) OSHAwebsite clearly acknowledges that it has no authority in the area of environmental, disposal, or transport elements and as such no citations will be forthcoming from OSHA regarding compliance activity in these areas which are newly listed on the SDS. Action Plan/Monthly Mailer: A training memo on GHS and a pictogram being sent to your dealership by mail must be used to train employees on new labeling signs. The colored GHS sheet may be posted on the technician notice board after the training has been completed. As always, keep documentation of the training completed including the name and signature of the employees in attendance. A training video covering the changes under the GHS is in theworks andwill be distributed to dealers in a timely manner. As always, your comments are welcome. Please send us an email to sam@ cellyservices.com. Poster: Aquick cardpictogramfromtheOSHAwebsite canbe downloadedas well. https://www.osha.gov/Publications/OSHA3491QuickCardPictogram.pdf https://www.osha.gov/dsg/hazcom/pictograms/ Sam has been helping automobile dealers comply with EPA & OSHA regulations in California, Nevada, Arizona, Hawaii & New York since 1987. Sam received his MS (1986) in Chemical Engineering from School of Mines & Technology followed by a JD (1997) from Southwestern University. Sam is a Certified Safety Professional. Send your comments/questions to sam@ cellyservices.com. Authority Cited: Title 29CFR 1900.1200 Reach your target audience a ordably. advertise get results DANI GORDEN Advertising Sales 855.747.4003 dani@thenewslinkgroup.com