REMINDER

OSHA’s New Haz Com Standard Takes Effect June 1, 2015

David Kendziorski

MICAR Program Manager

 In 2012, OSHA revised the Hazard Communication standard, also known as the “Right-to-Know” Law. Some training needed to be conducted by December 2013, and most of the requirements must be implemented by June 1, 2015.

Auto recyclers are required to meet the following requirements:

  1. Written HazCom Plan. Plan must also include a hazardous material inventory. See the HazCom section in your new ARM Safety Compliance Manual. There is a sample plan, and a simple “fill-in-the-blank” plan to help you.
  2. New GHS Labels and Pictograms. Place on all containers of hazardous materials (vehicle and equipment fluids, cleaners and solvents, batteries, mercury switches). You can now purchase the labels and pictograms online at Seton.com, Grainger.com, Accuform.com, and even Amazon.com. You can also download the labels and pictograms on osha.gov for free. These are new Federal labeling requirements. Note that you must still continue to use other labels required by DEQ or your fire department: name of content (used oil), waste category (Universal Waste or Hazardous Waste), and National Fire Protection Association – NFPA- diamonds and HMIS-style labels.
  3. Safety Data Sheets. The new format Safety Data Sheets (SDS) replace the old Material Safety Data Sheets (MSDS). Obtain SDS from manufacturers, distributors, suppliers, or online (just Google product name, SDS). Despite the June 1 deadline, many SDS are not yet available from the manufacturers. So replace your current MSDS with the new SDS as they become available. Place the SDS in a 3-ring binder, in alphabetical order. Add a Table of Contents.

Annual Training. Excellent online HazCom training is available for free through ARA University. Sign up through the ARM office.

 

ARM Members Jump on the Safety Bandwagon!

About 90% of ARM members have requested and received the new Safety Compliance Manual, and nearly half of the members have already signed up for the free ARA University online safety training courses. Way to go, ARM members! Let’s keep our employees safe! Contact the ARM office to obtain your Manual or sign up for the training.


IMPORTANT INDUSTRY CORRESPONDENCE REGARDING MOTOR VEHICLE SAFETY RECALLS


IMPORTANT INDUSTRY CORRESPONDENCE REGARDING MOTOR VEHICLE SAFETY RECALLS

From the Automotive Recyclers Association (ARA)

July 10, 2015

Regrettably, the number of defective automotive parts in today’s marketplace is increasing at alarming rates, as indicated by the over 100 million vehicles recalled since the beginning of 2014 in the United States alone. ARA understands that these recall campaigns create multiple challenges for our members – professional automotive recyclers who provide safe and quality OEM recycled automotive parts to the marketplace – and we are writing today to let you know how your association has and will continue to aggressively work to help protect and promote your inventory of safe and quality OEM recycled parts in this era of continuous automotive safety recalls.

Please know that this email will be one of several that ARA will share with you in the coming months to keep you informed of the latest actions that your association has taken to address the implications that recalls have on the automotive parts supply chain, and also in the context of the three major laws passed providing for the federal regulation of the recall process (see side text box).

First and foremost, to minimize the effects of safety recalls on the automotive parts supply chain, your inventories, and the consumers who rely on recycled OEM parts, ARA is aggressively promoting the need for access to bulk VIN recall data and parts data so that you are able to identify in a streamlined, integrated and efficient manner those OEM parts which have been recalled.

ARA has also taken steps forward to ensure that auto manufacturers adhere to the law as written and provide ARA members with fair market value for recalled parts that recyclers must remove from their inventory. High level meetings with Congress and the automakers are ongoing to consider how best to address the fair market value of those parts that ARA members have and continue to take out of the market.

Furthermore, ongoing conversations with the National Highway Traffic Safety Administration (NHTSA) – the federal agency established by the U.S. Department of Transportation to carry out vehicle and consumer safety programs – and consumer groups are occurring during which ARA has emphasized the industry’s need to be able to integrate bulk VIN data into inventory management systems so that those VINS/parts that have been recalled can be flagged throughout the automotive recycling process to avoid possible market penetration.

