BY LAUREN BAILEY VP OF STATE LEGAL & REGULATORY AFFAIRS, COMPLYAUTO Creating a safe workplace isn’t just a good idea to keep your employees safe, it’s the law. Under OSHA’s regulations, dealerships are required to supply personal protective equipment (PPE) to their employees. However, simply making it available on an ad hoc basis is not enough; you are required to take a systematic, documented approach to identifying hazards and deciding whether PPE is necessary for each job. That process, called a PPE hazard assessment, is mandatory under the law. If your dealership hasn’t completed and certified such an assessment, you are not only putting your employees at risk, but you’re also out of compliance and at risk of fines of up to $16,550 per violation. WHAT THE LAW REQUIRES Under OSHA’s General Industry Standard, 29 CFR §1910.132(d), all employers, including dealerships, must evaluate their workplaces to determine whether hazards that require PPE are present or likely to be present. If such hazards exist, the employer must: • Identify and select the PPE that will protect employees. • Ensure each employee is properly fitted with the selected PPE. • Communicate those PPE requirements to affected employees. • Train employees on how to use and maintain the equipment. Most critically, the employer must also certify in writing that the hazard assessment was performed. This certification must include: • The name of the person who conducted the assessment. • The date of the assessment. • Identification of the work areas evaluated. • A clear statement that the assessment was completed. Without this certification, your PPE program is incomplete, and your business will be at risk during an OSHA inspection. Are You in Compliance with OSHA’s PPE Hazard Assessment Requirement? WHY DEALERSHIPS ARE AFFECTED Potential hazards are common in dealership operations. Technicians may face risks from moving parts, compressed air, sharp edges or chemical exposure. Staff in the Parts Department may be exposed to lifting injuries or impact hazards. Detailers regularly handle cleaning agents or work on slippery surfaces. The purpose of a hazard assessment is to identify these risks by job role and location and determine what protections, if any, are required. It is not enough to assume that safety glasses or gloves are appropriate; the selection must be based on a careful and documented evaluation of the specific hazards encountered. WHO SHOULD PERFORM THE ASSESSMENT? Hazard assessments should be conducted by someone with thorough knowledge of the facility and its operations. This person must understand how to evaluate exposures across multiple risk categories, including eye, face, hand, foot, hearing and respiratory hazards. For larger or more complex dealerships, especially those with collision repair centers or reconditioning operations, THE GENERATOR 24
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