The Association also is working to educate federal officials and industry stakeholders about the need for access to parts data, as noted below.

  • In response to a question asked on behalf of ARA by a Member of Congress, U.S. Department of Transportation Secretary Anthony Foxx recently stated for the record that automakers should provide “parts numbers related to recalls” in an “efficient and easy to use format directly to recyclers and others who need this information.”
  • In December 2014 and June 2015, again on behalf of ARA a Member of Congress asked automakers as well as organizations representing domestic and foreign auto manufacturers why professional automotive recyclers do not have access to the automakers parts data. We are awaiting the answers to those questions that will be entered into the official hearing record.
  • During a May 2015 NHTSA Recall Workshop, ARA argued the case and a consensus of participants agreed with the position that stakeholders should have access to both bulk VIN data and parts data.

ARA’s demands for automotive recyclers’ access to bulk VINs and OEM parts data are unrelenting and continuous. ARA is proud to continue to lead the charge to meet these demands so that the automotive parts supply chain is streamlined, quality driven and protects the safety of the nation’s drivers.

 


October 27, 2015 in Lansing.  Don’t miss your chance to be heard!!  


Be sure to register for the 15th Annual Automotive Recyclers of Michigan & Friends Golf Outing at the Links of Novi by June 1, 2015.   Proceeds benefit the Kent Utter Jr. Memorial Scholarship Fund & ARM.

Click on EVENTS and GOLF OUTING for the registration form.

 

 


Friday, October 21, 2016 at the Gilmore Car Museum, Hickory Corners, MI. 

Explore the Past As We Plan for the Future!

You’ll want to be sure to join us for this year’s Annual Meeting at the Gilmore Car Museum in Hickory Corners. Consistently rated as one of the top 3 car museums in the country, the Gilmore has something for everyone. It sits on over 90 acres with over 400 extraordinary vehicles that date from the birth of the automobile to the present day, including Fords, Cadillacs, Duesenbergs, Packards, muscle cars, motorcycles, and a Tucker. You won’t want to miss meeting their makers, the villains and scoundrels, the geniuses and innovators who gave our world its wheels. From pedal cars to a research library, to a stunning exhibit of hood ornaments and a museum store, to an old-fashioned gas station and a vintage diner, you won’t want to miss this!

Be sure to bring your classic car and join us for a tailgate-like meal and drinks on October 21, 2016 for Annual Meeting, Election of officers, team building, and a ride in a Model T, all while exploring this one-of-a-kind treasure right here in Michigan!

2016 ARM Annual Meeting

 


All ARM Members-Be sure to get your free ARM Safety Manual if you haven’t already received it and make sure you get your registration information for ARA University into the ARM office as soon as possible. Don’t miss this opportunity to protect the health and safety of your employees and help your facility comply with many of the MIOSHA regulations affecting auto recyclers. If you have any questions please contact us at 810-695-6760 or arm@mi.automotiverecyclers.org.

 

 


Join us at the 6th Annual Road Show and Business Networking Conference for the launch of ARM’s New Safety Program.

OSHA requires that employee safety training be comprehensive and documented.

The New Safety program will provide the necessary education, training, technical assistance, and recordkeeping guideance to help members comply with regulations.

Each company attending the Safety Program Workshop at the Road Show will receive a Safety Compliance Manual that will include forms, sample reports, prototypes, and fill-in-the-blank documents that you will need to comply with MI OSHA safety regulations.

Workshop is available to ARM Members ONLY!

 

 

 

 


OSHA requires that employers who have more than 10 employees must post their facility’s injury and illness log (FORM 300) of the year prior by February 1st. Employers are required to maintain records relating to employee injuries and illness throughout the year. Although the records are generally not filed with OSHA, they must be maintained at the worksite for a five-year period and made available to employees and OSHA inspectors.

The information contained in the 300 form includes a record of each illness or injury, a summary of the prior year’s experience, and a recap that must be posted in the workplace from February 1 through April 30 each year. While the use of Form 300 is not mandatory, posting the information contained in the form is. Posting the information contained in the 300 logs is necessary even if there were no emplyee injuries or illnesses within the last year.